Agencies | Governor
Virginia Regulatory Town Hall
Department of Housing and Community Development
Board of Housing and Community Development
Virginia Uniform Statewide Building Code [13 VAC 5 ‑ 63]
Action Update the Uniform Statewide Building Code
Stage Proposed
Comment Period Ends 6/26/2020
Next Comment     Back to List of Comments
2/27/20  9:15 pm
Commenter: Andrew Grigsby

It's time to bring Virginia into compliance with the 2012 IECC efficiency standards

My comments refer to the energy efficiency standards of the USBC. I urge the Board to adopt the 2018 International Energy Conservation Code (IECC) wholesale, without alteration. The Virginia amendments that weaken our residential energy code relative to the IECC increase the total cost of housing (when considering mortgage payments plus energy costs) and should be abandoned.


The current draft update to the USBC fails to bring Virginia into compliance with key provisions of the 2012 IECC. Virginians still are not enjoying the cost savings, improved comfort, resiliency benefits, and improved indoor air quality that the IECC adopted 9 years ago. The deficiencies compared to the 2012 IECC that persist in the current draft 2018 USBC include

  • Whole-building air leakage limit: in 2012, the IECC adopted 3ACH. Virginia adopted 5ACH and remains there now. (I applaud the inclusion of mandatory mechanical testing of air leakage that is included in this draft. The 5ACH standard in place the last few years has been unenforceable without a mechanical test.)
  • Duct leakage threshold: the IECC adopted 4% in 2012. Virginia adopted 6% and remains there now.
  • Exterior wall insulation: in 2012, the IECC standard increased from R13 to R20/13+5 (cavity/cavity+continuous). Virginia went to R5/13+1 in 2012 and remains there now.
  • Attic insulation: the IECC adopted R49 as the cost-effective standard for this climate zone in 2012. Virginia remains at R38.


In 2012, the US Dept. of Energy calculated that, compared with the 2009 Virginia USBC, “life-cycle cost savings, averaged across building types, are $5,836 for the 2012 IECC,” and that the “simple payback period is 5.2 years for the 2012 IECC,” with positive cash-flow in year 1 of homeownership (see The 2015 IECC update included very modest changes that, compared to the 2012 IECC, obtained $101 in life-cycle cost savings with simple payback in less than 1 year in Virginia’s climate zone (see


Virginia’s residential energy code has been improved since 2009, but critical elements still are left out. The simplest thing is to use the unadulterated IECC. This has the added benefit of providing uniformity across state lines, which obtains further process efficiency for many builders.


Rigorous energy codes are a win for

  • energy resource planning (costs, grid stability, predictability)
  • environmental policy (climate change, resource use)
  • the construction industry (increase value and quality of their product, more jobs)
  • the mortgage industry (32% less risk of default: see the IMT/UNC report at
  • local jobs (framing and insulating don’t happen overseas, testing is new work, quality takes time)
  • housing affordability (increases predictability of monthly costs and lowers total cost of housing)
  • home buyers/renters of all kinds (comfort, savings, predictability, indoor air quality)

Besides, people want it. A 2013 survey by the National Association of Homebuilders reports that 9 out of 10 homebuyers are willing to pay 2-3% more for a home that includes permanent energy efficiency features.


In 2020, we should not be building new homes that will need major retrofitting to comport with the clean energy goals, social cost of carbon, focus on resiliency, etc. that are now driving Virginia policy and regulation. The cheapest time to make a building energy efficient is during construction or major renovation. That is how to provide the maximum comfort and cost benefits to Virginia residents. In 2020, Virginia should, at the very least, bring our residential energy code into compliance with provisions of the IECC that have been in effect since 2012. This is the true path to affordable housing: reducing the total cost of homeownership.


As the 2018 code update cycle is completed this year, I urge the Board of Housing and Community Development to adopt proposals that bring Virginia into full compliance with the current IECC.

CommentID: 79342