| Action | Update the Uniform Statewide Building Code |
| Stage | Proposed |
| Comment Period | Ended on 6/26/2020 |
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47 comments
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
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 www.energycodes.gov/sites/default/files/documents/VirginiaResidentialCostEffectiveness.pdf). 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 www.energycodes.gov/sites/default/files/documents/VirginiaResidentialCostEffectiveness_2015.pdf).
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
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.
My previous earlier comment included an inaccurate statement. Virginia already has a 4% leakage threshold for residential duct systems - which aligns with the current IECC - not 6% as I stated earlier.
I purchased a home in Richmond, Virginia that was built in 1938. The home had NO insulation in the walls, floor, or perimeter of the foundation. Single pane windows with leaky sash tracks were the standard. The ceiling had just 4" of rock wool. In the wintertime, you could feel the cold air blow across your feet as the air changed regularly in the home. This was the standard for 1938.
There is no reason not to follow the Virginia Law mandated IECC national standard when it comes to reviewing code changes in Virginia.
The cost of purchasing an energy-efficient home is quickly offset by the savings in monthly utility bills. The comfort of the home is why we have homes, to begin with. Quality of installation, materials, and practices can help save energy over the life of the mortgage AND the life of the home, adding real value to the homeowner who can boast to the energy efficiency to the next purchaser.
A builder's job is to build a quality home. A good builder's job is to build a quality, energy-efficient home, built to the best science, common sense, and reasonable cost. This good builder can market efficiency as a bonus, not as an added cost. The bust builder would build an energy-efficient home he/she would be proud to live in, and in fact, does live in.
You have a chance here to correct the code to bring affordable living to more people, by not just considering what a home costs to build, but what it costs to own and operate. Lower utility bills mean more money for the homeowner to participate in a wider economy.
Virginia building codes should not remain outdated and inefficient. Do not continue old policies that cut corners and ignore best practices that reduce costs to Virginians and to the environment. The most up-to-date versions of International Energy Conservation Code (IECC) should be adopted, or even more ambitious building codes.
My family has to pay for the energy we use. The buildings of today will stick around for a long time and place an undue burden on families, especially low-income families, who already share a disproportionate energy cost burden in Virginia. Update the building codes to be leading, protect our environment, and not fall behind.
There is a lot at stake beyond a monthly bill for an average family. As Virginia is decades behind on clean energy, energy efficiency, and climate action, there is no time to wait to adopt new policies that change the way we do business. Energy efficiency is a commitment to our own collective future.
As an Environmental Studies student at the University of Richmond with a focus on sustainability and equitable climate action, I support the implementation of IECC and even more ambitious standards such as Earth Craft or Passive House standards.
A stronger building energy efficiency code will save residents money and save the climate.
Please adopt the most recent IECC building energy efficiency code for Virginia housing and other buildings.
Sincerely,
William Driscoll
Arlington, VA
Virginia should, at the very least, require adherence to the most recent IECC standards. The environmental and long-term financial implications require it.
Houses built to the highest efficiency standards save far more money on energy over time than they add to the upfront cost of the house. Our environment cannot wait for efficiency standards to raise.
To whom it may concern,
Each time I see a house being torn down and a new inefficient house being built in my neighborhood, I ask myself the question:
Why is Fairfax County allowing houses be built that are not only expensive to heat and cool but definitely not addressing health, safety, energy and water conservation necessary to "build" a better world. These houses are not in line with the IECC. Building energy efficient houses are absolutely necessary in order to ensure that future generations have a high standard of living instead of a world that will be uninhabitable. We should be leading the way in adopting energy efficient housing. It is unacceptable that a highly educated, wealthy county such as Fairfax would be so out of touch with the realities of the demise of our planet because people are putting profit ahead of the health and well being of our environment. Future generations will curse you if you do not "get with the program" and start taking the environmental crisis seriously.
Please stop allowing builders to tear down the trees. Trees are one of the best ways to fight pollution. Some countries are planting trees to stop pollution.
Best
Jennifer Bears
Thank you for providing this opportunity to comment on this important issue.
The Board should adopt the energy-saving provisions of the latest International Energy Conservation Code (IECC). The Board’s current proposal ignores the critical need for all sectors to become more energy efficient to avert the direst consequences of climate change. Furthermore, the Board’s proposal is inconsistent with Virginia law, which requires the Board to adopt provisions that permit buildings to be constructed at least possible cost “consistent with recognized standards of health, safety, energy conservation and water conservation.” Virginia code suggests that building regulations may go beyond the IECC for purposes of health and safety, but should not fall short of its standards, as the Board is now proposing to do.
Although requiring energy efficiency may increase builders’ up-front investment costs (at least for now), research has demonstrated that buildings constructed to the highest efficiency standards save more money on energy over time than they add to the upfront cost. This is true even if we don’t take important externalities into account, such as the long-term cost to the environment of continuing to allow energy-inefficient building practices.
The climate crisis creates an imperative that we use building codes to reduce our consumption of fossil fuels. Ralph Northam recently made it clear in Executive Order 43 that Virginia is committed to a path of clean energy and energy efficiency. Buildings represent an enormous portion of all energy use and are a major contributor to climate change. Requiring builders to build homes that produce their own energy is a key part of any plan to address the climate crisis.
Thank you for considering my comments.
Please consider strengthening the Virginia building code by including applicable higher energy and air quality standards that may be found in the International Energy Conservation Code. The USBC does not adequately address some of the low cost measures in the IECC that would help with energy conservation, greenhouse gas emissions and long term energy cost savings for homeowners.
A simple truth: the Commonwealth of Virginia (its businesses, its citizens, its built environment, …) is an energy hog with mediocre (perhaps even dismal) energy efficiency.
Simple truths behind those numbers are one of the reasons why legislators made sure to include substantial energy-efficiency measures in the Clean Economy Act (VCEA). While the VCEA sets a better path forward, it isn’t comprehensive across all the economy and its measures don’t relieve other parties’ responsibilities for acting responsibly in the interest of the Commonwealth and its Citizens.
So much that matters in our lives is shaped out of sight, out of mind for most of us. When boarding a plane, we assume that the plane’s design has been improved and there are inspectors out there making sure it’s safe to fly. The same is true with so much throughout our lives — from washing machines to automobiles to elevators to … Well-managed standards and regulations are critical to our ability to function in the complex reality of modern society.
This is certainly true when it comes to buildings — standards and regulations lay a minimum basis for what will be around for decades to come. From structural soundness to fire safety to electrical wiring to energy efficiency, quality building codes are key to a quality built environment. And, as per energy efficiency, since buildings account for roughly 40% of energy use and the buildings will last for decades — poor energy efficiency codes translates to decades of wasteful energy use with higher bills and higher pollution loads.
One reason for Virginia’s poor energy efficiency rankings: a long history of lagging behind the curve when it comes to International Energy Conservation Code (IECC). Currently, Virginia’s code is based on the 2015 IECC (not the 2018) with critical portions of Virginia code dating back to the 2012 code and even the 2009 code. A decade is, in today’s world, an eternity when it comes to energy efficiency and technologies. Just a few examples for an understanding:
The idea of having a building code in the 2020s based on over 10-year-old technologies and processes is ludicrous.
It appears that DHCD might, rather than simply upgrading to the latest IECC (2018), will simply continue many of the outdated elements of the existing code. (For a useful overlapping/reinforcing perspective, see Ivy Main’s eloquent discussion.) Among those is to keep Virginia on the 2009 insulation standard rather than moving up something closer to present day standards. Regretfully, there are special interests (e.g., builders) who are perfectly willing to lower their costs for higher profits while delivering a lower-quality and higher-cost product to people for decades to come. The DHCD, it seems from the bleachers, has given builders and contractors a leading voice (role might not be too strong a word) in structuring Virginia’s building code. The DHCD’s approach to the IECC appears to be ‘explain why we should upgrade’ rather than ‘make the case why we shouldn’t’. This facilitates putting energy efficiency on the back burner. Quite simply: this is unacceptable.
This isn’t ‘just about climate’ but quite clearly about acting in the best interests of Virginia’s citizens and communities. For example, as Andrew Grigsby thoughtfully makes clear in his comment, advancing to current insulation standards has a rapid (perhaps 5 years) payback and would save an average home owner more than $5000. Energy efficiency investments are ‘no brainers‘ that, sadly, few home purchasers really have a say about: it’s all about the code.
With that in mind, some thoughts for DHCD:
In summary, DHCD should recognize that aggressive energy efficiency measures are in the public interest (from improved energy resiliency to reduced energy costs to reduced climate impacts) and that the legislature and the Governor have made clear that energy efficiency and climate mitigation are important for the Commonwealth. By adopting the 2018 building code and not keeping insulation at 2009 standards, the DHCD could demonstrate that recognition.
Members
Board of Housing and Community Development
Public Meeting June 26, 2020
Commonwealth of Virginia
Dear Members of the Board:
I am communicating to ask each member to personally give attention this year to the current status of the residential energy requirements in Virginia’s Uniform Statewide Building Code (USBC). The consequences of its current weakening amendments to the energy-conserving model developed by the International Code Council (ICC) is an emerging social justice issue. Additional delays will serve to inflate the inequity. Please prepare to adopt all of the cost-effective energy efficiency and conservations provisions into the USBC free of the current array of weakening amendments.
In the meantime, your approval to remove the visible inspection alternative to the blower door test is a significant development and much appreciated. Two substantial shortfalls remain, wall and attic insulation levels, as well as other weakening provisions. Given the multitude of challenges we face in moving towards a low to zero carbon future, Virginia should be promoting one of the easiest paths to reach its goal of a low carbon energy future by accelerating our transition to net zero and net zero-ready construction and major renovation. Stronger efficiency measures will bring many improvements to houses and protect the communities where they are built. All Virginians deserve this protection.
Let me briefly describe the civil equity issue I see emerging from Virginia’s deferring full adoption of the ICC model. The failure to fully adopt the model, unamended, increases the financial burden of vulnerable low- and moderate-income Virginians who are disproportionately people of color. Builders often incorporate upper scale features including higher than code energy efficiency measures as part of a premium upgrade or through a builder’s participation in a green program such as Energy Star or Earth Craft House. Basic low-cost, new construction built to but meet the code’s outdated energy efficiency requirements yields a shortened life cycle for the structure, thus weakening its long-term market value. When such a house is planned and built today using criteria that has been out of date for close to a decade, the house is planned and built to become obsolete prematurely. The inequity issue becomes more evident when houses with built-in energy obsolescence are marketed and sold to entry-level, first-time buyers and the elderly. These demographic groups are disproportionately low-income, fixed-income and people of color. These Virginians are more often to be financially less able to weather economic downturns, and their capacity to meet their future mortgage, maintenance and utility obligations is compromised by the inherently higher costs for heating and cooling less-efficient dwellings. The structure’s obsolete energy and conservation design accelerates the relative decline in value, potentially harmful for owners, tenants, their communities, as well as Virginia and our nation. As the electric and natural gas utilities enjoy the sovereign power of eminent domain, the higher utility costs enabled by the code’s short-comings should be likened to a private tax imposed by for-profit businesses.
Such harm presents as structural racial bias in home ownership prospects. It is easily and cost effectively avoidable. Please consider how the Board may actively address this emerging injustice.
Sincerely,
Ross Shearer
Vienna, VA
Virginia ranks very low out of the US States as far as energy efficiency. That hurts us in all kinds of ways. It means people are paying higher utility bills, in particular those that can't afford it. It means that we need more fossil fuels because we need more energy than the renewables we have. That means that we need fossil fuel infrastructure like compressor stations that tend to be sited in minority neighborhoods and thus adversely and dis-proportionately affect the health of minority residents. It also means that we are not succeeding in the fight against climate change, which means that low-lying areas like Hampton Roads are at more risk.
Buildings are a huge fraction of the state energy use. Please help Virginia cut that energy use and related carbon emission by updating the building codes to more efficient international standards that look toward the future.
This document has a collection of articles about how much renewable energy and energy efficiency can help us go carbon-free.
https://docs.google.com/document/d/1LjtamziqYH24JAZ4Y8RIDU0P7yr7UHP97FhxFfe_AZs/edit?usp=sharing
This site has information about the harm the pipelines do, and why we need energy efficiency to reduce our relaince on fracked gas pipelines.
Let's pick that fruit already. Let's move Virginia from lagging to leading.
Improving Virginia energy efficiency building code, both for Residential and Commercial buildings is a HIGH priority. Reducing carbon emissions, improving energy conservation, why is this even a question?
Our building energy efficiency codes are far behind most in the 1st world, and are one reason our building energy costs and carbon emissions are so high. Additionally, greatly improving our building energy efficiency building codes will make achieving our renewable energy targets far less expensive, so improving the code will be a win-win-win.
Virginia has not met the International Energy Conservation Code (IECC) since at least 2012. It is time to amend the Uniform Statewide Building Code (USBC) to meet the 2018 IECC energy conservation standards for all construction covered by the Virginia. Given that nationally, buildings represent 70% of electricity consumption, energy efficiency is one of the best and easiest ways to reduce electrical consumption and carbon emissions. In 2020, Virginia passed the Virginia Clean Economy Act - a landmark statue that calls for dramatic carbon reduction in light of the threat of climate change and the negative health, economic and environmental impacts it will bring across the Commonwealth. Bringing building codes up to energy efficiency standards laid out by the IECC will help us achieve those carbon reduction goals and create a clean energy economy. Furthermore, energy efficient buildings reduce utility bills of customers. Finally, Virginia law requires that the USBC protect the "health, safety and welfare of residents in the Commonwealth" and be be "consistent with recognized standards of health, safety, energy conservation and water conservation..." Minimizing costs to home builders must not take precedence over health and welfare of residences OR consistency with internationally recognized standards such as the IECC designed to do just that.
I urge the Virginia Board of Housing and Community Development to amend the Uniform Statewide Building Code to meet or exceed the 2018 International Energy Conservation Code (IECC) for all forms of construction covered by Virginia's Uniform Statewide Building Code. Energy Efficiency (met by conservation, reduction in use/demand of energy with supporting building codes, etc.) is a low hanging fruit to pick for reducing energy demand and use, and a long lasting way to reduce green house gas emissions in the state. It also provides a healthier living and working environment for our residents, which turns into lower health costs, and much higher productivity for our employed citizens. I have worked on numerous energy efficiency projects with energy companies who increase the energy efficiency for institutions of higher education, municipalities, states, commercial entities and residences. There are a set of codes, and a path to providing energy efficiency be it in our utilities, in our government buildings and in our ways of life at work and at home. It is a win win situation for all of us. We create jobs by increasing efficiency in new construction, and retrofitting older built environments. We employ energy efficient products (lighting, appliances, building materials and practices) all of which exist. There are no barriers to employing new energy conservation building codes than to simply adopt them. No one loses in this. Reducing the 60% (recently quoted by our VA legislators) consumption of energy that our built environments use in VA by energy efficiency measures supports the goals of the VCEA, and does not costs tax payers money that they won't recoup. There are clear pathways to do this achieved in other states. What is VA waiting for? Please make these important changes now. Thank you.
The Board should update the Uniform Statewide Building Code to meet or exceed 2018 IEEC standards for all forms of covered construction. Virginia's recent adoption of VCEA demonstrates its commitment to allowing citizens to benefit from technology advances and lower utility bills resulting from energy efficiency. Now, the Board has the opportunity to align energy efficiency in building construction to help achieve VCEA's promise and directly impact consumer's individual control of their utility bills and carbon reduction. Virginia's continued economic prosperity depends on allowing consumers to benefit from advanced technologies and materials designed to meet updated IEEC standards.
Virginia has not met the International Energy Conservation Code (IECC) since at least 2012. It is time to amend the Uniform Statewide Building Code (USBC) to meet the 2018 IECC energy conservation standards for all construction covered by the Virginia Code. Given that nationally, buildings represent 70% of electricity consumption, energy efficiency is one of the best and easiest ways to reduce electrical consumption and carbon emissions. In 2020, Virginia passed the Virginia Clean Economy Act - a landmark statue that calls for dramatic carbon reduction in light of the threat of climate change and the negative health, economic and environmental impacts it will bring across the Commonwealth. Bringing building codes up to energy efficiency standards laid out by the IECC will help us achieve those carbon reduction goals and create a clean energy economy. Furthermore, energy efficient buildings reduce utility bills of customers. Finally, Virginia law requires that the USBC protect the "health, safety and welfare of residents in the Commonwealth" and be be "consistent with recognized standards of health, safety, energy conservation and water conservation..." Minimizing costs to home builders must not take precedence over health and welfare of residences OR consistency with internationally recognized standards such as the IECC designed to do just that.
The changes to Section 115.2 to remove the “Responsible Party” are on dangerous legal ground.
First, one must recognize that according to Section 115.1, violation of the Building Code is a criminal offense (non-classed misdemeanor). “In accordance with § 36-106 of the Code of Virginia, it shall be unlawful for any owner or any other person, firm or corporation, on or after the effective date of any code provisions, to violate any such provisions.” Further, the Code intentionally employs language specifying that it is unlawful for “any person, firm or corporation to violate the code.” This purpose of this language to eliminate the possibility of a loophole for that would otherwise allow for work without a permit or work performed by contractors without a license where the code official would only have the option to charge the property owner with a criminal act.
Second, this change ignores the requirements set forth in 112.1 which states in relevant part: “It shall be the duty of any person performing work covered by this code to comply with all applicable provisions of this code and to perform and complete such work so as to secure the results intended by the USBC.” This language places a legal duty on the individual performing the work to comply with the Code and is intentionally worded in such a way that one cannot claim that they are not legally responsible simply because they are not the name listed on the permit. It is this section of the Code that defines for code officials who the "Responsible Party" is.
By removing the requirement to issue the Notice of Violation to the “Responsible Party” you get 2 very negative outcomes. First, this would result in issuing what amounts to a criminal citation to a homeowner simply because an unlicensed contractor duped them into obtaining the permit in their name. This is the legal equivalent of the police issuing a citation to the victim of a robbery simply because they failed to lock their door. Second, the real “criminal” (i.e. the unlicensed contractor) gets away with the criminal act because this change would redefine legal responsibility to the victim of the criminal act. Furthermore, simply allowing for the issuance of a Notice of Violation to other parties through permissive language while directing the issuance of of the notice to the permit holder ignores our responsibility as code enforcement officials to hold those performing the work accountable for proper, code compliant construction.
To illustrate the potential for serious legal implications, I will share an example from a locality that occurred when the NOV was incorrectly issued to a homeowner rather than the “Responsible Party.” The property owner was told by the “contractor” that if he obtained the permit, it would be cheaper and easier, as the County was more forgiving of homeowners than contractors. The unsuspecting owner obtained the permit in his name listing “Owner as Contractor” on the issued permit. The contractor was not properly licensed for the scope of work to be performed. There were numerous problems with the work that eventually led to the issuance of a NOV. The NOV was improperly issued to the homeowner, even though he was not the one performing the work and creating the violation condition. Meanwhile, the real violator was not cited and eventually simply walked off the job with money in hand and no legal ramifications. All that was bad enough, but it gets worse. The owner held a high-level security clearance with the Federal Government which was put at risk due to the improperly issued citation. The unlicensed contractor, because no legal action was brought against him, was free to continue to victimize other unsuspecting property owners without consequence.
Finally, Code already recognizes that the ultimate purpose of the correction and Notice of Violation process is to achieve compliance with the Code – even when we are no longer able to pursue the “Responsible Party” to that end. That is why there is language differentiating to whom the NOV is to be issued, and who is to be copied. That is precisely why Section 115.2 contains the statement: “When the owner of the building or structure, or the permit holder for the construction in question, or the tenants of such building or structure, are not the responsible party to whom the notice of violation is issued, then a copy of the notice shall also be delivered to the such owner, permit holder or tenants.” This portion of the process insures that the property owner/tenant (permit holder) is aware of the situation and provides a path forward to compliance should the real criminal (the Responsible Party) disappear.
It is critical to the proper enforcement of Code that we, as code officials, are diligent in pursuing the “Responsible Party.” This change does not help to promote that end. In fact, it does quite the opposite, and weakens our enforcement position in the long run. I urge you to maintain the strong legal support for the issuance of citations to those who create the violation condition by rejecting this amendment.
Virginia is currently ranked (by the American Council for an Energy Efficient Economy) as 29th, in the bottom half of US states. Energy efficiency should be the first energy source for buildings, which represent 40% of Virginia's energy use. Virginia has made strides to improve its standing, and Governor Northam recently made a commitment to energy efficiency and clean energy (in Executive Order 43, September 2019).
At the same time, Virginia law requires that the Board of Housing and Community Development to refer to the national standard on energy efficiency (the International Energy Efficiency Conservation Code, or IEECC) in setting standards. The Board should fully embracing the IEECC standards, or go beyond them. Although there are minimal increased upfront costs associated with higher energy efficiency, the payback period is short (often around 5 years) and the savings accrue each year afterwards, saving money and energy for decades to come, since buildings typically last 40-100 years.
Virginians already pay among the highest electricity bills in the country. Inefficient homes mean higher electricity bills. Higher bills hit lower income people and people of color hardest. At this time in our history, is that a statement that we, in the Commonwealth of Virginia, wish to make? I hope not.
I urge the Board to the IEECC standards for Virginia.
Dear Chairman Semones:
I write today in support of updating Virginia’s residential building code with strong energy efficiency standards that reflect the urgent economic and environmental need to promote energy efficiency. I understand that the Board of Housing and Community Development (BHCD) is considering merely continuing current standards instead of modernizing them, and I encourage the Board to choose the latter option and help bring Virginia from the back to the front of the pack on energy efficiency.
As the House patron of the Virginia Clean Economy Act (VCEA), which created the Commonwealth’s first energy efficiency resource standard for utilities, I collaborated with industry stakeholders, activists, constituents, and my fellow lawmakers on this important issue. Our work proved that there is clear bipartisan support in the General Assembly for ambitious energy efficiency standards and programs – it is the fastest, cheapest way to reduce energy bills and reduce carbon emissions. The VCEA made great strides on energy efficiency, but we have to do more if we are to maximize this important energy-saving tool in Virginia.
I urge the Board to adopt, at a minimum, the International Energy Conservation Code’s (IECC) 2018 standards for all USBC-covered forms of construction. The Board should reject using the IECC’s 2009 standards, which fail to reflect the technological advances of the last decade and do not meet the popular demand for strong energy efficiency requirements.
Thank you for your consideration, and I am ready to answer any questions that you may have.
Best,
Delegate Rip Sullivan
48th District of Virginia
Virginia has not met the International Energy Conservation Code (IECC) since at least 2012. It is time to amend the Uniform Statewide Building Code (USBC) to meet the 2018 IECC energy conservation standards for all construction covered by the Virginia Code. Given that nationally, buildings represent 70% of electricity consumption, energy efficiency is one of the best and easiest ways to reduce electrical consumption and carbon emissions. In 2020, Virginia passed the Virginia Clean Economy Act - a landmark statue that calls for dramatic carbon reduction in light of the threat of climate change and the negative health, economic and environmental impacts it will bring across the Commonwealth. Bringing building codes up to energy efficiency standards laid out by the IECC will help us achieve those carbon reduction goals and create a clean energy economy. Furthermore, energy efficient buildings reduce utility bills of customers. Finally, Virginia law requires that the USBC protect the "health, safety and welfare of residents in the Commonwealth" and be be "consistent with recognized standards of health, safety, energy conservation and water conservation..." Minimizing costs to home builders must not take precedence over health and welfare of residences OR consistency with internationally recognized standards such as the IECC designed to do just that.
The Virginia Board of Housing and Community Development (BHCD) can ensure an energy-efficient, healthy future for the residents of the Commonwealth by updating the Virginia Uniform Statewide Building Code (USBC). Virginia Clinicians for Climate Action (VCCA) recommends that the BHCD meet or exceed guidelines in the most recent (2018) International Energy Conservation Code (IECC) to achieve this goal.
Numerous scientific studies have demonstrated that housing renovations based on various “green” building standards similar to those outlined in the IECC are associated with better human health (1, 2, 3, 4). Green building methods often involve improving ventilation, insulation, and heating and cooling equipment to increase energy efficiency and reduce pollutants; controlling moisture in buildings; and avoiding building materials that contain hazardous substances (1, 2). A study investigating the health effects of residential energy conservation among 248 households in Boston, Chicago, and New York City found that energy retrofits resulted in statistically significant improvements in general health and symptoms associated with sinusitis and hypertension (1). Green renovations of low-income housing in Washington, DC yielded significant improvements in general health, in addition to improvements in building dampness problems and reductions in cockroach and rodent allergens (3). Ventilation upgrades have been shown to relieve asthma-related and non-asthma respiratory problems (4).
Furthermore, energy-efficient homes can improve the well-being of Virginians through decreasing the financial burden associated with energy costs. Governor Northam’s Executive Order 43 recognized that low-income and minority households experienced higher energy-related financial burdens than the average household in the same city, and clean energy innovation can lower energy bills for these populations, promoting equity in Virginia (5). Low-income and minority populations disproportionately experience the harmful effects of climate change and environmental problems (6); adopting progressive building guidelines is a necessary step towards alleviating health disparities.
In the United States, buildings use 40% of our energy and 70% of our electricity, and emit over 33% of our greenhouse gas emissions (7). Energy production and emissions contribute to air pollution and climate change, both of which are associated with a multitude of direct and indirect health consequences. Continuously updating building codes will protect the future health of our community, as houses may last decades to over a century.
VCCA recommends that the BHCD adopt the latest IECC provisions and prepare to continue updating Virginia code in accordance with new IECC recommendations to best protect health and equity in the Commonwealth.
https://link.springer.com/article/10.1007/s12053-013-9216-8
https://journals.lww.com/jphmp/fulltext/2015/07000/Moving_Into_Green_Healthy_Housing.5.aspx
https://www.enterprisecommunity.org/download?fid=1560&nid=4271
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3072905/
https://www.governor.virginia.gov/media/governorvirginiagov/executive-actions/EO-43-Expanding-Access-to-Clean-Energy-and-Growing-the-Clean-Energy-Jobs-of-the-Future.pdf
https://nca2018.globalchange.gov/
https://www.ase.org/initiatives/buildings
The Building Code should require all new petroleum retail facilities to prepare for electric vehicle charging stations by preparing electrical capacity for two level 2 stations (80 amp/240V per station) or one DC Fast Charging station (minimum 100 amp service per station).
It is critical to upgrade the Uniform Statewide Building Code to require high energy efficiency in all buildings, residential and business. This is an area that is ripe for transitioning off of fossil fuels cheaply. And we MUST transition off of fossil fuels asap. Remember, they're experiencing almost daily flooding in the Tidewater area. This is the right path for Virginia. Thank you for your time and attention.
It is time for Virginia to meet or exceed the 2018 International Energy Conservation Code (IECC) for all forms of construction covered by Virginia's Uniform Statewide Building Code. Virginia has lagged behind in conservation requirements and with our new VCEA, energy efficient buildings and any rehabs are going to be necessary. I did not realize it but nationally buildings represent 70% of electricity consumption! We need to start now in making our building codes more efficient.
Thank you,
Jessie Clark
Science and practical development have brought about the potential for dramatic improvements in residential energy consumption. These improvements ensure a home will consume far less energy throughout the life of the home in order to provide a comfortable environment for the owners / occupants. This is good for the homeowner and good for the environment.
The costs to build in these improvements during construction are minimal. This is proven across other parts of the US and the world as a whole. The benefits are manifested throughout the life of the home, decades if not longer.
Virginian citizens deserve better homes that reflect the improvements possible in their construction. Regulations should be weighted so the buyer of the property gets a better built home rather than the builder who is currently providing homes far below what is possible. These changes bring minimal cost and effort but extensive gains for decades. Please improve the energy standards for new build homes.
Please prioritize homeowners' needs by adopting standards that require energy conservation and efficiency, and that require new buildings to be sited and wired for solar and electric vehicle technology. This will bring homeowner costs down over the long run. As Virginia transitions to clean energy and energy efficiency, housing is a critical part of the equation, accounting for 40% of energy use in Virginia. Virginia's building codes need to reflect technological advances in energy conservation, and need to be in step with the critical need to reach zero net carbon emissions.
I am writing to ask that you update Virginia's residential building code with strong energy efficiency standards, not just to maintain the status quo. Now is the time to modernize the standards that were developed ten years ago, before many technological advances had been made or envisioned. An update to the building code will materially reduce energy use and the size of our carbon footprint. It is your job to keep the best interests of Virginia residents in your focus as you make this important change to the Virginia Building Code. Thank you in advance for looking out for Virginia residents, their children and their grandchildren and the future of our planet!
We can no longer afford to treat our activities that affect the environment as "business as usual." All industries, including the building industry, must adjust to minimize their impact on further degradation of the environment. Updating our outdated building codes is key to recognizing the reality we all face. Yes, this increases upfront costs a bit, but the long term reduction in cost - both to homeowners and to the environment - far outweigh those costs.
We are in an existential moment and we need to do everything we can to be certain that this planet remains habitable. The earth is our most basic Home. Construction of human-built homes should be done in a way that ensures they are safe and environmentally sound. I don’t think permitting builders to save money is a good counter-argument to this imperative.
Please improve the energy efficiency codes for residential and commercial buildings in Virginia. The time is now or yesterday for making these changes. People who negligently waste energy today are robbing the future from our children and the next generation, if not this one with all the sickness. Please do this.
The best way to save energy is not to spend it in the first place! Energy efficiency for buildings allows every Virginian to participate in a solution to cutting carbon emissions while also saving on heating bills. The transition to a sustainable energy economy has to happen in a lot of areas, and energy efficiency in buildings is a common-sense place to start. Time for Virginia to get on board with improved standards.
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
Virginia's ACEEE energy efficiency ranking 35th out of 48 is unacceptable. The Commonwealth has an advanced economy and a literate, politically savvy population. There is no reason to accept such a low ranking, which DROPPED recently. Buildings account for 40% of energy use. Old, outdated, inadequate building codes must be replaced by modern standards that reflect advances in technology. Using better materials and better practices, while more expensive to use, more than pays for itself in the cost savings enjoyed for years to come. Virginians don't need to pay for electricity bills that are artificially higher due to bad building codes. Virginia must address climate change by decreasing it's greenhouse gas emissions, and that includes improving building codes to ensure weather-tight, well insulated structures. Instead of catering to the building industry, regulators must act on the best interests of Virginians and on protecting Virginia's environment. Responsibly addressing the Climate Crisis requires strong, up-to-date building standards. Raise Virginia's energy efficiency ranking by adopting strong, modern building codes.
Virginia's ACEEE energy efficiency ranking 35th out of 48 is unacceptable. The Commonwealth has an advanced economy and a literate, politically savvy population. There is no reason to accept such a low ranking, which DROPPED recently. Buildings account for 40% of energy use. Old, outdated, inadequate building codes must be replaced by modern standards that reflect advances in technology. Using better materials and better practices, while more expensive to use, more than pays for itself in the cost savings enjoyed for years to come. Virginians don't need to pay for electricity bills that are artificially higher due to bad building codes. Virginia must address climate change by decreasing it's greenhouse gas emissions, and that includes improving building codes to ensure weather-tight, well insulated structures. Instead of catering to the building industry, regulators must act on the best interests of Virginians and on protecting Virginia's environment. Responsibly addressing the Climate Crisis requires strong, up-to-date building standards. Raise Virginia's energy efficiency ranking by adopting strong, modern building codes.
The VA Board of Housing and Community Development should amend the Uniform Statewide Building Code to meet or exceed 2018 International Energy Conservation Code (IECC) for all forms of construction covered by Virginia's Uniform Statewide Building Code.
1. Virginians deserve thermally comfortable buildings
Better insulated buildings with more efficient systems are more comfortable to live and breathe in -- they don't get too hot or too cold regardless of the weather.
Updated codes will help ensure that Virginia is keeping pace with the improved understanding of what it takes to make the buildings best suited for the climate. Let's give Virginians the best.
2. Recent election results have shown that Virginians are ready to embrace progress
While most residents are not aware of codes, they are quite aware of new announcements being made by their new representatives. They are hungry to hear that we are moving in the right direction, and bringing in meaningful change. Codes are the most effective way to reduce energy use and emissions from buildings (ACEEE) -- buildings are the largest sector where meaningful reductions in emissions can be made to slow down climate change (Mckinsey, IEA). Climate change is a big issue on the mind of constituents, red or blue. Let's put them at ease with impactful updates. (Imagine the headlines!)
3. Costs are a non-issue compared to increased disposable income
The stakeholder process used in code development ensures that only the most cost-effective standard measures make it to the codes. Besides, the price of upgrades to the latest code are minor compared to other real estate pricing concerns, especially in the urban markets. So, financial concerns should not hold us back. The savings from utilities will most likely be pumped back into the Virginia economy (more Virginia wine, anyone?). Let's provide Virginians with more disposable income.
Bottomline: Let's adopt the current IECC codes (2018) (and leave our neighbors in the dust.)
I am writing to request that any revisions to the residential building code strengthen--not loosen--requirements for energy efficient siting, materials and construction, so that housing helps Virginia meet its goals for conserving energy and mitigating climate change. Home buyers will benefit since energy-efficient housing will reduce operating costs and so save them money. Thank you for this opportunity to comment.
Virginia has not met the International Energy Conservation Code (IECC) for at least the last eight years. It is time to change this and amend the Uniform Statewide Building Code (USBC) to meet the 2018 IECC energy conservation standards for all construction covered by the Virginia Code. Given that nationally, buildings represent 70% of electricity consumption, and electricity prices in Virginia are among the country's highest, investments in energy efficiency provide immediate and cost-effective economic and financial returns, and are one of the best and easiest ways to reduce electrical consumption and carbon emissions. Energy-efficient buildings reduce utility bills of customers and provide these benefits over the long term. In 2020, Virginia passed the Virginia Clean Economy Act - a landmark statue that calls for dramatic carbon reduction in light of the threat of climate change and the negative health, economic and environmental impacts (e.g., sea-level rise in Tidewater, more energy-intensive storms) it is already bringing across the Commonwealth. Bringing building codes up to energy efficiency standards laid out by the IECC will help us achieve those carbon reduction goals and create a clean, stable, and more equitable energy economy. Finally, Virginia law requires that the USBC protect the "health, safety and welfare of residents in the Commonwealth" and be "consistent with recognized standards of health, safety, energy conservation and water conservation..." Minimizing up-front costs to home builders must not take precedence over health and welfare of residents, protection of the environment and reduction of carbon pollution, OR consistency with internationally recognized standards such as the IECC, which are designed to promote citizen health and welfare.
Improve Virginia's energy efficiency codes to save residents money and reduce our impact on the climate; please amend the Uniform Statewide Building Code (USBC) to meet the 2018 International Energy Conservation Code for all construction covered by the Virginia.