September 24, 2013

Stephen W. Calhoun

Regulatory Coordinator

Department of Housing and Community Development

Main Street Centre

600 East Main Street, Suite 300

Richmond, VA 23219

Dear Mr. Calhoun,

The Virginia Board of Housing and Community Development (BHCD) is currently deliberating on the 2012 building code, and this year was anticipated to be one of the best years for residential and commercial building energy efficiency improvements, as the national model code recommendation included upgrades that would represent a 15% national gain in building efficiency – and could achieve as much as a 27.4% gain for Virginia’s residential buildings, according to a recent analysis completed by the U.S. Department of Energy.  This jump could eliminate 55.6 million metric tons of CO2 by 2035, equivalent to taking 11.6 million cars off the roads.

However, these higher standards have been removed from the proposed Virginia residential code,. Unless the provisions are reinstated, Virginia will miss this opportunity to modernize and improve residences statewide.

Roanoke Valley Cool Cities Coalition is a 501.c.3 nonprofit organization with almost 300 affiliates representing over 25,000 citizens in our region.  Our mission is to help local citizens reduce their carbon emissions and the harmful consequences that ensue. http://rvccc.org.

On behalf of our affiliates, I respectfully urge you and the Board of Housing and Community Development (BHCD) to fully restore the provisions of the national code that have been removed for Virginia, as these are founded on less than accurate economic data and would, in fact, leave Virginia homeowners and tenants at a disadvantage as consumers.

The improved standards aim at reducing energy waste in new buildings, with the added benefit of lowering owner’s energy costs. While the commercial building code remains relatively untouched in changes to the energy efficiency provisions, these higher standards have been removed from the Virginia residential code. Unless the provisions are reinstated, Virginia will miss this opportunity to modernize and improve residences statewide.

CHANGES WHICH SHOULD BE RESTORED

This BHCD has approved a series of proposals which weaken or remove the 2012 national model code, or International Energy and Conservation Code (IECC), energy efficiency improvements. These include, but are not limited to, efficiency reductions in requirements for:

•          Wall insulation – reduced R-Value from 20 or 13+5 to 15 or 13+1, and changed U-Factor from 0.057 to 0.079.
•          Ceiling insulation – reduced R-Value from 49 to 38, and changed U-Factor from 0.026 to 0.030.
•           Replacement fenestration – removed requirement that replacement fenestration meet the same standard as windows used in new construction.
•          Glazing shade fraction and area – reduced interior shade fraction from 0.92 to 0.70 for Summer and 0.85 for Winter, and set glazing area assumption at a fixed 15%.
•          High-efficacy lighting – reduced requirement for high-efficacy lamps from 75% to 50% of permanent luminaires.
•          Duct testing – allowed visual inspection in lieu of mandatory mechanical testing, and changes acceptable post-construction total leakage from 4 cfm to 6 cfm.
•          Blower door testing – allowed visual inspection in lieu of mandatory mechanical testing.

 POTENTIAL SAVINGS AND BENEFITS TO VIRGINIANS:

The benefits of Virginia’s adoption of the national model energy standards include, but are not limited to:

•          Stabilize homeowner energy costs while improving homeowner comfort
•          Delay the need to build more expensive power plants
•          Lessen U.S. and Virginia’s reliance on energy imports
•           Benefit future generations with long-lasting energy and cost-saving improvements

 According to the U.S. Department of Energy

•          “on average, Virginia homeowners will save $5,836 with the 2012 IECC.
•          After accounting for upfront costs and additional costs financed in the mortgage, homeowners should see net positive cash flows (i.e., cumulative savings exceeding cumulative cash outlays) in 1 year for the 2012 IECC.
•          Average annual energy savings are $388 for the 2012 IECC.”

If the Commonwealth were to adopt and achieve full compliance with the national energy standards by the year 2014, the Building Codes Assistance Project assesses that by 2035 Virginia would:

•          Allow businesses and households to keep about $800 million annually via reduced energy bills (about $9.2 billion cumulatively through 2035).
•          Reduce the demand for about 82 trillion Btu of energy per year – about 10% below the otherwise projected baseline energy use of the Commonwealth’s building sector in 2035.
•           Reduce the need for state and federal funding for low-income households that struggle with high energy bills.

Virginia homes and businesses lacking in energy efficiency put owners and occupants at a disadvantage by making energy costs less affordable throughout the life of the building. Energy efficiency helps avoid utility rate increases for new power plants to meet peak demand, and efficient homes have been proven to reduce the rate of foreclosure.

For all these reasons, I urge you and the BHCD to do what is right for the citizens of Virginia and restore all energy efficiency standards to the new Virginia building code.

Sincerely,

Bob Blankenship