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 Ended on 9/29/2013
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9/27/13  8:42 am
Commenter: Andrew Grigsby, Virginia Energy Efficiency Council

Virginia should adopt all of the efficiency improvements from the model codes

The claim that some requirements of the new IECC raise the cost of housing unnecessarily is not supported by the bulk of the available evidence. These specific technologies are included (while others are not) precisely because they have been repeatedly documented to lower the overall cost of homeownership.  This research comes from utilities, national labs, independent building science research organizations, and university research centers across the country.

Of course the numbers vary. For example, in some available reports, cost estimates for adding insulation to hot water pipes range from $10 to $1000 in similarly-sized homes. Estimates about the cost impact of each efficiency improvement and the energy impact vary among researchers due to many reasons including house designs, local labor costs, local material costs, house sizes, local energy prices, etc. So, as the saying goes, actual mileage will vary. It also is the case that, for each of these efficiency improvements, a smart builder will devise strategies (like giving his framers a case of caulk, or altering designs to keep all ductwork in conditioned space) to minimize added costs. So, to continue the metaphor, driver behavior will affect actual mileage.

The task when adopting code changes to establish the minimum standard for houses that we intend to be functional and valuable for another hundred years. Total value certainly includes the cost to operate. History has shown that it is reasonable to assume that energy prices will trend upwards throughout the ownership lifecycle of a new home. Given that, it makes little sense to use today’s energy prices to guide our cost-effectiveness calculations. The country’s top building scientists suggest basing decisions on an estimate of energy prices half-way through the home’s life. While we are not prepared to make precise forecasts of future energy prices, we do maintain that it is completely sensible, for individuals and for society, to invest a modest amount as a hedge against high energy prices in the future.

Smart homebuilders will see real opportunity here: delivering superior performance to their clients. Houses that implement these energy upgrades will perform better. They will resolve problems that have disappointed homebuyers for years. Properly implemented, advanced energy codes and good building science help create satisfied customers who drive more business to good builders.

The primary drivers of increased housing costs are land speculation, the increased size of houses, and complexity of design. These increase prices by tens of thousands or more overnight – with no financial payback to buyers. Advanced energy codes add, on average, a few thousand to construction costs and often provide monthly savings to the homeowner the day the house is occupied.

Even at the same price, a homeowner benefits from adding $20-40 per month to the mortgage to invest in the efficiency of the home – compared to paying that same amount towards energy bills. Mortgage interest is tax deductable; utility payments are not. The monthly payment on a fixed mortgage will stay constant; energy prices tend to rise. Again, by investing in their new house now, new homebuyers hedge against rising energy costs – while also increasing durability and comfort. 

All builders must comply with the code – so no builder in the Commonwealth is put at any competitive disadvantage by the adoption of rigorous codes. Today, superior builders who use these practices are penalized – as their competitors may mislead potential clients about the cost-benefit of efficiency upgrades and undersell the quality builder.

These are upgrades that create more work for the builder which he should make money on. It seems builders would welcome these improvements as good policies that level the playing field among builders, improve the product that they provide, and improve their industry’s overall reputation.

Virginia’s Board of Housing and Community Development is charged with ensuring that the citizens of the Commonwealth enjoy the most cost-effective energy codes. The 2012 IECC provides just that – and should be adopted without alteration.

Specific recommendations:

Do not alter the 2012 IECC’s requirement for insulation on hot water pipes.

·         This is a very doable and cost-effective efficiency improvement. After the plumbing lines have been inspected and tested, this is a punch list item that a builder can accomplish at minimal cost with no workflow disruption.

·         For an average house, the Pacific Northwest National Laboratory published research estimating that for around $200 in builder’s costs, an average homeowner can expect to save about 2.75 mBtu annually from insulating all hot water pipes to R-3. This equates to about 800 kilowatt hours, which is just over $80 per year given Virginia’s current average price.  Clearly this is a superb investment. Currently, Dominion Virginia Power’s Home Energy Check-up program will provide a rebate of $50 for installing insulation on as little as five feet of hot water pipes in existing houses. This indicates how valuable Virginia’s largest utility views the energy savings from this improvement.

Do not alter the 2012 IECC’s requirement for 75% high-efficiency lighting fixtures to 50%.

·         The 75% standard can be maintained with as little as $25 in most homes. That’s the added cost to install CFLs rather than incandescent lamps in 15 more hard-wired fixtures. Dominion Virginia Power’s Home Energy Check-up program will provide a rebate of $50 for installation of just two 15-Watt CFLs. A builder that does not pursue this efficiency improvement is simply throwing away his clients’ money.

Do not alter the 2012 IECC’s requirement for R49 attic insulation down to R38.

·         The Building Technology Center at Oak Ridge National Lab has promoted R49 as the cost-effective insulation option for Virginia for more than 5 years. 

·         Several Virginia insulation installers quoted (in February, 2013) prices of $.19/sf to increase a cellulose attic install from R38 to R49. That’s around $200; call it $300 with builder markup. Software modeling by VAEEC members for a typical new Virginia home shows this saves around $14/yr. at today’s energy prices. By the time electricity costs increase 20%, that extra attic insulation will save this same homeowner more than $100/yr. This seems an excellent risk. It won’t cost just $300 to invite the insulator back in 5 years.  

Do not alter the 2012 IECC’s requirement for R20 wall insulation down to R15.

·         Heat pumps come and go. So do appliances, water heaters, and furnaces. We even can replace windows. We can add insulation to an attic and we can seal ductwork. All of these happen regularly in house’s lifetime of, say, 80 years. But we do not typically expect to change wall insulation. It is possible – we can add insulated sheathing when replacing siding. But given that most houses will not alter their wall insulation, what is the price point for energy we ought to have in mind when designing our walls?

·         On a typical, 2 story colonial in Virginia, R21 walls save about $100/yr over R15 at today’s energy prices. The foam sheathing option (R13 cavity plus R5 continuous) provides slightly more savings. Again, software modeling shows that a 20% increase in utility costs more than doubles the savings.

Do not alter the 2012 IECC’s requirement for 3 air changes per hour building tightness up to 5.

·         This is a fairly rigorous standard, but builders who have become accustomed to having blower door tests know that it is very doable. In complicated houses it will be somewhat more difficult. But complexity adds much greater costs in many other ways – and is something a buyer can easily avoid. For building crews that have been sufficiently trained, additional costs to build to this standard are truly minimal. It’s the simple attention to detail that all homebuyers deserve.

·         To even discuss 3 versus 5 air changes presumes that an actual blower door test is included.

Do not alter the 2012 IECC’s requirement for blower door confirmation of building tightness. Do not allow a visual inspection option.

·         There is no substitute for actual mechanical testing of the building. A visual inspection standard is no standard. Air leaks – even large ones – are not always detectable visually. In January of this year one VAEEC board member tested a 10-yr old house that looked great – but tested at 20 air changes per hour. It is precisely the hard-to-find leaks that are the problem. Most builders will address a visible hole. It is not difficult to build a tight house. But the only way to find the random problems is to test. And we can only know the actual air changes per hour if we test.

Do not alter the 2012 IECC’s requirement for 4% duct leakage limit up to 6%.

·         Average duct leakage in the US housing stock is estimated to exceed 15%. This is pure waste, dollars being blown out the window. The cure, in an average new home, is maybe an hour’s worth of careful work and some $30 in materials. That 2% duct leakage should save between $20 and $25 annually at today’s energy prices (as shown by modeling on a typical new home in Virginia).

Do not alter the 2012 IECC’s requirement for mechanical testing for confirmation of duct leakage. Do not allow a visual inspection option.

·         There is no substitute for a pressure test of the ductwork. Any person who actually has tested ductwork knows that, unless every inch of the entire duct system is readily visible, then only a mechanical test would have a hope of finding all of the leaks. It makes no sense to ask an inspector to crawl around the entire system hunting for leaks. Usually that’s physically impossible. The only evaluation that gives results that can be compared against an objective standard is an actual pressure test. Otherwise, there is no standard.

The houses used for modeling with REM/Rate software in Sterling, Va. climate zone: <photos>

·         Left: conditioned floor area=3360sf; ceiling area=1680sf; above grade wall area=1426sf; conditioned walkout basement; 2.01ACH50; 0.5% duct leakage to outside

·         Right: conditioned floor area=4314sf; ceiling area=1390sf; above grade wall area=3363sf; conditioned walkout basement; 2.7ACH50; 2.8% duct leakage to outside

Modeling performed by

Andrew grigsby, LEED AP, HERS Rater, BPI BA & EP

Principal, Commonwealth Sustainability Works


P.O. Box 633, Culpeper, Va. 22701


CommentID: 29107