Virginia Regulatory Town Hall
Department of Energy
Department of Energy
Previous Comment     Next Comment     Back to List of Comments
8/23/18  10:52 am
Commenter: Justin Koscher, Polyisocyanurate Insulation Manufacturers Association

Building Energy Efficiency

The Polyisocyanurate Insulation Manufacturers Association (PIMA) would like to take this opportunity to comment on the Virginia Energy Plan now being developed by the Department of Mines, Minerals and Energy.    PIMA is the trade association for North American manufacturers of rigid polyiso foam insulation – a product that is used in most low-slope commercial roofs as well as in commercial and residential walls.  Polyiso insulation products and the raw materials used to manufacture polyiso are produced in over 50 manufacturing facilities across North America, including Hopewell, Virginia. 

Development of a new Energy Plan provides Virginia with the opportunity to demonstrate leadership on energy and environmental policy and to promote energy-efficiency measures that will have a positive impact on Virginia’s employment and economy.  According to the most recent U.S. Energy and Employment Report there are now 2.25 million Americans directly employed in energy-efficiency jobs in the United States and 72,621 of these jobs are in Virginia.[1]   With the right policies, Virginia can grow this segment of its economy and become more competitive.


  • Move forward with adoption of the 2018 International Energy Conservation Code (IECC) and remove the Virginia specific amendments that weaken that code;
  • Provide additional resources for building energy code training and enforcement focused on the area of existing building alterations; and
  • Develop a commercial building energy “stretch” code and allow local jurisdictions the option of adopting that code in place of the energy chapter in the Virginia Construction Code.

Building Energy Codes

PIMA encourages the Department to focus more attention on buildings and the use of building energy codes as a key policy for addressing the environmental and economic consequences of energy waste.  Residential and commercial buildings account for 41% of total U.S. energy use and 74% of electricity use, so measures targeting this sector will have a relatively large impact.   The most cost-effective and comprehensive tools for reducing this energy use are strong building energy codes along with quality code training and education of local code officials, designers, and builders.  The benefits of reducing building energy use include: consumer and business cost savings; improved energy productivity and a stronger economy; reduction in air pollution; increased job growth; improved resiliency; and increased flexibility and reliability of our energy system and grid.  

Although PIMA is encouraged by the Virginia’s recent progress in the area of building energy codes, we believe the State could do more.  The recent adoption of the 2015 I-Codes, including the 2015 IECC, by the Virginia Department of Housing and Community Development (DHCD) included several changes to both the IECC and the International Existing Building Code (IEBC) that reduces the energy-efficiency benefits of these codes.  As part of the new Energy Plan, we strongly encourage you to include recommendations for adopting the 2018 IECC and IEBC without the Virginia specific amendments that weaken the energy-efficiency provisions. 

  1. Energy Savings Potential Related to New Construction

Commercial: Updating Virginia’s commercial building energy code to the 2018 IECC would reduce building energy costs by approximately 8.2%.[2]   Recent advances in energy efficiency under the IECC have proven to be extremely cost effective for commercial buildings, even when measured against strict simple payback standards.   A cost-effectiveness analysis of the 2018 IECC is not yet available, but for the 2015 IECC (which had a similar incremental percentage improvement in energy performance compared to the previous edition), the average incremental cost of construction was only a tenth of one percent nationally[3] and the average simple payback period for Virginia was determined to be immediate.[4] 

Residential: Although the incremental percentage increases in energy efficiency between the 2012, 2015 and 2018 versions of the IECC are not as large for residential buildings, Virginia could make significant improvements in this area by simply bringing the residential thermal envelope and air leakage requirements up to 2015 or 2018 IECC levels.  These two areas were weakened during the last code adoption cycle (i.e., weakened from the requirements under the 2015 IECC model code). 

II.Energy Saving Potential Related to Alterations in Existing Buildings

One of the more impactful changes to the model energy codes was in 1999 and 2000 when the scope of ASHRAE Standard 90.1 and the International Energy Conservation Code (IECC) were both expanded to cover alterations in existing buildings.    Underscoring the importance of including existing buildings within the scope of the energy code, the Pacific Northwest National Laboratory (PNNL) advised states who were considering the adoption of ASHRAE Standard 90.1-1999 (which initiated the coverage of alterations in the model codes) that “the expansion of this code to existing buildings could produce nearly 50% more savings then if it were applied to new buildings alone.”[5]  This assessment from over 16 years ago is supported today through individual state construction permit data.  Although we do not have commercial construction data for Virginia, in similar populous states, the amount of commercial construction that is attributed to building alterations vs. new construction is very high: 80% in New York[6] and 50% in New Jersey (both measured as a percentage of total construction).[7]

The intent of including existing buildings under the energy code is to leverage the natural cycle of building upgrades and component replacement in order to improve energy efficiency.  More than half of existing commercial buildings were built before state and local governments started to adopt building energy codes, so these older buildings offer a huge opportunity for energy savings and the most cost-effective time to improve a building’s energy performance is when it is renovated and/or when components and systems are replaced.  This process is particularly important for envelope improvements, which reduce building heating and cooling loads, thus creating the potential for even greater improvement in equipment efficiencies in the future.  As one example, approximately 2.5 billion square feet of commercial, low-slope roofs are replaced or re-covered each year on existing buildings.  Replacing a typical existing roof with an energy code-compliant roof reduces whole building energy use by an average of 5.7% and could result in a ten-year cumulative energy cost savings of more than $12 billion and a cumulative CO2 emission reduction of more than 100 million metric tons[8] (equal to the annual emissions of 24.8 coal-fired power plants or 21.4 million cars).[9]

  1. Energy “Stretch” Code

Stretch codes provide easily-adoptable code language that is cost-effective and that local jurisdictions can adopt as an overlay of the base energy code in order to achieve greater energy savings, typically in the range of 10 to 20 percent.[10]  Using stretch codes helps signal to the market which direction building practices are heading.  This will result in earlier acceptance and adoption of energy-efficient measures and construction practices which should also translate into greater acceptance of the base code.  Currently, Massachusetts and New York have energy stretch codes that can be adopted at the local level.

  1. Energy Code Training

The success of building energy codes depends on enforcement and compliance.  Providing adequate resources towards the education and training of building professionals and code officials will provide local governments with the reinforcement they need to effectively enforce building energy codes.  Also, regular energy code training keeps builders, designers, and code officials knowledgeable about building science and new construction techniques, materials and technologies that are relevant to building energy use. 

  1. Additional Benefits of a Strong Energy Code for Virginia

Building energy codes enable Virginia businesses that lease real property to be more competitive and to invest more money back into their businesses and local communities.  Sometimes referred to as an issue of “split incentives,” this is particularly prevalent with commercial buildings, were businesses that rent retail, office or commercial space are responsible for paying the energy costs associated with operating the building.[11]  They pay these energy costs with little to no influence over improvements that would improve energy efficiency.  Virginia’s energy code can help ensure that these businesses are afforded access to energy efficient buildings.

Furthermore, the 2018 IECC will help ensure Virginia residents and businesses have homes and buildings that promote general welfare and safety.  For example, in a recent Department of Energy survey, one in five respondents reported reducing or forgoing basic necessities like food and medicine to pay an energy bill and 14% reported receiving a disconnection notice for energy service.[12]  Moreover, 2017 served as a reminder that severe weather can leave communities stranded without power for days or even weeks.  Buildings constructed with energy-efficient envelopes can help protect occupants during the most vulnerable times.[13]  The benefits of modern building energy codes are clear and the risks of failing to protect Virginia’s health and safety can be easily avoided.


[1] U.S. Energy and Employment Report, National Association of State Energy Officials (NASEO) and Energy Futures Initiative, May, 2018,

[2] Energy Savings Analysis ANSI/ASHRAE/IES Standard 90.1-2016, Office of Energy Efficiency & Renewable Energy, U.S. Department of Energy (June 2017). Available at:

[3] R. Hart et al., “National Cost-Effectiveness of ANSI/ASHRAE/IES Standard 90.1-2013,” Pacific Northwest National Laboratory, January 2015, page 4.26 (Note: estimate is a weighted average).

[4] R. Hart et al., Cost-Effectiveness of ASHRAE Standard 90.1-2013 for the State of Virginia, Pacific Northwest National Laboratory, December 2015. Available at:

[5] Cort KA, DB Belzer, MA Halverson, EE Richman, and DW Winiarski.  2002.  Analysis of Potential Benefits and Costs of Adopting ASHRAE Standard 90.1-1999 as a Commercial Building Energy Code in Michigan.  PNNL-14017, Pacific Northwest National Laboratory, Richland, WA, page 28,

[6] New York State Energy Research and Development Authority, New Efficiency: New York, April 2018, page 61. file:///C:/Users/mangjc/Downloads/New-Efficiency-New-York%20(3).pdf

[7] NJ Department of Community Affairs, Dollar amount of construction authorized by building permit type, July 7, 2017 (data averaged over the last five years)

[8] Jerry Phelan et al., Energy and Environmental Impact Reduction Opportunities for Existing Buildings with Low-Slope Roofs, Bayer Materials Science, April 2009.   This average site energy savings and cumulative energy cost savings is for 7 building categories in climate zones 2-6.

[9]  From U.S. EPA’s Greenhouse Gas Equivalencies Calculator at

[10] See

[11] 39% of non-government commercial building space is leased and another 13% have a mix of owner-occupied and leased tenants (2012 CBECS data, Table B1).

[12] “One in three U.S. households faced challenges in paying energy bills in 2015,” U.S. Energy Information Administration. Available at:

[13] “Leaks and Lives: How Better Building Envelopes Make Blackouts Less Dangerous,” ACEEE (2014). Available at:

CommentID: 66464