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.