Agencies | Governor
Virginia Regulatory Town Hall
Agency
Department of Housing and Community Development
Board
Board of Housing and Community Development
chapter
Virginia Uniform Statewide Building Code [13 VAC 5 ‑ 63]
Action Update the Uniform Statewide Building Code
Stage Proposed
Comment Period Ends 6/26/2020
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6/25/20  5:10 pm
Commenter: Ross Shearer

Weakened amendments of the USBC's residential energy provisions are a social justice concern
 

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

CommentID: 83811