I object to the loss of energy conservation measures in new construction, in particular the change of the following specific standards:

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.

These components of a home may not be efficiently improved following construction and improve the heating and cooling performance of a home for the life of the mortgage. The cost is easily justified as a small increment which has a proven pay-back.

I  strongly oppose the apparent weakening of the proposed 2012 building code – particularly as it relates to energy efficiency.  Investments in energy efficiency during construction or renovation are without a doubt the easiest and cheapest way of conserving energy, reducing energy-related emissions, and saving households a great deal of money in the long term.  The cost of electricity and other household fuels is only expected to rise in the coming decades – and may rise precipitously over the expected lifetime of new homes built today.  It would be a serious mistake – environmentally, socially, and economically -  to miss this opportunity to substantially improve the energy efficiency of Virginia’s housing stock.

Strong statewide building codes are the best way to help lower-income homeowners and renters who often have trouble paying utility bills. It is disgraceful that the state is contemplating bowing to the homebuilders' lobbying and adopting lower code standards that will make home heating and cooling less affordable. Virginia can do better by its people.

It is absolutely essential that Virginia adopt the full 2012 IECC energy efficient building codes. Buildings account for over 40% of our energy use in the U.S. Requiring new homes and commercial buildings to be more energy efficient is the first/best step in reducing energy waste and represents a common sense approach to reducing consumption. 90% of electricity generated in the U.S. is the result of burning fossil fuels. Fossil fuesl have a huge impact on our natural environment - including the air we breathe, the water we drink and the soil we use to grow food. Anything we can do collectively to be less wasteful and consume less is a win/win for everybody. Do not allow special interest groups - who oppose these new building standards - the ability or power to satisfy their narrow agenda. The standards are already watered down because Virginia has opted to allow "visual" inspection vs. diagnostic testing for duct leakage and air sealing. "Visual" testing does not work. Air leakakge and duct leakge must be verified and quantified by a blower door and a duct blaster. So reducing the effectiveness of these standards even further is a huge step backwards.

Billy Weitzenfeld

Executive Director, AECPype over this text and enter your comments here. You are limited to approximately 3000 words.

very much in favor of approving and/or adopting as read.

m smith

The Hampton Roads Planning District Commission (HRPDC) supports the provisions for rainwater non-potable water systems as set forth in the proposed regulation amending the Virginia Uniform Statewide Building Code, 13VAC5-63-210 R (75) and 13VAC5-63-320 (19).  HRPDC's September 19, 2013 comment letter is available at: http://www.hrpdc.org/uploads/docs/RainwaterHarvesting_Building%20Code%20Comment%20Ltr.pdf

September 23, 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. You may see our full affiliates list here: http://rvccc.org/affiliates/.

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 again 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,

Dr. Diana Christopulos, President

Roanoke Valley Cool Cities Coalition

907 Greenbrier Court

Salem, VA 24153

Please record me as supporting the comments submitted by the Roanoke Valley Clean Cities Coalition in favor of restoring all of the energy efficiency requierments to the proposed revised building code.  I was a member of the Roanoke City Council for six years and am a former chairman of the Western Virginia Water Authority.

Adopt Energy Efficiency Building Codes

It is absolutely essential that Virginia adopt the full 2012 IECC energy efficient building codes. Buildings account for over 40% of our energy use in the U.S. Requiring new homes and commercial buildings to be more energy efficient is the first/best step in reducing energy waste and represents a common sense approach to reducing consumption.

Do not allow special interest groups - who oppose these new building standards - the ability or power to satisfy their narrow agenda.

Virginia must not allow "visual" inspection vs. diagnostic testing for duct leakage and air sealing. "Visual" testing does not work. Air leakage and duct leakage must be verified and quantified by a blower door and a duct blaster.

The home I live in has insufficient ceiling and wall insulation, yet it is difficult to add more.  Do not stick future homeowners and renters with high utility bills for the life of the home just because homebuilders want to save a few $$ up front.

Reducing the energy efficiency of a new building is shortsighted. What is saved in building costs is more than lost in the higher operating costs of the structure.

I fully support adherring to the national standards for energy efficiency and for the legislature to not "dumb down." the regulations.

I agree with Conrad Grundlehner, that  lessening those standards is a very short-sided view.

I also agree with the Roanoke Valley Cities Coalition stand that we must decrease our energy consumption and improve our environmental footprint.  Cutting corners in that goal is going to have a negative impact on our future!

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

It is foolish to hold on to old high depletion standards of the 20th Century.  We are healthy when we adapt our needs to that which can be sustainably provided.  The energy performance of our buildings constitute approximately half the energy consumed in our economy.  Construction and maintenance of our buildings offer our biggest opportunity to reduce the depletion of non renewable resourses and reduce emissions and environmental legacies associated with most fossil fuels, (permanent loss of water through fracking, tar sands, off shore drilling).  Our responsibility as adults is to develop the infrastructure to be appropriate for the limitations that can be sustained in a healthy way. 

It is foolish to hold on to old high depletion standards of the 20th Century.  We are healthy when we adapt our needs to that which can be sustainably provided.  The energy performance of our buildings constitute approximately half the energy consumed in our economy.  Construction and maintenance of our buildings offer our biggest opportunity to reduce the depletion of non renewable resourses and reduce emissions and environmental legacies associated with most fossil fuels, (permanent loss of water through fracking, tar sands, off shore drilling).  Our responsibility as adults is to develop the infrastructure to be appropriate for the limitations that can be sustained in a healthy way. 

The Low Income Weatherization Program managed by DHCD is a good example of responsible energy policy and practice.

These proposals are not.

Visual determine air leakage? Really? 

I strongly support the full implementation of the International Energy and Conservation Code (IECC), energy efficiency improvements to the 2012 building code.  Higher standards are always better, especially in the building industry and insulation is key to keeping energy costs lower. 

As detailed in many of the previous comments, the energy efficiency measures that have been removed from the national standard should be restored in the VA proposed building code.  The benefits are too numerous to ignore and the consequences of not restoring the energy efficiency measures are too costly (financially & otherwise). 

It is unbelievable that Virginia would miss this opportunity to modernize and eliminate a huge amout of carbon emissions from the housing sector. Reinstate the energy efficiency measures so Virginia can stop being so backwards (there are already enough disincentives for energy/fuel efficiency here). 

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, largely due to lobbying efforts from the Home Builders Association of Virginia. Unless the provisions are reinstated, Virginia will miss this opportunity to modernize and improve residences statewide.

Don't let the special interests win this one!

My home was built in 1959 in Springfield; a brick faced veneer rambler.  It does not have any insulation in the walls.  This home would never have been allowed in New England with such a lack of adequate insulation.   Think of all the natural gas that has been wasted during the past 50 years just becauce the builder saved a few hundred dollars.

Let's move Virginia into the 21st Century and adopt the National Building Code; it's the moral thing to do.  Time to stop wasting the natural resources that God gave us.

As a Virginia home owner of a 1978 house who cares about energy efficiency, I have managed to take my energy usage from a peak of 1450 kilowatt hours down to under 600 kilowatt hours in about a year.  

I added R-38 insulation, two temperature controlled exhaust fans, changed all of my lights to LEDs, added a Nest thermostat and installed a hybrid hot water heater.  As a result my electric bill and gas bills haven't been above $100 a month since.

I still have plenty of work to close the draftiness of my window frames, and those old windows are screaming to be be replaced.

Reducing energy efficient building standards puts a huge burden on the home-owner to tighten up their household.  It is large, ongoing burden that many folks simply don't get around to, or don't have the funds to take up that challenge.

Energy efficient building standards will make the homes of Virginia more comfortable, more affordable to the homeowner, and will conserve our energy resources and protect the environment.

My grandfather used to tell me "do it right the first time".  As a Virginia homeowner chasing drafty windows I strongly urge regulatory action on energy-efficient building standards.

As someone who is getting ready to replace a 20 year old roof for about $10,000, I would like to point out that good solid construction can reduce the total cost of ownership of a home.  This would then increase the value of the home and increase property tax revenue as well.  This would still save me money since energy costs would be lower and maintenance would be less as well.

I believe that expenditures on home energy is not a productive use of my money.  I expect my state government to have MY best interests in mind and maintain realistic and forward looking regulations that protect me, even if I do not understand the technical details of home building and everything that is involved. 

Please pass state building codes that make homes with greater energy efficency  -  this saves the homeowner from expensive utility bills, and helps reduce air pollution too!

I am a high school Environmental Science teacher.  I am strongly in support of stringent energy codes.  We need smart, efficient homes now.  Please continue to move forward on these common sense measures. 

By reading many of the comments here, it would seem like Virginia is in the stone age when it comes to energy conservation improvements. Nothing could be further from the truth. We have made significant improvements in the energy conservation of our homes and businesses over the past decade. So many improvements that we can barely keep up with them. The BHCD is listening and Virginia is getting another set of improvements to energy conservation efforts in the 2012 Codes. I have a hard time accepting that the measures we are taking today are not good enough. We do not even know the long term affect of our efforts....because there hasn't a long term to evaluate! I dare say we can effectively evaluate where we are right now, especially since the improvements proposed are based on calcualtions and assumptions, not actual data from every part of the country.

There is nothing that will prevent a new home builder from doing more than the code mandates. The Uniform Statewide Building Code is the MINIMUM safe standard. If you want to sell energy conservation, then sell it to the consumer. Make them want to choose to install a higher SEER heat pump than is required. Show them the savings involved with higher R values, fewer air changes, and better U factors in windows.

There have been many to testify to the savings incurred by making energy improvements to their homes. Great! But it was their CHOICE to make those changes. Others build homes with marble countertops, building a larger deck, putting in a swimming pool, paving a driveway or building a home theater. The key is, its the consumers choice, as it should always be.

This is not a question of consumer choice.  This is a question of saving our environment, for all of us, not just for the owner of one home.  Precisely because homeowners are ofter unaware of the hidden values of better building techniques is why we have building codes in the first place.  Just as building codes help keep chimneys from catching fire and floors from falling in, better building efficiencies make the environment safer for all of us.  Now that better insulation is available, why not require it in the building codes?  Because ductwork often leaks from the very beginning, it needs to be properly tested before the house is put on the market.  These are no-brainers, but invisible to the potential home-buyer.  That's why the homebuilders don't want them, because home buyers don't see them.

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.

I have had my duct work inspected, NOT visually, and found places where heat was leaking and had them fixed.  I have also upgraded my insulation in my house on the advice of an inspection for energy savings and find my 80+ year old house is much warmer now.  We all should be making the improvements that we can to save energy costs and protect the environment, and lessening the requirements for home building energy efficiency is just silly!

I am opposed to weakening energy efficiency building codes in Virginia. The Board of Housing and Community Development should follow the national model building code provisions that would improve the efficiency of Virginia residences by as much as 27.4%, according to analysis by the U.S. Department of Energy.

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

andrew.grigsby@commonwealthsustainability.com

540/219-8912

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

Website: www.commonwealthsustainability.com

LEAP is the sponsor of the Home Performance with ENERGY STAR program in many areas of Virginia.  The home performance contractors in our areas have been using the 2012 model code in retrofitting existing homes in our areas for three years with great success.  The strategies are affordable and effective - and homeowners are very pleased with their savings and comfort improvements.

Stricter energy codes provide for lower energy use and improved occupant comfort and health.  Energy is not and will not be getting cheaper.  I have performed scores of energy audits, most of these are driven by high energy use and the associated high cost.  We also hear many comfort complaints due to poor duct design and issues with the insulation and thermal bypasses.   I have audited both new and existing homes in over a dozen counties across Virginia and my experience has shown that inspectors were not able to identify thermal bypass issues, shell and duct leaks or improper insulation installs all of which end up causing higher energy use and comfort issues. 

As a energy retrofitter I can't tell you how many older house that we have upgraded just to get to minimum standards. Lets not do what our parents did, and be responsible to future generations, by conserving their resources and pass on houses that are responsible to energy usage.  The upgrades that are proposed really do not add that much cost considering the long term savings. We are rethinking the way we build from the ground up.

It  would be irresponsible to ditch suggested energy efficiency requirements.  Production builders will certainly resist implementation of anything that slows a project or costs a penny, they tend to be strictly bottom line driven since many answer to stockholders ..... do not listen to them.  Look forward as visionary leaders and implement all facets of future codes to give new homeowners a place they can afford as our energy costs rise.  I have been involved in remediation projects where real savings of 70% have been realized at great costs to homeowners, the homes were not that old, just poorly built.   

Please make the common sense decision. Let's look at the future. Utilities are not going down and we have to do everything we can just to keep what we have. Affordable homes means affordable homes, not having utility bills matching  your house or rent payment. Let's not take away anymore hope away from the next generation.

It's up to you. Don't be persuaded by the ones that can't or won't think out of the pocket. Do the right thing.

Your average American  concerned citizen.

Don Mowry

It is really quite shocking that the Board is even considering amendments that would wekean the 2012 IECC code to be adopted in Virginia.  It's shocking because it defies logic, intelligence and even basic economics.

Improving the code will save everyone money.  Unfortunately the National Association of Homebuilders, through their Virginia affiliate, have pushed through amendments to weaken the code and therefore negatively influence homeowners, the environment and Virginia's economcy. 

Energy efficiency works. It creates jobs, saves money and reduces our impact on the environment.  Contrary to what I've heard coming from the NAHB for the past 30 years (they have an arrogant disregard for logic and common sense), people love energy efficiency.  A tighter, better built home is better for everyone!  NAHB ignores operational costs when it falsely claims that code-required efficiency improvements cost more.  Such improvements pay for themselves in a few years. 

I urge the Board to reject all insulation R-value reductions proposed. I urge the Board to require blower door and duct blast tests for all new construction. This will increase the quality, safety, reliability, and comfort of new residential construction.  I urge full adoption of the 2012 IECC Code without the weakening amendments proposed by the NAHB and it's Virginia lobbyists.  

Finally, given energy efficiency's potential to reduce dramatically our energy demand, I urge the Board to extend the public comment period on this matter for two months so that more citizens have an opportunity to voice their concerns.  Many people did not hear about this matter until last week.  Giving people 60 more days would assure the Board that ample time was allotted for public input.

Thank you for your service to Virginia.

Sincerely,
Jason Halbert

Business owner, home owner, Virginia resident

I find it hard to believe that the adoption of these energy codes  are  even at issue.  Those of us in the building industry  know that practices such as those identified in the 2012 code changes will significantly reduce the energy useage and improve home comfort of residential buildings. We are a not for profit home builder that builds for the less fortunate.  My major charge is to build a simple affordable home who's cost of ownership, read as energy useage, is the absolute minimmum I can produce. I have been building homes for Habitat using most of these practices for the past 10 years and am totally committed to continue these practices even if the code does not call for it. Homeowners of the homes we build with these practices report significantly lower utility costs than similiar homes not built under the   same  practices.  We know energy costs will increase in the future, we must get ahead of the curve and not play catchup with building practices we know work now. As a not for profit builder ,I am very concerned about keeping my costs of construction to an absolute minimum,and I know full well that some of these practices cost more, but we are   committed to keeping our homeowners cost of ownership to the absolute minimum we can afford to build, and  we can certainly afford to build to these practices and even more stringent practices..