In my previous post, I shared the top commercial energy code proposals introduced in May at the International Code Council’s (ICC) 2019 Committee Action Hearings that represent big wins for building efficiency proponents. Below are key energy proposals that did not make it through but may resurface in October.
In addition to the work in favor of efficiency there remained notable opposition and attempts to roll back the efficiency of the current code. Additionally, some losses were felt on the side of grid interaction and the merging of energy efficiency and renewables that would be valuable to jurisdictions looking to integrate these areas into their codes. Here are some of the other key proposals IMT will be watching closely as we move through the rest of the development cycle.
Attempts to weaken the code
The commercial energy code performance path currently limits the amount of on-site solar generation a new or renovated building can count as a trade-off. The intention of this limit is to focus on improving the efficiency of the building and its systems first, before turning to generation. Without a backstop, it would be possible for a developer to meet the code with an inefficient and low-performing building because it receives 100% of its electricity from an on-site solar installation. This is similar to putting a brand new sail on a leaky and sinking boat. Although IMT fully supports and recognizes the importance of on-site solar generation to meet long-term goals of net-zero energy construction and carbon reduction, we also believe investing in energy efficiency first is a critical step to meet those goals. Therefore, we support the committee’s disapproval of the elimination of the solar backstop on the performance path.
Roofing Replacements and Upgrades
Several proposals were put forward to reduce the requirements for building renovations that take on roof replacements and re-roofing. Proponents testified that additional flexibility is required for renovation projects because existing buildings may not be able to accommodate new levels of roof insulation required by a modern energy code. Opponents pointed out that the code already gives certain exceptions for existing building envelopes, and provides jurisdictions the power to grant code modifications for individual circumstances. These proposals were disapproved across the board.
Most buildings undergoing construction are existing buildings. Keeping the number of exceptions for renovations low is critical if cities want to meet their climate and energy-use reduction goals. As cities look to new models of regulating the energy use of existing buildings, the code will need to minimize these types of exceptions to help owners to meet more stringent performance standards.
Recognizing Grid Interaction
A solar appendix was proposed to set a minimum amount of required on-site solar based on the size of the building. Cities are looking for off-the-shelf solutions to include solar energy requirements in their building codes because they often do not have the time or capacity to modify base codes or undertake studies to understand the appropriate amount of solar to put on buildings. A national model standard in the form of an appendix to the energy code is a step in the right direction. It will provide a vetted solution to those jurisdictions that are looking to take the next step, but will not be required to be adopted by all.
IMT joined in a handful of collaborative working sessions during the hearings to address major concerns of efficiency advocates. After working together to develop language for backstops protecting both the additional efficiency options and the performance path, a conclusion could not be reached. Debate in front of the committee on opposing scoping language sent this proposal back to the drawing board. IMT is excited to work with SEIA and other partners to present a solution in public comment for the final action hearings.
Proposals to allow energy storage failed on the floor due to concerns over coordination with the fire code and a few confusing floor amendments but will likely revisited in the public comment period. With the addition of generation to more and more buildings, combining generation with storage is the next step toward buildings contributing to grid optimization. A building that can shift its peak loads to pull from storage will help change the peak demand on the grid, which may reduce the need for new generation as more buildings come online. The committee acknowledged that on-site storage is going to be essential for effective use of energy, providing resilience, durability, and long-term use of buildings.
Follow us as we monitor the progress of the 2021 IECC through to the end of the Public Comment Hearings in October.