Background

Model building energy codes are developed by private standards organizations such as the International Code Council and the American Society of Heating, Refrigerating and Air-Conditioning Engineers, are updated every three years, and are then available for adoption by state and local governments. While the federal government does not “adopt” codes, the Department of Energy (DOE) plays a significant role in their development and also works with states to encourage adoption and enforcement. However, DOE’s role in building energy code development has been expanding, moving beyond its original authorization of “technical advisor” to pushing energy codes and, at times, even advocating for inclusion of certain products or technologies over others. 

Energy Codes Should Be Product​ and Technology Neutral

Some manufacturers have realized that by having their product mandated in a code, they can gain market advantage. For example, wall construction now favors foam sheathing over wood products in certain climate zones. Any code should be technology and product neutral, should not pick winners and losers, and should be a decision made by state and local authorities specifying expected performance. Once energy goals have been set by state and local officials, respective product industries should be given equal opportunity to demonstrate how their products contribute to meeting those goals.

AWC strongly believes that DOE should be limited to a role of “technical advisor,” seek only realistic energy goals, and not seek to give an advantage to any particular products/technologies. DOE should also return to the appropriate role of helping states implement energy codes chosen by individual states and training code officials and aiding compliance/enforcement efforts.