AGA Files Comments on 2027 IECC Draft Scope and Intent

WASHINGTON – The American Gas Association filed comments on the 2027 International Energy Conservation Code (IECC) Draft Scope and Intent document meant to address potential issues with both the process and the content of the code’s development. AGA strongly supports decreasing greenhouse gas emissions, and views improved energy efficiency as a key part of our strategy to do so. However, the comments reflect AGA’s view that the IECC – a code explicitly designed for the purpose of improving energy efficiency and decreasing energy use – should maintain a focus on measures that promote both.

The comments emphasize AGA’s “grave concerns that the IECC’s Draft Scope and Intent contradicts the IECC’s stated purpose of energy efficiency, violates the due process principles required of voluntary standard developers, is anticompetitive, and violates the Energy Policy Conservation Act.”

“We recognize that the ICC has made progress in addressing many of the significant problems with the previous process,” said AGA General Counsel Michael Murray. “What these comments make clear however is that we must make sure this process is fully transparent. We’re pleased that ICC has solicited public comment on this process, including in two earlier rounds of comments. However, the fact that the filed comments solicited in October or April haven’t been acknowledged or published for public review is concerning.”

In addition to a call for greater transparency and public accountability, the comments highlight the importance of keeping within the core stated purpose of the 2027 Draft Scope and Intent that all code provisions should:

• Provide market-driven, enforceable requirements,
• That deliver a reasonable level of energy conservation that is:
  • Safe,
  • Technologically feasible, and
  • Life cycle cost effective,
• Considering economic feasibility, including potential costs and savings for consumers and building owners, and return on investment.”

The second paragraph of the 2027 Draft begins by stating that “The code may include non-mandatory provisions incorporating additional energy efficiency and greenhouse gas reduction resources and provisions that lead to achievement of zero energy buildings.”

While discussions of specific greenhouse gas emissions reductions strategies are worth having, the IECC is simply the wrong forum. to warrant inclusion in the primary energy conservation code.  There must be evidence that shows how proposed methods would reduce overall energy use, rather than simply privileging one type of energy over another – particularly as in much of the country, the direct use of natural gas is the lowest emissions option available for home heating when properly measuring energy based on the full fuel cycle metric. If such provisions were to meet the relevant threshold for inclusion in the code, the comments make it clear that full-fuel-cycle analysis should be applied to the GHG emission reductions and zero energy buildings.

“Decreasing emissions is a priority for our industry. In service to this aim, we need an energy conservation code that retains energy conservation as its core guiding principle,” Murray concluded.