Overcoming Codes and Standards Barriers to Innovations in Building Energy Efficiency
Building codes have really motivated builders to increase the energy efficiency of new homes in recent years. But as quickly as the codes are changing, new products are coming to the market even faster. Sometimes these new products make possible approaches and construction techniques that were unknown when the current code was first proposed—which might have been several years before it was adopted by various jurisdictions. Due to this delay, the codes themselves can become barriers to innovations that might further increase the efficiency, comfort, health, or durability of new homes.
One good example is the codes that govern unvented crawl spaces. As recently as 2003, the wording in the International Residential Codes (IRC) specified crawl space ventilation but was silent about unvented crawl spaces. Researchers working with the U.S. Department of Energy (DOE) found that the use of unvented crawl spaces minimized the risk of moisture problems in humid climates. The IRC code language has since been changed specifically to allow unvented crawl spaces.
If you are a builder or contractor, you may have run into code barriers yourself. Perhaps you have attempted to use a new product or technique that your building inspector wasn’t familiar with, or that wasn’t addressed by code, so your approach was denied. A code barrier could be any requirement in a code or standard that prohibits or discourages an innovation. Sometimes the fact that the code just doesn’t address an innovative technique is enough to act as a barrier.
There are ways to work through code barriers. DOE’s Building America, a program dedicated to improving the energy efficiency of America’s housing stock through research and education, is working with the U.S. housing industry to help builders identify and remove code barriers to innovation in the home construction industry (see “Building Energy Codes Program Help Desk” and “Building America Success in Code Adoption”). In a recent report published by Building America, we identified five approaches builders can take to work through barriers to getting energy-efficient innovations approved.
Building Energy Codes Program Help Desk
The DOE Building Energy Codes program operates a help desk that builders, contractors, and code officials can use to get help with building energy code questions. Author Pam Cole has personally fielded more than 46,000 calls and e-mails to the help desk over the past 14 years, responding to requests for information and answering questions on all types of building related-topics. If you have a question, contact the help desk.
The program’s website, www.energycodes.gov, also contains a wealth of information. Check here to download free software tools (REScheck and COMcheck) to help simplify and clarify compliance with the model energy codes and standards for residential or commercial buildings, find out what energy code version is in force in your state, or download publications and training materials that may be pertinent to your technology.
Search codes resources. The Building America Solution Center contains code compliance briefs for some innovations that are known to have code barriers. (For example, see the code compliance brief on double wall framing.) DOE’s Building Energy Codes program has code notes that address dozens of topics related to code issues. Check here to see if others have dealt with an issue similar to yours.
Look for an alternative-methods clause or plead special circumstances. Check the code for any language allowing an alternative approach or exception, or plead special circumstances with the code official. Be prepared to explain the innovation in clear and understandable terms that address any risks that might be associated with use of that innovation. Some jurisdictions have forms that builders and contractors can fill out to request consideration of alternative materials or approaches.
Refer to a newer version of the code. Check to see if the latest version of the code or standard has language covering the innovation you want to implement, even if the version has not yet been adopted by your jurisdiction. The code official may be swayed by the fact that the organization that created the code has seen fit to accommodate the innovation in future code versions and may accept your request.
Building America Success in Code Adoption
Building America’s research teams have been instrumental in getting several innovations adopted into code. Here are just three examples:
Thermal Bypass Checklist
Although air sealing of building enclosures has been part of the energy codes since ASHRAE Standard 90-75, the forerunner of almost all U.S. energy codes and standards, the language of the requirement left quite a bit of room for interpretation on how, where, and what air sealing should be installed. Building America researchers worked with code organizations through three three-year code cycles to get a detailed thermal bypass checklist included in the 2009 International Energy Conservation Code with blower door leakage limits or visual inspection requirements. This was revised in the 2012 IECC to require a blower door test with more stringent leakage limits.
Unvented Crawl Spaces Allowed
Crawl space ventilation was once required by codes throughout the United States. Yet ventilating crawl spaces has been shown to waste energy and increase moisture problems in homes in humid climates. Building America research led to the adoption of unvented crawl space provisions in model codes, encouraging builders to insulate crawl spaces for savings of up to 20% in heating and cooling energy and substantially reducing the risk of moisture problems.
Building America-sponsored research led to code changes that defined vapor control smeasures more precisely and paved the way for the codes to clearly specify climate- appropriate vapor control strategies, reducing moisture risks in insulated building assemblies. These changes are encouraging builders to use climate-appropriate vapor retarders to reduce the likelihood of moisture damage in hundreds of thousands of new homes built each year. See Figure A.
Ask for an interpretation. Ask the code organization for an interpretation as to whether your innovation conflicts with current code. All codes-, standards-, and ratings- writing organizations have a process whereby technical questions related to their documents can be answered. A favorable interpretation by the code body will often persuade a code official to allow the innovation. See the following links to submit questions to the appropriate codes and standards organization:
- ASHRAE: Published interpretations. Request a new interpretation.
- International Association of Plumbing and Mechanical Officials (IAPMO).
- International Code Council (ICC).
- National Fire Protection Association (NFPA).
- Sheet Metal and Air Conditioning Contractors National Association (SMACNA).
Another good, but potentially costly, option is to hire an organization like the International Code Council Evaluation Service (ICC-ES) to look at a proposed innovation and identify potential issues the innovation may face within the family of ICC I-codes. If no issues are found, an ICC-ES report can be a powerful tool to use in convincing code officials that the innovation is permissible. Get more information on the ICC-ES. See a complete list of evaluation reports ICC-ES has produced. IAPMO offers a similar service.
Cole, P. C., and M. A. Halverson. Building America Guidance for Identifying and Overcoming Code, Standard, and Rating Method Barriers, PNNL-22755. Download a copy of this report.
Learn more about DOE’s Building America Program.
If you have dealt with a code barrier related to an energy efficiency innovation, or if you are dealing with one now, we would like to hear from you. Please contact Building America’s Codes and Standards Innovation team.
Get the code or standard changed. This long-term approach involves drafting new text, providing an analysis of and documenting justification for the change, engaging stakeholders and addressing objections, and providing expert testimony at hearings. This is a lengthy process with no guarantee of success. However, there are many organizations interested in residential energy efficiency that may be willing to take up the cause if you identify a barrier to a significant energy-saving technology and can provide relevant documentation for an amendment. For example, DOE reviews the International Energy Conservation Code (IECC) and related standards for opportunities to save energy. DOE gathers supporting documentation for proposed changes, submits change proposals, and supports those proposals through the public hearing process. DOE also maintains membership on the ASHRAE 90.2 Standing Standards Project Committee. Get more information.
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