Thank you for your consideration of my comments regarding the Virginia Uniform Statewide Building Code (13 VAC 5-63).  I support the full adoption of the 2012 and 2015 IECC provisions.  If full adoption is not possible, I encourage you to adopt the following provisions:

• Building envelope tightness:  VA USBC should require duct blaster and blower door tests, rather than using visual inspections.
• Duct gaps:  Ideally, ducting in new construction should have zero leakage.  As with the building envelope tightness testing, testing for duct gaps should not be through visual inspection.  Code amendments should include a mechanical duct blaster test.
• Insulation:  insulation R values should be increased to 20 for wall insulation and 49 for attic insulation.

Since many residential buildings are expected to last between 75 to 100 years, the decisions made today affect future generations.  Nationally, non-manufacturing buildings account for about 1/3 of CO2 emissions and 70% of electrical consumption.  These new suggested provisions are critical to reducing Virginia’s carbon footprint.