Mr. John Ainslie, Chair

Board of Housing and Community Development

Department of Housing and Community Development

600 East Main Street, Suite 300

Richmond, VA 23219

RE:  Comments on Virginia Uniform Statewide Building Code

Dear Chairman Ainslie:

Thank you for the opportunity to submit comments on the Virginia Uniform Statewide Building Code (13 VAC 5-63).  The Virginia League of Conservation Voters advocates for changes in the code to ensure buildings are more energy efficient to reduce Virginia’s carbon footprint.

Reducing carbon emissions through energy efficiency measures will help mitigate climate change, which is already impacting Virginia through increasing temperatures and rising sea levels.  Virginia cities are taking steps to reduce emissions and improve energy efficiency, and leadership through the implementation of a strong model building code will help local initiatives to succeed.  For example, Richmond announced a goal to reduce greenhouse gas emissions in the city by 80% by 2050 and Arlington has an initiative to reduce its emissions by 25% by 2020.  State executive actions also encourage strong energy efficiency measures.  Both the Governor’s Executive Order 57 and Executive Committee on Energy Efficiency highlighted the need to update energy efficiency building codes.

A comprehensive model code will have a tremendous impact.  The U.S. Energy Information Administration has found that buildings consume about 40% of the energy in the country.  Nationally, more efficient measures could allow home and business owners to save “an estimated $126 billion and [and achieve] 841 million metric tons of avoided carbon dioxide emissions through 2040,” according to the U.S. Department of Energy, and such savings “equate to the annual emissions of 177 million passenger vehicles, 245 coal power plants, and 89 million homes.”

Requiring mechanical testing, such as duct blaster testing and blower door testing, and not relying on visual inspections will allow for accurate evaluations of air-tightness and energy losses.  We recommend that the building code is updated to at least meet the 2015 International Energy Conservation Code standards, and if the standards are not adopted in their entirety now then we encourage the inclusion of the best practices from the model codes during this process. 

Sincerely,

Mike Town

Executive Director