Virginia Regulatory Town Hall
Agency
Department of Housing and Community Development
 
Board
Board of Housing and Community Development
 
chapter
Virginia Uniform Statewide Building Code [13 VAC 5 ‑ 63]
Action Update the Uniform Statewide Building Code
Stage Proposed
Comment Period Ended on 5/26/2017
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Previous Comment     Back to List of Comments
5/26/17  5:03 pm
Commenter: William Penniman

Building Code
 

As a citizen of Virginia and someone who has spent a career working on energy issues, I strongly urge Virginia to adopt the full 2015 International Energy Conservation Code, including the requirement for blower door testing.  Failure to adopt the full code will harm Virginians as home buyers because their homes will be less efficient; will harm them as consumers because their costs of utility-supplied energy will be increased by unnecessary demand; and will harm them as residents whose air, water and climate will be harmed by avoidable energy combustion.

Permitting builders to use "visual" testing in place of blower door testing is equivalent to allowing car manufacturers to rely on visual inspection of brakes.  It is meaningless, and the results will be hidden from the buyer by finished walls and insulation.  They will experience potentially decades of higher energy costs as leaks require them to buy more energy and pay for costly repairs if they ever learn of leaks that should never have been built into a home.  Those lifecycle costs are harmful and should be avoided. Looking only at "first costs" to a builder deprives consumers of the least cost solution to home-ownership or occupancy over the life of the home.

The Governor's Executive Order 57 and Energy Efficiency advisory committee have recognized the importance of improving building energy efficiency.  Now is the time to do it with adoption of the full 2015 energy effficiency standards.

William Penniman, 2007 Upper Lake Dr., Reston, VA 20191

CommentID: 59554