Agencies | Governor
Virginia Regulatory Town Hall
Department of Housing and Community Development
Board of Housing and Community Development
Virginia Uniform Statewide Building Code [13 VAC 5 ‑ 63]
Action Update the Uniform Statewide Building Code
Stage Proposed
Comment Period Ends 5/26/2017
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5/10/17  11:18 am
Commenter: Ross Shearer, Vienna VA

A case for adopting all the IECC’s energy efficiency provisions

In its consideration of the Virginia Uniform State Building Code (VA USBC), the Board of Housing and Community Development should adopt all of the energy saving recommendations of the 2012 and 2015 International Energy and Conservation Code.  At the minimum the VA USBC should require the duct blaster and blower door tests by eliminating the current exemptions permitting a visual inspection in lieu of the actual mechanical tests.  It should also adopt the IECC’s leakage rates, which are lower than those currently allowed by the VA USBC) and the IECC’s higher insulation R-values for exterior walls (R20) and ceilings (R49). 

The VA USBC section 102 purpose states that buildings “should be permitted to be constructed at the least possible cost.”  Permitting to the “least possible cost” includes constructing to control the costs of ownership, which the current, and proposed code fail to do. The costs of the additional 2012 IECC energy efficiency provisions typically provide a rate of return on investment that beats the long-term average of the stock market. The Department of Energy estimated a Virginia statewide average savings of $388 for every newly built residence had the BHCD adopted the entire 2012 IECC compared to the 2009 code.  In practice these savings are likely much greater than estimated because the DOE calculation assumes an average compliance with the 2009 leakage limits for the building envelope and duct. That is highly unlikely in view of the higher thermal leakage rates of untested structures. 

Addtionally, there are these considerations:

The Benefits: Efficient homes save on utilities, usually present a more enjoyable and healthier interior experience, and reduce adverse public health impacts, and their associated costs, from the air pollution of conventional electricity production.

Consumer Information: Virginia’s homebuilders should be transitioning towards adoption of the Home Energy Rating System (HERS). The blower door and duct blaster tests are components for obtaining the HERS that informs the residential consumer market about the energy demands of houses. Requiring this test with its companion duct blaster test would nudge the real estate sales industry in Virginia’s major metropolitan areas to further expand its recognition of the Home Energy Rating System (HERS) so that prospective home buyers and tenants are informed about the energy requirements of houses on the market.

An economic stabilizing force for families and neighborhoods: The University of North Carolina’s Center for Community Capital disclosed in a 2013 study (with 99% confidence) that the higher the efficiency of the house, the lower the mortgage default rate.  The study was based on comparing Energy Star built homes against those that were not ES rated.  Energy Star requires the mechanical blower door and duct blaster tests. Other studies show that houses certified efficient retain better resale value.  Both these factors contribute to community and family stability.

Climate Change and Acidification of the Earth’s Oceans:  I see no evidence that the BHCD’s decisions on energy efficiency are influenced by the impacts from global warming that civilization faces, all due to our current dependence on fossil fuels for production of energy required to heat, cool and run our homes.  Much of coastal Virginia is threatened by sea level rise, so the Commonwealth has much at stake in adopting policies to, as a minimum, do its fair share.

The Center for Climate Change Communication at politically conservative George Mason University reports this year that its surveys show that nearly 70% of Americans “say the U.S. should participate in the COP21 (Paris Climate) agreement”, that global warming is happening and that “global warming is a threat to future generations”.  Earlier surveys reveal that about 50% of Americans believe warming is mostly due to human activities and about 1/3 think of it as a moral issue.  These rates would be higher if more Americans knew that almost all (over 98%) climate scientists have concluded, “Human caused climate change is happening”.  Because of the fossil fuel industry’s disinformation campaigns, only one in seven Americans is fully aware of the high level of scientific consensus.  With time, that level of misunderstanding will drop.

In view of the above, adoption of the basic cost-effective energy efficiency requirements is a minimal step that deserves the Board’s full support.

Governance:  The Commonwealth came under national criticism recently over the integrity of its governance structure.  Much of the criticism was based on simplistic criteria and misunderstandings that failed to appreciate how Virginia’s government is organized.  But there is a legitimate beef about governance when a Commonwealth’s organizational mechanism fails to adopt rules that benefit families, save them money and enhance the financial stability of neighborhoods.  

Being Prepared for the Future:  Has the BHCD done what it should to prepare Virginians for a future energy economy to be transformed by a future carbon tax?  Clearly not, as it has rejected the recommendations of the IECC that are highly cost effective within the current market price economy.

The following is restated from my posts on the cdp VA system:

Blower door statement Air Sealing R402.4.1.2:  I agree with Mr. Grigsby’s proposal to remove the visual inspection option R402.  New homebuilders cannot fulfill their required warranty that the structure meets the minimum air change rate, absent the dynamic testing by an independent blower door professional.   In my discussions with northern Virginia builders participating in Energy Star, I have been told that houses initially fail (either the blower door, the duct blaster or both tests) about 25% of the time.  Building without any intention of using the dynamic test must yield a very high failure rate with needless long-term energy costs and reduced comfort for homeowners and tenants. 

Duct Blaster Statement CE-R403.2.2 cdpVA-15: There is considerable merit to Mr. Grigsby’s proposal to remove the visual inspection option R(403).2.2.2.  Absent the dynamic testing, no new homebuilder can assure buyers of its required warranty that the duct is sealed to comply within the code’s maximum air leakage rate. This matters because ducting usually penetrates the building envelope into the attic or crawl space. A visual inspection cannot be an adequate substitute for detecting what is not viewable. 

Loss of conditioned air with the resultant draw of unconditioned air through leaky areas of the building’s envelope should be minimized.  Homeowners and tenants should not be condemned for the life of the building to pay the costs of this avoidable waste when the remedy is the cost-effective duct blaster test requirement.