Page 15 - CodeWatcher Fall 2016 Issue

2018 IECC Public Comment Hearing

Mechanical Equipment Tradeoff
T HIS DEBATE HAS BECOME a triennial
tradition. This particular tradeoff was first ERI path of the residential energy code. One executive we
removed from the 2009 IECC, but this spoke with called it “disingenuous” for proponents of the
argument has returned for every code cycle ERI path to also oppose an equipment tradeoff. Another
since. Each time, the governmental voting person noted that window tradeoffs are already allowed,
members have voted to keep it out of the model some states have chosen to amend their energy codes to
allow equipment tradeoffs, and many above-code programs

code. At this year’s code development hearing, also allow an equipment tradeoff.

the committee approved this proposal. However, there was Both sides of this debatewould probablyagree that changing

an assembly motion to disapprove, and after a round of the NAECA standard would go a long way towards ending

online voting, 57% of voters agreed, so

the proposal was disapproved.

In RE-134, NAHB is taking a

slightly different approach than their

past three attempts to reinstate this

tradeoff. They have proposed a UA

backstop. Using a 115% multiplier, this

would not allow a thermal envelope

less than (approximately) a home built

to the 2009 IECC. (In some climate

zones, it would be more stringent

than the 2009 IECC, while in others

it would be less stringent.) There are

also seven public comments attached

to this proposal, though most are

seeking disapproval.

According to one executive we

spoke with, the problem resides

with the NAECA standard. Because

80 AFUE is the lowest allowable

(new) furnace rating, and nearly all Credit Christian Delbert

furnaces installed in cold climates

are 90 AFUE (or higher), a lot of credit

would be given for something that’s

already viewed as either necessary

or commonplace in the market.

Therefore, if an inordinate amount of credit is given, this seemingly never-ending argument. To get the NAECA

insulation levels could be lessened. That would lead to less standard changed takes an act of Congress! (Seriously; it

efficient thermal envelopes, which would in turn make the needs their approval.) The Department of Energy could have

efficient equipment run more often than would otherwise spearheaded the update long ago, but faced resistance from

be needed. the gas industry. It appears as though something may finally

Other proponents of RE-134 point out that such a tradeoff change on this front but not for another four or five years

is allowed in the commercial energy code, as well as the at the soonest.

The topics above, plus many other proposals, will get sorted out in Kansas City in late
October and then online throughout November. It is our hope that the governmental
voting memberreps take in as much information as possible before casting theirvotes.

www.codewatcher.us Mike Collignon is the executive director and cofounder of the Green Builder Coalition.
Fall 2016 / CodeWatcher 15