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The ICC’s
Nightmare
on Elm Street

The trade-off loophole in the proposed 2018 IECC may

earn first-ever “negative” determination from DOE.
IBY BILL FAY
               N THE 2009 IECC, the ICC’s Governmental Member Voting         2012 IECC and again during hearings on the 2015 IECC.
               Representatives (GMVRs) closed the equipment trade-off          Like Freddy Kruger, the ETO is the loophole that just won’t die.
               (ETO) loophole once and for all. This was good news:            This year, a builder-stacked and builder-dominated Residential
               An analysis by ICF International, one of the world’s leading
               energy analytics firms found that stopping equipment          Energy Committee once again recommended reinstating the ETO
               trade-offs added at least 6-9 percent to the 2009 IECC’s      (RE134), then added its support for two other trade-off loopholes for
               already historic 12 percent boost in new home efficiency.     windows and lighting.

                                                                               Not only are trade-offs a zero-sum game at best, but with very few
                                                                             proposals that boost efficiency, these three trade-offs could end up
                                                                             sinking the 2018 IECC, itself.

Furthermore, the analysis found that an individual home                      RE134 will add at least 6-9 percent to new home energy use. The

built using all available equipment trade-offs could have consumed as ETO allows a builder to weaken a new home’s envelope features—

much as 22 percent more energy than a home that didn’t use them. most of which will perform for the 80- to 100-year life of the home—in

Did I say “once and for all?”                                                exchange for installing more efficient equipment that may last 20-25

Actually, efficiency opponents have forced the GMVRs to vote three years. In other words, when the equipment is replaced after a few

more times on the ETO loophole – twice during consideration of the years, the trade-off home with the weaker envelope will continue

22	 GREEN BUILDER  November/December 2016                                   www.greenbuildermedia.com
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