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Building Energy Codes Program

DOE Public Comments
for the 2007/2008 ICC Code Development Cycle


The U.S. Department of Energy (DOE) has submitted six Public Comments for the Final Action Hearings in the International Code Council's (ICC) 2007/2008 Code Development Cycle. These hearings will be held in Minneapolis, MN this September. The DOE comments pertain to the International Energy Conservation Code (IECC) and International Residential Code (IRC). The referenced proposals apply only to residential buildings.

Two of the proposals aim for energy efficiency improvements in both the IECC and IRC (EC64 and EC72). Three proposals would bring major efficiency improvements already approved in the IECC at the Code Development Hearings last February into the IRC as well (EC71, EC18, and EC22). One proposal cleans up basement and crawlspace U-factor requirements in both the IECC and IRC (EC42).

DOE also intends to vigorously defend energy efficiency improvements approved at the Palm Springs Hearings if these are challenged. DOE originally submitted 17 proposals at the beginning of the code development cycle started in August 2007. These proposals can be viewed at DOE Code Change Proposals for the 2007/2008 ICC Code Development Cycle. DOE welcomes an open dialogue on improving energy efficiency in building codes. If you have thoughts or suggestions on DOE's proposals or on energy efficiency codes in general, please contact Ronald Majette.

The six Public Comments are provided below.


Further improvements in energy efficiency in both the IECC and IRC:

  1. EC64: Delete the "visual inspection option" for air sealing, requiring pressure testing to confirm that the building envelope air leakage is below a reasonable limit.

    Public Comment Form EC64 (PDF 129 KB).

  2. EC72: Ban the practice of using building cavities as return air ducts.

    Public Comment Form EC72 (PDF 37 KB).

Energy efficiency improvements for the IRC that are already approved in the IECC:

  1. EC71: Verification of duct sealing by pressurization test in the IRC. This would require duct systems that are not fully inside the conditioned space to be tested to ensure that air leakage is below a reasonable limit. Although the code already requires that ducts be sealed, its' lack of verification requirements results in a continued problem of excessive duct leakage in residences.

    Public Comment Form EC71 (PDF 46 KB).

  2. EC18: Further reduce vertical fenestration U-factor requirements from 0.65 to 0.50 in climate zone 2 and 0.55 to 0.40 in climate zone 3 in the IRC. These lower U-factors have already been approved in the IECC by code change EC16.

    Public comment Form EC18 (PDF 45 KB).

  3. EC22: Reduce maximum allowable SHGC from 0.40 to 0.30 in climate zones 1, 2, and 3 in the IRC. This would bring the IRC into agreement with the IECC as modified by EC26.

    Public Comment Form EC22 (PDF 43 KB).

Code Cleanup:

  1. EC42: Remove ground conductance from foundation U-factor requirements in Table N1102.1.3 of the IRC. Adjust U-factor requirements to properly account for approved changes EC33 and EC36 in the IECC. EC42 does not change code stringency.

    Public Comment Form EC42 - Part I (PDF 43 KB).

    Public Comment Form EC42 - Part II (PDF 44 KB).


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