APGA Continues Participation in the IECC Appeals Process

By Sydney Novoa posted 20 days ago


This week, APGA, along with several members, engaged in the International Energy Conservation Code (IECC) 2024 appeals process by indicating intent to present or submitting written comments to the International Code Council (ICC) on how a number of code provisions, in its current form, have violated ICC's process and procedures. 

The members that commented were Rinnai, Middle Tennessee Natural Gas Utility (MTNG), Philadelphia Gas Works (PGW), and the Municipal Gas Authority of Georgia (MGAG). APGA would like to thank these members for their engagement on this important issue. If you are not listed but did submit comments, please let APGA staff know.

On January 2, APGA filed an appeal as part of the IECC 2024 appeals process. The filed appeal raised the concern that a number of the proposed provisions for the code would be outside the scope and intent of the IECC. The appeal also raises concerns that the proposed provisions were developed in violation of due process and International Codes Council (ICC) procedures and would be federally preempted. The contested provisions include “electric/EV/solar-ready” provisions and “all electric” appendices.

This week’s effort allowed interested parties, or their representatives, to respond to all the appeals submitted in January. Any comments submitted by the deadline will be considered by the ICC Appeals Board. There will also be an opportunity to present information in support of or against any appeals during the ICC Appeals Board hearings on February 21-23.

As ICC’s codes will be adopted at all levels of government, it is vital that ICC’s development process for the IECC be fair and transparent - a standard that APGA contends ICC did not meet during the development of the 2024 IECC. Such process violations have resulted in many provisions that would inhibit Americans’ ability to choose the direct use of natural gas in their homes or businesses.

Furthermore, APGA supports the transparent development of building codes and standards, such as the IECC, through consensus-based processes that follow the tenets of due process and fair competition. However, APGA is concerned that numerous provisions were inappropriately processed for inclusion in the 2024 version of the code. Consequently, APGA believes they must be removed.

APGA will be presenting at the ICC Appeals Board hearings, so more information on future actions will be provided. If you want to view the Appeals Board hearings live online, the links to watch will be posted on the 2024 IECC Appeals web page.

For questions on this article, please contact Sydney Novoa of APGA by phone at 202-464-0834 or email at