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APGA Responds to 2027 IECC Draft Scope and Intent

By Sydney Novoa posted 08-22-2024 11:22 AM

  
On August 19, APGA submitted comments in response to the International Code Council’s (ICC) 2027 International Energy Conservation Code (IECC) Draft Scope and Intent. APGA would like to thank Philadelphia Gas Works (PGW) for submitting supportive comments in response to the draft as well. 
 
The intent and the scope of the IECC should provide energy conservation measures regardless of energy source. The present draft scope and intent appears to allow consumers to choose the appropriate appliances and energy sources that suit their needs. However, APGA iterated that the preservation of consumer choice should remain in the finalized 2027 scope if any edits, based on feedback received during this comment period, are made to the finalized 2027 scope. APGA is encouraged by the ICC Board commentary, which expresses the need to preserve consumer choice. It would be ideal to have the ICC explicitly codify that sentiment from the Board commentary, which will reduce the chance for misinterpretations of the IECC’s scope and intent in the future. Unfortunately, there will likely be further efforts to use the IECC to restrict natural gas use in buildings. 
 
Additionally, APGA argued added complexity in the base code will hinder smaller jurisdictions with less resources from adopting and implementing the code. Furthermore, any inclusion of provisions that do not conserve all energy sources in the base code may present additional confusion and result in the adoption of a code that is not permissible under federal law or state law, if that state has passed a consumer choice bill. This could open an adopting jurisdiction to legal challenges. 
 
As a reminder, the ICC Board of Directors developed a draft scope and intent for the 2027 IECC based on feedback from the 2024 IECC appeals process. The ICC Board of Directors also provided commentary on the revisions made to the scope and intent. The ICC sought comment on this draft and following review and consideration of the public comments, like those submitted by APGA, the Board of Directors will set the final scope and intent statements for the 2027 IECC. 
 
APGA staff will keep the Codes and Standards Committee updated on future developments on the 2027 IECC. Please join this committee if you are interested in this and other codes and standards efforts. 
 
To read the submitted comments, click here.  
 
For questions on this article, please contact Sydney Novoa by phone at 202-464-0834 or by email at snovoa@apga.org. 

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