Regulatory Submissions

On December 30, APGA filed comments in response to the International Code Council’s (ICC) invitation to provide public comments on how to improve the International Energy Conservation Code (IECC) standards development process.  The comments were jointly filed with the American Gas Association and National Propane Gas Association.

Through the comment letter, APGA and the other associations raised a number of concerns that should be addressed in future development cycles of the IECC.  Requested revisions included prohibiting the grouping of code change proposals in “omnibuses” and requiring all necessary data associated with a proposal to be submitted before its consideration, as well as ensuring the consensus committees are appropriately balanced.  APGA also urged ICC to strive for ANSI accreditation, as it would help ensure the integrity of the code.  Some of these same concerns were also raised in APGA’s recent appeal of a number of 2024 IECC provisions.

Additionally, APGA and others supported two proposed changes to the process put forward by ICC to help increase efficiency of the IECC’s develop process:

1. The approval of changes to the draft will require a two-thirds majority vote of the consensus committee at all phases.

2. Public Comment Draft #1 (4b) and Public Comment Draft #2 (4c) will only be open for comments on substantive technical changes made to the immediate preceding draft published for public comment.

While APGA believes these are important improvements, the joint letter makes it clear that additional changes are needed to ensure a transparent and fair IECC development process.