Flexibility for the Future

2021 IECC: Ready and Resilient | 2021 IECC: Commercial | 2021 IECC: Residential

As energy codes continue to advance, the need for flexibility is becoming increasingly important. It is clear that the requirements that are effective for all buildings in all climate zones are limited. Conversely, many potential requirements are very effective, but only in some climate zones or some building types or some building designs.

Flexibility provides a solution. By including multiple options that may be highly effective in some situations but not in others, the code can offer increasing energy efficiency while providing projects flexibility to choose the path to efficiency that works best for that project. This is at the heart of Section C406 in the commercial section of the energy code.

The following proposals advance the flexibility of both the commercial and residential parts of the energy code. They allow the code to improve the energy efficiency of buildings without adopting requirements that are not appropriate for all projects. Official public comments which suggest changes to the proposal are also included below.

CE218: C406 Points Option. Approved as Modified by Code Development Committee. The current additional efficiency package options (C406) are all considered equal in the 2018 IECC; however, there is a great deal of variation in the energy savings. This proposal modifies the “pick one” option requirement to introduce a point system that reflects the different savings potential (based on an analysis of the options by PNNL) of the different options based on climate zone and building type. This modification makes C406 more flexible and effective and allows for the addition of more options. Proponent for this proposal is Eric Makela, representing Northwest Energy Codes Group.

Composite Mock Up of C406 Points Option with CE218

CE218:C406 Points Option Fact Sheet


Additional proposals supporting CE218

CE226: C406 Dwelling/Sleeping Unit Lighting Efficiency. Approved as Modified by Code Development Committee. The Advanced lighting option in Section C406.3 only has requirements for Lighting Power Density. For buildings dominated by dwelling units, especially multifamily projects, this is a substantial loophole. This proposal Closes that loophole by modifying the C406.3 advanced lighting option to specifically include requirements for lighting used in dwelling and sleeping units. Proponent for this proposal is Eric Makela, representing New Buildings Institute

CE240: C406 Kitchen Equipment Additional Package. Approved as Submitted by Code Development Committee. This proposal creates a new Efficiency Package for Section aimed at full-service and fast food commercial kitchens such as those found in Assembly Group A-2 or establishments that engage primarily in commercial food preparation and/or dispensing. Proponent for this proposal is Nicholas O’Neil, representing NW Energy Codes Group.


Contact Amy Cortese, NBI director of programs, at [email protected], with any questions.

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