How to comment on the 2024 Commercial IECC

The public comment draft of the 2024 commercial IECC is now available and proposed recommendations could result in energy savings, a reduction in greenhouse gas emissions, and improved grid reliability benefits. Because of the potential impact of the code, this review period presents a crucial moment to weigh in on the specific language that jurisdictions will depend on for the next three years to meet their climate commitments.

It’s important to weigh in during this critical code cycle for addressing climate change. The International Code Council and commercial consensus committee need to hear your support for building codes that address climate change. Governments, businesses, NGOs, and individuals have until October 21, 2022 to provide comment on the code language that jurisdictions will depend on for the next four years to support achieving their climate commitments.


NBI has developed a number of resources to help you learn how to comment.

The public comment document and instructions here can be used as detailed guides to any one of the ways to comment described below.

Making your voice heard: Commenting on the Draft Commercial 2024 International Energy Conservation Code
Included in this document are summaries of the draft code amendments and revisions that were submitted by New Buildings Institute into the ICC process to advance the 2024 IECC. They are categorized by electrification; resilience, renewables and grid integration; new building energy efficiency; and existing building energy efficiency. Each item provides a brief code change title, a proposal number, the section of the code that could be impacted, and a summary.
NBI Public Comment Commercial 2024 IECC

How to Comment on the 2024 IECC
With this resource you can find step by step instructions. Using the cdpACCESS online portal allows industry market actors to give their comments on the proposed code for commercial buildings.
Ways to Engage and Using cdpACCESS

Additional resources
Webinar: Unpacking the 2024 IECC Commercial Public Comment Draft
Webinar
Blog: Advance climate action by getting involved now in the commercial 2024 IECC update
Blog


There are four ways in which you can weigh in, listed below in order of level of effort (lowest to highest).

Indicate which method you would like to use in this google form and we can help you if needed:

  1. Low: Sign on Letter. This is the easiest way to provide comment, but is also the lower impact option, as the Committees are likely to weigh formal submissions through cdpACCESS (included in options 2-4 below) with more consideration. NBI has developed a general sign-on letter and a building electrification sign-on letter. Tesla has also developed a sign-on letter for Electric Vehicle Infrastructure requirements. The Smart Surfaces Coalition is encouraging organizations to draft their own letter to support cool roofs.  We will forward your response to Noelani Derrickson ([email protected]) at Tesla and Emily Morin ([email protected]) at the Smart Surface Coalition.
  2. Medium: Co-proponent. This is more impactful than a sign on letter but not as impactful as submitting a statement from your own organization. NBI will be accepting co-proponents on the following proposals: Electrification Readiness Requirements, Electrification Incentive, All-Electric Appendix, Cool Roof Requirements, and Mandatory Renewables. We will push invitations for you to joins as a co-proponent. Follow these instructions to accept invitation.
  3. High: Submit supportive statements via energy.cdpaccess.com. This one of the more time intensive ways to comment on the IECC, but much more impactful than signing on to a letter or being a co-proponent. To submit a supportive statement via cdpACCESS, read NBI’s public comments on each section of the code then determine which sections you would like to comment on, draft your comment and follow these instructions to upload comment to energy.cdpaccess.com. Follow the links for a 10-minute cdpACCESS tutorial or a 30 minute webinar.
  4. Very High: Submit code change proposals via energy.cdpaccess.com. The most time intensive way to comment on the IECC includes submitting reason statements along with a suggested code change proposal. This is only needed for proposals that are missing in the code, such as electrification or cool roof measures, or proposals where there are needed revisions. To suggest changes to code with reason and cost statement: download NBI’s public comments on each section of the code. Determine which sections you would like to propose revisions. Follow these instructions to upload your revisions and comment to cdpAccess. For more detailed instructions watch this 10-minute cdpACCESS tutorial or a 30 minute webinar.

Bonus: Attend the Commercial Consensus Committee and Subcommittee Meetings. The most impactful thing you can do is attend the Commercial Consensus Committee meetings where these proposals are being discussed. If you would like to be involved in defending any of NBI’s or your own proposals at these meetings, fill out this form and we will let you know when those meetings occur. For all levels of supportive above, this bonus action will amplify your base action and may be your only way to truly influence the new IECC-C process.


Sign on Letters

A general sign- on letter covering all topics and a letter to support building electrification are available here. These letters relate to action one described above in ways to weigh in.
General Sign On Letter Commercial 2024 IECC Support Building Electrification


For more information

Learn more about what is in the commercial draft—watch our webinar, read our blog, and read the full 2024 IECC National Model Energy Code (Base Codes).