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. 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.
CE218 A Public Comments
CE218 B Public Comments
CE218 C Public Comments

See a Compilation of the Base CE218: C406 Points Option with modification and additional proposals that will build off the base proposal

Read more about the CE218:C406 Points Option


Additional proposals supporting CE218

CE226: C406 Dwelling/Sleeping Unit Lighting Efficiency. 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

CE229: C406 Enhanced Digital Lighting Controls: This proposal enhances to the requirements for the digital lighting controls options in Section C406 to increase savings and the reliability of those savings. Proponent for this proposal is Jonathan McHugh, representing McHugh Energy Consultants Inc.

CE232: C406 Controlled Receptacles. This proposal introduces a new C406 option for controlled receptacles in offices. The requirement is based on a requirement the Seattle Energy Code. Proponent for this proposal is Eric Makela, representing Northwest Energy Codes Group.

CE235: C406 Extra Area Daylight Responsive Controls: This proposal introduces an additional option to C406 for increasing the amount of daylit area served by automatic daylighting controls above those required in the main body of the code. Proponent for this proposal is Jim Edelson, representing New Buildings Institute; Eric Makela, representing Northwest Energy Codes Group.

CE240: C406 Kitchen Equipment Additional Package. 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.


RE207-19: Flex Points Additional Energy Efficiency. This proposal creates a “flex points” requirement similar to the mandatory efficiency options in C406 of the commercial section of the energy code. The proposal outlines additional efficiency options, each worth points depending on saving potential. Projects are required to achieve a certain number of points with several options that cover all aspects of building performance provided. Proponent for this proposal is Eric Makela, representing New Buildings Institute.


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

Additional 2021 IECC Proposals

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