On January 15 the International Code Council (ICC) Board published the draft 2030 IECC (International Energy Conservation Code) Scope & Intent, including the cost benefit analysis approach. The draft Scope & Intent outlines what will be considered within scope for the code and establishes the framework for how interested parties will engage in the process to propose and modify the 2027 IECC. While energy codes have been a critical tool for states and cities to address emerging energy challenges related to large load growth and energy affordability, they are also an effective mechanism for meeting the ambitious climate commitments of the 24 states (plus DC and Puerto Rico) and 130 U.S. cities that have 100% clean energy/net zero emissions goals. 

For the first time, in this draft, the ICC Board has proposed to split the IECC into two: the base IECC and IECC Expanded (IECCX), which “may include optional or mandatory provisions incorporating additional energy efficiency and greenhouse gas reduction resources and provisions that lead to advancement of zero energy buildings.” The draft Scope & Intent further outlines which topics—including advanced credits, demand response and grid interoperability, electric readiness, electric energy storage, and renewables—are allowed in the main body and the appendices of each code. This approach diverges from previous code development processes in several significant ways. 

NBI was instrumental in the formation of the IECC-Commercial code and has contributed substantially through every code cycle since. While NBI recognizes the challenge of meeting the varied policy objectives of adopting jurisdictions throughout the U.S. and beyond, the newly released draft will make it difficult for industry to engage with, develop, adopt, enforce, and comply with the codes.  

Leading up to the February 15 deadline for public comments, NBI will be convening stakeholders to discuss these changes and their implications. Together, we’ll make constructive recommendations to move toward a successful code development process and final code product(s).  

We will focus on the following changes: 

• The exclusion of renewable energy as an option for optimizing energy compliance in buildings is lost ground that the IECC 2030 will need to reclaim to not fall behind the 2027 code.  
• The limitations on electric and solar readiness, demand response, grid-interoperability, electric energy storage, and renewables from the IECC, and from mandatory requirements in the main body of the IECCX, will require building more utility infrastructure, raise consumer electric bills, and increase future retrofit costs for decades.  
• The cost-effectiveness approach, and assumptions for the cost-effectiveness evaluations in the IECC, including the use of simple payback rather than lifecycle cost, zero (0) maintenance cost for residential, and the maximum seven (7) year payback for multifamily takes a narrow view of affordability.  
• The exclusion of social cost of carbon from the IECCX cost-effectiveness approach limits how cities and states regulate the social, climate, and health hazards of combustion fuels.  
• The creation of two additional consensus committees (residential and commercial) for IECCX may increase time burdens for interested parties engaging in the development process. 

While the current approach is presented as a step forward, the IECCX largely maintains the status quo of where the IECC has been for the past two cycles—with the exception of the allowance of embodied carbon criteria in appendices. Moreover, aspects of the draft Scope & Intent may unintentionally undermine hard-won gains in efficiency and long-term benefits for residents by prioritizing short-term, lowest upfront-cost considerations. Despite these reservations, we believe there is an opportunity for industry partners to work together to ensure near-term affordability is balanced with long-term value and performance. 

Divergence of IECC and ASHRAE Will Lead to Inconsistency and Confusion

The ICC Board’s decision to split IECC and IECCX follows similar movements at ASHRAE, which is pursuing a dual approach with the development of 90.1-E, which will provide guidance on enhanced operational energy emissions performance for commercial buildings. While ASHRAE’s pathway is informed by the technical committees, and decisions regarding the structure and approach of 90.1-E are developed and voted on by the technical committee members, it is unclear which objectives or priorities drive the ICC Board’s decision-making. The process is opaque.  

With both the IECC and AHSRAE developing dual pathways, maintaining alignment between the IECC and ASHRAE becomes even more important to support jurisdictions and the design and construction industry—and to avoid fragmentation of the national model energy codes. 

The development of ASHRAE 90.1-E is consistent with ASHRAE’s Position on Decarbonization that states that newly constructed buildings should have zero operational greenhouse gas emissions by 2030. In pursuit of this, 90.1-E will consider the social cost of carbon to cost justify code measures associated with the reduction of operational emissions and will include all the associated requirements to achieve emissions reductions goals in the main body. On the other hand, the IECCX is not explicitly driven by carbon reductions goals, is not considering the social cost of carbon, and has limited many topics to optional credits in the main body. This distinction is important, as ASHRAE 90.1-E’s inclusion of all associated criteria in the main body of the text supports a clear and consistent pathway for jurisdictions and buildings looking to achieve reduced emissions through compliance with the standard, while even the IECCX relegates most carbon reduction criteria to the appendices. This structure will require jurisdictions to pick and choose from what is developed and published to meet their emissions reductions goals through adoption of the code.   

Moving Forward Towards the 2030 Code Development Cycle 

Between now and February 15, NBI will be reaching out to industry organizations, states, and interested stakeholders to coordinate and facilitate discussions on the 2030 draft Scope & Intent, with the goal of identifying clear recommendations for requests for clarification, and comment responses. Our goal, as it has been for ten code cycles and nearly 30 years, is to work towards a smooth, successful code development process that produces easily adoptable, enforceable energy codes that meet the needs of jurisdictions and communities pursuing energy efficiency goals, reduce bills, and improve environmental and health outcomes.  

Through these discussions, NBI and its partners will work through questions and considerations and seek to gain clarity on how items outlined in the draft Scope & Intent may impact the industry, such as: 

1. What are the impacts of excluding the social cost of carbon, using Simple Payback in lieu of lifecycle cost, and the assumptions laid out in the cost-effectiveness approach?  
2. Will individuals be eligible to participate on multiple committees across IECC and IECCX, and how might allowances or limitations here impact involvement for interested parties?  
3. How will IECC and IECCX be reviewed through statutory obligations, and how will this impact adoption by different jurisdictions?  
4. How will coordination between IECCX and ASHRAE 90.1-E be managed and maintained?  
5. How can the 2030 Scope & Intent be refined to meet the needs of adopting jurisdictions in meeting energy, climate, and affordability goals?  

The table below provides a side-by-side comparison of the topics and to what extent they are permitted in the main body and/or appendices of the IECC and IECCX according to the draft Scope & Intent.   

 

Topic	Main Body		Appendices		Description
	IECC	IECCX	IECC	IECCX
Advanced Credits (Penalty for specific equipment types)	Not Allowed	Not Allowed	Not allowed	Allowed	Above code requirements through additional credits for compliance. Additional credits required for buildings using fossil fuel energy equipment/appliances
All Electric Buildings	Not allowed	Not allowed	Not allowed	Allowed*	Requirement that all equipment/appliances are fully electric
Alternate R-Value	Allowed	Allowed	Allowed	Allowed	Prescriptive tables providing R-values for alternative framing or construction techniques
Demand Response	Allowed as optional credit	Allowed as optional credit	Allowed	Allowed	Building equipment/appliances (typically service water heating, lighting, and mechanical equipment) that has a control that can receive a signal from the utility to modify consumption for a limited time period.
Electric Energy Storage	Not allowed	Allowed as optional credit	Not allowed	Allowed	One or more devices, assembled, capable of storing energy to supply electrical energy at a future time.
Electric Ready Buildings	Not allowed	Allowed as optional credit	Not allowed	Allowed	Requirements for dedicated electric pathways and space reserved in the electrical panel for the capability of all appliances operating fully on electricity
Embodied Carbon	Not allowed	Not allowed	Not allowed	Allowed	Carbon emissions are associated with the extraction, harvesting, manufacturing, transporting, installation, and demolition of building material or appliance.
Embodied Carbon Rating	Not allowed	Not allowed	Not allowed	Allowed	Embodied carbon is calculated as global warming potential (GWP) and expressed in carbon dioxide equivalent units (CO2e). To quantify a product’s embodied carbon, an analysis called life cycle assessment (LCA) is used to assess the environmental impacts associated with each stage of the product lifecycle. The disclosure of LCA results through Environmental Product Declarations (EPDs) provides valuable information to consumers about the environmental impact of building products. An adoption authority could mandate submittal of EPDs for products/appliances. Also, the AHJ could require maximum C02e levels for products or the building as a whole.
Energy Rating Index (ERI) Compliance Path	Allowed	Allowed	Allowed	Allowed	A compliance path for IECC Residential dwelling units using ICC/RESNET standard 301. The index is a numerical integer value representing the relative energy performance of a rated design or constructed dwelling unit as compared with the energy performance of the ERI Reference Design, where an ERI value of 100 represents the energy performance of the ERI Reference Design and an ERI value of 0 represents a rated design or constructed dwelling unit with zero net energy performance.
EV / Charging (Required or Readiness)	Not Allowed	Allowed as optional credit	Not Allowed	Allowed	Installation of charging infrastructure for installation or future installation of Electric Vehicle Service Equipment parking spaces
Glide Path	Not Allowed	Not Allowed	Not Allowed	Allowed	A framework for adopting authorities that wish to step down annual energy use to a net energy goal over several code adoption cycles.
Grid Interoperability	Allowed as optional credit	Allowed as optional credit	Allowed	Allowed	The ability of buildings to communicate with the electric grid to exchange information and energy in a seamless, two-way flow. This allows buildings to optimize their energy use based on grid signals, occupant needs, and on-site generation, helping to stabilize the grid, integrate more renewables, and reduce energy costs.
Net-Zero (Includes “Stretch”)	Not Allowed	Not Allowed	Not Allowed	Allowed	A model for applying new renewable energy generation when new buildings add electric load to the grid. This renewable energy will avoid the additional emissions that would otherwise occur from conventional power generation. Often in conjunction with advanced efficiency requirements.
Offsite (Renewables)	Not Allowed	Allowed	Not Allowed	Allowed	Energy from renewable energy resources harvested at a location other than the building site. Various methods are available to procure off-site energy or offsets.
Onsite (Renewables)	Not Allowed	Allowed	Not Allowed	Allowed	Energy from renewable energy resources harvested at the building site.
Operational Carbon Rating	Not allowed	Allowed	Not allowed	Allowed	Operational Carbon is carbon emissions associated with energy used during the occupancy and use of a building. An Operational Carbon Rating is a numerical integer value, calculated in accordance with ANSI/RESNET/ICC 301, that represents the relative Carbon Dioxide equivalence (CO2e) emissions of a rated design as compared with the CO2e emissions of the CO2e reference design, where an Index value of 100 represents the CO2e performance of the CO2e reference design and an Index value of 0 (zero) represents a home that emits zero net CO2e annually.
Solar Readiness	Not Allowed	Allowed as optional credit	Not Allowed	Allowed	Preparedness for future solar system installation. Includes structural allowances, electrical pathways, electrical panel sizing
Total Seasonal Performance Ratio (TSPR)	Allowed	Allowed	Allowed	Allowed	A metric for determining efficiency of building systems rather than individual pieces of equipment. Simulation of proposed building modeled versus a standard reference design. Currently TSPR is allowable HVAC system compliance option in the 2024 IECC.

Please note: chart formatting may not appear correctly on mobile devices.

Authors

Co-authored by Tristan Grant, Acting Director of Codes and Policy with help from the entire NBI Codes and Policy Team.

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