Comments to Adopt Energy Efficiency Codes Submitted to the State of Pennsylvania

First: A huge thank you!  The participation in the commenting process on building codes was outstanding: there were over 50 comments submitted commenting on the 2015 ICC Codes in General and over 160 comments submitted concerning the International Energy Conservation Codes.

What did all of these comments say?  Well, since you took the time to comment – it seemed the least we could do was summarize the comments.  The comments are publically posted here (  The comments submitted concerning the adoption of the 2015 I-Codes are organized by (with number of comments in each category) General (50), International Building Code (20), ICC Performance (1), Independent Electoral Boundaries Commission (2), International Energy Conservation Code (162), International Fire Code (1), International Mechanical Code (1), International Plumbing Code (3), International Residential Code (63).

The general comments (50 of them) on the 2015 I-Codes: every single one recommends adoption, and recommend adoption without any modification.  Five townships/boroughs and two cities (Harrisburg and Pittsburgh) submitted comments recommended full adoption without modification, citing the difficulties of using modified code that was designed to be interdependent.  As well as the difficulties of enforcing a code that is almost 10 years old and no longer supported (trying to find 2009 code books on ebay to be able to do your job is a bit sad).  Other comments recommended full adoption came from architects/engineers (12), as well as code consultants (4), as well as nonprofits, the state Department of Environmental Protection, a Fire Marshal, Construction Legislative Council and the National Electrical Contractors Association.

Most of the submitted comments concerned the International Energy Conservation Code… and of the over 160 comments there were only six comments* submitted that recommended not adopting provisions that would improve energy efficiency.  Of these, three were submitted by one organization – effectively stating that they did not want commissioning required, which seems a little strange to me as commissioning is one of the most cost effect ways to ensure that the building operates as designed (I don’t know if I have heard of an instance where a commissioning agent’s works did not end up paying for itself, normally many times over).  Of the other three, two (from homebuilders) made the recommendation based on the increased cost to the builder… and the other said that ventilation systems are normally installed improperly so we shouldn’t require more energy efficient buildings – so shoddy work is better with more shoddy work?

*A little note:  there were 6 other comments recommending to not adopt part of the IECC – specifically section R406.  This section allows for less insulation when high efficiency mechanical systems are installed – which was soundly rejected by all commenters as shortsighted and costly to the homeowner: as improving the insulation is a much more disruptive/costly endeavor to do after the building is built and reduces the lifetime performance of the structure.

The remaining approximately 145 comments are all in favor of adopting the IECC, the reasons include: cost for the consumer, economy in Pennsylvania, health and safety, jobs, reducing emissions/climate change, resiliency, natural hazard mitigation, consistency across state lines, energy burden for low income residents, and quality control.  These comments were submitted by many residents of Pennsylvania, from architects and manufactures, to physicians and residents that have firsthand experience of the low quality of construction caused by using outdated codes.

(A few submitted comments were not viewable or did not indicate adoption or rejection.)

Again – thank a huge thank you to all in this public input process!  Hopefully the voices of the many professionals who build, design, own and operate buildings in Pennsylvania will be heard – we’ll just have to wait to May 1st to learn of the Review and Advisory’s Council recommendations.  Hopefully they listen to the overwhelming majority of Pennsylvanians (both building professionals and consumers) of what they want from the building code in Pennsylvania.


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