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As Governor Abbott signed HB 1736 into law this week, the energy efficiency of new single-family homes in Texas will improve starting next year. This is a good thing! It will lead to less overall energy use and lower peak demand without sacrificing the comfort and livability of new homes. It will also save new homeowners money, while also saving water and natural gas. However, there are many other types of new buildings, both residential and commercial, that could be improved. In a recent letter to State Comptroller Glenn Hegar (who oversees the State Energy Conservation Office), Conservation Director Cyrus Reed urged him to align the building energy codes for other building types with the most up to date standards.
[Update: Comptroller Hegar responded to Cyrus Reed's letter, saying that he is assessing the next appropriate steps. Click here to read Hegar's letter.]
Below is a copy of Cyrus' original letter.
June 3, 2015
Dear Comptroller Hegar,
Now that the legislative session is over, a number of organizations interested in the issue of our energy use in new and remodeled buildings wanted to urge you to begin taking action through the State Energy Conservation Office to update our statewide energy codes for commercial and other non-residential buildings, as well as state-funded commercial and residential buildings.
HB 1736: Moving forward on Energy Codes for Single-family Homes
As your office is aware, in the recently concluded legislative session, a compromise bill that was supported by most stakeholders passed both the House and Senate with bipartisan support. While the bill has many components, the most important one is that it establishes the energy chapter of the 2015 International Residential Code as the statewide code effective September 1, 2016.
Assuming the bill is not vetoed in the coming days – and because there was no significant opposition to the bill we have no reason to believe it will – the 2015 IRC would be the state energy code for Texas for single-family homes in approximately a year. We would expect that SECO, along with the Energy Systems Laboratory will play a key role in letting builders and cities that implement local codes know about this new state law and state code.
Time to Move Ahead on Commercial Codes
Because the state would be adopting the 2015 IRC on September 1, 2016, we believe the Comptroller through SECO should take advantage of this timing, and immediately open a rulemaking to also adopt the 2015 IECC for other building types. As you know, last year, the Energy Systems Laboratory specifically compared the energy provisions of the commercial 2009 IECC – current code – with the 2015 IECC, and also compared the 2012 IECC with the 2015 IECC. They then recommended, in November of 2014, that SECO adopt the 2015 IECC as the statewide code for all non-residential construction. Simply put, these new codes would lead to less overall energy use, lower peak demand, save money, while also saving water and gas.
SECO and ESL also invited comments from stakeholders, and while there was opposition from some homebuilders on the 2015 IRC – issues which have been largely fixed through the flexibility offered by HB 1736 – there was overwhelming support for adoption of the 2015 IECC for other building types. Thus, industry, environmental and architectural firms all supported adoption of the 2015 IECC for commercial buildings.
While we had previously advocated that the 2015 IECC be adopted as the statewide code by June of 2015 or January of 2016 at the latest, because of HB 1736, we would suggest that the Comptroller and SECO immediately open a rulemaking to adopt the 2015 IECC for all non-residential buildings on September 1, 2016. This would allow the two codes – the residential 2015 IRC and the 2015 IECC – to be adopted at the local level simultaneously, lessening costs and confusion. It would also allow SECO, ESL and other groups to help prepare builders with training, materials and education.
State-Funded Buildings
We have been disappointed that the Comptroller and SECO have not moved forward on an update of the codes covering state-funded buildings, or convened a meeting of an advisory council required by passage of HB 51 in the 2011 Legislative Session to look at high performance standards.
Codes for state-funded buildings last became effective in September of 2011. We would suggest that to better align state-funded buildings with the other codes, that a new base code – such as the 2013-90.1 ASHREA or the 2015 IECC – be adopted for state buildings, and that SECO also look at revising the water conservation requirements and consider a high performance rating as well.
We look forward to working with the Comptroller and SECO on implementation of HB 1736, as well as rulemaking to adopt the 2015 IECC for non-residential buildings by September 1, 2016, and a rulemaking to adopt a base code and high performance standards for energy and water conservation for state-funded buildings.
Sincerely,
Cyrus Reed
Conservation Director
Lone Star Chapter, Sierra Club