2026-07-14 Comment response to the published Request for information

Building Efficiency ResourcesSupportBusiness
Summary: The commenter, a Home Energy Rating provider, supports the use of strong building energy codes to improve home quality, occupant health, and long-term affordability. They argue that while there is a modest upfront cost, the energy savings and increased resilience of compliant homes provide a net positive cash flow for homeowners and reduce long-term costs.
As a Home Energy Rating provider, we work with builders implementing different building codes all over the United States, resulting in thousands of efficient single-family homes and multifamily dwelling units annually. Building codes are synonymous with quality construction that, instead of costing an astronomical amount upfront, is focused on correct installation of HVAC and insulation. The result of installing systems correctly and third party verifying them, is a home that is more comfortable to live in, healthier for occupants, more durable in the long term and most critically, more affordable to operate. A modest upfront investment for a contractor will pay for itself many times over the life of the home and if is proven to be less than any increase in mortgage cost. The builders we work with see increased sales and reduced call backs due to the modest investment in complying with efficient codes. Home energy costs are rising, with more than a third of Americans in both rural and urban areas struggling to pay their bills. Building a home right the first time with strong energy efficiency standards is a critical tool for reducing these costs and keeping them lower. Conversely, outdated codes that allow inefficient, energy-wasting new homes to be built saddles homebuyers with high energy bills for decades. Science-based analysis from the Department of Energy, the national labs, and others have repeatedly shown that the investment more than pays for itself, saving homeowners more money per month right away (because savings from lower monthly energy bills surpass the additional monthly mortgage cost) and generating massive long-term savings. The Pacific Northwest National Laboratory’s analysis of the 2024 IECC found in all climate zones that “beginning in year 1, there is a net positive cash flow per year to the customer for the 2024 IECC-compliant home when compared to the 2021 IECC-compliant home.” The average single-family homeowner would see $144 in net annual savings, with total net savings of nearly $3,000. Surveys, including from the National Association of Homebuilders and Consumer Reports, consistently show Americans want energy efficiency and support energy efficiency policies and standards. The Federal Emergency Management Agency (FEMA) found that by 2040 up-to-date building codes will avoid $132 billion in damage from storms and other disasters that are increasing due to climate change. Building energy codes also increase resilience by allowing residents to safely stay in their homes for longer during a power outage with extreme heat or cold, as well as by avoiding moisture and mold damage. A joint 2023 study by three national laboratories (PNNL, LBNL, and NREL) and the Department of Energy (DOE) found that building to the 2021 IECC would protect residents during extreme heat and cold events, reducing deaths and doubling the length of time residents can safely stay in their homes during a power outage. Home energy codes improve resident health outcomes. Up-to-date energy codes will yield improved indoor air quality and more comfortable homes, reducing health risks like asthma, respiratory disease and hypertension and improving overall quality of life.

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