2026-07-16 Comment response to the published Request for information

DOE’s questions appropriately address cost, payback, regional differences, and consumer affordability. However, the methodology appears to continue treating the problem primarily as an economic modeling exercise. After decades of building-energy policy, I believe several critical real-world variables remain underrepresented. Modeled energy savings depend on the quality of construction, proper installation, owner behavior, owner education, length of ownership, and whether the installed systems are operated and maintained as intended. The economic value also depends on whether appraisers and lenders recognize verified improvements in building performance. These are not secondary issues. A technically sound energy measure can fail in the marketplace when the builder cannot recover its value, the trades do not understand how to execute it properly, or the homeowner does not understand how to operate the building. I therefore encourage DOE to evaluate not only the cost and theoretical payback of individual code provisions, but the entire delivery system through which those provisions must succeed. Better modeling alone will not solve a problem caused by misaligned incentives, inconsistent construction quality, inadequate consumer education, and poor communication among builders, trades, appraisers, lenders, regulators, and consumers. The United States has spent decades studying how to make buildings more energy efficient. Many of the technical solutions are already well understood and have been tested. The greater challenge may now be leadership: creating a system in which the people responsible for financing, building, valuing, operating, and regulating these buildings understand the same goals and have incentives that support them.