2026-07-20 Comment response to the published Request for information
North American Insulation Manufacturers Association (NAIMA)SupportTrade association
Summary: The North American Insulation Manufacturers Association (NAIMA) supports the DOE's efforts to improve building energy code methodologies but argues that the analysis should prioritize long-term homeownership affordability over initial construction costs. They recommend that the DOE account for the lifecycle benefits of permanent building envelope improvements, such as insulation and air sealing, and incorporate more realistic electricity price scenarios and construction cost offsets.
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