2026-07-21 Comment response to the published Request for information

My name is Rob Howard and I am the President of Howard Building Science, a small homebuilder based in Granite Falls, NC. Thank you for the opportunity to submit these comments in support of building energy codes and the important role they play in protecting affordability for American families. I earned my General Contractors license in 2004, and I have been building affordable housing for 20 years. I am currently building a small development of 11 homes on 1.25 acres in downtown Granite Falls, NC. Duke Street Cottages is a prime example of the “missing middle” housing that provides a greater diversity of housing choice in a community where most new construction are expensive custom homes on large lots that are out of reach for most people. I’m building the homes at Duke Street Cottages to the DOE Efficient New Homes Program standards, which are based on the 2021 International Energy Conservation Code. My experience shows that meeting or exceeding the 2021 IECC is very achievable, and it actually improves affordability. With energy bills rising rapidly, and more than a third of Americans in rural and urban areas alike struggling to pay their bills, building a home right the first time with strong energy efficiency is a critical tool for reducing these costs. Adopting modern codes is the simplest way to do that. Conversely, allowing outdated, energy-wasting new homes to be built saddles homebuyers with high energy bills for decades. We should build homes that are not just affordable to buy, but also affordable to own and operate. In my experience, the upfront cost of building to the updated energy codes is modest. It may come out to be about $30 more in terms of added monthly mortgage costs, but that is more than covered by the monthly energy bill savings, so the homebuyer saves money right away in terms of their net cash flow, and those savings grow over the long- term to become quite significant. The codes also deliver other important benefits in terms of durability, health, safety, and comfort. I have always looked at building energy codes as the baseline, but not the finish line. Building energy codes represent a minimum level that all builders can meet cost-effectively and deliver lower energy bills and higher-quality construction for our customers. Walking back these codes would strengthen the hand of lower quality builders building homes that don’t stand up to modern energy standards, while undermining so many homebuilders that are doing the right thing and creating better, safer, more affordable homes through energy efficiency.