2026-07-27 Comment response to the published Request for information

As a working architect with over 15 years of experience, I vehemently oppose the proposed revisions to DOE's cost model methodology because they rely on misleading comparisons, obsolete building codes, and fail to take into account co-benefits to health and wellness of building occupants. I realize the current Federal administration is uninterested in recognizing the value of American’s, but as a human being who would values my health, it is quite important to me that all cost modeling incorporate this outcome alongside financial cost. Further, I have reviewed Ed Mazria’s calculations (published in Architect magazine on July 16, 2026) indicating that energy codes and the energy star program have saved Americans 3.48 trillion dollars and found them to be accurate and compelling. One central problem with the DOE’s proposed methodology is that it places greater emphasis on initial construction costs while diminishing the importance of long-term energy savings and lifecycle benefits will discourage design decisions that reduce operating expenses, improve building performance, and increase asset value over decades of service. To my eye, this proposal nakedly prioritizes the profitability of the fossil fuel industry over the prosperity of American Citizens; therefore I vigorously object to the the proposed Methodology for Assessing Affordability.