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

Thank you for the opportunity to submit comments on the benefits of building energy codes, particularly for housing affordability. As owners of Cutler Development, a real estate developer based in West Des Moines, Iowa, we know firsthand that the latest building energy codes are cost-effective, achievable, and deliver enormous benefits to our customers. Our firm focuses on high-performance building projects, including affordable multifamily housing, and all of our projects meet or exceed the ASHRAE 90.1-2022 standard. In fact, many of our new construction projects far exceed code in terms of energy efficiency and other advanced energy features because we see so much value in it. Particularly in the multifamily building context, there is only a modest additional cost to meet the latest building energy codes, and the cost savings from lower energy bills exceeds those added costs. And that’s not even accounting for the many other benefits that high-performing housing delivers—like resilience and safety. Meeting updated energy codes improves durability to extreme weather and allows people to safely stay in their homes for longer in the event of a power outage thanks to better insulation and building envelope structures. As Iowa faces more and more severe storms, those features are increasingly important. We also find that these homes are a lot more comfortable year-round because they are better at maintaining temperatures, quieter, and have healthy indoor air quality. It is just common sense to building a building right the first time, so that it’s affordable, durable, and comfortable for the long-term. Many of our developments serve households earning 30-80% of the area median income, for whom $50-100 off their monthly energy bill can make a dramatic difference for their pocketbook. According to the U.S. EIA, more than 43 million households struggled to pay their energy bills in 2024, with 75% of those reporting reducing or forgoing food or medicine to pay for energy costs. This is a serious affordability issue and building energy codes are one of the best tools we have to ensure that new housing is built to minimum standards for cost-effective efficiency so that families aren’t stuck footing the bill for homes that just waste energy. We urge you to properly account for all of the benefits of building energy codes when evaluating their cost-effectiveness. We need building energy codes to protect truly affordable and high-quality housing for Americans.