2026-05-04 Updating and Improving the Methodology for Assessing Affordability and Cost Effectiveness of Building Energy Codes; Request for information

Cutler Development, a real estate developer, supports the inclusion of building energy codes as a tool for housing affordability and long-term value. They argue that the codes are cost-effective, improve home durability and comfort, and provide significant energy bill savings for low-income households.

Isaac Scott, owner of Clare Homes, argues that building energy codes support housing affordability by lowering long-term energy bills and improving home durability and safety. He urges the DOE to include these long-term benefits and public safety considerations in its methodology for assessing the impact of energy codes.

The commenter argues that the Department of Energy's premise regarding the cost of building energy codes is misleading because it fails to account for energy bill savings. They advocate for keeping the current methodology for assessing affordability and cost-effectiveness intact.

Janet Thome, President of Tiny House Alliance USA, supports the DOE's action to improve methodology for assessing building energy code costs. She argues that current codes and the interlocking relationships between organizations like the ICC, NIBS, and RESNET create a "closed compliance marketplace" that drives up construction costs and excludes affordable housing options like tiny homes.

Neil P. Osnato of Persistence Analytics Group LLC / United Grid supports the DOE's effort to improve the methodology for assessing building energy code affordability. He argues that the DOE should incorporate an "implementation-verification layer" that accounts for real market costs, realized savings, and regional variations rather than relying solely on modeled predictions.

Rob Howard, President of Howard Building Science, supports the role of building energy codes in ensuring long-term housing affordability and energy savings. He argues that meeting modern energy standards is achievable for builders and provides immediate and long-term financial benefits to homeowners while improving home quality.

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.

Heatcraft, a commercial refrigeration systems manufacturer, supports the DOE's objective to improve affordability and cost-effectiveness methodologies for building energy codes. They argue that the DOE should improve its analysis by incorporating real-world transaction costs, regional variability, refrigeration-specific prototype models, and the impact of regulatory burdens and refrigerant transitions.

Kenneth R. Krantz of TeraSun IP Holding, LLC and TeraSun Systems, LLC supports the DOE's efforts to prioritize affordability and transparency in building energy codes. The commenter argues that the International Energy Conservation Code (IECC) should focus on building efficiency rather than climate policy and proposes a performance-based, fuel-neutral framework for modular housing.

The commenter, a Home Energy Rating provider, supports the use of strong building energy codes to improve home quality, occupant health, and long-term affordability. They argue that while there is a modest upfront cost, the energy savings and increased resilience of compliant homes provide a net positive cash flow for homeowners and reduce long-term costs.