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

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.

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.

Janet Thome, President of Tiny House Alliance USA, argues that HUD is engaging in regulatory capture by granting a specific manufacturer (Clayton Homes) an exception to chassis requirements before the public comment period for a related rule has closed. She expresses concern that this premature implementation favors a large corporation while undermining safety, traceability, and the interests of smaller builders.

Janet Thome, President of the Tiny House Alliance USA, argues that the International Code Council (ICC) operates as a monopoly that creates high costs and regulatory barriers for housing. She supports the DOE's objective to reduce construction costs and regulatory burdens by highlighting the ICC's "closed-loop" system and its role in creating expensive, non-competitive standards.

Mickey Souza, a compliance rater at Energineers, argues that the focus on building energy codes should be on strengthening oversight and enforcement rather than reducing regulatory standards. He emphasizes that ensuring construction quality and contractor adherence to best practices is essential for protecting consumers from long-term costs and subpar performance.

The commenter supports the DOE's request for information but argues that the methodology should move beyond economic modeling to account for real-world variables like construction quality, owner behavior, and market incentives. They urge the DOE to evaluate the entire delivery system and leadership required to align stakeholders' incentives for building energy efficiency.

An anonymous member of the general public supports the nationwide adoption of the 2024 International Energy Conservation Code. The commenter argues that lower energy standards will harm public health and increase long-term housing costs, while claiming that the cost savings from reduced regulations are misleading.

Kenneth Roger Krantz, representing TeraSun Systems LLC, supports the DOE's objectives of improving affordability and reducing regulatory burden in building energy codes. He argues that the DOE should adopt real-time, batch-level digital verification systems to replace static, paper-based documentation for capturing cost and compliance data.

William Williams argues that minimizing energy codes to lower construction costs for builders results in higher operating costs and lower building durability for owners. He advocates for stricter energy codes that include mandatory air leakage testing for HVAC systems and building structures to ensure quality and long-term value.