Massachusett's is positioned to dramatically improve the energy efficiency in its new residential building “stretch code”. These comments address that proposal.
A Massachusetts energy code based on the 2009 IECC is appropriate. Per the Department of Energy, the 2009 IECC is half way to the goal of 30% more efficient than the 2006 IECC (source).
However the proposal deletes the residential energy code (Chapter 4) without a replacement code. Why would Massachusetts adopt a code that is half way to the goal then delete it?
Two options seem reasonable after adoption of 2009 IECC:
The current Massachusetts proposal substitutes a compliance method, HERS scores, for code. Good reasons to avoid using HERS scores as a code include:
In addition to HERS, the Massachusetts code change proposal specifies the Energy Star Bypass Checklist as part of the code. However, most of the Energy Star Thermal Bypass Checklist was incorporated into the 2009 IECC (and IRC) code (as Table 402.4.2 in 2009 IECC). Why adopt the 2009 IECC, delete the Thermal Bypass Checklist, then readopt it? Just adopting the 2009 IECC makes a codified version of the Energy Star Bypass Checklist part of the Massachusetts energy code.
As a voluntary program, deemed to meet or exceed a stretch code, Massachusetts should consider becoming an early user of the new Energy Star “Climate Choice” program, an upgrade of the existing Energy Star for Homes program. (source). The draft specifications include aggressive energy savings and an emphasis on quality construction. (source)
Massachusetts’s goal of much greater energy efficiency is encouraging. Hope the wisdom of the Massachusetts builders can be applied towards defining how best to make increased energy efficiency practical and real.