Despite holding several meetings over the last eight months about the proposed 2015 International Energy Conservation Code (IECC)/ASHRAE Standard 90.1 -2013 for commercial buildings, the Wisconsin Commercial Building Code Council (CBCC) made several unannounced changes to the proposed rule at their final meeting on November 16 that will result in reduced energy efficiency.

The discussion about the proposed energy code at previous meetings culminated in a working document that included some amendments that reflected current building practices in Wisconsin, but maintained the core level of efficiency embedded in the 2015 IECC/ASHRAE 90.1-2013. The State of Wisconsin is currently enforcing the 2009 IECC/ASHRAE 90.1-2007 by reference, so updating to an unamended 2015 IECC could save approximately 18% in energy use.

But without notice, at the end of the November 16 meeting, the CBCC recommended a code that is significantly less efficient than what they had originally discussed.

Updating to a Weaker Code?

The proposed rules (starting on pg. 15 found here) include the following  weakening amendments, in addition to several minor amendments:

Reduced the building thermal envelope to 2009 IECC levels

Maintaining the 2009 IECC thermal envelope efficiency levels would result in a missed opportunity to improve the level of above deck and metal building ceiling insulation by 33% and 36%, respectively, and attic insulation by 22%. If this increased level of insulation were required, buildings would be more comfortable and efficient.

Removed lighting occupant sensor requirements

The 2015 IECC expanded lighting sensor requirements to rooms that are visited frequently by occupants for a short period of time. These sensors help ensure energy is not wasted once an occupant leaves the room by automatically turning off the lights.

Removed system commissioning requirements

The 2015 IECC requires that mechanical systems are fine-tuned or commissioned to ensure they are operating properly and at the efficiency levels listed in the original specifications. With the removal of this requirement, equipment may not operate at optimum efficiency and could be required to be replaced more frequently.

Removed the added efficiency package requirement

The additional efficiency package provides options for designers to improve the efficiency of the building through increased efficiency in one of six building components. If this package were included in the Wisconsin code, depending on which option the designer selected, the building could be up to 10% more efficient.

With these changes, the proposed code is significantly less efficient than model code for commercial buildings.

It is important to note that, of the five states in the Midwest that MEEA has assisted in the adoption of the 2012 or 2015 IECC or ASHRAE 90.1 -2010 or 2013 for commercial buildings, none of them have proposed amendments that weaken the efficiency of the commercial code to this degree.

Not only does this proposal leave significant commercial energy savings on the table, but given the changes, these buildings will have reduced occupant comfort and may not be operating to the level of efficiency agreed upon in the design phase due to lack of building testing. If approved, this code will likely go into effect in April or May of 2017 and will not be updated for another three years, as required by state legislation.

Stand Up for Sensible Energy Codes

Now that these rules are proposed, there are two periods in which the public can submit comments to voice their concern about the impact this will have on building owners, businesses and renters. According to this notice, the CBCC is accepting comments that discuss the level of economic impact this rule will impose on Wisconsin businesses and residents until December 28. Another notice will be issued to accept comments about the merits of the rules as a whole in January.

For questions or comments, please contact Ian Blanding, MEEA’s Senior Building Policy Associate.