Less Than 100 Days To Comment On EPA’s Clean Power Plan

In June, the U.S. Environmental Protection Agency (EPA) released a historic plan under the Clean Air Act’s Section 111(d) to significantly reduce greenhouse gas (GHG) emissions from the nation’s largest source: existing power plants. Because 71 percent of America’s electricity is consumed by residential and commercial buildings, building energy codes – which have proven to be among the most cost effective measures to reduce carbon emissions – should be a prominent part of the menu of options that states can include in the State Compliance Plans they file with EPA. Unfortunately, EPA’s proposed plan doesn’t name specific demand reduction measures, like energy efficiency, that would be eligible for emission credits, let alone cite building energy codes as an option for state compliance plans.

While there is broad support for including GHG reductions from building energy codes in EPA’s Clean Power Plan, state air quality officials aren’t certain they can count on the construction sector’s compliance with them. Simply stated, they are concerned that they won’t be able to document their promised reductions in GHGs when it comes time to “true up” the results with EPA.

At the end of last year, an analysis by ICF International calculated the state-by-state energy savings and GHG reductions that would result from the construction of residential and commercial buildings that fully comply with the 2006, 2009, 2012, and 2015 IECC (BCAP’s Energy Code Calculator is a handy online tool for GHG calculations). Both the analysis and the calculator help a lot, but the big question remains: Just how many of them actually comply?

That’s where you come in. EPA has solicited public comments on its State Compliance Plan – you have until October 16th to help your state build a case in favor of building energy codes’ potential to reduce greenhouse gas emissions and to the let the Agency know that you support making building energy codes a part of the menu of eligible compliance options for states.

A few years ago, McKinsey & Company analyzed the cost effectiveness of the entire slate of greenhouse gas emission reduction measures. As their chart shows below, more energy efficient construction and efficiency improvements that fall under the purview of building energy codes were not only cost effective, they actually had “negative costs” (the resulting energy savings more than recouped the cost of the improvement measures).