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International Energy Conservation Code (IECC) Commercial - IECC [2024] Project Engagement VIEWS 223 PARTICIPANTS RESPONSES COMMENTS SUBSCRIBERS 20 0 26 2 Please provide a comment or question about the proposed Commercial provisions of the International Energy Conservation Code (IECC) 2024 Technical Code Amendments in the space below. Please respond by July 9, 2024. July 8, 2024 Attention: Public Comments Dear Austin Energy Green Building Staff, Vehicle Readiness proposals of the 2024 International Energy Conversation Code (IECC) The Alliance for Transportation Electrification appreciates the opportunity to comment on Austin Energy’s Residential and Commercial Electric Vehicle Readiness proposals of the 2024 International Energy Conversation Code (IECC). We applaud the City’s leadership in pushing forward the energy code in a timely manner. Although many cities and states have adopted energy codes, only a handful have been proactive in adopting, updating, and enforcing the most up-to-date codes. Energy codes ensure that a building's energy use is included as a fundamental part of the design and construction process of new buildings; making an early investment in building energy improvements will pay dividends to Austin residents for years into the future. We offer the following comments on the 2024 IECC Electric Vehicle Readiness proposals for both commercial and 1. We support the residential electric vehicle readiness proposal for one-and two- family dwellings, townhomes, and residential buildings. R-2 occupancies. The residential proposal derived from Appendix RE of the 2024 IECC Residential code requires that new one- and two-family dwellings and townhouses with designated parking provide one EV capable, EV ready, or EVSE space per dwelling unit. Multifamily buildings with four stories or less must provide an EV capable space, EV ready space, or EVSE space for 40 percent of dwelling units or automobile parking spaces, whichever is less. These requirements give building owners flexibility in establishing the level of EV readiness that will fit their current and future needs, while still providing the necessary minimum EV charging load that the distribution system needs to be sized for. Moreover, the language in Appendix RE was developed as a consensus proposal during the IECC code development process with input from a diverse group of stakeholders including representatives from the home builders, electrical manufacturers, EV charging providers, and utilities. It went through several rounds of public comment and editorial changes to ensure clarity, consistency, enforceability, and technical soundness. Adopting Appendix RE outright would help staff streamline and quicken the public input process given that the language has already been thoroughly vetted. commercial occupancy types 2. We strongly recommend increasing EV-ready requirements and including EVSE- installed spaces for certain We are concerned that the omission of EV-ready and EVSE-installed spaces in Table CG101.2.1 from all commercial occupancy types expect Groups R-1 and R-2 will result in an under-investment in necessary charging infrastructure to support current and future EV drivers in Austin. The current proposal heavily stacks EV-capable requirements across nearly all commercial building types, which puts the burden on building owners, EV drivers, or tenants to have an outlet or EVSE wired and installed at their parking space. While an EV capable space requires panel capacity, a dedicated circuit and raceway, it does not include a way for someone to drive up to a parking spot and plug in and charge. In particular, this barrier presents a significant obstacle to installing EV infrastructure at multi-family dwellings, which have proven to be the most challenging sector to deploy EV infrastructure. Unlike residents of single-family homes, multi-family tenants are commonly renters without the authority to retrofit parking spaces to install charging equipment. When retrofitting to provide EV charging is possible, tenants and owners can face costs of 4-6 times higher than if done during new construction2. The ability to charge an EV overnight is additionally important for multifamily tenants who are rural, low-income, and in disadvantaged communities, who typically have longer commutes and drive older EVs with shorter ranges. Several cities and counties across the country have included ambitious EVSE-installed and EV- ready requirements for commercial building types, including Scottsdale, Tucson, Coral Gables, St. Petersburgh, St. Louis County, Charlotte, Columbus, Orlando, Chicago, Seattle, and many others. We recommend that Austin match or exceed the ambition of its peer cities and adopt EV-ready and EVSE-installed requirements for new commercial buildings Tesla ambition of its peer cities and adopt EV ready and EVSE installed requirements for new commercial buildings. Tesla proposes revisions to Table CG101.2.1 in the Appendix 1. 3. We recommend including a Direct Current Fast Charging (DCFC) compliance pathway that provides new commercial buildings the option to meet compliance with charging that mirrors dwell times. Depending on the type of nonresidential building and the typical dwell time a vehicle is parked, a higher power level for charging beyond a standard Level 2 charger may be most beneficial. A DCFC compliance pathway would allow new non-residential buildings the option to meet EV- capable and EVSE compliance either through Level 2 or DCFC. For example, commercial buildings with short dwell times, such as grocery stores, would have the ability to use a DCFC compliance ratio of 5:1 EVSE installed if minimum requirements are met and at least one Level 2 EVSE is installed. A DCFC compliance option is important as it provides building owners with the incentive to go beyond minimum EVSE requirements and the optionality to install the level of EV charging, either Level 2 or DCFC, that best fits customer needs. This optionality also results 2 https://caletc.aodesignsolutions.com/assets/files/CALGreen-2019-Supplement-Cost-Analysis-Final-1.pdf in a more efficient use of state and private infrastructure investment given more optimal charging station usage. ATE proposes recommended language in the attached Appendix 2. . ATE appreciates the opportunity to provide feedback on 2024 IECC Electric Vehicle Readiness proposals for both commercial and residential buildings. We look forward to continued work with the City of Austin on its transportation electrification efforts. Thank you for the opportunity to submit these comments. Sincerely, Rick Tempchin Alliance for Transportation Electrification rick@evtransportationalliance.org 202-258-2912 *** APPENDIX 1 TABLE C405.14.1 EVSE Spaces EV Ready Spaces 5% 0% 10% 0% 10% 0% 0% 10% 0% 10% 0% 5% 5% 0% 0% EV Capable Spaces 10% 0% 5% 0% 0% 10% 0% 30% 30% Language to be added is underlined. Language to be removed is struck. REQUIRED EV POWER TRANSFER INFRASTRUCTURE Occupancy Group A Group B Group E Group F Group H Group I Group M Group R-1 Group R-2 Group R-3 and R-4 Group S exclusive of parking garages Group S-2 parking garages 5% 0% 5% 0% 5% 0% 2% 0% 1% 0% 5% 0% 5% 0% 10% 0% 10% 0% 0% 30% 5% 0% 30% 30% 35% 35% 5% 0% 30% 1 Tesla Road, Austin, TX 78725 P 650 681 5100 F 650 681 5101 APPENDIX 2 Language to be added is underlined. Language to be removed is struck. CG101.2.1 Quantity. The number of required electric vehicle (EV) spaces, EV capable spaces and EV ready spaces shall be determined in accordance with this section and Table CG101.2.1 based on the total number of automobile parking spaces and shall be rounded up to the nearest whole number. For R-2 buildings, the Table CG101.2.1 requirements shall be based on the total number of dwelling units or the total number of automobile parking spaces, whichever is less. 1. Where more than one parking facility is provided on a building site, the number of required automobile parking spaces required to have EV power transfer infrastructure shall be calculated separately for each parking facility. 2. Where one shared parking facility serves multiple building occupancies, the required number of spaces shall be determined proportionally based on the floor area of each building occupancy. 3. Installed electric vehicle supply equipment installed spaces (EVSE spaces) that exceed the minimum requirements of this section may be used to meet the minimum requirements for EV ready spaces and EV capable spaces. 4. Installed EV ready spaces that exceed the minimum requirements of this section may be used to meet the minimum requirements for EV capable spaces. 5. Where the number of EV ready spaces allocated for R-2 occupancies is equal to the number of dwelling units or to the number of automobile parking spaces allocated to R-2 occupancies, whichever is less, requirements for EVSE spaces for R-2 occupancies shall not apply. 6. Requirements for a Group S-2 parking garage shall be determined by the occupancies served by that parking garage. Where new automobile spaces do not serve specific occupancies, the values for Group S-2 parking garage in Table CG101.2.1 shall be used. 7. Group S-2 parking garages with no less than 50% long term parking spaces shall provide no less than 10% EV capable spaces. Long term parking spaces are considered as parking spaces where users generally park for more than 8 hours at a time, including overnight, at places such as airports, transit hubs, etc. 8. The installation of Direct Current Fast Charging (DCFC) EVSE shall be permitted to reduce the minimum number of required EV capable or EV ready spaces without EVSE or EVCS with Level 2 EVSE by five and reduce proportionally the required electrical load capacity to the service panel or subpanel. 22 days ago 22 days ago Please see attached letter in support of IECC 2024 Technical Code Amendments from SPEER. 2024 Proposed Code Adoption Austin Letter.pdf 23 days ago Thank you 23 days ago 23 days ago Please see the Atmos Energy's comment letter. 2024.07.08 - Atmos Energy Comments - 2024 Technical Code Amendments - Commercial.pdf We support the proposed adoption of the 2024 Commercial IECC, including the EV-ready, electric-ready, energy storage and demand response amendments. Increasing energy efficiency is important for reducing greenhouse gas emissions and local air pollution, keeping bills affordable and increasing electric grid and community resilience. I support the proposed adoption of the 2024 Commercial IECC, including the EV-ready, electric-ready, energy storage and demand response amendments. The American Gas Association (AGA) represents more than 200 local energy companies committed to the safe and reliable delivery of clean natural gas to more than 73 million customers throughout the nation. AGA appreciates the opportunity to comment on the proposed changes to the City of Austin’s commercial energy code. Our first concern is the city is not referencing a published 2024 edition of the IECC but relies on a redline version that may not be what is eventually published by the ICC. We would ask that the efforts to modify the commercial and the residential Austin Texas energy codes be based on a published and publicly available edition of the 2024 IECC and not rely on a redline version that may have, for a number of reasons, differences then the published 2024 IECC. Regarding the proposed revisions to add Appendix CG Electric Vehicle Charging Infrastructure and additional requirements and Appendix CH – Electric-Ready Commercial Building Provisions, we do not believe these additions help the city to meet its energy and emissions reduction goals and in fact, will result in an overall increase in both as well as an increase in construction cost that will impact the affordability of new and existing structures. Regarding the Electric Vehicle infrastructure, etc. requirements, it is clear that this will add significant cost and electricity usage with no specific documentation and analysis that justifies the benefits of such and extensive requirement for commercial building installations. The Appendix CH – Electric-Ready Commercial Building Provisions is even more troublesome since it adds a costly requirement that may never be used in the commercial application and if used, can actually add more source energy use than the fossil fuel appliances that it targets for possible future replacement. The ICC Board of Directors took the logical action at the end of the 2024 International Energy Conservation Code development process to remove both the Electric Vehicle provisions and the Electric-Ready Commercial Building Provisions from the compliance requirements of the 2024 IECC and we urge that the City of Austin, Texas do the same. The AGA March 20, 2024 Press Release that provides the March 18, 2024 ICC Board of Directors action on these requirements can be found here. In summary, AGA respectfully request that the city of Austin, Texas remove Appendix CG and Appendix CH from consideration during this code development process. 23 days ago Comments from Electrify America in support of including a power-allocation method as part of the EV-readiness City of Austin- Power-allocation method EV Building Code Requirements.pdf Please see attached comments on behalf of Texas Gas Service Company, a division of ONE Gas, Inc. (“Texas Gas 2024.07.08 - FINAL TGS Comments for Austin Energy Code.xps requirement. 23 days ago Service”) . 23 days ago July 8, 2024 Austin Energy Green Building EV Ready Building Code Commercial IECC [2024] Comment Electrify America applauds the City of Austin for recognizing the need for EV-ready buildings and appreciates the opportunity to submit comments on the city’s proposed building codes. With respect to compliance with these EV-ready codes, Electrify America proposes that the city include a power- based threshold, known as a “power-allocation method,” for meeting these requirements that would serve as an alternative to the benchmark based on percentage of parking spaces in a new facility. Setting a power-based requirement allows a property owner to meet EV charging requirements using the type of charger that best complements the use-case of their parking spaces. And, by doing so, the property owner can provide a better charging service to the driver using their parking space. California adopted the power-allocation method for meeting EV-ready requirements in 2023 which went into effect in 2024.So this is not a novel idea. Not all EV chargers provide the same charging speeds, and not all parking spaces are used the same. So, EV charging minimums should be flexible to allow property owners to comply by installing chargers that best match the use case of their spaces. At parking facilities that host vehicles for long periods of time, like residences and workplaces, slower level 2 chargers requiring hours to provide a meaningful charge can be appropriate. In contrast, at parking facilities that service commercial properties, parking sessions are much shorter. So, level 2 chargers are less effective because they do not offer significant range during the session. In these cases, Direct Current Fast Chargers (DCFC) are a much more appropriate solution because they provide a meaningful amount of range in a short amount of time. Thresholds for compliance with EV charging minimums based on a percentage of spaces disincentivize the build-out of fast chargers where they would be most effective. The reason is that the threshold is typically detrimentally high to be met with DCFC. The thresholds in the proposed language greatly exceed the number of chargers per station that is typical or even possible for fast charging providers. Under the proposed language, a parking facility with as few as 100 spaces would require between 15 and 30 chargers to be in compliance. Larger facilities, with about 1000 spaces could require 150-300 chargers. Even on the lower end of this spectrum, in smaller commercial parking facilities, the required number of stations is extremely high for DCFC providers. For reference, the typical Electrify America station has between 4-6 chargers; though, stations of 8-12 chargers are becoming more common in larger lots. A station of 15 chargers, as could be required in a smaller 100-space lot under the proposed language, would be among the five largest stations in Electrify America’s network. And the lot would likely be too small to host such a large station. 250 fast chargers, even in larger lots, is all but impossible with current technological, infrastructure, and resources limitations. Meeting these EV charging requirements through a combination of DCFCs and level 2 chargers does not alleviate these challenges. The proposed threshold based on the number of spaces could require the installation of dozens, or even hundreds, of level 2 chargers in addition to the fast chargers included in the station. Because demand for fast chargers is highest in facilities where parking sessions are often brief, these level 2 chargers installed merely to meet the statute’s requirements are not likely to provide a meaningful service and not likely to be economically viable. So, the disincentive created by a space-based threshold remains despite compliance being possible. As an alternative, Electrify America supports a requirement that sets a minimum power level, scaled to the size of the parking facility, to be provided by EV chargers. A power-allocation method for compliance would permit a property owner to install the type of charger that best complements their land use and to provide a charging service property owner to install the type of charger that best complements their land use and to provide a charging service that meets the needs of the drivers using their parking facility. The state of California, in the 2023 update to its green building code, known as “Calgreen,” proposed and adopted a power-allocation threshold as an alternative and in addition to one based on the number of spaces. In the “Final Express Terms for Proposed Building Standards….” attached, the Buildings Standards Commission approved a framework that would require, for example, parking facilities of 100 spaces to provide, effectively, 165 kW of power and lots of 1000 spaces to provide 1300 kW of power. This framework right-sizes the EV charging minimums to reflect the large amount of power offered by DCFCs. Charging stations compliant with the National Electric Vehicle Infrastructure (NEVI) program’s standards must include four chargers each providing at least 150 kW charging speeds, though the DCFC industry is capable of reaching 350 kW. So, a power-based requirement also complements the nationwide effort to expand fast charging infrastructure by encouraging the proliferation of NEVI-compliant stations. Although this power-based threshold produces fewer chargers, DCFCs provide greater amounts of charge and range than their level 2 counterparts and service more vehicles during a given time. Utilization data from Electrify America’s public DCFCs and level 2 chargers show that fast chargers dispense nearly 10x the number of kilowatt hours and enable 10x the number of driving miles per year as level 2 chargers. Additionally, level 2 chargers typically experience a number of charging sessions in the hundreds, annually, whereas a DCFC station performs thousands of charging sessions per year. DCFCs’ faster charging speeds provide more range in shorter period of time and result in more frequent turnovers from one session to the next. So, despite producing fewer chargers, the power-based threshold encourages the build-out of charging infrastructure that provides an equal, if not better, service to EV drivers. Power-based requirements provide property owners the flexibility to install the types of chargers, including DCFCs, that best meet the needs of their facility’s users. A power-allocation method of compliance, adopted in California, removes the disincentive to expanding fast charging infrastructure presented by the need for superfluous level 2 chargers simply to meet a minimum. And it does so while enhancing the charging services provided to the EV driver. As Austin considers ways to best support the proliferation of fast charging infrastructure, the city has a unique opportunity to be a leading voice on this matter and positively influence other states nation-wide as they consider doing the same. Electrify America appreciates the opportunity to submit these comments and would be happy to discuss this matter further and answer any questions the Committee may have. Respectfully submitted, /s/ Anthony Willingham Anthony Willingham Government Affairs & Public Policy Lead—State Electrify America LLC 1950 Opportunity Way, Reston, VA 20190 anthony.willingham@electrifyamerica.com Attachment FINAL EXPRESS TERMS FOR PROPOSED BUILDING STANDARDS OF THE CALIFORNIA BUILDING STANDARDS COMMISSION OF THE CALIFORNIA BUILDING STANDARDS COMMISSION REGARDING THE 2022 CALIFORNIA GREEN BUILDING STANDARDS CODE, CALIFORNIA CODE OF REGULATIONS, TITLE 24, PART 11 Power allocation method shall include the following: 1. Use any kVA combination of EV capable spaces, Low Power Level 2, Level 2 or DCFC EVSEs. 2. At least one Level 2 EVSE shall be provided. TOTAL NUMBER OF ACTUAL PARKING SPACES MINIMUM TOTAL kVA @ 6.6 kVA TOTAL kVA REQUIRED IN ANY OF EV CAPABLE, LOW-POWER LEVEL 2, (BSC 04/22) ... TABLE 5.106.5.3.6 COMBINATION LEVEL 2 OR DCFC 0-9 0 0 10-25 26.4 26.4 26-50 52.8 52.8 51-75 85.8 85.8 76-100 112.2 112.2 101-150 165 165 151-200 231 231 201 and over 20 percent of actual parking spaces x 6.6 Total required kVA =P x .20 x 6.6 Where P=Parking spaces in facility 1. Level 2 EVSE @ 6.6 kVA minimum. 2. At least one Level 2 EVSE shall be provided. 3. Maximum allowed kVA to be utilized for EV capable spaces is 75 percent. 4. If EV capable spaces are utilized, they shall meet the requirements of Section 5.106.5.3.1 EV capable spaces. 24 days ago Section C405.11.1 Automatic Receptacle Control - Code amendment should exclude this requirement completely. I am a professional electrical engineer on commercial buildings. Myself and every professional I have asked think the energy needed in wire, devices, and labor required to achieve this likely exceed any energy savings. I have attempted to look up the research and it is very thin. You are doubling the amount of plugs and copper line voltage drops down the wall, plus whatever control system you install to turn them off and on. In the end owners tend to override or not use the controlled receptacles in my experience. Furthermore, in my opinion, controlled receptacles are not safe. These are 120V 20A outlets completely capable of starting a fire. You are turning off outlets to save energy, but keep in mind you are also turning them on unexpectedly. Consider if someone puts something on top a space heater that is off at night, the next day it will turn automatically. We are putting these in schools. Thomas Ingram, P.E. Licensed Texas Professional Engineer #126808 24 days ago Regrading EV Capable, recommend being a specific as possible to leave out the guess work from developers on how to size level2 conduit, circuit requirements for alllevel2: - min of1" conduit per future EVSE pedestal - a service panel or subpanel(s) should be provided with panel space and electrical load capacity for a dedicated 208/240Volt, 40-ampere minimum branch circuit for each EV Capbal space, with the delivery of 30-ampere minimum to an installed EVSE. - EVSE capable panel should be clearly labelled "EVSE future" 24 days ago 24 days ago 24 days ago 24 days ago Please ensure 208/240v is required for all EV-Capable, EV-Ready, and EVSE installs - while 120v is fine for many owners, 240v incentivizes off-peak charging and helps improve adoption rates - consumers always overplan for their needs. This is especially critical for apartments. Observation. EV Ready speaks in KVA. consideration to speak to KW and/or amperage as KVAis typciallynot a name plate listing or how loads are sized with NEC. Prosped EV Ready/ and EVSE install code, consideration to add a requirement for commercial applications to follow US board of access EV accessibility requirements. in short.at least(1) stall @ 11' in width with a 5' Access aisle. https://www.access-board.gov/tad/ev/ California has similar requirements however goes a bit further. see attached guide Section10.4.10.1 - EV Make Ready Code Consideration for a DCFC alternative for those business operations are more in-line with fast serve / quick serve where driver dwell time is <1 hour. see Cal Green Code 5.106.5.3.2.1 “The installation of each DCFC EVSE shall be permitted to reduce the minimum number or required EV capable spaces without EVSE or EVCS with Level 2 EVSE by five and reduce proportionally the required electrical load capacity to serve panel or subpanel.” For Travel Plaza, Quick Serve Restaurant and neighborhood fueling stations, installing level2 is not applicable to use case, additionally it has the tendency to add additional cost for excess panel capacity that is likely to be stranded. The State of Colorado has a similar exemption 1DCFC:10 EVSE Capable/installed stalls. Happy to collaborate and share like-kind scenarios ChargePoint is helping its customers across the country navigate the right product mix for their specific use case and customer experience. 24 days ago Public Citizen strongly supports the City of Austin adopting the IECC 2024 Technical Code for commercial buildings, as proposed by staff. This code update is important for meeting the city's climate, energy and affordability goals. It will improve energy efficiency and the ability to participate in demand response programs for new buildings, while enabling easier and more affordable electrification of transportation and buildings. We support adopting the proposed base code and the proposed electric-ready, EV-ready, demand response and energy storage appendixes. These provisions will reduce greenhouse gas emissions, reduce other air pollution emissions and make buildings more resilient and flexible for future occupants. The EV-ready requirement is important for enabling wider adoption of electric vehicles. Electric vehicles are more affordable than ICE vehicles over time, but access to charging is still a challenge. The cost of installing a charger is significantly less if it is included in the original design of the building. Likewise, planning for future installation of electric appliances is cost-effective. These are important provisions for enabling beneficial electrification and decarbonization, as called for in the Austin Climate Equity Plan. Likewise, demand response and energy storage provisions align with the Austin Climate Equity Plan and the Austin Energy Resource, Generation and Climate Protection Plan. 24 days ago Regarding Appendix CI - proposing an exception/exemption for buildings or campuses that are participating in the Austin Energy Resilience as a Service (Raas) program or utilizing the AE-TES rider. In each of these situations associated facilities will already be effectively performing demand response actions that are either led by AE (RaaS) or performed daily due to the TES rider and not have additional large load to shed during the standard demand response windows. This would not exempt buildings on a campus that are not connected to TES or included in the RaaS evaluation of a campus. Glad to work on language to make this clear. I support the proposed adoption of the 2024 Commercial IECC, including the amendments. Increasing energy efficiency is important for reducing greenhouse gas emissions and local air pollution, keeping bills affordable and increasing electric grid and community resilience. Sierra Club also supports the proposed amendments to and adoption of the 2024 Commercial IECC. In particular, we fully support with local amendments the adoption of appendices related to EV infrastructure and parking, demand responsive controls for space, lighting and water heating (with exceptions for water heater timers), electric energy storage systems, solar-ready, electric-ready and mandatory on-site renewable energy systems (with some exceptions). Assuring that new commercial buildings are incorporating new technology directly - through onsite renewable and storage systems and EV infrastructure - or at least being ready to incorporate will align with community values and ultimately reduce carbon and energy use. 26 days ago 28 days ago 28 days ago Sierra Club also supports the proposed amendments to and adoption of the 2024 Commercial IECC. In particular, we fully support with local amendments the adoption of appendices related to EV infrastructure and parking, demand responsive controls for space, lighting and water heating (with exceptions for water heater timers), electric energy storage systems, solar-ready, electric-ready and mandatory on-site renewable energy systems (with some exceptions). Assuring that new commercial buildings are incorporating new technology directly - through onsite renewable and storage systems and EV infrastructure - or at least being ready to incorporate will align with community values and ultimately reduce carbon and energy use. Cyrus Reed, Sierra Club, Cyrus.reed@sierraclub.org 28 days ago 25-12-263 (A): "The following provisions are local amendments to the commercial provisions of the 2021 International Conservation Code. Each provision in this subsection is a substitute for an identically numbered provision deleted by Section 25-12-261(B) or an addition to the 2021 International Energy Conservation Code." -- I think this is supposed to reference 2024 IECC now yes? 6.5.10 Door Switches. If I understand this correctly, we are effectively turning off HVAC systems in a zone if an exterior door is propped open for more than 5 minutes. This makes pretty good sense. We do not want our buildings to heat/cool the entire neighborhood. No sense in making extremely tight building enclosures if the whole thing can be circumvented by a $0.50 wood doorstop or a landscaping rock you pick up off the sidewalk. On the flip side, is it allowed to automatically turn the systems back on at the previous set points when the door is closed? If not, I can see this playing havoc on the comfort and humidity levels in buildings with multiple tenants. Imagine someone moving into an apartment or dorm building. If you have to manually reset the HVAC systems, the common areas will be wildly uncomfortable before anyone with access to the thermostat will think about turning the system back on. Future Water Heater Space: I included this in the comments to the residential code as well. Why are we requiring a 3'x3'x7' area for the water heater? Even the largest heat pump unit I can find is only 28" in diameter. If the intent to ensure an air volume large enough for the heat exchanger, there are many other solutions including louvered doors, transfer grilles, or ducted supply/return runs. We believe the industry has provided enough variety within the market that we should not be code mandating a specific design solution; especially one that increases current industry footprint standards. 10.5.1.1 On-Site Renewable Energy: Is this section one of the optional points-based energy reduction methods? I understand mandating some sort of Solar Readiness on commercial buildings, that part of the code makes sense, but I certainly hope we are not going to require the general public to privately subsidize electrical production. I don't see how we can force people to pay for and install solar on their building. one month ago Please include an ERV exemption for multi-family dwelling units. IECC C403.7.4.1 The commercial section of the IECC requires ERVs to be installed in all buildings. ERVs are not currently a sufficiently effective nor cost-effective solution for multi-family dwelling units in Austin’s climate. While most commercial buildings require a relatively small number of larger, more efficient ERVs that can serve large areas, dwelling units each require their own smaller, less-efficient, and more expensive ERVs. The majority of projects that come across this requirement use a performance path to avoid the requirement and easily meet the overall code requirements without them. Some projects have paid the additional fees for an energy model solely to avoid the more expensive path of providing ERVs. Note that this is not just an issue for non-transient dwelling units - there may be instances where transient units for shelters and other short-term housing is impacted; however, the impact on hotels and non-housing related transient units and the needs/benefits in those scenarios is outside the scope of the housing impact. Recommendations: Modify IECC C403.7.4.1 to refer to dwelling units and add exemptions that cover multi-family housing and shelter housing. Edit C403.7.4.2 to conform language one month ago IECC C403.7.4.1 Please include an ERV exemption for multi-family dwelling units. The commercial section of the IECC requires ERVs to be installed in all buildings. ERVs are not currently a sufficiently effective nor cost-effective solution for multi-family dwelling units in Austin’s climate. While most commercial buildings require a relatively small number of larger, more efficient ERVs that can serve large areas, dwelling units each require their own smaller, less-efficient, and more expensive ERVs. The majority of projects that come across this requirement use a performance path to avoid the requirement and easily meet the overall code requirements without them. Some projects have paid the additional fees for an energy model solely to avoid the more expensive path of providing ERVs. Note that this is not just an issue for non-transient dwelling units - there may be instances where transient units for shelters and other short-term housing is impacted; however, the impact on hotels and non-housing related transient units and the needs/benefits in those scenarios is outside the scope of the housing impact. Recommendations: Modify IECC C403.7.4.1 to refer to dwelling units and add exemptions that cover multi-family housing and shelter housing. Edit C403.7.4.2 to conform language Chris Gannon, Architect Co-chair of Austin AIA Housing Advocacy Committee one month ago 1. Appendix CJ speaks to required storage of electricity on site. Are other forms of energy storage also acceptable responses to the requirement? 2. These changes appear to treat every project/site as separate entities. For larger facilities there may be many facilities on a single or adjacent sites. LEED and other rating entities have provisions for campus type accommodations of energy requirements to enable innovation on larger scales than individual projects might initiate. Will the City accept such campus wide solution options? one month ago Residential - IECC [2024] Project Engagement VIEWS 186 PARTICIPANTS RESPONSES COMMENTS SUBSCRIBERS 27 0 29 2 Please provide a comment or question about the proposed Residential provisions of the International Energy Conservation Code (IECC) 2024 Technical Code Amendments in the space below. Please respond by July 9, 2024. July 8, 2024 Attention: Public Comments Dear Austin Energy Green Building Staff, Vehicle Readiness proposals of the 2024 International Energy Conversation Code (IECC) The Alliance for Transportation Electrification supports Tesla's comments and appreciates the opportunity to comment on Austin Energy’s Residential and Commercial Electric Vehicle Readiness proposals of the 2024 International Energy Conversation Code (IECC). We applaud the City’s leadership in pushing forward the energy code in a timely manner. Although many cities and states have adopted energy codes, only a handful have been proactive in adopting, updating, and enforcing the most up-to-date codes. Energy codes ensure that a building's energy use is included as a fundamental part of the design and construction process of new buildings; making an early investment in building energy improvements will pay dividends to Austin residents for years into the future. We offer the following comments on the 2024 IECC Electric Vehicle Readiness proposals for both commercial and residential buildings. R-2 occupancies. 1. We support the residential electric vehicle readiness proposal for one-and two- family dwellings, townhomes, and The residential proposal derived from Appendix RE of the 2024 IECC Residential code requires that new one- and two-family dwellings and townhouses with designated parking provide one EV capable, EV ready, or EVSE space per dwelling unit. Multifamily buildings with four stories or less must provide an EV capable space, EV ready space, or EVSE space for 40 percent of dwelling units or automobile parking spaces, whichever is less. These requirements give building owners flexibility in establishing the level of EV readiness that will fit their current and future needs, while still providing the necessary minimum EV charging load that the distribution system needs to be sized for. Moreover, the language in Appendix RE was developed as a consensus proposal during the IECC code development process with input from a diverse group of stakeholders including representatives from the home builders, electrical manufacturers, EV charging providers, and utilities. It went through several rounds of public comment and editorial changes to ensure clarity, consistency, enforceability, and technical soundness. Adopting Appendix RE outright would help staff streamline and quicken the public input process given that the language has already been 2. We strongly recommend increasing EV-ready requirements and including EVSE- installed spaces for certain thoroughly vetted. commercial occupancy types We are concerned that the omission of EV-ready and EVSE-installed spaces in Table CG101.2.1 from all commercial occupancy types expect Groups R-1 and R-2 will result in an under-investment in necessary charging infrastructure to support current and future EV drivers in Austin. The current proposal heavily stacks EV-capable requirements across nearly all commercial building types, which puts the burden on building owners, EV drivers, or tenants to have an outlet or EVSE wired and installed at their parking space. While an EV capable space requires panel capacity, a dedicated circuit and raceway, it does not include a way for someone to drive up to a parking spot and plug in and charge. In particular, this barrier presents a significant obstacle to installing EV infrastructure at multi-family dwellings, which have proven to be the most challenging sector to deploy EV infrastructure. Unlike residents of single-family homes, multi-family tenants are commonly renters without the authority to retrofit parking spaces to install charging equipment. When retrofitting to provide EV charging is possible, tenants and owners can face costs of 4-6 times higher than if done during new construction2. The ability to charge an EV overnight is additionally important for multifamily tenants who are rural, low-income, and in disadvantaged communities, who typically have longer commutes and drive older EVs with shorter ranges. Several cities and counties across the country have included ambitious EVSE-installed and EV- ready requirements for commercial building types, including Scottsdale, Tucson, Coral Gables, St. Petersburgh, St. Louis County, Charlotte, Columbus, Orlando, Chicago, Seattle, and many others. We recommend that Austin match or exceed the ambition of its peer cities and adopt EV-ready and EVSE-installed requirements for new commercial buildings Tesla ambition of its peer cities and adopt EV ready and EVSE installed requirements for new commercial buildings. Tesla proposes revisions to Table CG101.2.1 in the Appendix 1. 3. We recommend including a Direct Current Fast Charging (DCFC) compliance pathway that provides new commercial buildings the option to meet compliance with charging that mirrors dwell times. Depending on the type of nonresidential building and the typical dwell time a vehicle is parked, a higher power level for charging beyond a standard Level 2 charger may be most beneficial. A DCFC compliance pathway would allow new non-residential buildings the option to meet EV- capable and EVSE compliance either through Level 2 or DCFC. For example, commercial buildings with short dwell times, such as grocery stores, would have the ability to use a DCFC compliance ratio of 5:1 EVSE installed if minimum requirements are met and at least one Level 2 EVSE is installed. A DCFC compliance option is important as it provides building owners with the incentive to go beyond minimum EVSE requirements and the optionality to install the level of EV charging, either Level 2 or DCFC, that best fits customer needs. This optionality also results 2 https://caletc.aodesignsolutions.com/assets/files/CALGreen-2019-Supplement-Cost-Analysis-Final-1.pdf in a more efficient use of state and private infrastructure investment given more optimal charging station usage. ATE proposes recommended language in the attached Appendix 2. . ATE appreciates the opportunity to provide feedback on 2024 IECC Electric Vehicle Readiness proposals for both commercial and residential buildings. We look forward to continued work with the City of Austin on its transportation electrification efforts. Thank you for the opportunity to submit these comments. Sincerely, Rick Tempchin Alliance for Transportation Electrification rick@evtransportationalliance.org 202-258-2912 *** APPENDIX 1 TABLE C405.14.1 EVSE Spaces EV Ready Spaces 5% 0% 10% 0% 10% 0% 0% 10% 0% 10% 0% 5% 5% 0% 0% EV Capable Spaces 10% 0% 5% 0% 0% 10% 0% 30% 30% Language to be added is underlined. Language to be removed is struck. REQUIRED EV POWER TRANSFER INFRASTRUCTURE Occupancy Group A Group B Group E Group F Group H Group I Group M Group R-1 Group R-2 Group R-3 and R-4 Group S exclusive of parking garages Group S-2 parking garages 5% 0% 5% 0% 5% 0% 2% 0% 1% 0% 5% 0% 5% 0% 10% 0% 10% 0% 0% 30% 5% 0% 30% 30% 35% 35% 5% 0% 30% APPENDIX 2 Language to be added is underlined. Language to be removed is struck. CG101.2.1 Quantity. The number of required electric vehicle (EV) spaces, EV capable spaces and EV ready spaces shall be determined in accordance with this section and Table CG101.2.1 based on the total number of automobile parking spaces and shall be rounded up to the nearest whole number. For R-2 buildings, the Table CG101.2.1 requirements shall be based on the total number of dwelling units or the total number of automobile parking spaces, whichever is less. 1. Where more than one parking facility is provided on a building site, the number of required automobile parking spaces required to have EV power transfer infrastructure shall be calculated separately for each parking facility. 2. Where one shared parking facility serves multiple building occupancies, the required number of spaces shall be determined proportionally based on the floor area of each building occupancy. 3. Installed electric vehicle supply equipment installed spaces (EVSE spaces) that exceed the minimum requirements of this section may be used to meet the minimum requirements for EV ready spaces and EV capable spaces. 4. Installed EV ready spaces that exceed the minimum requirements of this section may be used to meet the minimum requirements for EV capable spaces. 5. Where the number of EV ready spaces allocated for R-2 occupancies is equal to the number of dwelling units or to the number of automobile parking spaces allocated to R-2 occupancies, whichever is less, requirements for EVSE spaces for R-2 occupancies shall not apply. 6. Requirements for a Group S-2 parking garage shall be determined by the occupancies served by that parking garage. Where new automobile spaces do not serve specific occupancies, the values for Group S-2 parking garage in Table CG101.2.1 shall be used. 7. Group S-2 parking garages with no less than 50% long term parking spaces shall provide no less than 10% EV capable spaces. Long term parking spaces are considered as parking spaces where users generally park for more than 8 hours at a time, including overnight, at places such as airports, transit hubs, etc. 8. The installation of Direct Current Fast Charging (DCFC) EVSE shall be permitted to reduce the minimum number of required EV capable or EV ready spaces without EVSE or EVCS with Level 2 EVSE by five and reduce proportionally the required electrical load capacity to the service panel or subpanel. 22 days ago 22 days ago Please see attached letter in support of IECC 2024 Technical Code Amendments from SPEER. 2024 Proposed Code Adoption Austin Letter.pdf Please see the attached comments. 2024.07.08 - Atmos Energy Comments - 2024 Technical Code Amendments - Residential.pdf I support the proposed adoption of the 2024 Residential IECC, including the EV-ready, electric-ready, and demand response amendments. Increasing energy efficiency is important for reducing greenhouse gas emissions and local air pollution, keeping bills affordable and improving electric grid and community resilience. Building homes so that future residents can easily and affordably choose electric appliances and electric vehicles is important. There is one change I’d like to see to allow for full efficient electrification of all new homes. Remove the exemption for providing the required space if a home has a water heater on the outside of the house. Today is the final day to submit a comment on the City of Austin’s proposed adoption of the 2024 International Energy Conservation Code (IECC). This part of the building code ensures that new buildings are built to conserve energy and allow for the use of clean energy. Improving building energy efficiency is key to combating climate change, keeping electric bills affordable, and avoiding electric grid collapse. This code update will make new buildings more airtight and more efficient, and will include a few key provisions that will allow future building owners to choose electric appliances without expensive retrofits. (When a resident or business owner can simply buy an appliance and plug it in, the choice to use clean electric options becomes a lot more attractive!) There will also be a new requirement to leave sufficient space for a hot water heat pump, which looks much like a standard water heater tank but uses much less energy. Heat pumps take up about the same space as a standard hot water tank, so the problem mostly arises when replacing a tankless water heater with a heat pump. However, we need one important change to the Austin Residential IECC proposal to allow for full and efficient electrification of all homes: Remove the exemption for providing the required space if a home has a water heater on the outside of the house. Codes. We support the proposed adoption of the 2024 Residential and Commercial International Energy Conservation We support the proposed adoption of the 2024 Residential IECC, including the EV-ready, electric-ready, and demand response amendments. Increasing energy efficiency is important for reducing greenhouse gas emissions and local air pollution, keeping bills affordable and improving electric grid and community resilience. Building homes so that future residents can easily and affordably choose electric appliances and electric vehicles is important. There is one change I’d like to see to allow for full efficient electrification of all new homes. Remove the exemption for providing the required space if a home has a water heater on the outside of the house. 23 days ago 23 days ago Thank you 23 days ago I support the proposed adoption of the 2024 Residential IECC, including the EV-ready, electric-ready, and demand response amendments. There is one change I’d like to see to allow for full efficient electrification of all new homes. Remove the exemption for providing the required space if a home has an existing water heater on the outside of the house. 23 days ago 23 days ago 23 days ago I support the proposed adoption of the 2024 Residential IECC, including the EV-ready, electric-ready, and demand response amendments. Increasing energy efficiency is important for reducing greenhouse gas emissions and local air pollution, keeping bills affordable and improving electric grid and community resilience. Building homes so that future residents can easily and affordably choose electric appliances and electric vehicles is important. However, there is one change I’d like to see to allow for full efficient electrification of all new homes. Remove the exemption for providing the required space if a home has a water heater on the outside of the house. The city had one time provided for free home thermostats, which had the option of turning down or off the power during certain parts of the day. Those are still available or citizens could be allowed to purchase them at a reasonable price, that would provide a lot of saved electric energy. Thank you. The HBA's biggest concern with the 2024 IECC is centered around affordability. We appreciate that the 2024 code is more performance based and less prescriptive than the 2021 code, which allows builders the necessary flexibility they need to meet the code. However, there are some elements that we believe are a step too far and will unnecessarily add additional cost to the price of a home. 1. Electric vehicle capable / electric vehicle ready / EVSE space – Whether or not a home is built to accommodate an electric vehicle should lie solely with the homebuyer. EV capable has a minimal impact on affordability of approximately $500. However, electric ready and the full EVSE space would likely add $1,000+ to the price of a home. Since this code will affect all new construction, it will increase the cost of even the most affordable homes. We would request that the city leave this decision up to the homebuyer. However, if the city decides to move forward with this proposal, we ask that the city maintain the current draft that allows the least expensive method (electric vehicle capable) to meet the new code. 2. Do not go above or beyond the model code, specifically regarding the residential all-electric appendix that was not included in the base code. There are many reasons why a homebuyer might prefer gas appliances over electric, some of which are personal preference and others which are safety related. For example, during the freeze, when much of the city lost power, many homes with gas appliances were still able to prepare food and boil water. We would suggest the city consider strong incentives for the homebuilder and the homebuyer to switch over to electric appliances if they choose to do so. We understand that the ICC process is rigorous and has taken longer than anticipated. However, as stakeholders, it is difficult to fully weigh in on these proposed changes before the model code is finally released. We would request that the city open up the public input process again once the model code is released and can be reviewed along with the proposed amendments. The HBA is working with AE staff to provide more educational opportunities for our members. We ask that the City not rush to adoption and allow for a back-and-forth conversation with users and practitioners. If you have any questions, please reach out to David Glenn at david@hbaaustin.com. Upon further examination, Sierra Club believes that the exemption from the space requirement to accommodate a heat pump water heater for homes with an external tankless water heater is unnecessary and will inhibit beneficial electrification of homes. We recommend that exception be removed. We strongly support code changes to increase energy efficiency as an important action to reduce greenhouse gas emissions and local air pollution, keep bills affordable, and increase electric grid and community resilience. We hope to emphasize the importance of code that builds homes so that future residents can easily and affordably choose electric appliances and electric vehicles is I support the proposed adoption of the 2024 Residential IECC, including the EV-ready, electric-ready, and demand response amendments. Increasing energy efficiency is important for reducing greenhouse gas emissions and local air pollution, keeping bills affordable and improving electric grid and community resilience. Building homes so that future residents can easily and affordably choose electric appliances and electric vehicles is important. There is one change I’d like to see to allow for full efficient electrification of all new homes. Remove the exemption for providing the required space if a home has a water heater on the outside of the house. 23 days ago important. 23 days ago 23 days ago Revised The American Gas Association (AGA) represents more than 200 local energy companies committed to the safe and reliable delivery of clean natural gas to more than 73 million customers throughout the nation. AGA appreciates the opportunity to comment on the proposed changes to the City of Austin’s residential energy code. Our first concern is the city is not referencing a published 2024 edition of the IECC but relies on a redline version that may not be what is eventually published by the ICC. We would ask that the efforts to modify the residential Austin, Texas energy code be based on a published and publicly available edition of the 2024 IECC and not rely on a redline version that may have, for a number of reasons, differences then the published 2024 IECC. Regarding the proposed revisions to add Appendix RE Electric Power Transfer provisions Appendix RK – Electric- Ready provisions, we do not believe these additions help the city to meet its energy and emissions reduction goals and in fact, will result in an overall increase in both as well as an increase in construction cost that will impact the affordability of new and existing structures. Regarding the Electric Vehicle power transfer provisions, it is clear that this will add significant cost and electricity usage with no specific documentation and analysis that justifies the benefits of such and extensive requirement for residential building installations. The Appendix RK – Electric-Ready provisions is even more troublesome since it adds a costly requirement that may never be used in residential applications and if eventually used, can actually add more source energy use than the fossil fuel appliances that it targets for possible future replacement. The ICC Board of Directors took the logical action at the end of the 2024 International Energy Conservation Code development process to remove both the Electric Vehicle provisions and the Electric-Ready residential building provisions from the compliance requirements of the 2024 IECC and we urge that the City of Austin, Texas to do the same. The AGA March 20, 2024 Press Release that provides the March 18, 2024 ICC Board of Directors action on these requirements can be found here. In summary, AGA respectfully request that the city of Austin, Texas remove Appendix RE and Appendix RK from consideration during this code development process. 23 days ago The American Gas Association (AGA) represents more than 200 local energy companies committed to the safe and reliable delivery of clean natural gas to more than 73 million customers throughout the nation. AGA appreciates the opportunity to comment on the proposed changes to the City of Austin’s residential energy code. Our first concern is the city is not referencing a published 2024 edition of the IECC but relies on a redline version that may not be what is eventually published by the ICC. We would ask that the efforts to modify the residential Austin, Texas energy code be based on a published and publicly available edition of the 2024 IECC and not rely on a redline version that may have, for a number of reasons, differences then the published 2024 IECC. Regarding the proposed revisions to add Appendix RE Electric Power Transfer provisions Appendix RK – Electric- Ready provisions, we do not believe these additions help the city to meet its energy and emissions reduction goals and in fact, will result in an overall increase in both as well as an increase in construction cost that will impact the affordability of new and existing structures. Regarding the Electric Vehicle power transfer provisions, it is clear that this will add significant cost and electricity usage with no specific documentation and analysis that justifies the benefits of such and extensive requirement for residential building installations. The Appendix RK – Electric-Ready provisions is even more troublesome since it adds a costly requirement that may never be used in residential applications and if eventually used, can actually add more source energy use than the fossil fuel appliances that it targets for possible future replacement. The ICC Board of Directors took the logical action at the end of the 2024 International Energy Conservation Code development process to remove both the Electric Vehicle provisions and the Electric-Ready Commercial Building Provisions from the compliance requirements of the 2024 IECC and we urge that the City of Austin, Texas do the same. The AGA March 20, 2024 Press Release that provides the March 18, 2024 ICC Board of Directors action on these requirements can be found here. In summary, AGA respectfully, request that the city of Austin, Texas remove Appendix RE and Appendix RK from consideration during this code development process. 23 days ago Service”). 23 days ago capacity or conduit. 24 days ago Please see attached comments on behalf of Texas Gas Service Company, a division of ONE Gas, Inc. (“Texas Gas 2024.07.08 - FINAL TGS Comments for Austin Energy Code.docx For EV-capable spaces, please specify 1" or greater conduit, 4-wire, 50A capacity. This eliminates undersizing the Public Citizen strongly supports the City of Austin adopting the IECC 2024 Technical Code for residential buildings, as proposed by staff, with one exception. This code update is important for meeting the city's climate, energy and affordability goals. It will improve energy efficiency and the ability to participate in demand response programs for new buildings while enabling easier and more affordable electrification of transportation and buildings. We support adopting the proposed based code and the proposed electric-ready, EV-ready, and demand response appendixes. These provisions will reduce greenhouse gas emissions, reduce other air pollution emissions and make buildings more resilient and flexible for future occupants. The EV-ready requirement is important for enabling wider adoption of electric vehicles. Electric vehicles are more affordable than ICE vehicles over time, but access to charging is still a challenge. The cost of installing a charger is significantly less if it is included in the original design of the building. Likewise, designing for future installation of electric appliances is cost-effective. These are important provisions for enabling beneficial electrification and decarbonization, as called for in the Austin Climate Equity Plan. Likewise, the demand response provision aligns with the Austin Climate Equity Plan and the Austin Energy Resource, Generation and Climate Protection Plan. The one change that we request is for the exemption is for exception number 2 to section “RK101.1 Electric readiness” to be removed. This exception to the requirement to provide space for a heat pump water heater contradicts the goal of electrifying and decarbonizing buildings. It would leave future homeowners without an easy option to switch to an efficient heat pump water heater without incurring the significant cost of creating a space for it in the home and hiring a plumber and an electrician to connect a heat pump where one was not designed for. Additionally, including this exception could encourage more builders to install tankless water heaters on the exterior of homes, leaving them vulnerable during freezing temperatures. Many water heaters on the exterior of homes were damaged and required replacing after Winter Storm Uri. Not only does this inconvenience residents, it is also a waste of resources. The City of Austin should be encouraging resilient design of homes. Including this exception could encourage more such poor design because a builder may want to avoid the water heater space requirement and the only way to do so would be to place the tankless water heater outside. We request a conversation with the appropriate staff to discuss removing this exception. 24 days ago I received this sample input from Public Citizen and completely agree with the proposals below. The largest portion of my energy bill is air conditioning and appliances. As the owner of several EVs since 2013, I can tell you that the main deterrent to faster adoption is the lack of reliable and widespread charging infrastructure. In-home charging is the most accessible and convenient way to charge. These proposals will help tremendously to reduce air pollution and CO2 emissions, and increase access to solutions. I support the proposed adoption of the 2024 Residential IECC, including the amendments. Increasing energy efficiency is important for reducing greenhouse gas emissions and local air pollution, keeping bills affordable and increasing electric grid and community resilience. Building homes so that future residents can easily and affordably choose electric appliances and electric vehicles is important. There are two changes I’d like to see to allow for full efficient electrification of all new homes. 1) Adopt the EV-Ready amendment to allow for affordable installation of a car charger. 2) Remove the exemption for providing the required space if a home has a water heater on the outside of the house. 28 days ago The Sierra Club fully supports the adoption of the 2024 IECC for both commercial and residential buildings. Indeed, lowering energy use and incorporating new technology is a key tool to meet our long-term energy and climate goals, and because buildings can last well over 50 years, making sure new and refurbished buildings use less energy is of paramount importance. Austin has been a leader on energy codes, and adoption of the 2024 IECC would help cement this leadership. We have reviewed both proposals and appreciate in particular for the residential IECC, the adoption of the solar- ready, EV-ready and electric-ready, as well as water heater demand response requirements. We also support the additional energy savings required for those builders choosing the performance path. Adoption of the residential 2024 IECC with local amendment and required appendices should save energy (and water), lower carbon, and make future apartments and homes better prepared to embrace new technologies like electric vehicles, electric appliances and onsite solar and storage. According to the DOE’s Pacific Northwest National Laboratory, in climate zone 2, the improvements to the 2024 IECC should result in 5.16% energy savings, 7.10% energy cost savings and 7.07% carbon cost savings. While we understand that the 2024 IECC did lower the R-value requirement for ceiling insulation in residential buildings from 49 to 38 for the prescriptive path, we ask that the CIty of Austin consider as a requirement an R-value of 42, as the City of San Antonio recently adopted. This would be a good compromise for those builders picking the prescriptive path. We are very appreciative of the inclusion of water heater demand response and spacing requirements and agree that an exception for those water heaters that have predetermined timing controls would not need to meet the demand response requirements. We also support the spacing requirements for water heaters, as well as the exceptions provided for tankless water heaters located on the outside of dwellings, heat pump water heaters and those serving more than one unit. The City of Austin should consider other exceptions to the water heater space requirements as appropriate. Finally, the City of Austin should consider formally prohibiting space heaters that rely on resistance heating given the availability of space electric pump heating. 28 days ago After reviewing here are my comments, questions: 1. changing R-49 to R-38, will this will affect the U-values used in the IC3 calculation? 2. R-20 to R-25 entirely above roof decking - does IC3 distinguishing between above and below roof deck insulation. Making sure IC3 doesn’t default foamed roofs to the “entirely above” R-25 vs. current R-20. 3. Hallelujah, glad your getting rid of the magical R-15 by filling 2x4 cavity!!! 4. Duct Testing Targets, thank you for opting for the less complicated. 5. Future space for HP Water heaters may cause issue in smaller homes where they tuck the mech. closet under stairs. one month ago All is I have no issues with and have heard nothing from our COA clients. I support the proposed adoption of the 2024 Residential IECC, including the amendments. Increasing energy efficiency is important for reducing greenhouse gas emissions and local air pollution, keeping bills affordable and increasing electric grid and community resilience. Building homes so that future residents can easily and affordably choose electric appliances and electric vehicles is important. There are two changes I’d like to see to allow for full efficient electrification of all new homes. 1) Adopt the EV-Ready amendment to allow for affordable installation of a car charger. 2) Remove the exemption for providing the required space if a home has a water heater on the outside of the house. one month ago of the house. one month ago different assemblies. both? market? one month ago I support the proposed adoption of the 2024 Residential IECC, including the amendments. Increasing energy efficiency is important for reducing greenhouse gas emissions and local air pollution, keeping bills affordable and increasing electric grid and community resilience. Building homes so that future residents can easily and affordably choose electric appliances and electric vehicles is important. There are two changes I’d like to see to allow for full efficient electrification of all new homes. 1) Adopt the EV-Ready amendment to allow for affordable installation of a car charger. 2) Remove the exemption for providing the required space if a home has a water heater on the outside Insulation Requirements: Thank you for reducing attic insulation from R49 to R38. Our own analysis shows dwindling returns for the cost above R38. We also appreciate the distinction between attic/ceiling insulation, under roof deck insulation, and above roof deck insulation. It is nice that our code recognizes that those are all very Heated Slab Insulation: Does this requirement also apply to heated floor assemblies NOT embedded in the slab? Schluter's Ditra-Heat for example? Also, we have had inspectors fail slab edge insulation because it prevents a termite separation/inspection gap between the ground and the framing. Are there examples of how to accomplish R402.5.1.2 Air Leakage Testing: "During testing Exterior or Interior terminations of continuous ventilation systems shall be sealed." What about discontinuous ventilation? Bathroom exhaust fans, Hood vents, Intermittent Fresh Air Intake systems, etc.? Can those be taped off for the blower door testing as well? RK101.1.5 Water Heater Space: What is the purpose of the required 3'x3'x7' area? Even the largest heat pump water heater I can find only has a 28" diameter. If a water heater closet does not have enough volume for the air exchange, there are PLENTY of design options to make the system work; ducting, louvered doors, transfer grilles, etc. Why are we mandating one specific design solution when the industry already provides enough flexibility in the I am asking to remove resistance water heating from Residential buildings when it is the main hot-water supply. The use of this energy-wasteful technology affects the poor the most, since many multifamily and tract-home units are built with this equipment. Continued installation of resistance water heat not only adversely affects these specific consumers directly. It raises the summer peak demand (and the cost of summer peak demand) for all consumers who are Austin Energy I have spoken with a resident expert on the legality of this at the City of Austin legal department, and he has not provided any solid legal rationale as to why there would be a problem with this proposal. customers. one month ago one month ago Support for ERV exceptions in multi family and shelters. International Energy Conservation Code (IECC) Commercial - IECC [2024] Comment Attachments  To: Austin Mayor and City Council From: Todd McAlister, Executive Director, South-central Partnership for Energy Efficiency as a Resource Date: July 9, 2024 Re: International Energy Conservation Code 2024 Technical Code Amendments Honorable Mayor Watson and City Council Members, The South-central Partnership for Energy Efficiency as a Resource (SPEER) is the U.S. Department of Energy (DOE) recognized Regional Energy Efficiency Organization supporting energy and building code education, adoption and compliance throughout Texas and Oklahoma. Through this work, SPEER facilitates educational trainings and acts as a resource for local governments and the state as they seek to adopt new energy and building codes. In this capacity, SPEER supports the efforts of the City of Austin to review and consider adoption of the 2024 International Energy Conservation Code (IECC 2024) with amendments. The review, adoption, and enforcement of updated energy codes across the state will enhance efficiency in new buildings, lower energy costs for homeowners, and increase reliability and resiliency to the region’s energy grid. As new technologies flow into the region and the state prepares for a more diverse resource mixture to the wholesale electricity market, it is imperative for cities like Austin to adopt new codes to adequately prepare and receive the added efficiency gains which provide passive survivability and lower bills to the ratepayer. Residential Amendments: Relating to the IECC 2024 Residential Code Amendments outlined by the current proposal, SPEER supports the proposal for adoption with amendments by the City of Austin. The proposal provides consumers with adequate choice in fuel types through requiring electric ready homes, however, stops short of mandating specific fuel type requirements. This change allows for easier adoption of electric vehicles and backup generation for residents while not limiting their options for implementing new measures. Additionally, the changes to the ceiling insulation portions of the code protects residents of Austin from incoming heat transfer from their roofs which will ultimately aid in conserving energy in heating and cooling of homes. Lastly, the updated “pick-a-package” for home appliances will work as a force multiplier for conserving energy and reducing costs for customers. Maintaining an updated home envelope and with new energy efficient appliances will build the city’s resiliency and reliability during peak summer months and extreme weather events year-round. These savings are noted in the Pacific Northwest National Labs reporting on the 2024 IECC suite. The Residential updates will result in increases of 5% energy savings, 7% energy cost savings, and reductions of carbon emissions for the region of 7%. Commercial Amendments: SPEER supports the proposed amendments for the 2024 IECC Commercial Model Codes. Similar to the Residential Model Codes, the Commercial amendments provide electric ready commercial buildings without limiting consumer choice for implementation of measures. Through providing electric ready P.O. Box 1246 n Buda, Texas 78610 n phone: 512-279-0750 n www.eepartnership.org n @EEpartnership buildings, consumers have the opportunity to install their choice of fuel type for backup generation resources, as well as being prepared for increased electric vehicle adoption in the region. Conclusion: SPEER appreciates the opportunity to submit this letter of support for adoption and implementation of the 2024 IECC suite and looks forward to working with the City of Austin for additional amendments and adoption in the future. Sincerely, Todd McAlister Executive Director, SPEER Cc: Randy Plumlee, Codes Program Manager, SPEER Noah Oaks, State and Local Policy Manager, SPEER SPEER Page 2  Eric.Tate@atmosenergy.com July 8, 2024 City of Austin Austin City Hall 301 W. Second St. Austin, TX 78701 Re: Dear City of Austin: Comments on Proposed 2024 Technical Code Amendments Atmos Energy Corporation (“Atmos Energy”) supports fuel-neutral energy codes that are consistent with state and federal law. As proposed, the 2024 Technical Code would adopt provisions of the International Energy Conservation Code (“IECC”) and 2024 IECC appendices that advance the electrification of homes and businesses. Atmos Energy urges the City not to include these provisions in the final 2024 Technical Code. Atmos Energy is the nation’s largest natural-gas-only distributor, serving more than three million natural gas distribution customers in over 1,400 communities in eight states, from the Blue Ridge Mountains in the East to the Rocky Mountains in the West. Included in Atmos Energy’s service territory is the City of Austin, within which Atmos Energy serves approximately 11,000 customers. Atmos Energy’s vision is to be the safest provider of natural gas services and the company is committed to the safety and success of our communities, the environment, delivering a reliable source of energy, and providing exceptional customer service. This vision continues to fuel Atmos Energy’s investment in modernizing its system, which is integrated with our comprehensive environmental strategy focused on reducing the environmental impact from our operations. This strategy includes a robust set of programs that improve consumer energy efficiency within our service territories. Efforts to affordably increase energy efficiency for the broadest number of residents and businesses should be fuel neutral. Currently, the proposed 2024 Technical Code amendments would adopt provisions that favor electrification.1 Before finalizing the amendments, Atmos encourages the City to consider the following— 1. Fuel neutral measures promote efficient appliances and reliable energy. Atmos Energy’s SmartChoice Energy Efficiency Program offers rebates and incentives for businesses and residential customers, including those in the City, who install energy-efficient natural gas 1 Attachment A lists the 2024 IECC provisions the City has proposed to include in the 2024 Technical Code amendments that advance electrification. Atmos Energy Corporation | 5430 LBJ Freeway | 1800 Three Lincoln Centre | Dallas, TX 75240 | 972-855-3756 Office | 972- 855-3080 Fax appliances such as furnaces, tankless water heaters, smart thermostats, and more.2 The efficiency benefits of natural gas appliances are heightened when considering the energy consumed to generate and distribute the resource—transporting natural gas from wellhead to consumer’s meter results in less than 10% of energy lost, compared to a 63% energy loss in transporting electricity from powerplant to consumer home.3 2. Fuel neutrality is the most affordable approach to achieving emission reductions. Costs are a significant factor in a consumer’s decision to replace an appliance in their home, and natural gas appliances are often a more affordable option for improving energy efficiency. For example, in the forecast of the Department of Energy (“DOE”) of the average unit costs of residential energy sources, the DOE found that electricity is 3.3 times more expensive than the equivalent energy through the direct use of natural gas.4 Atmos Energy recommends that the City work with local industry to fully understand the actual cost impacts of imposing the provisions being considered. 3. Whether the codes at issue cost effectively increase energy efficiency is untested. In considering electric-favoring provisions, fuel neutral alternatives were not adequately evaluated as part of the 2024 IECC code development process. For example, the underlying analyses supporting the electric-readiness appendices were flawed and oversimplified—only comparing costs at time of construction versus retrofitting.5 Further, earlier this year, the Board of the International Code Council—the organization responsible for developing the 2024 IECC—found that certain provisions, including some in the 2024 Technical Code amendments, were not consistent with the intended purpose of “providing the minimum efficiency requirements for buildings that result in the maximum level of energy efficiency that is safe, technologically feasible, and life cycle cost effective considering economic feasibility, including potential costs and saving for consumers and building owners, and return on investment.”6 4. The codes at issue do not concern energy conservation. The International Code Council Board evaluated the function of the codes at issue here and found that they do not “concern[] . . . building energy conservation.”7,8 Accordingly, these codes do not accomplish the Technical Code’s foundational purpose of conserving energy use by homes and businesses and should not be included in the final 2024 Technical Code.9 2 Atmos Energy, Mid-Tex SmartChoice Rebates, https://www.atmosenergy.com/ways-to-save/mid-tex-appliance- rebate-program/. 3 Atmos Energy, Natural Living: Natural Gas: The Natural Choice for a Better Home, a Better Environment (Spring/Summer 2024) at 11, https://www.atmosenergy.com/static/6678f502ccd0cdf430497f5b2c934daf/Natural%20Living%20Spring%202024. pdf. 4 Energy Conservation Program for Consumer Products: Representative Average Unit Costs of Energy, 88 Fed. Reg. 58,575, 58,576 (Aug. 28, 2023). 5 Such analysis overlooks the possibility that electric readiness measures may never be fully utilized, as well as the varying timelines on which buildings will begin to utilize their readiness infrastructure. 6 International Code Council, 2024 IECC Appeals: ICC Board of Directors Actions Report, Apr. 11, 2024, at 6. 7 Id. at 10. 8 Also of note, the Board went on to determine that all-electric requirements pose a “significant risk of preemption based on case law” and added “[a] cautionary note regarding the risk of preemption.” Id. at 5 9 See Austin, Texas Code, Section 25-12-261 (entitled “International Energy Conservation Code”) 2 To aid in the City’s review of the proposed 2024 Technical Code amendments, a list of the 2024 IECC provisions that should not be included in the final 2024 Technical Code amendments is attached. Atmos Energy sincerely appreciates the City’s consideration of these comments. Please do not hesitate to reach out to Eric Tate at 469-975-4615 if you have questions or would like to discuss these comments further. Atmos looks forward to continuing to engage with the City on the code amendment process. Sincerely, Eric Tate Manager of Public Affairs Atmos Energy Corporation cc: Austin Energy Green Building Staff * * * 3  Attachment A As explained in Atmos Energy’s comments, we ask that the City omit or make optional the following proposed provisions which directly or indirectly preference electrification: Commercial:  Section C8.4.5: Additional Electric Infrastructure  Appendix CB: Solar-Ready Zone – Commercial  Appendix CG: Electric Vehicle Charging Infrastructure  Appendix CH: Electric-Ready Commercial Building Provisions 4  1 Tesla Road, Austin, TX 78725 P 650 681 5100 F 650 681 5101 July 8, 2024 Attention: Public Comments RE: Tesla Comments on City of Austin Residential and Commercial Electric Vehicle Readiness proposals of the 2024 International Energy Conversation Code (IECC) Dear Austin Energy Green Building Staff, Tesla1 appreciates the opportunity to comment on Austin Energy’s Residential and Commercial Electric Vehicle Readiness proposals of the 2024 International Energy Conversation Code (IECC). We applaud the City’s leadership in pushing forward the energy code in a timely manner. Although many cities and states have adopted energy codes, only a handful have been proactive in adopting, updating, and enforcing the most up-to-date codes. Energy codes ensure that a building's energy use is included as a fundamental part of the design and construction process of new buildings; making an early investment in building energy improvements will pay dividends to Austin residents for years into the future. We offer the following comments on the 2024 IECC Electric Vehicle Readiness proposals for both commercial and residential buildings. 1. We support the residential electric vehicle readiness proposal for one-and two- family dwellings, townhomes, and R-2 occupancies. The residential proposal derived from Appendix RE of the 2024 IECC Residential code requires that new one- and two-family dwellings and townhouses with designated parking provide one EV capable, EV ready, or EVSE space per dwelling unit. Multifamily buildings with four stories or less must provide an EV capable space, EV ready space, or EVSE space for 40 percent of dwelling units or automobile parking spaces, whichever is less. These requirements give building owners flexibility in establishing the level of EV readiness that will fit their current and future needs, while still providing the necessary minimum EV charging load that the distribution system needs to be sized for. Moreover, the language in Appendix RE was developed as a consensus proposal during the IECC code development process with input from a diverse group of stakeholders including representatives from the home builders, electrical manufacturers, EV charging providers, and utilities. It went through several rounds of public comment and editorial changes to ensure 1 Tesla’s mission is to accelerate the world’s transition to sustainable energy. To accomplish its mission, Tesla designs, develops, manufactures, and sells high-performance fully electric vehicles and energy generation and storage systems, installs, and maintains such systems, and sells solar electricity. Tesla also owns and operates an extensive EV charging network across the U.S. including stations in Austin. At Gigafactory Texas in Austin, TX, Tesla produces the Model Y crossover, and Cybertruck and manufactures Tesla’s new, advanced 4680 lithium-ion battery cell, cathode, and battery packs. Upon completion, Gigafactory Texas will invest over $10B in factory development and create at least 10,000 new jobs. 1 Tesla Road, Austin, TX 78725 P 650 681 5100 F 650 681 5101 clarity, consistency, enforceability, and technical soundness. Adopting Appendix RE outright would help staff streamline and quicken the public input process given that the language has already been thoroughly vetted. 2. We strongly recommend increasing EV-ready requirements and including EVSE- installed spaces for certain commercial occupancy types We are concerned that the omission of EV-ready and EVSE-installed spaces in Table CG101.2.1 from all commercial occupancy types expect Groups R-1 and R-2 will result in an under-investment in necessary charging infrastructure to support current and future EV drivers in Austin. The current proposal heavily stacks EV-capable requirements across nearly all commercial building types, which puts the burden on building owners, EV drivers, or tenants to have an outlet or EVSE wired and installed at their parking space. While an EV capable space requires panel capacity, a dedicated circuit and raceway, it does not include a way for someone to drive up to a parking spot and plug in and charge. In particular, this barrier presents a significant obstacle to installing EV infrastructure at multi-family dwellings, which have proven to be the most challenging sector to deploy EV infrastructure. Unlike residents of single-family homes, multi-family tenants are commonly renters without the authority to retrofit parking spaces to install charging equipment. When retrofitting to provide EV charging is possible, tenants and owners can face costs of 4-6 times higher than if done during new construction2. The ability to charge an EV overnight is additionally important for multifamily tenants who are rural, low-income, and in disadvantaged communities, who typically have longer commutes and drive older EVs with shorter ranges. Several cities and counties across the country have included ambitious EVSE-installed and EV- ready requirements for commercial building types, including Scottsdale, Tucson, Coral Gables, St. Petersburgh, St. Louis County, Charlotte, Columbus, Orlando, Chicago, Seattle, and many others. We recommend that Austin match or exceed the ambition of its peer cities and adopt EV-ready and EVSE-installed requirements for new commercial buildings. Tesla proposes revisions to Table CG101.2.1 in the Appendix 1. 3. We recommend including a Direct Current Fast Charging (DCFC) compliance pathway that provides new commercial buildings the option to meet compliance with charging that mirrors dwell times. Depending on the type of nonresidential building and the typical dwell time a vehicle is parked, a higher power level for charging beyond a standard Level 2 charger may be most beneficial. A DCFC compliance pathway would allow new non-residential buildings the option to meet EV- capable and EVSE compliance either through Level 2 or DCFC. For example, commercial buildings with short dwell times, such as grocery stores, would have the ability to use a DCFC compliance ratio of 5:1 EVSE installed if minimum requirements are met and at least one Level 2 EVSE is installed. A DCFC compliance option is important as it provides building owners with the incentive to go beyond minimum EVSE requirements and the optionality to install the level of EV charging, either Level 2 or DCFC, that best fits customer needs. This optionality also results 2 https://caletc.aodesignsolutions.com/assets/files/CALGreen-2019-Supplement-Cost-Analysis-Final-1.pdf  1 Tesla Road, Austin, TX 78725 P 650 681 5100 F 650 681 5101 in a more efficient use of state and private infrastructure investment given more optimal charging station usage. Tesla proposes recommended language in the attached Appendix 2. ***  Tesla appreciates the opportunity to provide feedback on 2024 IECC Electric Vehicle Readiness proposals for both commercial and residential buildings. We look forward to continued work with the City of Austin on its transportation electrification efforts. Thank you for the opportunity to submit these comments. .   Sincerely,     Tessa Sanchez Senior Policy Advisor Business Development and Public Policy   Tesla, Inc.      1 Tesla Road, Austin, TX 78725 P 650 681 5100 F 650 681 5101 APPENDIX 1 Language to be added is underlined. Language to be removed is struck. TABLE C405.14.1 REQUIRED EV POWER TRANSFER INFRASTRUCTURE Occupancy Group A Group B Group E Group F Group H Group I Group M Group R-1 Group R-2 Group R-3 and R-4 Group S exclusive of parking garages Group S-2 parking garages EVSE Spaces 5% 0% 5% 0% 5% 0% 2% 0% 1% 0% 5% 0% 5% 0% 10% 0% 10% 0% 0% 0% EV Ready Spaces 5% 0% 10% 0% 10% 0% 0% 0% 10% 0% 10% 0% 5% 5% 0% 0% EV Capable Spaces 10% 30% 30% 5% 0% 30% 30% 35% 35% 5% 0% 5% 0% 10% 0% 30%  1 Tesla Road, Austin, TX 78725 P 650 681 5100 F 650 681 5101 APPENDIX 2 Language to be added is underlined. Language to be removed is struck. CG101.2.1 Quantity. The number of required electric vehicle (EV) spaces, EV capable spaces and EV ready spaces shall be determined in accordance with this section and Table CG101.2.1 based on the total number of automobile parking spaces and shall be rounded up to the nearest whole number. For R-2 buildings, the Table CG101.2.1 requirements shall be based on the total number of dwelling units or the total number of automobile parking spaces, whichever is less. 1. Where more than one parking facility is provided on a building site, the number of required automobile parking spaces required to have EV power transfer infrastructure shall be calculated separately for each parking facility. 3. 2. Where one shared parking facility serves multiple building occupancies, the required number of spaces shall be determined proportionally based on the floor area of each building occupancy. Installed electric vehicle supply equipment installed spaces (EVSE spaces) that exceed the minimum requirements of this section may be used to meet the minimum requirements for EV ready spaces and EV capable spaces. Installed EV ready spaces that exceed the minimum requirements of this section may be used to meet the minimum requirements for EV capable spaces. 4. 5. Where the number of EV ready spaces allocated for R-2 occupancies is equal to the number of dwelling units or to the number of automobile parking spaces allocated to R-2 occupancies, whichever is less, requirements for EVSE spaces for R-2 occupancies shall not apply. 6. Requirements for a Group S-2 parking garage shall be determined by the occupancies served by that parking garage. Where new automobile spaces do not serve specific occupancies, the values for Group S-2 parking garage in Table CG101.2.1 shall be used. 7. Group S-2 parking garages with no less than 50% long term parking spaces shall provide no less than 10% EV capable spaces. Long term parking spaces are considered as parking spaces where users generally park for more than 8 hours at a time, including overnight, at places such as airports, transit hubs, etc. 8. The installation of Direct Current Fast Charging (DCFC) EVSE shall be permitted to reduce the minimum number of required EV capable or EV ready spaces without EVSE or EVCS with Level 2 EVSE by five and reduce proportionally the required electrical load capacity to the service panel or subpanel.  July 8, 2024 Austin Energy Green Building EV Ready Building Code Commercial IECC [2024] Comment Electrify America applauds the City of Austin for recognizing the need for EV-ready buildings and appreciates the opportunity to submit comments on the city’s proposed building codes. With respect to compliance with these EV-ready codes, Electrify America proposes that the city include a power-based threshold, known as a “power-allocation method,” for meeting these requirements that would serve as an alternative to the benchmark based on percentage of parking spaces in a new facility. Setting a power-based requirement allows a property owner to meet EV charging requirements using the type of charger that best complements the use-case of their parking spaces. And, by doing so, the property owner can provide a better charging service to the driver using their parking space. California adopted the power-allocation method for meeting EV-ready requirements in 2023 which went into effect in 2024.So this is not a novel idea. Not all EV chargers provide the same charging speeds, and not all parking spaces are used the same. So, EV charging minimums should be flexible to allow property owners to comply by installing chargers that best match the use case of their spaces. At parking facilities that host vehicles for long periods of time, like residences and workplaces, slower level 2 chargers requiring hours to provide a meaningful charge can be appropriate. In contrast, at parking facilities that service commercial properties, parking sessions are much shorter. So, level 2 chargers are less effective because they do not offer significant range during the session. In these cases, Direct Current Fast Chargers Electrify America, LLC / 1950 Opportunity Way, Reston, VA 20190 / www.electrifyamerica.com Page 1 Public  (DCFC) are a much more appropriate solution because they provide a meaningful amount of range in a short amount of time. Thresholds for compliance with EV charging minimums based on a percentage of spaces disincentivize the build-out of fast chargers where they would be most effective. The reason is that the threshold is typically detrimentally high to be met with DCFC. The thresholds in the proposed language greatly exceed the number of chargers per station that is typical or even possible for fast charging providers. Under the proposed language, a parking facility with as few as 100 spaces would require between 15 and 30 chargers to be in compliance. Larger facilities, with about 1000 spaces could require 150-300 chargers. Even on the lower end of this spectrum, in smaller commercial parking facilities, the required number of stations is extremely high for DCFC providers. For reference, the typical Electrify America station has between 4-6 chargers; though, stations of 8-12 chargers are becoming more common in larger lots. A station of 15 chargers, as could be required in a smaller 100-space lot under the proposed language, would be among the five largest stations in Electrify America’s network. And the lot would likely be too small to host such a large station. 250 fast chargers, even in larger lots, is all but impossible with current technological, infrastructure, and resources limitations. Meeting these EV charging requirements through a combination of DCFCs and level 2 chargers does not alleviate these challenges. The proposed threshold based on the number of spaces could require the installation of dozens, or even hundreds, of level 2 chargers in addition to the fast chargers included in the station. Because demand for fast chargers is highest in facilities where parking sessions are often brief, these level 2 chargers installed merely to meet the statute’s requirements are not likely to provide a Electrify America, LLC / 1950 Opportunity Way, Reston, VA 20190 / www.electrifyamerica.com Page 2 Public meaningful service and not likely to be economically viable. So, the disincentive created by a space-based threshold remains despite compliance being possible. As an alternative, Electrify America supports a requirement that sets a minimum power level, scaled to the size of the parking facility, to be provided by EV chargers. A power- allocation method for compliance would permit a property owner to install the type of charger that best complements their land use and to provide a charging service that meets the needs of the drivers using their parking facility. The state of California, in the 2023 update to its green building code, known as “Calgreen,” proposed and adopted a power-allocation threshold as an alternative and in addition to one based on the number of spaces. In the “Final Express Terms for Proposed Building Standards….” attached, the Buildings Standards Commission approved a framework that would require, for example, parking facilities of 100 spaces to provide, effectively, 165 kW of power and lots of 1000 spaces to provide 1300 kW of power.1 This framework right-sizes the EV charging minimums to reflect the large amount of power offered by DCFCs. Charging stations compliant with the National Electric Vehicle Infrastructure (NEVI) program’s standards must include four chargers each providing at least 150 kW charging speeds, though the DCFC industry is capable of reaching 350 kW. So, a power- 1 https://www.dgs.ca.gov/-/media/Divisions/BSC/03-Rulemaking/2022-Intervening-Cycle/ Commission-Meetings/2023-08-01/BSC-02-22-FSOR-Pt5.pdf Electrify America, LLC / 1950 Opportunity Way, Reston, VA 20190 / www.electrifyamerica.com Page 3 Public  based requirement also complements the nationwide effort to expand fast charging infrastructure by encouraging the proliferation of NEVI-compliant stations. Although this power-based threshold produces fewer chargers, DCFCs provide greater amounts of charge and range than their level 2 counterparts and service more vehicles during a given time. Utilization data from Electrify America’s public DCFCs and level 2 chargers show that fast chargers dispense nearly 10x the number of kilowatt hours and enable 10x the number of driving miles per year as level 2 chargers. Additionally, level 2 chargers typically experience a number of charging sessions in the hundreds, annually, whereas a DCFC station performs thousands of charging sessions per year. 2 DCFCs’ faster charging speeds provide more range in shorter period of time and result in more frequent turnovers from one session to the next. So, despite producing fewer chargers, the power-based threshold encourages the build-out of charging infrastructure that provides an equal, if not better, service to EV drivers. Power-based requirements provide property owners the flexibility to install the types of chargers, including DCFCs, that best meet the needs of their facility’s users. A power- allocation method of compliance, adopted in California, removes the disincentive to expanding fast charging infrastructure presented by the need for superfluous level 2 chargers simply to meet a minimum. And it does so while enhancing the charging services provided to the EV driver. As Austin considers ways to best support the proliferation of fast charging infrastructure, the city has a unique opportunity to be a leading voice on this matter and positively influence other states nation-wide as they consider doing the same. 2 https://media.electrifyamerica.com/en-us/releases/217 Electrify America, LLC / 1950 Opportunity Way, Reston, VA 20190 / www.electrifyamerica.com Page 4 Public Electrify America appreciates the opportunity to submit these comments and would be happy to discuss this matter further and answer any questions the Committee may have. Respectfully submitted, /s/ Anthony Willingham Anthony Willingham Government Affairs & Public Policy Lead—State Electrify America LLC 1950 Opportunity Way, Reston, VA 20190 anthony.willingham@electrifyamerica.com Electrify America, LLC / 1950 Opportunity Way, Reston, VA 20190 / www.electrifyamerica.com Page 5 Public STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION APPROVED BY THE CALIFORNIA BUILDING STANDARDS COMMISSION AUGUST 2, 2023 FINAL EXPRESS TERMS FOR PROPOSED BUILDING STANDARDS OF THE CALIFORNIA BUILDING STANDARDS COMMISSION REGARDING THE 2022 CALIFORNIA GREEN BUILDING STANDARDS CODE, CALIFORNIA CODE OF REGULATIONS, TITLE 24, PART 11 (BSC 04/22) The State agency shall draft the regulations in plain, straightforward language, avoiding technical terms as much as possible and using a coherent and easily readable style. The agency shall draft the regulation in plain English. A notation shall follow the express terms of each regulation listing the specific statutes authorizing the adoption and listing specific statutes being implemented, interpreted, or made specific (Government Code Section 11346.2(a)(1)). If using assistive technology, please adjust your settings to recognize underline, strikeout and ellipsis. LEGEND for EXPRESS TERMS (California only codes - Parts 1, 6, 8, 11, 12) • Existing California amendments appear upright • Amended or new California amendments appear underlined • Repealed California language appears upright and in strikeout • Ellipses ( ...) indicate existing text remains unchanged FINAL EXPRESS TERMS ITEM 1 Chapter 2 DEFINITIONS, Section 202 (Electric Vehicle Related Definitions) [Defined Electric Vehicle Terms published in 2022 CALGreen Code and effective January 1, 2023, are shown for context only.] AUTOMATIC LOAD MANAGEMENT SYSTEM (ALMS). [BSC-CG, DSA-SS and HCD] A system designed to manage load across one or more electric vehicle supply equipment (EVSE) to share electrical capacity and/or automatically manage power at each connection point. ELECTRIC VEHICLE (EV). [BSC-CG, HCD] An automotive-type vehicle for on-road use, such as passenger automobiles, buses, trucks, vans, neighborhood electric vehicles, electric motorcycles and the like, primarily powered by an electric motor that draws current from a rechargeable storage battery, fuel cell, photovoltaic array or other source of electric current. Plug-in hybrid electric vehicles (PHEV) are considered electric vehicles. For purposes of the California Electrical Code, off-road, self-propelled electric vehicles, such as industrial trucks, hoists, lifts, transports, golf carts, airline ground support equipment, tractors, boats and the like, are not included. ELECTRIC VEHICLE (EV) CAPABLE SPACE. [BSC-CG, DSA-SS and HCD] A vehicle space with electrical panel space and load capacity to support a branch circuit BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 1 of 60 Public August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION and necessary raceways, both underground and/or surface mounted, to support EV charging. ELECTRIC VEHICLE (EV) CHARGER. [HCD] Off-board charging equipment used to charge an electric vehicle. ELECTRIC VEHICLE CHARGING SPACE (EV SPACE). [HCD] A space intended for future installation of EV charging equipment and charging of electric vehicles. ELECTRIC VEHICLE CHARGING STATION (EVCS). [HCD] One or more electric vehicle charging spaces served by electric vehicle charger(s) or other charging equipment allowing charging of electric vehicles. Electric vehicle charging stations are not considered parking spaces. ELECTRIC VEHICLE (EV) READY SPACE. [HCD] A vehicle space which is provided with a branch circuit; any necessary raceways, both underground and/or surface mounted; to accommodate EV charging, terminating in a receptacle or a charger. ELECTRIC VEHICLE SUPPLY EQUIPMENT (EVSE). [BSC-CG, DSA-SS and HCD] The conductors, including the ungrounded, grounded and equipment grounding conductors and the electric vehicle connectors, attachment plugs, and all other fittings, devices, power outlets or apparatus installed specifically for the purpose of transferring energy between the premises wiring and the electric vehicle. LEVEL 2 ELECTRIC VEHICLE SUPPLY EQUIPMENT (EVSE). [HCD] The 208/240 Volt 40-ampere branch circuit, and the electric vehicle charging connectors, attachment plugs, and all other fittings, devices, power outlets, or apparatus installed specifically for the purpose of transferring energy between the premises wiring and the electric vehicle. LOW POWER LEVEL 2 ELECTRIC VEHICLE (EV) CHARGING RECEPTACLE. [HCD] A 208/240-volt 20-ampere minimum branch circuit and a receptacle for use by an EV driver to charge their electric vehicle or hybrid electric vehicle. [Propose to co-adopt and amend HCD’s existing EV definitions as shown in underlined below] ELECTRIC VEHICLE (EV) CHARGER. [BSC-CG] Off-board charging equipment used to charge an electric vehicle. ELECTRIC VEHICLE CHARGING STATION (EVCS). [BSC-CG] One or more electric vehicle charging spaces served by EVSE or receptacle(s). ELECTRIC VEHICLE SUPPLY EQUIPMENT (EVSE). [BSC-CG] The conductors, including the ungrounded, grounded and equipment grounding conductors and the electric vehicle connectors, attachment plugs, personnel protection system, and all other fittings, devices, power outlets or apparatus installed specifically for the purpose of transferring energy between the premises wiring and the electric vehicle. [Propose to co-adopt and amend HCD’s existing EV definitions shown in underlined below] LEVEL 2 ELECTRIC VEHICLE (EV) CHARGER. [BSC-CG] A 208/240-volt 30-ampere minimum electric vehicle charger connected to the premises electrical system capable of charging electric vehicles. BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 2 of 60 August 2, 2023 SOS Filing-FET Public STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION LEVEL 2 ELECTRIC VEHICLE SUPPLY EQUIPMENT. [BSC-CG] The 208/240 Volt 40-ampere branch circuit, and the electric vehicle charging connectors, attachment plugs, and all other fittings, devices, power outlets or apparatus installed specifically for the purpose of transferring energy between the premises wiring and the electric vehicle. LOW POWER LEVEL 2 ELECTRIC VEHICLE (EV) CHARGING RECEPTACLE. [BSC-CG] A 208/240 Volt 20-ampere minimum branch circuit and a receptacle. Notation: Authority: Health & Safety Code Sections 18930.5 and 18941.10. Reference(s): Health & Safety Code Sections 18930.5 and 18941.10. ITEM 2 Chapter 2 DEFINITIONS, Section 202 (Bird Friendly Related Definitions) [Propose to adopt new bird-friendly definitions as shown in underline below] 2 X 2 RULE. [BSC-CG] Visual markers are the most effective collision deterrents if spaced no more than 2 inches (5.1 cm) apart, a distance through which most birds cannot fly. ADHESIVE MARKER. [BSC-CG] An individual marker(s) applied to the first surface of glass (surface 1) in a pattern or as a custom decal. FILM. [BSC-CG] A material adhered to the first surface of glass (surface 1), perforated or printed with patterns as visual markers. GLASS, ACID ETCHED. [BSC-CG] Glass with hydrofluoric acid washed across the entire first surface (surface 1), which can result in a variety of patterns as visual markers. GLASS, FRITTED. [BSC-CG] Glass manufactured with ceramic-based paint applied in various patterns as visual markers. GLASS SURFACE. [BSC-CG] The exterior surface is the first surface (surface 1) where visual markers are usually applied, and subsequent interior surfaces are numbered in ascending order. MATURE TREE CANOPY. [BSC-CG] The top of the mature trees or vegetation typical of a region. ULTRAVIOLET (UV). [BSC-CG] Electromagnetic radiation on the first surface of glass (surface 1), with wavelengths between 300 and 400 nanometers (optimum at 370) visible to birds. VISUAL MARKER. [BSC-CG] Usually applied to the first surface of glass (surface 1), a pattern, solid shape, or treatment visible to birds. If markers are applied on an inside surface, surface 1 should have maximum 15% reflectivity. Notation: Authority: Health & Safety Code Section: 18930.5 Reference(s): Health & Safety Code Section 18930.5 Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 3 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION ITEM 3 Chapter 2 DEFINITIONS, Section 202 (CALGreen Carbon Reduction Related Definitions) BUY CLEAN CALIFORNIA ACT. [BSC-CG] The Buy Clean California Act (BCCA) (Public Contract Code Sections 3500-3505), targets carbon emissions associated with the production of structural steel (hot-rolled sections, hollow structural sections, and plate), concrete reinforcing steel, flat glass, and mineral wool board insulation. The maximum acceptable global warming potential (GWP) limit are established by the Department of General Services (DGS), in consultation with the California Air Resources Board (CARB). CRADLE-TO-GATE. [BSC-CG] Activities associated with a product or building’s life cycle from the extraction stage through production stage, and covering modules A1 through A3 in accordance with ISO Standards 14025 and 21930. CRADLE-TO-GRAVE. [BSC-CG] Activities associated with a product or building’s life cycle from the extraction stage through disposal stage, and covering modules A1 through C4 in accordance with ISO Standards 14025 and 21930. DECONSTRUCTION. [BSC-CG] BSC is withdrawing the definition. TYPE III ENVIRONMENTAL PRODUCT DECLARATION (EPD). [BSC-CG] A third- party verified report that summarizes how a product impacts the environment. Type III EPDs can be either product-specific, factory-specific, or industry-wide EPDs. See CRADLE-TO-GATE. PRODUCT-SPECIFIC EPD. [BSC-CG] A Type III EPD in which the environmental impacts can be attributed to a product design and manufacturer across multiple facilities. FACTORY-SPECIFIC EPD. [BSC-CG] A product-specific Type III EPD in which the environmental impacts can be attributed to a single manufacturer and manufacturing facility. INDUSTRY-WIDE EPD (IW-EPD). [BSC-CG] A Type III EPD in which the environmental impacts are an average of the typical manufacturing impacts for a range of products within the same product category for a group of manufacturers. REFERENCE STUDY PERIOD. [BSC-CG] The period of use for the building, in years, that will be assumed for life cycle assessment. Notation: Authority: Health and Safety Code Section 18928.1, 18930.5, Reference(s): Health and Safety Code Section 18928.1, 18930.5 ITEM 4 Chapter 5 NONRESIDENTIAL MANDATORY MEASURES, DIVISION 5.1- PLANNING AND DESIGN, SECTION 5.105 DECONSTRUCTION AND REUSE OF EXISTING STRUCTURES SECTION 5.105, DECONSTRUCTION AND REUSE OF EXISTING STRUCTURES Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 4 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION (Reserved) 5.105.1 Scope. [BSC-CG] Effective July 1, 2024, alteration(s) to existing building(s) where the combined altered floor area is 100,000 square feet or greater shall comply with either Section 5.105.2, 5.409.2, or 5.409.3. Addition(s) to existing building(s) where the total floor area combined with the existing building(s) is 100,000 square feet or greater shall comply with either Section 5.105.2, Section 5.409.2, or Section 5.409.3. Effective January 1, 2026, the combined floor area shall be 50,000 square feet or greater. Exception: Combined addition(s) to existing building(s) of two times the area or more of the existing building(s) is not eligible to meet compliance with Section 5.105.2. 5.105.2 Reuse of existing building. An alteration or addition to an existing building shall maintain at a minimum 45 percent combined of the existing building’s primary structural elements (foundations; columns, beams, walls, and floors; and lateral elements) and existing building enclosure (roof framing, wall framing and exterior finishes). Window assemblies, insulation, portions of buildings deemed structurally unsound or hazardous, and hazardous materials that are remediated as part of the project shall not be included in the calculation. 5.105.2.1 Verification of compliance. Documentation shall be provided in the construction documents to demonstrate compliance with Section 5.105.2. Note: Sample Worksheet WS-3 in Chapter 8 may be used to assist in documenting compliance with this section. 5.105.3 Deconstruction (reserved) Notation: Authority: Health and Safety Code Section 18930.5 Reference(s): Health and Safety Code Section 18930.5 ITEM 5 Section 5.106 SITE DEVELOPMENT, Section 5.106.5.3 5.106.5.3 Electric vehicle (EV) charging. [N] [BSC-CG] Construction to provide electric vehicle infrastructure and facilitate electric vehicle charging shall comply with Section 5.106.5.3.1 EV capable spaces, Section 5.106.5.3.2 Electric vehicle charging stations and associated Table 5.106.5.3.1, or Section 5.106.5.3.6 Electric vehicle charging stations (EVCS)-Power allocation method and associated Table 5.106.5.3.6 and shall be provided in accordance with regulations in the California Building Code and the California Electrical Code. Exceptions: 1. On a case-by-case basis where the local enforcing agency has determined compliance with this section is not feasible based upon one of the following conditions: a. Where there is no local utility power supply. Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 5 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION b. Where the local utility is unable to supply adequate power. c. Where there is evidence suitable to the local enforcement agency substantiating that additional local utility infrastructure design requirements, directly related to the implementation of Section 5.106.5.3, may adversely impact the construction cost of the project. 2. Parking spaces accessible only by automated mechanical car parking systems are not required to comply with this code section. 5.106.5.3.1 EV capable spaces. [N] EV capable spaces shall be provided in accordance with Table 5.106.5.3.1 and the following requirements: 1. Raceways complying with the California Electrical Code and no less than 1-inch (25 mm) diameter shall be provided and shall originate at a service panel or a subpanel(s) serving the area, and shall terminate in close proximity to the proposed location of the EV capable space and into a suitable listed cabinet, box, enclosure or equivalent. A common raceway may be used to serve multiple EV capable spaces. 2. A service panel or subpanel(s) shall be provided with panel space and electrical load capacity for a dedicated 208/240 volt, 40-ampere minimum branch circuit for each EV capable space, with delivery of 30-ampere minimum to an installed EVSE at each EVCS. 3. The electrical system and any on-site distribution transformers shall have sufficient capacity to supply full rated amperage at each EV capable space. 4. The service panel or subpanel circuit directory shall identify the reserved overcurrent protective device space(s) as “EV CAPABLE”. The raceway termination location shall be permanently and visibly marked as “EV CAPABLE.” Note: A parking space served by electric vehicle supply equipment or designed as a future EV charging space shall count as at least one standard automobile parking space only for the purpose of complying with any applicable minimum parking space requirements established by an enforcement agency. See Vehicle Code Section 22511.2 for further details. 5.106.5.3.2 Electric vehicle charging stations (EVCS). EV capable spaces shall be provided with electric vehicle supply equipment (EVSE) to create EVCS in the number indicated in Table 5.106.5.3.1. The EVCS required by Table 5.106.5.3.1 may shall be provided with Level 2 EVSE or DCFC as permitted in Section 5.106.5.3.2.1. in any combination of Level 2 and Direct Current Fast Charging (DCFC), except that at least one Level 2 EVSE shall be provided. At least one Level 2 EVSE shall be provided. One EV charger with multiple connectors capable of charging multiple EVs simultaneously shall be permitted if the electrical load capacity required by Section 5.106.5.3.1 for each EV capable space is accumulatively supplied to the EV charger. 5.106.5.3.2.1 The installation of each DCFC EVSE shall be permitted to reduce the minimum number of required EV capable spaces without EVSE or EVCS with Level 2 EVSE by five and reduce proportionally the required electrical load capacity to the BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 6 of 60 August 2, 2023 SOS Filing-FET Public STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION service panel or subpanel. 5.106.5.3.2.2 The installation of two Low Power Level 2 EV charging receptacles shall be permitted to reduce the minimum number of required EV capable spaces without EVSE in Table 5.106.5.3.1 by one. 5.106.5.3.3 Use of automatic load management systems (ALMS). ALMS shall be permitted…multiple EVs. [No change to text.] 5.106.5.3.4 Accessible electric vehicle charging station (EVCS). When EVSE is installed, accessible EVCS shall be provided in accordance with the California Building Code Chapter 11B Section 11B-228.3. Note: For EVCS signs, refer to Caltrans Traffic Operations Policy Directive 13-01 (Zero Emission Vehicle Signs and Pavement Markings) or its successor(s) 5.106.5.3.5 Electric vehicle charging station signage. Electric vehicle charging stations shall be identified by signage or pavement markings in compliance with Caltrans Traffic Operations Policy Directive 13-01 (Zero Emission Vehicle Signs and Pavement Markings) or its successor(s). TABLE 5.106.5.3.1 TOTAL NUMBER OF ACTUAL PARKING SPACES NUMBER OF REQUIRED EV CAPABLE SPACES NUMBER OF EVCS (EV CAPABLE SPACES PROVIDED WITH EVSE) 2 & 3 0 0-9 10-25 26-50 51-75 76-100 101-150 151-200 0 4 8 13 17 25 35 0 2 3 4 6 9 201 and over 20 percent of total actual parking spaces 1 25 percent of EV capable spaces 1 1. Calculation for spaces shall be rounded up to the nearest whole number. 2. The number of required EVCS (EV capable spaces provided with EVSE) in column 3 count toward the total number of required EV capable spaces shown in column 2. 3. At least one Level 2 EVSE shall be provided. 5.106.5.3.6 Electric vehicle charging stations (EVCS)-Power allocation method. The Power allocation method may be used as an alternative to the requirements in Section 5.106.5.3.1, Section 5.106.5.3.2 and associated Table 5.106.5.3.1. Use Table 5.106.5.3.6 to determine the total power in kVA required based on the total number of Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 7 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION actual parking spaces. Power allocation method shall include the following: 1. Use any kVA combination of EV capable spaces, Low Power Level 2, Level 2 or DCFC EVSEs. 2. At least one Level 2 EVSE shall be provided. TABLE 5.106.5.3.6 MINIMUM TOTAL kVA @ 6.6 kVA TOTAL kVA REQUIRED IN ANY COMBINATION OF EV CAPABLE3,4, LOW POWER LEVEL 2, LEVEL 2 1, 2, OR DCFC TOTAL NUMBER OF ACTUAL PARKING SPACES 0-9 10-25 26-50 51-75 76-100 101-150 151-200 0 26.4 52.8 85.8 112.2 165 231 0 26.4 52.8 85.8 112.2 165 231 201 and over 20 percent of actual parking spaces x 6.6 Total required kVA =P x .20 x 6.6 Where P=Parking spaces in facility 1. Level 2 EVSE @ 6.6 kVA minimum. 2. At least one Level 2 EVSE shall be provided. 3. Maximum allowed kVA to be utilized for EV capable spaces is 75 percent. 4. If EV capable spaces are utilized, they shall meet the requirements of Section 5.106.5.3.1 EV capable spaces. Notation: Authority: Health & Safety Code Sections 18930.5 and 18941.10. Reference(s): Health & Safety Code Sections 18930.5 and 18941.10. ITEM 6 Chapter 5 SITE DEVELOPMENT, Section 5.106.5.4 5.106.5.4 Additions or Alterations to existing buildings or parking facilities [A]. [BSC-CG] Existing buildings or parking facilities being modified by one of the following, shall comply with Section 5.106.5.4.1 or 5.106.5.4.2. When EVSE is installed, accessible EVCS shall be provided in accordance with the California Building Code, Chapter 11B, Section 11B-228.3. Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 8 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION 1. When the scope of construction work includes an increase in power supply to an electric service panel as part of a parking facility addition or alteration. 2. When a new photovoltaic system is installed covering existing parking spaces. 3. When additions or alterations to existing buildings are triggered pursuant to code Section 301.3 and the scope of work includes an increase in power supply to an electric service panel. Exceptions: 1. On a case-by-case basis where the local enforcing agency has determined compliance with this section is not feasible based upon one of the following conditions: a. Where there is no local utility power supply. b. Where the local utility is unable to supply adequate power. c. Where there is evidence suitable to the local enforcement agency substantiating that additional local utility infrastructure design requirements, directly related to the implementation of Section 5.106.5.3, may adversely impact the construction cost of the project. d. Where demonstrated as impracticable excluding local utility service or utility infrastructure issues. 2. Remote parking facilities that do not have access to the building service 3. Parking area lighting upgrades where no trenching is part of the scope of panel. work. 4. Emergency repairs including but not limited to, water line break in parking facilities, natural disaster repairs, etc. 5.106.5.4.1 Existing buildings or parking areas without previously installed EV capable infrastructure [A]. When EV capable infrastructure does not exist at an existing parking facility or building, and the parking facility or building undergoes an addition or alteration listed in Section 5.106.5.4, construction shall include electric vehicle charging in compliance with either Section 5.106.5.3 and associated Table 5.106.5.3.1, or Section 5.106.5.3.6 and associated Table 5.106.5.3.6 for the total number of actual parking spaces being added or altered. 5.106.5.4.2 Existing buildings or parking areas with previously installed EV capable infrastructure [A]. When EV capable infrastructure is available at an existing parking facility or building, and the parking facility or building is undergoing an addition or alteration listed in Section 5.106.5.4, construction shall include electric vehicle charging in compliance with either Section 5.106.5.3 and associated Table 5.106.5.3.1, or Section 5.106.5.3.6 and associated Table 5.106.5.3.6 utilizing the existing EV capable allocated power and infrastructure for the total number of actual parking spaces being added or altered. If the area being added or altered exceeds the existing EV capable capacity, allocated power and infrastructure, provide additional EV charging as needed to comply with this section. Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 9 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION Notation: Authority: Health & Safety Code Sections 18930.5 and 18941.10. Reference(s): Health & Safety Code Sections 18930.5 and 18941.10. ITEM 7 Chapter 5 SITE DEVELOPMENT, Section 5.106.5.5 5.106.5. 4 5 Electric vehicle (EV) charging: medium-duty and heavy-duty. [N] [BSC-CG] Construction shall comply with Section 5.106.5. 4 5.1 to facilitate future installation of electric vehicle supply equipment (EVSE). Construction for warehouses, grocery stores, retail stores, office buildings, and manufacturing facilities with planned off-street loading spaces shall also comply with Section 5.106.5. 4 5.1 for future installation of medium- and heavy-duty EVSE. Exceptions: 1. On a case-by-case basis where the local enforcing agency has determined compliance with this section is not feasible based upon one of the following conditions: a. Where there is no local utility power supply. b. Where the local utility is unable to supply adequate power. c. Where there is evidence suitable to the local enforcing agency substantiating that additional local utility infrastructure design requirements, directly related to the implementation of Section 5.106.5.3, may adversely impact the construction cost of the project. When EVSE(s) is/are installed, it shall be in accordance with the California Building Code, the California Electrical Code and as follows: 5.106.5. 4 5.1 Electric vehicle charging readiness requirements for warehouses, grocery stores and retail stores, office buildings, and manufacturing facilities with planned off-street loading spaces [N] In order to avoid future demolition when adding EV supply and distribution equipment, spare raceway(s) or busway(s) and adequate capacity for transformer(s), service panel(s) or subpanel(s) shall be installed at the time of construction in accordance with the California Electrical Code. Construction plans and specifications shall include, but are not limited to, the following: 1. The transformer, main service equipment and subpanels shall meet the minimum power requirement in Table 5.106.5. 4 5.1 to accommodate the dedicated branch circuits for the future installation of EVSE. 2. The construction documents shall indicate one or more location(s) convenient to the planned off-street loading space(s) reserved for medium- and heavy-duty ZEV charging cabinets and charging dispensers, and a pathway reserved for routing of conduit from the termination of the raceway(s) or busway(s) to the charging cabinet(s) and dispenser(s), as shown in Table 5.106.5. 4 5.1. 3. Raceway(s) or busway(s) originating at a main service panel or a subpanel(s) serving the area where potential future medium- and heavy-duty EVSE will be BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 10 of 60 August 2, 2023 SOS Filing-FET Public STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION located and shall terminate in close proximity to the potential future location of the charging equipment for medium- and heavy-duty vehicles. 4. The raceway(s) or busway(s) shall be of sufficient size to carry the minimum additional system load to the future location of the charging for medium- and heavy-duty ZEVs as shown in Table 5.106.5. 4 5.1. TABLE 5.106.5. 4 5.1, RACEWAY CONDUIT AND PANEL POWER REQUIREMENTS FOR MEDIUM-AND-HEAVY-DUTY EVSE [N] Additional capacity Required (kVa) for Raceway & Busway and Transformer & Panel … Building Type Building Size (sq. ft.) Number of Off- street loading spaces Grocery Retail Warehouse Manufacturing Facilities Manufacturing Facilities Manufacturing Facilities Office Buildings Office Buildings Office Buildings … … … … … … 10,000 to 50,000 1 or 2 10,000 to 50,000 3 or Greater Greater than 50,000 10,000 to 135,000 10,000 to 135,000 Greater than 135,000 1 or Greater 1 or 2 3 or Greater 1 or Greater … … 200 400 400 200 400 400 Notation: Authority: Health & Safety Code Sections 18930.5 and 18941.10. Reference(s): Health & Safety Code Sections 18930.5 and 18941.10. ITEM 8 Chapter 5-NONRESIDENTIAL MANDATORY MEASURES, DIVISION 5.4-MATERIAL CONSERVATION AND RESOURCE EFFICIENCY, SECTION 5.401 GENERAL SECTION 5.401, GENERAL 5.401.1 Scope. The provisions of this chapter shall outline means specify the requirements of achieving material conservation, and resource efficiency, and greenhouse gas (GHG) emission reduction through protection of buildings from exterior moisture, construction waste diversion, employment of techniques to reduce pollution through recycling of materials, the installation of products with lower GHG emissions and building commissioning or testing and adjusting. BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 11 of 60 August 2, 2023 SOS Filing-FET Public STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION Notation: Authority: Health and Safety Code Section 18930.5 Reference(s): Health and Safety Code Section 18930.5 ITEM 9 Section 5.402, DEFINITIONS 5.402 Definitions. The following terms are defined in Chapter 2. TYPE III ENVIRONMENTAL PRODUCT DECLARATION (EPD). ADJUST. BALANCE. BUILDING COMMISSIONING. BUY CLEAN CALIFORNIA ACT (BCCA). CRADLE-TO-GRAVE. PRODUCT-SPECIFIC EPD. FACTORY-SPECIFIC EPD. INDUSTRY-WIDE EPD (IW-EPD). ORGANIC WASTE. REFERENCE STUDY PERIOD. TEST. Notation: Authority: Health and Safety Code Section 18930.5 Reference(s): Health and Safety Code Section 18930.5 ITEM 10 Section 5.408, CONSTRUCTION WASTE REDUCTION, DISPOSAL AND RECYCLING 5.408.1 Construction waste management. [Proposed code changes withdrawn] Notation: Authority: Health and Safety Code Section 18930.5 Reference(s): Health and Safety Code Section 18930.5 ITEM 11 Section 5.409, LIFE CYCLE ASSESSMENT (Reserved) 5.409.1 Scope. [BSC-CG] Effective July 1, 2024, projects consisting of newly constructed building(s) with a combined floor area of 100,000 square feet or greater Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 12 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION shall comply with either Section 5.409.2, or Section 5.409.3. Alteration(s) to existing building(s) where the combined altered floor area is 100,000 square feet or greater shall comply with either 5.105.2, 5.409.2, or 5.409.3. Addition(s) to existing building(s) where the total floor area combined with the existing building(s) is 100,000 square feet or greater shall comply with either Section 5.105.2, Section 5.409.2, or Section 5.409.3. Effective January 1, 2026, the combined floor area 50,000 square feet or greater. 5.409.2 Whole building life cycle assessment. Projects shall conduct a cradle-to- grave whole building life cycle assessment performed in accordance with ISO 14040 and ISO 14044, excluding operating energy, and demonstrating a minimum 10 percent reduction in global warming potential (GWP) as compared to a reference baseline building of similar size, function, complexity, type of construction, material specification, and location that meets the requirements of the California Energy Code currently in effect. Software used to conduct the whole building life cycle assessment, including reference baseline building, shall have a data set compliant with ISO-14044, and ISO 21930 or EN 15804, and the software shall conform to ISO 21931 and/or EN 15978. The software tools and datasets shall be the same for evaluation of both the baseline building and the proposed building. Notes: 1. Software for calculating whole building life cycle assessment is available for free at Athena Sustainable Materials Institute (https://calculateca.com/software/impact-estimator/) and OneClick LCA - Planetary (www.oneclicklca.com/planetary). Paid versions include, but are not limited to, Sphera GaBi Solutions (gabi.sphera.com), SimaPro (simapro.com), OneClick LCA (www.oneclicklca.com) and Tally for Revit (apps.autodesk.com). 2. ASTM E2921-22 “Standard Practice for Minimum Criteria for Comparing Whole Building Life Cycle Assessments for Use with Building Codes, Standards, and Rating Systems” may be consulted for the assessment. 3. In addition to the required documentation specified in Section 5.409.2.3, Worksheet WS-9 may be required by the enforcing entity to demonstrate compliance with the requirements. 5.409.2.1 Building components. Building enclosure components included in the assessment shall be limited to glazing assemblies, insulation, and exterior finishes. Primary and secondary structural members included in the assessment shall be limited to footings and foundations, and structural columns, beams, walls, roofs, and floors. 5.409.2.2 Reference study period. The reference study period of the proposed building shall be equal to the reference baseline building and shall be 60 years. 5.409.2.3 Verification of compliance. A summary of the GWP analysis produced by the software and Worksheet WS-4 signed by the design professional of record shall be provided in the construction documents as documentation of compliance. A copy of the whole building life cycle assessment which includes the GWP analysis produced by the software, in addition to maintenance and training information, shall be included in the operation and maintenance manual and shall be provided to the owner at the close of Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 13 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION construction. The enforcing agency may require inspection and inspection reports in accordance with Sections 702.2 and 703.1 during and at completion of construction to demonstrate substantial conformance. Inspection shall be performed by the design professional of record or third party acceptable to the enforcing agency. Notation: Authority: Health and Safety Code Section 18928.1, 18930.5 Reference(s): Health and Safety Code Section 18928.1, 18930.5 ITEM 12 Chapter 5 NONRESIDENTIAL MANDATORY MEASURES, DIVISION 5.4- MATERIAL CONSERVATION AND RESOURCE EFFICIENCY, SECTION 5.409 LIFE CYCLE ASSESSMENT 5.409.3 Product GWP compliance – prescriptive path. [BSC-CG] Each product that is permanently installed and listed in Table 5.409.3 shall have a Type III environmental product declaration (EPD), either product-specific or factory-specific. 5.409.3.1 Products shall not exceed the maximum GWP value specified in Table 5.409.3. Exception: Concrete may be considered one product category to meet compliance with this section. A weighted average of the maximum GWP for all concrete mixes installed in the project shall be less than the weighted average maximum GWP allowed per Table 5.409.3 using Exception Equation 5.409.3.1. Calculations shall be performed with consistent units of measurement for the material quantity and the GWP value. For the purposes of this exception, industry wide EPD’s are acceptable. Exception EQUATION 5.409.3.1 GWPn < GWPallowed where and GWPn = Σ (GWPn)(vn) and GWPallowed = Σ (GWPallowed)(vn) n = each concrete mix installed in the project GWPn = the GWP for concrete mix n per concrete mix EPD, in kg CO2e /m3 GWPallowed = the GWP potential allowed for concrete mix n per Table 5.409.3 vn = the volume of concrete mix n installed in the project, in m3 5.409.3.2. Verification of compliance. Calculations to demonstrate compliance, Type III EPDs for products required to comply if included in the project, and Worksheet WS-5 signed by the design professional of record shall be provided on the construction documents. Updated EPDs for products used in construction shall be provided to the owner at the close of construction and to the Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 14 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION enforcement entity upon request. The enforcing agency may require inspection and inspection reports in accordance with Sections 702.2 and 703.1 during and at completion of construction to demonstrate substantial conformance. Inspection shall be performed by the design professional of record or third party acceptable to the enforcing agency. Note: [Withdrawn] TABLE 5.409.3 PRODUCT GWP LIMITS Maximum acceptable GWP value (unfabricated) (GWP allowed) 1.77 Unit of Measurement Buy Clean California Materials Product Category 1 Hot-rolled structural steel sections Hollow structural sections Steel plate Concrete reinforcing steel Flat glass Light-density mineral wool board insulation Heavy-density mineral wool board insulation Concrete, Ready-Mixed 2, 3 Concrete Product Category up to 2499 psi 2500-3499 psi 3500-4499 psi 4500-5499 psi 5500-6499 psi 6500 psi and greater 3.00 2.61 1.56 2.50 5.83 489 566 661 701 799 MT CO2e/MT MT CO2e/MT MT CO2e/MT MT CO2e/MT kg CO2e/MT kg CO2e/1 m2 kg CO2e/m3 kg CO2e/m3 kg CO2e/m3 kg CO2e/m3 kg CO2e/m3 kg CO2e/m3 14.28 kg CO2e/1 m2 Maximum GWP allowed value (GWP allowed) 450 Unit of Measurement Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 15 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION Concrete, Lightweight Ready-Mixed 2 Concrete Product Category up to 2499 psi 2500-3499 psi 3500-4499 psi Footnotes: Maximum GWP allowed value (GWP allowed) 875 956 1,039 Unit of Measurement kg CO2e/m3 kg CO2e/m3 kg CO2e/m3 1. The GWP values of the products listed in Table 5.409.3 are based on 175 percent of Buy Clean California Act (BCCA) GWP values, except for concrete products which are not included in BCCA. 2. For concrete, 175 percent of the National Ready Mix Concrete Association (NRMCA) 2022 version 3 Pacific Southwest regional benchmark values are used for the GWP allowed, except for High Early strength. 3. Concrete High Early Strength ready-mixed shall be calculated at 130 percent of the Ready mixed concrete GWP allowed values for each product category. Notation: Authority: Health and Safety Code Section 18930.5 Reference(s): Health and Safety Code Section 18930.5 ITEM 13 Chapter 5, DIVISION 5.4-MATERIAL CONSERVATION AND RESOURCE EFFICIENCY, Section 5.410 BUILDING MAINTANANCE AND OPERATION 5.410.1 Recycling by occupants. Provide readily accessible…restrictive. … 5.410.2 Commissioning. [N] New buildings 10,000 square feet and over. For new buildings … Sections 5.410.2 through 5.410.2.6 shall apply. Note: For energy-related systems … Commissioning requirements shall include: 1. Owner’s or owner … 2. Basis of design. 3. Commissioning … 4. Commissioning … 5. Functional … 6. Documentation … 7. Commissioning … Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 16 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION Exceptions: 1. Unconditioned … 2. Areas less than 10,000 … 3. Tenant improvements … 4. Open parking garages… Note: For the purposes of this section, unconditioned shall mean a building, area or room which does not provide heating and/or air conditioning. Informational Notes: 1. IAS AC 476 is an accreditation criteria for organizations providing training and/or certification of commissioning personnel. AC 476 is available to the Authority Having Jurisdiction as a reference for qualifications of commissioning personnel. AC 476 does not certify individuals to conduct functional performance tests or to adjust and balance systems. 2. 1 Functional performance testing for heating, ventilation, air conditioning systems and lighting controls must be performed in compliance with the California Energy Code. Notation: Authority: Health & Safety Code Section: 18930.5 Reference(s): Health & Safety Code Section 18930.5 ITEM 14 Chapter 6 REFERENCED ORGANIZATIONS AND STANDARDS SECTION 601 GENERAL 601.1 This chapter lists the organizations and standards that are referenced in various sections of this document. The standards are listed herein by according to the promulgating agency of the standard. [Entire table not shown, just new reference standards] ORGANIZATION STANDARD REFERENCED SECTION ACI American Concrete Institute American Concrete Institute ACI CT-21 A5.405.5.2.1.1 ASTM ASTM International ASTM C31/C31M-19 A5.405.5.3.4 ASTM C1798/C1798M-19 A5.405.5.3.5 … … BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 17 of 60 Public August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION ORGANIZATION STANDARD REFERENCED SECTION ASTM C1866/C1866M-20 A5.405.5.2 ASTM D7612-2021 A5.405.2.1 ASTM E2921-2022 5.409.2, A5.409.2 EN European Standards European and International standards online store - European Standards (en-standard.eu) ISO International Organization for Standardization ISO Central Secretariat Chemin de Blandonnet 8 CP 401 - 1214 Vernier, Geneva, Switzerland https://www.iso.org … … … Notation: EN 15804-2012 + A2:2019 5.409.2, A5.409.2.1, EN 15978:2011 A5.409.2.2 5.409.2, A5.409.2.1, A5.409.2.2 ISO 14040-2006+A1:2020 5.409.2, A5.409.2.1, ISO 14044:2006+A1:2020 ISO 21930-2017 ISO 21931-2017 A5.409.2.2 5.409.2, A5.409.2.1, A5.409.2.2 5.409.2, A5.409.2.1, A5.409.2.2 5.409.2, A5.409.2.1, A5.409.2.2 Authority: Health and Safety Code Section 18928.1, 18930.5 Reference(s): Health and Safety Code Section 18928.1, 18930.5 Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 18 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION ITEM 15 Chapter 8 COMPLIANCE FORMS, WORKSHEETS AND REFERENCE MATERIAL WORKSHEET (WS-3) Section 5.105.2 BUILDING REUSE DOCUMENTATION OF COMPLIANCE OF EXISTING BUILDING REUSE Area of Existing Building(s) _____ SF Area of Aggregate Addition(s) (if applicable) _____ SF Existing Total Area (A) Retained Total Area (B) % of Retained Structure (B)/(A) _____ SF _____ SF _____ % Primary Structural Elements of Existing Building(s) (foundations; columns, beams, walls, and floors; and lateral elements) Building Enclosure of Existing Building(s) (roof framing, wall framing and exterior finishes only) _____ SF _____ SF _____ % Total % Reuse of Required Elements = ≥45% _____ % Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 19 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION WORKSHEET (WS-4) Section 5.409.2 WHOLE BUILDING LIFE CYCLE ASSESSMENT Responsible Designer’s Declaration Statement: I attest that the Whole Building Life Cycle Analysis has been performed according to the requirements of Section 5.409.2 and has met the minimum 10 percent reduction in global warming potential as compared to a reference baseline building of similar size, function, complexity, type of construction, material specification, and location that meets the requirements of the California Energy Code currently in effect. Furthermore, I will ensure during construction that the material specifications will be reviewed for substantial conformance with the life cycle assessment indicated on the approved plans so at the close of construction the minimum 10 percent reduction in global warming potential is thereby secured. WORKSHEET (WS-5) Section 5.409.3 PRODUCT GWP COMPLIANCE - PRESCRIPTIVE PATH Responsible Designer’s Declaration Statement: I attest that prescriptive compliance has been performed according to the requirements of Section 5.409.3 and products have met the minimum 10 percent reduction in global warming potential as specified in Table 5.409.3. Furthermore, I will ensure during construction that the material specifications will be reviewed for substantial conformance with the global warming potential limits indicated on the approved plans so at the close of construction the minimum 10 percent reduction in global warming potential is thereby secured. Date: License: Phone: Date: License: Phone: Signature: Company: Address: City/State/Zip: Signature: Company: Address: City/State/Zip: BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 20 of 60 Public August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION WORKSHEET (WS-6) Section A5.105.2 BUILDING REUSE TIER 1 AND TIER 2 DOCUMENTATION OF COMPLIANCE OF EXISTING BUILDING REUSE Area of Existing Building _____ SF Existing Total Area (A) Retained Total Area (B) % of Retained Structure (B)/(A) _____ SF _____ SF _____ % _____ SF _____ SF _____ % _____ SF _____ SF _____ % Primary Structural Elements of Existing Building (foundations; columns, beams, walls, and floors; and lateral elements) Building Enclosure of Existing Building (roof framing, wall framing and exterior finishes only) Interior Nonstructural Elements (interior walls, doors, floor coverings, ceiling systems applicable for voluntary Tier 2 compliance) Total % Reuse of Required Elements _____ % BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 21 of 60 Public August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION WORKSHEET (WS-7) Section A5.409.2 WHOLE BUILDING LIFE CYCLE ASSESSMENT Responsible Designer’s Declaration Statement: I attest that the Whole Building Life Cycle Analysis has been performed according to the requirements of Section A5.409.2 and has met the minimum 15 percent (Tier 1) or 20 percent (Tier 2) reduction in global warming potential as compared to a reference baseline building of similar size, function, complexity, type of construction, material specification, and location that meets the requirements of the California Energy Code currently in effect. Furthermore, I will ensure during construction that the material specifications will be reviewed for substantial conformance with the life cycle assessment indicated on the approved plans so at the close of construction the minimum reduction in global warming potential is thereby secured. WORKSHEET (WS-8) Section A5.409.3 PRODUCT GWP COMPLIANCE-PRESCRIPTIVE PATH Designer’s Declaration Statement: I attest that prescriptive compliance has been performed according to the requirements of Section A5.409.3 and products have met the maximum acceptable GWP value for the products listed in Table A5.409.3 for either Tier 1 or Tier 2. Furthermore, I will ensure during construction that any material specification substitution will be reviewed for substantial conformance with the requirements of Section A5.409.3 so at the close of construction the minimum 15 percent reduction in global warming potential is thereby secured. Date: License: Phone: Date: License: Phone: Signature: Company: Address: City/State/Zip: Signature: Company: Address: City/State/Zip: BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 22 of 60 Public August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION WORKSHEET (WS-9) Section 5.409.2 and Section A5.409.2 WHOLE BUILDING LIFE CYCLE ASSESSMENT Notation: Authority: Health and Safety Code Section 18930.5 Reference(s): Health and Safety Code Section 18930.5 ITEM 16 Appendix A5 - NONRESIDENTIAL VOLUNTARY MEASURES, DIVISION A5.1 – PLANNING AND DESIGN SECTION A5.105, DECONSTRUCTION AND REUSE OF EXISTING STRUCTURES A5.105.1 If feasible, disassemble existing buildings instead of demolishing to allow reuse or recycling of building materials. A5.105.1.1 Existing building structure. Maintain at least 75 percent of existing building structure (including structural floor and roof decking) and envelope (exterior skin and framing) based on surface area. BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 23 of 60 August 2, 2023 SOS Filing-FET Public STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION Exceptions: 1. Window assemblies and nonstructural roofing material. 2. Hazardous materials that are remediated as a part of the project. 3. A project with an addition of more than two times the square footage of the existing building. A5.105.1.2 Existing nonstructural elements. Reuse existing interior nonstructural elements (interior walls, doors, floor coverings and ceiling systems) in at least 50 percent of the area of the completed building (including additions). Exception: A project with an addition of more than two times the square footage of the existing building. A5.105.1.3 Salvage. Salvage additional items in good condition such as light fixtures, plumbing fixtures and doors as follows. Document the weight or number of the items salvaged. 1. Salvage for reuse on the project items that conform to other provisions of Title 24 in an on-site storage area. 2. Nonconforming items may be salvaged in dedicated collection bins for exempt projects or other uses. A5.105.1 Scope. Projects with the area limits specified shall comply with Section A5.105.2 to achieve Tier 1 or Tier 2 compliance. 1. Alteration(s) to existing building(s) where the combined altered floor area is 50,000 square feet or greater shall comply with either Section A5.105.2, Section A5.409.2, or Section A5.409.3. 2. Addition(s) to existing building(s) where the total floor area combined with the existing building(s) is 50,000 square feet or greater shall comply with either Section A5.105.2, Section A5.409.2, or Section A5.409.3 Exception: Combined addition(s) to existing building(s) of two times the area or more of the existing building(s) is not eligible to meet compliance with Section A5.105.2. 3. Alteration(s) to existing building(s) where the aggregate floor area is less than 50,000 square feet shall comply with either Section 5.105.2, Section 5.409.2 or Section 5.409.3 for Tier 1 compliance, and either Section A5.105.2.1, Section A5.409.2.1, or A5.409.3 Tier 1 requirements for Tier 2 compliance. 4. Addition(s) to an existing building where the total floor area combined with the existing building(s) is less than 50,000 square feet shall comply with either Section 5.105.2, Section 5.409.2 or Section 5.409.3 for Tier 1 compliance, and either Section A5.105.2.1, Section A5.409.2.1, or A5.409.3 Tier 1 requirements for Tier 2 compliance. Exception: Combined addition(s) to existing building(s) of two times the area or more of the existing building(s) is not eligible to meet compliance with Section 5.105.2 or Section A5.105.2. A5.105.2 Reuse of existing building. Projects that include the reuse of an existing Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 24 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION building shall meet the minimum requirements of Section A5.105.2. A5.105.2.1 Tier 1: An alteration or addition to an existing building shall maintain at least 75 percent combined of the existing building’s primary structural elements (foundations; columns, beams, walls, and floors; and lateral elements) and existing building enclosure (roof framing, wall framing and exterior finishes). Window assemblies, insulation, portions of buildings deemed structurally unsound or hazardous, and hazardous materials that are remediated as part of the project shall not be included in the calculation. A5.105.2.2 Tier 2: An alteration or addition to an existing building shall maintain at least 75 percent combined of the existing building’s primary structural elements (foundations; columns, beams, walls, and floors; and lateral elements) and existing building enclosure (roof framing, wall framing and exterior finishes). In addition, an alteration to an existing building shall maintain 30% of existing interior nonstructural elements (interior walls, doors, floor coverings, ceiling systems). Window assemblies, insulation, portions of buildings deemed structurally unsound or hazardous, and hazardous materials that are remediated as part of the project shall not be included in the calculation. A5.105.2.3 Verification of compliance. Documentation shall be provided in the construction documents to demonstrate compliance with Section A5.105.2. Note: Sample Worksheet WS-6 in Chapter 8 may be used to assist in documenting compliance with this section. A5.105.3 Deconstruction (reserved) Notation: Authority: Health and Safety Code Section 18930.5 Reference(s): Health and Safety Code Section 18930.5, 18941.5 ITEM 17 Chapter A5, DIVISION A5.106 PLANNING AND DESIGN, Section A5.106 SITE DEVELOPMENT A5.106.5.1 Designated parking for clean air vehicles. In new projects or additions or alterations that add 10 or more vehicular parking spaces, provide designated parking for any combination of zero-emitting, fuel-efficient high efficient and carpool/vanpool vehicles as listed in code Sections A5.106.5.1.1 or A5.106.5.1.2. A5.106.5.1.1 Tier 1. Provide 35 percent designated parking spaces of the total number of parking spaces, for any combination of zero-emitting, fuel-efficient high efficient and carpool/vanpool vehicles. Calculation for spaces shall be rounded up to the nearest whole number. Note: Designated parking for clean air vehicles shall count toward the total parking spaces required by the local enforcing agencies. A5.106.5.1.2 Tier 2. Provide 50 percent designated parking spaces of the total number of parking spaces, for any combination of zero-emitting, fuel-efficient high efficient and Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 25 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION carpool/van pool vehicles. Calculation for spaces shall be rounded up to the nearest whole number. Note: Designated parking for clean air vehicles shall count toward the total parking spaces required by the local enforcing agencies. A5.106.5.1.3 Future charging spaces. Future EV charging spaces qualify as designated parking as described in Section A5.106.5.1 Designated parking for clean air vehicles. Note: Future EV charging spaces shall count toward the total parking spaces required by the local enforcing agencies. A5.106.5.1.3 4 parking stall markings. Paint, in the paint used for stall stripping…parked vehicle. CLEAN AIR/ VANPOOL/EV Note: Vehicles bearing …designated parking spaces. A5.106.5.1.4 5 Vehicle designations. Building managers may … parking stickers. Notes: 1. Information on … following sources: a. California Drive Clean. b. California Air Resources Board. c. US EPA … standards. d. DMV Registration Operations. 2. Purchasing policy … General Services … Notation: Authority: Health & Safety Code Sections 18930.5 and 18941.10. Reference(s): Health & Safety Code Sections 18930.5 and 18941.10. ITEM 18 Chapter A5, DIVISION A5.106 PLANNING AND DESIGN, Section A5.106 SITE DEVELOPMENT A5.106.5.3 Electric vehicle (EV) charging. [N] Construction shall comply with Section A5.106.5.3.1 Tier 1 or A5.106.5.3.2 3 Tier 2, and in accordance with regulations in the California Building Code and the California Electrical Code. A5.106.5.3.1 Tier 1. Comply with Section 5.106.5.3.1 EV capable spaces, Section 5.106.5.3.2 Electric vehicle charging stations and associated Table A5.106.5.3.1 Tier 1, or comply with Section A5.106.5.3.2 Electric vehicle charging stations (EVCS)-Power allocation method and associated Table A5.106.5.3.2 Tier 1. Table A5.106.5.3.1 shall be used to determine the number of Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 26 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION EV capable spaces required. Refer to Section 5.106.5.3 for design space requirements. When EV capable spaces are provided with EVSE to create EVCS per Table A5.106.5.3.1, r Refer to Section 5.106.5.3.2 for the allowed permitted use of Level 2 or Direct Current Fast Charger (DCFC) to create EVCS. Refer to Section 5.106.3.2.1 for the allowed use of DCFC to comply with both EV capable spaces and Level 2 EVSE. and Refer to Section 5.106.5.3.3 for the allowed use of Automatic Load Management System (ALMS). TABLE A5.106.5.3.1 Tier 1 TOTAL NUMBER OF ACTUAL PARKING SPACES TIER 1 NUMBER OF REQUIRED EV CAPABLE SPACES TIER 1 NUMBER OF EVCS (EV CAPABLE SPACES PROVIDED WITH EVSE) 2, 3 0 0-9 10-25 26-50 51-75 76-100 101-150 151-200 2 5 11 19 26 38 53 2 4 6 9 13 18 201 and over 30 percent of actual total parking spaces1 33 percent of EV capable spaces 1 1. Calculation for spaces shall be rounded up to the nearest whole number. 2. The number of required EVCS (EV capable spaces provided with EVSE) in column 3 count toward the total number of required EV capable spaces shown in column 2. 3. At least one Level 2 EVSE shall be provided. A5.106.5.3.2 Electric vehicle charging stations (EVCS)-Power allocation method. The Power allocation method may be used as an alternative to the requirements in Section 5.106.5.3.1, Section 5.106.5.3.2, and associated Table A5.106.5.3.1 Tier 1. Use Table A5.106.5.3.2 Tier 1 to determine the total power in kVA required based on the total number of actual parking spaces. Power allocation method shall include the following: 1. Use any kVA combination of EV capable spaces, Low Power Level 2, Level 2 or DCFC EVSEs. 2. At least one Level 2 EVSE shall be provided. Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 27 of 60 August 2, 2023 SOS Filing-FET TABLE A5.106.5.3.2 Tier 1 MINIMUM TOTAL kVA @ 6.6 kVA TOTAL kVA REQUIRED IN ANY COMBINATION OF EV CAPABLE 3,4, LOW POWER LEVEL 2 LEVEL 2 1, 2, OR DCFC STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION TOTAL NUMBER OF ACTUAL PARKING SPACES 0-9 10-25 26-50 51-75 76-100 101-150 151-200 13.2 33 72.6 125.4 171.6 250.8 349.8 13.2 33 72.6 125.4 171.6 250.8 349.8 201 and over 30 percent of actual parking spaces x 6.6 Total required kVA =P x .30 x 6.6 Where P=Parking spaces in facility 1. Level 2 EVSE @ 6.6 kVA minimum. 2. At least one Level 2 EVSE shall be provided. 3. Maximum allowed kVA to be utilized for EV capable spaces is 67 percent. 4. If EV capable spaces are utilized, they shall meet the requirements of Section 5.106.5.3.1 EV capable spaces. A5.106.5.3.2 3Tier 2. Comply with Section 5.106.5.3.1 EV capable spaces, Section 5.106.5.3.2 Electric vehicle charging stations and associated Table A5.106.5.3.3 Tier 2, or Section A5.106.5.3.4 Electric vehicle charging stations (EVCS)-Power allocation method and associated Table A5.106.5.3.4 Tier 2. Table A5.106.5.3.2 shall be used to deteremine the number of EV capable spaces required. Refer to Section 5.106.5.3for design requirements. When EV capable spaces are provided with EVSE to create EVCS per Table A5.106.5.3.2, r Refer to Section 5.106.5.3.2 for the allowed permitted use of Level 2 or Direct Current Fast Charger (DCFC) to create EVCS. Refer to Section 5.106.3.2.1 for the allowed use of DCFC to comply with both EV capable spaces and Level 2 EVSE. and Refer to Section 5.106.5.3.3 for the allowed use of Automatic Load Management System (ALMS). Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 28 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION TABLE A5.106.5.3.2 3 Tier 2 TOTAL NUMBER OF ACTUAL PARKING SPACES TIER 2 NUMBER OF REQUIRED EV CAPABLE SPACES TIER 2 NUMBER OF EVCS (EV CAPABLE SPACES PROVIDED WITH EVSE) 2, 3 0 0-9 10-25 26-50 51-75 76-100 101-150 151-200 3 8 17 28 40 57 79 3 6 9 13 19 26 201 and over 45 percent of total actual parking spaces1 33 percent of EV capable spaces 1 1. Calculation for spaces shall be rounded up to the nearest whole number. 2. The number of required EVCS (EV capable spaces provided with EVSE) in column 3 count toward the total number of required EV capable spaces shown in column 2. 3. At least one Level 2 EVSE shall be provided. A5.106.5.3.4 Electric vehicle charging stations (EVCS)-Power allocation method. The Power allocation method may be used as an alternative to the requirements in Section 5.106.5.3.1, Section 5.106.5.3.2 and associated Table A5.106.5.3.3 Tier 2. Use Table A5.106.5.3.4 Tier 2 to determine the total power in kVA required based on the total number of actual parking spaces. Power allocation method shall include the following: 1. Use any kVA combination of EV capable spaces, Low Power Level 2, Level 2 or DCFC EVSEs. 2. At least one Level 2 EVSE shall be provided. Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 29 of 60 August 2, 2023 SOS Filing-FET TABLE A5.106.5.3.4 Tier 2 MINIMUM TOTAL kVA @ 6.6 kVA TOTAL kVA REQUIRED IN ANY COMBINATION OF EV CAPABLE3,4, LOW POWER LEVEL 2, LEVEL 2 1,2, OR DCFC STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION TOTAL NUMBER OF ACTUAL PARKING SPACES 0-9 10-25 26-50 51-75 76-100 101-150 151-200 28.8 76.8 163.2 268.8 384 547.2 758.4 28.8 76.8 163.2 268.8 384 547.2 758.4 201 and over 45 percent of actual parking spaces x 6.6 Total required kVA =P x .45 x P x 6.6 Where P=Parking spaces in facility 1. Level 2 EVSE @ 6.6 kVA minimum. 2. At least one Level 2 EVSE shall be provided. 3. Maximum allowed kVA to be utilized for EV capable spaces is 75 percent. 4. If EV capable spaces are utilized, they shall meet the requirements of Section 5.106.5.3.1 EV capable spaces. Notation: Authority: Health & Safety Code Sections 18930.5 and 18941.10. Reference(s): Health & Safety Code Sections 18930.5 and 18941.10. ITEM 19 Chapter A5, DIVISION A5.106 PLANNING AND DESIGN, Section A5.106 SITE DEVELOPMENT Section A5.106.11 Reduction of Hheat island effect. Reduce nonroof heat island by requiring Section A5.106.11.1 Hardscape alternatives, and roof heat islands by Section A5.106.11.2 Cool roofs, or Section A5.106.11.3 Shade trees. A5.106.11.1 Hardscape alternatives. Use one or a combination of strategies 1 and 2 for 50 percent of site hardscape or put 50 percent of parking underground. 1. Use light colored materials with an initial solar reflectance value of at least 30 as determined in accordance with American Society for Testing and Materials (ASTM) Standards E1918 or C1549. 2. Use open-grid pavement system or pervious or permeable pavement system. Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 30 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION A5.106.11.2 Cool roof for reduction of heat island effect. Use roofing materials having a minimum aged solar reflectance and thermal emittance complying with Sections A5.106.11.2.1 and A5.106.11.2.2 or a minimum aged Solar Reflectance Index (SRI) complying with Section A5.106.11.2.3 and as shown in Table A5.106.11.2.2 for Tier 1 or Table A5.106.11.2.3 for Tier 2. Exceptions: [No changes to exceptions or note] … A5.106.11.3 2.4 Verification of compliance. If no documentation is available, an inspection shall be conducted to ensure roofing materials meet cool roof aged solar reflectance and thermal emittance or SRI values. A5.106.11.3 Shade trees. [BSC-CG] In the absence of a local shade tree ordinance, comply with mandatory Section 5.106.12 Shade trees. Notation: Authority: Health and Safety Code Section 18930.5 Reference(s): Health and Safety Code Section 18930.5, 18941.5 ITEM 20 Chapter A5, DIVISION A5.106 PLANNING AND DESIGN, Sections A5.102 DEFINITIONS and A5.107 BIRD-FRIENDLY BUILDING DESIGN A5.102.1 Definitions. The following terms are defined in Chapter 2. SECTION A5.102 DEFINITIONS 2 X 2 RULE ADHESIVE MARKER FILM GLASS, ACID ETCHED GLASS, FRITTED GLASS SURFACE MATURE TREE CANOPY ULTRAVIOLET (UV) VISUAL MARKER SECTION A5.107 BIRD-FRIENDLY BUILDING DESIGN A5.107 Bird-friendly building design. A newly constructed building, or an alteration of an existing building that includes the addition or replacement of 50 percent or more of the exterior glazing shall comply with the bird-friendly building design elements and features in Sections A5.107.1 through A5.107.3 the California Energy Code, and the fire Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 31 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION hazard severity zone regulations in Chapter 7A of the California Building Code. Exception: Alteration to the glazing in historical buildings per the California Historical Building Code. A5.107.1 Required elevation treatment. Building elevation treatment shall incorporate bird-friendly mitigation strategies. No less than 90 percent of a building elevation, measured from grade to a height of 40 feet (12 m) above grade, or from grade to the height of an adjacent mature tree canopy (whichever is greater), shall incorporate bird-friendly mitigation strategies. No less than 60 percent of building elevation, 40 feet (12 m) above grade to the top of the building elevation, shall incorporate bird-friendly mitigation strategies. Strategies to minimize the risk of birds colliding with buildings: 1. Glazing Glazing with visual markers shall include, but is not limited to, the following: a. Etched or fritted glass with patterns of elements on the exterior having minimum dimensions of 1/4” (.64 cm) diameter for dots or 1/8” (.32 cm) width for stripes in a density of 2 inches (5.1 cm) maximum horizontally and vertically (the “2 X 2 Rule”). Note: If the visual markers are on glass surface 2, they can be effective if visible behind an exterior surface with reflectivity of 15% or less. b. Interior or exterior glazing film with 2 X 2 visual markers. c. Laminated glass with 2 X 2 visual markers, patterned Ultraviolet (UV) coating or use of contrasting patterned UV-absorbing and UV- reflecting films. Note: Low-e coatings shall be behind the visual markers d. Glass block or channel glass. e. Developed glazing technologies, documented to reduce bird strikes, as tested by an independent third party and approved by the authority having jurisdiction; or 2. Slats, Screens, Netting, Louvers Glazing protected by exterior features that create a visible barrier in front of the glazing, may include, but not be limited to: a. Horizontal or vertical slats of 1/8” (.32 cm) minimum face width with minimum 2” (5.1 cm) spacing that obscure 85% or more of glass when viewed from all feasible angles. b. Grilles, screens or 1/8” (.32 cm) dia. welded wire mesh with openings no more than 2” (5.1 cm) maximum horizontally and vertically installed parallel to and no more than 3 ¼ ft. (1 m) from the first surface of glass (glass surface 1). c. Netting with 1” (2.5 cm) maximum openings, installed taut at least 6” (15 cm) away from the first surface of glass; or Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 32 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION d. Sunshades or louvers 9” (22.5 cm) deep vertically spaced a maximum 9” (22.5 cm) or 6” (15 cm) deep horizontally at maximum 6” (15 cm) spacing and parallel or angled to the glass surfaces. A5.107.2 Special conditions. The following special conditions shall comply with the provisions in Section A5.107.1 (as appropriate) 1. Glass facades adjacent to vegetated roof. 2. Glass railings and guardrails. 3. Transparent corners that extend 5.5 feet (1.68 m) on either side of a building. 4. Glass passageways less than 5.5 feet (1.68 m) wide. 5. Auxiliary glass building such as a glass pavilion or atria exposed to the sky. 6. Auxiliary glass building such as a glass pavilion or atria exposed to a courtyard with a water feature or plants. 7. Stained glass windows insulated on the exterior with clear glazing. A5.107.3 Nighttime conditions. Nighttime lighting at the top of the building, and in the interiors of all areas visible through exterior glazing, including lobby and atria, shall be controlled with time-switch control devices or occupancy sensors complying with the current California Energy Code. The control device shall be programmed so the lights are extinguished from 2 am to dawn. Exception: Emergency lighting, lighting required for nighttime security and aeronautical beacon lighting required by the Federal Aviation Administration. A5.107.3.1 Systems or operation and maintenance manual. Include written recommendations that lighting is extinguished pursuant to Section A5.107.3 and janitorial services to the building are scheduled between sunrise and sunset. Notation: Authority: Health & Safety Code Section: 18930.5 Reference(s): Health & Safety Code Section 18930.5 ITEM 21 Appendix A5 - NONRESIDENTIAL VOLUNTARY MEASURES, DIVISION A5.4 – MATERIAL CONSERVATION AND RESOURCE EFFICIENCY, SECTIONS A5.401 GENERAL, A5.402 DEFINITIONS, A5.405 MATERIAL SOURCES and A5.406 LIFE CYCLE ASSESSMENT SECTION A5.401, GENERAL A5.401.1 Scope. The provisions of this chapter specify the requirements shall outline means of achieving enhanced compliance with material conservation, and resource efficiency, and greenhouse gas (GHG) emissions reduction through reuse of existing building stock and materials; use of recycled, regional, rapidly renewable, and certified wood materials; and employment of techniques to reduce pollution through recycling of materials. Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 33 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION Notation: Authority: Health and Safety Code Section 18928.1, 18930.5 Reference(s): Health and Safety Code Section 18928.1, 18930.5, 18941.5 ITEM 22 Section A5.402, DEFINITIONS A5.402.1 Definitions. The following terms are defined in Chapter 2. BUILDING COMMISSIONING BUY CLEAN CALIFORNIA ACT (BCCA). CRADLE-TO-GRAVE. EMBODIED ENERGY TYPE III ENVIRONMENTAL PRODUCT DECLARATION (EPD). PRODUCT-SPECIFIC EPD. FACTORY-SPECIFIC EPD. INDUSTRY-WIDE EPD (IW-EPD). EUTROPHICATION LIFE CYCLE ASSESSMENT (LCA) LIFE CYCLE INVENTORY (LCI) OVE. POST CONSUMER CONTENT PRECONSUMER (or POSTINDUSTRIAL) CONTENT. RECYCLED CONTENT. RECYCLED CONTENT VALUE (RCV). REFERENCE STUDY PERIOD. [No change to Sections A5.403 and A5.404] Notation: Authority: Health and Safety Code Section 18930.5 Reference(s): Health and Safety Code Section 18930.5, 18941.5 ITEM 23 Section A5.405, MATERIAL SOURCES [No change to Sections A5.405.1 through A5.405.2] A5.405.2.1 Reserved. Certified Wood Components - Sustainability Standards. Provide wood products, for at least 50 percent of the project permanently installed products, that have been certified by independent third parties and labeled as Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 34 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION having been produced in compliance with the accepted principles of sustainable forest management. The use of recycled and/or recovered wood products do not need to be certified. Comply with one or more of the following certifications of wood sustainability: 1. Sustainable Forestry Initiative (SFI). 2. Forest Stewardship Council (FSC) 3. Program for the Endorsement of Forest Certification (PEFC). 4. American Forest Foundation’s American Tree Farm System® (ATFS). 5. Canadian Standards Association’s Sustainable Forest Management System Standards (CSA Z809). 6. Manufacturer’s fiber procurement system that has been audited by an approved agency as compliant with the provisions of ASTM D7612 as a responsible or certified source. Notation: Authority: Health & Safety Code Section: 18930.5 Reference(s): Health & Safety Code Section 18930.5 ITEM 24 Section A5.405, MATERIAL SOURCES [No change to Sections A5.405.1 through A5.405.4] A5.405.5 Cement and concrete. Use Cement and concrete made with recycled products and complying with the following sections shall comply with A5.405. A5.405.5.1 Cement. Cement shall comply with one of the following standards: 1. Portland cement shall meet ASTM C150, Standard Specification for Portland Cement. 2. Blended cement shall meet ASTM C595, Standard Specification for Blended Hydraulic Cement or ASTM C1157, Standard Performance Specification for Hydraulic Cement. 3. Other Hydraulic Cements shall meet ASTM C1157, Standard Performance Specification for Hydraulic Cement. A5.405.5.2 Concrete. Unless otherwise directed by the Engineer of Record, use concrete manufactured with cementitious materials in accordance with Sections A5.405.5.2.1 and A5.405.5.2.1.1, as approved by the enforcing agency. Use concrete manufactured with cementitious materials in accordance with Section A5.405.2, as approved by the Engineer of Record. A5.405.5.2.1 Supplementary cementitious materials (SCM). Use concrete made with one or more supplementary cementitious materials (SCM) conforming to the following standards: Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 35 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION 1. Fly ash conforming to ASTM C618, Specification for Coal Fly Ash and Raw or Calcined Natural Pozzolan for Use in Concrete. 2. Slag cement (GGBFS) conforming to ASTM C989, Specification for Use in Concrete and Mortars. 3. Silica fume conforming to ASTM C1240, Specification for Silica Fume Used in Cementitious Mixtures. 4. Natural pozzolan conforming to ASTM C618, Specification for Coal Fly Ash and Raw or Calcined Natural Pozzolan for Use in Concrete. 5. Blended supplementary cementitious materials conforming to ASTM C1697, Standard Specification for Blended Supplementary Cementitious Materials. The amount of each SCM in the blend will be used separately in calculating Equation A5.4-1. If Class C fly ash, is if used in the blend, it will be considered to be “SL” SL for the purposes of satisfying the equation. 6. Ultra-fine fly ash (UFFA) conforming to ASTM C618, Specification for Coal Fly Ash and Raw or Calcined Natural Pozzolan for Use in Concrete and the following chemical and physical requirements: 7. Metakaolin conforming to ASTM C618, Specification for Coal Fly Ash and Raw or Calcined Natural Pozzolan for Use in Concrete, the following chemical and physical requirements: Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 36 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION 8. Ground-Glass Pozzolan per ASTM C1866/C1866M. 9.8. Other materials with comparable or superior environmental benefits, as approved by the Engineer of Record and enforcing authority. A5.405.5.2.1.1 Mix design equation. Use any combination of one or more SCM, satisfying Equation A5.4-14. When ASTM C595 or ASTM C1157 cement is used, the amount of SCM in these cements shall be used in calculating Equation A5.4-14. Exception: Minimums in mix designs approved by the Engineer of Record may be lower where high early strength is needed for concrete products or to meet an accelerated project schedule. High early strength shall be defined as outlined in ACI CT. F/25 + SL/50 + UF/12 ≥1 (Equation A5.4-14) where: F = Fly ash, natural pozzolan or other approved SCM, or blended SCM, as a percent of total cementitious material for concrete on the project. SL = GGBFS, as a percent of total cementitious material for concrete on the project. UF= Silica fume, metakaolin or UFFA, as a percent of total cementitious material for concrete on the project. A5.405.5.3 Additional means of compliance. Any of the following measures shall be permitted to be employed for the production of cement or concrete, depending on their availability and suitability, in conjunction with Section A5.405.5.2. A5.405.5.3.1 Cement. The following measures shall be permitted to be used in the manufacture of cement. A5.405.5.3.1.1 Alternative fuels. The use of alternative fuels where permitted by state or local air quality standards. A5.405.5.3.1.2 Alternative power. Alternate electric power generated at the cement plant and/or green power purchased from the utility meeting the requirements of Section A5.211. A5.405.5.3.2 Concrete manufacture. The following measures shall be permitted to be used in the manufacture of concrete, as approved by the Engineer of Record. A5.405.5.3.2.1 Alternative energy. Renewable or alternative energy meeting the requirements of Section A5.211. A5.405.5.3.2.2 .1 Recycled aggregates. Concrete made with one or more of the following materials: 1. Blast furnace slag as a lightweight aggregate in unreinforced concrete. Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 37 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION 2. Recycled concrete aggregate (RCA) or crushed concrete aggregate (CCA) that meets grading requirements of ASTM C33, Standard Specification for Concrete Aggregates. a. Recycled concrete aggregate (RCA) – created from existing concrete structures, including building foundations, parking areas, and sidewalks. It has been processed to create a recycled concrete aggregate, usable in many applications. b. Crushed concrete aggregate (CCA) – created by taking concrete that was batched but not used in initial construction and is returned in the mixer truck to the concrete batch plant. As a recent mix and unplaced it is a clean product with known properties. 3. Other materials with comparable or superior environmental benefits, as approved by the engineer and enforcing authority. A5.405.5.3.2.3 Mixing water. Water recycled by the local water purveyor or water reclaimed from manufacturing processes and conforming to ASTM C1602, Standard Specification for Mixing Water Used in the Production of Hydraulic Cement Concrete. A5.405.5.3.2.4 .3 High strength concrete. Concrete elements designed to reduce their total size compared to standard 3,000 psi concrete, thereby reducing the total volume of cement, aggregate and water used on the project, as approved by the Engineer of Record. A5.405.5.3.4 Later Ages of Maturity – An increase in the age of maturity of testing for determining compressive strength for acceptance of concrete from the current 28 days to 42 or 56 days, in compliance with ASTM C31/C31M. A5.405.5.3.5 Returned Fresh Concrete – The use of returned fresh concrete in compliance with ASTM C1798/C1798M or Caltrans Section 90-9. [No change to Sections A5.406 and A5.408] Notation: Authority: Health and Safety Code Section 18928.1, 18930.5, Reference(s): Health and Safety Code Section 18928.1, 18930.5, 18941.5 Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 38 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION ITEM 25 Appendix A5 NONRESIDENTIAL VOLUNTARY MEASURES, DIVISION A5.4- MATERIAL CONSERVATION AND RESOURCE EFFICIENCY, SECTION A5.409, LIFE CYCLE ASSESSMENT A5.409.1 General. Life cycle assessment shall be ISO 14044 compliant. The service life of the building and materials assemblies shall not be less than 60 years unless designated in the construction documents as having a shorter service life as approved by the enforcing agency. [New Life Cycle Assessment voluntary measures] A5.409.1 Scope. Projects with the area limits specified shall comply with Section A5.409.1 to achieve Tier 1 or Tier 2 compliance. Projects of any size shall comply with A5.409.5 to achieve Tier 2 compliance. 1. Projects consisting of newly constructed building(s) with a combined floor area of 50,000 square feet or greater shall comply with either Section A5.409.2 or Section A5.409.3. 2. Alteration(s) to existing building(s) where the combined altered floor area is 50,000 square feet or greater shall comply with either Section A5.105.2, Section A5.409.2 or Section A5.409.3. 3. Addition(s) to existing building(s) where the total floor area combined with the existing building(s) is 50,000 square feet or greater shall comply with either Section A5.105.2, Section A5.409.2 or Section A5.409.3. Exception: Combined addition(s) to existing building(s) of two times the area or more of the existing building(s) is not eligible to meet compliance with Section A5.105.2. 4. Projects consisting of newly constructed building(s) with a combined floor area of less than 50,000 square feet shall comply with either Section 5.409.2 or Section 5.409.3 for Tier 1 compliance, and either Section A5.409.2.1 or A5.409.3 Tier 1 requirements for Tier 2 compliance. 5. Alteration(s) to existing building(s) where the aggregate floor area is less than 50,000 square feet shall comply with either Section 5.105.2, Section 5.409.2, or Section 5.409.3 for Tier 1 compliance, and either Section A5.105.2.1, Section A5.409.2.1, or Section A5.409.3 Tier 1 requirements for Tier 2 compliance. 6. Addition(s) to an existing building where the total floor area combined with the existing building(s) is less than 50,000 square feet shall comply with either Section 5.105.2, Section 5.409.2, or Section 5.409.3 for Tier 1 compliance, and either Section A5.105.2.1, Section A5.409.2.1, or Section A5.409.3 Tier 1 requirements for Tier 2 compliance. Exception: Combined addition(s) to existing building(s) of two times the area or more of the existing building(s) is not eligible to meet compliance with Section 5.105.2 or Section A5.105.2. A5.409.2 Whole building life cycle assessment. Projects shall meet the minimum requirements of Section A5.409.2 for Tier 1 or Tier 2 compliance. A5.409.2.1 Tier 1. Projects shall conduct a cradle-to-grave whole building life BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 39 of 60 August 2, 2023 SOS Filing-FET Public STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION cycle assessment meeting the requirements of Section 5.409.2 and performed in accordance with ISO14040 and 14044, excluding operating energy, demonstrating a minimum 15 percent reduction in global warming potential (GWP) as compared to a reference baseline building of similar size, function, complexity, type of construction, material specification, and location that meets the requirements of all parts of the California Building Standards Code currently in effect. Software used to conduct the whole building life cycle assessment, including reference baseline building, shall have a data set compliant with ISO- 14044, and ISO 21930-2017 or EN 15804, and the software shall conform to ISO 21931 and/or EN 15978. The software tools and datasets shall be the same for evaluation of both the baseline building and the proposed building. Exception: For projects that include building reuse, the reference baseline building shall exclude the reused elements. The percent reduction in GWP shall be achieved through the design and construction of new project elements. A5.409.2.2 Tier 2. Projects shall conduct a cradle-to-grave whole building life cycle assessment meeting the requirements of Section 5.409.2 and performed in accordance with ISO14040 and ISO 14044, excluding operating energy, demonstrating a minimum 20 percent reduction in GWP as compared to a reference baseline building of similar size, function, complexity, type of construction, material specification, and location that meets the requirements of all parts of the California Building Standards Code currently in effect. Software used to conduct the whole building life cycle assessment, including reference baseline building, shall have a data set compliant with ISO-14044, and ISO 21930 or EN 15804, and the software shall conform to ISO 21931 and/or EN 15978. The software tools and datasets shall be the same for evaluation of both the baseline building and the proposed building. Exception: For projects that include building reuse, the reference baseline building shall not be of new construction and shall retain existing materials. The percent reduction in GWP shall be achieved through the design and construction of new project elements. A5.409.2.3 Verification of compliance. A summary of the GWP analysis produced by the software and Worksheet WS-7 signed by the design professional of record shall be provided in the construction documents as documentation of compliance. A copy of the whole building life cycle assessment which includes the GWP analysis produced by the software, in addition to maintenance and training information, shall be included in the operation and maintenance manual and shall be provided to the owner at the close of construction. The enforcing agency may require inspection and inspection reports in accordance with Sections 702.2 and 703.1 during and at completion of construction to demonstrate substantial conformance. Inspection shall be performed by the design professional of record or third party acceptable to the enforcing agency. A5.409.3 Product GWP compliance – prescriptive path. Each product that is permanently installed and listed in Table A5.409.3, shall have a Type III environmental product declaration (EPD), either product-specific or factory-specific. Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 40 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION A5.409.3.1. Products shall comply with the requirements for product GWP performance in accordance with Section A5.409.3 using for the maximum acceptable GWP value for the product category listed in Table A5.409.3 for Tier 1 or Tier 2 compliance for the verified reduction calculation resulting in a minimum 15 percent reduction in total GWP. Exception: Concrete may be considered one product category to meet compliance with this section. A weighted average of the maximum GWP for all concrete mixes installed in the project shall be less than the weighted average maximum GWP allowed per Table A5.409.3 using Exception Equation A5.409.3.1. Calculations shall be performed with consistent units of measurement for the material quantity and the GWP value. For the purposes of this exception, industry wide EPD’s are acceptable. Exception EQUATION A5.409.3.1 GWPn < GWP allowed where and GWPn = Σ (GWPn)(vn) and GWP allowed = Σ (GWP allowed)(vn) n = each concrete mix installed in the project GWPn = the GWP for concrete mix n per concrete mix EPD, in kg CO2e /m3 GWP allowed = the GWP potential allowed for concrete mix n per Table 5.409.3 vn = the volume of concrete mix n installed in the project, in m3 A5.409.3.2. Verification of compliance. Calculations to demonstrate compliance, Type III EPDs for products required to comply if included in the project, and Worksheet WS-8 signed by the design professional of record shall be provided on the construction documents. Updated EPDs for products used in construction shall be provided to the owner at the close of construction and to the enforcement entity upon request. The enforcing agency may require inspection and inspection reports in accordance with Sections 702.2 and 703.1 during and at completion of construction to demonstrate substantial conformance. Inspection shall be performed by the design professional of record or third party acceptable to the enforcing agency. Note: [Withdrawn] Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 41 of 60 August 2, 2023 SOS Filing-FET TABLE A5.409.3 PRODUCT GWP LIMITS TIER 1 AND TIER 2 Tier 1 Maximum acceptable GWP value (unfabricated) (GWP allowed) 1.52 Tier 2 Maximum acceptable GWP value (unfabricated) (GWP allowed) 1.01 Unit of Measurement MT CO2e/MT STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION Buy Clean California Product Category 1 Hot-rolled structural steel sections Hollow structural sections Steel plate Concrete reinforcing steel Flat glass Light-density mineral wool board insulation Heavy-density mineral wool board insulation Concrete Product Category up to 2499 psi 2500-3499 psi 3500-4499 psi 4500-5499 psi 5500-6499 psi 6500 psi and greater 2.57 2.24 1.34 2.15 5.00 419 485 567 601 685 12.24 8.16 kg CO2e/1 m2 Concrete, Ready-Mixed 2, 3 Tier 1 Maximum acceptable GWP value (unfabricated) (GWP allowed) 386 Tier 2 Maximum acceptable GWP value (unfabricated) (GWP allowed) 257 1.71 1.49 0.89 1.43 3.33 279 323 378 401 456 MT CO2e/MT MT CO2e/MT MT CO2e/MT kg CO2e/MT kg CO2e/1 m2 Unit of Measurement kg CO2e/m3 kg CO2e/m3 kg CO2e/m3 kg CO2e/m3 kg CO2e/m3 kg CO2e/m3 BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 42 of 60 Public August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION Concrete, Lightweight Ready-Mixed 2 Tier 1 Maximum acceptable GWP value (unfabricated) (GWP allowed) 750 Tier 2 Maximum acceptable GWP value (unfabricated) (GWP allowed) 500 819 891 546 594 Unit of Measurement kg CO2e/m3 kg CO2e/m3 kg CO2e/m3 Concrete Product Category up to 2499 psi 2500-3499 psi 3500-4499 psi Footnotes: 1. The GWP values of the products listed in Table A5.409.3 are based on 150% of Buy Clean California Act (BCCA) GWP values, except for concrete products which are not included in BCCA. 2. For concrete, Tier 1 is 150%, Tier 2 is 100% of the National Ready Mixed Concrete Association (NRMCA) 2022 version 3 Pacific Southwest regional benchmark values are used for the GWP allowed, except for High Early strength. 3. Concrete High Early Strength ready-mixed shall be calculated at 130% of the Ready mixed concrete GWP allowed values for each product category. [Renumbered and moved lower in this section] A5.409.24 Whole building life cycle assessment of additional impacts. Maintaining compliance with the requirements of Section 5.409.2, Cconduct a cradle-to-grave whole building life assessment performed in accordance with ISO 14044, including operating energy, showing that the building project achieves at least a and demonstrating a minimum 10 percent improvement for at least three of the a minimum of two additional impacts listed in Section A5.409.2.24.1, one of which shall be climate change,as compared to a reference baseline building of similar size, function, complexity, type of construction, material specification, location and operating energy performance, and meeting that meets the 2016 requirements of the California Energy Code at a minimum currently in effect. A5.409.2.1 Building components. The building envelope, structural elements, including footings and foundations, interior ceilings, walls and floors; and exterior finishes shall be considered in the assessment. 1. Plumbing, mechanical and electrical systems and controls; fire and smoke detection and alarm systems and controls; and conveying systems. 2. Interior finishes are not required to be included. Exceptions: Notes: 1. Software for calculating whole building life cycle assessments includes those found at the Athena Institute website (Impact Estimator software), Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 43 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION the PE International website (GaBi software), and the PRe Consultants website (SimaPro software). 2. Interior finishes, if included, may be assessed using the NIST BEES tool. A5.409.2.24.1 Impacts to be considered. Select from the following impacts in the assessment: 1. Climate change (greenhouse gases). 21. Fossil fuel depletion. 32. Stratospheric ozone depletion. 43. Acidification of land and water sources. 54. Eutrophication. 65. Photochemical oxidants (smog). A5.409.3 Materials and system assemblies. If whole building analysis of the project is not elected, select a minimum of 50 percent of materials or assemblies based on life cycle assessment of at least three of the impacts listed in Section A5.409.2.2, one of which shall be climate change. Note: Software for calculating life cycle assessments for assemblies and materials may be found at the Athena Institute web site and the NIST BEES web site. A5.409.4 Substitution for prescriptive standards. Performance of a life cycle assessment completed in accordance with Section A5.409.2 may be substituted for other prescriptive Material Conservation and Resource Efficiency provisions of Division A5.4, including those made mandatory through local adoption of Tier 1 or Tier 2 in Division A5.6. A5.409.5 Verification of compliance. Documentation of compliance shall be provided as follows: 1. The assessment is performed in accordance with ISO 14044. 2. The project meets the requirements of other parts of Title 24. 3. A copy of the analysis shall be made available to the enforcement authority. 4. A copy of the analysis and any maintenance or training recommendations shall be included in the operation and maintenance manual. Notation: Authority: Health and Safety Code Section 18928.1, 18930.5 Reference(s): Health and Safety Code Section 18928.1, 18930.5, 18941.5 BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 44 of 60 Public August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION ITEM 26 Chapter A5, DIVISION A5.601 CALGreen Tier 1 and Tier 2, Section A5.601 SITE DEVELOPMENT Division A5.6 - VOLUNTARY TIERS A5.601.1 Scope. The measures contained in this appendix are not mandatory unless adopted by local government as specified in Section 101.7. The provisions of this section outline means of achieving enhanced construction or reach levels by incorporating additional green building measures for newly constructed nonresidential buildings as well as additions and alterations. In order to meet one of the tier levels designers, builders or property owners are required to incorporate additional green building measures necessary to meet the threshold of each level. Refer to the provisions in Section 301.3 for nonresidential additions and alterations scope and application. A5.601.2 CALGreen Tier 1 A5.601.2.1 Prerequisites. To achieve CALGreen tier status, a project must meet all of the mandatory measures in Chapter 5 and, in addition, meet the provisions of this section. A5.601.2.2 Energy performance. For the purposes of mandatory energy efficiency standards in this code, the California Energy Commission will continue to adopt mandatory standards. A5.601.2.3 Tier 1. Comply with the energy efficiency requirements in Section A5.203.1.1 and Section A5.203.1.2.1. A5.601.2.4 Voluntary measures for Tier 1. In addition to the provisions of Sections A5.601.2.1 and A5.601.2.3 above, compliance with the following voluntary measures from Appendix A5 is required for Tier 1: 1. From Division A5.1, a. Comply with the designated parking requirements for fuel high efficient vehicles for a minimum of 35 percent of parking capacity per Section A5.106.5.1 b. Electric vehicle (EV) charging [N] and Table A5.106.5.3.1 w/ footnotes. c. Comply with thermal emittance, solar reflectance or SRI values for cool roofs in Section A5.106.11.2 and Table A5.106.11.2.1 2. 1 d. Comply with one elective measure selected from this division. 2. From Division A5.2 comply with ONE of the following: 1. Outdoor lighting as described in A5.203.1.1.1. 2. Service water heating in restaurants as described in A5.203.1.1.2. 3. Warehouse Dock Seal Doors A5.203.1.1.3. 4. Daylight Design Power Adjustments 5.203.1.1.4. 5. Exhaust Air Heat Recovery A5.203.1.1.5. … Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 45 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION A5.601.3 CALGreen Tier 2. A5.601.3.1 Prerequisites. To achieve CALGreen tier status, a project must meet all of the mandatory measures in Chapter 5 and, in addition, meet the provisions of this section. A5.601.3.2 Energy performance. For the purposes of mandatory energy efficiency standards in this code, the California Energy Commission will continue to adopt mandatory standards. A5.601.3.3 Tier 2. Comply with the energy efficiency requirements in Section A5.203.1.1 and Section A5.203.1.2.2. A5.601.3.4 Voluntary measures for Tier 2. In addition to the provisions of Sections A5.601.3.1 and A5.601.3.3 above, compliance with the following voluntary measures from Appendix A5 and additional elective measures shown in Table A5.601.3.4 is required for Tier 2: 1. From Division A5.1, a. Comply with the designated parking requirements for fuel efficient vehicles for a minimum of 50 percent of parking capacity per Section A5.106.5.1. b. Electric vehicle (EV) charging [N] and Table A5.106.5.3.2 w/ footnotes. c. Comply with thermal emittance, solar reflectance or SRI values for cool 1 roofs in Section A5.106.11.2 and Table A5.106.11.2.2.1 3 d. Comply with three elective measures selected from this division. 2. From Division A5.2 comply with TWO of the following: 1. Outdoor lighting as described in A5.203.1.1.1. 2. Service water heating in restaurants as described in A5.203.1.1.2. 3. Warehouse Dock Seal Doors A5.203.1.1.3. 4. Daylight Design Power Adjustments 5.203.1.1.4. 5. Exhaust Air Heat Recovery A5.203.1.1.5. … Notation: Authority: Health & Safety Code Section: 18930.5 Reference(s): Health & Safety Code Section 18930.5 ITEM 27 Chapter A5, DIVISION A5.602, VERIFICATION GUIDELINES MANDATORY MEASURES CHECKLIST, TIER 1 CHECKLIST AND TIER 2 CHECKLIST [Note: These checklists tables will be updated based on the final proposed code updates for both the mandatory and voluntary code sections] Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 46 of 60 August 2, 2023 SOS Filing-FET Plan Sheet, Spec, or Attach Reference STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION … Chapter 5 Divisions DIVISION 5.1 Planning and Design A5.602, CALGreen VERIFICATION GUIDELINES MANDATORY MEASURES CHECKLIST Requirement Section Title Code Section Y N/A O Mandatory Mandatory … Mandatory Mandatory Mandatory Mandatory Deconstruction and reuse of existing structures, Scope with Exception Reuse of existing building & Verification of compliance with note 5.105.1 5.105.2 and 5.105.2.1 Electric vehicle (EV) charging. [N] w/exceptions 5.106.5.3 EV capable spaces [N] 5.106.5.3.1 Electric vehicle charging stations (EVCS) Use of automatic load management systems (ALMS) 5.106.5.3.2 5.106.5.3.3 Mandatory Accessible EVCS 5.106.5.3.4 Mandatory Note for EVCS signs Mandatory Table 5.106.5.3.1 w/ footnotes 5.106.5.3.1, 5.106.5.3.2 and 5.106.5.3.3 Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 47 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION Requirement Section Title Code Section Y N/A O Mandatory Plan Sheet, Spec, or Attach Reference Electric vehicle (EV) charging [N] with Section 5.106.3.1, 5.106.5.3.2 and associated Table 5.106.5.3.1 OR OR 5.106.5.3.1, 5.106.5.3.2, Table 5.106.5.3.1, 5.106.5.3.2.1, 5.106.5.3.2.2, 5.106.5.3.3, 5.106.5.3.4 and 5.106.5.3.5. 5.106.5.3.6, Table 5.106.5.3.6 5.106.5.3.3, 5.106.5.3.4 and 5.106.5.3.5. 5.106.5.4 Mandatory 5.106.5.4.1 Mandatory 5.106.5.4.2 Mandatory Mandatory Mandatory Power Allocation Method: Section 5.106.5.3.6 and associated Table 5.106.5.3.6 Additions or Alterations to existing buildings or parking facilities [A] with Exceptions Existing buildings or parking areas without previously installed EV capable infrastructure [A]. Existing buildings or parking areas with previously installed EV capable infrastructure [A]. Electric vehicle (EV) charging: medium-duty and heavy-duty. [N] Electric vehicle charging readiness requirements for warehouses, grocery stores and retail stores, office buildings, and manufacturing facilities with planned off-street loading spaces [N] 5.106.5. 4 5 5.106.5. 4 5.1 Mandatory Table 5.106.5. 4 5.1 … … 5.106.5. 4 5 and 5.106.5. 4 5.1 … Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 48 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION DIVISION 5.2 Energy Efficiency [No change to table] DIVISION 5.3 Water Efficiency and Conservation [No change to table] DIVISION 5.4 Material Conservation and Resource Efficiency Requirement Section Title Code Section Y N/A O Plan Sheet, Spec, or Attach Reference … … Mandatory … 5.408.3 Mandatory Excavated soil and landscape debris (100% reuse or recycle) with Exception and Notes Life Cycle Assessment, Scope, Whole building life cycle assessment with Notes, Building components, Reference study period, and Verification of compliance Life Cycle Assessment, Scope, Product GWP compliance – prescriptive path, 5.409.3.1 with Exception and Exception EQUATION, Verification of compliance and Product GWP Limits Table with Footnotes 5.409.1, 5.409.2, 5.409.2.1, 5.409.2.2 and 5.409.2.3 5.409.1, 5.409.3, 5.409.3.1, 5.409.3.2 and Table 5.409.3 Mandatory Mandatory Recycling by occupants (with exceptions) 5.410.1 … … … Mandatory Inspection and reports 5.410.4.5.1 DIVISION 5.5 Environmental Quality [No change to table] Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 49 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION A5.602.1 CALGreen VERIFICATION GUIDELINES TIER 1 CHECKLIST … Chapter 5 Divisions DIVISION 5.1 Planning and Design (Select one elective from DIVISION 5.1) Requirement Section Title Code Section Y N O Plan Sheet, Spec, or Attach Reference Mandatory Mandatory Deconstruction and reuse of existing structures, Scope with Exception Reuse of existing building & Verification of compliance with note 5.105.1 5.105.2 and 5.105.2.1 Mandatory Storm water pollution … land 5.106.1 through 5.106.2 … … Tier 1 prerequisite Mandatory Mandatory Mandatory Designated parking-35% of parking capacity with future charging spaces, parking stall markings and vehicle designation stall identification Electric vehicle (EV) charging. [N] w/ exceptions Electric vehicle charging stations (EVCS) Use of automatic load management systems (ALMS) … A5.106.5.1, A5.106.5.1.1, A5.106.5.1.3, A5.106.5.1.4, A5.106.5.1.5 5.106.5.3 5.106.5.3.2 5.106.5.3.3 Mandatory EV capable spaces [N] 5.106.5.3.1 Mandatory Accessible EVCS 5.106.5.3.4 Mandatory Note for EVCS signs Mandatory Table 5.106.5.3.1 w/ footnotes Tier 1 prerequisite Electric vehicle (EV) charging [N] and Table A5.106.5.3.1 w/ footnotes 5.106.5.3.1, 5.106.5.3.2 and 5.106.5.3.3 A5.106.5.3, A5.106.5.3.1 Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 50 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION Requirement Section Title Code Section Y N O Plan Sheet, Spec, or Attach Reference Tier 1 prerequisite Electric vehicle (EV) charging [N] with Section 5.106.3.1, 5.106.5.3.2 and associated Table A5.106.5.3.1 Tier 1 5.106.5.3.1, 5.106.5.3.2, Table A5.106.5.3.1 Tier 1, 5.106.5.3.2.1, 5.106.5.3.2.2, 5.106.5.3.3, 5.106.5.3.4 and 5.106.5.3.5, A5.106.5.3.2, Table A5.106.5.3.2 Tier 1, 5.106.5.3.3, 5.106.5.3.4 and 5.106.5.3.5. 5.106.5.4 5.106.5.4.1 5.106.5. 4 5 5.106.5. 4 5.1 Mandatory Mandatory Mandatory Mandatory OR OR Power Allocation Method: Section A5.106.5.3.2 and associated Table A5.106.5.3.2 Tier 1 Additions or Alterations to existing buildings or parking facilities [A] with Exceptions Existing buildings or parking areas without previously installed EV capable infrastructure [A]. Existing buildings or parking areas with previously installed EV capable infrastructure [A]. Electric vehicle (EV) charging: medium-duty and heavy-duty. [N] Electric vehicle charging readiness requirements for warehouses, grocery stores and retail stores, office buildings, and manufacturing facilities with planned off-street loading spaces [N] Mandatory 5.106.5.4.2 Mandatory Table 5.106.5. 4 5.1 5.106.5. 4 5 and 5.106.5. 4 5.1 Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 51 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION Requirement Section Title Code Section Y N O Plan Sheet, Spec, or Attach Reference Mandatory Light pollution reduction [N] (with exceptions, notes and table) 5.106.8 through 5.106.8.2 Cool roof…. A5.106.11.2 Elective Community connectivity A5.103.1 … … Tier 1 Prerequisite … Elective … Elective Elective Elective Disassemble and reuse existing building structure (75%) with exceptions Disassemble and reuse existing nonstructural elements (50%) with exceptions Salvage Deconstruction and reuse of existing structures, Scope with Exceptions, Reuse of existing building, Tier 1 and Verification of compliance with Note Elective Storm water design … Elective … Elective Reduction of Heat Island effect, Hardscape alternatives Reduction of Heat Island effect, Cool roof with Exceptions, Solar reflectance, Thermal emittance, Solar reflectance index alternative, Verification of compliance … A5.105.1.1 A5.105.1.2 A5.105.1.3 A5.105.1, A5.105.2 and A5.105.2.1 and A5.105.2.3 A5.106.2- A5.106.2.2 … A5.106.11, A5.106.11.1 A5.106.11, A5.106.11.2, A5.106.11.2.1, A5.106.11.2.2, A5.106.11.2.3, A5.106.11.2.4 Elective Reduction of Heat Island effect, Shade trees A5.106.11, A5.106.11.3 Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 52 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION Requirement Section Title Code Section Y N O Elective Plan Sheet, Spec, or Attach Reference Bird-friendly building design, Required elevation treatment, Special conditions, Nighttime conditions with Exception, Systems or operation and maintenance manual A5.107, A5.107.1, A5.107.2, A5.107.3, A5.107.3.1 DIVISION 5.2 Energy Efficiency [No change to table] DIVISION 5.3 Water Efficiency and Conservation [No change to table] DIVISION 5.4 Material Conservation and Resource Efficiency (Select one elective from DIVISION 5.4) Requirement Section Title Code Section Y N O Plan Sheet, Spec, or Attach Reference … … Mandatory … 5.408.3 Mandatory Excavated soil and landscape debris (100% reuse or recycle) with Exception and Notes Life Cycle Assessment, Scope, Whole building life cycle assessment with Notes, Building components, Reference study period, and Verification of compliance Life Cycle Assessment, Scope, Product GWP compliance – prescriptive path, 5.409.3.1 with Exception and Exception EQUATION, Verification of compliance and Product GWP Limits Table with Footnotes 5.409.1, 5.409.2, 5.409.2.1, 5.409.2.2 and 5.409.2.3 5.409.1, 5.409.3, 5.409.3.1, 5.409.3.2 and Table 5.409.3 Mandatory … … … Mandatory Inspection and reports 5.410.4.5.1 Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 53 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION Requirement Section Title Code Section Y N O Plan Sheet, Spec, or Attach Reference Elective Wood framing or OVE w/ Note A5.404.1, A5.404.1.1, A5.404.1.2 Bio-based materials Certified Wood Components - Sustainability Standards A5.405.2 A5.405.2.1 … … … … … Elective Elective … Elective Elective Elective Elective Elective Elective Elective … Elective Elective A5.405.5.2 through A5.405.5.2.1.1 A5.405.5.3 through A5.405.5.3.2.4 A5.405.5.3, A5.405.5.3.1 A5.405.5.3, A5.405.5.3.2 A5.405.5.3, A5.405.5.3.4 A5.405.5.3, A5.405.5.3.5 … A5.409.1, A5.409.2, A5.409.2.1, A5.409.2.3 A5.409.1, A5.409.3, A5.409.3.1, A5.409.3.2, TABLE A5.409.3 Concrete manufacture, High strength concrete A5.405.5.3, A5.405.5.3.3 Cement and concrete: concrete with SCM & Mix design equation Cement and concrete- additional means of compliance Concrete manufacture, Recycled aggregates Concrete manufacture, Mixing water Concrete manufacture, Later Ages of Maturity Concrete manufacture, Returned Fresh Concrete … Life cycle assessment: general Scope with exceptions, Whole building life cycle assessment, Tier 1 with Exception, Verification of compliance Life cycle assessment: Scope with exceptions, Product GWP compliance – prescriptive path with Exception and Exception Equation, Verification of compliance, Product GWP Limits Tier 1 Table with footnotes Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 54 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION Requirement Section Title Code Section Y N O Plan Sheet, Spec, or Attach Reference Elective Elective Elective Elective Whole building life cycle assessment of additional impacts, Impacts to be considered Materials and systems assemblies A5.409.24, A5.409.24.1, A5.409.2.2 A5.409.3 Substitution for prescriptive standards A5.409.4 Verification of compliance A5.409.5 DIVISION 5.5 Environmental Quality [No change to table] A5.602.2 CALGreen VERIFICATION GUIDELINES TIER 2 CHECKLIST … Chapter 5 Divisions DIVISION 5.1 Planning and Design (Select two electives from DIVISION 5.1) Mandatory Mandatory Deconstruction and reuse of existing structures, Scope with Exception Reuse of existing building & Verification of compliance with note 5.105.1 5.105.2 and 5.105.2.1 Mandatory Storm water pollution … land 5.106.1 through 5.106.2 … … Tier 2 prerequisite Designated parking-50% of parking capacity with future charging spaces, parking stall markings and vehicle designation stall identification … A5.106.5.1, A5.106.5.1.2, A5.106.5.1.3, A5.106.5.1.4, A5.106.5.1.5 Requirement Section Title Code Section Y N O Plan Sheet, Spec, or Attach Reference Mandatory Electric vehicle (EV) charging. [N] 5.106.5.3 Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 55 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION Requirement Section Title Code Section Y N O Plan Sheet, Spec, or Attach Reference Mandatory Mandatory Mandatory EV capable spaces [N] 5.106.5.3.1 Electric vehicle charging stations (EVCS) Use of automatic load management systems (ALMS) 5.106.5.3.2 5.106.5.3.2.3 Mandatory Accessible (EVCS) 5.106.5.3.4 Mandatory Note for EVCS signs Mandatory Table 5.106.5.3.1 w/ footnotes Tier 2 prerequisite Tier 2 prerequisite Electric vehicle (EV) charging [N] and Table A5.106.5.3.2 w/ footnotes Electric vehicle (EV) charging [N] with Section 5.106.3.1, 5.106.5.3.2 and associated Table A5.106.5.3.3 Tier 2 OR OR Power Allocation Method: Section A5.106.5.3.4 and associated Table A5.106.5.3.4 Tier 2 Additions or Alterations to existing buildings or parking facilities [A] with Exceptions Existing buildings or parking areas without previously installed EV capable infrastructure [A]. Mandatory Mandatory 5.106.5.3.1, 5.106.5.3.2 and 5.106.5.3.3 A5.106.5.3, A5.106.5.3.2 5.106.5.3.1, 5.106.5.3.2, Table A5.106.5.3.3 Tier 2, 5.106.5.3.2.1, 5.106.5.3.2.2, 5.106.5.3.3, 5.106.5.3.4 and 5.106.5.3.5, A5.106.5.3.4, Table A5.106.5.3.4 Tier 2, 5.106.5.3.3, 5.106.5.3.4 and 5.106.5.3.5. 5.106.5.4 5.106.5.4.1 Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 56 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION Requirement Section Title Code Section Y N O Mandatory 5.106.5.4.2 Plan Sheet, Spec, or Attach Reference Mandatory Mandatory Existing buildings or parking areas with previously installed EV capable infrastructure [A]. Electric vehicle (EV) charging: medium-duty and heavy-duty. [N] Electric vehicle charging readiness requirements for warehouses, grocery stores and retail stores, office buildings, and manufacturing facilities with planned off-street loading spaces [N] 5.106.5. 4 5 5.106.5. 4 5.1 5.106.5. 4 5 and 5.106.5. 4 5.1 5.106.8 through 5.106.8.2 … A5.105.1.1 A5.105.1.2 A5.105.1.3 A5.105.1, A5.105.2, A5.105.2.2 and A5.105.2.3 Mandatory Table 5.106.5. 4 5.1 Mandatory Light pollution reduction [N] (with exceptions, notes and table) Cool roof…. A5.106.11.2 Elective Community connectivity A5.103.1 … … Tier 2 Prerequisite … Elective … Elective Elective Elective Disassemble and reuse existing building structure (75%) with exceptions Disassemble and reuse existing nonstructural elements (50%) with exceptions Salvage Deconstruction and reuse of existing structures, Scope with Exceptions, Reuse of existing building, Tier 2 and Verification of compliance with Note Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 57 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION Requirement Section Title Code Section Y N O Plan Sheet, Spec, or Attach Reference Elective Storm water design Elective Changing rooms with note A5.106.4.3 … … A5.106.2- A5.106.2.2 … … Reduction of Heat Island effect, Hardscape alternatives Reduction of Heat Island effect, Cool roof with Exceptions, Solar reflectance, Thermal emittance, Solar reflectance index alternative, Verification of compliance A5.106.11, A5.106.11.1 A5.106.11, A5.106.11.2, A5.106.11.2.1, A5.106.11.2.2, A5.106.11.2.3, A5.106.11.2.4 Reduction of Heat Island effect, Shade trees A5.106.11, A5.106.11.3 Bird-friendly building design, Required elevation treatment, Special conditions, Nighttime conditions with Exception, Systems or operation and maintenance manual A5.107, A5.107.1, A5.107.2, A5.107.3, A5.107.3.1 DIVISION 5.2 Energy Efficiency [No change to table] DIVISION 5.3 Water Efficiency and Conservation [No change to table] DIVISION 5.4 Material Conservation and Resource Efficiency (Select two electives from DIVISION 5.4) Requirement Section Title Code Section Y N O … … Mandatory … 5.408.3 Plan Sheet, Spec, or Attach Reference Excavated soil and landscape debris (100% reuse or recycle) with Exception and Notes BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 58 of 60 Public August 2, 2023 SOS Filing-FET … … Elective Elective Elective Elective STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION Requirement Section Title Code Section Y N O Mandatory Plan Sheet, Spec, or Attach Reference Mandatory 5.409.1, 5.409.2, 5.409.2.1, 5.409.2.2 and 5.409.2.3 5.409.1, 5.409.3, 5.409.3.1, 5.409.3.2 and Table 5.409.3 Life Cycle Assessment, Scope, Whole building life cycle assessment with Notes, Building components, Reference study period, and Verification of compliance Life Cycle Assessment, Scope, Product GWP compliance – prescriptive path, 5.409.3.1 with Exception and Exception EQUATION, Verification of compliance and Product GWP Limits Table with Footnotes … … … … … Mandatory Inspection and reports 5.410.4.5.1 Elective Wood framing or OVE w/ Note A5.404.1, A5.404.1.1, A5.404.1.2 … Elective Elective … Elective Elective Elective Elective Elective Elective Bio-based materials Certified Wood Components - Sustainability Standards A5.405.2 A5.405.2.1 … … Cement and concrete: concrete with SCM & Mix design equation Cement and concrete- additional means of compliance Concrete manufacture, Recycled aggregates Concrete manufacture, Mixing water A5.405.5.2 through A5.405.5.2.1.1 A5.405.5.3 through A5.405.5.3.2.4 A5.405.5.3, A5.405.5.3.1 A5.405.5.3, A5.405.5.3.2 Concrete manufacture, High strength concrete A5.405.5.3, A5.405.5.3.3 Concrete manufacture, Later Ages of Maturity A5.405.5.3, A5.405.5.3.4 Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 59 of 60 August 2, 2023 SOS Filing-FET STATE OF CALIFORNIA BUILDING STANDARDS COMMISSION Requirement Section Title Code Section Y N O Plan Sheet, Spec, or Attach Reference Elective … Elective Elective Elective Elective Elective Elective Elective Concrete manufacture, Returned Fresh Concrete A5.405.5.3, A5.405.5.3.5 Life cycle assessment: General A5.409.1 … … A5.409.1, A5.409.2, A5.409.2.2, A5.409.2.3 Life cycle assessment: general Scope with exceptions, Whole building life cycle assessment, Tier 2 with Exception, Verification of compliance Life cycle assessment: Scope with exceptions, Product GWP compliance – prescriptive path with Exception and Exception Equation, Verification of compliance, Product GWP Limits Tier 2 Table with footnotes Whole building life cycle assessment of additional impacts, Impacts to be considered Materials and systems assemblies A5.409.24, A5.409.24.1, A5.409.2.2 A5.409.3 Substitution for prescriptive standards A5.409.4 Verification of compliance A5.409.5 A5.409.1, A5.409.3, A5.409.3.1, A5.409.3.2, TABLE A5.409.3 DIVISION 5.5 Environmental Quality [No change to table] Notation: Authority: Health & Safety Code Sections 18930.5 and 18931.7(b). Reference(s): Health & Safety Code Sections 18930.5 and 18931.7(b). Public BSC TP-105 (Rev. 03/22) Final Express Terms BSC 04/22 - Part 11 - 2022 Intervening Code Cycle California Building Standards Commission Page 60 of 60 August 2, 2023 SOS Filing-FET  1301 S. Mopac Expressway Suite 400 Austin, TX 78746 jason.ketchum@onegas.com Phone: 918.282.8522 July 8th, 2024 Submitted via SpeakUp Austin and via email to: energcode@austinenergy.com Austin Energy Green Building Program 4815 Mueller Blvd. Austin, TX 78723 Re: Texas Gas Service Company’s Comments on City of Austin’s Proposed Adoption of Certain 2024 IECC Building Codes Austin Energy Staff and City of Austin Department of Development Services: Texas Gas Service Company, a division of ONE Gas, Inc. (“Texas Gas Service”) proudly provides over 235,000 customers inside the City of Austin (“City) and another 40,000 customers in the Austin Metro area with affordable, reliable and clean natural gas service. We are excited to work with the City and industry stakeholders in the development of a fuel neutral energy code, designed to achieve building energy conservation while maintaining building safety, energy affordability, and energy reliability and resilience within both the commercial and residential sectors. As a stakeholder, Texas Gas Service appreciates the City’s willingness to grant the public time to review the proposed inclusion of all (or only parts) of the 2024 IECC (International Energy Conservation Code) within the City of Austin’s building codes. Because the affordability of housing in the Austin area is important to current and potential residents,1 and the adoption of certain portions of the latest energy codes will likely increase the prices of new homes, these adoption proceedings are important. As such, Texas Gas Service strongly supports the City of Austin’s decision to organize public hearing(s) and to provide the opportunity for public comment surrounding any recommendations for adoption prior to taking final action. In 2024, ONE Gas, Inc. (“ONE Gas”), Texas Gas Service’s parent company received a rating of AAA (on a scale of AAA to CCC) in the MSCI ESG Ratings assessment. ONE Gas, also holds a “Prime” corporate rating in ESG from Institutional Shareholder Services (ISS) and is a member of See 1 , data.austiontexas.gov, “Percentage of Households Paying More Than 30 Percent (and more than 50 percent) of Income Toward Housing,” ttps://data.austintexas.gov/stories/s/EOA-C-1-Percentage-of- households-paying-more-than-/tevy-4u2b/; see also, The Texas Tribune, “Austin Will Try Again to Tame its Housing Affordability Crisis with Zoning Reforms. Can It Do It This Time?" September 19, 2023. July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations ONE Future, a coalition of companies across the natural gas value chain that are committed to keeping emissions intensity below 1%, a goal the coalition has beaten every year ONE Gas has been a participant. Further, natural gas has proven to be affordable, reliable and a clean energy source which works in tandem with the electrical grid. In support of our customers and our environment, Texas Gas Service offers a robust energy efficiency program throughout the State of Texas. Texas Gas Service was one of the first natural gas utility companies in the country to offer rebates for high efficiency appliances in Austin and have done so for 30 years. In the Central Texas Region alone, during 2023 and up until May 2024, TGS has provided over $750,000 in rebates to residential and commercial customers, including builders, for the installation and purchase of various high efficiency natural gas appliances, as well as weatherization strategies to improve building efficiency and reduce emissions. In 2023, our energy efficiency program avoided 44,400 metric tons of CO2e, which is equivalent to removing over 10,000 passenger vehicles off the road. The availability of natural gas for end-use in commercial and residential buildings is vital to the City of Austin’s ability to put forth a viable energy portfolio. As proven on numerous occasions over the past few years, natural gas is a critical component to a comprehensive energy plan. Because our infrastructure is located primarily below ground, our natural gas system has a 99% reliability rating. During Winter Storm Uri, (and the subsequent ice storms) we kept the gas flowing to provide life-saving services to our customers. During URI, service was interrupted to only 300 of our more than 690,000 customers that we serve throughout the state of Texas, and most of these outages lasted less than 24 hours. It is important to us that our customers continue to have access to safe and reliable natural gas in both good and difficult circumstances. And so, ONE Gas and members of each of its divisions (including Texas Gas Service) monitored and participated (both on its own and where possible in collaboration with others), in the IECC’s process of drafting, reviewing and adoption of the 2024 IECC codes. Along the way, we and other collaborators with interests tied to the Austin community have worked diligently to provide relevant input on a variety of issues raised during the IECC’s code adoption process. As can be expected some of our recommendations were considered while others went unacknowledged and unheard. However, we recognize that local government is more likely to have the ability recognize and to consider the real impacts that certain actions may have on its residents, industry and community. It is with this understanding that we are highlighting certain important issues that may have negative impacts on our customers ability to make reasonable and affordable choices related to building construction, the appliances they may desire and their ability to choose safe and reliable energy to warm their homes or businesses and/or to operate their appliances. We respectfully request your careful and thoughtful consideration of our recommendations below. Additionally, we are attaching, in Appendix I, proposed code language, that if adopted would implement building energy conservation measures in an equitable, affordable, and reliable manner for all Austinites. 2 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations Summary of Recommendations: • Electric Readiness – Sections 8.4.5 and RK101: This portion of the code is intended to prepare such buildings for electrification if and when fossil fuels are no longer a permissible or viable, cost-effective option. However, requirements for “electric readiness” for residential and commercial buildings were not properly justified in the IECC drafting process and as a result, led to these proposed requirements being relegated by the IECC committee as guidance material only and placed in an appendix of the 2024 IECC.2 Based on the lack of confidence in the justification and general uncertainty surrounding this proposed code, we recommend that the City of Austin reject the promulgation of this portion of the 2024 IECC appendix as requirements in the City of Austin energy code. Instead, should the City find some value in this proposed section, we encourage the City to revise the code language to align more closely with the manner of adoption by the 2024 IECC, which made the use of the information as non- mandatory guidance only for builders, building operators, and homeowners. • Partnership with Interested Parties: We strongly encourage the City of Austin to take steps to invite and build a close partnership with the local home builder associations to afford ready opportunities to understand the true cost implications of electric-ready code provisions that may be imposed upon Austinites, builders, and building operators, should the City choose to enforce or the building owner opt to pay for such electric-readiness preparations. Until true costs are determined, we recommend the City delay its final decision on this proposed code provision, given the importance of making sure there is an adequate supply of affordable new housing for all. Austin housing costs for both new homes and rental properties continue to climb, shutting out many potential new and low-income community home buyers and renters. The City of Austin needs to integrate housing affordability considerations in its consideration of 2024 IECC code adoption, looking at both the impact upon housing costs of construction and affordability directly affected by 2024 IECC and code amendment provisions. • Section R408 “additional energy credits” and Table R408.2: Publication of the revised Section R408 was done without broad stakeholder consensus concerning justification of the credit values, or the development of sound definitions of technology categories used for Table R408.2 credit assignments. Further, we are also raising a concern regarding the level of consideration given to the issues of relative site energy, full fuel cycle energy, and emissions reductions, and to the quantitative basis for numerical credit values across envelope and mechanical system options. among technology options for specific fuels and end uses, or between competing electric and gas options for residential buildings. We encourage the City of Austin to withhold adoption of this section until it has had an opportunity to independently review and justify these credit assignments from its adoption of the Table R408.2 credits as published to address the lack of technical consensus and justification during the 2024 IECC deliberations, with a specific focus on climate and emissions factors relevant to City of Austin energy supply alternatives foreseeable over the current IECC code cycle. 2 https://www.iccsafe.org/products-and-services/i-codes/code-development/2024-iecc-appeals/ 3 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations In addition, the “additional energy credits” in Table R408.2, presume a federal minimum energy efficiency for non-weatherized residential natural gas central furnaces of 95% AFUE and base additional credits on this minimum energy efficiency as a baseline. However, the federal minimum efficiency standard of 95% AFUE is under challenge in lawsuits filed by the American Gas Association (AGA) and other petitioners3 and as a result cannot simply be presumed as the baseline for Table R408.2 credits. If the AGA, et. al. petitions are successful, the federal minimum efficiency for non-weatherized residential natural gas central furnaces would remain at 80% AFUE, and “additional energy credits” available in Table R408.2 would have to be adjusted to account for the 80% AFUE baseline. Texas Gas Service recommends that the City of Austin revise its proposal for “additional energy credits” to recognize efficiency improvements over the current 80% baseline. This should begin at 90% AFUE for incentivizing installation of Category IV natural gas furnaces (i.e., condensing combustion, positive venting pressure) as a first tier of “additional energy credits” as available, to builders for both singularly credited measures and in combination with other measures such as installation of high efficiency air conditioning as currently offered in Table R408.2. We recommend this revision be made applicable at least until a court order is issued. • Texas Utility Code §181.903 (Texas 2021 HB 17) – Restriction on Regulation of Utility Services and Infrastructure: In 2021, the Texas Legislature took steps by adopting HB 17 (now codified as Tex. Util. Code § 181.903) to protect builders and property owners from facing the negative impacts of regulation that either encourages or discourages the installation of certain utility facilities based on energy type. To avoid potential conflict with this recent state law, we strongly encourage the city to conduct a comprehensive and thorough legal review of the proposed new codes in light of the legislative intent to ensure preservation of fuel choice for commercial and residential customers. For a more detailed discussion and support of our positions as summarized points above, please see “Texas Gas Service Attachment A” as attached hereto. Again, we appreciate the opportunity to meaningfully participate in the City’s process of reviewing the 2024 IECC code provisions for consideration of adoption and implementation by the City. We stand ready to provide additional details or to respond to questions on this subject upon the City’s request. Sincerely, Jason Ketchum VP Commercial 3 AGA, et al., v. DOE, D.C. Cir. Nos. 22-1030 and 23-1337. 4 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations TEXAS GAS SERVICE – ATTACHMENT A Discussion of Recommendations 2024 IECC and Electric-Readiness Provisions (Sections 8.4.5 and RK101.1) As proposed, the City of Austin’s draft technical code language requires infrastructure for water heaters, clothes dryers, and cooking appliances that utilize fuel gas or liquid fuel, to also include installation of a dedicated 240-volt branch circuit outlet to be installed within 3 feet of each appliance specified above. During the 2024 IECC appeals process and final decision-making period, the ICC Board of Directors specifically recognized that the ‘electric-ready’ code provisions (and other associated requirements) did not comport with traditional “Scope” and “Intent” of the IECC. As a compromise, the Board agreed to place the problematic language into appendices based upon the Board’s understanding that such coverages could not be justified as IECC requirements, which represent minimum energy conservation requirements. (emphasis added.) Texas Gas Service’s concern with the ‘electric-ready’ code provisions is that the economic analysis presented within the IECC code process was fundamentally flawed by the reliance on the presumption as a matter of course, that replacement of gas appliances with electric alternatives will take place in 100% of occupancies. The cost comparison used to support the presumption was restricted to the incorporation of electric infrastructure at the time of construction versus the possibility of future retrofit installation of electric infrastructure. The presumption did not allow for consideration of the facts that: (1) replacement of gas appliances with electric alternatives will not occur in all occupancies; and, (2) policies that would require such replacement in all cases, would run counter to cautions expressed by the ICC Board that could be challenged on federal preemption of EPCA covered products, discuss later in these comments. Additionally, any replacement not so mandated would need to be accounted for in actuarial predictions of gas appliance retirements. None of these considerations were taken into account in the development phase of the ‘electric ready’ provisions, now residing in IECC’s Appendix RK. The City of Austin, in their code changes summary, specifically states that electric-readiness code provisions are adopted to align with their Climate Equity Plan. According to the plan, the city will achieve energy efficient, net-zero carbon buildings with “equity principles” in mind to ensure that impacts to low-income communities and communities of color are fully understood and taken into consideration.4 Texas Gas Service stands with the City in its pursuit of a reduction in green house gas (“GHG”) emissions, in an equitable manner. However, we believe that it necessary to work toward achieving such a goal through a fuel agnostic approach to the adoption of the 2024 IECC. We also believe that natural gas emissions reduction strategies must be developed and deployed in a fair and equitable manner. Further, Texas Gas Service also believes that such emission reduction strategies should be achieved with consideration of economic justice for all Austinites. Austin Climate Equity Plan https://www.austintexas.gov/sites/default/files/files/Sustainability/Climate%20Equity%20Plan/Clima te%20Equity%20Plan%20Full%20Document__FINAL.pdf 5 4 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations We define economic justice to encompass three primary pillars: affordability, energy choice, and energy access. Like environmental justice, economic justice is the fair treatment of all people, regardless of income level, with respect to the City’s enforcement of energy regulation, or in this case, the development, adoption and enforcement of building codes. Language within the Climate Equity Plan specifically provides that such strategies designed to reduce natural gas emissions “may include but are not limited to” use of renewable natural gas and expansion of energy efficiency programs, and other “new technologies and programs.”5 However, if the proposed electric-readiness language is adopted as a requirement for new residential and commercial buildings, the ability for the City to utilize new technologies and programs to reduce natural gas emissions will no longer be an option because electric-readiness language is adopted upon the premise that electrification of the building sector will indeed occur and natural gas end- use will no longer be a viable option. By requiring placement of a branch circuit to include labels such as “for future electric clothes drying equipment”, the City is indirectly banning natural gas by requiring use of electric appliances. TGS is concerned that if such language is finalized and adopted, a dangerous precedent will occur by limiting the City and its residents to one single energy source - electricity. An equal important concern is that adoption of this strategy would also be contrary to the legislative intent expressed in Texas 2021 HB 17 (Tex. Util. Code § 181.903). In support of the legitimacy of our concern, during the May 30th, 2024, in-person code engagement meeting, Austin Energy staff stated that the reason for electric-readiness language adoption is to prevent the higher cost of electrifying the residential and commercial building sectors in the future. They also stated that the driver behind electric-readiness is to “allow these projects to have a choice when the homeowner decides in the future to replace that equipment, they can have an option of what fuel source to use.” We found this reasoning confusing as today, homeowners already have a choice to choose electric appliances as well as natural gas appliances. There is nothing now that prevents Austinites from choosing electric appliances. In addition, Austin Energy staff stated that electric-readiness provisions are drafted for adoption “based off of the equipment we have now” not on potential future additions which is contrary to the actual intent of the ‘electric ready’ provisions.6 Before the City moves forward with any serious considerations for the adoption of the proposed ‘electric ready’ provisions, we ask that the City encourage staff to further explain what equipment is available now that wouldn’t be available to consumers but for an adoption of the proposed code requirements. Electric-Readiness Cost Concerns According to the Pacific Northwest National Laboratory (PNNL), the entity that conducts the energy savings calculations of the newest IECC provisions, ‘electric readiness’ provisions are simply a measure in place in case natural gas is no longer a viable option. Specifically, the lab states that electric-readiness codes prevent homeowners from incurring “future costs should fossil https://www.austintexas.gov/sites/default/files/files/Sustainability/Climate%20Equity%20Plan/Clima te%20Equity%20Plan%20Full%20Document__FINAL.pdf, pg. (50, 94) 6 Technical Code Amendments In-Person Document, https://publicinput.com/g4245?lang=en 6 5 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations fuels become less affordable or even unavailable over the life of the building.” 7 PNNL also states that electric readiness codes will help “improve the cost effectiveness of electrification in the future,” not in the present. Again, these statements are based on an assumption that such required additional electrical infrastructure will be used and useful to consumers in a timely manner. In the City’s proposal for adoption of the ‘electric ready’ provisions, it has not provided a definition of “future” in a manner to permit the City the ability to consider the costs against any ‘future’ benefits of the proposed adoption. Also, in addition to PNNL analysis, the New Building Institute (NBI), another stakeholder in the 2024 IECC process and strong proponent of electric-readiness code language, stated that the cost of electrical panel upgrades and associated electric-readiness infrastructure for a new build “is equivalent to the expense of upgrading to an average stone kitchen countertop,” or between $1,000- $1,800.8 This analysis assumes that the average homeowner can afford the cost equivalent of upgrading to a kitchen countertop and that they will in fact reap the “thousands of dollars” saved from using such infrastructure. Finally, in 2021, Home Innovation Research Labs published cost analyses conducted for the National Association of Home Builders for four major U. S. cities comparing gas equipped houses to all electric houses.9 For new home construction in Houston, Texas (the metropolitan area closest to Austin), the study showed that costs of electrification (including costs of appliances for cooking, clothes drying, space heating (and cooling), and service water heating) averaged $24,282 more than the average baseline gas house . This total cost, while not specific to electric-ready equipment, addresses appliance costs, and illustrates two impacts. First, the increased cost of going all-electric in an average home is, on its own, an inducement not to later switch or add new fuels and to instead, make use of the already installed electric-ready infrastructure. This burden will force builders and owners to forgo consideration of the benefits of alternative fuel sources in favor of avoiding stranding the costs of that alternative infrastructure as a direct result of the mandated code compliance. Second, the added total cost to residential construction is likely to negatively impact economically disadvantaged and first-time home buyers by escalating home prices generally. Of course, these costs do not capture direct costs of electric-ready provisions such as branch circuits and panel upgrades. However, the U. S. Energy Star program estimates that panel upgrades for new builds (compared to that of standard systems) may add $1,000 to $2,500 and branch circuit costs of $300 to $1,000 per end use appliance with higher costs, where runs of circuits increase in length and increasing numbers of wall penetrations.10 In cases where these added expenses become 7 8 https://newbuildings.org/wp-content/uploads/2022/04/BuildingDecarbCostStudy.pdf https://www.pnnl.gov/main/publications/external/technical_reports/PNNL-32183.pdf 9 Home Innovation Research Labs, “Cost and Other Implications of Electrification Policies on Residential Construction,” prepared for National Association of Home Builders, February 2021. 10 U. S. Energy Star, “Make Your Home Electric Ready:” https://www.energystar.gov/products/energy_star_home_upgrade/make_your_home_electric_ready 7 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations stranded costs in particular, the added cost to home construction would represent a decidedly negative impact on consumer resources and financing capacity. Conflict with Chapter 181, Section 181.903 of the Utilities Code Texas Gas Service believes that draft language regarding electric-readiness codes for both commercial and residential end-uses may be in direct violation of Tex. Util. Code § 181.903 (Texas 2021 HB 17), which was signed into law on May 18th, 2021. The law specifically states that no regulatory or planning authorities, or political subdivision “may adopt or enforce an ordinance, resolution, regulation, code, order, policy, or other measure that has the purpose, intent, or effect of directly or indirectly banning, limiting, restricting, discriminating against, or prohibiting the connection or reconnection of a utility service or the construction, maintenance, or installation of residential, commercial, or other public or private infrastructure for a utility service based on the type or source of energy to be delivered to the end-use customer.”11 As discussed above, the electric-ready code provisions for commercial and residential buildings have a purpose and intent to indirectly ban, limit, and discriminate against natural gas end-use. The provisions serve to prohibit the connection of a utility service based on the type of energy source, in this case, natural gas, and to prevent it from being delivered to the end-use customer in the future. By requiring installation of branch circuits with labels that state ‘for future electric appliance,’ next to natural gas appliances, and by specifically targeting those buildings that operate natural gas appliances, the City would be prohibiting fuel choice. Due to our stated concerns, we strongly encourage a comprehensive and thorough legal review of state law to ensure that fuel choice for commercial and residential customers is preserved as intended under Texas law. 11 See, Tex. Util. Code § 181.903(b)( May 18, 2021). 8 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations Additional Considerations for Deliberation by City of Austin: A. Recent Electricity Cost and Reliability Projections Austin Energy provides valuable electricity services via various renewable resources such as solar, wind, and biomass. Because these resources are dependent upon weather patterns, which are drastically changing due to climate change, additional fuel resources like nonrenewables and natural gas distribution services are critical to meeting the ongoing (and increasing) high demand for electricity. Growing electricity demand from residential and commercial customers, increasing use of AI, and a transition away from fossil fuels is pushing the US electric grid to the brink, according to McKinsey & Company, the Federal Energy Regulatory Commission (FERC) and multiple news outlets.12 In FERC’s May 2024 summer energy market and reliability report, it explained that U.S. electric demand is expected to increase 2.7% this summer to 1,487 TWh compared to last summer. Similarly, U.S. data center load is expected to grow to nearly 21 GW this year, up from 19 GW in 2023, FERC staff said in the report. Electric demand from such facilities across the U.S. is expected to climb to 35 GW by the end of this decade, according to the report.13 A report released in June 2024, by the National Energy Assistance Directors Association (NEADA) and the Center for Climate and Energy Poverty shows increases in the US electricity bill average since 2014. Specifically, for the Southwest Region of the US, (which includes Texas), consumers can expect an average electricity bill to be upwards of $858 during the cooling season from June - September 2024. This burden weighs heaviest on low-income consumers. According to the report, the high costs are exacerbated by extreme heat events caused by climate change. The report recommends policy alternatives that are inclusive of low-income communities, such as weatherization assistance and installation of heat pumps. However, the heat pump recommendation does not take into consideration the impacts of climate zone differentiation and may not be suitable for the Southwest Region. Nonetheless, Texas Gas Service provides weatherization assistance throughout the Central Texas Region as well as rebates to make high efficiency natural gas appliances affordable for low-income customers.14 This report provides a snapshot into the importance of a fuel agnostic approach to energy usage via all policy avenues, including building code development. In addition to the NEADA report, the North American Electric Reliability Corporation (NERC) predicts a “potential for insufficient operating reserves” for ERCOT this summer if demand is at its highest. The report specifically states that although solar PV is added at a rate outpacing demand, energy risks are growing when solar output is at its lowest. Transmission permitting and development delays also contribute to this energy risk concern for ERCOT. Natural gas end-use https://www.washingtonpost.com/business/2024/05/13/power-grid-transmission-lines-electricity/ https://www.mckinsey.com/industries/technology-media-and-telecommunications/our- insights/investing-in-the-rising-data-center-economy 13 https://www.ferc.gov/news-events/news/report-2024-summer-energy-market-and-electric- reliability-assessment 14 https://neada.org/wp-content/uploads/2024/06/2024summeroutlook.pdf 9 12 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations offers certainty when the electric grid is not able to perform at its highest and meet the demand of the growing Texas population.15 B. The Berkeley Gas Ban and Court Challenges to State and Local Codes Disproportionately Affecting Fuel Gas Installation. Earlier this year, the City of Berkeley, California, repealed their ban on natural gas end-use in new residential and commercial buildings after the Ninth Circuit Court of Appeals ruled that such a ban was in violation of the Energy Policy and Conservation Act (EPCA). The ruling states that EPCA preempts state regulation or building code from regulating the efficiency of natural gas appliances; instead, the US Department of Energy oversees this concern. Many stakeholders including the California Restaurant Association and builders, were in opposition to a direct ban on natural gas end-use. As a result of the decision, other cities throughout California have repealed their bans on natural gas end-use. Although the City of Austin’s proposed energy code is not a direct ban on natural gas use in new residential and commercial buildings, the premise of electric-readiness code language is to prepare for a future for electrifying buildings and a hypothetical world without natural gas end-use, all of which is to be paid for by customers who may or may not want to discontinue their use of natural gas appliances. C. Legal Interpretation of Federal Preemption Risks Forewarned by 2024 IECC Cautionary Notices of Appendix Adoptions as Requirements As several appendices of the 2024 IECC note the potential for federal preemption issues with the use of appendix material as requirements, ONE Gas recognizes that all requirements that set criteria for EPCA “cover product” federal minimum efficiency standards other than the promulgated minimum efficiency standard subject the City of Austin to these risks if adopted as building requirements. Based upon court cases involving the EPCA statute and its prohibition of federal minimum efficiency standards, these risks are not manifest just for incidents where a local jurisdiction is setting conflicting minimum standard and can include energy efficiency programs that create biases against such minimum efficiency standard “covered products.” 16 As discussed for Table R408.2 above, ONE Gas strongly recommends that the City conduct a review of 2024 IECC requirements for “covered products” and determine whether or not such adoption of the proposed electric ready provisions would impose a risk of the City of violating federal preemption prohibitions. Although in its comments to the 2024 IECC, ONE Gas recommended that ICC conduct its own legal analysis of potential conflicts and associated risks for the benefit of potential adopting jurisdictions, the ICC Board, in recommending advisory language in appendix material covering this issue “punted” the consideration of the issue of potential risks to local jurisdictions to assess. 15 October 3, 2008. 16 Air Conditioning, Heating and Refrigeration Institute v. City of Albuquerque, Docket No. 08-633 MV/RLP, https://www.nerc.com/pa/RAPA/ra/Reliability%20Assessments%20DL/NERC_SRA_2024.pdf 10 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations D. Impacts of Additional Electricity Demand Upon Carbon Emissions Under Scenarios of Grid Makeup. The City of Austin neither provides nor documents usage of any impact analysis covering expanded electricity demand that might arise as a consequence of electric-ready provisions in the code and replacement of natural gas end use applications that may result. This is a serious deficiency in the ability of the City to assess benefits as well as costs of electric-ready requirements. Based upon federal grid electricity data published by the U. S. Environmental Protection Agency (EPA) in its eGRID database and employed in energy emissions estimating tools such as GTI Energy’s EPAT tool for the City of Austin,17 current grid electricity consumed in the City accounts for 916.5 pounds of carbon dioxide (CO2) per megawatt of power. Unless the City can demonstrate dramatic reductions in this CO2 emission rate in the future, electric-ready provisions in buildings (if put into effect) will proportionately increase the City’s CO2 emissions in the future. Also, these data sources document that current source energy consumption factors for the City of Austin to be 2.38 times the energy delivered to building sites in comparison to natural gas, which only accounts for a 1.09 times source energy factor. Emissions are proportional to these source energy factors and the current electricity grid mix. As a result, forced fuel switching to grid electricity based upon current data would likely increase the City’s emissions contribution over maintaining use of natural gas for many applications. ONE Gas strongly recommends that the City, prior to agreeing to promulgate electric-ready building requirements, take these effects into account. If the City bases its code on a different grid electricity future, that forecast should be made available to the public for review. 17 https://cmicepatcalc.gti.energy/BuildCityHouse.aspx. 11 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations APPENDIX I Texas Gas Service’s Proposed Code Language Update (Austin’s Commercial Code Provisions with PROPOSED Changes Highlighted in Blue)18 8.4.5 Additional electric infrastructure. Electric infrastructure in buildings that contain combustion equipment shall may be installed in accordance with this section. 1. Combustion space heating. Spaces containing combustion equipment for space heating shall may comply with Sections 8.4.5.1.1, 8.4.5.1.2 and 8.4.5.1.3 1.4.5.1.1 Designated exterior locations for future electric space-heating equipment. Spaces containing combustion equipment for space heating shall may be provided with designated exterior location(s) shown on the plans and of sufficient size for outdoor space-heating heat pump equipment, with a chase that is sized to accommodate refrigerant lines between the exterior location and the interior location of the space heating equipment, and with natural drainage for condensate from heating operation or a condensate drain located within 3 feet (914 mm) of the location of the future exterior space-heating heat pump equipment. 2.4.5.1.1 Dedicated branch circuits for future electric space-heating equipment. Spaces containing combustion space-heating equipment with a capacity not more than 65,000 Btu/h (19 kW) shall may be provided with a dedicated 240-volt branch circuit with ampacity of not less than 50. The branch circuit shall may terminate within 6 feet (1829 mm) of the space heating equipment and be in a location with ready access. Both ends of the branch circuit shall may be labeled with the words “For Future Electric Space Heating Equipment” and be electrically isolated. Spaces containing combustion equipment for space heating with a capacity of not less than 65,000 Btu/h (19 kW) shall be provided with a dedicated branch circuit rated and sized in accordance with Section 8.4.5.1.3, and terminating in a junction box within 3 feet (914 mm) of the location the space heating equipment in a location with ready access. Both ends of the branch circuit shall may be labeled “For Future Electric Space Heating Equipment.” Exceptions: 1. Where a branch circuit provides electricity to the space heating combustion equipment and is rated and sized in accordance with Section 8.4.5.1.3. 2. Where a branch circuit provides electricity to space cooling equipment and is rated and sized in accordance with Section 8.4.5.1.3. 3. Where future electric space heating equipment would require three-phase power and the space containing combustion equipment for space heating is provided with an electrical panel with a label stating “For Future Electric Space Heating Equipment” and a bus bar rated and sized in accordance with Section 8.4.5.1.3. Please note, in addition to the proposed edits as highlighted in blue, TGS added formatting edits only to the City’s original draft document to improve readability of the same information upon inclusion into the Company’s comments. 12 18 4. Buildings where the 99.6 percent design heating temperature is not less than 50°F (10°C). July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations TABLE 8.4.5.1 ALTERNATE ELECTRIC SPACE HEATING EQUIPMENT CONVERSION FACTORS (VA/kBtu/h) 99.6% HEATING DESIGN TEMPERATURE Greater Than (°F) Not Greater Than VA/kBtu/h 50 45 40 35 30 25 20 15 10 5 0 -5 10 -15 N/A 50 45 40 35 30 25 20 15 10 5 0 5 -10 Ps N/A 94 100 107 115 124 135 149 164 184 210 243 289 293 For SI: °C = [(° F) – 32]/1.8, 1 British thermal unit per hour = 0.2931 kW. Additional space heating electric infrastructure sizing. Electric infrastructure for future electric space heating equipment shall may be sized to accommodate not less than one of the following: 1. An electrical capacity not less than the nameplate space heating combustion equipment heating capacity multiplied by the value in Table 8.4.5.1, in accordance with Equation 8.4.5.1.VAs = Qcom x Ps 2. Equation 8.4.5.1 Where VAs = The required electrical capacity of the electrical infrastructure in volt-amps.Qcom = The nameplate heating capacity of the combustion equipment in kBtu/h Ps = The VA per kBtu/h from Table 8.4.5.1 in VA/kBtu/h. 3. An electrical capacity not less than the peak space heating load of the building areas served by the space heating combustion equipment, calculated in accordance with Section 6.4.2.1, multiplied by the value for the 99.6 percent design heating temperature in Table 8.4.5.1, in accordance with Equation 8.4.5.2. 13 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations VAs = Qdesign x Ps Equation 8.4.5.2 Where VAs = The required electrical capacity of the electrical infrastructure in volt-amps. Qdesign = The 99.6 percent design heating load of the spaces served by the combustion equipment in kBtu/h. Ps = The VA per kBtu/h from Table 8.4.5.1 in VA/kBtu/h. 2. Combustion service water heating Spaces containing combustion equipment for service water heating shall may comply with Sections 8.4.5.2.1, 8.4.5.2.2 and 8.4.5.2.3. 1.4.5.1.1 Combustion service water heating electrical infrastructure. For each piece of combustion equipment for water heating with an input capacity of not more than 75,000 Btu/h (22 kW), the following electrical infrastructure is required: 1. An individual 240-volt branch circuit with an ampacity of not less than 30 shall may be provided and terminate within 6 feet (1829 mm) of the water heater and shall be in a location with ready access . 2. The branch circuit overcurrent protection device and the termination of the branch circuit shall may be labeled “For future electric water heater.” 3. The space for containing the future water heater shall may include the space occupied by the combustion equipment and shall have a height of not less than 7 feet (2134 mm), a width of not less than 3 feet (914 mm), a depth of not less than 3 feet (914 mm) and with a volume of not less than 700 cubic feet (20 m3). Exception: Where the space containing the water heater provides for air circulation sufficient for the operation of a heat pump water heater, the minimum room volume shall not be required. 2.4.5.1.1 Designated locations for future electric heat pump water heating equipment. Designated locations for future electric heat pump water heating equipment shall may be in accordance with one of the following: 1. Designated exterior location(s) shown on the plans, of sufficient size for outdoor water heating heat pump equipment and with a chase that is sized to accommodate refrigerant lines between the exterior location and the interior location of the water heating equipment. An interior location with a minimum volume the greater of 700 cubic feet (19 822 L) or 7 cubic feet (198 L) per 1,000 Btu/h (293 W) combustion equipment water heating capacity. The interior location shall include the space occupied by the combustion equipment. 2. 3. An interior location with sufficient airflow to exhaust cool air from future water heating heat pump equipment provided by not fewer than one 16-inch (406 mm) by 24-inch (610 mm) grill to a heated space and one 8-inch (203 mm) duct of not more than 10 feet (3048 mm) in length for cool exhaust air. 14 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations 3.4.5.1.1 Dedicated branch circuits for future electric heat pump water heating equipment. Spaces containing combustion equipment for water heating with a capacity of greater than 75,000 Btu/h (21 980 W) shall may be provided with a dedicated branch circuit rated and sized in accordance with Section 8.4.5.2.4 and terminating in a junction box within 3 feet (914 mm) of the location the water heating equipment in a location with ready access . Both ends of the branch circuit shall be labeled “For Future Electric Water Heating Equipment.” Exception: Where future electric water heating equipment would require three-phase power and the main electrical service panel has a reserved space for a bus bar rated and sized in accordance with Section 8.4.5.2.4 and labeled “For Future Electric Water Heating Equipment.” 4.4.5.1.1 Additional water heating electric infrastructure sizing. Electric infrastructure water heating equipment with a capacity of greater than 75,000 Btu/h (21 980 W) shall may be sized to accommodate one of the following: 1. An electrical capacity not less than the combustion equipment water heating capacity multiplied by the value in Table 8.4.5.2 plus electrical capacity to serve recirculating loads as shown in Equation 8.4.5.3.VAw = (Qcapacity x Pw) + [Qrecirc x 293 (VA/(Btu/h))] Equation 8.4.5.3 Where VAw = The required electrical capacity of the electrical infrastructure for water heating in volt-amps Qcapacity = The water heating capacity of the combustion equipment in kBtu/hPw = The VA per kBtu/h from Table 8.4.5.2 in VA/kBtu/h Qrecirc = The capacity required for temperature e maintenance by recirculation, if applicable, in Btu/h 2. An alternate design that complies with this code, is approved by the authority having jurisdiction and uses no energy source other than electricity or on-site renewable energy. 15 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations TABLE 8.4.5.2 ALTERNATE ELECTRIC WATER HEATING EQUIPMENT CONVERSION FACTORS (VA/kBtu/h) 99.6% HEATING DESIGN TEMPERATURE Greater Than (°F) Not Greater Than VA/kBtu/ 55 50 45 40 35 30 25 20 15 10 5 0 60 55 50 45 40 35 30 25 20 15 10 5 Ps h 118 123 129 136 144 152 162 173 185 293 293 293 293 For SI: °C = [(° F) – 32]/1.8, 1 British thermal unit per hour = 0.2931 kW. Less than 0°F Combustion cooking. Spaces containing combustion equipment for cooking shall may comply with Section 3. 1.4.5.1.1 or 8.4.5.3.2. 8.4.5.3.1 Commercial cooking. Spaces containing commercial cooking appliances shall be provided with a dedicated branch circuit with a minimum electrical capacity in accordance with Table 8.4.5.3.1 based on the appliance in the space. The branch circuit shall may terminate within 3 feet (914 mm) of the appliance in a location with ready access . Both ends of the branch circuit shall be labeled with the words “For Future Electric Cooking Equipment” and be electrically isolated. 9.4.5.3.1 All other cooking. Spaces containing all other cooking equipment not designated as commercial cooking appliances shall may be provided with a dedicated branch circuit in compliance with NFPA 70 Section 422.10. The branch circuit shall may terminate within 6 feet (1829 mm) of fossil fuel ranges, cooktops and ovens and be in a location with ready access . Both ends of the 16 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations branch circuit shall may be labeled with the words “For Future Electric Cooking Equipment” and be electrically isolated. TABLE 8.4.5.3.1 COMMERCIAL COOKING MINIMUM BRANCH CIRCUIT CAPACITY COMMERCIAL COOKING APPLIANCE Range MINIMUM BRANCH CIRCUIT CAPACITY 469 VA/kBtu/h Steamer Fryer Oven Griddle 114 VA/kBtu/h 200 VA/kBtu/h 266 VA/kBtu/h 195 VA/kBtu/h 114 VA/kBtu/h All other commercial cooking appliances For SI: 1 British thermal unit per hour = 0.2931 kW. 4. Combustion clothes drying. Spaces containing combustion equipment for clothes drying shall may comply with Section 8.4.5.4.1 or 8.4.5.4.2. 1.4.5.1.1 Commercial drying. Spaces containing clothes drying equipment and end uses for commercial laundry applications shall may be provided with conduit that is continuous between a junction box located within 3 feet (914 mm) of the equipment and an electrical panel. The junction box, conduit and bus bar in the electrical panel shall may be rated and sized to accommodate a branch circuit with sufficient capacity for equivalent electric equipment with equivalent equipment capacity. The electrical junction box and electrical panel shall may have labels stating, “For Future Electric Clothes Drying Equipment.” 2.4.5.1.1 Residential drying. Spaces containing clothes drying equipment, appliances and end uses serving multiple dwelling units or sleeping areas with a capacity less than or equal to 9.2 cubic feet (0.26 m3) shall may be provided with a dedicated 240-volt branch circuit with a minimum capacity of 30 amperes, shall may terminate within 6 feet (1829 mm) of fossil fuel clothes dryers and shall may be in a location with ready access . Both ends of the branch circuit shall may be labeled with the words “For Future Electric Clothes Drying Equipment” and be electrically isolated. 9.4.5 On-site transformers. Enclosed spaces and underground vaults containing onsite electric transformers on the building side of the electric utility meter shall may have sufficient space to accommodate transformers sized to serve the additional electric loads identified in Sections 8.4.5.1, 8.4.5.2, 8.4.5.3 and 8.4.5.4. 17 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations (Residential Code Provisions with PROPOSED Changes Highlighted in Blue) RK101.1 Electric readiness. Water heaters, household clothes dryers and cooking appliances that use fuel gas or liquid fuel shall may comply with Sections RK101.1.1 through RK101.1.4 RK101.1.5. A space that is at least 3 feet (0.91 m) by 3 feet (0.91 m) wide by 7 feet (2.13) high shall may be available surrounding or within 3 feet (0.91 m) of the installed water heater. Exceptions: 1. Installed heat pump water heaters. 2. Installed tankless water heaters on the exterior of the dwelling unit. 3. Water heaters serving multiple dwelling units in a R-2 occupancy. 18 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations 19 International Energy Conservation Code (IECC) Residential - IECC [2024] Comment Attachments  To: Austin Mayor and City Council From: Todd McAlister, Executive Director, South-central Partnership for Energy Efficiency as a Resource Date: July 9, 2024 Re: International Energy Conservation Code 2024 Technical Code Amendments Honorable Mayor Watson and City Council Members, The South-central Partnership for Energy Efficiency as a Resource (SPEER) is the U.S. Department of Energy (DOE) recognized Regional Energy Efficiency Organization supporting energy and building code education, adoption and compliance throughout Texas and Oklahoma. Through this work, SPEER facilitates educational trainings and acts as a resource for local governments and the state as they seek to adopt new energy and building codes. In this capacity, SPEER supports the efforts of the City of Austin to review and consider adoption of the 2024 International Energy Conservation Code (IECC 2024) with amendments. The review, adoption, and enforcement of updated energy codes across the state will enhance efficiency in new buildings, lower energy costs for homeowners, and increase reliability and resiliency to the region’s energy grid. As new technologies flow into the region and the state prepares for a more diverse resource mixture to the wholesale electricity market, it is imperative for cities like Austin to adopt new codes to adequately prepare and receive the added efficiency gains which provide passive survivability and lower bills to the ratepayer. Residential Amendments: Relating to the IECC 2024 Residential Code Amendments outlined by the current proposal, SPEER supports the proposal for adoption with amendments by the City of Austin. The proposal provides consumers with adequate choice in fuel types through requiring electric ready homes, however, stops short of mandating specific fuel type requirements. This change allows for easier adoption of electric vehicles and backup generation for residents while not limiting their options for implementing new measures. Additionally, the changes to the ceiling insulation portions of the code protects residents of Austin from incoming heat transfer from their roofs which will ultimately aid in conserving energy in heating and cooling of homes. Lastly, the updated “pick-a-package” for home appliances will work as a force multiplier for conserving energy and reducing costs for customers. Maintaining an updated home envelope and with new energy efficient appliances will build the city’s resiliency and reliability during peak summer months and extreme weather events year-round. These savings are noted in the Pacific Northwest National Labs reporting on the 2024 IECC suite. The Residential updates will result in increases of 5% energy savings, 7% energy cost savings, and reductions of carbon emissions for the region of 7%. Commercial Amendments: SPEER supports the proposed amendments for the 2024 IECC Commercial Model Codes. Similar to the Residential Model Codes, the Commercial amendments provide electric ready commercial buildings without limiting consumer choice for implementation of measures. Through providing electric ready P.O. Box 1246 n Buda, Texas 78610 n phone: 512-279-0750 n www.eepartnership.org n @EEpartnership buildings, consumers have the opportunity to install their choice of fuel type for backup generation resources, as well as being prepared for increased electric vehicle adoption in the region. Conclusion: SPEER appreciates the opportunity to submit this letter of support for adoption and implementation of the 2024 IECC suite and looks forward to working with the City of Austin for additional amendments and adoption in the future. Sincerely, Todd McAlister Executive Director, SPEER Cc: Randy Plumlee, Codes Program Manager, SPEER Noah Oaks, State and Local Policy Manager, SPEER SPEER Page 2  Eric.Tate@atmosenergy.com July 8, 2024 City of Austin Austin City Hall 301 W. Second St. Austin, TX 78701 Re: Dear City of Austin: Comments on Proposed 2024 Technical Code Amendments Atmos Energy Corporation (“Atmos Energy”) supports fuel-neutral energy codes that are consistent with state and federal law. As proposed, the 2024 Technical Code would adopt provisions of the International Energy Conservation Code (“IECC”) and 2024 IECC appendices that advance the electrification of homes and businesses. Atmos Energy urges the City not to include these provisions in the final 2024 Technical Code. Atmos Energy is the nation’s largest natural-gas-only distributor, serving more than three million natural gas distribution customers in over 1,400 communities in eight states, from the Blue Ridge Mountains in the East to the Rocky Mountains in the West. Included in Atmos Energy’s service territory is the City of Austin, within which Atmos Energy serves approximately 11,000 customers. Atmos Energy’s vision is to be the safest provider of natural gas services and the company is committed to the safety and success of our communities, the environment, delivering a reliable source of energy, and providing exceptional customer service. This vision continues to fuel Atmos Energy’s investment in modernizing its system, which is integrated with our comprehensive environmental strategy focused on reducing the environmental impact from our operations. This strategy includes a robust set of programs that improve consumer energy efficiency within our service territories. Efforts to affordably increase energy efficiency for the broadest number of residents and businesses should be fuel neutral. Currently, the proposed 2024 Technical Code amendments would adopt provisions that favor electrification.1 Before finalizing the amendments, Atmos encourages the City to consider the following— 1. Fuel neutral measures promote efficient appliances and reliable energy. Atmos Energy’s SmartChoice Energy Efficiency Program offers rebates and incentives for businesses and residential customers, including those in the City, who install energy-efficient natural gas 1 Attachment A lists the 2024 IECC provisions the City has proposed to include in the 2024 Technical Code amendments that advance electrification. Atmos Energy Corporation | 5430 LBJ Freeway | 1800 Three Lincoln Centre | Dallas, TX 75240 | 972-855-3756 Office | 972- 855-3080 Fax appliances such as furnaces, tankless water heaters, smart thermostats, and more.2 The efficiency benefits of natural gas appliances are heightened when considering the energy consumed to generate and distribute the resource—transporting natural gas from wellhead to consumer’s meter results in less than 10% of energy lost, compared to a 63% energy loss in transporting electricity from powerplant to consumer home.3 2. Fuel neutrality is the most affordable approach to achieving emission reductions. Costs are a significant factor in a consumer’s decision to replace an appliance in their home, and natural gas appliances are often a more affordable option for improving energy efficiency. For example, in the forecast of the Department of Energy (“DOE”) of the average unit costs of residential energy sources, the DOE found that electricity is 3.3 times more expensive than the equivalent energy through the direct use of natural gas.4 Atmos Energy recommends that the City work with local industry to fully understand the actual cost impacts of imposing the provisions being considered. 3. Whether the codes at issue cost effectively increase energy efficiency is untested. In considering electric-favoring provisions, fuel neutral alternatives were not adequately evaluated as part of the 2024 IECC code development process. For example, the underlying analyses supporting the electric-readiness appendices were flawed and oversimplified—only comparing costs at time of construction versus retrofitting.5 Further, earlier this year, the Board of the International Code Council—the organization responsible for developing the 2024 IECC—found that certain provisions, including some in the 2024 Technical Code amendments, were not consistent with the intended purpose of “providing the minimum efficiency requirements for buildings that result in the maximum level of energy efficiency that is safe, technologically feasible, and life cycle cost effective considering economic feasibility, including potential costs and saving for consumers and building owners, and return on investment.”6 4. The codes at issue do not concern energy conservation. The International Code Council Board evaluated the function of the codes at issue here and found that they do not “concern[] . . . building energy conservation.”7,8 Accordingly, these codes do not accomplish the Technical Code’s foundational purpose of conserving energy use by homes and businesses and should not be included in the final 2024 Technical Code.9 2 Atmos Energy, Mid-Tex SmartChoice Rebates, https://www.atmosenergy.com/ways-to-save/mid-tex-appliance- rebate-program/. 3 Atmos Energy, Natural Living: Natural Gas: The Natural Choice for a Better Home, a Better Environment (Spring/Summer 2024) at 11, https://www.atmosenergy.com/static/6678f502ccd0cdf430497f5b2c934daf/Natural%20Living%20Spring%202024. pdf. 4 Energy Conservation Program for Consumer Products: Representative Average Unit Costs of Energy, 88 Fed. Reg. 58,575, 58,576 (Aug. 28, 2023). 5 Such analysis overlooks the possibility that electric readiness measures may never be fully utilized, as well as the varying timelines on which buildings will begin to utilize their readiness infrastructure. 6 International Code Council, 2024 IECC Appeals: ICC Board of Directors Actions Report, Apr. 11, 2024, at 6. 7 Id. at 10. 8 Also of note, the Board went on to determine that all-electric requirements pose a “significant risk of preemption based on case law” and added “[a] cautionary note regarding the risk of preemption.” Id. at 5 9 See Austin, Texas Code, Section 25-12-261 (entitled “International Energy Conservation Code”) 2 To aid in the City’s review of the proposed 2024 Technical Code amendments, a list of the 2024 IECC provisions that should not be included in the final 2024 Technical Code amendments is attached. Atmos Energy sincerely appreciates the City’s consideration of these comments. Please do not hesitate to reach out to Eric Tate at 469-975-4615 if you have questions or would like to discuss these comments further. Atmos looks forward to continuing to engage with the City on the code amendment process. Sincerely, Eric Tate Manager of Public Affairs Atmos Energy Corporation cc: Austin Energy Green Building Staff * * * 3  Attachment A As explained in Atmos Energy’s comments, we ask that the City omit or make optional the following proposed provisions which directly or indirectly preference electrification: Residential:  Section R408: Additional Efficiency Requirements  Appendix RB: Solar-Ready Provisions – Detached One- And Two-Family Dwellings and Townhouses  Appendix RE: Electric Vehicle Charging Infrastructure  Appendix RK: Electric Readiness 4 SWTCH Energy Inc. Greentown Labs 444 Somerville Ave Somerville, MA 02143 swtchenergy.com July 8, 2024 Austin City Council 301 W. Second St. Austin, Texas 78701 Re: SWTCH Comments on Proposed Electric Vehicle Readiness 2024 Technical Amendments - Residential Dear City of Austin Council Members, Development Services Department Staff, and Austin Energy Green Building Staff: SWTCH respectfully submits these comments on the proposed Electric Vehicle Readiness 2024 Technical Code Amendments to the City of Austin Model Residential Code. SWTCH is pleased to strongly support the proposed amendments to adopt the 2024 International Energy Conservation Code (IECC) Appendix code provisions on electric vehicle (EV) readiness. SWTCH applauds Austin’s commitment to transportation decarbonization and equitable access to EV charging. SWTCH has included any referenced sections from the 2024 IECC Appendix code provisions on page 3 of these comments. About SWTCH SWTCH is a leading provider of electric vehicle (EV) charging and energy management solutions for multifamily, commercial, and workplace properties in Texas and across North America. Our end-to-end solution optimizes EV charging usage and manages load to benefit drivers, property owners, and the grid. SWTCH has deployed more than 15,000 chargers across North America, with a strong focus on equitable access. SWTCH’s charging management platform is built upon a foundation of open communication standards and interoperability to prevent stranded assets and to ensure future flexibility, scalability, and innovation. SWTCH has actively participated in the 2024 IECC code development process, as well as other state and municipal EV readiness code cycles. Comments Residential Code Proposal SWTCH is a strong proponent of the EV-capable, EV-ready, and EVSE requirements for homes (one- and two- family dwellings, townhouses) and multifamily buildings (R-2 occupancies). In SWTCH’s experience working with Austin property owners, building managers, and new construction developers, the 2024 IECC Appendix code sets cost-effective and flexible EV readiness standards, especially for R-2 occupancies. These standards ensure buildings are future-proofed for current and future residents to access at-home EV charging solutions the same as single-family homes. Additionally, SWTCH is a strong advocate for 2024 IECC Appendix code provisions for EV charging load management. Section R404.7.4.4 sets appropriate minimum capacity standards per EVSE space, with options for EVSE spaces controlled by an EV energy 1 management system (EVEMS). These standards promote a 4:1 circuit sharing ratio1 when using EVEMS. SWTCH supports this circuit ratio for multifamily building use cases, in which higher ratios reduce power output and charging speeds beyond what is a positive user experience and lower ratios prevent buildings from realizing the full potential and value of EVEMS. Moreover, Section R404.7.5 sets forth electrical system capacity requirements that align with NFPA 70, National Electrical Code (NEC), a widely accepted standard that addresses installation of EVEMS. This section right sizes infrastructure for electrical load served to EV-capable, EV-ready, and EVSE that allows for properties to leverage EVEMS. In Closing SWTCH applauds the steps that the City of Austin Development Services Department and Austin Energy Green Building are taking to advance EV Readiness. We look forward to working with the City Council and other stakeholders to move forward formal adoption of IECC 2024 EV Readiness provisions into Austin’s residential model building code. Additionally, we recommend revisiting this code in 1-2 years to (a) understand the impact of removing parking minimum requirements for new developments, and (b) ensure sufficient EV charging is available for occupants at new buildings. SWTCH is also supportive of aligning code reviews with IECC code updates. We appreciate the opportunity to comment on these matters, and if you have questions or if I can provide more information, please contact me at ben.brint@swtchenergy.com or 415.535.8444. Respectfully, Ben Brint Policy Manager SWTCH Energy Inc. 1 Based on 40-ampere circuit, 30-ampere EV charger, 208/240V minimum capacity 2 IECC 2024 Residential EV Readiness Code Provisions 3  1 Tesla Road, Austin, TX 78725 P 650 681 5100 F 650 681 5101 July 8, 2024 Attention: Public Comments RE: Tesla Comments on City of Austin Residential and Commercial Electric Vehicle Readiness proposals of the 2024 International Energy Conversation Code (IECC) Dear Austin Energy Green Building Staff, Tesla1 appreciates the opportunity to comment on Austin Energy’s Residential and Commercial Electric Vehicle Readiness proposals of the 2024 International Energy Conversation Code (IECC). We applaud the City’s leadership in pushing forward the energy code in a timely manner. Although many cities and states have adopted energy codes, only a handful have been proactive in adopting, updating, and enforcing the most up-to-date codes. Energy codes ensure that a building's energy use is included as a fundamental part of the design and construction process of new buildings; making an early investment in building energy improvements will pay dividends to Austin residents for years into the future. We offer the following comments on the 2024 IECC Electric Vehicle Readiness proposals for both commercial and residential buildings. 1. We support the residential electric vehicle readiness proposal for one-and two- family dwellings, townhomes, and R-2 occupancies. The residential proposal derived from Appendix RE of the 2024 IECC Residential code requires that new one- and two-family dwellings and townhouses with designated parking provide one EV capable, EV ready, or EVSE space per dwelling unit. Multifamily buildings with four stories or less must provide an EV capable space, EV ready space, or EVSE space for 40 percent of dwelling units or automobile parking spaces, whichever is less. These requirements give building owners flexibility in establishing the level of EV readiness that will fit their current and future needs, while still providing the necessary minimum EV charging load that the distribution system needs to be sized for. Moreover, the language in Appendix RE was developed as a consensus proposal during the IECC code development process with input from a diverse group of stakeholders including representatives from the home builders, electrical manufacturers, EV charging providers, and utilities. It went through several rounds of public comment and editorial changes to ensure 1 Tesla’s mission is to accelerate the world’s transition to sustainable energy. To accomplish its mission, Tesla designs, develops, manufactures, and sells high-performance fully electric vehicles and energy generation and storage systems, installs, and maintains such systems, and sells solar electricity. Tesla also owns and operates an extensive EV charging network across the U.S. including stations in Austin. At Gigafactory Texas in Austin, TX, Tesla produces the Model Y crossover, and Cybertruck and manufactures Tesla’s new, advanced 4680 lithium-ion battery cell, cathode, and battery packs. Upon completion, Gigafactory Texas will invest over $10B in factory development and create at least 10,000 new jobs. 1 Tesla Road, Austin, TX 78725 P 650 681 5100 F 650 681 5101 clarity, consistency, enforceability, and technical soundness. Adopting Appendix RE outright would help staff streamline and quicken the public input process given that the language has already been thoroughly vetted. 2. We strongly recommend increasing EV-ready requirements and including EVSE- installed spaces for certain commercial occupancy types We are concerned that the omission of EV-ready and EVSE-installed spaces in Table CG101.2.1 from all commercial occupancy types expect Groups R-1 and R-2 will result in an under-investment in necessary charging infrastructure to support current and future EV drivers in Austin. The current proposal heavily stacks EV-capable requirements across nearly all commercial building types, which puts the burden on building owners, EV drivers, or tenants to have an outlet or EVSE wired and installed at their parking space. While an EV capable space requires panel capacity, a dedicated circuit and raceway, it does not include a way for someone to drive up to a parking spot and plug in and charge. In particular, this barrier presents a significant obstacle to installing EV infrastructure at multi-family dwellings, which have proven to be the most challenging sector to deploy EV infrastructure. Unlike residents of single-family homes, multi-family tenants are commonly renters without the authority to retrofit parking spaces to install charging equipment. When retrofitting to provide EV charging is possible, tenants and owners can face costs of 4-6 times higher than if done during new construction2. The ability to charge an EV overnight is additionally important for multifamily tenants who are rural, low-income, and in disadvantaged communities, who typically have longer commutes and drive older EVs with shorter ranges. Several cities and counties across the country have included ambitious EVSE-installed and EV- ready requirements for commercial building types, including Scottsdale, Tucson, Coral Gables, St. Petersburgh, St. Louis County, Charlotte, Columbus, Orlando, Chicago, Seattle, and many others. We recommend that Austin match or exceed the ambition of its peer cities and adopt EV-ready and EVSE-installed requirements for new commercial buildings. Tesla proposes revisions to Table CG101.2.1 in the Appendix 1. 3. We recommend including a Direct Current Fast Charging (DCFC) compliance pathway that provides new commercial buildings the option to meet compliance with charging that mirrors dwell times. Depending on the type of nonresidential building and the typical dwell time a vehicle is parked, a higher power level for charging beyond a standard Level 2 charger may be most beneficial. A DCFC compliance pathway would allow new non-residential buildings the option to meet EV- capable and EVSE compliance either through Level 2 or DCFC. For example, commercial buildings with short dwell times, such as grocery stores, would have the ability to use a DCFC compliance ratio of 5:1 EVSE installed if minimum requirements are met and at least one Level 2 EVSE is installed. A DCFC compliance option is important as it provides building owners with the incentive to go beyond minimum EVSE requirements and the optionality to install the level of EV charging, either Level 2 or DCFC, that best fits customer needs. This optionality also results 2 https://caletc.aodesignsolutions.com/assets/files/CALGreen-2019-Supplement-Cost-Analysis-Final-1.pdf  1 Tesla Road, Austin, TX 78725 P 650 681 5100 F 650 681 5101 in a more efficient use of state and private infrastructure investment given more optimal charging station usage. Tesla proposes recommended language in the attached Appendix 2. ***  Tesla appreciates the opportunity to provide feedback on 2024 IECC Electric Vehicle Readiness proposals for both commercial and residential buildings. We look forward to continued work with the City of Austin on its transportation electrification efforts. Thank you for the opportunity to submit these comments. .   Sincerely,     Tessa Sanchez Senior Policy Advisor Business Development and Public Policy   Tesla, Inc.      1 Tesla Road, Austin, TX 78725 P 650 681 5100 F 650 681 5101 APPENDIX 1 Language to be added is underlined. Language to be removed is struck. TABLE C405.14.1 REQUIRED EV POWER TRANSFER INFRASTRUCTURE Occupancy Group A Group B Group E Group F Group H Group I Group M Group R-1 Group R-2 Group R-3 and R-4 Group S exclusive of parking garages Group S-2 parking garages EVSE Spaces 5% 0% 5% 0% 5% 0% 2% 0% 1% 0% 5% 0% 5% 0% 10% 0% 10% 0% 0% 0% EV Ready Spaces 5% 0% 10% 0% 10% 0% 0% 0% 10% 0% 10% 0% 5% 5% 0% 0% EV Capable Spaces 10% 30% 30% 5% 0% 30% 30% 35% 35% 5% 0% 5% 0% 10% 0% 30%  1 Tesla Road, Austin, TX 78725 P 650 681 5100 F 650 681 5101 APPENDIX 2 Language to be added is underlined. Language to be removed is struck. CG101.2.1 Quantity. The number of required electric vehicle (EV) spaces, EV capable spaces and EV ready spaces shall be determined in accordance with this section and Table CG101.2.1 based on the total number of automobile parking spaces and shall be rounded up to the nearest whole number. For R-2 buildings, the Table CG101.2.1 requirements shall be based on the total number of dwelling units or the total number of automobile parking spaces, whichever is less. 1. Where more than one parking facility is provided on a building site, the number of required automobile parking spaces required to have EV power transfer infrastructure shall be calculated separately for each parking facility. 3. 2. Where one shared parking facility serves multiple building occupancies, the required number of spaces shall be determined proportionally based on the floor area of each building occupancy. Installed electric vehicle supply equipment installed spaces (EVSE spaces) that exceed the minimum requirements of this section may be used to meet the minimum requirements for EV ready spaces and EV capable spaces. Installed EV ready spaces that exceed the minimum requirements of this section may be used to meet the minimum requirements for EV capable spaces. 4. 5. Where the number of EV ready spaces allocated for R-2 occupancies is equal to the number of dwelling units or to the number of automobile parking spaces allocated to R-2 occupancies, whichever is less, requirements for EVSE spaces for R-2 occupancies shall not apply. 6. Requirements for a Group S-2 parking garage shall be determined by the occupancies served by that parking garage. Where new automobile spaces do not serve specific occupancies, the values for Group S-2 parking garage in Table CG101.2.1 shall be used. 7. Group S-2 parking garages with no less than 50% long term parking spaces shall provide no less than 10% EV capable spaces. Long term parking spaces are considered as parking spaces where users generally park for more than 8 hours at a time, including overnight, at places such as airports, transit hubs, etc. 8. The installation of Direct Current Fast Charging (DCFC) EVSE shall be permitted to reduce the minimum number of required EV capable or EV ready spaces without EVSE or EVCS with Level 2 EVSE by five and reduce proportionally the required electrical load capacity to the service panel or subpanel.  1301 S. Mopac Expressway Suite 400 Austin, TX 78746 jason.ketchum@onegas.com Phone: 918.282.8522 July 8th, 2024 Submitted via SpeakUp Austin and via email to: energcode@austinenergy.com Austin Energy Green Building Program 4815 Mueller Blvd. Austin, TX 78723 Re: Texas Gas Service Company’s Comments on City of Austin’s Proposed Adoption of Certain 2024 IECC Building Codes Austin Energy Staff and City of Austin Department of Development Services: Texas Gas Service Company, a division of ONE Gas, Inc. (“Texas Gas Service”) proudly provides over 235,000 customers inside the City of Austin (“City) and another 40,000 customers in the Austin Metro area with affordable, reliable and clean natural gas service. We are excited to work with the City and industry stakeholders in the development of a fuel neutral energy code, designed to achieve building energy conservation while maintaining building safety, energy affordability, and energy reliability and resilience within both the commercial and residential sectors. As a stakeholder, Texas Gas Service appreciates the City’s willingness to grant the public time to review the proposed inclusion of all (or only parts) of the 2024 IECC (International Energy Conservation Code) within the City of Austin’s building codes. Because the affordability of housing in the Austin area is important to current and potential residents,1 and the adoption of certain portions of the latest energy codes will likely increase the prices of new homes, these adoption proceedings are important. As such, Texas Gas Service strongly supports the City of Austin’s decision to organize public hearing(s) and to provide the opportunity for public comment surrounding any recommendations for adoption prior to taking final action. In 2024, ONE Gas, Inc. (“ONE Gas”), Texas Gas Service’s parent company received a rating of AAA (on a scale of AAA to CCC) in the MSCI ESG Ratings assessment. ONE Gas, also holds a “Prime” corporate rating in ESG from Institutional Shareholder Services (ISS) and is a member of See 1 , data.austiontexas.gov, “Percentage of Households Paying More Than 30 Percent (and more than 50 percent) of Income Toward Housing,” ttps://data.austintexas.gov/stories/s/EOA-C-1-Percentage-of- households-paying-more-than-/tevy-4u2b/; see also, The Texas Tribune, “Austin Will Try Again to Tame its Housing Affordability Crisis with Zoning Reforms. Can It Do It This Time?" September 19, 2023. July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations ONE Future, a coalition of companies across the natural gas value chain that are committed to keeping emissions intensity below 1%, a goal the coalition has beaten every year ONE Gas has been a participant. Further, natural gas has proven to be affordable, reliable and a clean energy source which works in tandem with the electrical grid. In support of our customers and our environment, Texas Gas Service offers a robust energy efficiency program throughout the State of Texas. Texas Gas Service was one of the first natural gas utility companies in the country to offer rebates for high efficiency appliances in Austin and have done so for 30 years. In the Central Texas Region alone, during 2023 and up until May 2024, TGS has provided over $750,000 in rebates to residential and commercial customers, including builders, for the installation and purchase of various high efficiency natural gas appliances, as well as weatherization strategies to improve building efficiency and reduce emissions. In 2023, our energy efficiency program avoided 44,400 metric tons of CO2e, which is equivalent to removing over 10,000 passenger vehicles off the road. The availability of natural gas for end-use in commercial and residential buildings is vital to the City of Austin’s ability to put forth a viable energy portfolio. As proven on numerous occasions over the past few years, natural gas is a critical component to a comprehensive energy plan. Because our infrastructure is located primarily below ground, our natural gas system has a 99% reliability rating. During Winter Storm Uri, (and the subsequent ice storms) we kept the gas flowing to provide life-saving services to our customers. During URI, service was interrupted to only 300 of our more than 690,000 customers that we serve throughout the state of Texas, and most of these outages lasted less than 24 hours. It is important to us that our customers continue to have access to safe and reliable natural gas in both good and difficult circumstances. And so, ONE Gas and members of each of its divisions (including Texas Gas Service) monitored and participated (both on its own and where possible in collaboration with others), in the IECC’s process of drafting, reviewing and adoption of the 2024 IECC codes. Along the way, we and other collaborators with interests tied to the Austin community have worked diligently to provide relevant input on a variety of issues raised during the IECC’s code adoption process. As can be expected some of our recommendations were considered while others went unacknowledged and unheard. However, we recognize that local government is more likely to have the ability recognize and to consider the real impacts that certain actions may have on its residents, industry and community. It is with this understanding that we are highlighting certain important issues that may have negative impacts on our customers ability to make reasonable and affordable choices related to building construction, the appliances they may desire and their ability to choose safe and reliable energy to warm their homes or businesses and/or to operate their appliances. We respectfully request your careful and thoughtful consideration of our recommendations below. Additionally, we are attaching, in Appendix I, proposed code language, that if adopted would implement building energy conservation measures in an equitable, affordable, and reliable manner for all Austinites. 2 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations Summary of Recommendations: • Electric Readiness – Sections 8.4.5 and RK101: This portion of the code is intended to prepare such buildings for electrification if and when fossil fuels are no longer a permissible or viable, cost-effective option. However, requirements for “electric readiness” for residential and commercial buildings were not properly justified in the IECC drafting process and as a result, led to these proposed requirements being relegated by the IECC committee as guidance material only and placed in an appendix of the 2024 IECC.2 Based on the lack of confidence in the justification and general uncertainty surrounding this proposed code, we recommend that the City of Austin reject the promulgation of this portion of the 2024 IECC appendix as requirements in the City of Austin energy code. Instead, should the City find some value in this proposed section, we encourage the City to revise the code language to align more closely with the manner of adoption by the 2024 IECC, which made the use of the information as non- mandatory guidance only for builders, building operators, and homeowners. • Partnership with Interested Parties: We strongly encourage the City of Austin to take steps to invite and build a close partnership with the local home builder associations to afford ready opportunities to understand the true cost implications of electric-ready code provisions that may be imposed upon Austinites, builders, and building operators, should the City choose to enforce or the building owner opt to pay for such electric-readiness preparations. Until true costs are determined, we recommend the City delay its final decision on this proposed code provision, given the importance of making sure there is an adequate supply of affordable new housing for all. Austin housing costs for both new homes and rental properties continue to climb, shutting out many potential new and low-income community home buyers and renters. The City of Austin needs to integrate housing affordability considerations in its consideration of 2024 IECC code adoption, looking at both the impact upon housing costs of construction and affordability directly affected by 2024 IECC and code amendment provisions. • Section R408 “additional energy credits” and Table R408.2: Publication of the revised Section R408 was done without broad stakeholder consensus concerning justification of the credit values, or the development of sound definitions of technology categories used for Table R408.2 credit assignments. Further, we are also raising a concern regarding the level of consideration given to the issues of relative site energy, full fuel cycle energy, and emissions reductions, and to the quantitative basis for numerical credit values across envelope and mechanical system options. among technology options for specific fuels and end uses, or between competing electric and gas options for residential buildings. We encourage the City of Austin to withhold adoption of this section until it has had an opportunity to independently review and justify these credit assignments from its adoption of the Table R408.2 credits as published to address the lack of technical consensus and justification during the 2024 IECC deliberations, with a specific focus on climate and emissions factors relevant to City of Austin energy supply alternatives foreseeable over the current IECC code cycle. 2 https://www.iccsafe.org/products-and-services/i-codes/code-development/2024-iecc-appeals/ 3 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations In addition, the “additional energy credits” in Table R408.2, presume a federal minimum energy efficiency for non-weatherized residential natural gas central furnaces of 95% AFUE and base additional credits on this minimum energy efficiency as a baseline. However, the federal minimum efficiency standard of 95% AFUE is under challenge in lawsuits filed by the American Gas Association (AGA) and other petitioners3 and as a result cannot simply be presumed as the baseline for Table R408.2 credits. If the AGA, et. al. petitions are successful, the federal minimum efficiency for non-weatherized residential natural gas central furnaces would remain at 80% AFUE, and “additional energy credits” available in Table R408.2 would have to be adjusted to account for the 80% AFUE baseline. Texas Gas Service recommends that the City of Austin revise its proposal for “additional energy credits” to recognize efficiency improvements over the current 80% baseline. This should begin at 90% AFUE for incentivizing installation of Category IV natural gas furnaces (i.e., condensing combustion, positive venting pressure) as a first tier of “additional energy credits” as available, to builders for both singularly credited measures and in combination with other measures such as installation of high efficiency air conditioning as currently offered in Table R408.2. We recommend this revision be made applicable at least until a court order is issued. • Texas Utility Code §181.903 (Texas 2021 HB 17) – Restriction on Regulation of Utility Services and Infrastructure: In 2021, the Texas Legislature took steps by adopting HB 17 (now codified as Tex. Util. Code § 181.903) to protect builders and property owners from facing the negative impacts of regulation that either encourages or discourages the installation of certain utility facilities based on energy type. To avoid potential conflict with this recent state law, we strongly encourage the city to conduct a comprehensive and thorough legal review of the proposed new codes in light of the legislative intent to ensure preservation of fuel choice for commercial and residential customers. For a more detailed discussion and support of our positions as summarized points above, please see “Texas Gas Service Attachment A” as attached hereto. Again, we appreciate the opportunity to meaningfully participate in the City’s process of reviewing the 2024 IECC code provisions for consideration of adoption and implementation by the City. We stand ready to provide additional details or to respond to questions on this subject upon the City’s request. Sincerely, Jason Ketchum VP Commercial 3 AGA, et al., v. DOE, D.C. Cir. Nos. 22-1030 and 23-1337. 4 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations TEXAS GAS SERVICE – ATTACHMENT A Discussion of Recommendations 2024 IECC and Electric-Readiness Provisions (Sections 8.4.5 and RK101.1) As proposed, the City of Austin’s draft technical code language requires infrastructure for water heaters, clothes dryers, and cooking appliances that utilize fuel gas or liquid fuel, to also include installation of a dedicated 240-volt branch circuit outlet to be installed within 3 feet of each appliance specified above. During the 2024 IECC appeals process and final decision-making period, the ICC Board of Directors specifically recognized that the ‘electric-ready’ code provisions (and other associated requirements) did not comport with traditional “Scope” and “Intent” of the IECC. As a compromise, the Board agreed to place the problematic language into appendices based upon the Board’s understanding that such coverages could not be justified as IECC requirements, which represent minimum energy conservation requirements. (emphasis added.) Texas Gas Service’s concern with the ‘electric-ready’ code provisions is that the economic analysis presented within the IECC code process was fundamentally flawed by the reliance on the presumption as a matter of course, that replacement of gas appliances with electric alternatives will take place in 100% of occupancies. The cost comparison used to support the presumption was restricted to the incorporation of electric infrastructure at the time of construction versus the possibility of future retrofit installation of electric infrastructure. The presumption did not allow for consideration of the facts that: (1) replacement of gas appliances with electric alternatives will not occur in all occupancies; and, (2) policies that would require such replacement in all cases, would run counter to cautions expressed by the ICC Board that could be challenged on federal preemption of EPCA covered products, discuss later in these comments. Additionally, any replacement not so mandated would need to be accounted for in actuarial predictions of gas appliance retirements. None of these considerations were taken into account in the development phase of the ‘electric ready’ provisions, now residing in IECC’s Appendix RK. The City of Austin, in their code changes summary, specifically states that electric-readiness code provisions are adopted to align with their Climate Equity Plan. According to the plan, the city will achieve energy efficient, net-zero carbon buildings with “equity principles” in mind to ensure that impacts to low-income communities and communities of color are fully understood and taken into consideration.4 Texas Gas Service stands with the City in its pursuit of a reduction in green house gas (“GHG”) emissions, in an equitable manner. However, we believe that it necessary to work toward achieving such a goal through a fuel agnostic approach to the adoption of the 2024 IECC. We also believe that natural gas emissions reduction strategies must be developed and deployed in a fair and equitable manner. Further, Texas Gas Service also believes that such emission reduction strategies should be achieved with consideration of economic justice for all Austinites. Austin Climate Equity Plan https://www.austintexas.gov/sites/default/files/files/Sustainability/Climate%20Equity%20Plan/Clima te%20Equity%20Plan%20Full%20Document__FINAL.pdf 5 4 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations We define economic justice to encompass three primary pillars: affordability, energy choice, and energy access. Like environmental justice, economic justice is the fair treatment of all people, regardless of income level, with respect to the City’s enforcement of energy regulation, or in this case, the development, adoption and enforcement of building codes. Language within the Climate Equity Plan specifically provides that such strategies designed to reduce natural gas emissions “may include but are not limited to” use of renewable natural gas and expansion of energy efficiency programs, and other “new technologies and programs.”5 However, if the proposed electric-readiness language is adopted as a requirement for new residential and commercial buildings, the ability for the City to utilize new technologies and programs to reduce natural gas emissions will no longer be an option because electric-readiness language is adopted upon the premise that electrification of the building sector will indeed occur and natural gas end- use will no longer be a viable option. By requiring placement of a branch circuit to include labels such as “for future electric clothes drying equipment”, the City is indirectly banning natural gas by requiring use of electric appliances. TGS is concerned that if such language is finalized and adopted, a dangerous precedent will occur by limiting the City and its residents to one single energy source - electricity. An equal important concern is that adoption of this strategy would also be contrary to the legislative intent expressed in Texas 2021 HB 17 (Tex. Util. Code § 181.903). In support of the legitimacy of our concern, during the May 30th, 2024, in-person code engagement meeting, Austin Energy staff stated that the reason for electric-readiness language adoption is to prevent the higher cost of electrifying the residential and commercial building sectors in the future. They also stated that the driver behind electric-readiness is to “allow these projects to have a choice when the homeowner decides in the future to replace that equipment, they can have an option of what fuel source to use.” We found this reasoning confusing as today, homeowners already have a choice to choose electric appliances as well as natural gas appliances. There is nothing now that prevents Austinites from choosing electric appliances. In addition, Austin Energy staff stated that electric-readiness provisions are drafted for adoption “based off of the equipment we have now” not on potential future additions which is contrary to the actual intent of the ‘electric ready’ provisions.6 Before the City moves forward with any serious considerations for the adoption of the proposed ‘electric ready’ provisions, we ask that the City encourage staff to further explain what equipment is available now that wouldn’t be available to consumers but for an adoption of the proposed code requirements. Electric-Readiness Cost Concerns According to the Pacific Northwest National Laboratory (PNNL), the entity that conducts the energy savings calculations of the newest IECC provisions, ‘electric readiness’ provisions are simply a measure in place in case natural gas is no longer a viable option. Specifically, the lab states that electric-readiness codes prevent homeowners from incurring “future costs should fossil https://www.austintexas.gov/sites/default/files/files/Sustainability/Climate%20Equity%20Plan/Clima te%20Equity%20Plan%20Full%20Document__FINAL.pdf, pg. (50, 94) 6 Technical Code Amendments In-Person Document, https://publicinput.com/g4245?lang=en 6 5 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations fuels become less affordable or even unavailable over the life of the building.” 7 PNNL also states that electric readiness codes will help “improve the cost effectiveness of electrification in the future,” not in the present. Again, these statements are based on an assumption that such required additional electrical infrastructure will be used and useful to consumers in a timely manner. In the City’s proposal for adoption of the ‘electric ready’ provisions, it has not provided a definition of “future” in a manner to permit the City the ability to consider the costs against any ‘future’ benefits of the proposed adoption. Also, in addition to PNNL analysis, the New Building Institute (NBI), another stakeholder in the 2024 IECC process and strong proponent of electric-readiness code language, stated that the cost of electrical panel upgrades and associated electric-readiness infrastructure for a new build “is equivalent to the expense of upgrading to an average stone kitchen countertop,” or between $1,000- $1,800.8 This analysis assumes that the average homeowner can afford the cost equivalent of upgrading to a kitchen countertop and that they will in fact reap the “thousands of dollars” saved from using such infrastructure. Finally, in 2021, Home Innovation Research Labs published cost analyses conducted for the National Association of Home Builders for four major U. S. cities comparing gas equipped houses to all electric houses.9 For new home construction in Houston, Texas (the metropolitan area closest to Austin), the study showed that costs of electrification (including costs of appliances for cooking, clothes drying, space heating (and cooling), and service water heating) averaged $24,282 more than the average baseline gas house . This total cost, while not specific to electric-ready equipment, addresses appliance costs, and illustrates two impacts. First, the increased cost of going all-electric in an average home is, on its own, an inducement not to later switch or add new fuels and to instead, make use of the already installed electric-ready infrastructure. This burden will force builders and owners to forgo consideration of the benefits of alternative fuel sources in favor of avoiding stranding the costs of that alternative infrastructure as a direct result of the mandated code compliance. Second, the added total cost to residential construction is likely to negatively impact economically disadvantaged and first-time home buyers by escalating home prices generally. Of course, these costs do not capture direct costs of electric-ready provisions such as branch circuits and panel upgrades. However, the U. S. Energy Star program estimates that panel upgrades for new builds (compared to that of standard systems) may add $1,000 to $2,500 and branch circuit costs of $300 to $1,000 per end use appliance with higher costs, where runs of circuits increase in length and increasing numbers of wall penetrations.10 In cases where these added expenses become 7 8 https://newbuildings.org/wp-content/uploads/2022/04/BuildingDecarbCostStudy.pdf https://www.pnnl.gov/main/publications/external/technical_reports/PNNL-32183.pdf 9 Home Innovation Research Labs, “Cost and Other Implications of Electrification Policies on Residential Construction,” prepared for National Association of Home Builders, February 2021. 10 U. S. Energy Star, “Make Your Home Electric Ready:” https://www.energystar.gov/products/energy_star_home_upgrade/make_your_home_electric_ready 7 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations stranded costs in particular, the added cost to home construction would represent a decidedly negative impact on consumer resources and financing capacity. Conflict with Chapter 181, Section 181.903 of the Utilities Code Texas Gas Service believes that draft language regarding electric-readiness codes for both commercial and residential end-uses may be in direct violation of Tex. Util. Code § 181.903 (Texas 2021 HB 17), which was signed into law on May 18th, 2021. The law specifically states that no regulatory or planning authorities, or political subdivision “may adopt or enforce an ordinance, resolution, regulation, code, order, policy, or other measure that has the purpose, intent, or effect of directly or indirectly banning, limiting, restricting, discriminating against, or prohibiting the connection or reconnection of a utility service or the construction, maintenance, or installation of residential, commercial, or other public or private infrastructure for a utility service based on the type or source of energy to be delivered to the end-use customer.”11 As discussed above, the electric-ready code provisions for commercial and residential buildings have a purpose and intent to indirectly ban, limit, and discriminate against natural gas end-use. The provisions serve to prohibit the connection of a utility service based on the type of energy source, in this case, natural gas, and to prevent it from being delivered to the end-use customer in the future. By requiring installation of branch circuits with labels that state ‘for future electric appliance,’ next to natural gas appliances, and by specifically targeting those buildings that operate natural gas appliances, the City would be prohibiting fuel choice. Due to our stated concerns, we strongly encourage a comprehensive and thorough legal review of state law to ensure that fuel choice for commercial and residential customers is preserved as intended under Texas law. 11 See, Tex. Util. Code § 181.903(b)( May 18, 2021). 8 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations Additional Considerations for Deliberation by City of Austin: A. Recent Electricity Cost and Reliability Projections Austin Energy provides valuable electricity services via various renewable resources such as solar, wind, and biomass. Because these resources are dependent upon weather patterns, which are drastically changing due to climate change, additional fuel resources like nonrenewables and natural gas distribution services are critical to meeting the ongoing (and increasing) high demand for electricity. Growing electricity demand from residential and commercial customers, increasing use of AI, and a transition away from fossil fuels is pushing the US electric grid to the brink, according to McKinsey & Company, the Federal Energy Regulatory Commission (FERC) and multiple news outlets.12 In FERC’s May 2024 summer energy market and reliability report, it explained that U.S. electric demand is expected to increase 2.7% this summer to 1,487 TWh compared to last summer. Similarly, U.S. data center load is expected to grow to nearly 21 GW this year, up from 19 GW in 2023, FERC staff said in the report. Electric demand from such facilities across the U.S. is expected to climb to 35 GW by the end of this decade, according to the report.13 A report released in June 2024, by the National Energy Assistance Directors Association (NEADA) and the Center for Climate and Energy Poverty shows increases in the US electricity bill average since 2014. Specifically, for the Southwest Region of the US, (which includes Texas), consumers can expect an average electricity bill to be upwards of $858 during the cooling season from June - September 2024. This burden weighs heaviest on low-income consumers. According to the report, the high costs are exacerbated by extreme heat events caused by climate change. The report recommends policy alternatives that are inclusive of low-income communities, such as weatherization assistance and installation of heat pumps. However, the heat pump recommendation does not take into consideration the impacts of climate zone differentiation and may not be suitable for the Southwest Region. Nonetheless, Texas Gas Service provides weatherization assistance throughout the Central Texas Region as well as rebates to make high efficiency natural gas appliances affordable for low-income customers.14 This report provides a snapshot into the importance of a fuel agnostic approach to energy usage via all policy avenues, including building code development. In addition to the NEADA report, the North American Electric Reliability Corporation (NERC) predicts a “potential for insufficient operating reserves” for ERCOT this summer if demand is at its highest. The report specifically states that although solar PV is added at a rate outpacing demand, energy risks are growing when solar output is at its lowest. Transmission permitting and development delays also contribute to this energy risk concern for ERCOT. Natural gas end-use https://www.washingtonpost.com/business/2024/05/13/power-grid-transmission-lines-electricity/ https://www.mckinsey.com/industries/technology-media-and-telecommunications/our- insights/investing-in-the-rising-data-center-economy 13 https://www.ferc.gov/news-events/news/report-2024-summer-energy-market-and-electric- reliability-assessment 14 https://neada.org/wp-content/uploads/2024/06/2024summeroutlook.pdf 9 12 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations offers certainty when the electric grid is not able to perform at its highest and meet the demand of the growing Texas population.15 B. The Berkeley Gas Ban and Court Challenges to State and Local Codes Disproportionately Affecting Fuel Gas Installation. Earlier this year, the City of Berkeley, California, repealed their ban on natural gas end-use in new residential and commercial buildings after the Ninth Circuit Court of Appeals ruled that such a ban was in violation of the Energy Policy and Conservation Act (EPCA). The ruling states that EPCA preempts state regulation or building code from regulating the efficiency of natural gas appliances; instead, the US Department of Energy oversees this concern. Many stakeholders including the California Restaurant Association and builders, were in opposition to a direct ban on natural gas end-use. As a result of the decision, other cities throughout California have repealed their bans on natural gas end-use. Although the City of Austin’s proposed energy code is not a direct ban on natural gas use in new residential and commercial buildings, the premise of electric-readiness code language is to prepare for a future for electrifying buildings and a hypothetical world without natural gas end-use, all of which is to be paid for by customers who may or may not want to discontinue their use of natural gas appliances. C. Legal Interpretation of Federal Preemption Risks Forewarned by 2024 IECC Cautionary Notices of Appendix Adoptions as Requirements As several appendices of the 2024 IECC note the potential for federal preemption issues with the use of appendix material as requirements, ONE Gas recognizes that all requirements that set criteria for EPCA “cover product” federal minimum efficiency standards other than the promulgated minimum efficiency standard subject the City of Austin to these risks if adopted as building requirements. Based upon court cases involving the EPCA statute and its prohibition of federal minimum efficiency standards, these risks are not manifest just for incidents where a local jurisdiction is setting conflicting minimum standard and can include energy efficiency programs that create biases against such minimum efficiency standard “covered products.” 16 As discussed for Table R408.2 above, ONE Gas strongly recommends that the City conduct a review of 2024 IECC requirements for “covered products” and determine whether or not such adoption of the proposed electric ready provisions would impose a risk of the City of violating federal preemption prohibitions. Although in its comments to the 2024 IECC, ONE Gas recommended that ICC conduct its own legal analysis of potential conflicts and associated risks for the benefit of potential adopting jurisdictions, the ICC Board, in recommending advisory language in appendix material covering this issue “punted” the consideration of the issue of potential risks to local jurisdictions to assess. 15 October 3, 2008. 16 Air Conditioning, Heating and Refrigeration Institute v. City of Albuquerque, Docket No. 08-633 MV/RLP, https://www.nerc.com/pa/RAPA/ra/Reliability%20Assessments%20DL/NERC_SRA_2024.pdf 10 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations D. Impacts of Additional Electricity Demand Upon Carbon Emissions Under Scenarios of Grid Makeup. The City of Austin neither provides nor documents usage of any impact analysis covering expanded electricity demand that might arise as a consequence of electric-ready provisions in the code and replacement of natural gas end use applications that may result. This is a serious deficiency in the ability of the City to assess benefits as well as costs of electric-ready requirements. Based upon federal grid electricity data published by the U. S. Environmental Protection Agency (EPA) in its eGRID database and employed in energy emissions estimating tools such as GTI Energy’s EPAT tool for the City of Austin,17 current grid electricity consumed in the City accounts for 916.5 pounds of carbon dioxide (CO2) per megawatt of power. Unless the City can demonstrate dramatic reductions in this CO2 emission rate in the future, electric-ready provisions in buildings (if put into effect) will proportionately increase the City’s CO2 emissions in the future. Also, these data sources document that current source energy consumption factors for the City of Austin to be 2.38 times the energy delivered to building sites in comparison to natural gas, which only accounts for a 1.09 times source energy factor. Emissions are proportional to these source energy factors and the current electricity grid mix. As a result, forced fuel switching to grid electricity based upon current data would likely increase the City’s emissions contribution over maintaining use of natural gas for many applications. ONE Gas strongly recommends that the City, prior to agreeing to promulgate electric-ready building requirements, take these effects into account. If the City bases its code on a different grid electricity future, that forecast should be made available to the public for review. 17 https://cmicepatcalc.gti.energy/BuildCityHouse.aspx. 11 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations APPENDIX I Texas Gas Service’s Proposed Code Language Update (Austin’s Commercial Code Provisions with PROPOSED Changes Highlighted in Blue)18 8.4.5 Additional electric infrastructure. Electric infrastructure in buildings that contain combustion equipment shall may be installed in accordance with this section. 1. Combustion space heating. Spaces containing combustion equipment for space heating shall may comply with Sections 8.4.5.1.1, 8.4.5.1.2 and 8.4.5.1.3 1.4.5.1.1 Designated exterior locations for future electric space-heating equipment. Spaces containing combustion equipment for space heating shall may be provided with designated exterior location(s) shown on the plans and of sufficient size for outdoor space-heating heat pump equipment, with a chase that is sized to accommodate refrigerant lines between the exterior location and the interior location of the space heating equipment, and with natural drainage for condensate from heating operation or a condensate drain located within 3 feet (914 mm) of the location of the future exterior space-heating heat pump equipment. 2.4.5.1.1 Dedicated branch circuits for future electric space-heating equipment. Spaces containing combustion space-heating equipment with a capacity not more than 65,000 Btu/h (19 kW) shall may be provided with a dedicated 240-volt branch circuit with ampacity of not less than 50. The branch circuit shall may terminate within 6 feet (1829 mm) of the space heating equipment and be in a location with ready access. Both ends of the branch circuit shall may be labeled with the words “For Future Electric Space Heating Equipment” and be electrically isolated. Spaces containing combustion equipment for space heating with a capacity of not less than 65,000 Btu/h (19 kW) shall be provided with a dedicated branch circuit rated and sized in accordance with Section 8.4.5.1.3, and terminating in a junction box within 3 feet (914 mm) of the location the space heating equipment in a location with ready access. Both ends of the branch circuit shall may be labeled “For Future Electric Space Heating Equipment.” Exceptions: 1. Where a branch circuit provides electricity to the space heating combustion equipment and is rated and sized in accordance with Section 8.4.5.1.3. 2. Where a branch circuit provides electricity to space cooling equipment and is rated and sized in accordance with Section 8.4.5.1.3. 3. Where future electric space heating equipment would require three-phase power and the space containing combustion equipment for space heating is provided with an electrical panel with a label stating “For Future Electric Space Heating Equipment” and a bus bar rated and sized in accordance with Section 8.4.5.1.3. Please note, in addition to the proposed edits as highlighted in blue, TGS added formatting edits only to the City’s original draft document to improve readability of the same information upon inclusion into the Company’s comments. 12 18 4. Buildings where the 99.6 percent design heating temperature is not less than 50°F (10°C). July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations TABLE 8.4.5.1 ALTERNATE ELECTRIC SPACE HEATING EQUIPMENT CONVERSION FACTORS (VA/kBtu/h) 99.6% HEATING DESIGN TEMPERATURE Greater Than (°F) Not Greater Than VA/kBtu/h 50 45 40 35 30 25 20 15 10 5 0 -5 10 -15 N/A 50 45 40 35 30 25 20 15 10 5 0 5 -10 Ps N/A 94 100 107 115 124 135 149 164 184 210 243 289 293 For SI: °C = [(° F) – 32]/1.8, 1 British thermal unit per hour = 0.2931 kW. Additional space heating electric infrastructure sizing. Electric infrastructure for future electric space heating equipment shall may be sized to accommodate not less than one of the following: 1. An electrical capacity not less than the nameplate space heating combustion equipment heating capacity multiplied by the value in Table 8.4.5.1, in accordance with Equation 8.4.5.1.VAs = Qcom x Ps 2. Equation 8.4.5.1 Where VAs = The required electrical capacity of the electrical infrastructure in volt-amps.Qcom = The nameplate heating capacity of the combustion equipment in kBtu/h Ps = The VA per kBtu/h from Table 8.4.5.1 in VA/kBtu/h. 3. An electrical capacity not less than the peak space heating load of the building areas served by the space heating combustion equipment, calculated in accordance with Section 6.4.2.1, multiplied by the value for the 99.6 percent design heating temperature in Table 8.4.5.1, in accordance with Equation 8.4.5.2. 13 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations VAs = Qdesign x Ps Equation 8.4.5.2 Where VAs = The required electrical capacity of the electrical infrastructure in volt-amps. Qdesign = The 99.6 percent design heating load of the spaces served by the combustion equipment in kBtu/h. Ps = The VA per kBtu/h from Table 8.4.5.1 in VA/kBtu/h. 2. Combustion service water heating Spaces containing combustion equipment for service water heating shall may comply with Sections 8.4.5.2.1, 8.4.5.2.2 and 8.4.5.2.3. 1.4.5.1.1 Combustion service water heating electrical infrastructure. For each piece of combustion equipment for water heating with an input capacity of not more than 75,000 Btu/h (22 kW), the following electrical infrastructure is required: 1. An individual 240-volt branch circuit with an ampacity of not less than 30 shall may be provided and terminate within 6 feet (1829 mm) of the water heater and shall be in a location with ready access . 2. The branch circuit overcurrent protection device and the termination of the branch circuit shall may be labeled “For future electric water heater.” 3. The space for containing the future water heater shall may include the space occupied by the combustion equipment and shall have a height of not less than 7 feet (2134 mm), a width of not less than 3 feet (914 mm), a depth of not less than 3 feet (914 mm) and with a volume of not less than 700 cubic feet (20 m3). Exception: Where the space containing the water heater provides for air circulation sufficient for the operation of a heat pump water heater, the minimum room volume shall not be required. 2.4.5.1.1 Designated locations for future electric heat pump water heating equipment. Designated locations for future electric heat pump water heating equipment shall may be in accordance with one of the following: 1. Designated exterior location(s) shown on the plans, of sufficient size for outdoor water heating heat pump equipment and with a chase that is sized to accommodate refrigerant lines between the exterior location and the interior location of the water heating equipment. An interior location with a minimum volume the greater of 700 cubic feet (19 822 L) or 7 cubic feet (198 L) per 1,000 Btu/h (293 W) combustion equipment water heating capacity. The interior location shall include the space occupied by the combustion equipment. 2. 3. An interior location with sufficient airflow to exhaust cool air from future water heating heat pump equipment provided by not fewer than one 16-inch (406 mm) by 24-inch (610 mm) grill to a heated space and one 8-inch (203 mm) duct of not more than 10 feet (3048 mm) in length for cool exhaust air. 14 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations 3.4.5.1.1 Dedicated branch circuits for future electric heat pump water heating equipment. Spaces containing combustion equipment for water heating with a capacity of greater than 75,000 Btu/h (21 980 W) shall may be provided with a dedicated branch circuit rated and sized in accordance with Section 8.4.5.2.4 and terminating in a junction box within 3 feet (914 mm) of the location the water heating equipment in a location with ready access . Both ends of the branch circuit shall be labeled “For Future Electric Water Heating Equipment.” Exception: Where future electric water heating equipment would require three-phase power and the main electrical service panel has a reserved space for a bus bar rated and sized in accordance with Section 8.4.5.2.4 and labeled “For Future Electric Water Heating Equipment.” 4.4.5.1.1 Additional water heating electric infrastructure sizing. Electric infrastructure water heating equipment with a capacity of greater than 75,000 Btu/h (21 980 W) shall may be sized to accommodate one of the following: 1. An electrical capacity not less than the combustion equipment water heating capacity multiplied by the value in Table 8.4.5.2 plus electrical capacity to serve recirculating loads as shown in Equation 8.4.5.3.VAw = (Qcapacity x Pw) + [Qrecirc x 293 (VA/(Btu/h))] Equation 8.4.5.3 Where VAw = The required electrical capacity of the electrical infrastructure for water heating in volt-amps Qcapacity = The water heating capacity of the combustion equipment in kBtu/hPw = The VA per kBtu/h from Table 8.4.5.2 in VA/kBtu/h Qrecirc = The capacity required for temperature e maintenance by recirculation, if applicable, in Btu/h 2. An alternate design that complies with this code, is approved by the authority having jurisdiction and uses no energy source other than electricity or on-site renewable energy. 15 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations TABLE 8.4.5.2 ALTERNATE ELECTRIC WATER HEATING EQUIPMENT CONVERSION FACTORS (VA/kBtu/h) 99.6% HEATING DESIGN TEMPERATURE Greater Than (°F) Not Greater Than VA/kBtu/ 55 50 45 40 35 30 25 20 15 10 5 0 60 55 50 45 40 35 30 25 20 15 10 5 Ps h 118 123 129 136 144 152 162 173 185 293 293 293 293 For SI: °C = [(° F) – 32]/1.8, 1 British thermal unit per hour = 0.2931 kW. Less than 0°F Combustion cooking. Spaces containing combustion equipment for cooking shall may comply with Section 3. 1.4.5.1.1 or 8.4.5.3.2. 8.4.5.3.1 Commercial cooking. Spaces containing commercial cooking appliances shall be provided with a dedicated branch circuit with a minimum electrical capacity in accordance with Table 8.4.5.3.1 based on the appliance in the space. The branch circuit shall may terminate within 3 feet (914 mm) of the appliance in a location with ready access . Both ends of the branch circuit shall be labeled with the words “For Future Electric Cooking Equipment” and be electrically isolated. 9.4.5.3.1 All other cooking. Spaces containing all other cooking equipment not designated as commercial cooking appliances shall may be provided with a dedicated branch circuit in compliance with NFPA 70 Section 422.10. The branch circuit shall may terminate within 6 feet (1829 mm) of fossil fuel ranges, cooktops and ovens and be in a location with ready access . Both ends of the 16 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations branch circuit shall may be labeled with the words “For Future Electric Cooking Equipment” and be electrically isolated. TABLE 8.4.5.3.1 COMMERCIAL COOKING MINIMUM BRANCH CIRCUIT CAPACITY COMMERCIAL COOKING APPLIANCE Range MINIMUM BRANCH CIRCUIT CAPACITY 469 VA/kBtu/h Steamer Fryer Oven Griddle 114 VA/kBtu/h 200 VA/kBtu/h 266 VA/kBtu/h 195 VA/kBtu/h 114 VA/kBtu/h All other commercial cooking appliances For SI: 1 British thermal unit per hour = 0.2931 kW. 4. Combustion clothes drying. Spaces containing combustion equipment for clothes drying shall may comply with Section 8.4.5.4.1 or 8.4.5.4.2. 1.4.5.1.1 Commercial drying. Spaces containing clothes drying equipment and end uses for commercial laundry applications shall may be provided with conduit that is continuous between a junction box located within 3 feet (914 mm) of the equipment and an electrical panel. The junction box, conduit and bus bar in the electrical panel shall may be rated and sized to accommodate a branch circuit with sufficient capacity for equivalent electric equipment with equivalent equipment capacity. The electrical junction box and electrical panel shall may have labels stating, “For Future Electric Clothes Drying Equipment.” 2.4.5.1.1 Residential drying. Spaces containing clothes drying equipment, appliances and end uses serving multiple dwelling units or sleeping areas with a capacity less than or equal to 9.2 cubic feet (0.26 m3) shall may be provided with a dedicated 240-volt branch circuit with a minimum capacity of 30 amperes, shall may terminate within 6 feet (1829 mm) of fossil fuel clothes dryers and shall may be in a location with ready access . Both ends of the branch circuit shall may be labeled with the words “For Future Electric Clothes Drying Equipment” and be electrically isolated. 9.4.5 On-site transformers. Enclosed spaces and underground vaults containing onsite electric transformers on the building side of the electric utility meter shall may have sufficient space to accommodate transformers sized to serve the additional electric loads identified in Sections 8.4.5.1, 8.4.5.2, 8.4.5.3 and 8.4.5.4. 17 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations (Residential Code Provisions with PROPOSED Changes Highlighted in Blue) RK101.1 Electric readiness. Water heaters, household clothes dryers and cooking appliances that use fuel gas or liquid fuel shall may comply with Sections RK101.1.1 through RK101.1.4 RK101.1.5. A space that is at least 3 feet (0.91 m) by 3 feet (0.91 m) wide by 7 feet (2.13) high shall may be available surrounding or within 3 feet (0.91 m) of the installed water heater. Exceptions: 1. Installed heat pump water heaters. 2. Installed tankless water heaters on the exterior of the dwelling unit. 3. Water heaters serving multiple dwelling units in a R-2 occupancy. 18 July 8, 2024 ONE Gas Comment on City of Austin 2024 IECC Code Recommendations 19