BCAP Public Comments to Environmental Protection Agency on Proposed 2011 ENERGY STAR Homes Guidelines
Friday, July 10, 2009
On July 10, 2009, BCAP submitted public comments to the Environmental Protection Agency regarding EPA's proposed 2011 guidelines for its ENERGY STAR Homes program.
July 10, 2009
Re: EPA’s Proposed 2011 Energy Star New Homes
On behalf of the Building Codes Assistance Project (BCAP), I would like to express our support for EPA’s Proposed 2011 Energy Star New Homes Guidelines with the following comments.
- 2011 should enable the HERS infrastructure to better accommodate code compliance as part of the Energy Star Homes “service”, helping to improve energy code implementation where desired, as well as take advantage of Raters promoting Energy Star through the connection with codes.
- “Any local energy code requirements will take precedence over ENERGY STAR Reference Design and mandatory elements and will replace those elements when the state code is more rigorous. “ It is unclear who will be charged with making this determination. Care will need to be taken to assure that Raters fully understand those different baseline code requirements. This function could be served by the local Accredited Rating Provider, rather than counting on each Rater to accommodate those details in modifying the Reference Design.
- There is some concern that the “moving target” of the new Reference Design might send mixed messages to the market. Care should be taken to not undermine the “label” value that has been built over so many years of positive progress with Energy Star by potentially sending a “mixed message” to the consumer public.
- The increased inclusion of current building science practices which address moisture and durability issues are progressive and necessary additions, including those proposed for the new checklists. Followed with required training for Raters and Builders, these concepts can be understood and more readily incorporated into builders’ “business as usual”.
- BCAP commends EPA’s proposal to account for the size of a home and see this as one of the many new progressive energy efficient features which sets Energy Star Labeled Homes apart from the improving national standards. Likewise, the inclusion of higher efficiency HVAC and appliances in the baseline package is also a good accommodation to the increase in technologies and efficiencies currently being realized in the marketplace.
BCAP applauds Energy Star Homes program as it continues to improve construction practice in the field, as well as to more closely align with improving national energy codes.
Cosimina Panetti, CEM, LEED AP
Senior Program Manager