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APGA-AGA Jointly File Appeal of ICC Actions on IECC

By Renée Lani posted 05-14-2020 11:59 AM

On May 8, APGA and the American Gas Association (AGA) jointly filed an appeal of International Code Council (ICC) actions related to several International Energy Conservation Code (IECC) pro-electrification provisions. APGA, through this appeal, contends that these provisions should have been prevented from moving forward by ICC staff during the code development process because they either raised potential federal preemption concerns or were outside of IECC's "intent" (as defined by the code) and, consequently, should not be included in the next edition of the IECC.

APGA members would be directly and materially affected by state or local adoption of the requirements of these proposals, as the proposals would disadvantage the competitiveness of natural gas direct use applications. The Air-Conditioning, Heating, & Refrigeration Institute (AHRI) and the National Association of Home Builders (NAHB) also filed appeals. ICC must respond to the appeals within 30 days. APGA staff will keep members updated as more information becomes available.
The appealed provisions are summarized below:

• RE147 requires "electrification-ready" wiring and outlets, which are outside the "intent" of the code and do not qualify as measurable "energy" saving provisions;

• RE167 eliminates continuously burning pilots, which creates a preemption conflict with federal provisions;

• RE126, the associated TABLE R403.5.1 UEF ratings for residential water heaters, are inconsistent with federal minimums, which creates a preemption conflict; and,

• CE217 (Parts I and II) requires installation of certain electric vehicle (EV) charging equipment and inclusion of EV ready spaces for commercial buildings, which are outside the "intent" of the code and do not qualify as measurable "energy" saving provisions.

The full APGA-AGA appeal letter can be found here. For questions on this article, please contact Renée Lani of APGA staff by phone at 202-464-0836 or by email at