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Existing Building Decarbonization Code

This document provides model code language for existing building retrofits to help jurisdictions require existing buildings to become more energy efficient and transition to low-carbon technologies, approaching net zero emissions. It includes commercial and residential code overlays for both all-electric and mixed-fuel retrofits. The overlays utilize key strategies like efficiency improvements, electrification of equipment and systems, grid integration measures, and building performance standards to help existing buildings decarbonize in a strategic and opportunistic manner through typical retrofit triggers.
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© © All Rights Reserved
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0% found this document useful (0 votes)
90 views104 pages

Existing Building Decarbonization Code

This document provides model code language for existing building retrofits to help jurisdictions require existing buildings to become more energy efficient and transition to low-carbon technologies, approaching net zero emissions. It includes commercial and residential code overlays for both all-electric and mixed-fuel retrofits. The overlays utilize key strategies like efficiency improvements, electrification of equipment and systems, grid integration measures, and building performance standards to help existing buildings decarbonize in a strategic and opportunistic manner through typical retrofit triggers.
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
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Existing Building

Decarbonization
Code
Model code language for
retrofits approaching net zero

Version 1.0 | September 2022

Chicago, IL
Table of Contents
Introduction and Background 3

Key Strategies for Existing Buildings 4

How to Use this Document 5

Commercial Overlay (All-Electric) 7

Commercial Overlay (Mixed-Fuel) 33

Residential Overlay (All-Electric) 59

Residential Overlay (Mixed-Fuel) 81

Acknowledgments
This project was completed with support from and in
collaboration with the U.S. Climate Alliance.
We gratefully acknowledge the following individuals for their
contributions and insights into the development of the Existing
Building Decarbonization Code.

PRIM A RY AU THORS CON TRIBU TORS


Kim Cheslak, NBI Courtney Anderson, City and County of Denver
Sean Denniston, NBI Jim Edelson, NBI
Mark Lyles, NBI Duane Jonlin, City of Seattle
Diana Burk, NBI Katrina Managan, City and County of Denver
Ben Rabe, NBI Kevin Rose, Northwest Energy Efficiency Alliance
Lauren Urbanek, Natural Resources Defense Council

Copyright © 2022 New Buildings Institute. Use of New Buildings Institute’s (NBI) Existing Building
Decarbonization Code overlay document (Version 1.0, September 2022) is permitted on a royalty
free basis. NBI claims no rights in and makes no representations as to the contents or use of the
International Energy Conservation Code®. NBI makes no representations as to the suitability of
this overlay for any purpose, and all content is provided as-is. All other rights reserved.
Introduction and Background
Jurisdictions across the United States have realized their building sector climate
goals cannot be reasonably achieved by addressing new construction alone.
As policymakers seek solutions to drive carbon emissions reductions in existing
buildings, their current options are limited relying primarily on benchmarking and
disclosure policies and building performance standards. Additional options for
existing building decarbonization must be developed and presented rapidly to
address the variety of physical and political realities jurisdictions face.

5.9M
There are 5.9 million existing commercial buildings in the U.S. comprising
97 billion square feet.1 New construction represents less than 2% of
building activity in any given year, leaving a vast amount of outdated
technologies in current building stock. By requiring existing buildings to be E XISTING
more energy efficient, cities could cut about 30% of all urban emissions by CO M MERCIA L
2050.2 Decarbonization retrofits will also aid jurisdictions in aligning climate
goals with public health and equity goals. A growing number of studies are BUILDINGS
highlighting the impact of indoor fossil fuel combustion and health, raising
calls for electrification of buildings. In addition to the operational energy-
and carbon-saving benefits from retrofits of existing buildings, it’s worth
noting the high levels of embodied carbon in construction materials that
could be saved (mainly in steel, concrete, and windows) by reusing and
improving existing buildings rather than demolishing and rebuilding.3
New Buildings Institute’s Decarbonization Building Code4 provided
the first off-the-shelf solution for jurisdictions to transform energy codes
into decarbonization codes for new buildings. Expanding where that
document left off, the Existing Building Decarbonization Code seeks
New construction
to complement the original by adding provisions specifically for existing
represents less than
buildings. Utilizing a familiar structure provided by the existing buildings
chapter (Chapter 5) in the International Energy Conservation Code
(IECC) this overlay creates requirements that are specifically tailored to
support decarbonization using the opportunities presented by common
2%
of building activity in any given
lifecycle events in existing buildings. It is meant to work in conjunction with year, leaving a vast amount
the provisions in the Building Decarbonization Code, utilizing many of of outdated technologies in
its definitions and requirements and adapting them to existing buildings. current building stock
The Building Decarbonization Code was able to rely on the efficiency
gains of the IECC 2021 for new construction and did not include any
efficiency provisions. For existing buildings, each construction event in the
lifecycle provides an opportunity to lower a building’s carbon footprint. By requiring existing buildings
The provisions presented here have been crafted to match reasonable to be more energy efficient,
and effective decarbonization strategies to these events, pairing these cities could cut about

30%
opportunities to decarbonize with additional efficiency to create buildings
that see additional benefits from electrification. The overlay also incorporates
trigger events and solutions for the inclusion of grid integration measures
including renewable energy production, electric vehicles, and battery OF A LL URBA N
storage. Continuing to recognize that not every jurisdiction is looking to
EMISSIONS
require mandatory electrification in all retrofits in their next code cycle,
options for full electrification and electric-ready are presented here. by 2050.

1 https://www.eia.gov/consumption/commercial/
2 According to a September 2019 report by Coalition for Urban Transitions https://urbantransitions.global/en/publication/climate-
emergency-urban-opportunity/
3 https://newbuildings.org/embodied-carbon-conundrum-solving-for-all-emission-sources-from-the-built-environment/
4 https://newbuildings.org/resource/building-decarbonization-code/

NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 3


Key Strategies for Existing Buildings

EFFICIENCY ELECTRIFICATION
Existing buildings were built to a variety of previous Electrification in existing buildings follows several
codes, and many do not perform as well as new paths including provisions for full electrification
construction, even those that have been updated over of a whole building, addition, building system, or
time. Provisions that require strategic, opportunistic individual piece of equipment. When these provisions
efficiency improvements are critical to get the existing are targeted to an individual building system
building stock decarbonized. These range from that system will be fully electrified even if other
improving the efficiency of equipment replacements parts of the building may still include combustion
to an application of the additional efficiency options in equipment. Depending on the building type or piece
Sections C406 and R408 in existing buildings. Many of equipment, the path toward electrification may
jurisdictions will find it necessary to continue to allow also result in “hybrid” building systems that use both
for the installation of new combustion equipment in electricity and fossil fuels. Where systems are not fully
existing buildings, making it additionally important electrified, providing electric ready infrastructure will
to adopt provisions to improve the performance of future-proof the next round of retrofits.
combustion equipment when it is allowed. These
include requirements to improve efficiency, reduce
emissions, and improve indoor air quality.

GRID IN TEGR ATION BUILDING PERFOR M A NCE


Buildings that rely increasingly on electricity for Many jurisdictions have begun to consider and adopt
their primary or sole source of energy also need to policies, most commonly building performance
adopt technology that can support grid integration. standards (BPS), to address the actual performance
Targeting key technologies like renewable energy, EV- of existing buildings in an effort meet their climate
charging, battery storage, and demand response will goals. Provisions for needed efficiency, system-by-
allow existing buildings to support a heathly grid. By system electrification, and onsite renewable energy
selecting optimized lifecycle events for the mandatory generation will integrate with BPS to aid in overall
installation of these technologies, buildings will benefit building sector decarbonization and energy use
from the lowest cost retrofit solutions and obtain the reductions, the main objectives of currently adopted
benefits of the installations themselves: lower cost BPS. Where jurisdictions will not adopt a BPS,
utility bills and increased resilience. and for buildings that fall below size thresholds for
regulation, the overlay will provide the opportunity to
advance existing building decarbonization without
performance regulations, closing an important gap
created by most BPS policies.

4 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE


How to Use This Document

The Existing Building Decarbonization Code is presented in two The Existing


Building
parallel electrification and mixed fuel paths, similar to the new Decarbonization
construction version. Specific code language to be used in the Code includes
provisions for:
amendment process is provided for each of the pathways.

1 2 efficiency

A LL-ELECTRIC MIX ED -FUEL


The electrification path includes provisions The mixed-fuel path includes provisions
to fully electrify buildings or building to only partially electrify building systems, renewable energy
systems, while introducing increased allowing hybrid systems that utilize both
efficiency. electricity and natural gas. The mixed-fuel
path supports decarbonization in buildings
with combustion equipment by including electric vehicle
provisions for targeted electrification- charging
readiness as well as provisions to improve
the performance and air quality of
combustion equipment.
energy storage

The code amendments are presented in strikethrough and underline


formatting that is commonly used in the amendment process.
The strikethrough markup indicates the deletion of portions of code text.
The underlined markup indicates the addition of portions of code text.

Both paths restructure Chapter 5 of the IECC to or why certain exceptions were carved out in the
improve usability generally and to make it easier new language. Narrative text should be removed
to incorporate new measures for decarbonization for any formal adoption process or repurposed as
provisions. The most noticeable change is the background information or a reason statement.
renumbering of sub-sections so building systems
Jurisdictions are not limited to using either the
have consistent numbering in both the residential
electrification or mixed-fuel paths in their entirety. If
and commercial sections and in the additions
these full pathways do not support individual goals
(C502/R502) and alterations (C503/R503) sections:
or political reality of a particular market, jurisdictions
envelope is always 50x.2, mechanical systems are
can select only a subset of the sections from one of
always 50x.3, water heating is always 50x.4, lighting
the paths or even mix and match sections from both
and power is always 50x.5.
paths. The Existing Building Decarbonization Code
Amendments are followed by narrative text where is structured to be flexible and allow jurisdictions to
needed to explain why a change was made, how find the solution that supports their climate goals
the code relates to other I-Code language, and/ while meeting the needs of their communities.

NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 5


Application to Different Existing Combined with targeting replacements, reconfiguring
of spaces, and remodeling scopes, this document
Building Retrofits introduces two key definitions based on the IEBC to
Retrofit work in existing buildings in the code is best further define points of intervention that are likely to
captured through the classifications described in the be impactful of decarbonization policies:
International Existing Building Code (IEBC): repair,
• substantial improvement (based on cost of work),
alteration, addition, and change of occupancy.
Through a building’s life, it is likely to experience • substantial energy alteration (based on potential
most, if not all, of these types of work. This overlay energy impact of work)
relies on the relative cost, scale, and scoping
With these in place, each scale of alteration is
implications of each of these interventions to present
presented with the best opportunities to transition
solutions for decarbonization.
to electrification and add necessary supportive
To meet long-term climate goals, every replacement measures.
should be treated as an opportunity to reduce
energy use and carbon emissions by optimizing Change of Occupancy
systems and electrifying equipment. When assessing Many changes of occupancy require at least some
the opportunities to decarbonize assets, owners, alterations to the space and building systems. The
managers, and operators should leverage large scale model energy code has specific provisions for
investments to move beyond aesthetic functions of a upgrade requirements where a change of occupancy
“face-lift” and plan inclusion of deep decarbonization increases energy use. The change of occupancy
strategies, such as efficiency, electrification, updating requirements presented here are meant to work in
building controls, and grid-integration of systems conjunction with alteration requirements and add
and equipment. Taking these actions when it makes clarity and code usability for the specifics of a change
the most financial and structural sense will transform of occupancy as a critical building lifecycle event to
buildings into carbon mitigation assets instead of leverage where an alteration may not be planned.
liabilities. Targeted provisions that opportunistically
require onsite renewable energy systems, EV
charging infrastructure, energy storage, and limited
electrification readiness where it would be most cost-
effective or more easily accommodated within a larger
project aid in this transition and are presented in both
the electrification and mixed-fuel paths.

Additions
Additions are generally treated as new construction
within code application and enforcement. Key
differences are that often the addition is smaller than
the base building and an addition may not necessitate
the addition of new space conditioning or water
heating equipment. Because of the differences in
scope, scale, and energy infrastructure being put into
additions, the overlay presents specific options for
new systems and system extensions as they relate to
the key decarbonization strategies found in the new
construction version.

Alterations
Alterations present the most variety in size and
scale. The IEBC defines three types of alterations
by these criteria as Level 1, Level 2, and Level 3.5

5 ICC 2021. International Existing Building Code, accessed at


https://codes.iccsafe.org/content/IEBC2021P1

6 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE


Existing Building
Decarbonization Code:

Commercial
Overlay
All-Electric
Commercial Overlay (All-Electric)
Chapter 1 – Scope and Application
C101 SCOPE AND G ENERAL REQUIREMENTS
Revise text as follows:
C101.3 Intent. This code shall regulate the design, and construction, repair, alteration, change of
occupancy, and additions of new and existing buildings for the effective use and conservation
reduction of greenhouse gas emissions and for the efficient production, use and storage of energy
over the useful life of each building. This code is intended to provide flexibility to permit the use of
innovative approaches and techniques to achieve this objective. This code is not intended to abridge
safety, health or environmental requirements contained in other applicable codes or ordinances.
Intent has been modified to push beyond simply the inclusion of considerations of greenhouse gas
emissions and production and storage of energy, to clearly emphasize the intent of the code to regulate
existing buildings.

Chapter 2 – Definitions
C202 GENERAL DEFINITIONS
Add new definitions as follows:
ELECTRIC EQUIPMENT. Any equipment or appliance used for space heating, service water
heating, cooking, clothes drying, or lighting that uses electricity as its sole source of energy.
This new definition for electric equipment is a parallel of the definition of “combustion equipment”
introduced in the Building Decarbonization Code.
ENERGY USE INTENSITY (EUI). An expression of building energy use in terms of net
energy divided by gross floor area.
EUI is an energy metric used in some performance-based energy policies, including many building
performance standards (BPS). It is included here to allow provisions of the Existing Building
Decarbonization Code integrate with BPSs. EUI is not currently defined in the suite of I-Codes, so it is
added here. If a jurisdiction already has a formal definition of EUI, particularly in a building
performance standard, then that definition should be integrated here as well.
SUBSTANTIAL ENERGY ALTERATION. An alteration that includes replacement of two or
more of the following:
1. 50% or more of the area of interior wall-covering material of the building thermal
envelope or fenestration.
2. 50% or more of the area of the exterior wall-covering material of the building thermal
envelope or fenestration.
3. Space-conditioning equipment constituting 50% or more of the total input capacity of the
space heating or space cooling equipment serving the building.

8 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE COMMERCIAL OVERLAY (ALL-ELECTRIC)
4. Water-heating equipment constituting 50% of more of the total input capacity of all the
water heating equipment serving the building.
5. 50% or more of the luminaires in the building
This new definition for substantial energy alteration is intended to capture projects that have the
opportunity to greatly increase efficiency by nature of their scope and clarify when certain requirements
related to the energy use of the building are triggered. By defining such scopes, confusion around generic
terms like major renovations and applicability of work classifications in the IEBC can be removed. Other
terms that define large-scale alterations such as Level III alteration or substantial improvement are not
specific to the energy systems. An alteration could cross their thresholds without having a significant
impact on the energy systems since they are based on metrics such as monetary value and reconfiguration
of spaces. Similarly, an alteration that has significant impact on the energy systems of the building may
not cross these other thresholds.
SUBSTANTIAL IMPROVEMENT. Any repair, reconstruction, rehabilitation, alteration,
addition or other improvement of a building or structure, the cost of which equals or exceeds 50
percent of the market value of the structure before the improvement or repair is started. If the
structure has sustained substantial damage, any repairs are considered substantial improvement
regardless of the actual repair work performed. The term does not, however, include either:
1. Any project for improvement of a building required to correct existing health, sanitary or
safety code violations identified by the building official and that are the minimum
necessary to assure safe living conditions.
2. Any alteration of a historic structure provided that the alteration will not preclude the
structure’s continued designation as a historic structure.
The definition of substantial improvement comes from the IBC and IEBC. The term generally aligns with
vernacular use of “major renovation,” which is not defined in code. It is used as a threshold for when
certain flood protection requirements are triggered for existing building alterations. Since it is based on
the monetary value of the alteration, it sets a useful threshold for introducing additional decarbonization
requirements for large alterations.
In addition, the Existing Building Decarbonization Code leverages definitions from the Building
Decarbonization Code including:
ALL-ELECTRIC BUILDING
APPLIANCE
COMBUSTION EQUIPMENT
COMMERCIAL COOKING APPLIANCES
ELECTRIC VEHICLE (EV)
EQUIPMENT
EV-CAPABLE SPACE
FUEL GAS
The use of these terms throughout assumes that adopting jurisdictions will adopt the Building
Decarbonization Code alongside this existing building overlay.

COMMERCIAL OVERLAY (ALL-ELECTRIC) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 9
Chapter 5 – Existing Buildings
C501 GENERAL
Add new text as follows:
C501.6 Requirements for combustion equipment. Where existing combustion equipment in additions,
alterations and changes of occupancy is to remain, equipment shall comply with this section.

This section creates an additional set of requirements for combustion equipment when it is allowed to be
installed in existing buildings. These requirements are intended to generally improve the emissions of the
equipment and the interior and exterior air quality.

C501.6.1 Phase out documentation. Permit applications for projects retaining existing
combustion equipment serving space heating and water heating shall include a plan for
the future replacement of the combustion equipment with electric equipment. The
documentation shall include the following:
1. Calculations of the electric load required by the replacement electric equipment
and of the available electric capacity of the building.
2. Identification of any existing onsite electrical infrastructure, including but not
limited to transformers, switchgear, electrical panels and conductors, that will
need to be altered to accommodate the replacement electric equipment.
3. Floor plans identifying any spaces that will need to be reconfigured to
accommodate the replacement electric equipment.
Where replacements are made with combustion equipment, building owners should understand the need for
long term phase out and switch to electric equipment to avoid potential abandoned assets. Jurisdictions
could also expand this section to include specifics related to other policies such as appliance emission
standards or replacement policies targeting specific dates for combustion equipment phase out.

C501.6.2 Fuel gas pipe testing. All fuel gas piping serving combustion equipment shall
be tested in accordance with Section 406 of the International Fuel Gas Code.
Exceptions:
1. For the purposes of demonstrating compliance with this section, unexposed pipe
joints and welds shall not be required to be exposed for examination during the test.
2. Where it has been demonstrated to the code official that the fuel gas piping has
met the requirements of this section within the previous five years.
3. Where compliance with this section would require interruption of fuel gas supply
to combustion equipment that serves other tenant spaces or other dwelling units,
provided all exposed pipe joints of the piping subject to the requirements of this
section have been inspected for leaks by means of an approved gas detector, a
noncorrosive leak detection fluid or other approved leak detection method once
the equipment has been placed in operation.

10 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE COMMERCIAL OVERLAY (ALL-ELECTRIC)
Gas piping degrades over time, creating the possibility of natural gas leakage. Even though the natural
gas is treated with mercaptan to give it that rotten egg smell, small leaks may go undetected, particularly
in buildings where pipes are not exposed and older buildings that are likely to have envelopes that are
less tight than newer construction. According to US DOE, building leakage accounts for nearly 27% of
the natural gas leakage in the US natural gas distribution system. 6 Leaking natural gas represents a loss
in energy, and even small leaks can add up over long periods of time. Additionally, natural gas is also a
potent Green House Gas, with over 86 times the global warming potential of CO2 on a short-term basis.
The installation of new gas equipment provides an ideal time to test gas pipe leakage. Contractors are
already on site and the gas will often be partially or fully turned off for the new equipment installation.
Additionally, new equipment installation can disturb and inflict additional stresses on existing piping,
creating opportunities for the formation of new leaks where existing natural gas piping has weakened but
not previously failed
This provision requires that existing fuel gas piping be tested like a new installation according the
International Fuel Gas Code (IFGC). It includes targeted exceptions for elements of the IFGC testing
methodology that is not appropriate for existing buildings. It also includes an exception for piping that
has been tested in the last five years in order to prevent repeated testing. Finally, it includes an exception
to ensure that testing requirements don’t necessitate other tenants losing service, which could be a
considerable in larger buildings with multiple tenant spaces. In those cases, it only requires visual
inspection of the exposed joints with a testing fluid.

Add new text as follows:


C501.7 Heat pump supplementary combustion equipment. Heat pumps having combustion
equipment and electric resistance equipment for supplementary space or water heating shall have
controls that limit supplemental heat operation to only those times when one of the following applies:

1. The heat pump is operating in defrost mode.


2. The vapor compression cycle malfunctions.
3. For space heating systems, the thermostat malfunctions.
4. For space heating systems, the vapor compression cycle cannot provide the necessary
heating energy to satisfy the thermostat setting.
5. For water heating, the heat pump water heater cannot maintain an output water
temperature of at least 120°F (49°C)
New supplementary space and water heating systems for heat pump equipment shall not be
permitted to have a heating input capacity greater than the heating input capacity of the heat
pump equipment.

Supplementary heating systems are effectively back-up systems intended to provide heating if the primary
heat pump system fails, if the operating conditions (heating demand, temperature around the heat pump
compressor, etc.) exceed the ability of the heat pump to effectively, or cost-effectively, provide heating.

6
“Natural Gas Infrastructure Modernization Programs at Local Distribution Companies: Key Issues and Considerations.” US DOE,
Office of Energy Policy and Systems Analysis. Washington DC, 2017.

COMMERCIAL OVERLAY (ALL-ELECTRIC) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 11
Designers sometimes utilize “hybrid heat” systems where combustion equipment provides the
supplementary heat to address these situations.
This new section creates a version of the supplementary heating equipment control requirements in
Section C403 that is customized for existing buildings. It addresses both space and water heating
applications and ensures that any combustion heating equipment used for supplementary heat is only
used when the heat pump system is unable to fully meet the buildings heating needs (the language in
C403 already addresses electric resistance supplementary heat).

C502 ADDITIONS
Revise text as follows:
C502.1 General. Additions to an existing building, building system or portion thereof shall
conform to the provisions of this code as those provisions relate to new construction without
requiring the unaltered portion of the existing building or building system to comply with this
code. Additions shall not create an unsafe or hazardous condition or overload existing building
systems. An addition shall be deemed to comply with this code if the addition alone complies or
if the existing building and addition comply with this code as a single building. Additions shall
comply with Sections C502.2 through C502.5.
These edits implement the restructuring discussed above in the introduction. The content of the sections is
unaffected. The compliance language from the original Section C502.3 has been moved here.
The requirement in C502.1 for additions to meet the requirements for new construction mean that
additions will be subject to the requirements in the Building Decarbonization Code for demand
responsive thermostats and water heaters, onsite renewable energy, electrification readiness, energy
storage infrastructure, etc.

Add new text as follows:


C502.1.1 Combustion equipment. Additions shall not be permitted to contain
combustion equipment and new equipment installed to serve additions shall not be
combustion equipment. Where systems with combustion equipment are extended into an
addition, the existing building and addition together shall use no more fossil fuel energy
than the existing building alone.

This section requires additions to effectively be all-electric by prohibiting them from containing or being
served by new combustion equipment additions combustion equipment. When additions are added to
existing buildings, space and water heating systems are often extended into the new addition. This
provision does allow the extension of systems that utilize combustion equipment into the addition. In
order to ensure that the addition does not result in higher consumption of fossil fuels, the provision also
requires that this extension doesn’t result in an increase in combustion energy. In order to extend a
system with combustion equipment into an addition, the efficiency of the existing building would need to
be improved to offset the increased consumption from the addition.

12 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE COMMERCIAL OVERLAY (ALL-ELECTRIC)
Add new text as follows:
C502.1.2 Building Performance Standards. Where an addition to a building makes it
subject to [OFFICIAL NAME OF THE LOCAL BUILDING PERFORMANCE
STANDARD], the permit application for the addition shall include a report that includes
the following:
1. The current or last reported EUI of the building
2. The performance targets from [NAME OF THE LOCAL BUILDING
PERFORMANCE STANDARD] that will be applicable to the building within
five years from the date of the permit application
Where the current or last reported EUI exceeds the performance targets that will be
applicable in the next five years, the report shall also include a plan describing how the
building will be brought into compliance. The report shall include energy efficiency
upgrades and operational improvements that will be made to the building before the
applicable target goes into effect and the impact of the alteration under permit review.
Exceptions:
1. Where the total building performance of the building with the alteration
determined in accordance with Section C407 demonstrates compliance with the
performance targets identified in the report required by this section.
2. Additions that increase the conditioned floor area of the building by less than
10% and install no new space conditioning or water heating equipment.
In jurisdictions with a BPS it is important that all work on existing buildings support and reinforce
the policy goals. Additions that either push a building into covered building status or are part of a
building is already subject to the BPS that are undertaken without consideration of impending BPS
performance targets represent a significant missed opportunity. This section requires that
consideration by creating a requirement that permit applications include the building’s current
performance and any BPS performance targets that will be in effect in the next 5 years, the typical
compliance cycle for US-based BPS. Where a building does not already meet those targets, it will be
required to also submit what is effectively a plan for compliance with the BPS. This will ensure that
project teams are thinking about a proposed alteration within the larger context of what will be
required to meet up-coming BPS requirements.
The exceptions allow the compliance path to be avoided when the alteration is complying by
performance modeling and that modeling shows that the alteration will bring the building into
compliance with the BPS performance target, and for additions that will in and of themselves not
create a major energy impact.
It may be necessary to modify the language in this provision to align with the terminology that is used in
the official BPS regulation to maximize correlation and usability. For example, the provision can be
modified to align with a carbon-based BPS by replacing “EUI” with “CUI” throughout and adding the
following definition:
CARBON USE INTENSITY (CUI). An expression of building carbon emissions in terms of the
equivalent carbon emissions of the net energy divided by gross floor area.

COMMERCIAL OVERLAY (ALL-ELECTRIC) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 13
This definition defines a carbon use intensity that parallels the definition of EUI. It is a carbon metric
where carbon emissions are divided by gross floor area in order to compare the emissions of different
buildings or assess the performance a building’s carbon emissions against a target.

Revise text and numbering as follows:


C502.2 Change in space conditioning. Any nonconditioned or low-energy space that is
altered to become conditioned space shall be required to comply with Section C502.
Exceptions:
1. Where the component performance alternative in Section C402.1.5 is used to
comply with this section, the proposed UA shall be not greater than 110
percent of the target UA.
2. Where the total building performance option in Section C407 is used to
comply with this section, the annual energy cost of the proposed design shall
be not greater than 110 percent of the annual energy cost otherwise permitted
by Section C407.2.
This section is moved to C503, the alterations section. It is reasonable to make conversions of
unconditioned space to conditioned space subject to the requirements for an addition, but they are
technically alterations. Code users could naturally skip over the additions section, go straight to the
alterations section, and miss this requirement. Moving the provision improves clarity and usability.

Revise text and numbering as follows:


C502.3 Compliance Additions shall comply with Sections C502.3.1 through C502.3.6.2.
C502.2 Building Envelope. New building envelope assemblies that are part of the addition shall
comply with Sections C502.2.1 through C502.2.2.
C502.3.1 C502.2.1 Vertical fenestration area.
C502.3.2 C502.2.2 Skylight area.
C502.3.3 C502.3 Building mechanical systems.
These edits implement the restructuring discussed above in the introduction. The content of the
subsections is unaffected. The compliance language from the original Section C502.3 has been moved to
C503.1 and a new C502.2 has been introduced for the envelope subsections.

Add new text as follows:


C502.3.1 Space heating equipment. New space heating equipment in additions shall be
electric heat pump equipment. Where existing systems with combustion equipment are
extended to serve the addition, they shall comply with Section C501.7.

14 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE COMMERCIAL OVERLAY (ALL-ELECTRIC)
Exceptions:
1. Electric resistance supplementary heat in accordance with Section C403.4.1.1
2. Up to 5W of electric resistance heat per square foot of conditioned floor area in
the addition
Requiring space heating installed during an addition to be electric will reduce carbon emissions and
improve air quality in homes. Heat pumps have been shown to be technically effective in all climate
zones, and cold-climate heat pump technology continues to improve, providing heating with a COP of
more than 3 above 5°F. 7
Exceptions are included for electric resistance supplementary heat and for up to 5W of electric resistance
heat per square foot of conditioned floor area. The latter creates a budget for electric resistance heat that
can be used for spot heating, small spaces, freeze protection and heat pump VAV systems with terminal
electric resistance heat. 5W is a fairly low budget for these VAV systems that will require efficient design
parameters such as delivering higher temperature air to the terminal boxes during heating that minimize
the operation of the electric resistance coils. This section does not allow the installation of new
combustion equipment, even as supplementary heat.

Revise text and numbering as follows:


C502.3.4 C502.4 Service water-heating systems.
C502.2.5 C502.4.1 Pools and inground permanently installed spas.
These edits implement the restructuring discussed above in the introduction. The content of the sections is
unaffected.

Add new text as follows:


C502.4.2 Heat Pump Water Heating. New water heaters in additions shall be electric
heat pump equipment.
Exceptions:
1. Electric storage water heaters with a rated storage volume of less than 20 gallons
(75.7 liters) and a rated input of less than 5kW.
2. Instantaneous electric water heaters located within 10 feet of the point of use.
3. Electric resistance equipment where not less than 75 percent of the annual service
water-heating requirement is provided by an on-site renewable energy system not
used to meet any other provision of this code.
4. Water heaters that serve end-uses that require water temperature of 150°F
(65.6°C) or hotter.

7
“Achieve Comfort and Reliable Performance with Cold-Climate Heat Pumps.” Zero Energy Project, 6 Feb. 2020,
https://zeroenergyproject.org/2020/01/22/achieve-comfort-and-reliable-performance-with-cold-climate-heat-
pumps/#:~:text=The%20Benefits%20of%20Heat%20Pumps%20in%20Cold%20Climates&text=Combustion%2Dbased%20hea
ting%20systems%20such,3%20at%205%C2%B0F.

COMMERCIAL OVERLAY (ALL-ELECTRIC) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 15
Heat pump water heaters can be 4-6 times more efficient than their electric resistance and combustion
counterparts. This provision requires new water heaters in additions to be heat pump water heaters. It
includes a few key exceptions:
1. Small electric resistance storage water heaters. These will have small loads and there aren’t
HPWH alternatives for them, so it is reasonable to allow them as electric resistance water heaters.
2. Instantaneous resistance water heaters used in point-of-use applications. The loads from these will
also generally be very low.
3. There is a blanket exemption for electric resistance water heating where 75% of the annual water
heating load is served by onsite renewable energy (most likely solar thermal or PV). This provides
flexibility and the pairing of dedicated renewable energy with electric resistance water heating
creates a system with total efficiency similar to a HPWH.
4. High-temperature applications are exempted since high temperature HPWHs are just now coming
on the market and don’t have broad market penetration.
If a jurisdiction finds that requiring central HPWHs is not a viable option, an additional exception for
equipment with an input rating of more than 300,000 kbtu/h can be added.

Alternate add new text as follows:


5. Water heaters with an input rating of 300,000 Btu/h or greater.

This will exempt large central systems from this requirement, allowing them to be any kind of water
heating system. This section can be also be replaced with an alternative that only requires electrification
(below),but not heat pumps specifically, allowing electric resistance options.

Alternate add new text as follows:


C502.4.2 Service water heating equipment. Where service water heating equipment is
added or replaced, new service hot water equipment shall not be combustion equipment.
Although such an approach would be more flexible, increasing large capacity electric resistance loads into
buildings can have serious implications for carbon emissions and energy affordability. This approach
should only be chosen in jurisdictions served by an electricity supply that has a carbon intensity comparable
to onsite natural gas combustion. Additionally, the utility cost implications—particularly for equipment that
serves residential occupancies—should be analyzed in order to ensure this requirement will not have an
unacceptably adverse effect on utility bills. Replacement of combustion equipment with electric resistance
equipment will also exacerbate the building electrical capacity issues for electrification.

Revise text and numbering as follows:


C502.2.6 C502.5 Lighting and power systems.
C502.2.6.1 C502.5.1 Interior lighting power.

16 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE COMMERCIAL OVERLAY (ALL-ELECTRIC)
C502.2.6.2 C502.5.2 Exterior lighting power.
These edits implement the restructuring discussed above in the introduction. The content of the
subsections is unaffected. The compliance language from the original Section C502.3 has been moved to
C503.1 and a new C502.2 has been introduced for the envelope subsections.

Add new text as follows:


C502.5.3 Renewable energy infrastructure. Additions with a new roof shall be provided with
equipment for on-site renewable energy with a rated capacity of not less than 0.25 W/ft²
(2.7 W/m²) multiplied by the sum of the gross conditioned floor area of the three largest
floors of the addition.
Exceptions:
1. Additions that increase the conditioned floor area of the building by less than 10%.
2. Additions where an unshaded flat plate collector oriented towards the equator
and tilted at an angle from horizontal equal to the latitude receives an annual
daily average incident solar radiation less than 3.5 kWh/m²·day (1.1
kBtu/ft²·day).
3. Additions where more than 80 percent of the roof area is covered by any
combination of equipment other than for on-site renewable energy systems,
planters, vegetated space, skylights, or occupied roof deck.
4. Additions where more than 50 percent of roof area is shaded from direct beam
sunlight by natural objects or by structures that are not part of the building for
more than 2,500 annual hours between 8:00 AM and 4:00 PM.

Additions with roofs provide an opportunity to introduce renewable energy systems. The requirements in
the Building Decarbonization Code for renewable energy systems reference buildings and so don’t
capture additions. This section uses the addition to trigger the requirements. The size of the system is
based on the size of the addition, rather than the whole building. The new section includes exceptions that
are paralleled from the new construction requirements. These exempt small additions, roofs without good
solar access and roofs that are already utilized for other uses.

Add new text as follows:


C502.5.4 Electric vehicle charging infrastructure. New parking facilities and new
parking spaces added to existing parking facilities shall comply with Section C405.14
based on the number of new parking spaces.
This section requires new parking facilities to meet the EV charging requirements in the new construction
portion of the Building Decarbonization Code. While this is implicitly required by Section C501, the
addition of this section makes it explicit for greater clarity and enforceability.

COMMERCIAL OVERLAY (ALL-ELECTRIC) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 17
Add new text as follows:
C502.6 Additional energy efficiency credits. Additions shall achieve credits in accordance with
Section C506. All-electric buildings shall be required to 10 credits and mixed-fuel buildings shall
be required to select 15 credits. Alterations to the existing building that are not part of an
addition, but permitted with an addition, may be used to achieve the required credits.
Exceptions:
1. Buildings in Utility and Miscellaneous Group U, Storage Group S, Factory Group F,
High-Hazard Group H
2. Additions less than 1,000 ft2 (92.9 m2) and less than 50% of existing floor area.
3. Additions that do not include the addition or replacement of equipment covered by
Section C403.3 or C404.2 that achieve a total of 5 credits.
4. Additions that do not contain conditioned space that achieve a total of 5 credits.
5. Buildings in Residential Group R and Institutional Groups I in climate zones 3C, 4B,
4C, 5C that achieve a total of 5 credits
6. Where the addition alone or the existing building and addition together comply with
Section C407
This section works with the new Section C506 (see below for more) to bring additional energy efficiency
to additions through implementing the additional efficiency credits in Section C406 in “substantial”
additions. The section requires 10 credits in additions to all-electric buildings, just like new buildings,
and greater efficiency of 15 credits for additions to mixed-fuel buildings. It also includes a series of
important exceptions for occupancy types with low building loads, small additions and buildings that
comply with Section C407. It also requires only 5 credits in additions to certain building types in certain
climate zones that have fewer credit options available, additions that don’t include new HVAC or water
heating equipment and additions that do not include conditioned space.

C503 ALTERATIONS
Add new text as follows:
C503.1.1 Change in space conditioning. Any nonconditioned or low-energy space that
is altered to become conditioned space shall be required to comply with Section C502.
Exceptions:
1. Where the component performance alternative by Section C402.1.5 is used to
comply with this section, the proposed UA shall be not greater than 110 percent
of the target UA.
2. Where the total building performance option by Section C407 is used to comply
with this section, the annual energy cost of the proposed design shall be not
greater than 110 percent of the annual energy cost otherwise permitted by Section
C407.2.

18 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE COMMERCIAL OVERLAY (ALL-ELECTRIC)
This content is located in the additions section in the model code (Section C502.2). As part of the restructuring
needed for this overlay, it has been relocated here since it describes an alteration project. The requirements
have not been changed, but the relocation will improve the usability and enforceability of the code.

Add new text as follows:


C503.1.2 Substantial improvement. Buildings undergoing substantial improvements
shall be all-electric buildings, comply with C402.5 and meet a site EUI by building type
in accordance with ASHRAE Standard 100 Table 7-2a.
Exception: Compliance with Standard 100 shall not be required where Group R-
occupancies achieve an ERI score of 80 or below without on-site renewable energy
included in accordance with RESNET/ICC 301, for each dwelling unit.
Substantial improvements are extensive alterations that have significant scope, large project budgets
relative to the value of the building and are more likely to already include major systems that could
include combustion equipment. The larger scopes and budgets of substantial improvements are likely to
occur infrequently within a building lifecycle and create the best opportunity to significantly increase
efficiency and electrify the full building. In jurisdictions where requiring substantial improvements to be
all-electric is not feasible, substantial alterations can be require to be electric ready. See Mixed Fuel
Section C503.1.3.

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C503.1.3 Combustion equipment. New combustion equipment and plumbing for
combustion equipment shall not be permitted to be installed in alterations.
This requirement prohibits the installation of new combustion equipment in alterations but does not
require the full removal of existing combustion equipment.

Add new text as follows:


C503.1.4 Building Performance Standards. Where the building is subject to
[OFFICIAL NAME OF THE LOCAL BUILDING PERFORMANCE
STANDARD], the permit application for the alteration shall include a report that
includes the following:
1. The current or last reported EUI of the building
2. The performance targets from [NAME OF THE LOCAL BUILDING
PERFORMANCE STANDARD] that will be applicable to the building within
five years from the date of the permit application
Where the current or last reported EUI exceeds the performance targets that will be
applicable in the next five years, the report shall also include a plan describing how the
building will be brought into compliance. The report shall include energy efficiency

COMMERCIAL OVERLAY (ALL-ELECTRIC) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 19
upgrades and operational improvements that will be made to the building before the
applicable target goes into effect and the impact of the alteration under permit review.
Exception: Where the total building performance of the building with the alteration
determined in accordance with Section C407 demonstrates compliance with the
performance targets identified in the report required by this section.
In jurisdictions with a Building Performance Standard (BPS), it is important that all alterations support and
reinforce the BPS. Alterations that are undertaken without consideration of impending BPS performance
targets represent a significant missed opportunity. This section requires that consideration by creating a
requirement that permit applications include the building’s current performance and any BPS performance
targets that will be in effect in the next 5 years, the typical compliance cycle for US-based BPS. Where a
building does not already meet those targets, it will be required to also submit what is effectively a plan for
compliance with the BPS. This will ensure that project teams are thinking about a proposed alteration
within the larger context of what will be required to meet up-coming BPS requirements.
The exception allows the compliance path to be avoided when the alteration is complying by performance
modeling and that modeling shows that the alteration will bring the building into compliance with the
BPS performance target.
It may be necessary to modify the language in this provision to align with the terminology that is used in
the official BPS regulation to maximize correlation and usability. For example, the provision can be
modified to align with a carbon-based BPS by replacing “EUI” with “CUI” throughout and adding the
following definition:
CARBON USE INTENSITY (CUI). An expression of building carbon emissions in terms of the
equivalent carbon emissions of the net energy divided by gross floor area.
This definition defines a carbon use intensity that parallels the definition of EUI. It is a carbon metric
where carbon emissions are divided by gross floor area in order to compare the emissions of different
buildings or assess the performance a building’s carbon emissions against a target.

Add new text as follows:


C503.3.2 System sizing. New heating and cooling equipment that is part of an alteration
shall be sized in accordance with Section C403.3.1 based on the existing building
features as modified by the alteration.
Exception: Where is has been demonstrated to the code official that compliance with
this section would result in heating or cooling equipment that is incompatible with
the rest of the heating or cooling system.
Space conditioning equipment is routinely oversized for its application. Even when equipment was sized
appropriately when it was installed, many buildings have undergone alterations, particularly energy
efficiency retrofits, that have changed the heating and cooling characteristics of the building. It is
reasonable to assume that the existing equipment sizing is more likely to be wrong than right, yet many
equipment replacements use existing system sizing to size new equipment. Oversized equipment is less
efficient, costs more to operate, costs more to install, provides lower levels of comfort and is less effective
at de-humidification.

20 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE COMMERCIAL OVERLAY (ALL-ELECTRIC)
This measure explicitly requires that new equipment installed as part of an alteration be sized based on
current building characteristics and loads, using current sizing standards. It provides an exception for
situations where right-sizing equipment may create an incompatibility with the rest of the system (as can
be the case with steam systems where boilers are sized to the radiators/convectors and not the building).

Add new text as follows:


C503.3.3 Controls. New heating and cooling equipment that are part of the alteration
shall be provided with controls that comply with Section C403.4.
Exception: Systems with direct digital control of individual zones reporting to a
central control panel
The IECC’s requirements for HVAC controls only apply to new controls. As a result, new equipment is
permitted to be controlled by existing controls that can fall far short of current code requirements. This
section requires new equipment to have code-compliant requirements. The exception ensures that this
section won’t trigger the replacement of an entire central control system when only one portion of a
central HVAC system is replaced.

Add new text as follows:


C503.3.4 Mechanical system acceptance testing. Where an alteration requires
compliance with Section C403 or any of its subsections, mechanical systems that serve the
alteration shall comply with Sections C408.2.2, C408.2.3 and C408.2.5.
Exceptions:
1. Mechanical systems and service water heater systems in buildings where the total
mechanical equipment capacity is less than 480,000 Btu/h (140.7 kW) cooling
capacity and 600,000 Btu/h (175.8 kW) combined service water-heating and
space-heating capacity.
2. Systems included in Section C403.5 that serve individual dwelling units and
sleeping units.
Retro-commissioning and building re-tuning is generally accepted as one of the most cost-effecting
energy efficiency measures for existing buildings. Average savings for building re-tuning is 12%, and
studies have found savings as high as 52%. However, the IECC only requires acceptance testing of new
portions of altered systems. This section requires an altered system to meet the relevant Sections of C408
for acceptance testing to ensure that the altered system is operating as intended.
Jurisdictions with Building Performance Standards (BPS) could replace the system capacity threshold with
the BPS application threshold to align the BPS and the energy code more fully. Most BPS are triggered
based on building size. Where this is the case, exception #1 would be replaced with the following:
1. Buildings with a gross floor area less than [SQUARE FOOTAGE
THRESHOLD OF THE BPS].

Where BPS or other policies have other triggers that may be important, exceptions can be further tailored.

COMMERCIAL OVERLAY (ALL-ELECTRIC) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 21
Add new text as follows:
C503.3.5 Furnace replacement. Where an existing furnace is replaced with new equipment
to provide space heating, that new equipment shall be an electric heat pump system.

This section requires electrification of space heating at equipment replacement, but only for furnaces.
Furnaces are generally one of the easier kinds of combustion space heating equipment to electrify since
they can generally be replaced with a heat pump connected to the same air distribution system. This
section requires electrification of space heating at equipment replacement, but only for furnaces.

Add new text as follows:


C503.3.6 Cooling equipment. New and replacement unitary air conditioners shall be
electric heat pump equipment sized and configured to provide both space cooling and
space heating. Any existing space heating systems that serve the same zone as the new
equipment shall be configured as supplementary heat in accordance with Section C501.7.
Unitary air conditioners are essentially cooling-only heat pumps. AC replacement therefore provides a
valuable opportunity to electrify or partially electrify space heating. This section requires that when AC
equipment is replaced that it gets replaced with a heat pump that is configured to also provide heating. It
also requires that any existing heating system be reconfigured as supplementary heating (see Section
C501.7). This allows existing heating equipment to remain as a backup heating system, which is
particularly important in buildings that are required to have emergency backup power for space heating
and to ease the transition of some jurisdictions policies to all-electric renovations.

Add new text as follows:


C503.3.7 Cooking equipment. Combustion equipment used for cooking shall not be
permitted in spaces undergoing an alteration.
This provision leverages an alteration to a space to require the electrification of any combustion cooking
equipment in that space. In commercial buildings, this would apply to domestic cooking equipment in
multifamily and other dwelling units, commercial kitchens, and cooking equipment in other spaces like
kitchenettes and community rooms. In the case of multifamily dwelling units and commercial kitchens,
this could be a substantial project. This provision can be limited by adding targeted exceptions for R-2
occupancies (multifamily units) or commercial cooking appliances (commercial kitchens). While these
exceptions would reduce market resistance, they would also remove most of the impact of the provision.

Add new text as follows:


C503.4.1 Service hot water system acceptance testing. Where an alteration requires
compliance with Section C404 or any of its subsections, service hot water systems that
serve the alteration shall comply with Sections C408.2.3 and C408.2.5.

22 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE COMMERCIAL OVERLAY (ALL-ELECTRIC)
Exceptions:
1. Service water heater systems in buildings where the total mechanical equipment
capacity is less than 600,000 Btu/h (175.8 kW) combined service water-heating
and space-heating capacity.
2. Systems included in Section C403.5 that serve individual dwelling units and
sleeping units.

Retro-commissioning and building re-tuning is generally accepted as one of the most cost-effecting
energy efficiency measures for existing buildings. Average savings for building re-tuning is 12%, and
studies have found savings as high as 52%. However, the IECC only requires acceptance testing of new
portions of altered systems. This section requires an altered system to meet the relevant Sections of C408
for acceptance testing to ensure that the altered system is operating as intended.
Jurisdictions with Building Performance Standards (BPS) could replace the system capacity threshold with
the BPS application threshold instead to align the BPS and the energy code more fully. Most BPS are
triggered based on building size. Where this is the case, exception #1 would be replaced with the following:
1. Buildings with a gross floor area less than [SQUARE FOOTAGE
THRESHOLD OF THE BPS].

Where BPS or other policies have other triggers that may be important, exceptions can be further tailored.

Add new text as follows:


C503.4.2 Service water heating equipment. Where service water heating equipment is
added or replaced, new service hot water equipment shall be electric heat pump equipment.
Exceptions:
1. Equipment with an input rating greater than 300,000 Btu/h.
2. Electric storage water heaters with a rated storage volume of less than 20 gallons
(75.7 liters) and a rated input of less than 5kW.
3. Instantaneous electric water heaters located within 10 feet of the point of use.
4. Electric resistance equipment where not less than 75 percent of the annual service
water-heating requirement is provided by an on-site renewable energy system not
used to meet any other provision of this code.
5. Water heaters that serve end-uses that require water temperature of 150°F
(65.6°C) or hotter.
6. Water heaters located on the exterior of the building.
7. Where it has been demonstrated to the code official that the dimensions or
structural capacity of the space in which the water heater is located cannot
accommodate a heat pump water heater sized to meet the service hot water load.

COMMERCIAL OVERLAY (ALL-ELECTRIC) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 23
This provision requires a heat pump water heater to be installed whenever combustion water heater
equipment is replaced. HPWHs can be more difficult to incorporate into existing buildings; therefore, the
section has some important exemptions:
1. Equipment with an input rating greater than 300,000 BTU/h is exempted. The technical and cost
obstacles for water heating electrification are different for different kinds of water heating
equipment. Large central boilers will often pose some of the greatest technical and cost
challenges for electrification, so they are exempted. 300,000 BTU/h corresponds to the size
division used for electrification readiness in the Building Decarbonization Code and will
generally only apply to storage water heaters, instantaneous water heaters and small boilers.
2. Small electric resistance storage water heaters. These will have small loads and there aren’t
HPWH alternatives for them, so it is reasonable to allow them as electric resistance water heaters.
3. Instantaneous resistance water heaters used in point-of-use applications. The loads from these
will also generally be very low.
4. There is a blanket exemption for electric resistance water heating where 75% of the annual water
heating load is served by onsite renewable energy (most likely solar thermal or PV). This
provides flexibility and the pairing of dedicated renewable energy with electric resistance water
heating creates a system with total efficiency similar to a HPWH.
5. High-temperature applications are exempted since high temperature HPWHs are just now
coming on the market and don’t have broad market penetration.
6. Some instantaneous gas water heaters are rated for exterior locations and are located outside the
building. There are currently not good HPWH options for these installations, so they’ve been exempted.
7. Buildings with space configuration constraints that prohibit a HPWH retrofit in existing space
configurations. This will require substantiating the limitation with the code official, effectively
requiring code official approval.
If a jurisdiction finds that requiring HPWHs is not a viable option, this section can be replaced with an
alternative that only requires electrification (below), which would allow electric resistance options.

Alternate add new text as follows:


C503.4.2 Service water heating equipment. Where service water heating equipment is
added or replaced, new service hot water equipment shall not be combustion equipment.
Exception: Equipment with an input rating greater than 300,000 Btu/h .
Although such an approach would be more flexible, it also allows for electric resistance equipment,
which can have serious implications for carbon emissions and energy affordability. This approach should
only be chosen in jurisdictions served by an electricity supply that has a carbon intensity comparable to
onsite natural gas combustion. Additionally, the utility cost implications—particularly for equipment that
serves residential occupancies—should be analyzed in order to ensure this requirement will not have an
unacceptably adverse effect on utility bills. Replacement of combustion equipment with electric resistance
equipment will also exacerbate the building electrical capacity issues for electrification.

24 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE COMMERCIAL OVERLAY (ALL-ELECTRIC)
Revise text as follows:
C503.5 Lighting and power systems. New lighting and power systems that are part of the
alteration shall comply with Sections C405 and C408.
This minor change adds “power” to the title and scope of C503.5 so that decarbonization requirements
related to electrical power can be added to the section.

Add new text as follows:


C503.5.1 Interior Lighting and Controls. New and existing lighting in the
alteration shall be provided with controls that comply with Section C405.2.
Exceptions:
1. Where the size or configuration of an interior spaces is not altered
2. Where less than 50 percent of the luminaires in the space are replaced
The IECC’s requirements for lighting controls only apply to new controls, even when substantial changes
are made to a lighting system. In some older buildings, lighting may not have any controls at all. Lighting
alterations therefore provide a valuable opportunity to introduce or upgrade lighting controls. This
section requires lighting controls to meet current control requirements in certain, more substantial
lighting retrofits.

Add new text as follows:


C503.5.2 Lighting acceptance testing. Where an alteration requires compliance with
Section C405 or any of its subsections, the registered design professional or approved
agency shall provide a report in accordance with section C408.3.2.3 demonstrating that
the new and existing lighting control systems that serve the alteration have been tested in
accordance with the following:
1. Verify that manual controls function.
2. Verify that occupancy and vacancy sensors automatically turn off the lights when
spaces are unoccupied.
3. Verify that time switch controls are functioning, set to the correct day and time,
programmed with scheduled off times, and provided with new backup batteries
(where applicable).
While best practices for any lighting project include ensuring that lighting controls are operating
properly, the code is only required new controls. New luminaires do not trigger control testing. This
provision ensures that lighting controls will be receive basic functional testing whenever a lighting
system is altered. This section is based on the acceptance testing requirements for lighting in Section
C408 but has tailored for existing controls since some of those requirements are only appropriate for new
buildings or new controls.

COMMERCIAL OVERLAY (ALL-ELECTRIC) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 25
Add new text as follows:
C503.5.3 Combustion lighting. New and replacement gas lighting shall not be permitted
as part of an alteration.
Gas lighting is not common but is still used for decorative purposes. This provision prohibits the
installation of new or replacement gas lighting. There is a very limited application of historic gas lighting
to establish historically accurate lighting that would still be allowed under the accommodations for
historic buildings in C501.6.

Add new text as follows:


C503.5.4 Electrical Service replacement. Where a building electrical service is
replaced, the new electrical service shall include additional electrical capacity for the
following as applicable:
1. Replacement of combustion equipment used for space heating with electric heat
pump equipment or reverse-cycle chiller sized for the heating load of the building
in accordance with C403.3.1 based on the existing building features
2. Replacement of combustion equipment used for water heating with electric heat
pump equipment sized for the service hot water load of the building
3. Replacement of combustion equipment used for cooking with electric cooking
equipment
4. Replacement of combustion equipment used for clothes drying with electric
equipment
5. Renewable energy infrastructure in accordance with Section C405.13
6. Sufficient electric capacity for all parking facilities served by the electrical
service to comply with Section C405.14 as a new parking facility. For the
purposes of compliance with this section, sizing shall be permitted to be based on
the capacity requirements of EVSE spaces served by an ALMS.
7. Energy storage infrastructure in accordance with Section C405.15.1
One potential significant cost in electrification retrofit projects is electrical service replacement. This
section ensures that if a building service is being replaced that it must be sized for the full electrification
of combustion equipment in the building—space heating, water heating, cooking and clothes drying—and
for the addition of the onsite renewable systems, EVCI and energy storage in the future. “Electrification-
sizing” the electrical service at the time of normal replacement is the most cost-effective approach to
providing sufficient capacity for individual electrification retrofits. This will remove that barrier for
future electrification retrofits.
Where jurisdictions are concerned with increased costs for these upgrades before the service may be put
to full use, several options are available to modify the language. First, the addition of new construction
quantities of EV charging capacity can be significant. Item 6 could be altered to only require electrical
capacity for a smaller percentage of EV charging spaces. Second, exceptions can be specifically crafted
to address the cost implications of such an upgrade.

26 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE COMMERCIAL OVERLAY (ALL-ELECTRIC)
Alternate add new text as follows:
Exception: Where it has been demonstrated to the code official that compliance with
this section will result in increased costs for electrical utility service be charged to the
building owner that create a substantial burden, the electrical service size shall be
permitted to be reduced to a size that will not increase utility infrastructure costs
charged to the building owner.

This exception has been crafted to provide discretion to the code official that the cost is not simply
increased but will show a substantial burden on the building owner. While this phrasing may be widely
interpreted, it is suggested that jurisdictions adopting this exception work to tailor this language to be
more prescriptive and appropriate to their local considerations.

Add new text as follows:


C503.5.5 Onsite renewable energy. Substantial improvements and alterations that
include roof replacements of more than 75 percent of the total roof area of the building,
the building or building site shall comply with Section C405.13.
Exception: Where roof replacements do not alter the existing structure and it has
been demonstrated to the code official that the existing structure cannot support the
addition of solar panels.
This provision requires roof replacement projects to be paired with the installation of an onsite
renewable energy system. There are different kinds of re-roofing projects. A roof recover only involves
putting a new layer of roofing material on top of existing roofing. A roof replacement includes the
removal of old roofing material, repair of exposed sheathing and installation of a new roof. Roof
replacements provide an advantageous opportunity to install an onsite renewable energy system like a
photovoltaic array. It exposes the roof structure under the roof cover, providing a clearer picture of the
condition and configuration of the roof structure. It also presents a more cost-effective time to make
structural improvements. It synchronizes the service life of the roof and the renewable energy system,
eliminating concerns about the need to repair a roof under the system. Synchronizing roof replacement
and rooftop renewable energy systems also reduces costs as both projects can often utilize the same
onsite construction and safety equipment.
If there is pushback to using roof replacement as a code trigger for the onsite renewable energy system,
substantial improvement could be used as a standalone trigger instead.

Alternate add new text as follows:


C503.5.5 Onsite renewable energy. Substantial improvements shall comply with Section
C405.13.
This would only require the renewable system when the building is undergoing a major renovation, as
substantial improvement is defined, giving the opportunity for reinforcing structure to be added to
accommodate future solar installations.

COMMERCIAL OVERLAY (ALL-ELECTRIC) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 27
Add new text as follows:
C503.5.6 Electric vehicle charging infrastructure. Parking facilities serving substantial
improvements shall comply with Section C405.14 as a new parking facility. All other
alterations shall be provided with electric vehicle parking infrastructure in accordance
with this section.
There are several building lifecycle events that support the addition of EV charging to existing sites or the
addition of electrical infrastructure to support future EV charging retrofits. This top section requires that
parking facilities that serve substantial improvements be retrofit to fully comply with the EV charging
requirements for new construction. All other alterations are directed to the subsections that include
targeted opportunistic electrical infrastructure upgrades during certain kinds of alterations.
C503.5.6.1 New parking facilities. New parking facilities and new parking
spaces added to existing parking facilities shall comply with Section C405.14
based on the number of new parking spaces.
This section makes explicitly clear that new parking facilities are subject to the EVCI requirements of
C405.14. This section may not be strictly necessary, but it ensures that there is no ambiguity in the code.
C503.5.6.2 Alterations to parking lots. Where more than 25% of the paving of
a parking lot is removed, the affected parking spaces shall be EV-capable spaces,
up to the total number of EV-capable spaces indicated in Table C405.14 based on
the total number of parking spaces in the parking lot. Where the parking lot
serves more than one occupancy type, the number of required EV-capable spaces
shall be based on a weighted average of the different occupancies. EV-capable
spaces shall be provided with raceway in accordance with the following:
1. Continuous between a junction box or outlet located within 3 feet (914
mm) of the parking space and an electrical panel serving the area of the
parking space or a space containing an electrical panel serving the area of
the parking space.
2. The raceway shall be sized and rated to accommodate a 40-amp, 208/240-
volt branch circuit and have a minimum nominal trade size of 1 inch.
3. Both ends of the raceway shall have labels stating “For future electric
vehicle charging”
Parking lot repaving is a cost effective time to undertake the retrenching of a parking lot that EVCI
retrofits often require. The paving material is already being removed and replaced, which limits the cost
of retrofitting a parking lot to only the cost of the retrenching. This section leverages these parking lot
repaving projects to introduce raceways for EV-Capable spaces. It sets a minimum threshold for paving
of 25% to ensure that the requirement is not triggered by simple repair projects. It also only includes
requirements for the raceway component of EV-Capable spaces, and not other components such as panel
capacity or physical space since those are not generally part of the scope of a re-paving project. As such,
it only requires the raceways to get into proximity of the panel and not connect as is required in new
construction. The section also sets a cap for the number of spaces that need to be provided with this
raceway, so that a retrofit project would not need to provide more EV-Capable spaces than are required
of new construction in C405.14.

28 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE COMMERCIAL OVERLAY (ALL-ELECTRIC)
C503.5.6.3 Alterations to parking structure electrical service. Where the
electrical service serving a parking garage is replaced, the electrical service shall
be sized to provide capacity for the parking garage to meet the requirements of
Section C405.14 as a new parking facility. For the purposes of compliance with
this section, sizing shall be permitted to be based on the capacity requirements of
EVSE spaces served by an ALMS.
Parking garages sometimes have independent electrical service connections and may not be captured by
the service upgrade requirements in Section C403.5.4 above. This ensures that parking garage electrical
service replacements are sized to accommodate an EV charging retrofit.

Add new text as follows:


C503.6 Additional energy efficiency credits. Substantial energy alterations shall comply with
Sections C506 in accordance with this section. All-electric buildings shall achieve a total of 5
credits and mixed-fuel buildings shall achieve a total of 10 credits.
Exceptions:
1. Alterations that are part of an addition complying with section C502.
2. Alterations that comply with Section C407.
3. Alterations that comply with Section C503.1.2.
This section works with the new section C506 (see below for more) to bring additional energy efficiency
through implementing the additional efficiency credits in C406 in substantial energy alterations.
Substantial energy alterations are defined in a way that they are projects that impact multiple building
energy systems, which creates multiple opportunities for acquiring credits from C406. The section
requires 5 credits in alterations to all-electric buildings—half of the credit target for new construction—
and 10 credits for mixed-fuel buildings. It includes a series of important exceptions:
1. An exception that reflects the allowance for alterations and additions to comply together under
Section C502 when they are part of the same project (see Section C502.6 above).
2. An exception for buildings that model using Section C407.
3. An exception for substantial improvements that comply with the EUI requirements of C503.1.2.

C505 CHANG E OF OCCUPANCY


Add new text as follows:
C505.1.1 Combustion equipment. Spaces undergoing a change in occupancy shall not
be permitted to be served by combustion equipment.
Exception: Where a central heating or water heating system serving other dwelling
or sleeping units in the same building is extended to serve spaces converted to a
dwelling or sleeping unit.
This provision prohibits changes of occupancy from being served by combustion equipment. This would
effectively require changes of occupancy to result in an all-electric space or all-electric building.
Jurisdictions should bear in mind that this could discourage changes of occupancy and the efficiency
gains that would otherwise have been gained through a standard change of occupancy. Where these

COMMERCIAL OVERLAY (ALL-ELECTRIC) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 29
changes are likely to require substantial alterations, this type of trigger may be already sufficiently
captured in the alterations section of this code and this section could be removed by an adopting
jurisdiction. The exception presented allows for areas of multifamily buildings to extend existing systems
to areas that have undergone a change of occupancy to provide more dwelling or sleeping units. This
exception mirrors residential provisions.

C506 ADDITIONAL EFFICIENCY


Add new text as follows:
SECTION C506
ADDITIONAL EFFICIENCY CREDITS

C506.1 General. Where required by Section C502 or C503, credits shall be achieved from Tables
C406.1(1) through C406.1 (5) where the table is selected based on the use group of the building
and from credit calculations as specified in relevant subsections of Section C406. Where a
building contains multiple use groups, credits from each use group shall be weighted by floor area
of each group to determine the weighted average building credit. Credits from the tables of
calculation shall be achieved where a building complies with one or more of the following:
1. More efficient HVAC performance in accordance with Section C406.2.
2. Reduced lighting power in accordance with Section C406.3.
3. Enhanced lighting controls in accordance with Section C406.4.
4. On-site supply of renewable energy in accordance with Section C406.5.
5. Provision of a dedicated outdoor air system for certain space-conditioning equipment in
accordance with Section C406.6.
6. High-efficiency service water heating in accordance with Section C406.7.
7. Enhanced envelope performance in accordance with Section C406.8.
8. Reduced air infiltration in accordance with Section C406.9
9. Where not required by Section C405.12, include an energy monitoring system in
accordance with Section C406.10.
10. Where not required by Section C403.2.3, include a fault detection and diagnostics (FDD)
system in accordance with Section C406.11.
11. Efficient kitchen equipment in accordance with Section C406.12.
This new section C506 creates a framework to use the additional efficiency credits from Section C406 in
alterations and additions been leveraged to achieve additional energy savings in the IECC in a very
flexible way. Over the last several code cycles, Section C406 has b C506.1 serves the same role as
C406.1, directing projects how to achieve credits from the various credit options in sections C406.2-12.

Unlike Section C406, the credit target is not set in this section. Those targets are set in the companion
Sections C502.6 for additions and C503.6 for alterations. It makes sense to apply Section C406 to all new
buildings, but not all alterations and additions. Less substantial additions and alterations and certain

30 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE COMMERCIAL OVERLAY (ALL-ELECTRIC)
other existing projects with limited scopes are less likely to be able to accommodate a reasonable number
of credit options to meet a credit target. By setting the targets in Sections C502 and C503, the credit
targets can be selectively applied to only those projects where it is reasonable to incorporate Section
C406 credit options as a requirement. It also allows for a clear distinction between the unique exceptions
for additions and alterations.

Chapter 6 – Referenced Standards


Add new standard as follows:

ASHRAE
100---2018: Energy Efficiency in Existing Buildings
C503.1.2

COMMERCIAL OVERLAY (ALL-ELECTRIC) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 31
Existing Building
Decarbonization Code:

Commercial
Overlay
Mixed-Fuel
Commercial Overlay (Mixed-Fuel)
Chapter 1 – Scope and Application
C101 SCOPE AND G ENERAL REQUIREMENTS
Revise text as follows:
C101.3 Intent. This code shall regulate the design, and construction, repair, alteration, change of
occupancy, and additions of new and existing buildings for the effective use and conservation
reduction of greenhouse gas emissions and for the efficient production, use and storage of energy
over the useful life of each building. This code is intended to provide flexibility to permit the use of
innovative approaches and techniques to achieve this objective. This code is not intended to abridge
safety, health or environmental requirements contained in other applicable codes or ordinances.
Intent has been modified to push beyond simply the inclusion of considerations of greenhouse gas
emissions and production and storage of energy, to clearly emphasize the intent of the code to regulate
existing buildings.

Chapter 2 – Definitions
C202 GENERAL DEFINITIONS
Add new definitions as follows:
ELECTRIC EQUIPMENT. Any equipment or appliance used for space heating, service water
heating, cooking, clothes drying, or lighting that uses electricity as its sole source of energy.
This new definition for electric equipment is a parallel of the definition of “combustion equipment”
introduced in the Building Decarbonization Code.
ENERGY USE INTENSITY (EUI). An expression of building energy use in terms of net
energy divided by gross floor area.
EUI is an energy metric used in some performance-based energy policies, including many building
performance standards (BPS). It is included here to allow provisions of the Existing Building
Decarbonization Code integrate with BPSs. EUI is not currently defined in the suite of I-Codes, so it is
added here. If a jurisdiction already has a formal definition of EUI, particularly in a building
performance standard, then that definition should be integrated here as well.

SUBSTANTIAL ENERGY ALTERATION. An alteration that replacement of two or more of


the following:
1. 50% or more of the area of interior wall-covering material of the building thermal
envelope or fenestration.
2. 50% or more of the area of the exterior wall-covering material of the building thermal
envelope or fenestration.
3. Space-conditioning equipment constituting 50% or more of the total input capacity of the
space heating or space cooling equipment serving the building.

34 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE COMMERCIAL OVERLAY (MIXED-FUEL)
4. Water-heating equipment constituting 50% of more of the total input capacity of all the
water heating equipment serving the building.
5. 50% or more of the luminaires in the building
This new definition for substantial energy alteration is intended to capture projects that have the
opportunity to greatly increase efficiency by nature of their scope and clarify when certain requirements
related to the energy use of the building are triggered. By defining such scopes, confusion around generic
terms like major renovations and applicability of work classifications in the IEBC can be removed. Other
terms that define large-scale alterations such as Level III alteration or substantial improvement are not
specific to the energy systems. An alteration could cross their thresholds without having a significant
impact on the energy systems since they are based on metrics such as monetary value and reconfiguration
of spaces. Similarly, an alteration that has significant impact on the energy systems of the building may
not cross these other thresholds.
SUBSTANTIAL IMPROVEMENT. Any repair, reconstruction, rehabilitation, alteration,
addition or other improvement of a building or structure, the cost of which equals or exceeds 50
percent of the market value of the structure before the improvement or repair is started. If the
structure has sustained substantial damage, any repairs are considered substantial improvement
regardless of the actual repair work performed. The term does not, however, include either:
1. Any project for improvement of a building required to correct existing health, sanitary or
safety code violations identified by the building official and that are the minimum
necessary to assure safe living conditions.
2. Any alteration of a historic structure provided that the alteration will not preclude the
structure’s continued designation as a historic structure.
The definition of substantial improvement comes from the IBC and IEBC. The term generally aligns with
vernacular use of “major renovation,” which is not defined in code. It is used as a threshold for when
certain flood protection requirements are triggered for existing building alterations. Since it is based on
the monetary value of the alteration, it sets a useful threshold for introducing additional decarbonization
requirements for large alterations.
In addition, the Existing Building Decarbonization Code leverages definitions from the Building
Decarbonization Code including:
ALL-ELECTRIC BUILDING
APPLIANCE
COMBUSTION EQUIPMENT
COMMERCIAL COOKING APPLIANCES
ELECTRIC VEHICLE (EV)
EQUIPMENT
EV-CAPABLE SPACE
FUEL GAS
The use of these terms throughout assumes that adopting jurisdictions will adopt the Building
Decarbonization Code alongside this existing building overlay.

COMMERCIAL OVERLAY (MIXED-FUEL) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 35
Chapter 5 – Existing Buildings
C501 GENERAL
Add new text as follows:
C501.6 Requirements for combustion equipment. New and replacement combustion equipment
in additions, alterations and changes of occupancy shall comply with this section.
This section creates an additional set of requirements for combustion equipment when it is allowed to be
installed in existing buildings. These requirements are intended to generally improve the emissions of the
equipment and the interior and exterior air quality.
C501.6.1 Replacement of electric equipment. Combustion equipment shall not be
permitted to be installed to replace electric equipment.

The largest cost for existing buildings to electrify is to install the infrastructure to swap the equipment.
Where electric appliances and equipment already exist, it is critical to maintain the electric energy source
and not install new fossil fuel infrastructure.

C5061.6.2 Phase out documentation. Permit applications for projects installing new and
replacement combustion equipment or retaining existing combustion equipment serving space
heating and water heating shall include a plan for the future replacement of the combustion
equipment with electric equipment. The documentation shall include the following:
1. Calculations of the electric load required by the replacement electric equipment
and of the available electric capacity of the building.
2. Identification of any existing onsite electrical infrastructure, including but not
limited to transformers, switchgear, electrical panels and conductors, that will
need to be altered to accommodate the replacement electric equipment.
3. Floor plans identifying any spaces that will need to be reconfigured to
accommodate the replacement electric equipment.
Where replacements are made with combustion equipment, building owners should understand the need for
long term phase out and switch to electric equipment to avoid potential abandoned assets. Jurisdictions
could also expand this section to include specifics related to other policies such as appliance emission
standards or replacement policies targeting specific dates for combustion equipment phase out.

C501.6.3 Sealed combustion and direct venting. Combustion equipment used for space
and water heating shall be direct vent or sealed combustion.

Space and water heating equipment that utilize direct venting or sealed combustion techniques improve
the efficiency of the equipment and the indoor air quality of a home by ensuring that hazardous
byproducts of the combustion process are vented outside of the living space.

C501.6.4 Low NOx furnaces. Warm-air furnaces shall have no more than 14 nanograms
of nitrogen dioxide emissions per joule of useful heat delivered to the heated space.

Exception: Equipment with an AFUE of not less than 90 percent.

36 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE COMMERCIAL OVERLAY (MIXED-FUEL)
This requirement also limits the nitrogen dioxide emissions from these appliances. Appliances in
buildings emit twice the amount of NOx as power plants, a major pollutant which causes asthma. The air
quality limit is based on NOx emission limits imposed by California’s South Coast Air Quality
Management District and the San Joaquin Valley Air Pollution Control District. An exception is given to
equipment that exhibit an AFUE of 90 percent or more because those systems use direct vent or sealed
combustion technology and comply with the NOx limit.

C501.6.5 Fuel gas pipe testing. All fuel gas piping that serves new or replacement
combustion equipment shall be tested as a new installation in accordance with Section
406 of the International Fuel Gas Code.
Exceptions:
1. For the purposes of demonstrating compliance with this section, unexposed pipe
joints and welds shall not be required to be exposed for examination during the test.
2. For the purposes of demonstrating compliance with this section, where it has
been demonstrated to the code official that the fuel gas piping has met the
requirements of this section within the previous five years.
3. Where compliance with this section would require interruption of fuel gas supply
to combustion equipment that serves other tenant spaces or other dwelling units,
provided all exposed pipe joints of the piping subject to the requirements of this
section have been inspected for leaks by means of an approved gas detector, a
noncorrosive leak detection fluid or other approved leak detection method once
the equipment has been placed in operation.
Gas piping degrades over time, creating the possibility of natural gas leakage. Even though the natural
gas is treated with mercaptan to give it that rotten egg smell, small leaks may go undetected, particularly
in buildings where pipes are not exposed and older buildings that are likely to have envelopes that are
less tight than newer construction. According to US DOE, building leakage accounts for nearly 27% of
the natural gas leakage in the US natural gas distribution system. 8 Leaking natural gas represents a loss
in energy, and even small leaks can add up over long periods of time. Additionally, natural gas is also a
potent Green House Gas, with over 86 times the global warming potential of CO2 on a short-term basis.
The installation of new gas equipment provides an ideal time to test gas pipe leakage. Contractors are already
on site and the gas will often be partially or fully turned off for the new equipment installation. Additionally,
new equipment installation can disturb and inflict additional stresses on existing piping, creating opportunities
for the formation of new leaks where existing natural gas piping has weakened but not previously failed
This provision requires that existing fuel gas piping be tested like a new installation according the
International Fuel Gas Code (IFGC). It includes targeted exceptions for elements of the IFGC testing
methodology that is not appropriate for existing buildings. It also includes an exception for piping that
has been tested in the last five years in order to prevent repeated testing. Finally, it includes an exception
to ensure that testing requirements don’t necessitate other tenants losing service, which could be a
considerable in larger buildings with multiple tenant spaces. In those cases, it only requires visual
inspection of the exposed joints with a testing fluid.

8
“Natural Gas Infrastructure Modernization Programs at Local Distribution Companies: Key Issues and Considerations.” US DOE,
Office of Energy Policy and Systems Analysis. Washington DC, 2017.

COMMERCIAL OVERLAY (MIXED-FUEL) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 37
Add new text as follows:
C501.7 Heat pump supplementary combustion equipment. Heat pumps having combustion
equipment and electric resistance equipment for supplementary space or water heating shall have
controls that limit supplemental heat operation to only those times when one of the following applies:

1. The heat pump is operating in defrost mode.


2. The vapor compression cycle malfunctions.
3. For space heating systems, the thermostat malfunctions.
4. For space heating systems, the vapor compression cycle cannot provide the necessary
heating energy to satisfy the thermostat setting.
5. For water heating, the heat pump water heater cannot maintain an output water
temperature of at least 120°F (49°C)
New supplementary space and water heating systems for heat pump equipment shall not be permitted
to have a heating input capacity greater than the heating input capacity of the heat pump equipment.

Supplementary heating systems are effectively back-up systems intended to provide heating if the primary
heat pump system fails, if the operating conditions (heating demand, temperature around the heat pump
compressor, etc.) exceed the ability of the heat pump to effectively, or cost-effectively, provide heating.
Designers sometimes utilize “hybrid heat” systems where combustion equipment provides the
supplementary heat to address these situations.
This new section creates a version of the supplementary heating equipment control requirements in Section
C403 that is customized for existing buildings. It addresses both space and water heating applications and
ensures that any combustion heating equipment used for supplementary heat is only used when the heat
pump system is unable to fully meet the buildings heating needs (the language in C403 already addresses
electric resistance supplementary heat).

C502 ADDITIONS
Revise text as follows:
C502.1 General. Additions to an existing building, building system or portion thereof shall
conform to the provisions of this code as those provisions relate to new construction without
requiring the unaltered portion of the existing building or building system to comply with this
code. Additions shall not create an unsafe or hazardous condition or overload existing building
systems. An addition shall be deemed to comply with this code if the addition alone complies or
if the existing building and addition comply with this code as a single building. Additions shall
comply with Sections C502.2 through C502.5.
These edits implement the restructuring discussed above in the introduction. The content of the sections is
unaffected. The compliance language from the original Section C502.3 has been moved here.
The requirement in C502.1 for additions to meet the requirements for new construction mean that additions
will be subject to the requirements in the Building Decarbonization Code for demand responsive thermostats
and water heaters, onsite renewable energy, electrification readiness, energy storage infrastructure, etc.

38 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE COMMERCIAL OVERLAY (MIXED-FUEL)
Add new text as follows:
C502.1.1 Combustion equipment. Additions shall not be permitted to contain
combustion equipment and new equipment installed to serve additions shall not be
combustion equipment. Where systems with combustion equipment are extended into an
addition, the existing building and addition together shall use no more fossil fuel energy
than the existing building alone.

This section requires additions to effectively be all-electric by prohibiting them from containing or being
served by new combustion equipment additions combustion equipment. When additions are added to
existing buildings, space and water heating systems are often extended into the new addition. This
provision does allow the extension of systems that utilize combustion equipment into the addition. In
order to ensure that the addition does not result in higher consumption of fossil fuels, the provision also
requires that this extension doesn’t result in an increase in combustion energy. In order to extend a
system with combustion equipment into an addition, the efficiency of the existing building would need to
be improved to offset the increased consumption from the addition.

Add new text as follows:


C502.1.2 Combustion equipment requirements. New combustion equipment serving
additions shall comply with section C501.6.
This section ensures that combustion equipment installed in additions is both more efficient and less likely
to worsen indoor air quality as required in Section C501.6.

Add new text as follows:


C502.1.3 Building Performance Standards. Where an addition to a building makes it
subject to [OFFICIAL NAME OF THE LOCAL BUILDING PERFORMANCE
STANDARD], the permit application for the addition shall include a report that includes
the following:
1. The current or last reported EUI of the building
2. The performance targets from [NAME OF THE LOCAL BUILDING
PERFORMANCE STANDARD] that will be applicable to the building within
five years from the date of the permit application
Where the current or last reported EUI exceeds the performance targets that will be
applicable in the next five years, the report shall also include a plan describing how the
building will be brought into compliance. The report shall include energy efficiency
upgrades and operational improvements that will be made to the building before the
applicable target goes into effect and the impact of the alteration under permit review.

COMMERCIAL OVERLAY (MIXED-FUEL) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 39
Exceptions:
1. Where the total building performance of the building with the alteration
determined in accordance with Section C407 demonstrates compliance with the
performance targets identified in the report required by this section.
2. Additions that increase the conditioned floor area of the building by less than
10% and install no new space conditioning or water heating equipment.
In jurisdictions with a BPS it is important that all work on existing buildings support and reinforce the
policy goals. Additions that either push a building into covered building status or are part of a building is
already subject to the BPS that are undertaken without consideration of impending BPS performance
targets represent a significant missed opportunity. This section requires that consideration by creating a
requirement that permit applications include the building’s current performance and any BPS performance
targets that will be in effect in the next 5 years, the typical compliance cycle for US-based BPS. Where a
building does not already meet those targets, it will be required to also submit what is effectively a plan for
compliance with the BPS. This will ensure that project teams are thinking about a proposed alteration
within the larger context of what will be required to meet up-coming BPS requirements.
The exceptions allow the compliance path to be avoided when the alteration is complying by performance
modeling and that modeling shows that the alteration will bring the building into compliance with the BPS
performance target, and for additions that will in and of themselves not create a major energy impact.
It may be necessary to modify the language in this provision to align with the terminology that is used in the
official BPS regulation to maximize correlation and usability. For example, the provision can be modified to
align with a carbon-based BPS by replacing “EUI” with “CUI” throughout and adding the following definition:
CARBON USE INTENSITY (CUI). An expression of building carbon emissions in terms of the
equivalent carbon emissions of the net energy divided by gross floor area.
This definition defines a carbon use intensity that parallels the definition of EUI. It is a carbon metric
where carbon emissions are divided by gross floor area in order to compare the emissions of different
buildings or assess the performance a building’s carbon emissions against a target.

Revise text and numbering as follows:


C502.2 Change in space conditioning. Any nonconditioned or low-energy space that is altered
to become conditioned space shall be required to comply with Section C502.
Exceptions:
1. Where the component performance alternative in Section C402.1.5 is used to comply
with this section, the proposed UA shall be not greater than 110 percent of the target UA.
2. Where the total building performance option in Section C407 is used to comply with this
section, the annual energy cost of the proposed design shall be not greater than 110
percent of the annual energy cost otherwise permitted by Section C407.2.
This section is moved to C503, the alterations section. It is reasonable to make conversions of
unconditioned space to conditioned space subject to the requirements for an addition, but they are
technically alterations. Code users could naturally skip over the additions section, go straight to the
alterations section, and miss this requirement. Moving the provision improves clarity and usability.

40 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE COMMERCIAL OVERLAY (MIXED-FUEL)
Revise text and numbering as follows:
C502.3 Compliance Additions shall comply with Sections C502.3.1 through C502.3.6.2.
C502.2 Building Envelope. New building envelope assemblies that are part of the addition shall
comply with Sections C502.2.1 through C502.2.2.
C502.3.1 C502.2.1 Vertical fenestration area.
C502.3.2 C502.2.2 Skylight area.
C502.3.3 C502.3 Building mechanical systems.
These edits implement the restructuring discussed above in the introduction. The content of the
subsections is unaffected. The compliance language from the original Section C502.3 has been moved to
C503.1 and a new C502.2 has been introduced for the envelope subsections.

Add new text as follows:


C502.3.1 Space heating equipment. New space heating equipment in additions shall be
electric heat pump equipment.
Exceptions:
1. Electric resistance supplementary heat in accordance with Section C403.4.1.1
2. Up to 5W of electric resistance heat per square foot of conditioned floor area
in the addition
3. Combustion equipment used for supplementary heat in accordance with
Section C501.7.

Requiring space heating installed during an addition to be electric will reduce carbon emissions and
improve air quality in homes. Heat pumps have been shown to be technically effective in all climate
zones, and cold-climate heat pump technology continues to improve, providing heating with a COP of
more than 3 above 5°F. 9
Exceptions are included for electric resistance supplementary heat and for up to 5W of electric resistance
heat per square foot of conditioned floor area. The latter creates a budget for electric resistance heat that
can be used for spot heating, small spaces, freeze protection and heat pump VAV systems with terminal
electric resistance heat. 5W is a fairly low budget for these VAV systems that will require efficient design
parameters such as delivering higher temperature air to the terminal boxes during heating that minimize
the operation of the electric resistance coils. An exception for supplementary combustion heating
equipment is also included, allowing new combustion equipment to be installed in the addition as long as
it is only used as supplementary heat.

9
“Achieve Comfort and Reliable Performance with Cold-Climate Heat Pumps.” Zero Energy Project, 6 Feb. 2020,
https://zeroenergyproject.org/2020/01/22/achieve-comfort-and-reliable-performance-with-cold-climate-heat-
pumps/#:~:text=The%20Benefits%20of%20Heat%20Pumps%20in%20Cold%20Climates&text=Combustion%2Dbased%20hea
ting%20systems%20such,3%20at%205%C2%B0F.

COMMERCIAL OVERLAY (MIXED-FUEL) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 41
Revise text and numbering as follows:
C502.3.4 C502.4 Service water-heating systems.
C502.2.5 C502.4.1 Pools and inground permanently installed spas.
These edits implement the restructuring discussed above in the introduction. The content of the
sections is unaffected.

Add new text as follows:


C502.4.2 Heat Pump Water Heating. New water heaters in additions shall be electric
heat pump equipment.
Exceptions:
1. Supplementary water heating systems controlled in accordance with C501.7
2. Electric storage water heaters with a rated storage volume of less than 20 gallons
(75.7 liters) and a rated input of less than 5kW.
3. Instantaneous electric water heaters located within 10 feet of the point of use.
4. Electric resistance equipment where not less than 75 percent of the annual service
water-heating requirement is provided by an on-site renewable energy system not
used to meet any other provision of this code.
5. Water heaters that serve end-uses that require water temperature of 150°F
(65.6°C) or hotter.

Heat pump water heaters can be 4-6 times more efficient than their electric resistance and combustion
counterparts. This provision requires new water heaters in additions to be heat pump water heaters. It
includes a few key exceptions:
1. Supplementary water heating that can be any fuel type.
2. Small electric resistance storage water heaters. These will have small loads and there aren’t
HPWH alternatives for them, so it is reasonable to allow them as electric resistance water heaters.
3. Instantaneous resistance water heaters used in point-of-use applications. The loads from these
will also generally be very low.
4. There is a blanket exemption for electric resistance water heating where 75% of the annual water
heating load is served by onsite renewable energy (most likely solar thermal or PV). This
provides flexibility and the pairing of dedicated renewable energy with electric resistance water
heating creates a system with total efficiency similar to a HPWH.
5. High-temperature applications are exempted since high temperature HPWHs are just now
coming on the market and don’t have broad market penetration.

42 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE COMMERCIAL OVERLAY (MIXED-FUEL)
Revise text and numbering as follows:
C502.2.6 C502.5 Lighting and power systems.
C502.2.6.1 C502.5.1 Interior lighting power.
C502.2.6.2 C502.5.2 Exterior lighting power.
These edits implement the restructuring discussed above in the introduction. The content of the
subsections is unaffected. The compliance language from the original Section C502.3 has been moved to
C503.1 and a new C502.2 has been introduced for the envelope subsections.

Add new text as follows:


C502.5.3 Renewable energy infrastructure. Additions with a new roof shall be
provided with equipment for on-site renewable energy with a rated capacity of not less
than 0.25 W/ft² (2.7 W/m²) multiplied by the sum of the gross conditioned floor area of
the three largest floors of the addition.
Exceptions:
1. Additions that increase the conditioned floor area of the building by less than 10%.
2. Additions where an unshaded flat plate collector oriented towards the equator and
tilted at an angle from horizontal equal to the latitude receives an annual daily
average incident solar radiation less than 3.5 kWh/m²·day (1.1 kBtu/ft²·day).
3. Additions where more than 80 percent of the roof area is covered by any
combination of equipment other than for on-site renewable energy systems,
planters, vegetated space, skylights, or occupied roof deck.
4. Additions where more than 50 percent of roof area is shaded from direct beam
sunlight by natural objects or by structures that are not part of the building for
more than 2,500 annual hours between 8:00 AM and 4:00 PM.
Additions with roofs provide an opportunity to introduce renewable energy systems. The requirements in
the Building Decarbonization Code for renewable energy systems reference buildings and so don’t
capture additions. This section uses the addition to trigger the requirements. The size of the system is
based on the size of the addition, rather than the whole building. The new section includes exceptions that
are paralleled from the new construction requirements. These exempt small additions, roofs without good
solar access and roofs that are already utilized for other uses.

Add new text as follows:


C502.5.4 Electric vehicle charging infrastructure. New parking facilities and new
parking spaces added to existing parking facilities shall comply with Section C405.14
based on the number of new parking spaces.
This section requires new parking facilities to meet the EV charging requirements in the new construction
portion of the Building Decarbonization Code. While this is implicitly required by Section C501, the
addition of this section makes it explicit for greater clarity and enforceability.

COMMERCIAL OVERLAY (MIXED-FUEL) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 43
Add new text as follows:
C502.6 Additional energy efficiency credits. Additions shall achieve credits in accordance with
Section C506. All-electric buildings shall be required to 10 credits and mixed-fuel buildings shall
be required to select 15 credits. Alterations to the existing building that are not part of an
addition, but permitted with an addition, may be used to achieve the required credits.
Exceptions:
1. Buildings in Utility and Miscellaneous Group U, Storage Group S, Factory Group F,
High-Hazard Group H
2. Additions less than 1,000 ft2 (92.9 m2) and less than 50% of existing floor area.
3. Additions that do not include the addition or replacement of equipment covered by
Section C403.3 or C404.2 that achieve a total of 5 credits.
4. Additions that do not contain conditioned space that achieve a total of 5 credits.
5. Buildings in Residential Group R and Institutional Groups I in climate zones 3C, 4B, 4C,
5C that achieve a total of 5 credits
6. Where the addition alone or the existing building and addition together comply with
Section C407
This section works with the new Section C506 (see below for more) to bring additional energy efficiency
to additions through implementing the additional efficiency credits in Section C406 in “substantial”
additions. The section requires 10 credits in additions to all-electric buildings, just like new buildings,
and greater efficiency of 15 credits for additions to mixed-fuel buildings. It also includes a series of
important exceptions for occupancy types with low building loads, small additions and buildings that
comply with Section C407. It also requires only 5 credits in additions to certain building types in certain
climate zones that have fewer credit options available, additions that don’t include new HVAC or water
heating equipment and additions that do not include conditioned space.

C503 ALTERATIONS
Add new text as follows:
C503.1.1 Change in space conditioning. Any nonconditioned or low-energy space that
is altered to become conditioned space shall be required to comply with Section C502.
Exceptions:
1. Where the component performance alternative by Section C402.1.5 is used to
comply with this section, the proposed UA shall be not greater than 110 percent
of the target UA.
2. Where the total building performance option by Section C407 is used to comply
with this section, the annual energy cost of the proposed design shall be not greater
than 110 percent of the annual energy cost otherwise permitted by Section C407.2.

44 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE COMMERCIAL OVERLAY (MIXED-FUEL)
This content is located in the additions section in the model code (Section C502.2). As part of the restructuring
needed for this overlay, it has been relocated here since it describes an alteration project. The requirements
have not been changed, but the relocation will improve the usability and enforceability of the code.

Add new text as follows:


C503.1.2 Substantial improvement. Buildings undergoing substantial improvements
shall comply with Sections C402.5 and C405.16 and meet a site EUI by building type in
accordance with ASHRAE Standard 100 Table 7-2a.
Exception: Compliance with Standard 100 shall not be required where Group R-
occupancies achieve an ERI score of 80 or below without on-site renewable energy
included in accordance with RESNET/ICC 301, for each dwelling unit.
Substantial improvements are extensive alterations that have significant scope, large project budgets
relative to the value of the building and are more likely to already include major systems that could
include combustion equipment. The larger scopes and budgets of substantial improvements are likely to
occur infrequently within a building lifecycle and create the best opportunity to significantly increase
efficiency and establish full electric ready infrastructure for the building and its systems.

Add new text as follows:


C503.1.3 Requirements for combustion equipment. New combustion equipment
serving alterations shall comply with Section C501.6.
This section ensures that when combustion equipment is installed for water heating, it meets the
requirements for testing and increased safety for combustion equipment in C501.6.

Add new text as follows:


C503.1.4 Building Performance Standards. Where the building is subject to
[OFFICIAL NAME OF THE LOCAL BUILDING PERFORMANCE
STANDARD], the permit application for the alteration shall include a report that
includes the following:
1. The current or last reported EUI of the building
2. The performance targets from [NAME OF THE LOCAL BUILDING
PERFORMANCE STANDARD] that will be applicable to the building within
five years from the date of the permit application
Where the current or last reported EUI exceeds the performance targets that will be
applicable in the next five years, the report shall also include a plan describing how the
building will be brought into compliance. The report shall include energy efficiency
upgrades and operational improvements that will be made to the building before the
applicable target goes into effect and the impact of the alteration under permit review.

COMMERCIAL OVERLAY (MIXED-FUEL) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 45
Exception: Where the total building performance of the building with the alteration
determined in accordance with Section C407 demonstrates compliance with the
performance targets identified in the report required by this section.
In jurisdictions with a Building Performance Standard (BPS), it is important that all alterations
support and reinforce the BPS. Alterations that are undertaken without consideration of impending
BPS performance targets represent a significant missed opportunity. This section requires that
consideration by creating a requirement that permit applications include the building’s current
performance and any BPS performance targets that will be in effect in the next 5 years, the typical
compliance cycle for US-based BPS. Where a building does not already meet those targets, it will be
required to also submit what is effectively a plan for compliance with the BPS. This will ensure that
project teams are thinking about a proposed alteration within the larger context of what will be
required to meet up-coming BPS requirements.
The exception allows the compliance path to be avoided when the alteration is complying by performance
modeling and that modeling shows that the alteration will bring the building into compliance with the BPS
performance target.
It may be necessary to modify the language in this provision to align with the terminology that is used in
the official BPS regulation to maximize correlation and usability. For example, the provision can be
modified to align with a carbon-based BPS by replacing “EUI” with “CUI” throughout and adding the
following definition:

CARBON USE INTENSITY (CUI). An expression of building carbon emissions in terms of the
equivalent carbon emissions of the net energy divided by gross floor area.
This definition defines a carbon use intensity that parallels the definition of EUI. It is a carbon metric
where carbon emissions are divided by gross floor area in order to compare the emissions of different
buildings or assess the performance a building’s carbon emissions against a target.

Add new text as follows:


C503.3.2 System sizing. New heating and cooling equipment that is part of an alteration
shall be sized in accordance with Section C403.3.1 based on the existing building
features as modified by the alteration.
Exception: Where is has been demonstrated to the code official that compliance with
this section would result in heating or cooling equipment that is incompatible with
the rest of the heating or cooling system.

46 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE COMMERCIAL OVERLAY (MIXED-FUEL)
Space conditioning equipment is routinely oversized for its application. Even when equipment was sized
appropriately when it was installed, many buildings have undergone alterations, particularly energy
efficiency retrofits, that have changed the heating and cooling characteristics of the building. It is
reasonable to assume that the existing equipment sizing is more likely to be wrong than right, yet many
equipment replacements use existing system sizing to size new equipment. Oversized equipment is less
efficient, costs more to operate, costs more to install, provides lower levels of comfort and is less effective
at de-humidification.
This measure explicitly requires that new equipment installed as part of an alteration be sized based on
current building characteristics and loads, using current sizing standards. It provides an exception for
situations where right-sizing equipment may create an incompatibility with the rest of the system (as can
be the case with steam systems where boilers are sized to the radiators/convectors and not the building).

Add new text as follows:


C503.3.3 Controls. New heating and cooling equipment that are part of the alteration
shall be provided with controls that comply with Section C403.4.
Exception: Systems with direct digital control of individual zones reporting to a
central control panel
The IECC’s requirements for HVAC controls only apply to new controls. As a result, new equipment is
permitted to be controlled by existing controls that can fall far short of current code requirements. This
section requires new equipment to have code-compliant requirements. The exception ensures that this
section won’t trigger the replacement of an entire central control system when only one portion of a
central HVAC system is replaced.

Add new text as follows:


C503.3.4 Mechanical system acceptance testing. Where an alteration requires
compliance with Section C403 or any of its subsections, mechanical systems that serve the
alteration shall comply with Sections C408.2.2, C408.2.3 and C408.2.5.
Exceptions:
1. Mechanical systems and service water heater systems in buildings where the total
mechanical equipment capacity is less than 480,000 Btu/h (140.7 kW) cooling
capacity and 600,000 Btu/h (175.8 kW) combined service water-heating and
space-heating capacity.
2. Systems included in Section C403.5 that serve individual dwelling units and
sleeping units.

Retro-commissioning and building re-tuning is generally accepted as one of the most cost-effecting
energy efficiency measures for existing buildings. Average savings for building re-tuning is 12%, and
studies have found savings as high as 52%. However, the IECC only requires acceptance testing of new
portions of altered systems. This section requires an altered system to meet the relevant Sections of C408
for acceptance testing to ensure that the altered system is operating as intended.

COMMERCIAL OVERLAY (MIXED-FUEL) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 47
Jurisdictions with Building Performance Standards (BPS) could replace the system capacity threshold with
the BPS application threshold to align the BPS and the energy code more fully. Most BPS are triggered
based on building size. Where this is the case, exception #1 would be replaced with the following:
1. Buildings with a gross floor area less than [SQUARE FOOTAGE
THRESHOLD OF THE BPS].

Where BPS or other policies have other triggers that may be important, exceptions can be further tailored.

Add new text as follows:


C503.3.5 Combustion heating equipment. New combustion equipment used for space
heating that is part of the alteration shall comply with Section C501.6.
This ensures the installation of combustion space heating equipment that is both more efficient and less
likely to worsen indoor air quality as required in Section C501.6.

Add new text as follows:


C503.3.5.1 Partial electrification of space heating. New and replacement
combustion equipment used for space heating shall only be permitted to be
installed as supplementary heating controlled in accordance with C501.7.
Where there are technical barriers to the full electrification of a building’s space heating system, hybrid
heat systems that combine heat pumps with combustion equipment are an effective strategy to reduce
carbon emissions through improving the efficiency of the system and reducing onsite combustion
emissions. In these systems, a heat pump serves most of the heating loads and the combustion equipment
only operates when the heat pump is unable to keep up with heating demand, particularly during low
outdoor temperatures. By prohibiting new combustion equipment except as supplementary heat, this
section requires that existing combustion heating systems be converted to hybrid heat systems at
equipment replacement.

Add new text as follows:


C503.3.6 Cooling equipment. New and replacement unitary air conditioners shall be
electric heat pump equipment sized and configured to provide both space cooling and
space heating. Any existing space heating systems that serve the same zone as the new
equipment shall be configured as supplementary heat in accordance with Section C501.7.
Unitary air conditioners are essentially cooling-only heat pumps. AC replacement therefore provides a
valuable opportunity to electrify or partially electrify space heating. This section requires that when AC
equipment is replaced that it gets replaced with a heat pump that is configured to also provide heating. It
also requires that any existing heating system be reconfigured as supplementary heating (see Section
C501.7). This allows existing heating equipment to remain as a backup heating system, which is
particularly important in buildings that are required to have emergency backup power for space heating
and to ease the transition of some jurisdictions policies to all-electric renovations.

48 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE COMMERCIAL OVERLAY (MIXED-FUEL)
Add new text as follows:
C503.3.7 Cooking equipment. Alterations of spaces containing cooking equipment shall
comply with Section C405.16.4 and this section.
C503.3.7.1 Ventilation. Where a space that is part of the alteration includes
combustion equipment used for cooking, the cooking equipment shall be
provided with exhaust equipment that complies with Sections 505.2, 505.3 and
505.5 of the International Mechanical Code and the following:
1. The exhaust fan shall be sized to provide no less than 150 CFM of
intermittent airflow.
2. The cooking equipment shall be provided with makeup air at a rate
approximately equal to the exhaust air rate. Such makeup air systems
shall be equipped with a means of closure and shall be automatically
controlled to start and operate simultaneously with the exhaust system.
Exception: Commercial cooking appliances
Gas cooking can release levels of pollutants that, if they were measured outside, would violate the Clean
Air Act. 10 As a result, households with gas cooking have nearly three times the rate of treatment for
asthma. 11 Outside of commercial cooking equipment, the mechanical code has only limited ventilation
requirements for cooking, only requiring ventilation for the room and not the cooking appliance itself. It
also does not differentiate between gas and electric cooking, despite the significantly higher level of
pollutants from gas cooking. 12 Ventilation has not always been required in spaces with cooking, so many
existing buildings do not have any mechanical ventilation at all. This provision improves the health and
indoor air quality of buildings with gas cooking by requiring that spaces with combustion cooking that
undergo an alteration be equipped with appropriate ventilation for gas cooking. It requires exhaust
specifically at the cooking equipment, and not just the space. It also requires makeup air to ensure that
the exhaust fans that can effectively exhaust contaminants. The ventilation rate has been set at 150CFM.
This is higher than the requirement in the mechanical code in order to account for the higher
concentration of pollutants in gas cooking. The exhaust rate is based on a proposal currently being
considered for the Washington state code requirements for ventilation of gas cooking.

Add new text as follows:


C503.4.1 Service hot water system acceptance testing. Where an alteration requires
compliance with Section C404 or any of its subsections, service hot water systems that
serve the alteration shall comply with Sections C408.2.3 and C408.2.5.

10
Gillis, J. and Nilles, B. (2019). “Your Gas Stove Is Bad for You and the Planet” The New York Times.
www.nytimes.com/2019/05/01/opinion/climate-change-gas-electricity.html
11
Jarvis et al. (1996) “Evaluation of asthma prescription measures and health system performance based on emergency department
utilization.” https://www.ncbi.nlm.nih.gov/pubmed/8618483
12
D. Michanowicz, et al. (2022) “Home is Where the Pipeline Ends: Characterization of Volatile Organic Compounds Present in
Natural Gas at the Point of the Residential End User.” American Chemical Society.

COMMERCIAL OVERLAY (MIXED-FUEL) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 49
Exceptions:
1. Service water heater systems in buildings where the total mechanical equipment
capacity is less than 600,000 Btu/h (175.8 kW) combined service water-heating
and space-heating capacity.
2. Systems included in Section C403.5 that serve individual dwelling units and
sleeping units.

Retro-commissioning and building re-tuning is generally accepted as one of the most cost-effecting
energy efficiency measures for existing buildings. Average savings for building re-tuning is 12%, and
studies have found savings as high as 52%. However, the IECC only requires acceptance testing of new
portions of altered systems. This section requires an altered system to meet the relevant Sections of C408
for acceptance testing to ensure that the altered system is operating as intended.
Jurisdictions with Building Performance Standards (BPS) could replace the system capacity threshold with
the BPS application threshold instead to align the BPS and the energy code more fully. Most BPS are
triggered based on building size. Where this is the case, exception #1 would be replaced with the following:
1. Buildings with a gross floor area less than [SQUARE FOOTAGE
THRESHOLD OF THE BPS].
Where BPS or other policies have other triggers that may be important, exceptions can be further tailored.

Add new text as follows:


C503.4.2 Service water heating equipment. New combustion equipment used for water
heating that is part of the alteration shall comply with Section C501.6.
This requires the installation of combustion water heating equipment that is both more efficient and less
likely to worsen indoor air quality as stipulated in C501.6
C503.4.2.1 Partial electrification of water heating equipment. Where
combustion equipment is replaced in service water heating systems that utilize
multiple boilers or water heaters, the cold-water inlet shall be connected to
electric heat pump water heating equipment.
Many central water heating systems utilize multiple smaller pieces of water heating equipment—such as
boilers—ganged together rather than a single larger piece of equipment. The failure of one piece of
equipment in these systems provides an opportunity for partial electrification, particularly in buildings
where space limitations may pose an obstacle to full electrification. In a partial electrification, the first
piece of equipment in the series is replaced with a HPWH, shifting the maximum amount of the load
possible to the HPWH.
This hybrid approach has multiple advantages. Boiler rooms often have waste heat that the HPWH can
scavenge for water heating if the compressor is located in the same space. HPWHs are typically most
efficient at heating cold water. All-electric systems typically require large storage tanks to provide a
buffer against hot water demand. A hybrid system can rely on the gas water heating equipment to serve
the peak, reducing space constraints issues.

50 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE COMMERCIAL OVERLAY (MIXED-FUEL)
Revise text as follows:
C503.5 Lighting and power systems. New lighting and power systems that are part of the
alteration shall comply with Sections C405 and C408.
This minor change adds “power” to the title and scope of C503.5 so that decarbonization requirements
related to electrical power can be added to the section.

Add new text as follows:


C503.5.1 Interior Lighting and Controls. New and existing lighting in the
alteration shall be provided with controls that comply with Section C405.2.
Exceptions:
1. Where the size or configuration of an interior spaces is not altered
2. Where less than 50 percent of the luminaires in the space are replaced
The IECC’s requirements for lighting controls only apply to new controls, even when substantial changes
are made to a lighting system. In some older buildings, lighting may not have any controls at all. Lighting
alterations therefore provide a valuable opportunity to introduce or upgrade lighting controls. This
section requires lighting controls to meet current control requirements in certain, more substantial
lighting retrofits.

Add new text as follows:


C503.5.2 Lighting acceptance testing. Where an alteration requires compliance with
Section C405 or any of its subsections, the registered design professional or approved
agency shall provide a report in accordance with section C408.3.2.3 demonstrating that
the new and existing lighting control systems that serve the alteration have been tested in
accordance with the following:
1. Verify that manual controls function.
2. Verify that occupancy and vacancy sensors automatically turn off the lights when
spaces are unoccupied.
3. Verify that time switch controls are functioning, set to the correct day and time,
programmed with scheduled off times, and provided with new backup batteries
(where applicable).
While best practices for any lighting project include ensuring that lighting controls are operating
properly, the code is only required new controls. New luminaires do not trigger control testing. This
provision ensures that lighting controls will be receive basic functional testing whenever a lighting
system is altered. This section is based on the acceptance testing requirements for lighting in Section
C408 but has tailored for existing controls since some of those requirements are only appropriate for new
buildings or new controls.

COMMERCIAL OVERLAY (MIXED-FUEL) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 51
Add new text as follows:
C503.5.3 Combustion lighting. New gas lighting shall not be permitted to be added to
the building or building site.
Gas lighting is not common but is still used for decorative purposes and allowed in most spaces by the
fire code. This provision prohibits the installation of new gas lighting but has no impact on existing
installations. There is a very limited application of gas lighting to establish historically accurate lighting
that may be allowed under the accommodations for historic buildings in C501.5.

Add new text as follows:


C503.5.4 Electrical Service replacement. Where a building electrical service is
replaced, the new electrical service shall include additional electrical capacity for the
following as applicable:
1. Replacement of combustion equipment used for space heating with electric heat
pump equipment or reverse-cycle chiller sized for the heating load of the building
in accordance with C403.3.1 based on the existing building features
2. Replacement of combustion equipment used for water heating with electric heat
pump equipment sized for the service hot water load of the building
3. Replacement of combustion equipment used for cooking with electric cooking
equipment
4. Replacement of combustion equipment used for clothes drying with electric
equipment
5. Renewable energy infrastructure in accordance with Section C405.13
6. Sufficient electric capacity for all parking facilities served by the electrical
service to comply with Section C405.14 as a new parking facility. For the
purposes of compliance with this section, sizing shall be permitted to be based on
the capacity requirements of EVSE spaces served by an ALMS.
7. Energy storage infrastructure in accordance with Section C405.15.1
One potential significant cost in electrification retrofit projects is electrical service replacement. This
section ensures that if a building service is being replaced that it must be sized for the full electrification
of combustion equipment in the building—space heating, water heating, cooking and clothes drying—and
for the addition of the onsite renewable systems, EVCI and energy storage in the future. “Electrification-
sizing” the electrical service at the time of normal replacement is the most cost-effective approach to
providing sufficient capacity for individual electrification retrofits. This will remove that barrier for
future electrification retrofits.
Where jurisdictions are concerned with increased costs for these upgrades before the service may be put
to full use, several options are available to modify the language. First, the addition of new construction
quantities of EV charging capacity can be significant. Item 6 could be altered to only require electrical
capacity for a smaller percentage of EV charging spaces. Second, exceptions can be specifically crafted
to address the cost implications of such an upgrade.

52 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE COMMERCIAL OVERLAY (MIXED-FUEL)
Alternate add new text as follows:
Exception: Where it has been demonstrated to the code official that compliance with
this section will result in increased costs for electrical utility service be charged to the
building owner that create a substantial burden, the electrical service size shall be
permitted to be reduced to a size that will not increase utility infrastructure costs
charged to the building owner.

This exception has been crafted to provide discretion to the code official that the cost is not simply
increased but will show a substantial burden on the building owner. While this phrasing may be widely
interpreted, it is suggested that jurisdictions adopting this exception work to tailor this language to be
more prescriptive and appropriate to their local considerations.

Add new text as follows:


C503.5.5 Onsite renewable energy. Substantial improvements and alterations that
include roof replacements of more than 75 percent of the total roof area of the building,
the building or building site shall comply with Section C405.13.
Exception: Where roof replacements do not alter the existing structure and it has
been demonstrated to the code official that the existing structure cannot support the
addition of solar panels.
This provision requires roof replacement projects to be paired with the installation of an onsite
renewable energy system. There are different kinds of re-roofing projects. A roof recover only involves
putting a new layer of roofing material on top of existing roofing. A roof replacement includes the
removal of old roofing material, repair of exposed sheathing and installation of a new roof. Roof
replacements provide an advantageous opportunity to install an onsite renewable energy system like a
photovoltaic array. It exposes the roof structure under the roof cover, providing a clearer picture of the
condition and configuration of the roof structure. It also presents a more cost-effective time to make
structural improvements. It synchronizes the service life of the roof and the renewable energy system,
eliminating concerns about the need to repair a roof under the system. Synchronizing roof replacement
and rooftop renewable energy systems also reduces costs as both projects can often utilize the same
onsite construction and safety equipment.
If there is pushback to using roof replacement as a code trigger for the onsite renewable energy system,
substantial improvement could be used as a standalone trigger instead.

Alternate add new text as follows:


C503.5.5 Onsite renewable energy. Substantial improvements shall comply with
Section C405.13.
This would only require the renewable system when the building is undergoing a major renovation, as
substantial improvement is defined, giving the opportunity for reinforcing structure to be added to
accommodate future solar installations.

COMMERCIAL OVERLAY (MIXED-FUEL) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 53
Add new text as follows:
C503.5.6 Electric vehicle charging infrastructure. Parking facilities serving substantial
improvements shall comply with Section C405.14 as a new parking facility. All other
alterations shall be provided with electric vehicle parking infrastructure in accordance
with this section.
There are several building lifecycle events that support the addition of EV charging to existing sites or the
addition of electrical infrastructure to support future EV charging retrofits. This top section requires that
parking facilities that serve substantial improvements be retrofit to fully comply with the EV charging
requirements for new construction. All other alterations are directed to the subsections that include
targeted opportunistic electrical infrastructure upgrades during certain kinds of alterations.
C503.5.6.1 New parking facilities. New parking facilities and new parking
spaces added to existing parking facilities shall comply with Section C405.14
based on the number of new parking spaces.
This section makes explicitly clear that new parking facilities are subject to the EVCI requirements of
C405.14. This section may not be strictly necessary, but it ensures that there is no ambiguity in the code.

C503.5.6.2 Alterations to parking lots. Where more than 25% of the paving of
a parking lot is removed, the affected parking spaces shall be EV-capable spaces,
up to the total number of EV-capable spaces indicated in Table C405.14 based on
the total number of parking spaces in the parking lot. Where the parking lot
serves more than one occupancy type, the number of required EV-capable spaces
shall be based on a weighted average of the different occupancies. EV-capable
spaces shall be provided with raceway in accordance with the following:
1. Continuous between a junction box or outlet located within 3 feet (914 mm)
of the parking space and an electrical panel serving the area of the parking
space or a space containing an electrical panel serving the area of the
parking space.
2. The raceway shall be sized and rated to accommodate a 40-amp, 208/240-
volt branch circuit and have a minimum nominal trade size of 1 inch.
3. Both ends of the raceway shall have labels stating “For future electric
vehicle charging”

Parking lot repaving is a cost effective time to undertake the retrenching of a parking lot that EVCI retrofits
often require. The paving material is already being removed and replaced, which limits the cost of retrofitting
a parking lot to only the cost of the retrenching. This section leverages these parking lot repaving projects to
introduce raceways for EV-Capable spaces. It sets a minimum threshold for paving of 25% to ensure that the
requirement is not triggered by simple repair projects. It also only includes requirements for the raceway
component of EV-Capable spaces, and not other components such as panel capacity or physical space since
those are not generally part of the scope of a re-paving project. As such, it only requires the raceways to get
into proximity of the panel and not connect as is required in new construction. The section also sets a cap for
the number of spaces that need to be provided with this raceway, so that a retrofit project would not need to
provide more EV-Capable spaces than are required of new construction in C405.14.

54 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE COMMERCIAL OVERLAY (MIXED-FUEL)
C503.5.6.3 Alterations to parking structure electrical service. Where the
electrical service serving a parking garage is replaced, the electrical service shall
be sized to provide capacity for the parking garage to meet the requirements of
Section C405.14 as a new parking facility. For the purposes of compliance with
this section, sizing shall be permitted to be based on the capacity requirements of
EVSE spaces served by an ALMS.
Parking garages sometimes have independent electrical service connections and may not be captured by
the service upgrade requirements in Section C403.5.4 above. This ensures that parking garage electrical
service replacements are sized to accommodate an EV charging retrofit.

Add new text as follows:


C503.6 Additional energy efficiency credits. Substantial energy alterations shall comply with
Sections C506 in accordance with this section. All-electric buildings shall achieve a total of 5
credits and mixed-fuel buildings shall achieve a total of 10 credits.
Exceptions:
1. Alterations that are part of an addition complying with section C502.
2. Alterations that comply with Section C407.
3. Alterations that comply with Section C503.1.2.
This section works with the new section C506 (see below for more) to bring additional energy efficiency
through implementing the additional efficiency credits in C406 in substantial energy alterations.
Substantial energy alterations are defined in a way that they are projects that impact multiple building
energy systems, which creates multiple opportunities for acquiring credits from C406. The section
requires 5 credits in alterations to all-electric buildings—half of the credit target for new construction—
and 10 credits for mixed-fuel buildings. It includes a series of important exceptions:
1. An exception that reflects the allowance for alterations and additions to comply together under
Section C502 when they are part of the same project (see Section C502.6 above).
2. An exception for buildings that model using Section C407.
3. An exception for substantial improvements that comply with the EUI requirements of C503.1.2.

C505 CHANG E OF OCCUPANCY


Add new text as follows:
C505.1.1 Combustion equipment. New combustion equipment shall not be installed in a
space undergoing a change of occupancy.
This provision will result in the partial electrification of a change of occupancy by prohibiting the
installation of new combustion equipment. Existing combustion equipment is allowed to remain. This
would build on whatever electrification provisions the jurisdiction chooses for the alterations section and
should be seen as going beyond the requirements for alterations.

COMMERCIAL OVERLAY (MIXED-FUEL) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 55
Add new text as follows:
C505.2 Additional energy efficiency packages for changes of occupancy with combustion
equipment. Where a space being converted from one occupancy type to another occupancy type
is served by combustion equipment, it shall achieve 5 credits in accordance with Section C406 in
addition to the credits required by Section C406.1.
Exception: Alterations complying with Section C503.1.2 or C503.6.
Many changes of occupancy are subject to full code compliance, which includes section C406. This
section requires that changes of occupancy that are served by combustion equipment achieve an
additional 5 credits from C406. The provision includes an exception for mixed-fuel alterations that are
already required to comply with the EUI requirements of C503.1.2 or the additional points required by
Section C503.6.

C506 ADDITIONAL EFFICIENCY


Add new text as follows:
SECTION C506
ADDITIONAL EFFICIENCY CREDITS

C506.1 General. Where required by Section C502 or C503, credits shall be achieved from Tables
C406.1(1) through C406.1 (5) where the table is selected based on the use group of the building
and from credit calculations as specified in relevant subsections of Section C406. Where a
building contains multiple use groups, credits from each use group shall be weighted by floor area
of each group to determine the weighted average building credit. Credits from the tables of
calculation shall be achieved where a building complies with one or more of the following:
1. More efficient HVAC performance in accordance with Section C406.2.
2. Reduced lighting power in accordance with Section C406.3.
3. Enhanced lighting controls in accordance with Section C406.4.
4. On-site supply of renewable energy in accordance with Section C406.5.
5. Provision of a dedicated outdoor air system for certain space-conditioning equipment in
accordance with Section C406.6.
6. High-efficiency service water heating in accordance with Section C406.7.
7. Enhanced envelope performance in accordance with Section C406.8.
8. Reduced air infiltration in accordance with Section C406.9
9. Where not required by Section C405.12, include an energy monitoring system in
accordance with Section C406.10.
10. Where not required by Section C403.2.3, include a fault detection and diagnostics (FDD)
system in accordance with Section C406.11.
11. Efficient kitchen equipment in accordance with Section C406.12.

56 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE COMMERCIAL OVERLAY (MIXED-FUEL)
This new section C506 creates a framework to use the additional efficiency credits from Section C406 in
alterations and additions been leveraged to achieve additional energy savings in the IECC in a very
flexible way. Over the last several code cycles, Section C406 has b C506.1 serves the same role as
C406.1, directing projects how to achieve credits from the various credit options in sections C406.2-12.
Unlike Section C406, the credit target is not set in this section. Those targets are set in the companion
Sections C502.6 for additions and C503.6 for alterations. It makes sense to apply Section C406 to all new
buildings, but not all alterations and additions. Less substantial additions and alterations and certain
other existing projects with limited scopes are less likely to be able to accommodate a reasonable number
of credit options to meet a credit target. By setting the targets in Sections C502 and C503, the credit
targets can be selectively applied to only those projects where it is reasonable to incorporate Section
C406 credit options as a requirement. It also allows for a clear distinction between the unique exceptions
for additions and alterations.

Chapter 6 – Referenced Standards


Add new standard as follows:

ASHRAE
100---2018: Energy Efficiency in Existing Buildings
C503.1.2

COMMERCIAL OVERLAY (MIXED-FUEL) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 57
Existing Building
Decarbonization Code:

Residential
Overlay
All-Electric
Residential Overlay (All-Electric)
Chapter 1 – Scope and Application
R101 SCOPE AND G ENERAL REQUIREMENTS
Revise text as follows:
R101.3 Intent. This code shall regulate the design, and construction, repair, alteration, change
of occupancy, and additions of new and existing buildings for the effective use and
conservation reduction of greenhouse gas emissions and for the efficient production, use and
storage of energy over the useful life of each building. This code is intended to provide
flexibility to permit the use of innovative approaches and techniques to achieve this objective.
This code is not intended to abridge safety, health or environmental requirements contained in
other applicable codes or ordinances.
Intent has been modified to push beyond simply the inclusion of considerations of greenhouse gas
emissions and production and storage of energy, to clearly emphasize the intent of the code to regulate
existing buildings.

Chapter 2 – Definitions
R202 GENERAL DEFINITIONS
Add new definitions as follows:
ELECTRIC EQUIPMENT. Any equipment or appliance used for space heating, service water
heating, cooking, clothes drying, or lighting that uses electricity as its sole source of energy.
This new definition for electric equipment is a parallel of the definition of “combustion equipment”
introduced in the Building Decarbonization Code.

ENERGY USE INTENSITY (EUI). An expression of building energy use in terms of net
energy divided by gross floor area.
EUI is an energy metric used in some performance-based energy policies, including many building
performance standards (BPS). It is included here to allow provisions of the Existing Building
Decarbonization Code integrate with BPSs. EUI is not currently defined in the suite of I-Codes, so it is
added here. If a jurisdiction already has a formal definition of EUI, particularly in a building
performance standard, then that definition should be integrated here as well.

SUBSTANTIAL ENERGY ALTERATION. An alteration that includes replacement of two or


more of the following:
1. 50% or more of the area of interior wall-covering material of the building thermal
envelope or fenestration.
2. 50% or more of the area of the exterior wall-covering material of the building thermal
envelope or fenestration.
3. Space-conditioning equipment constituting 50% or more of the total input capacity of the
space heating or space cooling equipment serving the building.

60 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE RESIDENTIAL OVERLAY (ALL-ELECTRIC)
4. Water-heating equipment constituting 50% of more of the total input capacity of all the
water heating equipment serving the building.
5. 50% or more of the luminaires in the building
This new definition for substantial energy alteration is intended to capture projects that have the
opportunity to greatly increase efficiency by nature of their scope and clarify when certain requirements
related to the energy use of the building are triggered. By defining such scopes, confusion around generic
terms like major renovations and applicability of work classifications in the IEBC can be removed. Other
terms that define large-scale alterations such as Level III alteration or substantial improvement are not
specific to the energy systems. An alteration could cross their thresholds without having a significant
impact on the energy systems since they are based on metrics such as monetary value and reconfiguration
of spaces. Similarly, an alteration that has significant impact on the energy systems of the building may
not cross these other thresholds.
SUBSTANTIAL IMPROVEMENT. Any repair, reconstruction, rehabilitation, alteration,
addition or other improvement of a building or structure, the cost of which equals or exceeds 50
percent of the market value of the structure before the improvement or repair is started. If the
structure has sustained substantial damage, any repairs are considered substantial improvement
regardless of the actual repair work performed. The term does not, however, include either:
1. Any project for improvement of a building required to correct existing health, sanitary or
safety code violations identified by the building official and that are the minimum
necessary to assure safe living conditions.
2. Any alteration of a historic structure provided that the alteration will not preclude the
structure’s continued designation as a historic structure.
The definition of substantial improvement comes from the IBC and IEBC. The term generally aligns with
vernacular use of “major renovation,” which is not defined in code. It is used as a threshold for when
certain flood protection requirements are triggered for existing building alterations. Since it is based on
the monetary value of the alteration, it sets a useful threshold for introducing additional efficiency and
decarbonization requirements.
In addition, the Existing Building Decarbonization Code leverages definitions from the Building
Decarbonization Code including:

ALL-ELECTRIC BUILDING
APPLIANCE
COMBUSTION EQUIPMENT
COMMERCIAL COOKING APPLIANCES
ELECTRIC VEHICLE (EV)
EQUIPMENT
EV-CAPABLE SPACE
FUEL GAS

The use of these terms throughout assumes that adopting jurisdictions will adopt the Building
Decarbonization Code alongside this existing building overlay.

RESIDENTIAL OVERLAY (ALL-ELECTRIC) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 61
Chapter 5 – Existing Buildings
R501 GENERAL
Add new text as follows:
R501.7 Requirements for combustion equipment. Where existing combustion equipment
remains following an addition, alteration and change of occupancy the building shall comply
with this section.

This section creates an additional set of requirements for combustion equipment when it is allowed to be
installed in existing buildings. These requirements are intended to generally improve the emissions of the
equipment and the interior and exterior air quality.

R501.7.1 Phase out documentation. Permit applications for projects retaining


combustion equipment serving space heating and water heating in control of the applicant
shall include a plan for the future replacement of the combustion equipment with electric
equipment. The documentation shall include the following:

1. Calculations of the electric load required by the replacement electric equipment


and of the available electric capacity of the building.
2. Identification of any existing onsite electrical infrastructure, including but not
limited to transformers, switchgear, electrical panels and conductors, that will
need to be altered to accommodate the replacement electric equipment.
3. Floor plans identifying any spaces that will need to be reconfigured to
accommodate the replacement electric equipment.\
Exception: Owner-occupied single family, two-family, and townhouses.
Where buildings are retaining combustion equipment, building owners should understand the need for
long term phase out and switch to electric equipment to avoid potential abandoned assets. The primary
focus of this section is on multifamily and rental units, with a specific exception for owner occupied
detached and attached homes. Jurisdictions could also expand this section to include specifics related to
other policies such as appliance emission standards or replacement policies targeting specific dates for
combustion equipment phase out.

R501.7.2 Fuel gas pipe testing. All fuel gas piping serving combustion equipment shall
be tested in accordance with Section 406 of the International Fuel Gas Code.
Exceptions:
1. For the purposes of demonstrating compliance with this section, unexposed pipe
joints and welds shall not be required to be exposed for examination during the test.
2. Where it has been demonstrated to the code official that the fuel gas piping has
met the requirements of this section within the previous five years.
3. Where compliance with this section would require interruption of fuel gas supply
to combustion equipment that serves other tenant spaces or other dwelling units,
provided all exposed pipe joints of the piping subject to the requirements of this

62 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE RESIDENTIAL OVERLAY (ALL-ELECTRIC)
section have been inspected for leaks by means of an approved gas detector, a
noncorrosive leak detection fluid or other approved leak detection method once
the equipment has been placed in operation.
Gas piping degrades over time, creating the possibility of natural gas leakage. Even though the natural
gas is treated with mercaptan to give it that rotten egg smell, small leaks may go undetected, particularly
in buildings where pipes are not exposed and older buildings that are likely to have envelopes that are
less tight than newer construction. According to US DOE, building leakage accounts for nearly 27% of
the natural gas leakage in the US natural gas distribution system. 13 Leaking natural gas represents a loss
in energy, and even small leaks can add up over long periods of time. Additionally, natural gas is also a
potent Green House Gas, with over 86 times the global warming potential of CO2 on a short-term basis.
The installation of new gas equipment provides an ideal time to test gas pipe leakage. Contractors are
already on site and the gas will often be partially or fully turned off for the new equipment installation.
Additionally, new equipment installation can disturb and inflict additional stresses on existing piping,
creating opportunities for the formation of new leaks where existing natural gas piping has weakened but
not previously failed
This provision requires that existing fuel gas piping be tested like a new installation according the
International Fuel Gas Code (IFGC). It includes targeted exceptions for elements of the IFGC testing
methodology that is not appropriate for existing buildings. It also includes an exception for piping that
has been tested in the last five years in order to prevent repeated testing. Finally, it includes an exception
to ensure that testing requirements don’t necessitate other tenants losing service, which could be a
considerable in larger buildings with multiple tenant spaces. In those cases, it only requires visual
inspection of the exposed joints with a testing fluid.

Add new text as follows:


R501.8 Heat pump supplementary combustion equipment. Heat pumps having combustion
equipment or electric resistance equipment for supplementary space or water heating shall have
controls that limit supplemental heat operation to only those times when one of the following applies:

1. The heat pump is operating in defrost mode.


2. The vapor compression cycle malfunctions.
3. For space heating systems, the thermostat malfunctions.
4. For space heating systems, the vapor compression cycle cannot provide the necessary
heating energy to satisfy the thermostat setting.
5. For water heating, the heat pump water heater cannot maintain an output water
temperature of at least 120°F (49°C)
New supplementary space and water heating systems for heat pump equipment shall not be
permitted to have a heating input capacity greater than the heating input capacity of the heat
pump equipment.

13
“Natural Gas Infrastructure Modernization Programs at Local Distribution Companies: Key Issues and Considerations.” US DOE,
Office of Energy Policy and Systems Analysis. Washington DC, 2017.

RESIDENTIAL OVERLAY (ALL-ELECTRIC) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 63
Supplementary heating systems are effectively back-up systems intended to provide heating if the primary
heat pump system fails, if the operating conditions (heating demand, temperature around the heat pump
compressor, etc.) exceed the ability of the heat pump to effectively, or cost-effectively, provide heating.
Designers sometimes utilize “hybrid heat” systems where combustion equipment provides the
supplementary heat to address these situations.
This new section creates a version of the supplementary heating equipment control requirements that is
customized for existing buildings. It addresses both space and water heating applications, and ensures
that any combustion heating equipment used for supplementary heat is only used when the heat pump
system is unable to fully meet the buildings heating needs (the language in C403 already addresses
electric resistance supplementary heat).

R502 ADDITIONS
Revise text as follows:
R502.1 General. Additions to an existing building, building system or portion thereof shall
conform to the provisions of this code as those provisions relate to new construction without
requiring the unaltered portion of the existing building or building system to comply with this
code. Additions shall not create an unsafe or hazardous condition or overload existing building
systems. An addition shall be deemed to comply with this code where the addition alone
complies, where the existing building and addition comply with this code as a single building, or
where the building with the addition does not use more energy, than the existing building.
Additions shall be in accordance with Sections R502.2 or R502.3 through R502.6.
These edits implement the restructuring discussed above in the introduction. It moves the prescriptive
compliance language from R502.3 here. The requirement in R502.1 for additions to meet the
requirements for new construction mean that additions will be subject to the requirements in the Building
Decarbonization Code for electrification.

Add new text as follows:


R502.1.1 Combustion equipment. Additions shall not be permitted to contain
combustion equipment and new equipment installed to serve additions shall be
electric equipment.

This section requires that new equipment installed in and to serve additions be all-electric Where
additions are large enough to require new equipment, it is critical that the new equipment be electric
equipment. This provision would allow for existing combustion equipment to be employed as back up if
deemed necessary and be extended from the existing building.

R502.1.1.1 Energy consumption of existing combustion equipment. Where


systems with combustion equipment are extended into an addition, the existing
building and addition together shall use no more fossil fuel energy than the
existing building alone.

64 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE RESIDENTIAL OVERLAY (ALL-ELECTRIC)
Additions, particularly smaller ones, often don’t have stand-alone systems; ductwork and hot water piping
is extended into the addition to provide space conditioning and water heating. When these systems utilize
combustion equipment, the expanded loads will result in increased use of total combustion energy. This
provision allows systems with combustion equipment to be extended into additions but requires that this
extension doesn’t result in an increase in combustion energy. In order to extend a system with combustion
equipment into an addition, the efficiency of the existing building would need to be improved in order to
offset the increased consumption from the addition.

Revise text as follows:


R502.2 Change in space conditioning. Any unconditioned or low-energy space that is altered to
become conditioned space shall be required to be brought into full compliance with this code.
Exceptions:
1. Where the simulated performance option in Section R405 is used to comply with this
section, the annual energy cost of the proposed design is permitted to be 110 percent
of the annual energy cost otherwise allowed by Section R405.2.
2. Where the Total UA, as determined in Section R402.1.5, of the existing building and
the addition, and any alterations that are part of the project, is less than or equal to the
Total UA generated for the existing building.
3. Where complying in accordance with Section R405 and the annual energy cost or
energy use of the addition and the existing building, and any alterations that are part
of the project, is less than or equal to the annual energy cost of the existing building.
The addition and any alterations that are part of the project shall comply with Section
R405 in its entirety.

This content is located in the additions section in the model code (Section C502.2). As part of the
restructuring needed for this overlay, it has been relocated here since it describes an alteration project.
The requirements have not been changed, but the relocation will improve the usability and enforceability
of the code.

Revise text as follows:


R502.3 Prescriptive compliance. Additions shall comply with Sections R502.3.1 through
R502.3.4.

R502.3.12 Building envelope.

These edits implement the restructuring discussed above in the introduction. The content of the
subsections is unaffected.

RESIDENTIAL OVERLAY (ALL-ELECTRIC) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 65
Revise text as follows:
R502.3.2 R502.3 Heating and cooling systems. New heating and cooling systems installed as
part of an addition and serving multiple dwelling units shall comply with Section C502.3. All
other heating and cooling systems HVAC ducts newly installed as part of an addition shall
comply with Section R403 and this section.
Previously this section only provided specific guidance on ductwork. The revision allows this section to
more easily accommodate additional items around heating and cooling systems. It also directs central
systems that serve multiple dwelling units to the commercial section to ensure that they are subject to all-
electric requirements that are appropriate for larger, central systems.

Add new text as follows:


R502.3.3 Space heating equipment. New space heating equipment in additions shall be
electric heat pump equipment. Where existing systems with combustion equipment are
extended to serve the addition, they shall comply with Section R501.8

Exceptions:
1. Electric resistance supplementary heat in accordance with R501.8
2. Up to 2kW of electric resistance heat per dwelling unit

Requiring space heating installed during an addition to be electric will reduce carbon emissions and
improve air quality in homes. Heat pumps have been shown to be technically effective in all climate zones,
and cold-climate heat pump technology continues to improve, providing heating with a COP of more than 3
above 5°F. 14 Exceptions are included for electric resistance supplementary heat and for up to 2kW of
electric resistance heat. The 2kW budget will allow for electric resistance spot heating and for dwelling
units that are very small or very well-insulated where there may not be appropriate heat pump options. The
provision allows an existing combustion system can be extended to serve the addition, but it must be
controlled as supplementary heat, and it can’t be new combustion equipment.

Add new text as follows:


R502.3.4 Ductwork. HVAC ducts newly installed as part of an addition shall comply
with Section R403.
Exception: Where ducts from an existing heating and cooling system are extended
into an addition and the capacity of the heating or cooling equipment is not increased,
Sections R403.3.5 and R403.3.6 shall not be required.

14
“Achieve Comfort and Reliable Performance with Cold-Climate Heat Pumps.” Zero Energy Project, 6 Feb. 2020,
https://zeroenergyproject.org/2020/01/22/achieve-comfort-and-reliable-performance-with-cold-climate-heat-
pumps/#:~:text=The%20Benefits%20of%20Heat%20Pumps%20in%20Cold%20Climates&text=Combustion%2Dbased%20hea
ting%20systems%20such,3%20at%205%C2%B0F.

66 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE RESIDENTIAL OVERLAY (ALL-ELECTRIC)
Currently, ducts that extend an existing system into an addition are exempt from all of the requirements for
new ductwork, including the requirements for duct construction. While it can be reasonable to exempt these
ducts from the duct testing requirements, all of the other requirements should still apply. This modification
closes that loophole. It does provide an exemption from duct testing, but only when the system extension
doesn’t increase the equipment size.

Revise text as follows:


R502.3.34 Service hot water systems. New service hot water systems that are part of the
addition and serve multiple dwelling units shall comply with Section C502.4. New service hot
water systems that are part of the addition and serve individual dwelling units shall comply with
Section R403.5 and this section.
These edits implement the restructuring discussed above in the introduction. It also directs central
systems that serve multiple dwelling units to the commercial section to ensure that they are subject to all-
electric requirements that are appropriate for larger, central systems.

Add new text as follows:


R502.4.1 Service hot water equipment replacement. Where service hot water systems
are replaced, new equipment shall be heat pump equipment.

Exceptions:
1. Electric resistance elements integrated into heat pump equipment.

2. Electric storage water heaters with a rated storage volume of less than 20 gallons and
a rated input of less than 5kW.
3. Electric resistance equipment where not less than 75 percent of the annual service
water-heating requirement is provided by an on-site renewable energy system not
used to meet any other provision of this code.
4. Where it has been demonstrated to the code official that the dimensions of the space
in which the water heater is located cannot accommodate a heat pump water heater
sized to serve the hot water load of the dwelling unit.
Heat pump water heaters, often installed in both conditioned and semi-conditioned spaces such as
basements and garages, can provide service water heating with efficiencies greater than 300%, thus
reducing the energy use of service water heating to less than 1/3 of the energy required by gas or electric
resistance water heaters. Buildings that cannot accommodate heat pump water heaters because of
insufficient space are exempt from this requirement. Buildings with small electric storage water heaters
that cannot be replaced by current heat pump water heaters are also exempt.
If a jurisdiction finds that requiring HPWHs is not a viable option, this section can be replaced with an
alternative that only requires electrification (below), which would allow electric resistance options.

RESIDENTIAL OVERLAY (ALL-ELECTRIC) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 67
Alternate add new text as follows:
R502.4.1 Service hot water equipment replacement. Where service hot water systems
are replaced, new equipment shall be electric equipment.

Although such an approach would be more flexible, it also allows for electric resistance equipment,
which can have serious implications for carbon emissions and energy affordability. This approach should
only be chosen in jurisdictions served by an electricity supply that has a carbon intensity comparable to
onsite natural gas combustion. Additionally, the utility cost implications should be analyzed in order to
ensure this requirement will not have an unacceptably adverse effect on utility bills. Replacement of
combustion equipment with electric resistance equipment will also exacerbate the building electrical
capacity issues for electrification.

Revise text as follows:


R502.3.4 R502.5 Lighting and power. New lighting and electrical power systems that are part of
the addition shall comply with this section and Section R404.1.
Previously this section only included requirements for lighting. The edit changes the scope of the section
to include power, aligning it with the commercial section of the code and allowing it to accommodate
additional requirements related to power such as EV charging, electrical service replacements, etc.

Add new text as follows:


R502.5.1 Lighting equipment. New interior and exterior lighting serving additions shall
be electric. Fuel gas lighting systems shall be prohibited.
While the use of gas lighting is nearly extinct for both indoor and outdoor new construction uses, gas
lamps remain a nostalgic feature in some residential buildings. Similar to the new construction language,
it is critical to ensure that the adoption of this overlay prohibits new installations of gas lighting and the
gas infrastructure they require.

Add new text as follows:


R502.5.1 Electric vehicle charging infrastructure. New parking facilities, new parking
spaces added to existing parking facilities and new attached and detached garages shall
comply with Section R404.5.
It is critical to install EV charging infrastructure when construction provides an opportunity. R404.5
requires one and two-family dwellings and townhouses to have one parking space with an EV Ready
space that is sized to accommodate the most common EVSE on the market. The requirements for EV
charging infrastructure for multifamily buildings are referenced to the commercial requirements as those
are more appropriate for EV charging in parking lots.

68 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE RESIDENTIAL OVERLAY (ALL-ELECTRIC)
Add new text as follows:
R502.5.2 Renewable energy infrastructure. Additions shall comply with the
requirements of Section R502.5.2.1 or R502.5.2.2.
Exception: Additions where the new roof area is less than less than 600 square feet
(55 m2) of roof area oriented between 110 degrees and 270 degrees of true north.
R502.5.2.1 One- and two- family dwellings and townhouses. Where an addition
with a roof is added, the dwelling unit shall comply with Section R404.4.
R502.5.2.2 Group R occupancies. Where an addition with a roof is added to an
R-2, R-3 or R-4 occupancy, the building shall comply with Section C502.5.3.
The requirements in the Building Decarbonization Code for renewable energy systems reference
buildings and so don’t capture additions, as they are not stand-alone buildings. This section uses the
addition to trigger the requirements, ensuring that new additions with roofs also have solar-ready zones
or are provided with solar generation in accordance with the occupancy type, referring R-2, R-3, and R-4
occupancies to the commercial section for additions. It also draws the distinction between the building
and the dwelling unit, as two-family or townhouse structures contain several units within the same
building, this measure is targeted at the individual unit level. It includes an exception for additions with
less than 600 sf of roof area since they are not large enough for the solar-ready zone required in the
Building Decarbonization Code.

Add new text as follows:


R502.5.3 Energy storage infrastructure. Additions with new attached or detached
garages shall comply with Section R404.6.
New attached and detached garages provide an ideal location for energy storage systems in residential
construction. This provision requires energy storage readiness that meets the requirements of the
Building Decarbonization Code be include in these projects.

Add new text as follows:


R502.6 Additional Efficiency Packages. Additions shall comply with Sections R506.1. All-
electric buildings shall be required to select one package and mixed-fuel buildings shall be
required to select two packages. Alterations to the existing building that are not part of the
addition, but permitted with the addition, shall be permitted to be used to achieve this
requirement.
Exceptions:
1. Additions that increase the building’s total conditioned floor area by less than 25 percent.
2. Additions that do not include the addition or replacement of equipment covered by
Sections R403.5 or R403.7.

RESIDENTIAL OVERLAY (ALL-ELECTRIC) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 69
3. Additions that do not contain conditioned space.
4. Where the addition alone or the existing building and addition together comply with
Section R405 or R406.
There are many opportunities to cost-effectively improve the efficiency, comfort and indoor air quality of
a home during an alteration. This section works with the new section R506 (see below for more) to bring
additional energy efficiency through implementing the additional efficiency packages in R408 in
“substantial” additions. The section requires one package in most additions just like new buildings. It
also includes a series of important exceptions for additions that may not be able to reasonably implement
an additional efficiency package due to limited scope and for additions that comply through sections
R405 or R406.
All-electric homes typically use less energy when compared to mixed-fuel homes. By requiring additions
served by combustion equipment to select two energy efficiency packages, this measure seeks to
encourage electrification and improve the efficiency of existing buildings. Language is identical between
the all-electric and mixed-fuel sections to recognize the variety of existing building configurations and
systems, even under an “all-electric” application, the electrification at strategic points may not
individually result in an all-electric building.

R503 ALTERATIONS
Revise text as follows:
R503.1 General. Alterations to any building or structure shall comply with the requirements of
the code for new construction, without requiring the unaltered portions of the existing building or
building system to comply with this code. Alterations shall be such that the existing building or
structure is not less conforming to the provisions of this code than the existing building or
structure was prior to the alteration.
Alterations shall not create an unsafe or hazardous condition or overload existing building
systems. Alterations shall be such that the existing building or structure does not use more energy
than the existing building or structure prior to the alteration. Alterations to existing buildings shall
comply with Sections R503.1.1 through R503.1.4 R503.2 through R503.6.
These edits implement the restructuring discussed above in Section R501. The new referenced sections
are the subsections dedicated to building systems and additional efficiency.

Add new text as follows:


R503.1.1 Change in space conditioning. Any unconditioned or low-energy space that is
altered to become conditioned space shall be required to be brought into full compliance
with this code.
Exceptions:
1. Where the simulated performance option in Section R405 is used to comply with
this section, the annual energy cost of the proposed design is permitted to be 110
percent of the annual energy cost otherwise allowed by Section R405.2.

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2. Where the Total UA, as determined in Section R402.1.5, of the existing building
and the addition, and any alterations that are part of the project, is less than or
equal to the Total UA generated for the existing building.
3. Where complying in accordance with Section R405 and the annual energy cost or
energy use of the addition and the existing building, and any alterations that are
part of the project, is less than or equal to the annual energy cost of the existing
building. The addition and any alterations that are part of the project shall comply
with Section R405 in its entirety.
This content is located in the additions section in the model code (Section R502.2). As part of the restructuring
needed for this overlay, it has been relocated here since it describes an alteration project. The requirements
have not been changed, but the relocation will improve the usability and enforceability of the code.
R503.1.1.1 Garages and basements. Garages and basements in single family
and two-family residential buildings and townhouses converted to conditioned
space, the space shall comply with R501.7. Where the space contains water
heating equipment, the space shall comply Section R404.7.2.
A common alteration and space conditioning change in residential construction is the conversion of a
garage or basement space. This is also a location that most often contains water heating equipment. By
implementing electrification readiness requirements at the time of that renovation, costs for replacement
of combustion water heating equipment will be greatly reduced in the future. The explicit link back to
combustion equipment requirement will ensure safety for residents and families to spend longer periods
of time in those spaces.

Add new text as follows:


R503.1.2 Substantial improvement. Buildings undergoing substantial improvements
shall be all-electric buildings, comply with R402.4 and one of the following:
1. For each dwelling unit in the project, achieve an ERI score of 80 or below, without
on-site renewable energy included in accordance with RESNET/ICC 301.
2. Meet a site EUI by building type in accordance with ASHRAE Standard 100
Table 7-2a.
Substantial improvements are extensive alterations that have significant scope, large project budgets
relative to the value of the building and are more likely to already include major systems that could
include combustion equipment. The larger scopes and budgets of substantial improvements are likely to
occur infrequently within a building lifecycle and create the best opportunity to significantly increase
efficiency and electrify the full building. In jurisdictions where requiring substantial improvements to be
all-electric is not feasible, substantial alterations can be require to be electric ready. See Mixed Fuel
Section R503.1.3.

RESIDENTIAL OVERLAY (ALL-ELECTRIC) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 71
Add new text as follows:
R503.1.3 Combustion equipment. New combustion equipment and plumbing for
combustion equipment shall not be permitted to be installed in alterations.
This requirement prohibits the installation of new combustion equipment in alterations but does not
require the full removal of existing combustion equipment.

Add new text as follows:


R503.1.4 Building Performance Standards. Where the building is subject to
[OFFICIAL NAME OF THE LOCAL BUILDING PERFORMANCE
STANDARD], the permit application for the alteration shall include a report that
includes the following:
1. The current or last reported EUI of the building
2. The performance targets from [NAME OF THE LOCAL BUILDING
PERFORMANCE STANDARD] that will be applicable to the building within
five years from the date of the permit application
Where the current or last reported EUI exceeds the performance targets that will be
applicable in the next five years, the report shall also include a plan describing how the
building will be brought into compliance. The report shall include energy efficiency
upgrades and operational improvements that will be made to the building before the
applicable target goes into effect and the impact of the alteration under permit review.
Exception: Where the total building performance of the building with the alteration
determined in accordance with Section C407 demonstrates compliance with the
performance targets identified in the report required by this section.
Some jurisdictions include low-rise multifamily in their Building Performance Standard (BPS) because the
BPS application is based on overall square footage of buildings, unrelated to building height which is used
in the energy code. In these jurisdictions, it is important that all alterations support and reinforce the BPS.
Alterations that are undertaken without consideration of impending BPS performance targets represent a
significant missed opportunity. This section requires that consideration by creating a requirement that
permit applications include the building’s current performance and any BPS performance targets that will
be in effect in the next 5 years, the typical compliance cycle for US-based BPS. Where a building does not
already meet those targets, it will be required to also submit what is effectively a plan for compliance with
the BPS. This will ensure that project teams are thinking about a proposed alteration within the larger
context of what will be required to meet up-coming BPS requirements. The exception allows the compliance
path to be avoided when the alteration is complying by performance modeling and that modeling shows that
the alteration will bring the building into compliance with the BPS performance target.
It may be necessary to modify the language in this provision to align with the terminology that is used in
the official BPS regulation to maximize correlation and usability. For example, the provision can be
modified to align with a carbon-based BPS by replacing “EUI” with “CUI” throughout and adding the
following definition:

72 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE RESIDENTIAL OVERLAY (ALL-ELECTRIC)
CARBON USE INTENSITY (CUI). An expression of building carbon emissions in terms of the
equivalent carbon emissions of the net energy divided by gross floor area.
This definition defines a carbon use intensity that parallels the definition of EUI. It is a carbon metric
where carbon emissions are divided by gross floor area in order to compare the emissions of different
buildings or assess the performance a building’s carbon emissions against a target.

Renumber as follows:
R503.1.1 R503.2 Building envelope.
R503.1.1.1 R503.2.1 Replacement fenestration.
These edits implement the restructuring discussed above in Section R501. The content of the sections
is unaffected.

Revise text as follows:


R503.1.2R503.3 Heating and cooling systems. New heating, and cooling systems HVAC ducts
newly installed as part of an alteration shall comply with Section R403 and this section.
Alterations to heating, cooling and duct systems shall comply with this section.
New HVAC and ducts in an alteration must meet the requirements for new construction of Section R403
along with specific requirements in this section tailored for decarbonization of existing buildings. Work
that is purely alteration to HVAC is directed to follow specific language in this section.

Add new text as follows:


R503.3.1 Ducts. Ducts and air handlers that are a part of the alteration shall be installed
in accordance with this section.
R503.3.1.1 New ducts. Newly installed ducts and air handlers shall be installed
in accordance with R403.3.
Exception. Where the capacity of the heating or cooling equipment is not
increased Sections R403.3.5 and R403.3.6 shall not be required.
R503.3.1.2 Existing ducts. Existing duct systems shall be tested in accordance with
Section R403.3.5 and shall have a total leakage less than or equal to 12.0 cubic feet
per minute (339.9 L/min) per 100 square feet (9.29 m2) of conditioned floor area.
Exceptions:
1. Where the total length of all ducts in the system is increased by less than 25%.
2. Where less than 25% of the registers, and less than 25% of the total
length of the ducts in the system are relocated.

RESIDENTIAL OVERLAY (ALL-ELECTRIC) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 73
During an alteration, building owners often re-use and extensively alter their ductwork without testing
and meeting any kind of air-leakage requirement. Because the standards for duct construction in the
IECC have changed dramatically over time, existing duct systems often have substantial leakage far
beyond what is allowed in new construction. This section requires that existing ductwork that is
substantially altered will have to meet a maximum leakage requirement. The leakage criterion is set at 3x
the requirement for new construction, so the altered ductwork would not be required to be as tight as new
construction. Existing ductwork that does not receive substantial alteration is unaffected by this section.

Add new text as follows:


R503.3.2 System Sizing. New heating and cooling equipment that is part of an alteration
shall be sized in accordance with Section R403.7 based on the existing building features
as modified by the alteration.

Exception: Where it has been demonstrated to the code official that compliance with
this section would result in heating or cooling equipment that is incompatible with
the remaining portions of the existing heating or cooling system.

Oversized equipment results in increased energy use, decreased occupant comfort and increased wear-
and-tear on equipment. Oversized equipment is also less effective at dehumidification. Like-for-like
equipment replacement are particularly vulnerable to oversizing. This requirement ensures that new
heating and cooling equipment installed in existing buildings is properly sized based on the buildings
features as modified by the alteration. It provides an exception for situations where right-sizing
equipment may create an incompatibility with the rest of the system (as can be the case with steam
systems where boilers are sized to the radiators/convectors and not the building).

Add new text as follows:


R503.3.3 Controls. New heating and cooling equipment that are part of the alteration
shall be provided with controls that comply with Section R403.1 and Section R403.2.
Controls are a vital component of effective and efficient operation of heating and cooling systems and
older controls that do not meet current code requirements significantly hamper efficiency in buildings.
This section requires that new heating and cooling equipment installed as part of an alteration be
provided with controls that will ultimately reduce the energy use and thus utility bills of an existing
building. This section also ensures that thermostats are demand responsive, thus improving the resiliency
and reducing emissions of the electrical grid.

Add new text as follows:


R503.3.4 Space heating. New and replacement equipment providing space heating shall
be electric heat pump equipment. Where existing combustion equipment serves the same
heating zone, it shall be configured as supplementary heat in accordance with R501.8.

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Exceptions:
1. Electric resistance heat controlled in accordance with Section R501.8.
2. Up to 2kW of electric resistance heat per dwelling unit.
All heating equipment must be electrified at time of replacement. Unlike new construction, existing
buildings may have particularly high heating loads that cannot be effectively or cost-effectively met in
some climates and applications. Therefore, the section still allows new combustion equipment
installations, but only as supplementary heat. These “hybrid heat” configurations partially electrify the
space heating.

Add new text as follows:


R503.3.5 Cooling equipment. New and replacement unitary air conditioners shall be
electric heat pump equipment sized and configured to provide both space cooling and
space heating. Any other space heating systems that serve the same zone shall be
configured as supplementary heat in accordance with Sections R403.1.2 and R501.8.

Exception: Where a space heating system serves multiple dwelling units the system
is not required to be configured to supplementary heat.

Unitary air conditioners are essentially cooling-only heat pumps. AC replacement therefore provides a
valuable opportunity to electrify or partially electrify space heating. This section requires that when AC
equipment is replaced that it gets replaced with a heat pump sized for the home’s heating load. It also
requires that any existing heating system be reconfigured as supplementary heating. This allows existing
heating equipment to remain as a backup heating system, which is particularly important in buildings
that are required to have emergency backup power for heating.

Add new text as follows:


R503.3.6 Combustion cooking. Combustion equipment used for cooking shall not be
permitted in spaces undergoing an alteration.
This provision leverages an alteration to a space to require the electrification of any combustion cooking
equipment in that space. Gas cooking can release levels of pollutants that, if they were measured outside,
would violate the Clean Air Act. 15 By removing combustion cooking at the time of renovation to spaces
containing cooking equipment, jurisdictions act at the right time in the lifecycle of a residential building
to increase safety and indoor air quality, as well as decarbonize.

Revise text as follows:


R503.1.3 R503.4 Service hot water systems. New service hot water systems that are part of the
alteration and serve multiple dwelling units shall comply with Section C503.4. New service hot
water systems that are part of the alteration and serve individual dwelling units shall comply with
Section R403.5 and this section.

Gillis, J. and Nilles, B. (2019). “Your Gas Stove Is Bad for You and the Planet” The New York Times.
15

www.nytimes.com/2019/05/01/opinion/climate-change-gas-electricity.html

RESIDENTIAL OVERLAY (ALL-ELECTRIC) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 75
This provision ensures that systems that serve multiple dwelling units comply with the commercial
alterations section, which has requirements that are more appropriate for large central systems. It directs
smaller systems that serve individual dwelling units to comply with the new construction requirements in
Chapter 4 and new water heating electrification requirements for water heating in the subsections. The
numbering change implements the restructuring discussed above in Section R501.

Add new text as follows:


R503.4.1 Service hot water equipment replacement. Where service hot water systems
are replaced, new equipment shall be heat pump equipment.

Exceptions:
1. Electric resistance elements integrated into heat pump equipment.

2. Electric storage water heaters with a rated storage volume of less than 20 gallons
and a rated input of less than 5kW.
3. Electric resistance equipment where not less than 75 percent of the annual service
water-heating requirement is provided by an on-site renewable energy system not
used to meet any other provision of this code.
4. Where it has been demonstrated to the code official that the dimensions of the
space in which the water heater is located cannot accommodate a heat pump
water heater sized to serve the hot water load of the dwelling unit.
Heat pump water heaters, often installed in both conditioned and semi-conditioned spaces such as
basements and garages, can provide service water heating with efficiencies greater than 300%, thus
reducing the energy use of service water heating to less than 1/3 of the energy required by gas or electric
resistance water heaters. Buildings that cannot accommodate heat pump water heaters because of
insufficient space are exempt from this requirement. Buildings with small electric storage water heaters
that cannot be replaced by current heat pump water heaters are also exempt.
If a jurisdiction finds that requiring HPWHs is not a viable option, this section can be replaced with an
alternative that only requires electrification (below), which would allow electric resistance options.

Alternate add new text as follows:


R503.4.1 Service hot water equipment replacement. Where service hot water systems
are replaced, new equipment shall be electric equipment.
Although such an approach would be more flexible, it also allows for electric resistance equipment,
which can have serious implications for carbon emissions and energy affordability. This approach should
only be chosen in jurisdictions served by an electricity supply that has a carbon intensity comparable to
onsite natural gas combustion. Additionally, the utility cost implications should be analyzed in order to
ensure this requirement will not have an unacceptably adverse effect on utility bills. Replacement of
combustion equipment with electric resistance equipment will also exacerbate the building electrical
capacity issues for electrification.

76 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE RESIDENTIAL OVERLAY (ALL-ELECTRIC)
Revise text as follows:
R503.1.4 R503.5 Lighting. New lighting and power systems that are part of the alteration shall
comply with Section R404.1 and this section.

This minor change adds “power” to the title and scope of R503.5 so that decarbonization requirements
related to electrical power can be added to the section.

Add new text as follows:


R503.5.1 Electrical Service replacement. Where a building electrical service is
replaced, the new electrical service shall include electrical capacity sized in accordance
with IRC Section E3702 for the following future branch circuits:

1. Replacement of all currently installed combustion equipment used for cooking


with electric cooking equipment
2. Replacement of all currently installed combustion equipment used for space
heating with electric heat pump equipment or reverse-cycle chiller sized for the
heating load of the building in accordance with R403.7 based on the existing
building features
3. Replacement of all currently installed combustion equipment used for water heating
with electric heat pump equipment sized for the service hot water load of the building
4. Replacement of all currently installed combustion equipment used for clothes
drying with electric clothes drying equipment
5. Replacement of all currently installed combustion lighting with electric lighting.
6. Electric vehicle charging infrastructure in accordance with Section R404.5
7. Energy storage infrastructure in accordance with Section R404.6
8. Renewable energy infrastructure in accordance with Section R404.4
The required capacity of space and water heating equipment shall be able to be reduced by
any energy recovery systems serving the water or space heating equipment in the building.

One potential significant cost in electrification retrofit projects is electrical service replacement. This
section ensures that if a building service is being replaced that it must be sized for the full electrification
of combustion equipment in the building—space heating, water heating and cooking—and for the
addition of the EVCI requirements in R404.5. “Electrification-sizing” the electrical service at the time of
normal replacement is the most cost-effective approach to providing sufficient capacity for individual
electrification retrofits. This will remove that barrier for future electrification retrofits.

RESIDENTIAL OVERLAY (ALL-ELECTRIC) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 77
Add new text as follows:
R503.5.3 Electric vehicle charging infrastructure. Alterations shall be provided with
electric vehicle charging infrastructure in accordance with this section.

R503.5.3.1 One- and two-family dwellings and townhouses. An alteration of a


one- and two-family dwelling and townhouse where any of the following apply
shall meet the requirements of R404.5.1.
1. Substantial improvements

2. Where the alteration includes a new dedicated attached or detached


garage or on-site parking space
3. Where alteration work in a garage includes the installation of a new
branch circuit
This section requires new parking facilities to meet the EV charging requirements in the new construction
portion of the Building Decarbonization Code. While this is implicitly required by Section C501, the
addition of this section makes it explicit for greater clarity and enforceability.

R503.5.3.2 R-2 occupancies. Alterations to existing parking facilities in R-2


occupancies shall comply Section C503.5.3.

This section requires that any substantial alteration or alteration that includes a new attached or detached
garage of single and two-family dwellings or townhouses meets the electric vehicle charging infrastructure
requirements in Section R404.5.1. R404.5.1 requires one and two-family dwellings and townhouses to have
one parking space with an EV Ready space that is sized to accommodate the most common EVSE on the
market. The requirements for EV charging infrastructure for multifamily buildings are referenced to the
commercial alteration requirements as those are more appropriate for EV charging in parking lots.

Add new text as follows:


R503.5.4 Fuel gas lighting equipment. Fuel gas lighting systems shall not be installed.
While the use of gas lighting is nearly extinct for both indoor and outdoor new construction uses, gas
lamps remain a nostalgic feature in historic neighborhoods. Since the IRC Chapter 24 Fuel Gas does
not prohibit the installation of fuel gas lighting, it is critical to ensure that the adoption of this overlay
does prohibit these installations.

Add new text as follows:


R503.5.5 Renewable energy infrastructure. Substantial improvements and alterations
that include roof replacements shall meet the requirements of R404.4.

78 | NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE RESIDENTIAL OVERLAY (ALL-ELECTRIC)
Exception: Where roof replacements do not alter the existing structure and it has
been demonstrated to the code official that the existing structure cannot support the
addition of solar panels.
Roof replacements need to include the solar readiness requirements or install solar as specified in R404.4.

Add new text as follows:


R503.6 Additional Efficiency Packages. Substantial energy alterations shall comply with
Sections R506 in accordance with this section. All-electric buildings shall install one package and
mixed-fuel buildings shall install two packages.
Exceptions:
1. Alterations that are permitted with an addition complying with Section R502.6.
2. Where the alteration complies with Section R405 or R406.
3. Alterations that comply with Section R503.1.2.
This section works with the new section R506 (see below for more) to bring additional energy efficiency
through implementing the additional efficiency packages from R408 in “major alterations”. It is
structured to apply only to substantial energy alterations. This ensures that this requirement will only be
triggered by projects that already have a large enough scope for which there are multiple package
options available to implement. All-electric homes are required to select one while mixed-fuel buildings
are required to select 2, ensuring that fossil fuels are additionally conserved through efficiency gains.
The section includes exceptions for alterations that are permitted and comply in conjunction with an
addition and alterations that comply with sections R405 and R406 are presented. It also includes an
exception for substantial improvements that are subject to the ERI or EUI requirements of Section
R503.1.2 or substantial energy alterations that would choose to use that path instead of the efficiency
packages.

R505 CHANG E OF OCCUPANCY


Revise text as follows:
R505.1 General. Any space that is converted to a dwelling unit or portion thereof from another
occupancy shall comply with this code and shall not be served by combustion equipment.
Exception: Where a central heating or water heating system serving other dwelling units in
the same building is extended to serve spaces converted to a dwelling unit.
This provision prohibits changes of occupancy from being served by combustion equipment. This would
effectively require changes of occupancy to result in an all-electric space or all-electric building.
Jurisdictions should bear in mind that this could discourage changes of occupancy and the efficiency
gains that would have otherwise been gained through a standard change of occupancy. Where these
changes are likely to require substantial alterations, this type of trigger may be already sufficiently
captured in the alterations section of this code and this section could be removed by an adopting
jurisdiction. The exception presented allows for areas of multifamily buildings to extend existing systems
to areas that have undergone a change of occupancy to provide more dwelling or sleeping units.

RESIDENTIAL OVERLAY (ALL-ELECTRIC) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 79
R506 ADDITIONAL EFFICIENCY
Add new text as follows:
SECTION R506
ADDITIONAL EFFICIENCY PACKAGE OPTIONS

R506.1 General. This section establishes additional requirements to achieve additional energy
efficiency in existing buildings. Additional efficiency package options for compliance with
Section R502.6, R503.6, and R505.2 are as follows:
1. Enhanced envelope performance in accordance with Section R408.2.1.
2. More efficient space-conditioning equipment performance in accordance with Section
R408.2.2
3. Reduced energy use in service water-heating in accordance with Section R408.2.3
4. More efficient duct thermal distribution system in accordance with Section R408.2.4
5. Improved air sealing and efficient ventilation system in accordance with Section
R408.2.5
Section R408 was added to the IECC in 2021. It requires new homes to include an additional efficiency
option to achieve greater efficiency. There is one significant gap in R408, it does not apply to additions or
alterations. R502 and R503 do not reference R408 in the sections with which additions and alterations
must comply. The exclusion from Section R408 is a significant missed opportunity for efficiency in
additions and alterations.
This proposal creates a framework to apply R408 to additions and substantial alterations. It creates a
new Section R506 that provides guidance for how to utilize R408 packages for existing buildings. It works
in conjunction with new sections R502.6 and R503.6 (see above) that establish which additions and
alterations will need to comply with this section.
Where adopted, jurisdictions should include the revisions to Section R408 that are captured in the new
construction versions of the Building Decarbonization Code which removes the incentive for more
efficient gas equipment for all-electric requirements and adds an additional option for water heating
systems for mixed fuel buildings.

Chapter 6 – Referenced Standards


Add new standard as follows:

ASHRAE
100---2018: Energy Efficiency in Existing Buildings
R503.1.2

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Existing Building
Decarbonization Code:

Residential
Overlay
Mixed-Fuel
Residential Overlay (Mixed-Fuel)
Chapter 1 – Scope and Application
R101 SCOPE AND G ENERAL REQUIREMENTS
Revise text as follows:
R101.3 Intent. This code shall regulate the design, and construction, repair, alteration, change of
occupancy, and additions of new and existing buildings for the effective use and conservation
reduction of greenhouse gas emissions and for the efficient production, use and storage of energy
over the useful life of each building. This code is intended to provide flexibility to permit the use of
innovative approaches and techniques to achieve this objective. This code is not intended to abridge
safety, health or environmental requirements contained in other applicable codes or ordinances.
Intent has been modified to push beyond simply the inclusion of considerations of greenhouse gas
emissions and production and storage of energy, to clearly emphasize the intent of the code to regulate
existing buildings.

Chapter 2 – Definitions
R202 GENERAL DEFINITIONS
Add new definitions as follows:
ELECTRIC EQUIPMENT. Any equipment or appliance used for space heating, service water
heating, cooking, clothes drying, or lighting that uses electricity as its sole source of energy.
This new definition for electric equipment is a parallel of the definition of “combustion equipment”
introduced in the Building Decarbonization Code.
ENERGY USE INTENSITY (EUI). An expression of building energy use in terms of net
energy divided by gross floor area.
EUI is an energy metric used in some performance-based energy policies, including many building
performance standards (BPS). It is included here to allow provisions of the Existing Building
Decarbonization Code integrate with BPSs. EUI is not currently defined in the suite of I-Codes, so it is
added here. If a jurisdiction already has a formal definition of EUI, particularly in a building
performance standard, then that definition should be integrated here as well.
SUBSTANTIAL ENERGY ALTERATION. An alteration that includes replacement of two or
more of the following:
1. 50% or more of the area of interior wall-covering material of the building thermal
envelope or fenestration.
2. 50% or more of the area of the exterior wall-covering material of the building thermal
envelope or fenestration.
3. Space-conditioning equipment constituting 50% or more of the total input capacity of the
space heating or space cooling equipment serving the building.

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4. Water-heating equipment constituting 50% of more of the total input capacity of all the
water heating equipment serving the building.
5. 50% or more of the luminaires in the building
This new definition for substantial energy alteration is intended to capture projects that have the
opportunity to greatly increase efficiency by nature of their scope and clarify when certain requirements
related to the energy use of the building are triggered. By defining such scopes, confusion around generic
terms like major renovations and applicability of work classifications in the IEBC can be removed. Other
terms that define large-scale alterations such as Level III alteration or substantial improvement are not
specific to the energy systems. An alteration could cross their thresholds without having a significant
impact on the energy systems since they are based on metrics such as monetary value and reconfiguration
of spaces. Similarly, an alteration that has significant impact on the energy systems of the building may
not cross these other thresholds. Because there can be overlap in projects that are substantial
improvements and substantial energy alterations, substantial improvements are explicitly excluded in the
definition and treated differently in the code.
SUBSTANTIAL IMPROVEMENT. Any repair, reconstruction, rehabilitation, alteration,
addition or other improvement of a building or structure, the cost of which equals or exceeds 50
percent of the market value of the structure before the improvement or repair is started. If the
structure has sustained substantial damage, any repairs are considered substantial improvement
regardless of the actual repair work performed. The term does not, however, include either:
1. Any project for improvement of a building required to correct existing health, sanitary or
safety code violations identified by the building official and that are the minimum
necessary to assure safe living conditions.
2. Any alteration of a historic structure provided that the alteration will not preclude the
structure’s continued designation as a historic structure.

The definition of substantial improvement comes from the IBC and IEBC. The term generally aligns with
vernacular use of “major renovation,” which is not defined in code. It is used as a threshold for when
certain flood protection requirements are triggered for existing building alterations. Since it is based on
the monetary value of the alteration, it sets a useful threshold for introducing additional efficiency and
decarbonization requirements.
In addition, the Existing Building Decarbonization Code leverages definitions from the Building
Decarbonization Code including:
ALL-ELECTRIC BUILDING
APPLIANCE
COMBUSTION EQUIPMENT
COMMERCIAL COOKING APPLIANCES
ELECTRIC VEHICLE (EV)
EQUIPMENT
EV-CAPABLE SPACE
FUEL GAS
The use of these terms throughout assumes that adopting jurisdictions will adopt the Building
Decarbonization Code alongside this existing building overlay.

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Chapter 5 – Existing Buildings
R501 GENERAL
Add new text as follows:
R501.7 Requirements for combustion equipment. Where new, replacement, and existing
combustion equipment remains following an addition, alteration and change of occupancy the
building shall comply with this section.
This section creates a set of requirements for combustion equipment when it is allowed to be installed in
existing buildings. These requirements are intended to generally improve the emissions of the equipment, the
interior and exterior air quality, and provide necessary electric readiness for the next round of replacements.
R501.7.1 Replacement of electric equipment. Combustion equipment shall not be
permitted to be installed to replace electric equipment.
The largest cost for existing buildings to electrify is to install the infrastructure to swap the equipment.
Where electric appliances and equipment already exist, it is critical to maintain the electric energy source
and not install new fossil fuel infrastructure or equipment.
R501.7.2 Phase out documentation. Permit applications for projects installing new and
replacement combustion equipment or retaining existing combustion equipment serving space
heating and water heating shall include a plan for the future replacement of the combustion
equipment with electric equipment. The documentation shall include the following:
1. Calculations of the electric load required by the replacement electric equipment
and of the available electric capacity of the building.
2. Identification of any existing onsite electrical infrastructure, including but not
limited to transformers, switchgear, electrical panels and conductors, that will
need to be altered to accommodate the replacement electric equipment.
3. Floor plans identifying any spaces that will need to be reconfigured to
accommodate the replacement electric equipment.

Exception: Owner-occupied single family, two-family, and townhouses.

Where replacements are made with combustion equipment, building owners should understand the need
for long term phase out and switch to electric equipment to avoid potential abandoned assets. The
primary focus of this section is on multifamily and rental units, with a specific exception for owner
occupied detached and attached homes. Jurisdictions could also expand this section to include specifics
related to other policies such as appliance emission standards or replacement policies targeting specific
dates for combustion equipment phase out.
R501.7.3 Sealed combustion and direct venting. Combustion equipment used for space
and water heating shall be direct vent or sealed combustion.
Space and water heating equipment that utilize direct venting or sealed combustion techniques improve
the efficiency of the equipment and the indoor air quality of a home by ensuring that hazardous
byproducts of the combustion process are vented outside of the living space.

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R501.7.4 Low NOx furnaces. Warm-air furnaces shall have no more than 14 nanograms
of nitrogen dioxide emissions per joule of useful heat delivered to the heated space.

Exception: Equipment with an AFUE of not less than 90 percent.

This requirement limits the nitrogen dioxide emissions from these appliances. Appliances in buildings
emit twice the amount of NOx as power plants, a major pollutant which causes asthma. The air quality
limit is based on NOx emission limits imposed by California’s South Coast Air Quality Management
District and the San Joaquin Valley Air Pollution Control District. An exception is given to equipment
that exhibit an AFUE of 90 percent or more because those systems use direct vent or sealed combustion
technology and comply with the NOx limit.
R501.7.5 Fuel gas pipe testing. All fuel gas piping that serves new or replacement
combustion equipment shall be tested as a new installation in accordance with Section
G2415.20 of the International Residential Code.
Exceptions:
1. For the purposes of demonstrating compliance with this section, unexposed pipe
joints and welds shall not be required to be exposed for examination during the test.
2. For the purposes of demonstrating compliance with this section, where it has
been demonstrated to the code official that the fuel gas piping has met the
requirements of this section within the previous five years.
3. Where compliance with this section would require interruption of fuel gas supply
to combustion equipment that serves other tenant spaces or other dwelling units,
provided all exposed pipe joints of the piping subject to the requirements of this
section have been inspected for leaks by means of an approved gas detector, a
noncorrosive leak detection fluid or other approved leak detection method once
the equipment has been placed in operation.
Gas piping degrades over time, creating the possibility of natural gas leakage. Even though the natural gas
is treated with mercaptan to give it that rotten egg smell, small leaks may go undetected, particularly in
buildings where pipes are not exposed and older buildings that are likely to have envelopes that are less
tight than newer construction. According to US DOE, building leakage accounts for nearly 27% of the
natural gas leakage in the US natural gas distribution system. 16 Leaking natural gas represents a loss in
energy, and even small leaks can add up over long periods of time. Additionally, natural gas is also a potent
Green House Gas, with over 86 times the global warming potential of CO2 on a short-term basis.
The installation of new gas equipment provides an ideal time to test gas pipe leakage. Contractors are
already on site and the gas will often be partially or fully turned off for the new equipment installation.
Additionally, new equipment installation can disturb and inflict additional stresses on existing piping,
creating opportunities for the formation of new leaks where existing natural gas piping has weakened but
not previously failed.
This provision requires that existing fuel gas piping be tested like a new installation according to the fuel-
gas piping requirements in the International Residential Code (IRC). It includes targeted exceptions for

16
“Natural Gas Infrastructure Modernization Programs at Local Distribution Companies: Key Issues and Considerations.” US DOE,
Office of Energy Policy and Systems Analysis. Washington DC, 2017.

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elements of the IFGC testing methodology that is not appropriate for existing buildings. It also includes
an exception for piping that has been tested in the last five years in order to prevent repeated testing.
Finally, it includes an exception to ensure that testing requirements don’t necessitate other tenants losing
service, which could be a considerable in larger buildings with multiple tenant spaces. In those cases, it
only requires visual inspection of the exposed joints with a testing fluid.

Add new text as follows:


R501.8 Heat pump supplementary combustion equipment. Heat pumps having combustion
equipment or electric resistance equipment for supplementary space or water heating shall have
controls that limit supplemental heat operation to only those times when one of the following applies:

1. The heat pump is operating in defrost mode.


2. The vapor compression cycle malfunctions.
3. For space heating systems, the thermostat malfunctions.
4. For space heating systems, the vapor compression cycle cannot provide the necessary
heating energy to satisfy the thermostat setting.
5. For water heating, the heat pump water heater cannot maintain an output water
temperature of at least 120°F (49°C)
New supplementary space and water heating systems for heat pump equipment shall not be
permitted to have a heating input capacity greater than the heating input capacity of the heat
pump equipment.

Supplementary heating systems are effectively back-up systems intended to provide heating if the primary
heat pump system fails, if the operating conditions (heating demand, temperature around the heat pump
compressor, etc.) exceed the ability of the heat pump to effectively, or cost-effectively, provide heating.
Designers sometimes utilize “hybrid heat” systems where combustion equipment provides the
supplementary heat to address these situations.
This new section creates a version of the supplementary heating equipment control requirements that is
customized for existing buildings. It addresses both space and water heating applications, and ensures
that any combustion heating equipment used for supplementary heat is only used when the heat pump
system is unable to fully meet the buildings heating needs (the language in C403 already addresses
electric resistance supplementary heat).

R502 ADDITIONS
Revise text as follows:
R502.1 General. Additions to an existing building, building system or portion thereof shall conform
to the provisions of this code as those provisions relate to new construction without requiring the
unaltered portion of the existing building or building system to comply with this code. Additions
shall not create an unsafe or hazardous condition or overload existing building systems. An addition
shall be deemed to comply with this code where the addition alone complies, where the existing

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building and addition comply with this code as a single building, or where the building with the
addition does not use more energy, than the existing building. Additions shall be in accordance with
Section R404.7 and Sections R502.2 or R502.3 through R502.6.
These edits implement the restructuring discussed above in the introduction. It moves the prescriptive
compliance language from R502.3 here. The requirement in R502.1 for additions to meet the
requirements for new construction mean that additions will be subject to the requirements in the Building
Decarbonization Code for electrification readiness where combustion equipment is newly installed.

Add new text as follows:


R502.1.1 Combustion equipment. Additions shall not be permitted to contain combustion
equipment and new equipment installed to serve additions shall be electric equipment.

This section requires that new equipment installed in and to serve additions be all-electric Where
additions are large enough to require new equipment, it is critical that the new equipment be electric
equipment. This provision would allow for existing combustion equipment to be employed as back up if
deemed necessary and be extended from the existing building.

R502.1.1.1 Energy consumption of existing combustion equipment. Where


systems with combustion equipment are extended into an addition, the existing
building and addition together shall use no more fossil fuel energy than the
existing building alone.
Additions, particularly smaller ones, often don’t have stand-alone systems; ductwork and hot water
piping is extended into the addition to provide space conditioning and water heating. When these systems
utilize combustion equipment, the expanded loads will result in increased use of total combustion energy.
This provision allows systems with combustion equipment to be extended into additions but requires that
this extension doesn’t result in an increase in combustion energy. In order to extend a system with
combustion equipment into an addition, the efficiency of the existing building would need to be improved
in order to offset the increased consumption from the addition.

Add new text as follows:


R502.1.2 Combustion equipment requirements. New combustion equipment serving
additions shall comply with section R501.7.
New combustion equipment is allowed in additions, provided they meet the additional requirements for
combustion equipment in Section R501.7.

Revise text as follows:


R502.2 Change in space conditioning. Any unconditioned or low-energy space that is altered to
become conditioned space shall be required to be brought into full compliance with this code.

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Exceptions:
1. Where the simulated performance option in Section R405 is used to comply with this
section, the annual energy cost of the proposed design is permitted to be 110 percent of
the annual energy cost otherwise allowed by Section R405.2.
2. Where the Total UA, as determined in Section R402.1.5, of the existing building and the
addition, and any alterations that are part of the project, is less than or equal to the Total
UA generated for the existing building.
3. Where complying in accordance with Section R405 and the annual energy cost or energy
use of the addition and the existing building, and any alterations that are part of the
project, is less than or equal to the annual energy cost of the existing building. The
addition and any alterations that are part of the project shall comply with Section R405 in
its entirety.
This content is located in the additions section in the model code (Section C502.2). As part of the restructuring
needed for this overlay, it has been relocated here since it describes an alteration project. The requirements
have not been changed, but the relocation will improve the usability and enforceability of the code.

Revise text as follows:


R502.3 Prescriptive compliance. Additions shall comply with Sections R502.3.1 through
R502.3.4.
R502.3.12 Building envelope.
These edits implement the restructuring discussed above in the introduction. The content of the
subsections is unaffected.

Revise text as follows:


R502.3.2 R502.3 Heating and cooling systems. New heating and cooling systems installed as
part of an addition and serving multiple dwelling units shall comply with Section C502.3. All
other heating and cooling systems HVAC ducts newly installed as part of an addition shall
comply with Section R403 and this section.
Previously this section only provided specific guidance on ductwork. The revision allows this section to
more easily accommodate additional items around heating and cooling systems. It also directs central
systems that serve multiple dwelling units to the commercial section to ensure that they are subject to all-
electric requirements that are appropriate for larger, central systems.

Add new text as follows:


R502.3.3 Space heating equipment. New space heating equipment in additions shall be
electric heat pump equipment.

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Exceptions:
1. Supplementary heat in accordance with R501.8
2. Up to 2kW of electric resistance heat per dwelling unit

Requiring space heating installed during an addition to be electric will reduce carbon emissions and
improve air quality in homes. Heat pumps have been shown to be technically effective in all climate
zones, and cold-climate heat pump technology continues to improve, providing heating with a COP of
more than 3 above 5°F. 17 The provision includes an exception that allows combustion equipment,
including new combustion equipment, to be used as supplementary heat. These “hybrid heat”
configurations partially electrify the space heating. Unlike new construction, existing buildings may have
particularly high heating loads that cannot be effectively or cost-effectively met by heat pumps alone in
some climates and applications.

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R502.3.4 Ductwork. HVAC ducts newly installed as part of an addition shall comply
with Section R403.
Exception: Where ducts from an existing heating and cooling system are extended
into an addition and the capacity of the heating or cooling equipment is not increased,
Sections R403.3.5 and R403.3.6 shall not be required.
Currently, ducts that extend an existing system into an addition are exempt from all of the requirements
for new ductwork, including the requirements for duct construction. While it can be reasonable to exempt
these ducts from the duct testing requirements, all of the other requirements should still apply. This
modification closes that loophole. It does provide an exemption from duct testing, but only when the
system extension doesn’t increase the equipment size.

Revise text as follows:


R502.3.34 Service hot water systems. New service hot water systems that are part of the
addition and serve multiple dwelling units shall comply with Section C502.4. New service hot
water systems that are part of the addition and serve individual dwelling units shall comply with
Section R403.5 and this section.

These edits implement the restructuring discussed above in the introduction. It also directs central
systems that serve multiple dwelling units to the commercial section to ensure that they are subject to all-
electric requirements that are appropriate for larger, central systems.

17
“Achieve Comfort and Reliable Performance with Cold-Climate Heat Pumps.” Zero Energy Project, 6 Feb. 2020,
https://zeroenergyproject.org/2020/01/22/achieve-comfort-and-reliable-performance-with-cold-climate-heat-
pumps/#:~:text=The%20Benefits%20of%20Heat%20Pumps%20in%20Cold%20Climates&text=Combustion%2Dbased%20hea
ting%20systems%20such,3%20at%205%C2%B0F.

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Add new text as follows:
R502.4.1 Service hot water equipment replacement. New combustion equipment used
for water heating that is part of the alteration shall comply with Section R501.7.
This requires the installation of combustion water heating equipment that is both more efficient and less
likely to worsen indoor air quality as stipulated in R501.7. Where jurisdictions would like to move toward
electrification but allow supplementary water heating, alternative language is provided.

Alternate Add new text as follows:


R502.4.1 Service hot water equipment replacement. Where service hot water systems
are replaced, new primary water heating equipment shall be heat pump equipment. Where
new or existing combustion equipment is used to provide supplementary water heating,
the equipment shall comply with Section R501.7.
This provision requires partial electrification, providing a “hybrid” water heating system that is reliant
on heat pump technology primarily, but allowed to use combustion equipment for supplementary heating.

Revise text as follows:


R502.3.4 R502.5 Lighting and power. New lighting and electrical power systems that are part of
the addition shall comply with this section and Section R404.1.
Previously this section only included requirements for lighting. The edit changes the scope of the section
to include power, aligning it with the commercial section of the code and allowing it to accommodate
additional requirements related to power such as EV charging, electrical service replacements, etc.

Add new text as follows:


R502.5.1 Lighting equipment. New interior and exterior lighting serving additions shall be
electric. Fuel gas lighting systems shall be prohibited.

While the use of gas lighting is nearly extinct for both indoor and outdoor new construction uses, gas
lamps remain a nostalgic feature in some residential buildings. Similar to the new construction language,
it is critical to ensure that the adoption of this overlay prohibits new installations of gas lighting and the
gas infrastructure they require.

Add new text as follows:


R502.5.1 Electric vehicle charging infrastructure. New parking facilities, new parking
spaces added to existing parking facilities and new attached and detached garages shall
comply with Section R404.5.
It is critical to install EV charging infrastructure when construction provides an opportunity. R404.5
requires one and two-family dwellings and townhouses to have one parking space with an EV Ready
space that is sized to accommodate the most common EVSE on the market. The requirements for EV

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charging infrastructure for multifamily buildings are referenced to the commercial requirements as those
are more appropriate for EV charging in parking lots.

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R502.5.2 Renewable energy infrastructure. Additions shall comply with the
requirements of Section R502.5.2.1 or R502.5.2.2.
Exception: Additions where the new roof area is less than less than 600 square feet
(55 m2) of roof area oriented between 110 degrees and 270 degrees of true north.
R502.5.2.1 One- and two- family dwellings and townhouses. Where an addition
with a roof is added, the dwelling unit shall comply with Section R404.4.
R502.5.2.2 Group R occupancies. Where an addition with a roof is added to an
R-2, R-3 or R-4 occupancy, the building shall comply with Section C502.5.3.
The requirements in the Building Decarbonization Code for renewable energy systems reference
buildings and so don’t capture additions, as they are not stand-alone buildings. This section uses the
addition to trigger the requirements, ensuring that new additions with roofs also have solar-ready zones
or are provided with solar generation in accordance with the occupancy type, referring R-2, R-3, and R-4
occupancies to the commercial section for additions. It also draws the distinction between the building
and the dwelling unit, as two-family or townhouse structures contain several units within the same
building, this measure is targeted at the individual unit level. It includes an exception for additions with
less than 600 sf of roof area since they are not large enough for the solar-ready zone required in the
Building Decarbonization Code.

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R502.5.3 Energy storage infrastructure. Additions with new attached or detached
garages shall comply with Section R404.6.
New attached and detached garages provide an ideal location for energy storage systems in residential
construction. This provision requires energy storage readiness that meets the requirements of the
Building Decarbonization Code be include in these projects.

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R502.6 Additional Efficiency Packages. Additions shall comply with Sections R506.1. All-electric
buildings shall be required to select one package and mixed-fuel buildings shall be required to select
two packages. Alterations to the existing building that are not part of the addition, but permitted
with the addition, shall be permitted to be used to achieve this requirement.
Exceptions:
1. Additions that increase the building’s total conditioned floor area by less than 25 percent.
2. Additions that do not include the addition or replacement of equipment covered by
Sections R403.5 or R403.7.

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3. Additions that do not contain conditioned space.
4. Where the addition alone or the existing building and addition together comply with
Section R405 or R406.
There are many opportunities to cost-effectively improve the efficiency, comfort and indoor air quality of a
home during an alteration. This section works with the new section R506 (see below for more) to bring
additional energy efficiency through implementing the additional efficiency packages in R408 in “substantial”
additions. The section requires one package in most additions just like new buildings. It also includes a series
of important exceptions for additions that may not be able to reasonably implement an additional efficiency
package due to limited scope and for additions that comply through sections R405 or R406.
All-electric homes typically use less energy when compared to mixed-fuel homes. By requiring additions
served by combustion equipment to select two energy efficiency packages, this measure seeks to
encourage electrification and improve the efficiency of existing buildings. Language is identical between
the all-electric and mixed-fuel sections to recognize the variety of existing building configurations and
systems, even under an “all-electric” application, the electrification at strategic points may not
individually result in an all-electric building.

R503 ALTERATIONS
Revise text as follows:
R503.1 General. Alterations to any building or structure shall comply with the requirements of
the code for new construction, without requiring the unaltered portions of the existing building or
building system to comply with this code. Alterations shall be such that the existing building or
structure is not less conforming to the provisions of this code than the existing building or
structure was prior to the alteration.
Alterations shall not create an unsafe or hazardous condition or overload existing building
systems. Alterations shall be such that the existing building or structure does not use more energy
than the existing building or structure prior to the alteration. Alterations to existing buildings shall
comply with Sections R503.1.1 through R503.1.4 R503.2 through R503.6.
These edits implement the restructuring discussed above in Section R501. The new referenced sections
are the subsections dedicated to building systems and additional efficiency.

Add new text as follows:


R503.1.1 Change in space conditioning. Any unconditioned or low-energy space that is
altered to become conditioned space shall be required to be brought into full compliance
with this code.
Exceptions:
1. Where the simulated performance option in Section R405 is used to comply with
this section, the annual energy cost of the proposed design is permitted to be 110
percent of the annual energy cost otherwise allowed by Section R405.2.

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2. Where the Total UA, as determined in Section R402.1.5, of the existing building
and the addition, and any alterations that are part of the project, is less than or
equal to the Total UA generated for the existing building.
3. Where complying in accordance with Section R405 and the annual energy cost or
energy use of the addition and the existing building, and any alterations that are
part of the project, is less than or equal to the annual energy cost of the existing
building. The addition and any alterations that are part of the project shall comply
with Section R405 in its entirety.
This content is located in the additions section in the model code (Section R502.2). As part of the restructuring
needed for this overlay, it has been relocated here since it describes an alteration project. The requirements
have not been changed, but the relocation will improve the usability and enforceability of the code.
R503.1.1.1 Garages and basements. Garages and basements in single family
and two-family residential buildings and townhouses converted to conditioned
space, the space shall comply with R501.7. Where the space contains water
heating equipment, the space shall comply Section R404.7.2.
A common alteration and space conditioning change in residential construction is the conversion of a
garage or basement space. This is also a location that most often contains water heating equipment. By
implementing electrification readiness requirements at the time of that renovation, costs for replacement
of combustion water heating equipment will be greatly reduced in the future. The explicit link back to
combustion equipment requirement will ensure safety for residents and families to spend longer periods
of time in those spaces.

Add new text as follows:


R503.1.2 Substantial improvement. Buildings undergoing substantial improvements
shall comply with Sections R402.4 and R404.7, and one of the following:
1. For each dwelling unit in the project, achieve an ERI score of 80 or below, without
on-site renewable energy included in accordance with RESNET/ICC 301.
2. Meet a site EUI by building type in accordance with ASHRAE Standard 100
Table 7-2a.
Substantial improvements are extensive alterations that have significant scope, large project budgets
relative to the value of the building and are more likely to already include major systems that could
include combustion equipment. The larger scopes and budgets of substantial improvements are likely to
occur infrequently within a building lifecycle and create the best opportunity to significantly increase
efficiency and establish full electric ready infrastructure for the building and its systems.

Add new text as follows:


R503.1.3 Combustion equipment. New combustion equipment serving alterations shall
comply with Section R501.7.

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Requiring the installation of combustion space and water heating equipment that is both more efficient
and less likely to worsen indoor air quality in alterations can both reduce carbon emissions and improve
the health of building occupants. Requiring certain types of alterations to implement energy efficiency
measures as described in Section R503.6 will also cost-effectively reduce a home’s utility bills.

Add new text as follows:


R503.1.4 Building Performance Standards. Where the building is subject to
[OFFICIAL NAME OF THE LOCAL BUILDING PERFORMANCE
STANDARD], the permit application for the alteration shall include a report that
includes the following:
1. The current or last reported EUI of the building
2. The performance targets from [NAME OF THE LOCAL BUILDING
PERFORMANCE STANDARD] that will be applicable to the building within
five years from the date of the permit application
Where the current or last reported EUI exceeds the performance targets that will be
applicable in the next five years, the report shall also include a plan describing how the
building will be brought into compliance. The report shall include energy efficiency
upgrades and operational improvements that will be made to the building before the
applicable target goes into effect and the impact of the alteration under permit review.
Exception: Where the total building performance of the building with the alteration
determined in accordance with Section C407 demonstrates compliance with the
performance targets identified in the report required by this section.
Some jurisdictions include low-rise multifamily in their Building Performance Standard (BPS) because
the BPS application is based on overall square footage of buildings, unrelated to building height which is
used in the energy code. In these jurisdictions, it is important that all alterations support and reinforce
the BPS. Alterations that are undertaken without consideration of impending BPS performance targets
represent a significant missed opportunity. This section requires that consideration by creating a
requirement that permit applications include the building’s current performance and any BPS
performance targets that will be in effect in the next 5 years, the typical compliance cycle for US-based
BPS. Where a building does not already meet those targets, it will be required to also submit what is
effectively a plan for compliance with the BPS. This will ensure that project teams are thinking about a
proposed alteration within the larger context of what will be required to meet up-coming BPS
requirements. The exception allows the compliance path to be avoided when the alteration is complying
by performance modeling and that modeling shows that the alteration will bring the building into
compliance with the BPS performance target.
It may be necessary to modify the language in this provision to align with the terminology that is used in
the official BPS regulation to maximize correlation and usability. For example, the provision can be
modified to align with a carbon-based BPS by replacing “EUI” with “CUI” throughout and adding the
following definition:
CARBON USE INTENSITY (CUI). An expression of building carbon emissions in terms of the
equivalent carbon emissions of the net energy divided by gross floor area.

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This definition defines a carbon use intensity that parallels the definition of EUI. It is a carbon metric
where carbon emissions are divided by gross floor area in order to compare the emissions of different
buildings or assess the performance a building’s carbon emissions against a target.

Renumber as follows:
R503.1.1 R503.2 Building envelope.
R503.1.1.1 R503.2.1 Replacement fenestration.
These edits implement the restructuring discussed above in Section R501. The content of the sections
is unaffected.

Revise text as follows:


R503.1.2R503.3 Heating and cooling systems. New heating, and cooling systems HVAC ducts
newly installed as part of an alteration shall comply with Section R403 and this section.
Alterations to heating, cooling and duct systems shall comply with this section.
New HVAC and ducts in an alteration must meet the requirements for new construction of Section R403
along with specific requirements in this section tailored for decarbonization of existing buildings. Work
that is purely alteration to HVAC is directed to follow specific language in this section.

Add new text as follows:


R503.3.1 Ducts. Ducts and air handlers that are a part of the alteration shall be installed
in accordance with this section.
R503.3.1.1 New ducts. Newly installed ducts and air handlers shall be installed
in accordance with R403.3.
Exception: Where the capacity of the heating or cooling equipment is not
increased Sections R403.3.5 and R403.3.6 shall not be required.
R503.3.1.2 Existing ducts. Existing duct systems shall be tested in accordance
with Section R403.3.5 and shall have a total leakage less than or equal to 12.0
cubic feet per minute (339.9 L/min) per 100 square feet (9.29 m2) of conditioned
floor area.
Exceptions:
1. Where the total length of all ducts in the system is increased by less than 25%.
2. Where less than 25% of the registers, and less than 25% of the total
length of the ducts in the system are relocated.
During an alteration, building owners often re-use and extensively alter their ductwork without testing
and meeting any kind of air-leakage requirement. Because the standards for duct construction in the
IECC have changed dramatically over time, existing duct systems often have substantial leakage far

RESIDENTIAL OVERLAY (MIXED-FUEL) NEW BUILDINGS INSTITUTE | EXISTING BUILDING DECARBONIZATION CODE | 95
beyond what is allowed in new construction. This section requires that existing ductwork that is
substantially altered will have to meet a maximum leakage requirement. The leakage criterion is set at 3x
the requirement for new construction, so the altered ductwork would not be required to be as tight as new
construction. Existing ductwork that does not receive substantial alteration is unaffected by this section.

Add new text as follows:


R503.3.2 System Sizing. New heating and cooling equipment that is part of an alteration
shall be sized in accordance with Section R403.7 based on the existing building features
as modified by the alteration.

Exception: Where it has been demonstrated to the code official that compliance with
this section would result in heating or cooling equipment that is incompatible with
the remaining portions of the existing heating or cooling system.
Oversized equipment results in increased energy use, decreased occupant comfort and increased wear-
and-tear on equipment. Oversized equipment is also less effective at dehumidification. Like-for-like
equipment replacement are particularly vulnerable to oversizing. This requirement ensures that new
heating and cooling equipment installed in existing buildings is properly sized based on the buildings
features as modified by the alteration. It provides an exception for situations where right-sizing
equipment may create an incompatibility with the rest of the system (as can be the case with steam
systems where boilers are sized to the radiators/convectors and not the building).

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R503.3.3 Controls. New heating and cooling equipment that are part of the alteration
shall be provided with controls that comply with Section R403.1 and Section R403.2.
Controls are a vital component of effective and efficient operation of heating and cooling systems and
older controls that do not meet current code requirements significantly hamper efficiency in buildings.
This section requires that new heating and cooling equipment installed as part of an alteration be
provided with controls that will ultimately reduce the energy use and thus utility bills of an existing
building. This section also ensures that thermostats are demand responsive, thus improving the resiliency
and reducing emissions of the electrical grid.

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R503.3.4 Space heating. New combustion equipment used for space heating that is part
of the alteration shall comply with Section R501.8.
This ensures the installation of combustion space heating equipment that is both more efficient and less
likely to worsen indoor air quality as required in Section R501.8.

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R503.3.4.1 Partial electrification of space heating. New and replacement
combustion equipment used for space heating shall only be permitted to be
installed as supplementary heating controlled in accordance with R501.8.
Where there are technical barriers to the full electrification of a building’s space heating system, hybrid
heat systems that combine heat pumps with combustion equipment are an effective strategy to reduce
carbon emissions through improving the efficiency of the system and reducing onsite combustion emissions.
In these systems, a heat pump serves most of the heating loads and the combustion equipment only operates
when the heat pump is unable to keep up with heating demand, particularly during low outdoor
temperatures. By prohibiting new combustion equipment except as supplementary heat, this section requires
that existing combustion heating systems be converted to hybrid heat systems at equipment replacement.

Add new text as follows:


R503.3.5 Cooling equipment. New and replacement unitary air conditioners shall be
electric heat pump equipment sized and configured to provide both space cooling and
space heating. Any other space heating systems that serve the same zone shall be
configured as supplementary heat in accordance with Sections R403.1.2 and R501.8.

Exception: Where a space heating system serves multiple dwelling units the system
is not required to be configured to supplementary heat.

Unitary air conditioners are essentially cooling-only heat pumps. AC replacement therefore provides a
valuable opportunity to electrify or partially electrify space heating. This section requires that when AC
equipment is replaced that it gets replaced with a heat pump sized for the home’s heating load. It also
requires that any existing heating system be reconfigured as supplementary heating. This allows existing
heating equipment to remain as a backup heating system, which is particularly important in buildings
that are required to have emergency backup power for heating.

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R503.3.6 Combustion cooking. Where a space that is part of the alteration includes
combustion equipment for domestic cooking, the domestic cooking equipment shall be
provided with exhaust equipment that complies with Sections M1503.2 through M1503.4
of the International Residential Code and the following:
1. The exhaust fan shall be sized to provide no less than 150 CFM of intermittent airflow.
2. The domestic cooking equipment shall be provided with makeup air in
accordance with Section M1503.6.1 and makeup air dampers that comply with
Section M1503.6.2 of the International Residential Code.

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Gas cooking can release levels of pollutants that, if they were measured outside, would violate the Clean
Air Act. 18 As a result, households with gas cooking have nearly three times the rate of treatment for
asthma. 19 Outside of commercial kitchens, the mechanical code has only limited ventilation requirements
for cooking, only requiring ventilation for the room and not the cooking appliance itself. It also does not
differentiate between gas and electric cooking, despite the significantly higher level of pollutants from gas
cooking. 20 Ventilation has not always been required in spaces with cooking, so many existing buildings do
not have any mechanical ventilation at all. This provision improves the health and indoor air quality of
buildings with gas cooking by requiring that spaces with combustion cooking that undergo an alteration
be equipped with appropriate ventilation for gas cooking. It requires exhaust specifically at the cooking
equipment, and not just the space. It also requires makeup air to ensure that the exhaust fans are
effectively exhausting contaminants. The ventilation rate has been set at 150CFM. This is higher than the
requirement in the mechanical code in order to account for the higher concentration of pollutants in gas
cooking. The exhaust rate is based on Washington state code requirements for ventilation of gas cooking.

Revise text as follows:


R503.1.3 R503.4 Service hot water systems. New service hot water systems that are part of the
alteration and serve multiple dwelling units shall comply with Section C503.4. New service hot
water systems that are part of the alteration and serve individual dwelling units shall comply with
Section R403.5 and this section.

This provision ensures that systems that serve multiple dwelling units comply with the commercial
alterations section, which has requirements that are more appropriate for large central systems. It directs
smaller systems that serve individual dwelling units to comply with the new construction requirements in
Chapter 4 and new water heating electrification requirements for water heating in the subsections. The
numbering change implements the restructuring discussed above in Section R501.

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R503.4.1 Service hot water equipment replacement. New combustion equipment used
for water heating that is part of the alteration shall comply with Section R501.7.
This requires the installation of combustion water heating equipment that is both more efficient and less
likely to worsen indoor air quality as stipulated in R501.7

18
Gillis, J. and Nilles, B. (2019). “Your Gas Stove Is Bad for You and the Planet” The New York Times.
www.nytimes.com/2019/05/01/opinion/climate-change-gas-electricity.html
19
Jarvis et al. (1996) “Evaluation of asthma prescription measures and health system performance based on emergency
department utilization.” https://www.ncbi.nlm.nih.gov/pubmed/8618483
20
D. Michanowicz, et al. (2022) “Home is Where the Pipeline Ends: Characterization of Volatile Organic Compounds Present in
Natural Gas at the Point of the Residential End User.” American Chemical Society.

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R503.1.4 R503.5 Lighting. New lighting and power systems that are part of the alteration shall
comply with Section R404.1 and this section.

This minor change adds “power” to the title and scope of R503.5 so that decarbonization requirements
related to electrical power can be added to the section.

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R503.5.1 Electrical Service replacement. Where a building electrical service is
replaced, the new electrical service shall include electrical capacity sized in accordance
with IRC Section E3702 for the following future branch circuits:

1. Replacement of all currently installed combustion equipment used for cooking


with electric cooking equipment
2. Replacement of all currently installed combustion equipment used for space
heating with electric heat pump equipment or reverse-cycle chiller sized for the
heating load of the building in accordance with R403.7 based on the existing
building features
3. Replacement of all currently installed combustion equipment used for water
heating with electric heat pump equipment sized for the service hot water load of
the building
4. Replacement of all currently installed combustion equipment used for clothes
drying with electric clothes drying equipment
5. Replacement of all currently installed combustion lighting with electric lighting.
6. Electric vehicle charging infrastructure in accordance with Section R404.5
7. Energy storage infrastructure in accordance with Section R404.6
8. Renewable energy infrastructure in accordance with Section R404.4
The required capacity of space and water heating equipment shall be able to be reduced by
any energy recovery systems serving the water or space heating equipment in the building.
One potential significant cost in electrification retrofit projects is electrical service replacement. This
section ensures that if a building service is being replaced that it must be sized for the full electrification
of combustion equipment in the building – space heating, water heating and cooking – and for the
addition of the EVCI requirements in R404.5. “Electrification-sizing” the electrical service at the time of
normal replacement is the most cost-effective approach to providing sufficient capacity for individual
electrification retrofits. This will remove that barrier for future electrification retrofits.

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Add new text as follows:
R503.5.3 Electric vehicle charging infrastructure. Alterations shall be provided with
electric vehicle charging infrastructure in accordance with this section.

R503.5.3.1 One- and two-family dwellings and townhouses. An alteration of a


one- and two-family dwelling and townhouse where any of the following apply
shall meet the requirements of R404.5.1.
1. Substantial improvements

2. Where the alteration includes a new dedicated attached or detached


garage or on-site parking space
3. Where alteration work in a garage includes the installation of a new
branch circuit
This section requires new parking facilities to meet the EV charging requirements in the new construction
portion of the Building Decarbonization Code. While this is implicitly required by Section C501, the
addition of this section makes it explicit for greater clarity and enforceability.
R503.5.3.2 R-2 occupancies. Alterations to existing parking facilities in R-2
occupancies shall comply Section C503.5.3.

This section requires that any substantial alteration or alteration that includes a new attached or detached
garage of single and two-family dwellings or townhouses meets the electric vehicle charging infrastructure
requirements in Section R404.5.1. R404.5.1 requires one and two-family dwellings and townhouses to have
one parking space with an EV Ready space that is sized to accommodate the most common EVSE on the
market. The requirements for EV charging infrastructure for multifamily buildings are referenced to the
commercial alteration requirements as those are more appropriate for EV charging in parking lots.

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R503.5.4 Fuel gas lighting equipment. Fuel gas lighting systems shall not be installed.
While the use of gas lighting is nearly extinct for both indoor and outdoor new construction uses, gas
lamps remain a nostalgic feature in historic neighborhoods. Since the IRC Chapter 24 Fuel Gas does not
prohibit the installation of fuel gas lighting, it is critical to ensure that the adoption of this overlay does
prohibit these installations.

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R503.5.5 Renewable energy infrastructure. Substantial improvements and alterations
that include roof replacements shall meet the requirements of R404.4.
Exception: Where roof replacements do not alter the existing structure and it has
been demonstrated to the code official that the existing structure cannot support the
addition of solar panels.
Roof replacements need to include the solar readiness requirements or install solar as specified in R404.4.

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R503.6 Additional Efficiency Packages. Substantial energy alterations shall comply with
Sections R506 in accordance with this section. All-electric buildings shall install one package and
mixed-fuel buildings shall install two packages.
Exceptions:
1. Alterations that are permitted with an addition complying with Section R502.6.
2. Where the alteration complies with Section R405 or R406.
This section works with the new section R506 (see below for more) to bring additional energy efficiency
through implementing the additional efficiency packages from R408 in “major alterations”. It is
structured to apply only to substantial energy alterations. This ensures that this requirement will only be
triggered by projects that already have a large enough scope for which there are multiple package
options available to implement. All-electric homes are required to select one while mixed-fuel buildings
are required to select 2, ensuring that fossil fuels are additionally conserved through efficiency gains.
Exceptions for alterations that are permitted and comply in conjunction with an addition and alterations
that comply with sections R405 and R406 are presented.

R505 CHANG E OF OCCUPANCY


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R505.1.2 Combustion equipment. New combustion equipment shall not be installed in a
space undergoing a change of occupancy.

This provision will result in the partial electrification of a change of occupancy by prohibiting the
installation of new combustion equipment. Existing combustion equipment is allowed to remain or be
extended into the changed spaces. This would build on whatever electrification provisions the jurisdiction
chooses for the alterations section and should be seen as going beyond the requirements for alterations.

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R505.2 Additional energy efficiency packages. Where a space undergoing a change of
occupancy is served by combustion equipment, it shall install one additional efficiency package
option in addition to the requirements of Section R401.2.5.
Exception: Alterations complying with Section R503.1.2 or R503.6.
Many changes of occupancy are subject to full code compliance, which includes Section R408. This
section requires that changes of occupancy that are served by combustion equipment implement an
additional package option beyond new construction, for a total of two packages. The provision includes
an exception for mixed-fuel alterations that are already required to comply with the ERI or EUI
requirements of R503.1.2 or the additional package required by Section R503.6.

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R506 ADDITIONAL EFFICIENCY
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SECTION R506
ADDITIONAL EFFICIENCY PACKAGE OPTIONS

R506.1 General. This section establishes additional requirements to achieve additional energy
efficiency in existing buildings. Additional efficiency package options for compliance with
Section R502.6, R503.6, and R505.2 are as follows:
1. Enhanced envelope performance in accordance with Section R408.2.1.
2. More efficient space-conditioning equipment performance in accordance with Section R408.2.2
3. Reduced energy use in service water-heating in accordance with Section R408.2.3
4. More efficient duct thermal distribution system in accordance with Section R408.2.4
5. Improved air sealing and efficient ventilation system in accordance with Section R408.2.5

Section R408 was added to the IECC in 2021. It requires new homes to include an additional efficiency
option to achieve greater efficiency. There is one significant gap in R408, it does not apply to additions or
alterations. R502 and R503 do not reference R408 in the sections with which additions and alterations
must comply. The exclusion from Section R408 is a significant missed opportunity for efficiency in
additions and alterations.
This proposal creates a framework to apply R408 to additions and substantial alterations. It creates a
new Section R506 that provides guidance for how to utilize R408 packages for existing buildings. It works
in conjunction with new sections R502.6 and R503.6 (see above) that establish which additions and
alterations will need to comply with this section.
Where adopted, jurisdictions should include the revisions to Section R408 that are captured in the new
construction versions of the Building Decarbonization Code which removes the incentive for more
efficient gas equipment for all-electric requirements and adds an additional option for water heating
systems for mixed fuel buildings.

Chapter 6 – Referenced Standards


Add new standard as follows:

ASHRAE
100---2018: Energy Efficiency in Existing Buildings
R503.1.2

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Chicago, IL

Codes for Climate is an initiative of NBI and RMI to deliver the climate-aligned
building codes and standards needed by U.S. states and cities in the face of
the pressing demands of policy goals. To scale greenhouse gas reductions
in the buildings sector to be in step with a 1.5ºC future, the initiative works
to support policy makers at multiple levels to move codes and standards
forward, making significant reductions in energy consumption and GHG
emissions from buildings possible and effective. The Existing Buildings
Decarbonization Code supports the goals of the Codes for Climate Initiative.

New Buildings Institute (NBI) is a nonprofit organization working to advance


best practice energy efficiency and decarbonization of the built environment.
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