Draft Proposal CA-11 

This concept has been developed by the DOE Building Energy Codes Program (BECP) as a possible code

change proposal to the Commercial provisions of the 2012 International Energy Conservation Code

(IECC).   Interested parties are asked to submit any and all comments on DOE's initial concepts and draft

code change proposals. For instructions on submitting comments, visit:

www.energycodes.gov/development/commercial/codes/iecc/concepts/

Increase IECC Scope for Additions and Alterations (CA-11) 

Objective: Increase the scope of what must meet the provisions of the IECC for additions,

rehabilitations, renovations, or repairs (e.g., reducing the exceptions in that area).

Suggested Code Change Proposal

Revise Exceptions 3, 7 and 8 to Section C101.4.3 as follows:

3. Existing cCeiling, wall or floor cavities exposed during construction provided these cavities they 

are filled with insulation having an R-value of at least 3.5 per inch of thickness.

7. Alterations that involve replacement of replace less than 50 10 percent of the connected lighting 

load luminaires in a space provided that such alterations do not increase where the space use is not 

changed and the installed interior lighting power is not increased. 

8. Alterations that replace only the bulb lamp and ballast within no more than 10 percent of the 

existing luminaires in a space provided that the alteration does not increase the installed interior 

lighting power. 

Reason: In Exception 3, additional clarification is needed as to the amount of insulation required when a

cavity is opened up and available for application of insulation.  The term “insulation” is not defined in

the code, although it is generally understood.  That said, it seems reasonable to establish a minimum

level of performance for the insulation to be applied.

The intent of exception 7 is to allow minor remodels or repairs without a wholesale upgrade of the

lighting system.  The move from 50% to 10% of the space lighting load is justified, as when a significant

portion of the space luminaires are replaced, it will be cost effective to meet current lighting power

density and control requirements on a par with new construction.  The language is also clarified to

improve understanding.  Moving to 10% aligns this provision with ASHRAE 90.1‐2010.  The exception is

also revised to provide a caveat focused on a change in space use, something that should be considered
within the scope of the code and in all cases “trigger” bringing the new space use in compliance with the

code as if it were a new space (technically such a change in space use is a new space).   

Exception 8 is similar to 7, in that it allows fixture repair without requiring upgrade to meet existing

lighting codes.  When replacement of lamps and ballasts for more than 10% of the fixtures in a space is

undertaken, it is appropriate to use ballasts and lamps that meet current connected lighting lode

requirements.  There are a range of reduced ballast factor ballasts on the market that allow updating of

fixtures to meet current code.

Cost Impact:  There is a possible first cost impact associated with this proposed change to the degree

that some lighting system alterations that involve replacement of luminaries will now have to meet the

code where previously they might have been excepted.  The cost should not be excessive, as efficient

luminaires and lamps are readily available that meet current codes.  Such systems that would now be

covered would subsequently use less energy and cost less to operate.  The cost effectiveness of more

efficient luminaires and lamps that meet code has been previously demonstrated in adoption of those

requirements into code.