PUBLIC CODE CHANGE PROPOSAL FORM 

FOR PUBLIC PROPOSALS TO THE INTERNATIONAL CODES 

2012-2014 CODE DEVELOPMENT CYCLE 

CLOSING DATES: Group A Codes: January 3, 2012 

Group B Codes: January 3, 2013 

Group C Codes: January 6, 2014 

*See Item 3 of these instructions for additional information concerning Group A and Group B Code 

 Development Committees Responsibilities* 

1)

Name: Date: 

Jurisdiction/Company: 

Submitted on Behalf of: 

Address: 

City: State: Zip Code: 

Phone: Ext. Fax: 

E-mail address (see # 4 below): 

2) Copyright Release: In accordance with Council Policy #28 Code Development, all Code Change Proposals, Floor Modifications and 

Public Comments are required to include a copyright release. A copy of the copyright release form is included at the end of this form. 

Please follow the directions on the form. This form as well as an alternative release form can also be downloaded from the ICC website 

at www.iccsafe.org. If you have previously executed the copyright release for this cycle, please check the below:

______2012-2014 Cycle copyright release on file 

3) Code: Indicate appropriate International Code(s) associated with this Public Proposal – Please use Acronym: ___IECC_____ 

 

If you have also submitted a separate coordination change to another I-Code, please indicate the code: ________ 

(See section below for list of names and acronyms for the International Codes). 

NOTE: Sections of the International Codes that have a letter designation in brackets in front of them are the responsibility of a 

different committee than the committee normally responsible for that code. For instance, Section 301.1.4 of the IEBC has a [B] in front 

of it, meaning that this section is the responsibility of one of the IBC Code Development Committees (in this case, IBC-S). Any

proposed changes to Section 301.1.4 will be heard by the IBC-Structural committee. 

Therefore, some code change proposals to Group B code text may be due by January 3, 2012, in order to be heard by Group A 

code development committees, and vice versa (proposed revision to a Group A code due January 3, 2013.) Please go to 

www.iccsafe.org/responsibilites for detailed information on Group A and Group B Code Development Committee 

responsibilities. 

4) Multiple Proposals: A proponent shall not submit multiple code change proposals to the same code section. When a proponent 

submits multiple code change proposals to the same section, the proposals shall be considered as incomplete proposals and not 

processed in accordance with Section 4.3 of CP #28. This restriction shall not apply to code change proposals that attempt to address 

differing subject matter within a code section. 

5) Referenced Standards: Check here if this code change proposal includes reference to a standard that is not currently referenced in 

one of the I-Codes. _____

 NOTE: If a new referenced standard is proposed, a copy of the standard must be provided by the proponent of the code change 

proposal. (This code change proposal will be considered incomplete and not processed if the new standard is not submitted in at least 

consensus draft form in accordance with Section 3.6 of Council Policy CP #28.) If you have forwarded a copy of the standard(s) to 

ICC please check below: 

 ______ Copy of new referenced standard(s) sent. (Please check: Electronic ___ or Hard Copy ___) 

6) E-mail address: Your email address will be published with your code change proposal unless you check here: ______

7) Information required: Be sure to format your proposal and include all information as indicated below and in the Code Change Proposal 

 Instructions’ section on Page 2 of this form. 
 

8) Format: Proposals should be sent to the office below via regular mail or email. An e-mail submittal is preferred, including an 

electronic version, in either WordPerfect or Word (see proposal formatting section on Page 2 of this form). 

Please use a separate form (see page 3) for each proposal submitted. Note: All code changes received will receive an acknowledgment 

by approximately two weeks after the code change deadline. Please contact the ICC staff listed below if you have not received an 

acknowledgment by two weeks after the code change deadline.

Group A Group B Group C Send to: 

IBC - International Building Code 

IFGC - International Fuel Gas Code 

IMC - International Mechanical 

Code 

IPC - International Plumbing Code 

IPSDC - International Private 

Sewage Disposal Code 

IADMIN – International Administrative Code 

(Chapter 1 of I-Codes except the IRC and the 

IECC, and Referenced Standards Updates) 

IEBC - International Existing Building Code 

IECC - International Energy Conservation 

Code 

IFC - International Fire Code 

ICC PC - ICC Performance Code 

IPMC - International Property Maintenance 

Code 

IRC - International Residential Code 

IWUIC - International Wildland-Urban 

Interface Code 

IZC - International Zoning Code

IgCC – International Green 

Construction Code 

ISPSC – International Swimming 

Pool and Spa Code 

International Code Council 

Chicago District Office 

Attn: Dynice Broadnax 

4051 West Flossmoor Road 

Country Club Hills, IL 60478-

5795 

Fax: 708/799-0320 

codechanges@iccsafe.org

CODE CHANGE PROPOSAL INSTRUCTIONS 

Please provide all of the following items in your code change proposal (see form on page 3). Your proposal should be entered on

page 3 as a separate file. However, please read the instructions provided below for each part of the code change proposal. The 

sections identified in parentheses are the applicable sections from CP #28 Code Development. The full procedures can be 

downloaded from www.iccsafe.org. 

PROPOSAL FORMATTING:

Show the proposal (see form on page 3) using strikeout, underline format. At the beginning of each section, one of the following instruction 

lines are also needed: 

 •Revise as follows 

 •Add new text as follows 

 •Delete and substitute as follows 

 •Delete without substitution 

The only formatting that is needed is BOLDING, STRIKEOUT AND UNDERLINING. Please do not provide additional formatting such 

as tabs, columns etc. as this will be done by ICC. DO NOT USE THE TRACKING CHANGES OPTION, AUTOMATIC 

NUMBERING, OR ANY OTHER ADVANCED FORMATTING TOOLS PROVIDED BY WORD. 

SEPARATE GRAPHIC FILES ARE REQUIRED FOR GRAPHIC MATERIALS. Graphic materials (Graphs, maps, drawings, charts, 

photographs, etc.) must be submitted as separate electronic files in .CDR, IA, TIF or .JPG format (300 DPI Minimum resolution; 600 DPI 

or more preferred) even though they may also be embedded in your Word or WordPerfect submittal. 

SUPPORTING INFORMATION: (3.3.4 & 3.4) 

The following items are required to be included in your proposal (see form on page 3): 

1. The proponent shall clearly state the purpose of the proposed code change 

2. The proponent shall provide a logical explanation which clearly shows why the current Code provisions are inadequate or overly

restrictive, specifies the shortcomings of the current Code provisions and explains how such proposals will improve the Code. 

3. The proponent shall substantiate the proposed code change based on technical information and substantiation. A minimum of two copies 

of all substantiating information shall be submitted. 

4. The proponent shall submit a bibliography of any substantiating material submitted with the code change proposal. 

REFERENCED STANDARDS: (3.4 & 3.6) 

List any new referenced standards that are proposed to be referenced in the code and provide a minimum of two copies. See also Item 5 on 

page 1 regarding proposed new referenced standards. Updates to currently referenced standards will be processed as a Group B proposal. 

For ICC rules on referenced standards, see Section 3.6 of CP #28. Additional copies will be required for committee members. ICC staff 

will provide you with a mailing list for the appropriate committees.

COST IMPACT: (3.3.5.6) 

The proponent shall indicate one of the following regarding the cost impact of the code change proposal: 

1) The code change proposal will increase the cost of construction; or 
 

2) The code change proposal will not increase the cost of construction.

The proponent should submit information that supports their claim. Any information submitted will be considered by the code development 

committee. This information will be included in the bibliography of the published code change proposal.

CODE CHANGE SUBMITTAL EXAMPLE

Code: IBC–12/13

705.1 

Proponent: John Doe, P.E., Acme Building Corporation, Inc, representing self

Revise as follows:

705.1 General. Each portion of a building separated by one or more a fire walls that comply

complies with the provisions of this section Section 705 shall be considered a separate building. 

Reason: A fire wall complying with Section 705 establishes the equivalent of separate buildings on either side of the fire 

wall. This proposal provides text that more succinctly states this purpose of a fire wall. 

Cost Impact: The code change proposal will not increase the cost of construction. 

Public Hearing: Committee: AS AM D 

 Assembly: ASF AMF DF 

CODE CHANGE PROPOSAL FORM 

(See instructions on page 2) 

Code: ____IECC____ –12-14

Code Sections/Tables/Figures Proposed for Revision (3.3.2); Note: If the proposal is for a new section, indicate (new). 

Table Section R202, Section R403.4, Section R403.4.1 (new), Chapter 5.

Proponent: Name/Company/Representing (3.3.1): (NOTE: DO NOT USE ACRONYMS FOR YOUR COMPANY OR 

ORGANIZATIONAL NAME)

Add definition to Section R202 as follows: 

DESUPERHEATER/WATER HEATER. A factory-made assembly of elements by which the flows of refrigerant vapor 

and water are maintained in such heat transfer relationship that the refrigerant vapor is desuper-heated and the water 

is heated. A water circulating pump may be included as part of the assembly.

Revise as follows: 

R403.4 Service hot water systems. Energy conservation measures for service hot water systems shall be in 

accordance with Sections R403.4.1 and R403.4.2, R403.4.2, and R403.4.3. 

Add new Section R403.4.1 as follows and renumber subsequent sections: 

R403.4.1 Water heating equipment (Prescriptive). In climate zones 1 through 5 each dwelling unit shall be 

provided with one or a combination of the following with the capability to provide hot water to meet the anticipated 

needs of the dwelling unit:

1. a water heater with desuperheater tested and listed in accordance with ARI 470 

2. a heat pump water heater

3. a solar water heating system

4. an instantaneous water heater

5. a storage gas water heater with energy factor (EF) of 0.67 or greater.
 

Exception: Replacements of existing water heating equipment.

2. Add new standard to Chapter 5 as follows: 

AHRI

470-06 Performance Rating of Desuperheater/Water Heaters R403.4.1

Reason: 

As shown in the attached analysis, there are cost effective ways to achieve significant energy savings in service water heating systems in climate 

zones 1-5 compared to standard-efficiency storage electric and fuel-fired heaters. The proposed change offers multiple options for compliance with 

the new requirement. 

Cost Impact: 

The code change proposal will increase the cost of construction.

Public Hearing: Committee: AS AM D 

 Assembly: ASF AMF DF 

COPYRIGHT RELEASE FOR 

2012-2014 PROPOSALS, MODIFICATIONS and PUBLIC COMMENTS 

SUBMITTED ON 

ICC CODES 

PRODUCED & PUBLISHED BY THE

INTERNATIONAL CODE COUNCIL 

This form is required for all Proposals, Floor Modifications and Public Comments submitted to the 

International Code Council. Only one signed Copyright release form is required for the entire 2012-

2014 Cycle and will be kept on file and can be used for all Proposal, Floor Modification and Public 

Comment submittals you submit to ICC unless you represent multiple entities. An executed form is 

required for each entity represented. 

I hereby grant and assign to ICC all rights in copyright I may have in any authorship contributions I 

make to ICC in the 2012-2014 Cycle in connection with any proposal and public comment, in its 

original form submitted or revised form, including written and verbal modifications submitted in 

accordance with Section 5.5.2 of CP #28. I understand that I will have no rights in any ICC 

publications that use such contributions in the form submitted by me or another similar form and 

certify that such contributions are not protected by the copyright of any other person or entity. 
 

Signature: ________________________________________________________________ 

Please type or print full name: 

Jurisdiction/Company: _________________________________________________ 

Entity Represented: ___________________________________________________

Contact info: Phone: _________ Email: ___________________________________

Date signed: _________________________________________________________

PLEASE FAX OR MAIL THE SIGNED COPYRIGHT RELEASE TO:

Fax: ICC Codes & Standards Department - 708-799-0320 

Email: dbroadnax@iccsafe.org 

Mail: ICC Codes & Standards Development 

Chicago District Office 

4051 W. Flossmoor Road 

Country Club Hills, IL 60478-5795 
 

Water Heaters 

Description 

Residential envelopes have been getting tighter and better over the last few years. As a result, domestic 

water heating energy is emerging as a significant end-use from the efficiency stand-point. There are 

multiple ways of improving the efficiency of generating hot water in homes. We analyzed some of the more 

common methods – for homes with gas water heaters, water heaters with Energy factor (EF) greater than 

the federal minimum baseline and tankless water heaters are analyzed; for homes with electric water 

heaters, heat-pump water heaters are analyzed. Desuperheaters are analyzed for all cases. 

The Life Cycle cost analysis uses the DOE Cost Effectiveness Methodology1

 for assessing cost 

effectiveness. This analysis has been carried out for the single family prototype, for 15 locations, one 

foundation type and one heating system except the heat pump water heater analysis which is carried out 

for homes with electric resistance and heat pump space heating. Table 1 indicates the location cost indices 

provided by Faithful and Gould (2011)2

 used to reflect local construction costs. Recent residential fuel 

prices specific to each location summarized in Table 2 are used for energy cost calculations. These have 

been obtained from the DOE Energy Information Administration.3 4

 

Table 1: Cost multipliers by State 

Location State Climate

Zone

Moisture

Regime

multiplier

Miami FL 1 moist 0.884

Phoenix AZ 2 dry 0.928

Houston TX 2 moist 0.837

El Paso TX 3 dry 0.837

San Francisco CA 3 marine 1.142

Memphis TN 3 moist 0.863

Albuquerque NM 4 dry 0.903

Salem OR 4 marine 1.038

Baltimore MD 4 moist 0.956

Boise ID 5 dry 0.918

Chicago IL 5 moist 1.069

Helena MT 6 dry 0.936

Burlington VT 6 moist 0.933

Duluth MN 7 moist 1.06

 

1 http://www.energycodes.gov/development/residential/methodology/

2

 Faithful + Gould. 2011. Residential Energy Efficiency Measures – Locations Factors. Portland, Oregon. 

http://bc3.pnnl.gov/wiki/index.php/Downloads

3

 U.S. Department of Energy (DOE). 2012a. Electric Power Monthly. DOE/EIA-0226. Washington, D.C. 

http://www.eia.doe.gov/cneaf/electricity/epm/table5_6_a.html

4

 U.S. Department of Energy (DOE). 2012b. Natural Gas Monthly. DOE/EIA-0130. Washington, D.C. 

http://www.eia.gov/oil_gas/natural_gas/data_publications/natural_gas_monthly/ngm.html 
 

Fairbanks AK 8 moist 1.336

High efficiency gas storage water heaters 

This concept looks at the energy savings potential of high efficiency storage water heater. The residential 

prototype is presently equipped with a 40 gallon hot water heater. Federal minimum efficiency 

requirements were revised in 2010 and compliance with the required standards for water heaters is 

required from April 2015. The new rule requires 40 gallon gas storage water heaters to have an EF of 

0.6155

. An EF of 0.67 is analyzed in this concept. 

Table 2: Fuel Costs by State 

Location State Climate

Zone

Moisture

Regime

Electricity‐

winter

($/kWh)

Electricity‐

summer

($/kWh)

Gas

($/thm)

Oil

($/MBtu)

Miami FL 1 moist 0.117 0.117 1.532 23.7

Phoenix AZ 2 dry 0.099 0.117 1.306 23.7

Houston TX 2 moist 0.11 0.12 0.814 23.7

El Paso TX 3 dry 0.11 0.12 0.814 23.7

San Francisco CA 3 marine 0.149 0.156 0.943 23.7

Memphis TN 3 moist 0.095 0.095 0.862 23.7

Albuquerque NM 4 dry 0.099 0.116 0.791 23.7

Salem OR 4 marine 0.091 0.092 1.174 23.7

Baltimore MD 4 moist 0.134 0.151 1.039 23.7

Boise ID 5 dry 0.078 0.084 0.869 23.7

Chicago IL 5 moist 0.108 0.122 0.717 23.7

Helena MT 6 dry 0.091 0.096 0.795 23.7

Burlington VT 6 moist 0.158 0.155 1.433 23.13

Duluth MN 7 moist 0.103 0.108 0.833 23.7

Fairbanks AK 8 moist 0.166 0.171 0.839 23.7

Energy Cost Savings 

Figure 1 below shows energy cost savings for each climate zone. 

Cost Effectiveness 

The cost for high efficiency water heaters were derived from the Technical Support document and Life 

Cycle Cost (LCC) spreadsheets for the Appliance Standards rule-making for water heaters67. These costs 

are blended for retrofits and new construction. To generate costs specific to new construction alone, the 

Crystal Ball (CB) analysis was re-run with the fractions set to 100% new construction and 0% retrofits. 

 

5 http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/htgp_finalrule_fedreg.pdf 6 http://www1.eere.energy.gov/buildings/appliance_standards/residential/heating_products_fr_tsd.html 7

http://www1.eere.energy.gov/buildings/appliance_standards/residential/heating_products_fr_spreadsheets.

html
 

The total installed cost for a 40 gallon gas storage water heater with EF 0.62 works out to $1609 while the 

total installed cost for a 40 gallon gas storage water heater with EF 0.67 works out to $1468. This 

unexpected drop in costs is due to lower venting costs associated with the high efficiency water heater. 

The baseline requires natural draft venting which has higher costs than the plastic power venting apparatus 

required by the high efficiency water heater. 

It can be concluded that using a higher efficiency water heater not only saves energy during its life, but 

also costs less to install. This measure is thus, cost-effective. 

Figure 1: Energy Cost Savings for Gas Storage Water Heaters with EF 0.67 over the 2012 IECC code 

Tankless Water Heaters 

The most common type of water heaters in residences are storage type. Stand-by losses are associated 

with storage tank water heaters because hot water draws are inconsistent in homes. This concept looks at 

tankless type of water heaters, which eliminate the stand-by losses almost entirely. Tankless water heaters 

have a small storage tank, usually 1 gallon, which has a small associated stand-by loss. Tankless water 

heaters with an Energy Factor (EF) of 0.82, which is the minimum EF for EnergyStar tankless water 

heaters8

, are analyzed in this concept. 

There is some evidence that instantaneous water heaters don’t perform at their rated efficiency when 

subjected to realistic hot water draw profiles, i.e., shorter draws that occur frequently during a typical day in 

residences. To account for this reduction in performance, the assumed EF of instantaneous water heaters 

is reduced to 92% of its value9

. 

 

8

 EnergyStar website http://www.energystar.gov/index.cfm?c=water_heat.pr_crit_water_heaters 9

 RESNET reduction factor for the EF of instantaneous water heaters 
 

Energy Cost Savings 

Figure 2 below shows energy cost savings for each climate zone. 

Figure 2: Energy Cost Savings for Tankless Water Heaters over the 2012 IECC code 

Cost Effectiveness 

The costs for gas fired instantaneous water heaters are derived from the Technical Support document and 

Life Cycle Cost (LCC) spreadsheets for the Appliance Standards rule-making for water heaters. These 

costs are blended for retrofits and new construction. To generate costs specific to new construction alone, 

the Crystal Ball (CB) analysis was re-run with the fractions set to 100% new construction and 0% retrofits. 

The total installed cost for a 40 gallon gas storage water heater with EF 0.62 works out to $1609 while the 

total installed cost for a gas fired instantaneous water heater with EF 0.82 works out to $2376. Figure 3 

below shows the Life Cycle Cost for this measure across all climate zones. Tankless water heaters turn out 

to be cost effective in the warmer climate zones but not so much as we move to the colder climate zones. 
 

Figure 3: Life Cycle Cost for Tankless water heaters over the 2012 IECC. Negative values indicate 

savings. 

Heat-Pump Water Heaters 

Heat-Pump water heaters (HPWH) combine the elements of a heat-pump and a water heater. HPWHs 

extract heat from the surrounding space and use it to heat water. As a result, they provide the dual benefit 

of cooling a space while providing the required hot water. We have considered a HPWH with EF 2.0 for this 

concept. 

The HPWH is assumed to be located inside the conditioned living space. Water heaters are usually placed 

in unconditioned garages or in closets inside a conditioned space. In order to perform effectively, HPWHs 

require sufficient surrounding space for heat exchange which may not always be available within a 

conditioned space. Due to the nature of HPWHs, they perform much better within conditioned spaces in 

cooling dominated climates. HPWHs are simulated in all climate zones in this analysis. 

Energy Cost Savings 

Figure 4 below shows energy cost savings for each climate zone. 
 

Figure 4: Energy Cost Savings for Heat-Pump Water Heaters over the 2012 IECC code (electric only) 

Cost Effectiveness 

The cost for high efficiency water heaters were derived from the Technical Support document and Life 

Cycle Cost (LCC) spreadsheets for the Appliance Standards rule-making for water heaters. These costs 

are blended for retrofits and new construction. To generate costs specific to new construction alone, the 

Crystal Ball (CB) analysis was re-run with the fractions set to 100% new construction and 0% retrofits. 

According to this data, the installed cost of 40 gallon Electric Storage Water Heaters with EF 0.95 is $688 

and that of an EF 2.35 Heat Pump Water Heater is $1697. State cost multipliers from table 2 are used to 

generate incremental costs by state. Figure 5 below shows the Life Cycle Cost Savings from this measure. 

According to our analysis, Heat-Pump water heaters in place of electric storage water heaters are cost 

effective in all zones. 
 

Figure 5: Life Cycle Cost for the concept over the 2012 IECC. Negative values indicate savings. 

Desuperheaters 

During summer operation, the heat removed from the refrigerant would normally be rejected to the 

atmosphere. Using this heat in the hot water system, therefore, results in significant energy savings 

because hot water heating is performed at a reduced energy input (greatly reduced in some cases). Heat 

supplied to the water during winter operation (in the heating season) is not "free" as in the cooling mode, 

because that heat would normally be used to satisfy space heating demands. However, energy savings are 

possible because the water heating takes place at an advantageous coefficient of performance (COP). 

Energy Cost Savings 

Figure 6 below shows energy cost savings for each climate zone. Desuperheaters are most effective for 

cooling dominated climate zones as it operates only when the air conditioner is running. Hence the 

expected the energy savings are much higher for CZ 1-3, with decreasing savings for the colder climate 

zones. 
 

Figure 6: Energy Cost Savings over the 2012 IECC code for Desuperheaters 

Cost Effectiveness 

Data available online documents the cost of equipment at $500 with installation costs ranging from $500-

$1000.10 11 An incremental cost of $1250 has been assumed for both equipment and installation. 

Figure 7: Life Cycle Costs over the 2012 IECC code for Desuperheaters 

 

10 http://bc3.pnnl.gov/wiki/index.php/Desuperheaters_(0004) 11 NW Council Cots on Desuperheaters. August 2008, Regional Technical Forum.