Draft Proposal CA-7 

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/

Refer to ANSI/ASHRAE/IES Standard 90.1 (CA-7) 

Objective:  Have one uniform set of minimum energy efficiency provisions for commercial buildings in

U.S. model codes and standards by replacing all of the IECC Commercial Provisions with a reference to

ANSI/ASHRAE/IES Standard 90.1.

Suggested Code Change Proposal

Revise Chapter 1 as follows:

C101.4.4 Change in occupancy or use. Spaces undergoing a change in occupancy that would result in 

an increase in demand for either fossil fuel or electrical energy shall comply with this code. Where the 

use in a space changes from one use in Table C405.5.2(1) or (2) to another use in Table C405.5.2(1) or 

(2), the installed lighting wattage shall comply with Section C405.5 the lighting power provisions of this 

code.

C101.4.6 Mixed occupancy. Where a building includes both residential and commercial occupancies, 

each occupancy shall be separately considered and meet the applicable provisions of IECC- Commercial 

Provisions or IECC-Residential Provisions of this code based on occupancy type.

C101.5 Compliance. Residential buildings shall meet the provisions of the IECC-Residential Provisions. 

Commercial buildings shall meet the provisions of IECC Commercial Provisions ASHRAE Standard 

90.1.

Delete Section C106 Referenced Standards.

(The remainder of Chapter 1 remains unchanged.)

Delete all definitions in Chapter 2 EXCEPT the following: addition, alteration, approved, building, code

official, commercial building, dwelling unit, labeled, listed, repair, and residential building.

Delete Chapters 3 and 4.

Revise Chapter 5 as follows:  Delete all references except ASHRAE 90.1‐2010.   
Reason: There is no need to maintain two separate documents covering the minimum energy efficiency

associated with the design and construction of commercial buildings.  The additional resources

expended to do this in terms of labor cost are likely in the millions of dollars—resources that would be

better invested in research to enhance a singular document and foster its uniform adoption,

implementation, and use.  Initially there was one document (ASHRAE/IES Standard 90‐75) but because it

was a design standard, it was not considered fully suitable for adoption as a law or building regulation

nor readily suited to compliance verification.  Because of these shortcomings in this original ASHRAE/IES

standard, the U.S. Department of Energy (DOE) supported the development of the Model Code for

Energy Conservation in New Building Construction (MCEC) by the ICC legacy organizations in 1977.  That

document became the Council of American Building Officials (CABO) Model Energy Code (MEC) and, up

until 1985, was updated in concert with ASHRAE Standard 90 (i.e., the standard addressed technical

issues as a design standard and the MEC put those criteria into enforceable building regulatory text).  

Beginning in 1985, with the desire to move energy efficiency forward, the MEC approved technical

changes that were different than those in ASHRAE Standard 90.  Since that time ASHRAE Standard 90

was split into two standards: 90.1 addressing commercial buildings and 90.2 addressing low‐rise

residential buildings.  While the MEC was updated and then became the IECC, ASHRAE Standard 90.1

was also updated and maintained.  Today the result is two documents that cover the same topic (energy

efficiency in commercial buildings) and each take countless hours to update and maintain.  This code

change sets the stage for the re‐creation of a singular document to address minimum energy efficiency

in building design and construction.  At the very least it should spur an initiative that would bring

ASHRAE and ICC together to discuss consolidation of their model codes/standards associated with

commercial buildings.  Optimally one document maintained under one ongoing process would result.   

Cost Impact: There is likely no cost impact as the provisions of the IECC and ASHRAE Standard 90.1 are

considered technically similar, and because ASHRAE Standard 90.1 is adopted by reference in the IECC,

that path to compliance currently exists to all users of the IECC.  There will be a reduction in cost

associated with having to administer, apply, maintain, support, and verify compliance with multiple and

duplicative documents.