Draft Proposal E-6 

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 Existing Buildings Code (IEBC).   

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/iebc_concepts

Occupancy Change Requirements (E-6) 

Objective: Require the building to either meet the provisions of the International Energy 

Conservation Code (IECC) or have no increase in connected load or capacity when there is a 

change in occupancy. Two alternatives are presented for consideration. 

Alternative 1: 

Suggested Code Change Proposal 

Add a new Section [B] 407.5 as follows: 

[B] 407.5 Energy Efficiency. 

Where a change in occupancy results in an increase in the connected lighting power, 

installed heating equipment capacity, or installed cooling equipment capacity of the 

building or portion thereof associated with the occupancy change, the building shall be 

brought into compliance with the IECC as if it were a new building or the building 

modified so that there is no increase in the connected lighting power, installed heating 

equipment capacity, and installed cooling equipment capacity.

Reason: Forty percent of U.S. energy use and seventy percent of U.S. electrical use are 

associated with existing buildings. As such, existing buildings represent a significant 

opportunity to save energy, reduce operating costs, and enhance the environment. Some 

portion of commercial building space undergoes a change in occupancy each year. Health and 

life safety codes currently address those changes in occupancy such that the resultant building 

after the occupancy change provides the necessary capabilities to protect the public health and 

safety. A review of Chapter 10 of the International Existing Buildings Code (IEBC) on changes 

in occupancy indicated the chapter does not include a consideration of energy efficiency, nor 

does Section 407. The IEBC must address this issue in situations where a change in use would 

result in an increase in energy use. 
Consider, for instance, the change in use from a storage warehouse to retail space, a portion of 

an office building to food service, or any other number of situations where the energy use of the 

building or spaces associated with the occupancy change will be increased. There currently is 

no way in the IEBC to address those, presenting a lost opportunity and even a way to 

circumvent the 2012 IECC. The proposed change addresses this by offering two options by 

which to achieve compliance. One is to bring the building after the occupancy change up to the 

2012 IECC, and the other is to simply accomplish the change with no increase in connected 

load. 

Cost Impact: There will be an increase in cost to the degree that buildings that previously were 

not required to meet the energy code will now be required to either meet the energy code or be 

creative in implementing the change with no increase in connected load. 

Alternative 2: 

Suggested Code Change Proposal 

Add a new Section [B] 407.5 as follows: 

[B] 407.5 Energy Efficiency. 

Where a change in occupancy results in an increase in the installed capacity of the 

building electrical and/or energy systems from non-renewable sources the building or 

portion thereof associated with the occupancy change shall be brought into compliance 

with the IECC as if it were a new building or the building modified so that there is no 

increase in the increase in installed capacity of the building electrical and/or energy 

systems from non-renewable sources of electrical power or energy.

Reason: Forty percent of U.S. energy use and seventy percent of U.S. electrical use are 

associated with existing buildings. As such, existing buildings represent a significant 

opportunity to save energy, reduce operating costs, and enhance the environment. Some 

portion of commercial building space undergoes a change in occupancy each year. Health and 

life safety codes currently address those changes in occupancy such that the resultant building 

after the occupancy change provides the necessary capabilities to protect the public health and 

safety. A review of Chapter 10 of the International Existing Building Code (IEBC) on changes in 

occupancy indicated in the chapter does not include a consideration of energy efficiency, nor 

does Section 407. The IEBC must address this issue where a change in use would result in an 

increase in energy use. 

Consider, for instance, the change in use from a storage warehouse to retail space, a portion of 

an office building to food service, or any other number of situations where the energy use of the 

building or spaces associated with the occupancy change will be increased. There currently is 

no way in the IEBC to address those, presenting a lost opportunity and even a way to 

circumvent the 2012 IECC. The proposed change addresses this by offering two options by 

which to achieve compliance. One is to bring the building after the occupancy change up to the 

2012 IECC, and the other is to simply accomplish the change with no increase in connected 

load. 
Cost Impact: There will be an increase in cost to the degree that buildings that previously were 

not required to meet the energy code will now be required to either meet the energy code or be 

creative in implementing the change with no increase in connected load.