Draft Proposal E-8 

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

Demand Increase Requirements (E-8) 

Objective: Require the building to meet the provisions of the 2012 International Energy 

Conservation Code (IECC) with any change in occupancy resulting in increased demand for 

energy or power. Two alternatives are presented for consideration. 

Alternative 1: 

Suggested Code Change Proposal 

Add new Sections 1011 and 1011.1 as follows: 

1011 ENERGY EFFICIENCY

1011.1 Increased demand. Where the occupancy of an existing building or part of an 

existing building is changed such that the new occupancy results in an increase in the 

connected lighting power, installed heating equipment capacity, or installed cooling 

equipment capacity of the building the new occupancy shall comply with the IECC or the 

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

installed heating equipment capacity, or 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. A portion of 

the total 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 does 

not include a consideration of energy efficiency. The IEBC must address this issue where a 

change in use would result in an increase in energy use. This is consistent with, for instance, 

Section 1010 on plumbing, in which a change in occupancy that results in an increased demand 

for water triggers a requirement to meet the International Plumbing Code. 

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 in which 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 changes in occupancy that 

previously were not required to meet the energy code will now be required to meet the energy 

code. 

Alternative 2: 

Suggested Code Change Proposal 

Add new Sections 1011 and 1011.1 as follows: 

1011 ENERGY EFFICIENCY

1011.1 Increased demand. Where the occupancy of an existing building or part of an 

existing building is changed such that the new occupancy results in an increase in the 

installed capacity of the building electrical and/or energy systems from non-renewable 

sources the new occupancy shall comply with the IECC or the building modified so there 

is no 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. A portion of 

the total 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. The IEBC must 

address this issue where a change in use would result in an increase in energy use. This is 

consistent with, for instance, Section 1010 on plumbing, in which a change in occupancy that 

results in an increased demand for water triggers a requirement to meet the International 

Plumbing Code. 

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 in which 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 changes in occupancy that 

previously were not required to meet the energy code will now be required to meet the energy 

code.