Mr. Keith Lambert  
Director, Bureau of Construction Codes  
Michigan Department of Licensing and Regulatory Affairs  
611 W Ottawa St.  
Lansing, MI 48933  
July 5th, 2022  
Re: Michigan’s 2021 Energy Conservation Code Adoption  
Dear Director Lambert,  
The undersigned organizations write in support of the inclusion of the following effective energy  
efficiency and electrification provisions in the update of Michigan’s commercial and residential  
energy conservation codes:  
1. Maintain the 2021 International Energy Conservation Code (IECC) with no weakening  
amendments for both commercial and residential codes  
2. Add back in the energy monitoring requirement in the commercial code  
3. Require electric vehicle (EV) readiness in residential code  
These provisions will lower costs for Michigan residents and businesses, increase household  
resilience from extreme weather events, and help reduce climate impacts from the building  
sector. This is crucial for ensuring Michigan’s building codes are equitable, delivering benefits to  
people facing poor housing quality, high energy burdens, and disproportionate health impacts in  
their homes and communities resulting from our reliance on fossil fuels.  
At a time of global disruption and uncertainty impacting energy prices, the solutions we propose  
are forward thinking and will improve the state’s energy independence and reduce cost-volatility  
associated with fossil fuels.  
In addition, our recommendations would grow jobs in Michigan. According to the Clean Jobs  
Midwest report, in 2019, “clean energy jobs grew more than twice as fast as overall employment  
across the Midwest,” with Michigan in particular adding thousands more jobs in renewable  
energy generation than fossil fuels.1  
1. Maintain 2021 IECC with No Weakening Amendments for Both Commercial and  
Residential Codes  
We applaud the Bureau for adopting the 2021 IECC residential code in full. As the Bureau  
moves forward with the code adoption process, we ask that you maintain the full adoption of the  
2021 IECC and adopt no amendments that would weaken its efficiency provisions.  
As a recent US Department of Energy (DOE) analysis shows, adopting the 2021 IECC is  
cost-effective and "will provide statewide energy savings of 10.7% across all climate zones  
compared to the current [Michigan] state energy code. This equates to $327 in annual utility bill  
savings for the average Michigan household.”2 Much of these savings come from improvements  
1 https://www.cleanjobsmidwest.com/state/michigan  
2 Michigan Residential Code Cost Effectiveness 2021  
in envelope requirements in the 2021 code such as continuous exterior wall insulation and high  
air-tightness requirements.  
Improved thermal envelopes not only save Michiganders money, but also provide a comfortable  
and healthy interior environment. An efficient building shell is a key mechanism for improving  
the comfort of the occupant and meeting the occupant’s needs and preferences by reducing  
unwanted temperature variations. Building envelope improvements are also a key mechanism  
to protect residents against the extreme weather events we already experience due to climate  
change.3 Effective insulation and air sealing provide essential “hours of safety” during severe  
weather events and power outages, resulting in critical extra days before the onset of  
life-threatening conditions from extreme temperatures.4 This aspect of greater efficiency is  
called “passive survivability” and provides an important health and safety rationale for stronger  
energy codes with robust building shell provisions.  
One key improvement in building shell efficiency included in the 2021 IECC is the requirement  
to have continuous wall insulation. Requiring continuous insulation benefits homeowners in  
multiple ways. First, it saves energy versus a cavity only option. More importantly, continuous  
insulation is an integral part of a holistic approach to insulation which doesn't simply view each  
section separately, but recognizes that the entire insulation system (walls, floors and ceilings)  
work together to maximize energy savings. Continuous insulation also provides additional  
comfort and resilience in the home by eliminating thermal bridges. Thermal bridges are areas of  
the envelope where cavity insulation doesn't reach (for example, at the studs) which allow heat  
to flow, which, in turn, undermines the R-value of the walls. Moreover, thermal bridges are areas  
that are susceptible to moisture. Continuous insulation eliminates this concern. The additional  
R-5 in the 2021 IECC typically amounts to 1" or less of exterior insulation. At current retail prices  
of $15/32 sq. ft (contractors should be able to make bulk purchases at a lower cost5), this will  
add no more than $750 to the cost of a home; which is a small price to pay for additional energy  
savings, increased comfort and reduced risk of moisture.  
The efficiency improvements in the 2021 IECC also help Michigan combate climate change by  
reducing building sector greenhouse gas emissions. The DOE estimates that adopting the 2021  
IECC in Michigan will “reduce statewide CO2 emissions over 30 years by 11,460,000 metric  
tons, equivalent to the annual CO2 emissions of 2,493,000 cars on the road .”6  
2. Add Back the Energy Monitoring Requirement into the Commercial Code  
Unfortunately, the draft commercial code released by LARA removed a key section from the  
IECC commercial energy conservation code – Section C405.12 to C405.12.5, which requires  
energy monitoring for buildings over 25,000 square feet. The undersigned organizations and  
communities strongly oppose this weakening amendment. You can’t manage what you don’t  
measure. The ability to understand how much energy your building is using is key to the  
operation and maintenance of buildings, particularly for large complex buildings that are  
regulated under the commercial code. Energy monitoring also increases awareness of, and  
engagement with, energy efficiency measures and other energy and emissions savings  
opportunities. Energy monitoring has been shown to reduce energy consumption in buildings by  
3 Extreme weather events have increased significantly in the last 20 years  
4 Hours of Safety in Cold Weather - RMI and https://www.urbangreencouncil.org/babyitscoldinside  
5
https://www.lowes.com/pl/Expanded-polystyrene--Board-insulation-Insulation-accessories-Building-supplies/4294858  
106?refinement=4294642294  
6 IBID US DOE Cost-Effectiveness of the 2021 IECC for Residential Buildings in Michigan  
2 to 8% by giving building owners the information they need to understand how much energy is  
being used and by what building operations. This is because building performance, if not  
properly monitored and maintained, erodes over time, and energy monitoring ensures that high  
performance buildings continue to perform as designed over the building’s lifetime. In addition, a  
growing number of communities in Michigan are working to achieve carbon neutrality by 2030.  
For these communities to be successful they must address the energy use of existing buildings  
which will be much harder without energy monitoring in place. Additionally, energy monitoring  
requirements provide tremendous data sets for energy management professionals to study,  
allowing more improvement in both the predictive energy modeling efforts in the design phase  
and the retro-commission process post building occupancy, which can help to further Michigan’s  
progress toward the 2030 goal.  
Given the importance of energy monitoring we recommend Michigan add back in the energy  
monitoring requirement in the commercial code and strengthen it by requiring end use  
monitoring of EV chargers so operators can better manage both building and vehicle energy  
consumption.  
3. Require EV Readiness for the Residential Code  
The transition to EVs is well underway. The number of EVs on US roads is projected to grow  
from 1 million vehicles at the end of 2018, to 18.7 million by 2030.7 Developments in global  
markets are driving this increase in EV adoption. Michigan’s auto manufacturers are working to  
maintain their leadership in the automotive industry by embracing the transition to EVs. For  
example, General Motors recently announced it would only produce zero-emission vehicles by  
2035.8 To power this increase in EVs, the U.S. will need 9.6 million charge ports, a substantial  
portion of which will be installed in single and multi-family residential buildings.9 Michigan  
currently only offers 480 publicly accessible charging stations featuring nearly 1,400 charging  
ports, in addition to 146 private charging stations throughout the state.10 Without additional EV  
charging readiness amendments in the state’s building code, we miss a key opportunity to help  
our residents transition to EVs.  
A major barrier to the transition to EVs is the lack of charging infrastructure at homes and the  
potential need for extensive electrical upgrades to accommodate charging. It is more  
cost-effective to make a building “EV ready” when it is being built or undergoing major  
renovations than trying to add equipment after the building is constructed. To reduce expensive  
retrofit costs, and ensure Michiganders have cost-effective access to charging, Michigan’s  
residential building code should incorporate EV-ready provisions that ensure the conduit and  
infrastructure is in place to support the easy installation of a charger. Approving an EV-ready  
amendment in the residential code will ensure people have affordable access to charging at  
their homes and allow customers to easily transition off of gas-powered vehicles when they are  
ready and able.  
Ensuring buildings have EV chargers or are EV-ready is cost effective. Research undertaken by  
New Buildings Institute indicates that the cost of the added infrastructure to make a home  
7 EEI celebrates 1 million electric vehicles on US roads  
8 https://www.nytimes.com/2021/01/28/business/gm-zero-emission-vehicles.html  
9
EEI celebrates 1 million electric vehicles on US roads  
10https://www.michigan.gov/whitmer/0,9309,7-387-90499_90640-558822--,00.html#:~:text=Michiga  
n%20currently%20offers%20480%20publicly,charging%20stations%20throughout%20the%20state.  
EV-ready is estimated to be $500 at the time of construction. If a home was not made EV-ready  
but chose to add an EV charger later with an insufficient supply infrastructure in place, the cost  
of the retrofit (if the retrofit is feasible) was found to be between $1,500 to $3,000. Therefore,  
adding the infrastructure to make a home EV-ready saves $1,000 to $2,500 for the average  
homeowner who must add an EV charger later.  
By adding provisions in the energy code to aid the transition from gas-powered to  
electric-powered vehicles, Michigan will substantially reduce carbon emissions and other  
harmful pollutants. More accessible EV charging is also necessary for meeting the  
administration’s carbon emission reduction targets and reducing local air pollution. According to  
the final MI Healthy Climate Plan, the transportation sector was the second largest source of  
Michigan’s greenhouse gas emissions.11 EVs can also reduce the health impact of carbon  
monoxide, nitrogen oxides, and other smog-causing air pollution that is typically released by  
conventional vehicles. Ensuring affordable access to charging is necessary for making it easier  
to switch over to EVs and reduce these significant emissions.  
Finally, these amendments to the code will help keep Michigan at the forefront of the auto  
industry and help support our auto workers and the Michigan auto sector as it moves towards a  
fully electric future.  
C.C.:  
Governor Gretchen Whitmer  
Jen Flood, Office of Governor Whitmer  
Kara Cook, Office of Governor Whitmer  
Liesl Clark, Department of Environment, Great Lakes, and Energy  
Cory Connolly, Department of Environment, Great Lakes and Energy  
Orlene Hawks, Department of Licensing and Regulatory Affairs  
Courtney Pendleton, Department of Licensing and Regulatory Affairs  
Marlon Brown, Department of Licensing and Regulatory Affairs  
Dan Scripps, Michigan Public Service Commission  
Charlotte Jameson  
Michigan Environmental Council  
Isaac Robert Elnecave  
PHIUS  
Dr. Laura Sherman  
Michigan Energy Innovation Business Council  
Mike Berkowitz  
Sierra Club  
11 MI Healthy Climate Plan,  
https://www.michigan.gov/egle/about/organization/climate-and-energy/mi-healthy-climate-plan  
Julie Quinn  
Michigan Clinicians for Climate Action  
Nick Occhipinti  
Michigan League of Conservation Voters  
Alexis Blizman  
Ecology Center  
David Dye  
DFD Architecture  
Jacob Serfling  
Midwest Building Decarbonization Coalition  
Diana Burk  
New Buildings Institute  
Stacey Paradis  
Midwest Energy Efficiency Alliance  
Submitted via Email: LARA-BCC-Rules@michigan.gov  
July 5, 2022  
Department of Licensing and Regulatory Affairs  
Bureau of Construction Codes  
Administrative Services Division  
American Chemistry Council Comments Supporting the Michigan Adoption of the 2021 International  
Energy Conservation Code for Residential and Commercial Buildings  
The American Chemistry Council (ACC) thanks you for the opportunity to submit comments and  
recommend the adoption of the 2021 International Energy Conservation Code (IECC) with reference to  
ASHRAE 90.1-2019.  
Chemistry is essential to the U.S. economy and plays a vital role in driving innovations that make our  
world safer, more sustainable, and more productive. Chemistry supports over 25% of the U.S. GDP and  
9% of U.S. goods exports – a $486 billion enterprise. 529,000 skilled American jobs are provided by the  
business of chemistry. The U.S. is the 2nd largest global producer, providing 13% of the world's  
chemicals. Chemistry in Michigan pays $1.83 billion in wages and generates $138 million in state and  
local taxes.1  
There are many reasons we support the Michigan adoption of these modern energy codes. Primarily,  
the energy savings that are realized by the people who live and own businesses in the state. The  
Department of Energy (DOE) determined the 2021 energy codes provide cost-effective levels of energy  
efficiency and performance for residential and commercial buildings in Michigan. Based on housing  
starts in Michigan the adoption of the 2021 Residential IECC would save $3,873,000 in the first year  
alone.2 Likewise, based on new commercial construction numbers in Michigan the adoption of the 2021  
IECC with reference to ASHRAE 90.1-2019 for commercial buildings would save $1,587,000 in the first  
year alone.3  
This is especially important in order to address the environmental justice issue of the affordable  
housing needs of lower income households. According to the U.S. Energy Information Administration:  
1 See Michigan.pdf (americanchemistry.com)  
2 See Cost-Effectiveness of the 2021 IECC for Residential Buildings in Michigan (energycodes.gov)  
3 See Cost-Effectiveness of ANSI/ASHRAE/IES Standard 90.1-2019 for Michigan (energycodes.gov)  
americanchemistry.com®  
700 Second St., NE | Washington, DC 20002 | (202) 249.7000  
Across the United States, high utility bills are costing homeowners a significant portion  
of their monthly incomes. According to the most recent EIA Residential Energy  
Consumption Survey,4 about one in five households reported reducing or forgoing  
basic necessities like food and medicine to pay an energy bill. Stronger energy codes and  
more widespread code compliance can help change the tide on this type of energy  
poverty. Improving compliance with residential energy codes opens up an array of  
economic and health benefits for homeowners, residents, local governments, and  
building officials, including:  
Reduced energy costs that yield monthly savings for owners and occupants, helping  
to boost the local economy and improving housing affordability by reducing utility  
costs.  
More comfortable and durable homes that better shield people from outdoor  
temperature extremes.  
Better protected occupant health from improved efficiency and indoor air quality.  
Greater market certainty for the building design and construction industry due to  
consistent implementation across jurisdictions.  
A level playing field for manufacturers, builders, and other building related  
industries.  
Beyond the obvious energy savings benefits there are many other important reasons for Michigan to  
update their building energy codes:  
Job creation, based on U.S. Census data on residential housing permits, it is estimated that over  
80,000 residential one- and two-family homes have been permitted in Michigan since the last  
energy code update in late 2017.5  
GHG emission reductions, DOE estimates that the 30-year cumulative reduction of CO2  
emissions that Michigan would realize with the adoption of the 2021 residential provisions is  
equivalent to 11,460,000 metric tons.6  
Resilience, in a 2021 report the National Institute of Building Sciences found that adopting the  
latest building code requirements is affordable and saves $11 per $1 invested. Building codes  
have greatly improved society’s disaster resilience, while adding only about 1% to construction  
costs relative to 1990 standards. The greatest benefits accrue to communities using the most  
recent code editions.7  
Energy Security, the International Energy Agency recognizes that energy efficiency can bolster  
regional or national energy security. By reducing overall energy demand, efficiency can reduce  
4 See Residential Energy Consumption Survey (RECS) - Energy Information Administration (eia.gov)  
5 See U.S. Census Bureau, Building Permits Survey, available at https://www.census.gov/construction/bps/  
6 See Cost-Effectiveness of the 2021 IECC for Residential Buildings in Michigan (energycodes.gov)  
7 See Mitigation Saves: Mitigation Saves up to $13 per $1 Invested (nibs.org)  
americanchemistry.com®  
700 Second St., NE | Washington, DC 20002 | (202) 249.7000  
reliance on imports of oil, gas and coal. Energy efficiency can therefore play a crucial role in  
ensuring both long- and short-term energy security in a cost-effective manner.8  
ACC is grateful for the opportunity to encourage and support the adoption of the 2021 International  
Energy Conservation Code (IECC) for all the great benefits these new codes would bring to the people in  
the State of Michigan.  
Sincerely,  
Amy Schmidt  
American Chemistry Council  
Director, Building and Construction  
8 See Energy security – Multiple Benefits of Energy Efficiency – Analysis - IEA  
americanchemistry.com®  
700 Second St., NE | Washington, DC 20002 | (202) 249.7000  
29 June 2022  
Department of Licensing and Regulatory Affairs  
Bureau of Construction Codes  
Administrative Services Division  
LARA-BCC-Rules@michigan.gov  
RE: 10a Michigan Energy Code (ORR# 2021-49 LR) Proposal  
Andrew Queenan, with Pure Architects and AIA Grand Rapids is writing in support  
of including Appendix CC, as an optional appendix, in the Michigan Commercial  
Energy Code. Currently, unlike the ASHRAE appendices, they are not specifically  
included in the draft language. We are making the following proposal (added  
language in red):  
R 408.31087 Applicable code.  
Rule 1087. Rules governing the energy efficiency for the design and construction of buildings and  
structures, not including residential buildings, shall be those contained in the international energy  
conservation code, 2015 2021 edition, except for sections C104.1 to C104.5, C107.2 to C107.5,  
C108.2 to C108.4, C109.1 to C109.4, C110.1 to C110.3, C301.2, C301.3, C302, C401.2.1 to  
C408.3.2, C405.12 to C405.12.5, C502.2 to C502.2.6.2, C503.2 to C503.6 and the ASHRAE energy  
standard for buildings except low-rise residential buildings, ANSI/ASHRAE/IESNA standard 90.1-  
2013 2019 (hereafter the standard), including appendices A, B, C, D, and G, except for sections  
8.4.2,8.4.3 to 8.4.3.2. Additionally, Appendix CC of the international energy conservation code,  
2021 edition, is included as a voluntary appendix that authorities having jurisdictions, at their  
discretion, may choose to adopt by ordinance as a supplement to the international energy  
conservation code, 2021 edition, to require renewable energy systems of adequate capacity to  
achieve net zero carbon emissions in applicable new buildings as defined in the scope of  
Appendix CC within that jurisdiction. With the amendments noted, the international energy  
conservation code and the standard are adopted by reference in these rules by reference. The  
Michigan energy code is available for inspection at the Lansing office of the Michigan Department  
of Licensing and Regulatory Affairs, Bureau of Construction Codes, 611W. Ottawa Street, Lansing,  
Michigan 48933. The code may be purchased from the International Code Council, through the  
bureau’s website at www.michigan.gov/bcc, at a cost as of the time of adoption of these rules of  
$44.00 $52.00. The ASHRAE 90.1- 2013 2019 standard is available for inspection at the Lansing  
office of the Michigan Department of Licensing and Regulatory Affairs, Bureau of Construction  
Codes, 611 W. Ottawa Street, Lansing, Michigan 48933. The standard may be purchased from the  
American Society of Heating, Refrigeration and Air- Conditioning Engineers, Inc., 1791 Tullie  
Circle, NE, Atlanta, Georgia 30329, 180 Technology Parkway NW, Peachtree Corners, Georgia  
30092, or from https://www.ashrae.org at a cost as of the time of adoption of these rules of $135.00  
$177.00 each  
1
www.purearchitects.com  
July 1, 2022  
Reasoning:  
IECC 2021 Appendix CC (aka Zero Code) is a flexible framework that cities and states  
can use to help reach their building decarbonization goals. IECC 2021 Appendix CC  
combines energy efficiency and renewable energy to support the construction of  
code-compliant, zero carbon buildings that use clean energy. It applies to new  
commercial, industrial and mid- to high-rise residential buildings—the dominant  
building types being constructed in cities today.  
As a VOLUNTARY Appendix, it gives any Authorities Having Jurisdiction the option  
of adopting the appendix. Keeping the appendix voluntary provides jurisdictions  
an important framework to reach their decarbonization goals, if they choose to  
adopt the appendix.  
In summary we support Appendix CC because:  
o Voluntary for jurisdictions to adopt  
o Compliance with 2021 IECC is required  
o Sets a minimum renewable energy requirement based on energy  
simulations or default values  
o Provides an incentive for buildings to be designed to be more energy  
efficient than code requires  
o Encourages on-site renewable energy when feasible  
o Supports off-site renewable energy procurement when necessary  
o 2021 IECC energy efficiency requirements cannot be traded with renewable  
energy  
o Establishes a consistent framework that local governments can modify for  
their specific needs and conditions  
As members of the Grand Rapids 2030 District, AIA Grand Rapids Committee on  
the Environment, and AIA Michigan, we are prepared to support ongoing  
education programs for developers, architect, engineers and code officials who  
choose to implement Appendix CC.  
Sincerely,  
ZachRB NOMA  
Man
Andrew Queenan, AIA, NCARB, LFA  
Architect  
Pure Architecture and Development, PLLC  
2
www.purearchitects.com  
July1, 2022  
Department of Licensing and Regulatory Affairs  
Bureau of Construction Codes  
Administrative Services Division  
P.O. Box 30254  
Lansing, MI 48909  
LARA-BCC-Rules @michigan.gov  
(517) 482-5519  
July 5, 2022  
Dear Director Hawks, Deputy Director Pendleton, and Director Lambert:  
Thank you for the opportunity to comment regarding the proposed rule sets (2021  
– 48 LR & 2021 – 49 LR) to amend the Michigan Energy Code. The Michigan Energy  
Innovation Business Council (Michigan EIBC) is a business trade association  
representing over 140 companies across a full range of advanced energy industries,  
including energy efficiency, electric vehicles (EVs), renewables, demand response  
technologies, energy storage, and others. Michigan EIBC’s mission is to grow  
Michigan’s advanced energy economy by fostering opportunities for innovation and  
business growth for the advanced energy industry in the state.  
Overall Comments  
Updating our building codes is one of the greatest tools the State of Michigan holds  
to make necessary advancements in energy efficiency and advanced mobility.  
Michigan EIBC strongly supports the Michigan Department of Licensing and  
Regulatory Affairs (LARA)’s Bureau of Construction Codes (BCC)’s decision to include  
significant and necessary energy efficiency improvements in the residential and  
commercial energy code drafts. The 2021 residential edition of the International  
Energy Conservation Code (IECC) represents approximately a 12% improvement in  
efficiency through more efficient thermal envelopes, improved mechanical system  
efficiency, improved lighting, and other cost-effective improvements compared to  
the 2015 model code, which is similar to Michigan’s current code. Implementing the  
1
residential IECC will save Michigan residents money on their energy bills, continue  
to support the growing industry in energy efficiency, and advance the work in  
futureproofing Michigan’s building stock.  
Michigan EIBC strongly urges LARA to push further to ensure Michigan continues on  
this track. Specifically, Michigan EIBC recommends including amendments to  
require EV charging readiness in both the residential and commercial codes. And in  
the commercial code, we strongly urge LARA to add the energy monitoring  
requirements from the 2021 IECC back into the final Michigan code. These  
additions will ensure new homes and buildings are equipped to charge their cars  
and ensure new businesses and multifamily homes are properly monitored  
through energy monitoring, so they can be better maintained over the long-term.  
EV Readiness: Residential and Commercial Codes  
Michigan EIBC strongly urges the BCC to include language requiring that all new  
homes are EV ready and commercial buildings/multi-family housing with parking  
include EV ready spaces. Both of these recommendations were included in the MI  
Healthy Climate Plan and the Michigan Council on Future Mobility & Electrification’s  
2021 Report.1, 2 Additionally, cities in Michigan are already moving in this direction:  
Ann Arbor adopted an EV charging and readiness ordinance for new developments  
last year, and Lansing is currently considering a similar ordinance.3, 4 These  
additions will not only support Michigan’s advanced mobility future and economy,  
but also, they will save residential customers and commercial building owners  
money and they will help to protect public health.  
Due to improved technology and increased consumer demand, the transition to  
EVs is well underway, and Michigan’s future buildings should be ready for this shift.  
Auto manufacturers are embracing the transition to EVs. For example, both General  
1 Michigan Department of Environment, Great Lakes, and Energy. “MI Healthy Climate Plan.” April, 2022.  
Available at https://www.michigan.gov/egle/-/media/Project/Websites/egle/Documents/Offices/OCE/MI-Healthy-  
Climate-Plan.pdf?rev=d13f4adc2b1d45909bd708cafccbfffa&hash=99437BF2709B9B3471D16FC1EC692588.  
2 Michigan Department of Labor and Economic Opportunity. “Council on Future Mobility and Electrification  
2021 Report.” Available at https://www.michigan.gov/documents/leo/CFME_Report_2021_738091_7.pdf.  
3 Stanton, Ryan. MLive. “Ann Arbor council Oks ordinance requiring EV parking for new developments.” January  
19, 2021. Available at https://www.mlive.com/news/ann-arbor/2021/01/ann-arbor-council-oks-ordinance-  
requiring-ev-parking-for-new-  
developments.html#:~:text=For%20multi%2Dfamily%20housing%20developments,and%2065%25%20EV%2Dca  
pable.  
4 Wiewgorra, Luisa. Fox 47 News. “Lansing could adopt requirements for EV charging stations.” Available at  
https://www.fox47news.com/neighborhoods/downtown-old-town-reo-town/lansing-could-adopt-requirement-  
for-ev-charging-stations  
2
Motors and Ford made announcements in the past year regarding their plans to  
switch their manufacturing to EVs.5, 6 Across the U.S., EV sales increased by 80  
percent from 2017 to 2018, and the number of EVs on U.S. roads is projected to  
grow from 1 million vehicles at the end of 2018 to 18.7 million by 2030. To charge  
these new EVs, the U.S. will need 9.6 million charging ports -- a substantial portion  
of which will be installed where they are most useful for consumers: at homes and  
businesses.  
Unfortunately, it can be costly and challenging to install charging stations at existing  
residential and commercial structures due to the potential need for extensive  
electrical upgrades. This often requires the installation of conduit through existing  
concrete or drywall to connect the electric vehicle supply equipment (EVSE) to  
electrical service. According to research from the New Buildings Institute, making  
homes EV ready at the time of construction can save customers $1,000 to $2,500 in  
retrofit costs, if they choose to install a charger at a later time. For commercial  
buildings and multi-family residences, EV ready construction can save about $7,000  
to $8,000 in retrofit costs according to a study conducted by the California Air  
Resources Board.7 Therefore, it is more cost-effective to ensure a new home or  
commercial building is EV ready when it is being built or undergoing major  
renovations than to conduct these extensive electrical upgrades when a charger is  
later installed.  
More accessible EV charging infrastructure is also necessary to reduce carbon  
emissions and local air pollution. In 2018, the transportation sector was the second  
largest source of Michigan’s greenhouse gas emissions, representing 28 percent of  
total emissions.8 In order to meet Governor Whitmer’s goal under Executive  
Directive 2020-10 of 100 percent carbon neutrality in Michigan by 2050, policies  
must be put in place to reduce transportation sector greenhouse gas emissions and  
to support the transition from gas-powered vehicles to EVs in the state.  
5 Eisenstein, Paul A. “GM to go all-electric by 2035, phase out gas and diesel engines.” Available at  
https://www.nbcnews.com/business/autos/gm-go-all-electric-2035-phase-out-gas-diesel-engines-n1256055.  
6 Wayland, Michael. “Ford ups EV investments, targets 40% electric car sales by 2030 under latest turnaround  
plan.” Available at https://www.cnbc.com/2021/05/26/ford-ups-ev-investments-targets-40percent-electric-car-  
sales-by-2030-under-latest-turnaround-  
plan.html#:~:text=Ford%20Motor%20said%20Wednesday%20it,than%20%2430%20billion%20through%.  
7 California Air Resources Board. “EV Charging Infrastructure: Nonresidential Building Standards.” November 15,  
2019. Available at ww2.arb.ca.gov/sites/default/files/2020-  
08/CARB_Technical_Analysis_EV_Charging_Nonresidential_CALGreen_2019_2020_Intervening_Code.  
pdf.  
8 Michigan Department of Environment, Great Lakes, and Energy. “Draft MI Healthy Climate Plan.” January 14,  
2022. Available at https://www.michigan.gov/documents/egle/Draft-MI-Healthy-Climate-Plan_745872_7.pdf.  
3
Additionally, according to the Health Effects Institute, “air pollution is one of the  
top-ranking factors for death and disability, with vehicle emissions [being] the main  
contributor to outdoor air pollution.”9 To both improve air quality and reduce  
emissions, it is necessary that Michigan prepares its future homes and businesses  
with the infrastructure needed to switch to EVs.  
Michigan EIBC recommends the following EV readiness language be added to  
the residential code, including new definitions, and new Section R404.5 and  
revisions to Table R405.2 and Table R406.2:  
Add new definitions as follows:  
ELECTRIC VEHICLE (EV). An automotive-type vehicle for on-road use, such as  
passenger automobiles, buses, trucks, vans, neighborhood electric vehicles,  
electric motorcycles, and the like, primarily powered by an electric motor that  
draws current from a rechargeable storage battery, a fuel cell, a photovoltaic  
array, or another source of electric current. Plug-in hybrid electric vehicles  
are electric vehicles having a second source of motive power. Off-road, self-  
propelled electric mobile equipment, such as industrial trucks, hoists, lifts,  
transports, golf carts, airline ground support equipment, tractors, boats and  
the like, are not considered electric vehicles.  
ELECTRIC VEHICLE SUPPLY EQUIPMENT (EVSE). The conductors, including  
the ungrounded, grounded, and equipment grounding conductors and  
the electric vehicle connectors, attachment plugs, and all other fittings,  
devices, power outlets, or apparatus installed specifically for the purpose of  
transferring energy between the premises wiring and the electric vehicle.  
LEVEL 2 ELECTRIC VEHICLE SUPPLY EQUIPMENT (Level 2 EVSE). Electric  
Vehicle Supply Equipment capable of providing AC Level 2 EV charging.  
EV READY SPACE. A designated parking space that is provided with an  
electrical circuit capable of supporting an installed Level 2 EVSE in close  
proximity to the proposed location of the EV parking space.  
Add new section as follows:  
9 GreenBiz. “Electric bus fleets are the latest tool for improving air quality.” Available at  
https://www.greenbiz.com/article/electric-bus-fleets-are-latest-tool-improving-air-quality.  
4
R404.5 Electric vehicle charging infrastructure. Electric infrastructure for  
the current and future charging of electric vehicles shall be installed in  
accordance with this section. EV ready spaces are permitted to be counted  
toward meeting minimum parking requirements.  
R404.5.1 One- and two- family dwellings and townhouses.  
One- and two-family dwellings and townhouses with a  
dedicated attached or detached garage or on-site parking  
spaces and new detached garages shall be provided with one EV  
ready space per dwelling unit. The branch circuit shall meet the  
following requirements:  
1. A 208/240-volt circuit installations, including panel  
capacity, raceway wiring, receptacle, and circuit  
overprotection devices that are able to provide Level 2  
charging  
2. Terminates at a junction box or receptacle located within  
3 feet (914 mm) of the parking space, and  
3. The electrical panel directory shall designate the branch  
circuit as “For electric vehicle charging” and the junction  
box or receptacle shall be labelled “For electric vehicle  
charging”.  
R404.5.2 Group R occupancies. Parking facilities serving Group  
R-2, R-3 and R-4 occupancies shall comply with Section C405.15.  
Revise table as follows:  
TABLE R405.2  
REQUIREMENTS FOR TOTAL BUILDING PERFORMANCE  
SECTION a  
TITLE  
Electrical Power and Lighting Systems  
R404.1  
R404.2  
R404.5  
Lighting equipment  
Interior lighting controls  
Electric vehicle charging  
infrastructure  
5
Revise table as follows:  
TABLE R406.2  
REQUIREMENTS FOR ENERGY RATING INDEX  
SECTION a  
TITLE  
Electrical Power and Lighting Systems  
Lighting equipment  
R404.1  
R404.2  
R404.5  
Interior lighting controls  
Electric vehicle charging  
infrastructure  
R406.3  
Building thermal envelope  
Michigan EIBC recommends the following EV readiness language be added to  
the commercial code, including new definitions, revisions to C401.2.2 and and  
Table C405. 12.2, and new section C405.14:  
Add new definitions as follows:  
AUTOMATIC LOAD MANAGEMENT SYSTEMS (ALMS). A control system that  
allows multiple connected EVSE to share a circuit or panel and automatically  
reduce power at each charger, reducing the total connected electrical  
capacity of all EVSE.  
ELECTRIC VEHICLE (EV). An automotive-type vehicle for on-road use, such as  
passenger automobiles, buses, trucks, vans, neighborhood electric vehicles,  
electric motorcycles, and the like, primarily powered by an electric motor that  
draws current from a rechargeable storage battery, a fuel cell, a photovoltaic  
array, or another source of electric current. Plug-in hybrid electric vehicles  
are electric vehicles having a second source of motive power. Off-road, self-  
propelled electric mobile equipment, such as industrial trucks, hoists, lifts,  
transports, golf carts, airline ground support equipment, tractors, boats and  
the like, are not considered electric vehicles.  
6
ELECTRIC VEHICLE SUPPLY EQUIPMENT (EVSE). The conductors, including  
the ungrounded, grounded, and equipment grounding conductors and  
the electric vehicle connectors, attachment plugs, and all other fittings,  
devices, power outlets, or apparatus installed specifically for the purpose of  
transferring energy between the premises wiring and the electric vehicle.  
ELECTRIC VEHICLE SUPPLY EQUIPMENT (EVSE) SPACE. A parking space that  
is provided with a dedicated EVSE.  
EV CAPABLE SPACE. A parking space that is provided with some of the  
infrastructure necessary for the future installation of an EVSE – such as  
conduit, raceways, electrical capacity, or signage – or reserved physical space  
for such infrastructure.  
EV READY SPACE. A parking space that is provided with an electrical circuit  
capable of supporting an installed EVSE.  
Revise text as follows:  
C401.2.2 ASHRAE 90.1  
Commercial buildings shall comply with the requirements of  
ANSI/ASHRAE/IESNA 90.1 and Section C405.14.  
Revise table as follows:  
TABLE  
C405.12.2 ENERGY USE CATEGORIES  
LOAD CATEGORY  
Total HVAC system  
DESCRIPTION OF ENERGY CUSE  
Heating, cooling and ventilation,  
including but not limited to fans,  
pumps, boilers, chillers, and  
water heating. Energy used by  
120-volt equipment, or by  
208/120-volt equipment that is  
located in a building where the  
main service is 480/277-volt  
power, is permitted to be  
7
excluded from total HVAC system  
energy use.  
Interior lighting  
Exterior lighting  
Lighting systems located within  
the building.  
Lighting systems located on the  
building site but not within the  
building.  
Plug loads  
Devices, appliances and  
equipment connected to  
convenience receptacle outlets.  
Any single load that is not  
included in HVAC, lighting or plug  
load category and that exceeds 5  
percent of the peak connected  
load of the whole building,  
including but not limited to data  
centers, manufacturing  
Process load  
equipment, and commercial  
kitchens.  
Electric vehicle charging  
Building operations and other  
miscellaneous  
Electric vehicle charging loads.  
The remaining loads not included  
in this table, including but not  
limited to vertical transportation  
systems, automatic doors,  
motorized shading systems,  
ornamental fountains,  
ornamental fireplaces, swimming  
pools, in-ground spas and snow-  
melt systems.  
Add new sections as follows:  
C405.14 Electric vehicle charging infrastructure. Parking facilities shall be  
provided with electric vehicle charging infrastructure in accordance with this  
section and Table C405.14 based on the total number of parking spaces and  
rounded up to the nearest whole number. EVSE, EV ready spaces and EV  
capable spaces may be counted toward meeting minimum parking  
requirements. EVSE spaces may be used to meet requirements for EV  
ready spaces and EV capable spaces. EV ready spaces may be used to meet  
8
requirements for EV capable spaces. An ALMS may be used to reduce the total  
electrical capacity required by EVSE spaces provided that all EVSE spaces are  
capable of simultaneously charging at a minimum rate of 1.4 kW. Where  
more than one parking facility is provided on a building site, the number of  
parking spaces required shall be calculated separately for each parking  
facility.  
Exception: In parking garages, the conduit required for EV capable  
spaces may be omitted provided the parking garage electrical service  
has no less than 1.8 kVA of additional reserved capacity per EV capable  
space.  
TABLE C405.14  
ELECTRIC VEHICLE CHARGING INFRASTRUCTURE REQUIREMENTS  
OCCUPANCY  
EVSE SPACES  
15%  
EV READY  
SPACES  
NA  
EV CAPABLE  
SPACES  
40%  
Group B  
Occupancies  
Group M  
25%  
NA  
40%  
Occupancies  
R-2 Occupancy  
All other  
NA  
10%  
100%a  
NA  
NA  
40%  
Occupancies  
a. Or one EV ready space per dwelling unit.  
C405.14.1 EV Capable Spaces. EV Capable Spaces shall be  
provided with electrical infrastructure that meets the following  
requirements:  
1. Conduit that is continuous between a junction box  
or outlet located within 3 feet (914 mm) of the parking space  
and an electrical panel serving the area of the parking space  
2. The electrical panel to which the conduit connects shall  
have sufficient dedicated physical space for a dual-pole, 40-  
amp breaker  
9
3. The conduit shall be sized and rated to accommodate a  
40-amp, 208/240-volt branch circuit and have a minimum  
nominal trade size of 1 inch  
4. The electrical junction box and the electrical panel  
directory entry for the dedicated space in the electrical panel  
shall have labels stating “For future electric vehicle charging”  
C405.14.2 EV Ready Spaces. The branch circuit serving EV Ready  
Spaces shall meet the following requirements:  
1. Wiring capable of supporting a 40-amp, 208/240-volt  
circuit,  
2. Terminates at an outlet or junction box located  
within 3 feet (914 mm) of the parking space,  
3. A minimum capacity of 1.8 kVA.  
4. The electrical panel directory shall designate the branch  
circuit as “For electric vehicle charging” and the junction box  
or receptacle shall be labelled “For electric vehicle charging,”  
C405.14.2 EVSE Spaces. The EVSE serving EVSE spaces shall be capable  
of supplying not less than 6.2 kW to an electric vehicle and shall  
be located within 3 feet (914 mm) of the parking space.  
Energy Monitoring Requirements: Commercial Code  
It is critical that LARA add the energy monitoring requirements from the 2021 IECC  
model code, which were removed from the draft, back into Michigan’s final  
commercial energy code. Removing this requirement would significantly impede  
commercial building owners from maintaining their high-performance buildings at  
the level originally designed, losing out on cost savings. According to a report from  
the American Council for an Energy-Efficient Economy focused on energy  
management in industrial and commercial facilities, some programs are capable of  
saving building owners between two and five percent annually.10 Building energy  
performance, if not properly monitored and maintained, erodes over time, and  
therefore energy monitoring, in addition to commissioning, would ensure the level  
of energy efficiency, as designed, is met over the life of the building. If LARA decides  
10 American Council for an Energy-Efficient Economy. “Energy Management Proves Cost Effective in Industrial  
and Commercial Facilities.” May 6, 2021. Available at https://www.aceee.org/press-release/2021/05/energy-  
management-proves-cost-effective-industrial-and-commercial-facilities.  
10  
to maintain the removal of this important part of the 2021 IECC model code from  
Michigan’s commercial energy code, it has the very real potential to erode much of  
the carbon impact of the new code as the energy savings associated with the new  
commercial buildings will not be maintained over time. Additionally, the energy  
monitoring requirements would provide tremendous data sets for energy  
management professionals to study and improve both the predictive energy  
modeling efforts in the design phase and the retro-commission process post  
building occupancy.  
Michigan EIBC recommends LARA add Section 405.12 to C405. 12.5 from the  
IECC 2021 code back into the state’s commercial energy code, which requires  
energy monitoring for buildings over 25,000 square feet.  
Conclusion  
Thank you for the opportunity to comment on the importance of improving  
Michigan’s energy code. To reiterate, Michigan EIBC is strongly supportive of the  
advancements the second drafts have already made toward improving energy  
efficiency of Michigan’s homes and buildings, and it is necessary that these  
advancements remain as LARA makes additional EV charging and energy  
monitoring improvements to the residential and commercial energy codes. We look  
forward to working with you throughout the remainder of this process.  
Thank you,  
Michigan EIBC  
11  
5 July 2022  
Department of Licensing and Regulatory Affairs  
Bureau of Construction Codes  
Administrative Services Division  
LARA-BCC-Rules@michigan.gov  
RE: 10a Michigan Energy Code (ORR# 2021-49 LR) Proposal  
Michigan 2030 Districts are writing in support of including Appendix CC, as an optional appendix,  
in the Michigan Commercial Energy Code. Currently, unlike the ASHRAE appendices, Appendix CC  
is not specifically included in the draft language. We are making the following proposal (added  
language in red):  
R 408.31087 Applicable code.  
Rule 1087. Rules governing the energy efficiency for the design and construction of  
buildings and structures, not including residential buildings, shall be those contained  
in the international energy conservation code, 2015 2021 edition, except for sections  
C104.1 to C104.5, C107.2 to C107.5, C108.2 to C108.4, C109.1 to C109.4, C110.1 to  
C110.3, C301.2, C301.3, C302, C401.2.1 to C408.3.2, C405.12 to C405.12.5, C502.2  
to C502.2.6.2, C503.2 to C503.6 and the ASHRAE energy standard for buildings  
except low-rise residential buildings, ANSI/ASHRAE/IESNA standard 90.1-2013 2019  
(hereafter the standard), including appendices A, B, C, D, and G, except for sections  
8.4.2,8.4.3 to 8.4.3.2. Additionally, Appendix CC of the international energy  
conservation code, 2021 edition, is included as a voluntary appendix that authorities  
having jurisdictions, at their discretion, may choose to adopt by ordinance as a  
supplement to the international energy conservation code, 2021 edition, to require  
renewable energy systems of adequate capacity to achieve net zero carbon emissions  
in applicable new buildings as defined in the scope of Appendix CC within that  
jurisdiction. With the amendments noted, the international energy conservation code  
and the standard are adopted by reference in these rules by reference. The Michigan  
energy code is available for inspection at the Lansing office of the Michigan  
Department of Licensing and Regulatory Affairs, Bureau of Construction Codes,  
611W. Ottawa Street, Lansing, Michigan 48933. The code may be purchased from the  
International Code Council, through the bureau’s website at www.michigan.gov/bcc,  
at a cost as of the time of adoption of these rules of $44.00 $52.00. The ASHRAE  
90.1- 2013 2019 standard is available for inspection at the Lansing office of the  
Michigan Department of Licensing and Regulatory Affairs, Bureau of Construction  
Codes, 611 W. Ottawa Street, Lansing, Michigan 48933. The standard may be  
purchased from the American Society of Heating, Refrigeration and Air- Conditioning  
Engineers, Inc., 1791 Tullie Circle, NE, Atlanta, Georgia 30329, 180 Technology  
Parkway NW, Peachtree Corners, Georgia 30092, or from https://www.ashrae.org at  
a cost as of the time of adoption of these rules of $135.00 $177.00 each.  
115 1/2 East Liberty  
Ann Arbor, MI 48104  
a member of the  
2030 Districts Network  
Reasoning:  
IECC 2021 Appendix CC (aka Zero Code) is a flexible framework that cities and states can use to  
help reach their building decarbonization goals. IECC 2021 Appendix CC combines energy  
efficiency and renewable energy to support the construction of code-compliant, zero carbon  
buildings that use clean energy. It applies to new commercial, industrial and mid- to high-rise  
residential buildings—the dominant building types being constructed in cities today.  
As a VOLUNTARY Appendix, it gives any Authorities Having Jurisdiction the option of adopting the  
appendix. Keeping the appendix voluntary provides jurisdictions an important framework to  
reach their decarbonization goals, if they choose to adopt the appendix.  
In summary we support Appendix CC because:  
o
o
o
Voluntary for jurisdictions to adopt  
Compliance with 2021 IECC is required  
Sets a minimum renewable energy requirement based on energy simulations or default  
values  
o
Provides an incentive for buildings to be designed to be more energy efficient than code  
requires  
o
o
o
o
Encourages on-site renewable energy when feasible  
Supports off-site renewable energy procurement when necessary  
2021 IECC energy efficiency requirements cannot be traded with renewable energy  
Establishes a consistent framework that local governments can adjust for their specific  
needs and conditions  
All three Michigan 2030 Districts, in collaboration with AIA Michigan, are prepared to provide  
ongoing education for developers, architect, engineers and code officials who choose to  
implement Appendix CC. We need to bring on new buildings with no additional carbon emission  
to give existing buildings the time to increase their efficiency, electrify and procure/install  
renewables.  
Sincerely,  
Jan K. Culbertson, FAIA, LEED AP  
Leadership Council Chair, Ann Arbor 2030 District  
Connie Lilly, Executive Director  
Detroit 2030 District  
Cheri Holman  
Cheri Holman, Executive Director  
Grand Rapids 2030 District  
June 5, 2022  
Public Hearing Testimony  
RE: 10a Michigan Energy Code (ORR# 2021-49 LR)  
Jan Culbertson, FAIA  
Ann Arbor 2030 District Leadership Chair  
Scio Township Planning Commission Chair  
I am proposing that the State of Michigan adopt IECC Appendix CC (AKA Zero Code) as a voluntary appendix in the  
Michigan Commercial Energy Code thereby giving enforcing Authorities Having Jurisdiction the option to adopt the  
appendix.  
Appendix CC is a flexible framework to help reach building decarbonization goals. It adds the requirement of on-site  
and/or off-site renewable energy to support the construction of code-compliant, zero carbon buildings that use clean  
energy.  
Appendix CC provides a standard formula to calculate how much renewable energy is needed to meet a building’s  
energy demand after satisfying the energy-efficiency requirements of the ASHRAE Standard 90.1-2019 / IECC 2021.  
Appendix CC provides technical guidance on different strategies and options for procuring renewable energy including  
power purchase agreements and renewable energy credits.  
Why is this important?  
MI Healthy Climate Plan has the goal of achieving economy-wide carbon neutrality no later than 2050. The goal includes  
interim reductions of 28% by 2025, 52% by 2030, and maintaining net negative greenhouse gas emissions (GHG) after  
2050.  
Washtenaw County has the goal of achieving community-wide carbon neutrality no later than 2035.  
Ann Arbor has the goal of achieving community-wide neutrality by 2030.  
Adding new buildings, without them bring on additional renewable energy to offset their emissions, ADDS to the carbon  
that we are trying to eliminate, increasing the environmental burden. Adopting Appendix CC means new commercial  
buildings would essentially be net zero energy and would not generate additional operational carbon emissions—  
carbon that we will later have to sequester.  
As a planning commission chair, I struggle to develop ordinances that will meet decarbonization goals with the limited  
policy tools available. Appendix CC would make a tremendous difference—Net Zero Energy Buildings going from being  
incentivized to being required. It would also allow jurisdictions to focus on improving the efficiency of and decarbonizing  
the existing building stock, which is already a significant challenge.  
Why a Voluntary Appendix?  
I recognize that Michigan as a whole may not be ready to adopt such a provision, but many cities where many of the  
larger, new developments are happening, would readily adopt a requirement for new commercial construction to be net  
zero energy.  
Voluntary adoption would provide a proof of concept for a new energy code provision, paving the way for state-wide  
adoption in the next code update cycle.  
Would Appendix CC create an economic burden?  
Adding solar PV or the purchase of renewable energy need not create additional costs for new construction. Commercial  
solar installations can create a positive cash flow, especially when the building is designed for on-site solar. I am a  
member of a solar LLC that owns a solar system on a non-profit building’s roof. The non-profit is saving on their current  
electricity rates AND will be able to purchase the system for minimal cost within 5 years reaping additional savings well  
into the future.  
Off-site renewable procurement has become a thriving market. Just in Washtenaw County, Washtenaw Community  
College, the University of Michigan and the Ann Arbor Public Schools have entered into long term contracts with the DTE  
MIGreen Power Program to offset their electricity, with projected overall SAVINGS in their energy costs.  
On the other hand, constructing new buildings without renewable energy adds to our decarbonization burden that will  
result in increased future costs.  
Proposal:  
Add the following language “in Red” to the Michigan Commercial Energy Code, Rule 1087:  
R 408.31087 Applicable code.  
Rule 1087. Rules governing the energy efficiency for the design and construction of buildings and  
structures, not including residential buildings, shall be those contained in the international energy  
conservation code, 2015 2021 edition, except for sections C104.1 to C104.5, C107.2 to C107.5, C108.2 to  
C108.4, C109.1 to C109.4, C110.1 to C110.3, C301.2, C301.3, C302, C401.2.1 to C408.3.2, C405.12 to  
C405.12.5, C502.2 to C502.2.6.2, C503.2 to C503.6 and the ASHRAE energy standard for buildings except  
low-rise residential buildings, ANSI/ASHRAE/IESNA standard 90.1-2013 2019 (hereafter the standard),  
including appendices A, B, C, D, and G, except for sections 8.4.2,8.4.3 to 8.4.3.2. Additionally, Appendix  
CC of the international energy conservation code, 2021 edition, is included as a voluntary appendix that  
authorities having jurisdictions, at their discretion, may choose to adopt by ordinance as a supplement to  
the international energy conservation code, 2021 edition, to require renewable energy systems of  
adequate capacity to achieve net zero carbon emissions in applicable new buildings as defined in the  
scope of Appendix CC within that jurisdiction. With the amendments noted, the international energy  
conservation code and the standard are adopted by reference in these rules by reference. The Michigan  
energy code is available for inspection at the Lansing office of the Michigan Department of Licensing and  
Regulatory Affairs, Bureau of Construction Codes, 611W. Ottawa Street, Lansing, Michigan 48933. The  
code may be purchased from the International Code Council, through the bureau’s website at  
www.michigan.gov/bcc, at a cost as of the time of adoption of these rules of $44.00 $52.00. The ASHRAE  
90.1- 2013 2019 standard is available for inspection at the Lansing office of the Michigan Department of  
Licensing and Regulatory Affairs, Bureau of Construction Codes, 611 W. Ottawa Street, Lansing,  
Michigan 48933. The standard may be purchased from the American Society of Heating, Refrigeration  
and Air- Conditioning Engineers, Inc., 1791 Tullie Circle, NE, Atlanta, Georgia 30329, 180 Technology  
Parkway NW, Peachtree Corners, Georgia 30092, or from https://www.ashrae.org at a cost as of the time  
of adoption of these rules of $135.00 $177.00 each.  
Alternatively, I urge adoption of Appendix CC in the Michigan Commercial Energy Code as a state-wide requirement as  
necessary to eliminate the future economic burden of the people of this state for sequestering the additional emissions  
of new buildings.  
Sent via Electronic Mail  
June 27, 2022  
Amanda Johnson, Rules Analyst  
Michigan Department of Licensing and Regulatory Affairs  
Bureau of Construction Code, Administrative Services Division  
611 W. Ottawa Street  
Lansing, Michigan 48933  
LARA-BCC-Rules@michigan.gov  
Re:  
Support for Adoption of the 2021 International Energy Conservation Code  
(Pending Rule Sets 2021-48LR and 2021-49LR)  
Dear Ms. Johnson,  
The Polyisocyanurate Insulation Manufacturers Association (PIMA) is writing in support of the  
proposed rules for adopting the 2021 IECC for residential and commercial buildings. Keeping the State’s  
energy code updated to the current version of the IECC is an important and cost-effective policy for  
addressing the negative economic and environmental consequences of energy waste in buildings – a  
sector that is responsible for 40% of total U.S. energy use. Importantly, Michigan will benefit from the  
removal of several previously adopted amendments that in the past weakened the code’s stringency and  
undermined the achievement of State’s climate goals. Also, adopting the 2021 IECC will help Michigan  
achieve a range of benefits, including:  
Reduced air pollution;  
Consumer and business cost savings;  
Increased flexibility and reliability of our energy system and grid;  
Improved resiliency;  
Reduced peak energy demand; and  
Improved energy productivity and a stronger economy.  
Staying current with the model energy code ensures that Michigan will benefit from the regular  
improvements in construction practices and building technology. This is especially true for alterations  
performed on commercial buildings and ensures that the energy code will drive energy efficiency  
improvements in existing buildings when components are replaced or when buildings are otherwise  
altered.  
Moving from Michigan’s current energy code, which is based on the 2015 IECC (and the  
ASHRAE Standard 90.1-2013), to the 2021 IECC will save Michigan residents money and increase  
employment. Also, this change is clearly cost effective. For commercial buildings, this change has a  
simple payback that is immediate, and for residential buildings purchased with a mortgage, there would  
be a positive net savings within 5 years. Over 30 years, about 15,000 jobs would result from these  
stronger energy codes.1  
Most of the country views stronger building energy codes as an effective policy that benefits the  
environment and the economy. Like Michigan, your neighbors -- Illinois and Ohio -- are in the midst of  
adopting the 2021 IECC for both residential and commercial buildings and Wisconsin is close to adopting  
this code for commercial buildings and will soon start its review for residential buildings.  
Buildings are responsible for 74% of total electricity consumption in the United States. Twenty-  
seven percent of Michigan’s electricity is still generated by burning coal, a product that comes entirely  
from out-of-state.2 As a result, weak building energy codes send money out of Michigan to purchase  
coal. Adopting the 2021 IECC will improve building energy efficiency, reduce energy use and waste, and  
result in investments that benefit the state and local economies.  
About PIMA  
PIMA is the trade association for North American manufacturers of rigid polyiso foam insulation –  
a product that is used in most low-slope commercial roofs as well as in commercial and residential walls.  
Polyiso insulation products and the raw materials used to manufacture polyiso are produced in over 50  
manufacturing facilities across North America. The insulation industry overall employs over 12,000  
workers in the Michigan.  
Thank you for the opportunity to submit these comments. Please contact me should additional  
information be necessary (jkoscher@pima.org; (703) 224-2289).  
Sincerely,  
Justin Koscher  
President  
1
U.S. Department of Energy, see “State Energy Code Fact Sheet-Michigan”,  
https://www.energycodes.gov/sites/default/files/2021-07/EED_1365_BROCH_StateEnergyCodes_states_MICHIGAN.pdf  
2 U.S. Energy Information Administration, https://www.eia.gov/beta/states/states/mi/analysis  
2
   
Building Codes & Regulations Committee  
Professional Chapter of the International Code Council  
MEMORANDUM  
7-5-2022  
Department of Licensing and Regulatory Affairs  
Bureau of Construction Codes  
Administrative Services Division  
LARA-BCC-Rules@michigan.gov  
RE: 10a Michigan Energy Code (ORR# 2021-49 LR) Proposal  
The American Institute of Architects, Detroit Chapter, Building Codes and Regulations Committee, AIAD  
BC&RC, is writing in support of including Appendix CC, as an optional appendix, in the Michigan  
Commercial Energy Code. Currently, unlike the ASHRAE appendices, they are not specifically included in  
the draft language. We are making the following proposal (added language in red):  
R 408.31087 Applicable code.  
Rule 1087. Rules governing the energy efficiency for the design and construction of  
buildings and structures, not including residential buildings, shall be those contained in the  
international energy conservation code, 2015 2021 edition, except for sections C104.1 to  
C104.5, C107.2 to C107.5, C108.2 to C108.4, C109.1 to C109.4, C110.1 to C110.3, C301.2,  
C301.3, C302, C401.2.1 to C408.3.2, C405.12 to C405.12.5, C502.2 to C502.2.6.2, C503.2  
to C503.6 and the ASHRAE energy standard for buildings except low-rise residential  
buildings, ANSI/ASHRAE/IESNA standard 90.1-2013 2019 (hereafter the standard),  
including appendices A, B, C, D, and G, except for sections 8.4.2,8.4.3 to 8.4.3.2.  
Additionally, Appendix CC of the international energy conservation code, 2021 edition, is  
included as a voluntary appendix that authorities having jurisdictions, at their discretion,  
may choose to adopt by ordinance as a supplement to the international energy  
conservation code, 2021 edition, to require renewable energy systems of adequate capacity  
to achieve net zero carbon emissions in applicable new buildings as defined in the scope  
of Appendix CC within that jurisdiction. With the amendments noted, the international  
energy conservation code and the standard are adopted by reference in these rules by  
reference. The Michigan energy code is available for inspection at the Lansing office of the  
Michigan Department of Licensing and Regulatory Affairs, Bureau of Construction Codes,  
611W. Ottawa Street, Lansing, Michigan 48933. The code may be purchased from the  
International Code Council, through the bureau’s website at www.michigan.gov/bcc, at a  
cost as of the time of adoption of these rules of $44.00 $52.00. The ASHRAE 90.1- 2013  
2019 standard is available for inspection at the Lansing office of the Michigan Department  
of Licensing and Regulatory Affairs, Bureau of Construction Codes, 611 W. Ottawa Street,  
Lansing, Michigan 48933. The standard may be purchased from the American Society of  
Heating, Refrigeration and Air- Conditioning Engineers, Inc., 1791 Tullie Circle, NE,  
Atlanta, Georgia 30329, 180 Technology Parkway NW, Peachtree Corners, Georgia  
30092, or from https://www.ashrae.org at a cost as of the time of adoption of these rules of  
$135.00 $177.00 each.  
AIA Detroit | 440 Burroughs Street, Suite 524, Detroit, MI 48202 | aiadetroit.com  
Reasoning:  
IECC 2021 Appendix CC (aka Zero Code) is a flexible framework that cities and states can use to help  
reach their building decarbonization goals. IECC 2021 Appendix CC combines energy efficiency and  
renewable energy to support the construction of code-compliant, zero carbon buildings that use clean  
energy. It applies to new commercial, industrial and mid- to high-rise residential buildings—the  
dominant building types being constructed in cities today.  
As a VOLUNTARY Appendix, it gives any Authorities Having Jurisdiction the option of adopting the  
appendix. Keeping the appendix voluntary provides jurisdictions an important framework to reach their  
decarbonization goals, if they choose to adopt the appendix.  
In summary we support Appendix CC because:  
o
o
o
o
Voluntary for jurisdictions to adopt  
Compliance with 2021 IECC is required  
Sets a minimum renewable energy requirement based on energy simulations or default values  
Provides an incentive for buildings to be designed to be more energy efficient than code  
requires  
o
o
o
o
Encourages on-site renewable energy when feasible  
Supports off-site renewable energy procurement when necessary  
2021 IECC energy efficiency requirements cannot be traded with renewable energy  
Establishes a consistent framework that local governments can modify for their specific needs  
and conditions  
AIA Detroit is prepared to provide ongoing education for developers, architect, engineers and code  
officials who choose to implement Appendix CC.  
Sincerely,  
Justin James Bialek, AIA, NCARB, AIAD BC&RC Chair  
Department of Licensing and Regulatory Affairs  
Bureau of Construction Codes  
Administrative Services Division  
LARA-BCC-Rules@michigan.gov  
July 5, 2022  
RE: 10a Michigan Energy Code (ORR# 2021-49 LR) Proposal  
AIA Detroit is writing in support of including Appendix CC, as an optional appendix, in the Michigan  
Commercial Energy Code. Currently, unlike the ASHRAE appendices, they are not specifically  
included in the draft language. We are making the following proposal (added language in red):  
R 408.31087 Applicable code.  
Rule 1087. Rules governing the energy efficiency for the design and construction of buildings and  
structures, not including residential buildings, shall be those contained in the international energy  
conservation code, 2015 2021 edition, except for sections C104.1 to C104.5, C107.2 to C107.5, C108.2  
to C108.4, C109.1 to C109.4, C110.1 to C110.3, C301.2, C301.3, C302, C401.2.1 to C408.3.2,  
C405.12 to C405.12.5, C502.2 to C502.2.6.2, C503.2 to C503.6 and the ASHRAE energy standard  
for buildings except low-rise residential buildings, ANSI/ASHRAE/IESNA standard 90.1-2013 2019  
(hereafter the standard), including appendices A, B, C, D, and G, except for sections 8.4.2,8.4.3 to  
8.4.3.2. Additionally, Appendix CC of the international energy conservation code, 2021 edition, is  
included as a voluntary appendix that authorities having jurisdictions, at their discretion, may  
choose to adopt by ordinance as a supplement to the international energy conservation code,  
2021 edition, to require renewable energy systems of adequate capacity to achieve net zero  
carbon emissions in applicable new buildings as defined in the scope of Appendix CC within that  
jurisdiction. With the amendments noted, the international energy conservation code and the  
standard are adopted by reference in these rules by reference. The Michigan energy code is available  
for inspection at the Lansing office of the Michigan Department of Licensing and Regulatory Affairs,  
Bureau of Construction Codes, 611W. Ottawa Street, Lansing, Michigan 48933. The code may be  
purchased from the International Code Council, through the bureau’s website at  
www.michigan.gov/bcc, at a cost as of the time of adoption of these rules of $44.00 $52.00. The  
ASHRAE 90.1- 2013 2019 standard is available for inspection at the Lansing office of the Michigan  
Department of Licensing and Regulatory Affairs, Bureau of Construction Codes, 611 W. Ottawa  
Street, Lansing, Michigan 48933. The standard may be purchased from the American Society of  
Heating, Refrigeration and Air- Conditioning Engineers, Inc., 1791 Tullie Circle, NE, Atlanta, Georgia  
30329, 180 Technology Parkway NW, Peachtree Corners, Georgia 30092, or from  
https://www.ashrae.org at a cost as of the time of adoption of these rules of $135.00 $177.00 each.  
T (313) 588-1411  
AIA Detroit  
440 Burroughs St  
Suite 524  
E staff@aiadetroit.com  
www.aiadetroit.com  
Detroit, MI 48202  
Reasoning:  
IECC 2021 Appendix CC (aka Zero Code) is a flexible framework that cities and states can use to help  
reach their building decarbonization goals. IECC 2021 Appendix CC combines energy efficiency and  
renewable energy to support the construction of code-compliant, zero carbon buildings that use clean  
energy. It applies to new commercial, industrial and mid- to high-rise residential buildings—the  
dominant building types being constructed in cities today.  
As a VOLUNTARY Appendix, it gives any Authorities Having Jurisdiction the option of adopting the  
appendix. Keeping the appendix voluntary provides jurisdictions an important framework to reach  
their decarbonization goals, if they choose to adopt the appendix.  
In summary we support Appendix CC because:  
o
o
o
o
Voluntary for jurisdictions to adopt  
Compliance with 2021 IECC is required  
Sets a minimum renewable energy requirement based on energy simulations or default values  
Provides an incentive for buildings to be designed to be more energy efficient than code  
requires  
o
o
o
o
Encourages on-site renewable energy when feasible  
Supports off-site renewable energy procurement when necessary  
2021 IECC energy efficiency requirements cannot be traded with renewable energy  
Establishes a consistent framework that local governments can modify for their specific needs  
and conditions  
All three Michigan 2030 Districts and AIA Michigan are prepared to provide ongoing education for  
developers, architect, engineers and code officials who choose to implement Appendix CC.  
Sincerely,  
___________________________________________  
___________________________________________  
Megan Martin-Campbell, AIA  
Katie Johnson, AIA  
2022 AIA Detroit President  
2022 AIA Detroit Vice President / President Elect  
T (313) 588-1411  
AIA Detroit  
440 Burroughs St  
Suite 524  
E staff@aiadetroit.com  
www.aiadetroit.com  
Detroit, MI 48202  
Mr. Keith Lambert  
Director, Bureau of Construction Codes  
Michigan Department of Licensing and Regulatory Affairs  
611 W Ottawa St.  
Lansing, MI 48933  
June 30, 2022  
Re: Michigan’s Energy Code Adoption  
Dear Director Lambert,  
RMI (formerly Rocky Mountain Institute) and the New Buildings Institute (NBI) respectfully submit the  
following comments to the Department of Licensing and Regulatory Affairs (LARA) on the amendments  
for the Michigan Energy Code. RMI is an independent, non-partisan, non-profit organization whose  
mission includes researching the business models, policies, technologies, and financing mechanisms  
necessary to advance an equitable clean energy transition. New Buildings Institute (NBI) works  
collaboratively with industry market players—governments, utilities, energy efficiency advocates and  
building professionals—to promote advanced design practices, innovative technologies, public policies,  
and programs that improve energy efficiency at the highest levels and decarbonize the built environment.  
Michigan will benefit from 2021 IECC with commercial energy monitoring, efficiency packages, EV-  
readiness, and all-electric amendments.  
We applaud LARA for including 2021 IECC in this initial draft for Michigan’s updated energy codes. 2021  
IECC is necessary for Michigan to have modern, affordable new construction. With the adoption of 2021  
IECC, we encourage LARA to consider the following amendments:  
1. Include the energy monitoring section – Section C405.12 to C405.12.5, which requires energy  
monitoring for buildings over 25,000 square feet in the commercial code. This amendment is a key  
tool for tracking energy use and helping commercial buildings reduce consumption.  
2. Require EV-readiness in both the residential and commercial code. EV-readiness in new homes  
will enable customer choice for their transportation without homeowners having to pay up to x3-4  
more later to retrofit compared to building to EV-readiness standards.1  
3. Include an amendment to the proposed code to require at least three options be selected from the  
list of Additional Efficiency Package Options. This amendment can generate high energy savings  
at low costs while providing builders with flexibility in complying with a high efficiency code.  
In addition, we strongly recommend that Michigan adopt an all-electric new construction  
amendment in climate zones 5 and 6 alongside an electric-ready amendment in climate zone 7. All-  
electric new construction benefits Michiganders because it has lower upfront costs than a mixed fuel home  
built to current code and can help keep utility bills stable amid rising, volatile gas prices. At minimum, an  
electric-ready amendment enables customers to use best in class technology. Failure to at least require  
electric readiness will create logistical and economic hurdles for customers to gain access to modern,  
efficient, healthy appliances like heat pumps in the future.  
1 https://newbuildings.org/wp-content/uploads/2022/04/BuildingDecarbCostStudy.pdf  
All-electric and electric-ready codes are being passed across the U.S.  
States and cities across the United States are passing all-electric or electric-ready codes giving new home  
residents access to innovative, efficient appliance technologies, like heat pumps and induction stoves. Over  
60 jurisdictions across 11 States have already adopted policies that require or encourage building  
electrification.2 The most recent example in the codes space is Washington state which just passed an all-  
electric heating mandate in commercial and multifamily buildings.3 Colorado passed a law requiring cities  
and counties to update their building codes to be electric-ready.4 Alongside states, local jurisdictions, like  
New York City, have passed all-electric new construction bills as well.5 Michigan is positioned to join these  
states and cities as a leader in the new construction sector.  
All-electric codes will economically benefit Michiganders  
All-electric construction codes in Michigan can reduce costs for residents. RMI and NBI submitted analysis  
to LARA, in service of the Stille-Derossett-Hale Single State Construction Code Act6, examining the  
upfront and life cycle costs of all-electric new construction codes in Michigan.7 Our study concludes that  
for single-family new construction:  
1. All-electric new construction could reduce upfront costs by over $2,000 compared to a mixed  
fuel home built to current code. All-electric homes reduce upfront costs because they avoid gas  
infrastructure costs. Gas infrastructure on single-family home property costs approximately $6000.  
2. All-electric new construction is cost neutral over seven years in climate zones 5 and 6. The  
costs a homeowner would pay in the first seven years (including utility bills, mortgage bills,  
property taxes, and a down payment on upfront costs) are comparative to a single-family mixed  
2 https://www.buildingdecarb.org/zeb-ordinances.html  
3 https://grist.org/buildings/washington-state-requires-electric-heat-pumps-buildings/  
4 https://www.bouldercounty.org/news/boulder-county-commissioners-welcome-landmark-energy-codes-legislation/  
5 https://www.urbangreencouncil.org/content/projects/local-law-154-nycs-all-electric-new-buildings-  
law#:~:text=With%20Local%20Law%20154%2C%20New,and%20making%20occupants%20more%20comfortable  
6 http://www.legislature.mi.gov/(S(ervayhjjbvqjiirehphhi4dk))/mileg.aspx?page=getobject&objectname=mcl-act-  
230-of-1972&queryid=40215&highlight=  
7 https://www.michigan.gov/lara/-/media/Project/Websites/lara/bcc-media/Rules-Info/Part-10-Michigan-Energy-  
Code/Compiled-2021-Energy-Codes-Advisory-Meeting-Comments-  
322.pdf?rev=9fe80d902fc547ac864918012652d6a2&hash=061E4101D96506D30961ABDF9D2A84F9  
fuel home built to current code. This finding indicates new construction can benefit from the health  
and comfort benefits of an all-electric home without a cost premium.8  
3. Cost-effectiveness for all-electric new construction is improving. Our analysis was conservative  
using rates from November 2021 and minimum code compliant appliances. The cost-effectiveness  
of all-electric codes will improve with high performance cold climate heat pumps, heat pump  
friendly electric rates, and utility incentives, which this analysis did not include to comply with the  
Stille-Derossett-Hale Single State Construction Code Act.  
In conclusion, our study finds that all-electric code amendments in Michigan can reduce upfront costs  
making housing more accessible to more Michiganders. This benefit comes with comparable lifecycle costs  
and will be subject to less gas price volatility.  
All-electric new construction avoids rising, volatile gas prices  
Michigan utilities are warning that rising natural gas prices will lead to utility bill hikes for residents.9 These  
claims are backed by new research from the Michigan Public Service Commission which expects natural  
gas prices to increase by 89% between 2021 and 2022, a stark difference from the 6.4% increase of electric  
rates between May 2021 and May 2022.10 Low-income Michiganders, who already spend 15% of their  
income on energy, can’t afford to be subject to volatile, rising gas prices.11 Since heat pumps are highly  
efficient and leverage steadier electricity prices, all-electric new construction can help keep bills low and  
steady for Michigan residents. All-electric codes, which leverage the benefits of electric appliances, can  
help ease these concerns and mitigate future price hikes from the continued build out of gas infrastructure.  
As Michigan adds more renewable resources to the grid, these prices will become even more stable because  
it is not dependent on imported fuels.  
All-electric or electric-ready codes benefit Michigan’s economy and enable customer choice.  
Considering the results of this analysis, we recommend that all-electric 2021 IECC be adopted in Climate  
Zones 5 and 6. In Climate Zone 7, we recommend that Michigan adopt electric-ready 2021 IECC. All-  
electric codes will provide residents with low-upfront costs while reducing indoor air pollution emissions  
and keeping utility bills stable. At minimum, electric-ready will enable Michigan to leverage modern  
technologies when homeowners are ready to do so. Electric-ready construction provides residents with the  
most consumer choice when it is time to decide how they will heat their home, water, and food. It provides  
them with the option to use heat pumps and induction stoves which are innovative technologies that can  
keep Michigan warm and comfortable on the coldest days and keep utility bills and mortgage payments  
low and steady.  
Lauren Reeg  
Associate  
RMI  
lreeg@rmi.org  
Diana Burk  
Project Manager  
New Buildings Institute  
diana@newbuildings.org  
8 https://rmi.org/wp-content/uploads/2022/02/all_electric_buildings_healthy_factsheet.pdf  
9 https://www.thedailyreporter.com/story/news/2021/09/10/michigan-gas-utility-rates-increase-2022/8264271002/  
10 https://www.michigan.gov/mpsc/-/media/Project/Websites/mpsc/regulatory/reports/energy-  
appraisal/2022_Summer_Energy_Appraisal.pdf  
11 https://www.elevatenp.org/wp-content/uploads/Energy-Burden-in-MI.pdf  
July 1, 2022  
Keith Lambert  
Bureau of Construction Codes  
Department of Licensing and Regulatory Affairs  
Administrative Services Division  
P.O. Box 30254  
Lansing, MI 48909  
Re: MEEA’s comments in support of the adoption of the 2021 International Energy Conservation  
Code for residential and commercial buildings  
Dear Mr. Lambert and the Bureau of Construction Codes,  
Thank you for the opportunity to provide comments on current update to the Michigan Energy  
Code. The Midwest Energy Efficiency Alliance (MEEA) is a member-based non-profit organization  
promoting energy efficiency to optimize energy generation, reduce consumption, create jobs  
and decrease carbon emissions in all Midwest communities. We have submitted numerous  
comments on this process, and thus will be brief in this round.  
MEEA recommends the adoption of the 2021 International Energy Conservation Code (IECC)  
without weakening amendments as the statewide minimum building energy code for residential  
and commercial buildings. Adopting the 2021 IECC without weakening amendments would  
establish a number of benefits for Michiganders and result in more efficient, resilient buildings,  
plus put the state on track to meet its established climate goals.  
The proposed energy code released by LARA on June 16, 2022, appears to have a few  
amendments that weaken the 2021 IECC. In the residential energy code, R408.301066 and  
R408.31071 remain; these amendments have previously impacted the alternative performance  
path and systems sections in Michigan’s energy code and will continue to reduce the efficiency  
and efficacy of the residential energy code. In addition, a referenced table is now numbered  
differently and could be problematic if not updated. The proposed commercial energy code  
removes monitoring requirements and some requirements for lighting alterations. If these sections  
remain in the upcoming code, Michiganders will not be able to realize the full benefits of the  
2021 IECC.  
The 2021 IECC has proven to be cost-effective and will save residents and business owners on  
their utility bills. According to reports from the US Department of Energy and the Pacific  
Northwest National Laboratory, “adopting the 2021 IECC in Michigan is expected to result in  
homes that are energy efficient, more affordable to own and operate, and based on current  
industry standards for health, comfort and resilience.”1 Additionally, moving to the commercial  
2021 IECC will reduce statewide CO2 emissions by 10.0 MMT (30 years cumulative), equivalent to  
the CO2 emissions of 2,182,000 cars driven for one year, and stimulate the creation of high-  
1 https://www.energycodes.gov/sites/default/files/2021-07/MichiganResidentialCostEffectiveness_2021_0.pdf  
MEEA Comments on Updating Michigan’s Energy Codes // July 2022  
1
quality jobs across the state2. Only if adopted in full, with no amendments, will Michiganders  
realize these intended benefits.  
Increasingly Michigan municipalities have expressed interest to MEEA for the ability to adopt  
advanced energy codes. One option the state of Michigan has would be to adopt the 2021  
IECC Appendices so that municipalities are given the choice of more stringency in energy  
efficiency beyond the state energy code. MEEA recommends that the state of Michigan  
strongly consider giving municipalities this option and can provide technical expertise on stretch  
code adoption and implementation. Please let us know if you if you need more information on  
that option.  
The adoption of the 2021 IECC is a cost-effective way to gradually increase the level of  
efficiency of residential and commercial buildings and remain a leader in the Midwest. We  
recommend the full unamended adoption of the 2021 IECC as a way to reduce long-term  
energy use and costs for residents and businesses, create healthier and more comfortable  
indoor environments, and increase the resiliency of the building stock so new residential  
dwellings and commercial buildings last for the next 75-100 years.  
If you have any questions about this testimony, noted reports and references or general impact  
and analysis of building energy codes, please contact Alison Lindburg, Senior Building Policy  
Manager for MEEA at alindburg@mwalliance.org.  
Sincerely,  
Stacey Paradis  
Executive Director  
2
https://www.energycodes.gov/sites/default/files/2021-07/Cost-effectiveness_of_ASHRAE_Standard_90-1-2019-  
Michigan.pdf  
MEEA Comments on Updating Michigan’s Energy Codes // July 2022  
2
Mr. Keith Lambert  
Director, Bureau of Construction Codes  
Department of Licensing and Regulatory Affairs  
Administrative Services Division  
611 W. Ottawa Street, Lansing, MI 48933  
Re: Administrative Rules for Construction Code – Part 10a. Michigan Energy Code, Rule Set 2021-49 LR  
Dear Director Lambert,  
Thank you for the opportunity to provide comments and feedback on proposed changes to the  
Construction Code – Part 10a Michigan Energy Code rule set. This regulatory framework and  
proposed updates are important in ensuring safe and affordable workplaces and living spaces for  
thousands of Michigan families. In today’s economic climate, housing attainability is a top priority  
for the business community and a critical component in addressing labor capacity challenges.  
In general, we support the agency’s efforts to strengthen and modernize Michigan’s Energy Code by  
utilizing the 2021 International Energy Conservation Code. Revised standards to increase energy  
efficiency such as building envelope improvements provide increased resiliency to our state’s  
buildings and housing. Promoting technologies that improve structural energy efficiency  
demonstrate chemistry and advanced manufacturing as climate and clean energy solutions that  
spur innovation and hold long-term economic benefits.  
While we support the general direction the bureau has taken, we also would like to offer cautionary  
analyses of attempts by some advocacy organizations to push beyond the Bureau’s current draft  
rule by adopting appendices within the 2021 IECC that allow for local units of government to put  
further restrictive codes and standards in place. These ‘stretch codes,’ specifically referenced in  
Appendices RC and CC, would allow local governments to take extraordinary measures that would  
negatively impact affordability, such as reducing a customer’s ability to use natural gas for new  
construction to favor electrification in homes and businesses. As such, we do not support the  
inclusion of appendices RC 101 and CC 101 when adopting these updated codes even as a voluntary  
option for local governments.  
If leveraged, these voluntary appendices would serve as de facto mandates, and would inhibit  
business retention and attraction statewide and put the dream of new homeownership out of reach  
for thousands of Michiganders. Manufacturing and service-based industries like the restaurant and  
lodging sectors rely heavily upon natural gas as an efficient energy solution. Additionally, a de facto  
mandate of electrification would also be detrimental to the pocketbooks of thousands of Michigan  
residents utilizing natural gas and propane to heat their homes. In fact, according to the Energy  
Information Administration (EIA), nearly a third of U.S. households faced energy insecurity for  
affordability-related reasons. In the U.S. Department of Energy’s 2020 forecast, “natural gas  
remains the lowest cost way to heat your home and is the most immediate way to reduce the  
energy burden for low-income households.” Finally, these mandates myopically favor electrification  
over the use of other clean and cost-effective solutions to lowering the carbon intensity of  
Michigan’s building and housing stock, such as carbon offsets, renewable natural gas and more.  
Allowing for more restrictive codes within specific local jurisdictions would inhibit safety and  
reliability, as it would create a patchwork of distinct policy landscapes that don’t necessarily align  
with the statewide management of the electric distribution and gas distribution systems.  
Municipalities that adopt stretch codes would likely require costly utility infrastructure upgrades to  
handle increased electric load for new construction, and thus would place a new burden on existing  
customers within that municipality. We are therefore deeply concerned that allowing for this  
regulatory structure can create cross-subsidization of costs within the same customer rate class. A  
single, uniform statewide energy code(s) will help provide the most equitable regulatory structure,  
and we encourage the Bureau to not include the previously mentioned stretch code appendices. ,  
We appreciate the opportunity to speak to their potentially unintended and costly consequences.  
Thank you again for the opportunity to provide this written comment. If we can serve as a resource  
in the future, please do not hesitate to reach out.  
Sincerely,  
Mike Alaimo  
Director, Environmental and Energy Affairs  
Michigan Chamber of Commerce  
Caroline Liethen  
Director, Environmental and Regulatory Policy  
Michigan Manufacturers Association  
7/2/2022  
Department of Licensing and Regulatory Affairs  
Bureau of Construction Codes  
Administrative Services Division  
Telephone (517) 582-5519  
LARA-BCC-Rules@michigan.gov  
My name is Roger Papineau. I live at 1901 Beulah Highway, PO Box 574, Beulah, MI 49617.  
I am writing today to give comments and questions on the proposed Part 10 and 10a Energy  
Code Rules.  
1. If the proposed rules are promulgated, will residential provisions of the Michigan Energy Code  
(Part 10) and the Michigan Residential Code (Chapter 11) conflict?  
2. If provisions of the Michigan Energy Code (Part 10) and Michigan Residential Code (Chapter 11)  
do conflict, will the Michigan Residential Code provisions take precedence over the Michigan  
Energy Code?  
3. Do the proposed rules amend Chapter 11 (Energy Efficiency) of the 2015 Michigan Residential  
Code?  
Retain and amend R 408.31060e.  
Reason: Parts 10 &10a are unique to Michigan. It makes no sense to list over 3140 counties,  
boroughs, and parishes across the United Sates in a code book dedicated to Michigan.  
Also, the current copy of ASHRAE 169-2013 puts Marquette in Zone 6A, not 7A. This change is  
required to maintain consistency across the various codes.  
Additionally, Figure R301.1 is nearly impossible to read.  
Code change proposal CE36-19 Part II revised the makeup of the climate zones.  
IECC: FIGURE R301.1 (IRC N1101.7), TABLE R301.1 (IRC N1101.7), R301.3 (IRC N1101.7.2), TABLE  
R301.3(1) [IRC N1101.7.2(1)], TABLE R301.3(2) [IRC N1101.7.2(2)]  
Proponent: David Collins, representing SEHPCAC (SEHPCAC@iccsafe.org); David Collins, representing The  
American Institute of Architects (dcollins@preview-group.com)  
Reason:  
Currently approximately 10% of the counties across the US have different climate zones under the  
IECC and ASHRAE 90.1, ASHRAE 90.2, and the IgCC. This proposal updates the climate zones to correspond  
with the release of ASHRAE Standard 169-2013, which is referenced in both the 2018 IgCC and ASHRAE 90.1  
and ASHRAE 90.2 Approximately 10% of the counties in the United States have a change in Climate Zone  
designation due to this change. ICC has a licensing agreement with ASHRAE to include the climate zone map,  
definitions and tables for consistency with ASHRAE Standard 169-2013.  
ANSI/ASHRAE Addendum a to ANSI/ASHRAE Standard 169-2013 shows Marquette County MI to be  
in Climate Zone 6A. See Figure A-1 and Table A-3.  
Delete without substitution Section R404.2.  
Reason: This section increases the cost of construction with no return on investment due to the  
requirement that all lamps be hi-efficacy.  
Zach Waas Smith  
Community Engagement Specialist  
Office of Sustainability & Innovations  
City of Ann Arbor  
301 E Huron St., Ann Arbor, MI 48104  
zwaassmith@a2gov.org  
June 28, 2022  
Department of Licensing and Regulatory Affairs  
Bureau of Construction Codes  
Administrative Services Division  
P.O Box 30254  
Lansing, MI 48909  
LARA-BCC-Rules@michigan.gov  
RE: 10a Michigan Energy Code (ORR# 2021-49 LR)  
Thank you for the opportunity to submit comments pertaining to the code adoption process. The City of Ann  
Arbor is writing to encourage the inclusion of the following in the Michigan Energy Code:  
1) All energy monitoring requirements, specifically section C405.12 Energy Monitoring. This section  
appropriately equips large buildings with the means of measuring and tracking energy consumption in  
the interest of reducing wasted energy. These energy monitoring requirements will help owners of new  
buildings understand their energy consumption and clarify similar goals for existing building owners.  
2) All IECC appendices, specifically Appendix CC. Unlike the ASHRAE appendices, Appendix CC is not  
specifically included in the current draft language. The IECC 2021 Appendix CC (aka Zero Code) is a  
critically important framework that allows Michigan and its cities to more easily reach their carbon  
neutrality goals. IECC 2021 Appendix CC combines energy efficiency and renewable energy to support  
the construction of code-compliant, zero carbon buildings that use clean energy. It applies to new  
commercial, industrial and mid- to high-rise residential buildings—the dominant building types being  
constructed in cities today.  
3) Maintain the inclusion of all sections pertaining to the requirements for all-electric buildings. The  
buildings we construct today will be the buildings we occupy and operate for many years. Given the  
goals of the State of Michigan, the Federal government, and the local jurisdictions throughout  
Michigan, it is imperative that we eliminate fossil fuel reliance immediately.  
A2ZERO is Ann Arbor’s plan for a just transition to carbon neutrality by 2030. Because two-thirds of Ann  
Arbor’s greenhouse gas emissions come from buildings, the inclusion of the above key components in the  
Michigan Energy Code will help Ann Arbor best serve its residents & businesses by creating a pathway  
toward safer, healthier, more comfortable, and more efficient buildings, all while preserving our state for  
future generations.  
We intend for our comments to be interpreted as minimum suggestions; we eagerly express our willingness  
to explore additional requirements to enable everyone achieve carbon neutrality.  
Thank you for your time and consideration.  
Sincerely,  
Zach Waas Smith  
Jeffrey S. Ferweda, AIA, NCARB  
Sedgewick + Ferweda Architects  
410 East Court Street  
Flint, Michigan 48503  
www.architectsinmichigan.com  
American Institute of Architects (AIA) Michigan Government Affairs Co-Chair  
Vienna Township Planning Commission Chair  
June 5th, 2022  
Public Hearing Testimony  
RE: 10a Michigan Energy Code (ORR# 2021-49 LR)  
I am proposing that the State of Michigan adopt IECC Appendix CC (AKA Zero Code) as a required appendix in the  
Michigan Commercial Energy Code. The American Institute of Architects (AIA) and Architecture 2030 have  
AIA Michigan supports policies, programs, and practices that promote adaptable, resilient, and regenerative buildings  
and communities. This includes creating zoning and planning policies and practices that recognize historic patterns of  
discrimination, the impacts of climate change, and environmental justice concerns.  
Michigan recognizes its need to lead the industry in advocating for building a better and more resilient built  
environment. Buildings account for up to 40% of the world’s energy use, easily indicating the need to create and improve  
the efficiency of these buildings and other elements of the built environment.  
The appendix gives jurisdictions the option to adopt a zero-net-carbon standard as their community’s minimum energy  
code. Local jurisdictions that adopt the appendix could require all new commercial, institutional, and mid- and high-rise  
residential buildings to produce or procure enough renewable energy to achieve zero-net-carbon annually. Additionally,  
the appendix encourages on-site renewable energy systems but also supports off-site renewable energy when on-site  
generation is not feasible, such as for high-rise buildings with insufficient roof area, or buildings in densely built and  
shaded areas.  
Power companies are asking people to lessen the burden on the grid at peak times. Around the country, there have  
been significant grid power outages. Buildings, as the largest single energy siphon we have, are the logical target to help  
restore a balance and set our State as a leader in resilient building practices.  
Proposal:  
Add the following language “in Red” to the Michigan Commercial Energy Code, Rule 1087:  
R 408.31087 Applicable code.  
Rule 1087. Rules governing the energy efficiency for the design and construction of buildings and  
structures, not including residential buildings, shall be those contained in the international energy  
conservation code, 2015 2021 edition, except for sections C104.1 to C104.5, C107.2 to C107.5, C108.2 to  
C108.4, C109.1 to C109.4, C110.1 to C110.3, C301.2, C301.3, C302, C401.2.1 to C408.3.2, C405.12 to  
C405.12.5, C502.2 to C502.2.6.2, C503.2 to C503.6 and the ASHRAE energy standard for buildings except  
low-rise residential buildings, ANSI/ASHRAE/IESNA standard 90.1-2013 2019 (hereafter the standard),  
including appendices A, B, C, D, and G, except for sections 8.4.2,8.4.3 to 8.4.3.2. Additionally, Appendix  
CC of the international energy conservation code, 2021 edition, is included as an appendix as a  
supplement to the international energy conservation code, 2021 edition, to require renewable energy  
systems of adequate capacity to achieve net zero carbon emissions in applicable new buildings as defined  
in the scope of Appendix CC within that jurisdiction. With the amendments noted, the international energy  
conservation code and the standard are adopted by reference in these rules by reference. The Michigan  
energy code is available for inspection at the Lansing office of the Michigan Department of Licensing and  
Regulatory Affairs, Bureau of Construction Codes, 611W. Ottawa Street, Lansing, Michigan 48933. The  
code may be purchased from the International Code Council, through the bureau’s website at  
www.michigan.gov/bcc, at a cost as of the time of adoption of these rules of $44.00 $52.00. The ASHRAE  
90.1- 2013 2019 standard is available for inspection at the Lansing office of the Michigan Department of  
Licensing and Regulatory Affairs, Bureau of Construction Codes, 611 W. Ottawa Street, Lansing,  
Michigan 48933. The standard may be purchased from the American Society of Heating, Refrigeration and  
Air- Conditioning Engineers, Inc., 1791 Tullie Circle, NE, Atlanta, Georgia 30329, 180 Technology  
Parkway NW, Peachtree Corners, Georgia 30092, or from https://www.ashrae.org at a cost as of the time  
of adoption of these rules of $135.00 $177.00 each.  
Alternatively, I urge the adoption of Appendix CC as a voluntary appendix in the Michigan Commercial Energy Code, as a  
minimum step that empowers local communities to take action on climate change through building codes.  
Sincerely,  
Jeffrey S. Ferweda, AIA, NCARB  
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