HomeMy WebLinkAbout08/25/2025 - AIR QUALITY ADVISORY BOARD - AGENDA - Regular meeting Air Quality Advisory Board
Monday, August 25, 2025
5:30 – 8:00 PM (dinner for Board members and presenters served at 5:15 pm)
300 Laporte Ave | C ouncil Information Center “CIC Room” (first floor)
Meeting link for hybrid access (requires internet access): fcgov.com/aqab-teams-meeting
1. CALL TO ORDER
2. ROLL CALL
3. AGENDA REVIEW
4. PUBLIC PARTICIPATION
5. APPROVAL OF MINUTES
6. PREVIOUS BUSINESS
1. Air Quality Monitoring Advisory Committee update
2. NRAB/AQAB Collaboration on Building Performance Standards Policy
7. NEW BUSINESS
a. Building Energy Code Updates; 6:00- 7:00
Energy Services and Planning and Development staff will meet with the Board to discuss building
energy code updates, including background on process and major changes to code, that will be
introduced to the City Council at the September 9th Work Session. (Discussion)
8. OTHER BUSINESS
● Board Member Reports
● Six Month Calendar Review https://www.fcgov.com/cityclerk/planning-calendar.php
● Revisit action items from previous meetings & preview of next meeting
City Websites with Updates:
● Air Quality Advisory Board webpage: https://www.fcgov.com/cityclerk/boards/air-quality -advisory
● Our Climate Future: https://ourcity.fcgov.com/ourclimatefuture
9. ADJOURN
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Air Quality Advisory Board
REGULAR MEETING
Monday, July 21, 2025 – 5:30 PM
222 Laporte Avenue, Colorado River Room
1. CALL TO ORDER: 5:33 PM
2. ROLL CALL
a. Board Members Present –
• Dan Welsh (Chair)
• Mark Houdashelt (Vice Chair)
• Michael Johnson
• Matt Ayres
• Howard Gebhart
• Michael Cheeseman
• Christina Swope (arrived late)
• Maria Moore (arrived late)
b. Board Members Absent –
• Adam Schmidt
c. Staff Members Present –
• Honore Depew, Environmental Services Senior Manager
• Selina Lujan de Albers, Staff liaison
• Cassie Archuleta, Lead Air Quality Specialist
d. Guest(s) –
• Nancy Wendl and
3. AGENDA REVIEW
No changes.
4. PUBLIC PARTICIPATION
None.
5. APPROVAL OF MINUTES – JUNE 2025
Members discussed changes to the minutes.
Houdashelt made a motion, seconded by Gebhart, to approve the minutes of
the June 2025 meeting as amended. The motion was adopted unanimously.
THE MOTION CARRIED.
6. PREVIOUS BUSINESS
a. Elections – Vice Chair
Chair Welsh noted Houdashelt is willing to continue to serve as Vice Chair;
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however, he would prefer not to remain in that position. No other members
expressed interest in the position. Houdashelt stated he would remain.
b. Air Quality Monitoring Advisory Committee Update
Chair Welsh stated the AQMAC has had intermittent regular meetings and
has divided into two factions: the engagement subcommittee focused on
outreach and education, and the technical subcommittee focused on the
actual monitoring. He stated there have been a number of recent education
and outreach opportunities.
Chair Welsh read a statement from Micah Warners thanking the Air Quality
Advisory Board and AQMAC for support at Bike to Work Day.
Chair Welsh noted the AQMAC technical subcommittee has not had recent
formal meetings, though there is a field campaign underway that is a
partnership between CDPHE, the Regional Air Quality Council, and CSU’s
Atmospheric Science Department seeking to characterize the formation
mechanisms of ozone throughout the region. He noted there are two mobile
labs that are driving throughout the region as far south as Denver and as far
north as Fort Collins.
Cassie Archuleta stated the technical subcommittee did have a meeting to
tour the mobile lab and hear an overview of the project from a CSU
representative. She also noted there will be an engagement meeting next
month.
c. Change in Date for August Meeting
Chair Welsh noted there are two opportunities for workshops through the
Regional Air Quality Council in August and the Fort Collins workshop takes
place on the same day as the regularly scheduled AQAB meeting.
Additionally, he noted he and Lujan de Albers will both be out of town on
August 18th . Some members expressed interest in attending the workshop
and all agreed to move the meeting to August 25th .
Gebhart made a motion, seconded by Johnson, to move the August
meeting to the 25th. The motion was adopted unanimously.
THE MOTION CARRIED.
7. NEW BUSINESS
a. Our Climate Future (OCF) Refresh Project – Honore Depew
Honore Depew, Environmental Services Senior Manager, stated this item is
specific to one component of the OCF strategic refresh, which is how to
incorporate new and existing Environmental Services work and strategies into
the OCF framework to help advance them more effectively with less siloing
and separation. He provided a timeline of the overall project and noted staff
is currently in the latter phase of the engagement portion. He stated next
steps are to summarize and incorporate the feedback and create proposed
implementation strategies. Additionally, the other component is the Strategic
Funding Plan which Council will be discussing in an October work session.
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Depew discussed the project overview process, which included a gaps
assessment and peer city research , as well as an assessment of current
revenue streams, funding priorities, and sequencing. He stated the enhanced
OCF framework, which is more effective and inclusive of the City’s
sustainability efforts, is aligned and integrated with municipal sustainability
and adaptation efforts, and includes coordinated and useful planning,
implementation and storytelling, will be complete by the end of 2025.
Additionally, the OCF Strategic Funding Plan , which is a strategy and
guidance document with a 15-year time horizon that provides high -level vision
and guidance for the medium and long term, as well as clarity and focus for
implementation strategies in the near term, will be complete by the first
quarter of 2026.
Vice Chair Houdashelt asked if both of the deliverables need to be approved
by Council. Depew replied they do not need to be officially adopted by
Council, as OCF was adopted in 2021 and its text and content are not
changing.
Depew discussed the OCF’s alignment with City Plan and other adopted
plans. He noted there is no adopted Council goal for air quality. He
discussed the OCF big moves that are grouped into the following categories:
better together, resource better, breath e better, and live better.
Depew outlined the big question regarding local government sustainability:
how to achieve long-term sustainability goals for the community when
commitments to transformational change can be in tension with near-term
priorities and resource constraints. He noted the areas of influence that can
help get at that question include economic drivers, regulations and policy,
infrastructure investments, and behavior change through education. OCF
then works as a strategic framework providing goals, vision, and
implementation support.
Depew stated the purpose of the OCF strategic refresh is to make OCF
simpler to talk about, more inclusive of the City’s sustainability efforts, and a
more useful tool for planning and accountability. He summarized what is
needed for the refresh, includin g navigating tensions between priorities,
clarifying how next moves add up to big moves, supporting resourcing OCF
related work, aligning and integrating municipal sustainability and adaptation,
and identifying and integrating related new and existing work into the OCF
framework.
Depew outlined next steps in the process, which include incorporating input
and feedback from staff and community engagement, summarizing
enhancements to the OCF framework, and developing an implementation
approach for 2026, including the OCF Strategic Funding Plan.
Vice Chair Houdashelt asked about the motivation for this project. Depew
replied the motivation related to having the Strategic Funding Plan be more
deliberate and clear about what types of criteria are used to help sequence
and prioritize investments, to help guide and inform Council in its decision -
making, to assist staff throughout the organization understand what sorts of
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projects and programs would be eligible for funding, and to help the
community look at and respond to how the 2050 tax dollars are being used.
As a precursor to the Funding Plan, it was necessary to ensure the structure
on which the Funding Plan was built makes sense and helps to deliver those
outcomes. Additionally, Depew stated there has been an evolution in the way
sustainability is considered. He noted OCF was a joint update of the Road to
Zero Waste, the Energy Policy Plan, and the Climate Action Plan, and since it
was adopted, the Environmental Services Department has been reorganized,
a more inclusive definition of climate work has been normalized and
socialized, and the time is right to attempt to help make more sense of these
complex issues without losing the details and importance of acting
indi vidually.
Lujan de Albers added that going through a strategic refresh allows for a
better understanding of shared leadership across the organization and
community when implementing next move strategies to get to the big moves
and goals around emissions reduction an d zero waste.
Depew noted it is important to define and clarify responsibilities and authority
to help guide investments.
Chair Welsh noted a lot has happened since OCF was adopted, including the
development of potential funding sources such as the 2050 tax to aid or
implement the areas of influence.
Depew noted Sustainability staff has been more reactive in the past and has
reviewed budget offers through the lens of mitigation, resilience, and equity by
assessing impacts to greenhouse gas emissions, for example. He stated the
goal of this work is to try to get ahead of that type of reactivity. He noted
remittance fees from the disposable bag ordinance and the ongoing budget
from the Energy Services Department for advancing efficiency and renewable
electricity are funding sources as well as the 2050 tax.
Swope noted the City is not on track to meet its 2026 goals and requested
input as to how clarifying goals now will help. Depew replied it is important to
clarify how we support moving toward and achieving outcomes and goals, or
how we can be more clear about why we are not. He noted goals are used as
indicators of progress, staff has been directed to maximize potential for
reaching long-term goals while simultaneously reaching toward the interim
goals. Additionally, he commented on the importance of thinking through the
lenses of the areas of influence, including direct investments, given the ballot
language of the 2050 tax relating to reducing climate and air pollution and
reaching 100% renewable electricity.
A Board Member asked if there has been any quantitative analysis of the
strategies. Depew replied there has been a great deal of quantifiable analysis
of the impacts on mitigation of different strategies, and it can be projected
how much emissions would be reduced given certain infrastructure
investments, for example. He noted that is particularly well documented in
terms of electricity, though a full cost benefit analysis of dollars invested to
greenhouse gas emissions reduction has not occurred. Additionally, he noted
it is difficult in terms of climate action to assign a direct correlation between a
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new bike lane and a reduction in wildfire, for example; however, it is known
that the cost of inaction leads to overall warming of the planet and
inconsistent weather patterns.
Depew opened a discussion about how to better incorporate air quality
strategy into OCF by outlining the goals of the 2019 Air Quality Plan, including
reducing emissions, measuring and tracking, reducing pollution, focusing on
transported pollution, managi ng pollutant sources, and resilience and
adaptation. He discussed a proposed regrouping of the overall air quality
strategies as laid out in the strategic plan involving understanding and
characterizing the problem, source reduction, and adaptation and resilience.
Members discussed a California air quality analysis tool and modeling for
meeting the building energy codes.
Depew requested input as to the pros and cons of grouping strategies and air
quality work into cohorts and what general feedback the Board may have in
terms of integrating and aligning air quality strategies into OCF.
A Board Member asked about the definition of cohort in terms of the OCF
framework. Depew replied cohorts would be organizational arrangements of
strategies that are smaller than a big move, but larger than a next move in
OCF.
Moore noted the State has already acted on many of the topics, including
construction, oil and gas, small engines, and industrial sources. She stated
she would prefer to see more specifics and an evolving list from Fort Collins.
Gebhart stated it is good for the Plan to take credit for things in which
progress has been made; however, it also needs to be forward looking.
Depew stated he would like OCF to be less of a plan that might take credit for
something and more as a way of organizing thinking and helping to direct
resources and suggest which policies, programs, and investments should be
sequenced and prioritized.
Lujan de Albers asked if the cohort categories (problem characterization,
source reduction, and adaptation and resilience) resonate with the Board as a
starting point. Members generally concurred with the cohorts and Gebhart
stated they seem to be scientifically oriented.
Vice Chair Houdashelt stated the proposed cohorts would not be the way he
would like to structure funding conversations. Depew noted the list is not
exhaustive in terms of strategies but is illustrative of the groupings and
requested input as to how they could better be grouped or defined.
Moore stated she would like the list to be more specific and exhaustive.
Depew stated the sequencing intention for this phase is to ensure that OCF
as a framework, which is now connected to funding, strategy, and helping to
support sustainable initiatives widely across the organization, has air quality
outcomes, or cohorts, embedded within it so that as the Strategic Funding
Plan is finalized and the next moves plan is updated, there is a place for them
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to land.
Moore expressed concern that things in the space are rapidly evolving and
reiterated her desire to see more specifics.
A Board Member stated he does not see any fundamental issue with the three
outlined cohorts; however, he stated he does not feel equipped to look at it
through the lens of Council in terms of funding.
Gebhart commented on needing to know what data gaps need to be filled by
the City and having funding go toward that.
Chair Welsh commented on the possibility of a timeline framework examining
expected revenues which could be either used for larger identified projects or
smaller programs or initiatives that could also use funding.
Vice Chair Houdashelt suggested ‘Source Reduction’ could be changed to
‘Source Reduction Strategies’ to be more specific.
Depew commented on OCF being a larger bubble to help network and
holistically connect the more specific strategies that are in other adopted
plans such as the Active Modes Plan. He also discussed a new program
being implemented by the Regional Air Quality Council (RAQC) that will
provide $1.5 million to Larimer and Weld Counties.
Moore reiterated her concern that OCF lacks measurable outcomes.
Vice Chair Houdashelt expressed concern that there is a lack of information
as to the actual effectiveness of plans that exist.
Members and staff discussed the Regional Air Quality Council’s metrics and
accounting for how emissions inventories can be completed based on how
programs impact emissions inventories.
Moore commented on the possibility of doing emissions research at schools
during drop-off and pick-up times.
A Board Member commented on the emissions reduction goal numbers and
noted something is being measured in that realm. Depew stated there is an
annual inventory of greenhouse gas emissions for both municipal operations
and community wide divided by sector and source.
Moore stated that information needs to be more transparent.
Depew stated the intent was to have monitoring as one element of problem
characterization.
Gebhart suggested identifying separately that there is funding dedicated
toward the monitoring verification component.
Moore commended the framework but stated more specifics need to be
included.
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Chair Welsh commended the idea of the strategic refresh process and asked
Depew if the conversation has been beneficial. Additionally, he noted the
Board’s request for additional specifics regarding filling data gaps and
including quantitative evaluations of which metrics and source areas will be
the most effective use of resources. He asked if a list of which specifics and
elements that are not included in the presentation could be provided and
asked Board Members to provide ideas back to staff such as anti -idling
campaigns or small engine conversions.
Depew stated that accepting and expecting non -closure is part of the spirit of
a different way for staff and Board Members to engage with one another. He
stated the goal would be for staff to be able to tap into the guidance and
expertise of Board Members in addition to having them advise Council.
Swope commented on her desire to see staff come to the Board with specific
ideas to improve air quality and then have Board Members provide feedback.
Depew replied staff is attempting to change the systems so that strategy and
implementation can be done more effectively. He acknowledged the
frustration with the way local government works but stated this work and
continued conversations will enhance the ability to do the kinds of things
mentioned by Swope. He provided an example of a specific FC Moves
project that would aim to get people out of cars to reduce emissions that may
involve certain expenditures or engagement by Council at the regulatory level.
He also commented on the importance of building the foundational
organizational structure to help Council make better decisions.
Depew summarized the discussion topics, including clarifying that the cohorts
would be tied to proactive funding strategies, developing some loose
definitions for each of the cohorts to better describe them, considering cross
cutting factors such as region alism, partnership, and monitoring, thinking
about areas of focus across timelines, identifying where the data gaps are
specifically in the problem characterization cohort, looking to partnerships and
regionalism, considering pulling out monitoring as a separate category,
including and emphasizing transparency about metrics and tying that to the
sophisticated greenhouse gas reporting that is being done, and continuing to
engage the AQAB in prioritizing sequencing strategies to support air quality.
Moore suggested adding more specific deadlines to the timeline.
A Board Member asked what climate pollutants are included in the
greenhouse gas inventory other than carbon dioxide, methane, and nitrous
oxide. Depew replied industrial processes and product use are also included.
Archuleta noted there are also particle and ozone precursor inventories.
Depew noted the City adheres to the carbon accounting practices from
international protocol and has an A+ rating for reporting. He also noted the
City is attempting to discuss air pollution and climate pollution together.
Vice Chair Houdashelt commented on the importance of monitoring against
expectations.
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Depew noted he will be returning to discuss the Strategic Funding Plan and
next moves strategies that support the outcomes. Additionally, he noted air
quality strategies have largely been a part of resilience but stated he would
like continued feedback and suggestions. He suggested the source reduction
cohort could tie in well with the convenient transportation choices big move in
OCF.
Chair Welsh noted this is an ongoing two-way conversation.
8. OTHER BUSINESS
a. Board Member Reports
Chair Welsh noted a meeting has been scheduled with Councilmember
Ohlson on July 31st for himself and the Natural Resources Advisory Board
and Land Conservation and Stewardship Board Chairs. He stated he
generally feels the Board is functioning well and noted the more recent focus
on interactions with staff.
Vice Chair Houdashelt suggested getting a response from Councilmember
Ohlson regarding the discussion this evening and whether the Board is to
advise staff. Moore replied Councilmember Ohlson has already stated the
Board is to advise staff. Other members concurred with her assessment.
Chair Welsh noted the Board is not directing staff but is establishing a
relationship.
Lujan de Albers suggested ensuring the Board is still on track from the
Council perspective based on its current efforts.
Gebhart commented on the value of staff presentations coming earlier in the
process.
Lujan de Albers noted the feedback received from the AQAB in terms of
having more direction and earlier involvement with staff has been heard
across the department; therefore, Depew and she have shifted their
approach in terms of establishing better collaborative partnerships with the
Boards. She also noted that while the Board is not directing staff, it is
advising staff on topics going before Council.
Chair Welsh stated Council’s permission is not needed for the Board to find
better ways to work internally.
Vice Chair Houdashelt commented on the importance of staying within the
Board’s scope.
A Board Member suggested seeking input from Councilmember Ohlson on
how to best interact with the new liaison.
b. Six Month Calendar Review
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c. Revisit Action Items from Previous Meetings and Preview of Next Meeting
Lujan de Albers noted the plan for the August 25th meeting is to have Energy
Services staff present prior to going before Council on September 9th for
discussion of the Energy Building Code. She stated the presentation would
primarily be informational given the timeframe and there would not be time for
the Board to provide input to Council; therefore, the Board can opt not to hear
the presentation if desired, though informational presentations may also hold
some value.
Gebhart stated informational presentations can have value and the Board
must appreciate the difference between those and presentations that are
seeking input.
Vice Chair Houdashelt noted the Energy Building Code item has yet to be
scheduled for Council adoption.
9. ADJOURNMENT
● 8:05 pm
Minutes approved by a vote of the Board on 8/XX/2025
Headline Copy Goes Here
Sr Project Manager –Building Energy
Code
Brad Smith
2024 Building Code
Adoption
Path to Zero Carbon
New Construction
by 2030
08-25-2025
Headline Copy Goes Here
2
Code Adoption
International Code Council (ICC)
publishes code every three years
•ex: 2012, 2015, 2018, 2021, etc.
Current Building Code
•The 2021 body of codes were
adopted on April 15, 2022 (with local
amendments).
•City policy to adopt energy code
within one year after publish
•Targeting adoption late 2025.
Headline Copy Goes Here
3
Code Adoption - regional alignment
Northern Colorado communities align to review code, amendments to code,
and stretch code.
•Larimer County
•Loveland
•Wellington
•Greeley
•SAFEbuilt
•Windsor, Timnath
•Fort Collins
Headline Copy Goes Here
4
Our Climate Future
Big Move 6
EFFICIENT, EMISSIONS FREE
BUILDINGS
EEFB2: Develop and energy
performance path for new
construction to zero carbon building
by 2030.
Community Conversations 2019
•Flexibility
•Transparency – spans 3 code cycles
•Real energy outcomes (kWh & Therms)
•Fossil fuel de-biasing of the code
•Data-informed decision-making
Headline Copy Goes Here
5
Building Energy code – Path to Zero Carbon New Construction
What this project is.
1.A building code for new construction
2.Meeting the desires of the community - OCF
3.A transparent, flexible approach to building
4.Innovative
What this project isn’t.
1.A ban on gas
2.Building Performance Standards (BPS)
3.Restrictive building code approach
4.Forgone conclusion
Headline Copy Goes HereWhat is a zero carbon / energy building?
1.Energy Efficient
2.Free of on-site GHG emissions from
energy use
3.Powered by 100% non -carbon energy
4.Ability to utilize demand response for
electric grid resilience
Fort Collins definition of a zero-carbon
new building / home:
Headline Copy Goes HereImplementing Performance Path to Zero Carbon Building
1.Developed as Appendices to the IECC
•Appendix CZ – Commercial
•Appendix RZ – Residential
2.Adopt appendices through our code amendments
Code Language:
A new Appendix CZ Commercial Performance Path to Zero
Carbon Building is hereby adopted in its entirety.
Headline Copy Goes Here
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Colorado Wildfire Resiliency Code
•HB23-166 established a Wildfire Resiliency Code
Board tasked with defining the Wildland Urban
Interface (WUI) and adopting rules for
jurisdictions within the WUI
•Jurisdictions within the WUI must adopt by
4/1/2026
•Exterior hardening and material requirements,
establishes a landscaping buffer area and
provides ongoing maintenance requirements
•Proposed to adopt with the larger building code
adoption but setting an effective date of 4/1/2026
Headline Copy Goes Here
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Colorado Wildfire Resiliency Code Map
•Most of Fort Collins does not
fall within the WUI
•Largest impacts to NW and SW
Fort Collins
•Some impact NE and SE Fort
Collins
2025 Colorado Wildfire Resiliency Code Map
Headline Copy Goes HereEV Charging (IBC)
10
•Revised language to align with newest Land
Use Code
•Provided parking spaces vs required parking
spaces
•Separated new buildings and additions
requirements for clarity.
•Additions providing new parking must comply with
the percentages required for new buildings
•Additions not providing new parking must provide
at least one EVSE installed space
•Design flexibility added
•Projects rewarded for installing above minimum
requirements
•Encourages additional EV installed installations
Headline Copy Goes HereEV Charging - Example
11
New residential project -100 parking spaces provided
EVSE Installed EV Ready
(receptacle installed)
EV Capable
(conduit only)
Standard
compliance path
10 20 40
Alternative 1 15 20 10
Alternative 2 15 5 40
Alternative 3 10 30 10
Headline Copy Goes Here
12
Advisory Board questions
•Does the Board have any questions or clarification about
proposed building code update?
•Does Board recommend that council pursue adoption of
building code update to advance building codes, including
amendments as proposed by staff?
Headline Copy Goes Here
Thank you!
Brad Smith Marcus Coldiron
Sr Project Manager – Building Energy Code Chief Building Official
brsmith@fcgov.com mcoldiron@fcgov.com
970-416-4321 970-416-2324
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SIGNIFICANT CHANGES to the 2024 IECC – Commercial
Provisions
Chapter C1 Admin Provisions
C101.3 Intent. The IECC—Commercial Provisions provide market-driven, enforceable
requirements for the design and construction of commercial buildings, providing minimum
efficiency requirements for buildings that result in the maximum level of energy efficiency that
is safe, technologically feasible, and life cycle cost effective, considering economic feasibility,
including potential costs and savings for consumers and building owners, and return on
investment. Additionally, the code provides jurisdictions with supplemental requirements,
including ASHRAE 90.1, and optional requirements that lead to achievement of zero energy
buildings, presently, and through glidepaths that achieve zero energy buildings by 2030 and on
additional timelines sought by governments, and achievement of additional policy goals as
identified by the Energy and Carbon Advisory Council and approved by the Board of Directors.
Requirements contained in the code will include, but not be limited to, prescriptive- and
performance-based pathways. The code may include nonmandatory appendices incorporating
additional energy efficiency and greenhouse gas reduction resources developed by the
International Code Council and others. The code will aim to simplify code requirements to
facilitate the code’s use and compliance rate. The code is updated on a 3-year cycle with each
subsequent edition providing increased energy savings over the prior edition. This code is
intended to provide flexibility to permit the use of innovative approaches and techniques to
achieve this intent. This code is not intended to abridge safety, health or environmental
requirements contained in other applicable codes or ordinances.
C105.6.2 Compliance Documentation. (this is for documentation required when building is
finished, not at review). This section has some errors that ICC does not feel would be solved
through the errata process and require it to go through a committee to fix. The change isn’t in
the requirements, but in the code sections that got referenced. Changes to other sections redid
the numbering but this section didn’t get references changed so it reads incorrectly. Please
note that the intent behind this section is to say that if you comply with the prescriptive
requirements of this code, then your final documents must identify the envelope insulation
path used (i.e. R-Value, U-Factor, or Component Performance Alternative), all compliance
calculations, and a plan for annual energy use data gathering and disclosure as specified in
C405.13 Energy Monitoring.
Chapter C2 Definitions New Definitions:
1. Air Leakage
2. Approved Source
3. Best Efficiency Point (BEP)
4. Chi-Factor (for determining thermal bridging)
5. Clean Water Pump
6. Common Areas
7. Community Renewable Energy Facility
8. Dehumidifier
9. Demand Control Kitchen Ventilation (DCKV)
10. Demand Response Signal
11. Demand Responsive Control
12. Desiccant Dehumidification System
13. DX-Dedicated Outdoor Air System Unit (DX-DOAS Unit)
14. East-Oriented
15. Emittance
16. Energy Recover, Series
17. Energy Recovery Ration, Series (SERR)
18. Energy Storage System (ESS)
19. Energy Use Intensity (EUI)
20. Exterior Wall Envelope
21. Fan Electrical Input Power
22. Fan System
23. Fan System, Complex
24. Fan System, Exhaust or Relief
25. Fan System, Return
26. Fan System, Single-Cabinet
27. Fan System, Transfer
28. Fan System Airflow
29. Financial Renewable Energy Power Purchase Agreement
30. Green Retail Tariff
31. High Capacity Gas-Fired Water Heater
32. High-End Trim
33. Horticultural Lighting
34. Humidistatic Controls
35. HVAC Total System Performance Ration (HVAC TSPR)
36. Indoor Grow
37. Integrated HVAC System
38. North Oriented
39. Occupied-Standby Mode
40. Owner
41. Parking Area, Exterior
42. Parking Area, Interior
43. Parking Garage Section
44. Photosynthetic Photon Efficacy (PE)
45. Physical Renewable Energy Power Purchase Agreement
46. Process Application
47. PSI-Factor
48. Pump Energy Index (PEI)
49. Purchased Energy
50. Renewable Energy Certificate (REC)
51. Renewable Energy Investment Fund (REIF)
52. Sensible Energy Recovery Ratio
53. Simulated Building Performance
54. South Oriented
55. Substantial Improvement
56. Thermal Block
57. Thermal Bridge
58. West Oriented
59. Work Area
Revised Definitions:
1. Air Curtain Unit replaces air curtain
2. Biomass Waste replaces biomass
3. Dedicated Outdoor Air System (DOAS)
4. Enthalpy Recover Ration (ERR)
5. Large Diameter Ceiling Fan (changed from 7’ to 84 ½ “
6. Low slope (added 17% slope as applied to roofs)
7. Roof Replacement
8. Wall, Above-Grade
Chapter C4 Energy Efficiency
C401 General
C401.2.1 International Energy Conservation Code. Changed name of Total Building Performance
to Simulated Building Performance
C402 Building Thermal Envelope
C402.1 General. Building Thermal Envelope:
1. Prescriptive compliance requires a calculation of through penetrations of
mechanical equipment because anything greater than 1% of the opaque above-
grade wall area must have that area calculated as a separate wall assembly,
calculated by Component Performance Alternative (COMcheck) or by area weighted
averaging using approved method.
2. Wall solar reflectance and thermal emittance (CZ 0 only)
3. Roof solar reflectance and thermal emittance (CZ 0-3 only) - no changes
4. If exceeding the allowed window or skylight area in C402.5, then you must use
simulated performance, ASHRAE 90.1 or Component Performance Alternative.
5. Air leakage complies with C402.6
6. Thermal Bridging must comply with C402.7
7. Walk in coolers, freezers, etc., comply with C403.12
C402.1.2.1 Methods of determining U-, C- and F-factors. Brought Footnote A out from under the
envelope table and made it its own section, allowing compliance with ASHRAE 90.1 Appendix A
for assembly U-factors.
C402.1.2.1.6 Cold -formed steel assemblies. Now sends you to AISI S250 for U-factors
for building envelopes containing cold-formed steel framed ceilings and walls.
C402.1.2.1.7 Spandrel panels. The opaque assemblies within fenestration framing systems
(spandrel panels) now has its own code section and U-factor table but alternatively allows you
to use ASTM C1363 or NFRC 100 for calculating U-Factors.
TABLE C402.1.3 OPAQUE BUILDING THERMAL ENVELOPE INSULATION COMPONENT MINIMUM
REQUIREMENTS, R-VALUE METHODa R-value table gives no options for cavity only insulation for
metal framed walls.
C402.1.4 Component performance method. Component Performance Method: changed to be an
alternative to R-, C-, F-, psi-, and chi-factors plus now allows you to use this path to get out of
window to wall area limits. Still must meet SHGC requirements though.
C402.2.4 Slabs-on-grade. Added requirements for where perimeter insulation should be installed for
slab on
grade and heated slabs with an exception for slab on grade floors greater than 24 inches.
TABLE C402.5 Fenestration. U-factors of fixed fenestration got more efficient for climate zones 3, 4,
5, 7 and 8.
C402.6.1.1 Air barrier design and documentation requirements. New list of items required to show air
barrier design and documentation.
C402.6.1.2.2 Electrical and Communication boxes. Added air sealing requirements for
electrical and communication boxes
C402.6.2 Air Leakage compliance. Revamped the blower door testing requirements by tightening
up the max cfm of leakage from 0.4 to 0.35, changing the exception that allowed evaluation
and correction if leakage was between 0.4 and 0.6 cfm/sq ft to no be only allowed between
0.35 and 0.45cfm/sq ft. changed all of the exceptions for climate zones and size of buildings to
just exempt CZ 2B, Exempt buildings larger than 25,000 sqft in CZ 0-4, other than group R and I,
as long as they get verified through the envelope design and construction verification criteria.
All other commercial buildings get blower door tests. Allows R and I occupancies to test to a
different metric than other buildings if they choose testing instead of verification.
C402.7 Thermal bridges in above-grade walls. Thermal bridges in above-grade walls must be
identified and dealt with. Exceptions exist for buildings in CZ 0-3, any thermal bridge where the
conductivity isn’t greater than 3 Btu/h, the blocking/coping/flashing or similar for attachment
of roof coverings, and any thermal bridges already accounted for in a U-o r C-factor of the
building thermal envelope. Makes you look at thermal bridging for balconies and floor decks,
cladding supports, structural beams and columns, where vertical fenestration intersects with
above grade walls, and finally at parapets.
C403 Mechanical Systems
C403.1 General. The mechanical section changed to either allow compliance with all of the
requirements in C403, or compliance as a data center, or compliance with the new Section
C409, which is the Calculation of the HVAC total system performance ratio. This new section is
very limited to specific occupancies and systems.
C403.3.2 HVAC equipment performance requirements. Revised all of the HVAC equipment
efficiency tables to just be copied from ASHRAE 90.1.
C403.4.1.2 Deadband. Changed thermostat deadband requirements to require separate control
setpoints for heating and cooling, keep the 5 degree deadband between heating and cooling
setpoints, and also now have a minimum 1 degree deadband when setpoints get adjusted.
C403.4.1.3 Setpoint adjustment and display. If occupants can adjust the thermostats, the
adjustment for heating must be independent from the adjustment for cooling so that when
one is changed the other isn’t unless it is need to keep up with minimum deadband
requirements.
C403.4.1.4 Setpoint overlap restriction. If heating and cooling are on different thermostats
altogether, must provide a means to not allow heating to exceed cooling setpoint so that you
don’t simultaneously heat and cool.
C403.4.7 Heating and cooling system controls for operable openings to the outdoors. Revised
the requirements for operable openings to the outdoors to require any opening to the outdoors
that is greater than 40 sqft be interlocked with heating and cooling system and within 5 minutes
of the door opening it must disable or set back heating to no more than 55 degrees and disable
or reset cooling to no less than 90 degrees. Exceptions exist for entrances with automatic
closing devices, emergency exits with alarms, spaces without a thermostat or temperature
sensor, food prep locations as long as they are separately zoned, spaces served by radiant
heating and cooling, certain alterations, and doors served by air curtains.
C403.4.8 Humidification and dehumidification controls. New section on humidification and
dehumidification controls, disallowing humidistatic controls to use mechanical cooling to
reduce humidity levels below certain levels as well as disallowing the controls to use fossil fuels
or electricity to produce relative humidity above 30% in the warmest zone served by the
system. Exceptions apply to both situations. Also notes that if a zone is served by both
humidification and dehumidification there must be a means provided to prevent simultaneous
operation of both.
C403.7.1 Demand control ventilation. The requirements increased for when demand control
ventilation is required. Also allows a registered design professional to demonstrate an
engineered ventilation system that prevents the maximum concentration of contaminants from
being more than would be obtainable by the required rate of outdoor air ventilation and does
not allow more than 15% rate reduction of outdoor air.
C403.7.2 Parking garage ventilation controls. Ventilation for parking garages changed by breaking
the garage into “parking garage sections” hence the new definition and having separate
ventilation systems and controls for each section that reduce fan airflow to not less than 0.05
cfm/sqft of floor area served and no more than 20% of the design capacity. The ventilation
system for each section must also be controlled so that the fan motor demand is not more than
30% of the design wattage at 50% of the design airflow.
C403.7.5 Kitchen exhaust systems. Kitchen exhaust hood systems serving type 1 exhaust hood must
be provided with demand control kitchen ventilation controls if the hood airflow rate is greater
than 5,000 cfm. Exceptions for certain UL 710 exhaust hoods or where ERV is installed with a
specific sensible heat recovery effectiveness.
C403.7.8 Occupied standby controls. Occupied standby controls that setback the heating
and cooling by not less than 1 degree and shut off airflow supplied to the zone when the space
temperature is between the active heating and cooling setpoints or if there are multiple zone
systems, must be provided for each ventilation zone in postsecondary classrooms, lecture
rooms training rooms; conference and meeting rooms; lounges breakrooms enclosed offices,
open office areas and corridors.
C403.7.9 Dwelling unit ventilation system. Fans that serve to move the air for a heating or cooling
system for individual dwelling units cannot also be used to provide the outdoor air.
C403.8.5 Low-capacity ventilation fans. Airflow for low-capacity ventilation fans must now be
tested and airflow reported in the listing or on the label.
C403.8.6.2 Intermittent exhaust control for bathrooms and toilet rooms. Exhaust fans for
bathrooms and toilet rooms must now have a manual on capability and either a timer to shut it
off after not more than 30 minutes, an occupant sensor control, a humidity control or a
contaminant control that responds to a particle or gaseous concentration. With exceptions for
exhaust fans used as part of the mechanical ventilation system for R-2, R-3, and R-4
occupancies.
C403.9 Large-diameter ceiling fans. Ceiling fans now have fan efficiency requirements.
C403.15, C403.16, C403.17 (.15) Dehumidification in spaces for plant growth and maintenance.
(.16) Service water pressure-booster systems. (.17) Clean water pumps. There are now
requirements for equipment that dehumidifies indoor grow and greenhouse spaces, service
water pressure booster systems, and clean water pump efficiencies.
C404 Service Water Heating
No large changes in service hot water requirements, some of the sections were reworked.
C405 Electrical Power and Lighting Systems
C405.2 Lighting controls. Lighting controls clarifies that the requirements apply to lighting systems
powered through the energy service for the building, as well as building site lighting that the
building owner is responsible for.
C405.2.3 Dimming controls. Light reduction controls have changed to dimming controls with a
specific list of where they apply, similar to occupancy sensors. There is an exception for dimming
control when high-end trim lighting controls are provided. See new definition.
C405.2.8.1 Demand responsive lighting controls function. New Demand responsive lighting
controls function that automatically reduces the output of controlled lighting to 80% or less of
full power upon receipt of a demand response signal. There is no C405.2.8 that tells you when
this demand responsive lighting control is required so it is a requirement for how the controls
function but not that the controls are required. (Per direction from ICC: There is a pointer to
C405.2.8.1 in Appendix CI – Demand Responsive Controls. Where it is adopted, this section
then applies. However, if DRCs are already included in the building, then you would be required to
follow C405.2.8.1 per C405.1. Also, if you choose DRCs as an option in C406 then this
section would apply as well).
C405.2.10.1 Sleeping units and dwelling units in hotels, motels, and vacation timeshare
properties. Sleeping units and dwelling units in hotels, motels and vacation timeshare
properties must have at least two 125V, 15- and 20-amp switched receptacles in each room
except bathrooms, kitchens, foyers, hallways and closets, and the lighting controls must
automatically turn off lights and switched receptacles within 20 minutes of occupants leaving
the unit. There is an exception for rooms with certain captive key override controls.
C405.2.10.2 Sleeping units in congregate living facilities. Sleeping units in congregate living
facilities must have lighting in bathrooms on occupant sensors and then a manual control at the
entrance that turns off lights and switched receptacles in the unit with an exception for lighting
in bathrooms and kitchens. There is nothing in C405.2.10 that specifies when, if, or how many
switched receptacles are required, just that there needs to be a control to shut them off. (There is
no errata for this section at this time so for now it really is an “if you install the switched
receptacles then there must be a control to shut them off”
C405.4 Horticultural lighting. Lighting for plant growth changed to “Horticultural Lighting”. Now
there is an efficacy for horticultural lighting in greenhouses vs all other horticultural lighting.
Plus, the luminaires in a greenhouse must be controlled to automatically shut off when there is
enough daylight available. Other luminaires for horticultural lighting must be controlled to shut
off at specific programmed times.
C405.13 Energy Monitoring. Energy Monitoring got a boost in efficiency by requiring compliance
for buildings not less than 10,000 sq ft instead of the previous 25,000 sq ft.
C405.15 Renewable energy systems. Requires buildings in all climate zones except CZ 8 to be
provided with a specific on-site renewable electricity generation system, exempting buildings
less than 5,000 sqft or buildings that are shaded; however, any exempted building must comply
with off-site renewable energy requirements of C405.15.2, which states that they must procure
off-site renewable electrical energy that is determined by a new Equation 4-11. There are now
provisions to tell how the building owner procures and is credited for the total amount of off-
site renewable electrical energy through things like physical renewable energy power purchase
agreements, financial renewable energy power purchase agreements, community renewable
energy facility, off site renewable energy systems owned by the building property owner,
renewable energy investment fund or a green retail tariff. And gives the required location for
the generation source. There are provisions for off-site contracts, Renewable energy certificate
(REC) documentation, and REC purchases.
C406 Additional Efficiency, Renewable and Load Management Requirements C406.1 Compliance
1. Buildings greater than 2,000 sqft of CFA must meet C406.1.1 additional energy
efficiency credit requirements.
2. Buildings greater than 5,000 sqft of CFA must meet the additional energy efficiency
credits plus the new renewable and load management credit requirement by building
occupancy group.
3. Build out construction (finishing off of a core and shell building) greater than 1,000
sq ft that doesn’t have final lighting or final HVAC installed under prior permit must meet
C403.1.1.2 building core/shell and build-out construction that gives these buildings their
own efficiency credit requirements. There is an exception for core and shell buildings
where at least 20% of the net floor areas is without final lighting or HVAC but then
doesn’t really exempt them from the requirements because each exception installs a
new requirement to meet one of the efficiency package requirements.
C406.1.1 Additional energy efficiency credit requirements. No longer gives a 10 credit
requirement across the board. The number of credits is based on climate zone and building
occupancy. Some credits can be carried over from the renewable and load management
credits but there are limits put on the carryover.
C407 Simulated Building Performance
C407.5.1.2 Testing required by software vendors. Software tools now must be tested by
the software vendor in accordance with ASHRAE standard 140 and publish their test results on
a public website.
C408 Maintenance Information and System Commissioning
C408.2 Me c hanic al sy st e ms and s erv ic e w at e r -he at i ng sy st e ms
c ommi ss i oni ng and c om pl et i on r e qui re m e nts . HVAC and SWH
commissioning now exempts buildings less than 10,000 sqft of CFA and combined heating,
cooling and SWH capacity of less than 960,000 Btu/hr. Also exempt are specific
components within dwelling units and sleeping units.
C408.3.1 Functional testing. Functional testing of lighting controls expanded to also include
testing of receptacle control systems.
C409 Calculation of the HVAC Total System Performance Ratio
Brand new section compliments options for compliance listed in section C406.2.2 More
efficient HVAC equipment performance.
Chapter C5 Existing Buildings
C502 Additions
C502.3.7 Additional energy efficiency credit requirements. Additions now must comply with
C406 additional efficiency requirements, but they only have to get 50% of the credits required
based on occupancy group and climate zone. There are 5 exceptions.
C502.3.8 Renewable energy systems. Now must comply with the renewable energy systems
requirements but only for the addition.
C503 Alterations
C503.2.1 Roof, ceiling and attic alterations. New section on Roof, ceiling and attic alterations that
specifies when the
insulation requirements must be met.
C503.2.4 Above-grade wall alterations. Big change in above grade wall alterations and when they
have to comply.
1. Existing exposed cavities need to be filled.
2. New cavities meet new requirements
3. Adding exterior wall coverings and fenestration requires either continuous insulation
being added or at least an R-value added to bring the wall into compliance with today’s
values, or an approved design that minimizes deviation from today’s U- factors.
C503.2.5 Floor alterations. Floors being altered must be brought into compliance or at least get the
best you can get.
C503.2.7 Air barrier. Any thermal envelope assemblies being altered get an air barrier, but it doesn’t
have to be continuous because unaltered portions don’t need to be changed.
C503.3.3 Heating and cooling systems. Duct testing required for alterations for either 25% or more of
the total length of the ducts in the system are relocated or the total length of all ducts in the
system is increased by 25% or more.
C503.3.5 System sizing. New heating and cooling systems installed as part of alteration must
comply with control requirements and be sized correctly.
C503.3.6 Replacement or added roof-mounted mechanical equipment. Roofs with insulation
entirely above deck that have roof mounted mechanical equipment that is replaced, or new
equipment added, must install curbs for added or replaced equipment that will allow for future
addition of insulation.
C503.5.1 Interior lighting and controls. Alterations that add full height partitions kick in
compliance with lighting for new buildings. Also, altering lighting requires compliance with
LPDs, controls, functional testing.
C503.5.2 Exterior lighting and controls. If alteration increases exterior lighting more than 400 watts, all
the exterior lighting must comply even if it wasn’t being touched. Any altered lighting controls
must be compliant as new construction.
C503.6 Additional energy efficiency credit requirements for alterations. Alterations that are
substantial improvements (see definition) must meet C406.2, C406.3, or both to earn the
number of credits required in Table C406.1.1(1). Exceptions apply.
C505 Change of Occupancy or Use
C505.1 General. Changes of occupancy now have Group F, H, S, or U occupancies complying with
the alteration’s provisions of C503. Any buildings undergoing a change of occupancy without
alterations must comply with C505.2 Energy use intensities, with exceptions for buildings that
don’t increase energy use intensity or buildings where the occupancy or use change is less
than 5,000 sqft in area.
Chapter C6 Referenced Standards
Many updated standards to more current editions. Many new standards, most of which deal with
mechanical equipment or procedures.
Appendices
• Maintains Appendix CA Board of appeals and Appendix CB Solar ready zone with minimal
change.
• Appendix CC Zero Energy Commercial Buildings was updated.
New appendices:
1. CD The 2030 glide path for those wanting to achieve zero net energy by 2030. It
reduces the net annual energy use of buildings by about 1/3 compared to the 2021
IECC. It is assuming that the 2027 and 2030 will also reduce energy use by 1/3.
2. CE Required HVAC Total System Performance Ratio (TSPR): can be adopted for stretch
codes and utility incentive certification that requires TSPR analysis where it is applicable
and requires a higher level of performance, saving 5% versus minimum efficiency
systems.
3. CF Energy Credits can be adopted by AHJs seeking stretch codes building on the
methodology of Section C406. Contains an “advanced energy credit package”.
4. CG Electric Vehicle Charging Infrastructure can be adopted by AHJs seeing electric
vehicle charging infrastructure requirements.
5. CH Electric-Ready commercial building provisions can be adopted by AHJs wanting new
buildings to be electric ready.
6. CI Demand responsive controls can be adopted for those seeking demand responsive
controls to be integrated into heating and cooling systems, water heating systems and
lighting systems.
7. CJ Electrical energy storage systems provide requirements for electric energy
storage readiness.
• Adds Resource CRA for all electric commercial building provisions. It isn’t an appendix, just
related information that is not part of the code. Has a note to jurisdictions to be sure to look at
federal laws that might preempt these provisions.
• Adds resource CRB the 2030 glide path (prescriptive), which is intended to be adopted by
jurisdictions who will require new construction to operate at next zero energy by year 2030. It is not
an appendix like CD, which utilizes a performance approach, this one uses a prescriptive path and
is just a resource.
SIGNIFICANT CHANGES to the 2024 IECC - Residential Provisions
Chapter R1 Admin Provisions
R101.3 New Intent: The IECC—Residential Provisions provide market-driven, enforceable
requirements for the design and construction of residential buildings, providing minimum
efficiency requirements for buildings that result in the maximum level of energy efficiency
that is safe, technologically feasible, and life cycle cost-effective, considering economic
feasibility, including potential costs and savings for consumers and building owners, and
return on investment. Additionally, the code provides jurisdictions with optional
supplemental requirements, including requirements that lead to achievement of zero
energy buildings, presently, and, through glidepaths that achieve zero energy buildings by
2030 and on additional timelines sought by governments, and achievement of additional
policy goals as identified by the Energy and Carbon Advisory Council and approved by the
Board of Directors. The code may include nonmandatory appendices incorporating
additional energy efficiency and greenhouse gas reduction resources developed by the
International Code Council and others. Requirements contained in the code will include,
but not be limited to, prescriptive- and performance-based pathways. The code will aim to
simplify code requirements to facilitate the code’s use and compliance rate. The code is
updated on a 3-year cycle with each subsequent edition providing increased energy savings
over the prior edition. The IECC residential provisions shall include an update to Chapter 11
of the International Residential Code. This code is intended to provide flexibility to permit
the use of innovative approaches and techniques to achieve this intent. This code is not
intended to abridge safety, health or environmental requirements contained in other
applicable codes or ordinances.
R104.1.1 Above code programs. clarifies when you can call a program an above code
program, looking at the total building thermal envelope thermal conductance using
equation 1-1 based on climate zone.
R107.4 Approved third-party inspection agencies. expands on the provisions for approved
third party inspection agencies, spelling out their need to be independent agencies with
adequate equipment to perform inspections and tests with trained and credentialed
personnel.
Chapter R2 Definitions
New Definitions:
1. Air handling unit
2. Approved source
3. Automatic shutoff control
4. Balanced ventilation system
5. Biodiesel blend
6. Common areas
7. Construction documents
8. Continuous pilot
9. Damper
10. Demand Response Signal
11. Demand Responsive Control
12. Distribution system efficiency (DSE)
13. Ductwork
14. Emittance
15. Enclosed Reflective Airspace
16. Energy Rating Index
17. Existing Building
18. F-Factor (Thermal Transmittance)
19. Fuel Gas
20. Fuel Oil
21. Grade Plane
22. Heat Exchanger
23. Intermittent Ignition
24. Interrupted Ignition
25. Knee Wall
26. Liquid Fuel
27. Living Space
28. Low slope
29. Occupiable space
30. On-demand pilot
31. Plenum
32. Radiant Barrier
33. Reflective Insulation
34. Simulated Building Performance
35. Sleeping Unit
36. Solar Ready Zone
37. Space Conditioning
38. Space Conditioning Equipment
39. Steep Slope
40. Substantial Improvement
41. Work Area
Revised Definitions:
1. Duct System
2. Rated Design
3. Roof Replacement
4. Testing Unit Enclosure Area replaces Dwelling Unit Enclosure Area
Chapter R3 General Requirements
R303.1.6 and R303.2.2 (1.6) Airspaces. (2.2) Radiant barrier. provisions for radiant barrier
and reflective airspace installation requirements were brought into the General
Requirements.
Chapter R4 Energy Efficiency
R401 General
R401.2.1 Prescriptive Compliance Option. Now only the Prescriptive path of compliance
must comply with R408 additional efficiency requirements.
R401.2.2 Simulated Building Performance Option Total Building Performance is changed
back to Simulated Building Performance
R402 Building Thermal Envelope
R402.1.5 Component performance alternative. Total UA Alternative now becomes
Component Performance Alternative just like commercial. Brings in F factor so that slabs
can be traded off again. Also allows the option to get assembly U- factors and F-factors
from ASHRAE 90.1 Appendix A. R402.2.10 Slab- on-grade floors was changed to exempt
slabs that are 24” or more below grade (used to be 12”), and slabs complying with
simulated performance or ERI paths.
R402.3 Radiant barriers. does not require radiant barriers but clarifies that if you install them,
they must be installed according to ASTM C1743.
R402.5 Air Leakage. Air leakage testing (maximum air leakage rate):
1. Prescriptively, CZ 0-2 = 4 ACH/50; CZ 3-5 = 3 ACH/50; CZ6-8 = 2.5 ACH/50
2. Performance or ERI: All CZs = 4 ACH/50 or 0.22 CFM/SQFT of building thermal
envelope area or dwelling testing unit enclosure area.
3. Exceptions for attached housing and houses under 1500 SQFT of conditioned floor
area (CFA) to be 0.27 CFM/SQFT/testing unit enclosure area.
4. Provisions for sampling for buildings with eight or more units to be tested.
R403 Systems
R403.3.4 Duct systems located in conditioned space. Brought in more clarification for when
ductwork (changed the word ducts everywhere to ductwork) is considered to be inside the
conditioned space.
R403.3.5 Ductwork buried within ceiling insulation. Added provisions for supply ductwork in
unvented attics that have vapor diffusion ports in Climate Zones 0-3A. Also, added a
reminder that air permeable insulation installed in unvented attics must comply with Section
R806.5 of the IRC.
R403.3.7 Duct system testing. Duct system testing brought back the exception for ducts
entirely within conditioned space but only if there is no more than 10 feet of total ductwork
external to the space conditioning equipment. Also, changed max leakage rate to 3 cfm if
equipment isn’t installed yet.
R403.3.8 Duct system leakage. The amount of duct leakage allowed once equipment is
installed now depends on equipment and duct configuration, whether the duct system
serves more than 1000 SQFT of CFA or 1000 SQFT of CFA or less, and the number ducted
returns. Also, clarifies that the amounts are for Total Duct Leakage (TDL) and not Leakage
to Outside (LTO) when using prescriptive paths of compliance.
R403.3.9 Unit Sampling. Allows sampling for ductwork testing in buildings with eight or
more dwelling units.
R403.6.1 Heat or energy recovery ventilation. Now climate zones 6 (new), 7, and 8 must have
heat recovery or energy recovery ventilation systems. They must be a balanced ventilation
system with a sensible recovery efficiency of at least 65% at 32 degrees.
R403.6.4 Unit sampling. Now allows for sampling of the mechanical ventilation system
testing for buildings with eight or more dwelling units or sleeping units.
R403.6.5 Intermittent exhaust control for bathrooms and toilet rooms. Intermittent
exhaust control for bathrooms and toilet rooms. Clarifies how controls must work if they are
designed for intermittent operation. Must be time control, occupant sensor control,
humidity control, or contaminant control with exception for systems serving as the whole
house mechanical ventilation system.
R403.7.1 Electric -resistance space heating. puts limits on the installed heating
capacity for all electric-resistance space heating serving one- and two-family dwellings
and townhouses in CZ 4-8.
R404 Electrical Power, Lighting and Renewable Energy Systems
R404 becomes Electrical Power, Lighting and Renewable Energy Systems instead of
Electrical Power and Lighting Systems.
TABLE R404.1 Lighting Power Allowances for Building Exteriors. Brings in watt/sq ft
lighting power allowance for exteriors like in commercial.
R404.1.1 Exterior Lighting. Brings in exterior lighting power requirements but then exempts
almost everything out of the requirement except maybe R-2, and R-4.
R404.2.1 Habitable spaces. Interior lighting has dimmer or auto off controls for “habitable
spaces”
R404.2.2 Specific locations. Garages, unfinished basements, laundry rooms and utility
rooms have auto off within 20 minutes of occupants leaving a space
R404.4 Renewable energy certificate (REC) documentation. REC documentation states
that where renewable energy generation is used to comply with this code, documentation
must be turned in that demonstrates where RECs or Energy attributable certificates (EACs)
are associated with that portion of renewable energy used to comply then the RECs or EACs
shall be retained or retired on behalf of the property owner. They don’t transfer.
R405 Simulated Building Performance
R405.2 Simulated Building performance compliance. does bring in a type of penalty for fuel
burning appliances used for space heating or water heating by saying that the annual
energy cost of the dwelling unit shall be less than or equal to 80% of the annual energy cost
of the standard reference design. Everything else must be at 85%. Also, each dwelling unit
greater than 5000 sq ft of living space above grade must reduce the annual energy cost an
additional 5% of the standard reference design. (This Section was not part of the removal
of the building electrification proposals that were removed by ICC Board of Directors after
the appeals process, likely just missed, but it cannot be handled as an erratum and must go
through the 2027 code cycle to be fixed so a jurisdiction would need to amend it if they felt
that it should be taken out. However, Colorado State Law does not allow a jurisdiction to
amend a code to be less restrictive than the published version so you would need to show
how the full code, once amended, is not less restrictive.)
R405.5.2 Testing required by software vendors. Software tools now must be tested by the
software vendor in accordance with ASHRAE standard 140 and publish their test results on a
public website.
R406 Energy Rating Index Compliance Alternative
R406.1 Scope. Reads confusingly by stating that this path is limited to dwelling units and
then goes on to say that if you are anything other than a dwelling unit in a Group R-2, R-3 or
R-4 building, you have to use the prescriptive path and cannot use ERI, or any other path for
that matter. There are no R-2, R-3, or R-4 occupancies in the IRC, only the IBC so this looks
to say that homes built out of the IRC cannot use this path.
It is believed that this wording was really meant to say that if you have a space that is not a
dwelling unit within an R-2, R-3 or R-4 building, then that space must go prescriptive. (An
erratum has been submitted to state that “…Analysis shall be limited to dwelling units in
residential buildings.” And then leave the rest to show that spaces other than dwelling units
go prescriptive.)
R406.3 Building thermal envelope. ERI has new backstop using a multiplier to get a max
building thermal envelope thermal conductance using the prescriptive U- and F-factors
from the U factor table, based on climate zone. Also, this gives a max SHGC of 0.30 for
climate zones 0-3.
R406.5 ERI-based compliance. ERI Gives a rating required with or without Onsite Power
Production (OPP) based on climate zones.
R408 Additional Efficiency Requirements
R408.2 Additional energy efficiency credit requirements. Additional Efficiency
Requirements gets changed to a point system requiring 10 credits from at least 2 measures.
Requires 5 additional credits if a dwelling unit is over 5000 sq ft of area. Measures include
thermal envelope performance, roof solar reflectance, air leakage, heat pumps, high
performance HVAC and water heating systems, appliances, lighting controls, ERV or HRV
installed, renewable energy and demand responsive thermostat. R401.2 now has these
additional efficiency requirements only applying to buildings using the prescriptive path of
compliance. The Simulated Performance path has a 15% better proposed design to make
up for not using this section and the ERI path has a lower score required instead of
requiring this section.
Chapter R5 – Existing Buildings
R502 Additions Requires additions to comply with R408.2 and get at least 5 credits. There
are exceptions.
R503.1.1.2 Roof, ceiling and attic altercations. New section on Roof, ceiling and attic
alterations that specifies when the insulation requirements must be met.
R503.1.1.3 Above-grade wall alterations. Large change in above grade wall alterations and
when they must comply.
1. Existing exposed cavities need to be filled.
2. New cavities meet new requirements
3. Adding exterior wall coverings and fenestration requires either continuous insulation
being added or at least an R-value added to bring the wall into compliance with
today’s values, or an approved design that minimizes deviation from today’s U-
factors.
R503.1.1.6 Air barrier. Air barrier is required to be provided but not continuous.
R503.1.2.2 Heating and colling systems. Requires new heating and cooling equipment that is
part of an alteration to be sized properly.
R503.1.2.3 Duct system leakage. When ductwork increases by 25% as it relates to registers
installed, total length of duct system or relocation of ducts, duct leakage testing required to
meet 12 cfm/100sqft of CFA.
Appendices
Maintains appendices RA board of appeals, RB solar ready provisions, and RC Zero Net Energy
Residential Building Provisions.
• Added appendices:
o RD electric energy storage provisions
o RE electric vehicle charging infrastructure
o RF Alternative Building Thermal Envelope Insulation R Value Options
o RG 2024 IECC Stretch Code
o RH Operational Carbon Rating and Energy Reporting
o RI On site renewable energy
o RJ Demand Responsive controls
o RK Electric ready residential building provisions
o RL Renewable Energy Infrastructure
• Added Resource RRA all electric residential buildings.
Community Development and
Neighborhood Services
281 North College Avenue
PO Box 580, Fort Collins, CO 80522
970-416-2324
mcoldiron@fcgov.com
MEMORANDUM
Date: 6/4/2025
To: Mayor and City Councilmembers
Through: Kelly DiMartino, City Manager
Caryn Champine, Director, Planning, Development & Transportation
Lori Schwarz, AICP, PDT Deputy Director, Community Development and
Neighborhood Services Director
From: Marcus Coldiron, Chief Building Official
Subject: Adoption of the 2024 Building Codes update
BOTTOM LINE
The purpose of this memo is to provide council with an update on the adoption and timeline for
the 2024 Building Codes. The 2024 International Codes (2024 I-Codes) represent the most up-
to-date, comprehensive, and fully integrated body of codes regulating building construction and
systems using prescriptive and performance-related provisions. The purpose of these codes is to
establish the minimum construction requirements to safeguard the public health, safety, and
general welfare by regulating structural strength and stability, sanitation, light and ventilation,
energy conservation, and property protection from hazards attributed to the built environment
within the City of Fort Collins.
BACKGROUND
Since 1924, the City of Fort Collins has periodically reviewed, amended, and adopted the latest
nationally recognized building standards available for the times. The City has updated the
minimum construction standards 17 times since 1924.
The 2024 International Codes will replace the 2021 editions of the International Building Code,
International Residential Code, International Mechanical Code, International Fuel Gas Code,
International Energy Conservation Code, Internation Existing Building Code, International
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Swimming Pool and Spa Code, International Property Maintenance Code and Colorado Plumbing
Code, all of which were adopted on April 15th, 2022.
Building codes and standards are reviewed and voted on by code officials and construction
industry professionals from across the country and published every three years under the
oversight of the International Code Council (ICC). These core 2024 I-Codes represent the latest
construction publications from ICC.
REVIEW PROCESS
The implementation of new building standards can impact the construction industry and local
economy. To better understand these impacts, a code review committee is convened to review
the new codes and all local amendments. In addition to representation from several surrounding
jurisdictions, the code review committee represents a wide spectrum of volunteers from across
the local construction industry including private developers, residential and commercial builders,
architects, engineers, representatives from the energy conservation sector, and Poudre Fire
Authority.
Starting in March 2025, the code review committee began meeting to discuss new code, proposed
amendments, and current amendments. This committee will continue to meet through July 2025
and will conclude with a vote to move for adoption of the 2024 I-Codes and amendments. While
this review process requires considerable time and resources, it produces enforceable and
effective building codes and amendments that the community and construction industry create
and support together while continuing to align with the City’s goals and priorities.
KEY ANTICIPATED UPDATES AND CHANGES
A handful of new amendments are being proposed, some of which support the City’s sustainability
and Our Climate Future goals. Part of the focus for this adoption is to simplify our local
amendments and achieve greater alignment regionally. There are also several state bills and laws
in different stages of approval that may have significant impact to building codes throughout the
state.
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Some current amendments are now represented in the new 2024 code as written (codes have
caught up to us) and will be proposed to be deleted, while other amendments that did not have
the intended outcomes, have proven to be ineffective or were cumbersome as written will also be
proposed to be deleted or modified.
State bills/laws:
HB25-1273: Residential building stair modernization.
Signed by the Governor on 5/13/2025, this bill requires any jurisdiction with a population
over 100,000 to adopt a building code to allow up to 5 stories of a multifamily residential
building that satisfies certain life/safety requirements to be served by a single exit.
Colorado model electric ready and solar ready codes.
This law requires that any City and counties with building code must adopt the 2021 IECC
along with the model electric ready and solar ready code, also including provisions for
electric vehicles, when updating any building code between July 1, 2023, and June 30,
2026.
o Note: Due to previous building code adoptions, current code meets or exceeds
these requirements and as such, no additional action is required by the City.
SB23-166: The Colorado wildfire resiliency code bill.
Signed into law in 2023, This bill established a Wildfire Resiliency Code Board that was
tasked with defining the Wildland Urban Interface (WUI) and adopting rules for jurisdictions
in an area within the WUI by July 1, 2025. These rules will include a requirement that
jurisdictions adopt a code, such as the International Wildland-Urban Interface Code within
a predetermined timeline (currently proposed as 9 months after the July 1, 2025 date).
Local amendment highlights:
EV Charging: After introducing EV charging requirements in the 2021 building code
adoption, staff has received significant feedback regarding the implementation and impact
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of these requirements on new and existing developments and buildings. Staff will be
working with the code adoption committee to identify what opportunities exist, if any, to
add some flexibility of choice in the application of the requirements while still maintaining
strong alignment with city plans and Council priorities. This could include some trade-off
options for builders and developers that want to install more EV chargers than the
minimum required by code. Changes will also include reworking language to better align
with the recently adopted changes to the Land Use Code.
Accessory Dwelling Unit (ADU) appendix: Adoption of this appendix will allow flexibility in
adding an ADU to an existing dwelling. The provisions in the appendix allow for tradeoffs
that lessen the complexity, the construction waste, and financial impacts of the project
while maintaining equivalent life and safety considerations.
Energy Code: An energy code path to zero carbon building for new construction by 2030
is currently in development. To reach this goal, Fort Collins plans to implement
performance code, or a modeled approach to energy (e.g. energy use index or EUI) and
carbon dioxide equivalent (CO2e) compliance targets for code years 2024, 2027, and
2030. Establishing targets out to year 2030 will enable the building community to plan
years in advance. This also moves new construction beyond the traditional prescriptive
code approaches in the International Energy Conservation Code with a focus on debiasing
the code from fossil fuels. This is achieved through a departure from energy cost
compliance that is replaced with EUI and CO2e target compliance.
The City’s approach would encourage a shift to efficient electric space and water heating
that results in improved comfort, health and safety, electric grid resiliency, reduced energy
burden, and the intent to improve cost of construction. Once established, EUI and CO2e
targets for new construction will subsequently require higher performance each code cycle
through a stepped approach to the 2030 code. Recognized as an innovative approach,
the City was awarded a U.S. Department of Energy federal grant in July of 2023 through
the Infrastructure Investment and Jobs Act. The areas of interest within the project are on
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local code development and adoption, workforce training and education, implementation
and compliance, equity, energy and environmental justice, and partnerships.
•Water demand calculator (WOe): The woe is a method used to right-size plumbing
distribution system in residential buildings, by using a more accurate method to estimate
peak flow rate. The proposed code requires the woe be used for multi-unit residential
and allows it as optional for single-unit residential. The current method outlined in the IPe
has not been updated in decades to account for greater fixtures' efficiency levels installed
in today's buildings. Actual peak flows are much lower today than the current method uses.
Right sizing plumbing distribution systems inside a building can save on water
development fees and costs before construction, material costs during construction, and
energy and water use after occupancy.
•Visitability (guest accessibility): A visibility amendment was added and adopted with the
2021 building codes. Visitability is a common term used in building and accessibility codes.
However, the definition and requirements associated with visitability vary between those
codes. For added clarity and ease of understanding, our local amendment will propose
changing the nomenclature to "guest accessibility". Additionally, allowing the required
main floor guest accessible bathroom to be accessed from a bedroom, in addition to the
living, dining or kitchen, will add additional flexibility in design while still providing improved
accessibility.
•Temporary Emergency Uses: As a long-standing program, the permitting process and
life/safety requirements associated with community based and seasonal overflow shelters
by way of an alternative means of compliance, will now be proposed to be codified. This
allows facilities, after obtaining a building permit and meeting all life/safety requirements,
to operate as a community-based shelter for no more than 180 days in a 12-month period
and seasonal overflow shelters to operate from the beginning of November through the
end of April.
City of k�olli�
Copies or Unauthorized Distribution is strictly prohibited
This amended appendix to the International Existing Building Code also provides the
ability to extend temporary uses to other existing structures in the case of an emergency
event declared by local, state or federal entities.
NEXT STEPS
Following the conclusion of the code review committee in July, staff will present the proposed
building codes and local amendments to numerous Boards and Commissions and external
community groups, seeking additional feedback and participation prior to bringing them to Council
for adoption by the end of the year. The anticipated effective date of the updated codes is January
1, 2026.
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