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Item 6A - Energy Code memo1 MEMORANDUM To: Landmarks Board From: Maureen Rait, Executive Director of Public Works David Driskell., Executive Director of Planning, Housing + Sustainability Dave Thacker, Building Services Manager/Chief Building Official Kendra Tupper, Energy Services Manager Elizabeth Vasatka, Business Sustainability Coordinator Date: October 5, 2016 Subject: Energy Codes: Update on the City’s Long-Term Strategy and Seeking Feedback on the Proposed Near-Term Energy Code Amendments EXECUTIVE SUMMARY This memo outlines the long-term strategy for Boulder’s energy codes and proposed amendments for the next building and energy code update (late 2016). Staff has provided an outline of the long-term strategy (Attachment A) for context, and is updating and seeking feedback from the Landmarks Board on the proposed near-term energy code amendments (Attachment B). Long-Term Strategy The City of Boulder has set an aggressive goal of adopting net zero energy (NZE) codes by 2031, and has developed a strategy and pathway to achieve that target. Staff recognizes that in order to support the city’s Climate Commitment and sustainability goals, energy codes must begin to address sustainability beyond just energy use such as transportation, water, indoor environmental quality and waste. In fact, when staff projected emissions reductions out to 2050, savings from the implementation of progressively more stringent energy codes was the largest of any building efficiency program, including EnergySmart, SmartRegs and the Building Performance Program. 2 Proposed elements of the long-term strategy for energy codes include: 1. Pathways for achieving high performance NZE codes including: a phased schedule for NZE deadlines, early adopter incentives, allowance of off-site renewables, future adoption of outcome-based codes and the encouragement of all-electric buildings. 2. A six-year cycle for major updates linked to the national code adoption schedule, with local evaluation and updates every three years. 3. The prioritization and phasing schedule of non-energy sustainability requirements for commercial energy codes. Proposed Near-Term Updates Staff has developed proposed updates to the building and energy code, which is tentatively scheduled to be presented to City Council for consideration and adoption in late 2016. The proposed effective date of these changes is early 2017. Proposed near-term building and energy code updates include: 1. Restructuring and updates of the residential energy code, Green Building and Green Points (link to the current Green Building and Green Points program); and 2. New prescriptive requirements for commercial buildings, including only allowing this prescriptive pathway for alterations and new construction/additions with a construction cost less than $500,000. 3. Other miscellaneous updates including: revising how multi-family units are addressed and allowing off-site renewable energy for energy code compliance. Questions 1. Does the Board have feedback on the proposed near-term updates? 2. Does the Board have any questions on how the city’s adopted building and/or energy codes address historically significant buildings? BACKGROUND Please refer to Attachment B for an overview of energy and green codes. This Attachment provides background information on national energy and green codes, definitions of key terms that are used throughout this memo and a brief history of Boulder’s energy codes. Goals and Objectives of the City’s Energy Codes The overall long-term goal for the city’s energy code is to build high-performance, NZE residential and commercial buildings. The objectives below are designed to support this overarching goal: Supporting the Climate Commitment  To achieve and sustain significant greenhouse gas (GHG) reductions in support of the city’s overall Climate Commitment 3  To reach NZE codes by 2031  To support technologies and practices that will move the community towards local, distributed and renewable energy systems (for both buildings and transportation) that support the goal of 100 percent renewable electricity, as well as economic vitality and community resilience Promoting High-Performance Buildings  To promote sustainable building practices throughout the lifecycle of the building process (e.g., waste management, water management, transportation impacts, etc.)  To promote the development and ongoing maintenance of safe, comfortable and high performing buildings  To support energy resilience (the ability to maintain operations during grid failure) Creating Effective and Viable Codes  To adopt codes that are feasible to update regularly, implement and enforce  To provide building owners and design professionals with viable and economically feasible paths to comply with energy codes that are straightforward and easy to understand What is Net Zero Energy (NZE)? While NZE can be defined a number of ways, in this context, NZE means: The amount of renewable energy produced on-site, plus the amount purchased from approved community energy systems, is equal to or greater than the annual energy consumption of the site. This definition makes it possible for all buildings to become NZE even with poor solar access or other site constraints. ANALYSIS: NEAR-TERM CODE UPDATES As the city evaluates and updates its energy codes every three years, staff has gathered stakeholder feedback on some of the challenges related to compliance with current codes. Staff has drafted updates based on the feedback received which will be presented to council for adoption in late 2016 with an effective date in early 2017. Specifically, staff is proposing the following near-term energy code amendments:  Restructuring and updates to the current residential energy code, Green Building and Green Points (GBGP), including amendments to the International Residential Code (IRC) to require electric vehicle charging infrastructure  New prescriptive requirements for commercial buildings, including amendments to the International Building Code (IBC) to require solar photovoltaic (PV)-ready and electric vehicle charging infrastructure for multi-family and commercial buildings 4 In addition, the city plans to improve the compliance process by streamlining steps and providing more consistent and detailed guidance. Please see the July 19, 2016 Information Packet Memo (Attachment G) for a summary of the scope and intended outcomes of this compliance improvement effort. Staff also plans to make a few administrative updates to clarify the common points of confusion, such as how to consistently measure square footage in gaining compliance with the Green Points program. Near-Term Residential Energy Code Updates Planned amendments to the current residential building and energy code are as follows: 1) Eliminate the point structure in the Green Building and Green Points program, and prioritize and update key measures as mandatory (see Table 1). 2) Implement a sliding Energy Rating Index (ERI) scale based on floor area which will require residential buildings larger than 5,000 square feet (sf) to be NZE (see Figure 1). 3) Revise the ERI requirements for additions to impose more efficient requirements for larger homes and additions. ERI requirements for additions will only apply if the addition is 1,000 sf or larger – smaller additions will be required to meet the prescriptive requirements of the 2012 International Energy Conservation Code (IECC). 4) Revise alterations requirements as follows: a) Eliminate the Green Points program “point” options and the 500 sf threshold, to provide clarity and streamline the building permit process. b) Change the trigger for alteration requirements from measured floor area to the percentage of the project cost1 compared to the assessed or appraised value of the existing structure (see Table 2). c) Mandatory efficiency measures will be required for all alterations; these include: energy advising, energy audits and new construction regulations (see Table 2). 1 Project cost will be either the customer’s construction cost or the city’s project cost evaluation, whichever is higher. 5 Table 1: Proposed Changes to the Point Structure of GBGP  Requirements Current Requirements Proposed Requirements Energy Performance1 ERI/HERs ERI/HERs Waste Management2 Mandatory Mandatory Preservation of Natural Resources: Require shading from existing and new trees; organic, low water landscaping practices; and stormwater management3 Optional point Mandatory Solar Photovoltaic “Ready:” Pre-wire for solar PV and a space allocation roof plan Optional point Mandatory Electric Vehicle Charging Infrastructure: Require the installation of both 120-Volt and 240-Volt charging outlets in any dedicated off-street parking space for single family homes and townhomes. For multi- family units, require charging infrastructure (120 and 240 V outlets) for 7.5% of the parking spaces, and require Level 2 dual port charging stations for 2.5% of the spaces.5 NA Mandatory (NEW) Water Efficiency: High efficiency kitchen and bathroom fixtures Optional point Covered in IRC4 Sustainable Products: Require the use of re-used, recycled, bio-based, environmentally certified or locally sourced materials Optional point Not required Solar Thermal “Ready”: Require solar thermal systems to heat hot water (water heating, space heating and/or pools and spas) Optional point Not required Material Efficient Framing: Require efficient use of lumber and methods to frame a house and design the structure Optional point Not required6 Indoor Air Quality: Require means of detecting, reducing and mitigating indoor air pollutants Optional point Design Process and Education: Require green building design professionals and an owner manual for efficient operation Optional point 1 Updated for both new construction (Figure 1) and additions. 2 These requirements may be revised to increase the diversion rates (based on the current recycling markets). 3 A landscaping plan is required for new construction must be submittal with the permit. A landscape rehabilitation plan will be required for additions and alterations. 4 Staff will increase the current requirements in the International Residential Code (IRC) to match the current national EPA’s WaterSense Standards 5 This requirement is only triggered when there are at least 25 parking spaces. 6 An updated HERS rating software will be released in the 2017, which will incorporate these sustainability attributes. The design manual will remain a requirement. 6                         Figure 1: Proposed Changes to Efficiency Requirements for New Homes  Table 2: Alterations Requirements  Thresholds for  requirements   Project cost is  ≤20% of assessed  value of existing  property   Project cost is 21‐50% of  assessed value of existing  property   Project cost is >51% of  assessed value of existing  property  Measures All energy and building code requirements (for the scope of the alteration) EnergySmart Advising1 EnergySmart Audit2 and Advising Triggers new construction requirements Air sealing and insulation in ceiling and walls3 Crawl space conditioning3 0 10 20 30 40 50 60 0 1000 2000 3000 4000 5000Energy Rating Index (ERI)Residential Structure Floor Area (square feet) Current2019 2022 2017 2025 2028 2031 7 1 Homeowner must contact EnergySmart and discuss the construction project with an energy advisor to ensure efficiency opportunities are maximized. 2 Homeowner must enroll in EnergySmart and receive an energy audit that includes a blower door test that measures infiltration of the existing building. 3 When applicable, implement these measures to code standards. Near-Term Commercial Energy Code Updates Revisions to the prescriptive path of Boulder’s commercial energy code are being proposed with the primary goal of improving usability and compliance while maintaining or increasing energy efficiency. While the performance pathway for new construction and major alterations must have an energy performance which is 30 percent better than IECC 2012, the prescriptive path is limited by market availability and construction and cost feasibility per individual requirement. The changes are described below, along with rationale for the changes. Table 3: Proposed Changes to Commercial Energy Code  Proposed Change Rationale When the Performance (Modeling) Approach is Required or Allowed: For new buildings, additions, and major alterations (more than 50 percent of the exterior wall area is being demolished) with a project cost greater than or equal to $500,0002, compliance using the modeling based performance approach will be required. Compliance using the prescriptive approach for these projects will no longer be allowed. Alterations which are not considered “major alterations” are required to comply using the prescriptive approach. Performance approach compliance is designed for new construction and major alterations that must achieve the city’s energy requirement of 30 percent better than IECC 2012. This requirement is so efficient that it requires the whole building tradeoffs allowed via the performance pathway. For smaller scope alterations, the prescriptive pathway is much better suited. 2 A threshold of a project cost of $500,000 was chosen as the limit for allowing the prescriptive path for new construction and additions based on the typical costs of energy modeling require for the performance and outcome based paths. This limit should keep the modeling costs to below 2.5 percent of the total project cost. 8 Proposed Change Rationale Revision of Prescriptive Requirements: The custom prescriptive pathway is being replaced with amendments to the IECC 2012 prescriptive path. These amendments will increase the stringency of IECC 2012 requirements up to what is allowed by federal regulations, or what is being proposed for the 2018 version of the International Green Conservation Code (IgCC). These changes address insulation levels, fenestration performance, lighting power and equipment efficiency. Current prescriptive requirements in the commercial energy code are extremely stringent, without the tradeoffs allowed through the modeling-based performance path. Overwhelming stakeholder feedback indicates that the requirements are confusing and extremely difficult, if not impossible, to achieve. These new prescriptive requirements will replace a complicated set of custom requirements. Simplification of prescriptive requirements that are based on nationally developed standards will improve compliance and simplify enforcement. Operable Window/Door Shut Off: New mandatory requirement for operable windows and doors to have switches which will shut off heating and cooling equipment when doors or windows are left open. This change prevents wasted operation of heating and cooling equipment when doors or windows remain opened. These requirements are based on requirements already present in other energy codes. Removal of the Building Area Method: For determining prescriptive interior lighting power, the Space by Space Method is now the only allowed approach. The Space by Space Method is based on the details of the proposed design. The Building Area Method is an approximation based on “typical” space allocations for a building type. Appliance Requirements: New mandatory requirement that appliances installed in multi-family buildings be EnergyStar rated. Requiring EnergyStar appliances in new residential occupancies will ensure that this end use is addressed even when multi-family buildings are covered under the commercial energy code. Solar “Ready” Requirements: Mandatory requirement to identify roof locations for installation of future solar systems , and keep these areas clear of obstructions. Locations for conduit and other electrical equipment that would be required for the solar system must also be identified. This equipment need not be installed. Identification and reservation of space for future solar systems will greatly facilitate future installation of solar systems where solar systems are not currently required or where larger systems may be required in the future. 9 Proposed Change Rationale Requirements for Electric Vehicle (EV) Charging Infrastructure: The following will be required for offices, industrial buildings and multi-family buildings3:  7.5% of parking spaces must have (1) 240-V and (1) 120-V charging outlet  2.5% of parking spaces must have a Level 2, dual port charging station installed Lodging facilities will be required to install charging stations (Level 2, dual port) for 1% of parking spots (a minimum of 1). Workplace EV charging provides employees that live in multi-family units without EV charging the opportunity to drive an EV. There is also a need for EV charging facilities at lodging facilities, as more and more rental car agencies are beginning to offer EV options. However, there has been very little usage in general public charging stations provided at commercial buildings for transient visitors. 3 There must be at least 25 parking spaces to trigger these requirements. 10 Other Miscellaneous Energy Code Updates Table 4: Summary of Other Miscellaneous Energy Code Updates Impacting Both Residential and Commercial Buildings Topic Description of Update Multi-family Units 1) Townhomes and duplexes will be covered under residential energy code. If there are any shared commercial spaces, they must comply with the prescriptive requirements for the commercial energy code. 2) All other multi-family buildings are covered under the commercial energy code, regardless of the number of stories. Water Fixture Use Rates The water fixture use requirements covered under the International Plumbing Code (IPC) and the International Residential Code (IRC) will be amended to be as efficient as current national WaterSense standards put out by the Environmental Protection Agency (EPA). Allow Off-Site Renewables Due to shading, roof space constraints and high energy intensity buildings (such as a data center or lab), off-site renewable energy will be required for some residential and commercial buildings to achieve NZE. Off-site renewable options will only be allowed if all on-site renewable options have been exhausted. Community solar gardens, but not Renewable Energy Credits (RECS), will be allowed to meet required overall energy performance for new buildings and major alterations. NEXT STEPS In terms of the next code updates, there are several more steps in the coming months. The tentative schedule is as follows:  November 3, 2016: Planning Board will review near-term energy code amendments.  November 15, 2016: City Council First Reading of proposed energy code amendments.  December 6, 2016: City Council Second Reading of proposed energy code amendments.  Q1 2017: Amendments to energy code become effective (following 60-day grace period after adoption)  Q1 2017: Noresco, the city’s consultant for this work, will conduct staff training and develop supporting documentation and resources on the city’s website to help explain the energy codes  Q2 2017: Staff will implement changes to improve energy code compliance Once the 2018 version of the national codes are released, the city will work quickly to adopt the 2018 versions of the codes, with local amendments.  Q1 2018: Staff will review the newly released 2018 codes, including IECC 2018 and IgCC 2018 11  Q3 2018: Staff will review the next building code update with the relevant boards, including moving from IECC 2012 to IECC 2018 and beginning to adopt portions of IgCC 2018  Q4 2018: Planned adoption of full set of ICC 2018 building codes, with amendments  Q1 2019: New building codes (based on ICC 2018 codes) becomes effective 12 ATTACHMENT A: LONG-TERM STRATEGY Proposed elements of the long-term strategy for energy codes include: 1. The long-term pathway for achieving high performance, NZE codes including: a. The allowance of off-site renewables to meet energy code requirements. b. The adoption of an outcome-based pathway for commercial energy codes. c. A schedule for when new buildings would need to meet a NZE code. d. Early adopter incentives for designing NZE buildings before the requirements ARE phased in. e. The encouragement of all-electric buildings. 2. A six-year cycle for major updates linked to the national code adoption schedule, with local evaluation and updates every three years (see the July 19, 2016 Information Packet Memo for more information). 3. Prioritization and a proposed phasing schedule of adopting IgCC’s non-energy sustainability requirements for commercial codes, and subsequently amending other portions of the city’s codes that may currently address these issues (see the July 19, 2016 Information Packet Memo for more information). The City of Boulder has set an aggressive goal of having NZE codes in effect by 2031, and this recent work effort represents staff’s first attempt at charting a clear strategy and pathway to achieve that target. The figure and table below provide more details on the key components of the long-term strategy and illustrate when each is suggested to go into effect. Figure 2: Long‐Term Strategy Key Component Timeline  13 Table 5: Long-Term Strategy Key Components (Post 2016/2017 Updates) Key Component of Long-Term Strategy Description Scope Phasing Off-Site Renewables Due to shading, roof space constraints and high energy intensity buildings (such as a data center or lab), off- site renewable energy will be required for many buildings to achieve NZE. Off-site renewable options will only be allowed if all on-site renewable options have been exhausted. Community solar gardens, but not Renewable Energy Credits (RECS), will be allowed to meet required overall zEPI scores for new buildings and major renovations. Commercial and Residential 2017 Require a Base Level of Efficiency Prior to Renewables The following method will ensure that building efficiency is prioritized before the use of renewables:  A zEPI score (commercial) or ERI (residential) is required for overall compliance.  A zEPI score of 45 or an ERI of 50 must be achieved through efficiency alone; renewables can then be used to achieve the code specified energy target (currently zEPI 38 for commercial and ERI value of 25 to 60 for residential). Commercial and Residential 2019 Outcome-Based Codes for Commercial Buildings Staff plans to pilot a voluntary outcome-based energy code for new commercial buildings, which will be based on the actual, measured energy consumption of the building post-occupancy.  Outcome-based codes bring energy behavior of occupants, maintenance and operating practices under the purview of the codes. These factors can account for 50 percent of a building’s energy use.  This is a new approach to energy codes; compliance and enforcement approaches are still under development nationally.  Data collected from the Building Performance Program will aid this process. Commercial Voluntary pilot 2019; possibly mandatory in 2022 (depending on pilot outcome) Schedule for NZE Compliance Staff is planning a slightly accelerated schedule for NZE for new residential and commercial buildings. Those with low energy use intensity and high roof to floor area ratios, can reasonably be required to be NZE sooner than 2031. This allows NZE requirements to be phased in over time to minimize enforcement issues, and accelerates achievement of the city’s Climate Commitment goals. Commercial and Residential 2019 to 2031 14 Key Component of Long-Term Strategy Description Scope Phasing Early Adopter Incentives  Providing incentives for buildings to be NZE before it is required by code encourages owners and design teams to develop advanced designs and share feasible examples for other buildings.  These incentives might include reduced city fees, expedited plans approvals and/or positive publicity. Commercial and Residential 2020 Encouragement of All-Electric Buildings To support long-term goals, local code amendments should begin encouraging all-electric buildings within the next five years.  Many of the city’s long-term goals will eventually require that the use of natural gas in buildings be minimized or eliminated: the goals of having all new buildings be NZE; moving the city towards local, distributed and fossil-fuel-free energy systems; and achieving and sustaining significant greenhouse gas reductions.  Buildings that use natural gas be made net zero with on-site or building-owned resources. They must have a market to allow excess renewable energy to be sold to other buildings to offset the gas consumption.  Minimizing the use of natural gas in new buildings facilitates the long-term achievement of a sizeable population of net zero buildings. Commercial and Residential 2022 15 ATTACHMENT B: OVERVIEW OF ENERGY AND GREEN CODES Many components of the long-term strategy, as well as the short-term updates, rely on the national suite of building and energy codes. This section provides background information on those codes, definitions of key terms that are used throughout this memo, and a brief history of Boulder’s energy codes. The International Code Council (ICC) publishes an extensive series of model codes every three years. In Colorado, these codes can then be adopted by local jurisdictions along with modifications or exclusions, as desired. The International Energy Conservation Code (IECC) and the International Green Construction Code (IgCC) are two such codes, and both are based on standards developed by the America Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE). Table 6: Summary of National Energy and Green Codes National Code International Energy Conservation Code (IECC) International Green Construction Code (IgCC) Scope Building energy performance – applies to both commercial and residential buildings “Green Code” addressing many aspects of sustainability beyond energy; applies only to commercial and high-rise (>3 stories) residential buildings Use in Boulder Code Residential: IECC 2012 with local amendments (Green Building and Green Points) Commercial: 30 percent more stringent than IECC 2012 Not currently adopted Alternate compliance via ASHRAE Commercial: 30% more stringent than ASHRAE 90.1-2010 ASHRAE 189.1 (2014 is equivalent to IgCC 2015) Important Notes IECC 2015 is only slightly more stringent than the 2012 version4, and still far less stringent than Boulder’s current codes. IECC 2018 is expected to have more significant updates and changes when released. IgCC 20185 will be merged with the ASHRAE Standard 189.1-2017, reducing confusion and pulling the best aspects from both codes. 4 IECC 2015 compared to IECC 2012: 8.7% more stringent for commercial buildings and 0.73% more stringent for residential buildings (according to Department of Energy) 5 Planned for release in late 2017 16 While the IgCC is now available to provide green code language for commercial buildings, there is still no suitable national model code6 for low-rise residential buildings. There are also many voluntary residential green building programs, but most of them have third-party evaluators, cost money to participate in and verify, have their own compliance guidelines and were not designed to be “codified” (e.g., LEED for Homes, etc.) As a result, Boulder will continue to update and evolve its residential green building code, the Green Building and Green Points program. Pathways for Compliance Energy codes have traditionally included at least two paths to compliance, prescriptive and performance (see figure below). More recently, an additional option of outcome-based energy codes has emerged. Mandatory requirements must be met regardless of which path is chosen. Figure 3: Energy Code Pathways for Compliance  One limitation to both prescriptive and performance pathways is that they only address efficiency characteristics of building design. Studies have shown that these design aspects only account for 50 percent or less of the total energy consumption of the building. Characteristics that are just as important include good building maintenance, efficient process and plug loads, and operating practices by occupants and building staff. To account for the energy performance of the entire building as used after occupancy, the addition of outcome-based compliance is being explored for commercial buildings. This is an approach that uses performance modeling to establish an energy consumption target during the design stage, but final compliance is shown by monitoring of a building’s energy consumption 6 National Green Building Standard (NGBS) is the only known option, but is not recommended because the energy chapter is not set up to guide builders to reach NZE and because it requires that certification is achieved through the Home Innovations Research Lab, a subsidiary of the National Association of Home Builders. 17 over a period of time (typically one year) following full occupancy. A building that exceeds the target energy consumption established at the design stage must then take corrective actions to reduce consumption. This type of code is currently being evaluated for inclusion in IgCC, IECC, and in several jurisdictions. It is as also being piloted in Seattle as an optional compliance path with a lower energy target than the performance path alone (link to 2014 ACEEE paper on Seattle’s program). Outcome-based codes verify and guarantee that new buildings are actually performing to the efficiency levels to which they were designed, but they also feature more complicated compliance verification and contract structures, as compliance responsibility is spread over multiple parties, including building occupants. Metrics for Energy Code Stringency and Compliance As the energy codes become more stringent, new methods of showing compliance or describing stringency are evolving. As a result, several metrics have been established to compare energy code stringency. These metrics will be referred to later in this memo. 18 Table 7: Metrics and Energy Rating Scales EUI (Energy Use Intensity): the total annual energy used per square foot of gross floor area. It is expressed in unit of kBtus (thousand British thermal units) per square foot per year (kBtu/ft2- yr). HERS (Home Energy Rating System): A nationally recognized index created by RESNET and used as the industry standard to measure the energy efficiency of a house. It is a scale where 0 is a NZE house and 100 is the energy consumption of a typical new construction house that meets the IECC 2006 for energy efficiency. ERI (Energy Rating Index)7: The ERI is essentially a non-trademarked equivalent of the HERS index. It is used as the scale for establishing the performance path target by the current version of the IECC for low-rise residential buildings. Current Boulder residential energy code requires a HERS score/ERI ranging from 25 to 60, depending on house size. zEPI (Zero Energy Performance Index): This is a scale for commercial buildings that is similar to the ERI for residential buildings. This scale also uses 0 for NZE buildings, but a score of 100 is representative of the EUI of typical existing building (opposed to new construction) from the 2003 CBECS8 data. The current Boulder energy code is equivalent to a zEPI score of 38. The metrics described the figure above can help establish more stringent energy code requirements by specifying a lower zEPI or HERS/ERI requirement, thereby moving toward NZE. By using these metrics, the comparison with energy code requirements throughout the country is possible, regardless of which model code is adopted. However, compliance with the commercial energy code requires modeling the energy usage of the reference building. This can vary by building type, floor area and other factors. In the future, there is an opportunity to simplify the commercial energy codes greatly by stating energy targets by building usage in 7 Because ERI is the metric used in national energy codes, the city will use this term in place of HERS. 8 Commercial Building Energy Consumption Survey – The Energy Information Administration (EIA) conducts a survey of existing building energy use by building type and climate zone to form this dataset. 19 terms of Energy Use Intensity (EUI), which then eliminates the need for modeling a fictitious reference building. Brief History of the City’s Energy Codes The city has a long history of “green” (also referred to as “above” or “sustainability”) code programs, and more recently, it has acquired a reputation of boldly adopting aggressive energy code requirements. Below is a summary and brief timeline of code and policy adoption that has put the city at the forefront in progressive and stringent building and energy code requirements, with supporting programs such as Energy Smart, SmartRegs, and the Building Performance Program. Table 8: Overview of Boulder Energy Code History Currently, the city evaluates and amends the latest national codes on a three-year cycle, and usually adopts the newest suite of national/international code every six years. Because the city has not yet adopted a national green building code, such as the IgCC for commercial buildings, other portions of the city’s codes and Design Standards currently address many non-energy sustainability issues (such as transportation and water). Please refer to Attachment A in the July 19, 2016 Information Packet Memo for a more complete history of the city’s residential and commercial energy codes, including a comparison of their stringency to other energy codes.