2026-06-29 Comment response to the published Request for information

Recommendation: DOE Should Work With ASTM International The U.S. Department of Energy has requested public comments on alternatives to the current building energy code framework. I encourage DOE to work with ASTM International to develop practical, consensus-based energy standards and methodologies that improve energy efficiency while preserving affordability, encouraging innovation, and expanding consumer choice. ASTM International has more than a century of experience developing voluntary consensus standards used throughout the world. ASTM standards support many areas of energy-efficient construction, including building envelopes, insulation, roofing systems, renewable energy technologies, thermal energy measurement, and building energy performance assessments. Today, ASTM publishes more than 12,000 standards developed through more than 140 technical committees, providing one of the world's most comprehensive technical standards systems. For building energy performance, ASTM already has technical committees working in many of the areas DOE is evaluating. ASTM Committee E06 on Performance of Buildings develops standards supporting building envelope performance, air leakage, windows, doors, curtain walls, and overall building enclosure performance. ASTM Committee C16 on Thermal Insulation develops standards supporting thermal insulation materials and building thermal performance. ASTM Committee D08 on Roofing and Waterproofing develops standards for cool roof technologies and roofing performance that improve building energy efficiency. ASTM Committee E44 on Solar, Geothermal and Other Alternative Energy Sources** develops standards for solar energy systems, renewable energy technologies, heat meters, and thermal energy applications. ASTM Committee E50 on Environmental Assessment, Risk Management and Corrective Action** has developed important building energy performance standards, including ASTM E2797, Standard Practice for Building Energy Performance Assessment for a Building Involved in a Real Estate Transaction ASTM E3224, Standard Guide for Building Energy Performance and Improvement Evaluation in the Assessment of Property Condition. These committees and standards demonstrate that ASTM already possesses the technical expertise needed to support practical, performance-based energy methodologies. ASTM E3224: Building Energy Performance ASTM E3224 is especially relevant because it addresses building energy performance using a whole-building evaluation. Building energy performance includes the annual energy consumed by a building for heating, cooling, ventilation, lighting, domestic hot water, refrigeration, cooking, office equipment, computers, appliances, and other miscellaneous energy end uses. This is important because energy performance is not limited to insulation or a single building component. It evaluates how the entire building performs as an integrated system. A whole-building energy performance approach considers the combined effect of the building envelope, mechanical systems, lighting, water heating, equipment, appliances, and actual building energy consumption. ASTM E3224 provides a recognized framework for evaluating building energy performance and identifying opportunities for improvement. This type of performance-based methodology demonstrates how ASTM can help DOE evaluate the real-world performance of buildings rather than relying solely on prescriptive component requirements. A Balanced Consensus Process One of ASTM's greatest strengths is its balanced consensus process. ASTM standards are developed through committees that include producers, users, consumers, consultants, government representatives, laboratories, engineers, architects, builders, researchers, and other technical experts. ASTM's committee structure is intentionally balanced so that no single interest category can dominate the standards development process. Producers, users, consumers, and general interest members are classified to maintain balance and encourage broad participation. Every voting member has the opportunity to participate, review proposed standards, vote, and help shape the final result through an open and transparent consensus process. This effort should include tiny houses on wheels, tiny houses on permanent foundations, starter homes, accessory dwelling units, cottages, and other attainable housing options. Working with ASTM would allow DOE to build upon an internationally recognized standards development system while encouraging innovation, affordability, consumer choice, and technical excellence in future building energy policy. ANSI Article: ASTM E3224-19: Building Energy Performance https://blog.ansi.org/ansi/astm-e3224-19-energy-performance/ Thank you for your consideration, Janet Thome President Tiny House Alliance USA