2026-07-29 Comment response to the published Request for information

**Comments on Building Energy Code Affordability and Cost-Effectiveness** **Docket No. EERE-2026-BT-BC-0034** Initial construction costs are a legitimate part of affordability. Material, labor, design, equipment, and financing costs can affect whether a household qualifies for a mortgage, whether a business proceeds, and whether housing can be delivered at a supportable price. Affordability, however, should not be measured only at construction or purchase. A lower initial price may not produce a more affordable building if it results in higher utility bills, maintenance, premature equipment replacement, recurring repairs, or corrective work after occupancy. DOE should evaluate affordability through two complementary measures: total project cost and total cost of ownership. **Total Project Cost** Total project cost should include land and site development, design, materials, equipment, labor, financing, utility coordination, code compliance, permitting and inspection fees, documented delays, and construction errors or rework. DOE should distinguish costs directly attributable to an energy-code requirement from costs caused by other conditions. Land prices, interest rates, labor shortages, insurance, design choices, zoning, utility availability, incomplete documents, applicant revisions, market demand, and contractor performance can all affect final cost. These costs should not be assigned to energy codes without a clear relationship. **Total Cost of Ownership** DOE should also evaluate post-construction costs, including energy expenses, maintenance, equipment replacement, corrective repairs, residual value, energy-price volatility, and resilience or avoided losses supported by credible data. Benefits such as comfort, indoor environmental quality, productivity, and disaster resistance may be difficult to monetize. DOE should address them through transparent assumptions, sensitivity analyses, or separately reported nonmonetary benefits. **Evaluation Periods** No single timeframe represents every consumer. DOE should report initial cost, monthly and first-year cash flow, five-year ownership, twelve-year ownership, and thirty-year ownership or the useful life of the measure. A shorter ownership period should not automatically exclude benefits continuing after sale. Where appropriate, the analysis should consider residual value, remaining equipment life, and whether lower operating costs affect marketability or value. **Regional Analysis** Construction costs and energy performance vary by climate, utility rate, labor market, building type, and construction practice. DOE should provide regional results and disclose assumptions for costs, financing, equipment life, energy-price escalation, and discount rates. **Permitting and Regulatory Costs** Permitting timelines and regulatory costs should be evaluated using documented data. When delays occur, the analysis should identify whether they resulted from municipal review, incomplete applications, design revisions, utilities, zoning, contractor scheduling, financing, materials, outside approvals, or applicant changes. Total project time should not automatically be attributed to permitting or code administration. Local governments should be accountable for reasonable review times, transparent fees, inspection availability, and consistent administration. The costs and benefits of permitting, plan review, and inspections should be evaluated using evidence, including administrative costs and delays and any measurable reduction in errors, corrective work, deficiencies, or costs transferred to owners and occupants. **Recommended Methodology** DOE should present affordability as a range of measurements rather than a single calculation. At a minimum, it should disclose: 1. Incremental initial cost and effect on monthly cash flow. 2. Operating, maintenance, and replacement costs. 3. Results across multiple ownership periods and regions. 4. Sources and age of cost data. 5. Financing, discount-rate, energy-price, and equipment-life assumptions. 6. Costs and benefits that cannot be reliably monetized. 7. Sensitivity analyses showing how results change when assumptions change. Energy-code provisions should not be presumed cost-effective merely because they reduce energy use. Conversely, a requirement should not be considered unaffordable solely because it increases initial cost. Requirements that do not demonstrate reasonable consumer value under transparent and realistic assumptions should be reconsidered. Requirements that increase initial cost but reduce monthly or long-term costs should have those effects presented clearly. A sound methodology should examine the full cost of constructing, financing, owning, operating, maintaining, repairing, and transferring a building. This provides a more complete and impartial assessment of affordability than focusing primarily on initial construction costs.