MA Stretch Codes Update
Written By Yve Torrie, Director of Climate, Energy & Resilience
In July and August 2022, A Better City received robust comments from members about the proposed update to the Massachusetts Stretch Energy Code and the development of the Municipal Opt-In Specialized Stretch Energy Code, released on June 24th. The resulting A Better City comments were sent to DOER by August 12th and posted on A Better City’s blog in September.
DOER set up a technical advisory committee who met throughout the summer of 2022 to review all the comments received in August, along with technical code language. Based on the committee’s technical review and comments, DOER released final code language for the Stretch Energy Code and Specialized Municipal Opt-in Code on September 23rd as follows:
On November 2nd, DOER held a webinar to provide an overview of the updates to the Stretch Energy Code and New Specialized Opt-in Stretch Energy code. Slides and a webinar recording were provided.
A Better City then compared ABC’s comments to DOER’s final code changes to understand the impact of our comments. We were heartened to see that the thoughtful and detailed comments from members resulted in some significant changes. Our comment letter has been updated so that each comment is now followed by a statement in red showing which comments resulted in changes and which did not. Here are the high-level takeaways:
- An Exception on Space Heating Electrification (C401.4): Highly Ventilated Buildings (SectionC407.2.1), such as hospitals and labs that have highly glazed envelopes, are only required to partially electrify. This exception was added so that these buildings can comply by meeting 25% of their peak heating demand with electric heating systems like heat pumps. The committee also added a provision to allow heat to be extracted from exhaust flows throughout section C401.4.
- A Change to Air Leakage Compliance. (C402.5.2): Specific leakage testing methods in commercial buildings were removed. New construction must test for air leakage according to ASTM E1186 (or ASTM E779, ANSI/RESNET/ICC 380, ASTM E1827), but they allow for more flexibility and expert judgement. The blower door testing is still required as part of the optional PHIUS documentation and certification.
- A Change to Minimize Reheat (C403.7.1): This whole section was removed, so there is no limit on ventilation rates. The previous version had limited it to 135% of ASHRAE 62.1 recommendations, so this is a big win for healthy indoor air. The committee also added an exception in 402.5.10 (HVAC system interlocks) for operable openings included in designed natural ventilation systems.
- There was no substantive change to Thermal energy demand intensity (TEDI) limits (C407.1.1.52.3): A medium sized bucket was added to the EUI limits but the magnitude and range of the EUIs stayed the same.
- There was no Mention of Grid Reliability, Capacity, Resiliency, and Affordability. The code makes no mention of the electrical grid or reliability. Although this was expected, a long-term study and plan should be put in place for all-electric building loads. NYC’s Local Law 154 (all-electric buildings law) included a requirement for such a study to be conducted: Grid Ready: Powering NYC's All-Electric Buildings.
DOER’s Final Regulations, 225 CMR 22.00 and 225 CMR 23.00, were submitted to the Joint Committee on Telecommunications, Utilities, and Energy (TUE Committee) at the end of September 2022, allowing the required 3 months for their passage through the TUE Committee. These regulations will be filed with the Secretary of State in December 2022. The updated codes will become effective at different times:
- Updated Residential Stretch Energy Code in January 2023
- Updated Commercial Stretch Energy Code in July 2023
- The Specialized Opt-in Stretch Energy Code will need to be adopted by cities and towns (usually a 6-month process). DOER is recommending a 6-month adoption allowance once approved. The Specialized Opt-in Stretch Energy Code is therefore not expected to become effective before January 2024. DOER has also suggested a January 1 or July 1 effective date.
For any comments or questions, please contact Yve Torrie.