P.O. Box 1286 Lawrence, KS. 66044

Ph. 785-841-3900 Fax 785-841-0749

March 12, 2005

Dear Commissioner,

I would like to bring to your attention some information which may help you in the discussion of the Chapter 11 of the 2003 IRC concerning energy efficiency. In section N1101.2.1 we are given two ways to comply with the Code. The first is a prescriptive method using the guidelines prescribed in this chapter based on a maximum glazing area of 15%. The second is to meet the requirements of the International Energy Conservation Code (IECC) for detached one- and two-family dwellings. The U.S. Department of Energy (DOE) has developed free software which is available for downloading called “RESCHECK” (www.energycodes.gov/rescheck/) which is specially designed to help homebuilders and code officials ensure that residential building design and construction meets the standards set forth in the IECC without requiring them to use the prescriptive methods set forth in Chapter 11 of the IRC. DOE recognizes that prescriptive code requirements can be restrictive and cost inefficient because it is based on the 15% glazing maximum. The vast majority of residential housing is constructed with far less exterior glazing so DOE designed this interactive energy engineering software to take into consideration the specific elements of the building construction relative to its location and climatic conditions. It allows the building designer to change specific elements of the construction until the building becomes compliant. This helps the individual builder to make his own decisions as to how the building may be constructed in the most cost efficient manner and still be compliant with the IECC.

I have used the Rescheck program for several years, and am currently using the program to evaluate buildings I am constructing in Gardner, KS. which also operates under the 2003 IRC. I used Rescheck to evaluate two different models I currently have under construction in Lawrence. One is one side of a two-family unit slab on grade (the Elliott) and the other is a single family unit (the Boulder) with a partially finished daylight basement. I also evaluated the same single family unit with a full unfinished and uninsulated basement. I have attached PDF files of the Rescheck analysis for each individual model for you to examine. I have also attached a spreadsheet with a Rescheck Compliance overview to help show how the program works with specific input changes that reflect actual construction practices along with some inexpensive options for achieving compliance if typical construction methods are inadequate. I then calculated the costs of constructing the same buildings using the prescriptive methods outlined in the IRC and have attached a spreadsheet depicting those resulting costs.

As a result of this analysis I support adopting Chapter 11 of the 2003 IRC as written since it clearly allows for flexibility in design and cost of compliance through the use of the Rescheck software. However I would like to strongly encourage that the Commission states specifically in the adopting ordinance that the use of DOE’s Rescheck analysis and compliance verification is acceptable to demonstrate compliance to Chapter 11, Section N1101.2.1 (2.) of the 2003 International Residential Code. Hopefully this allows those unfamiliar with the software will be given a direction to look for more information. If you have any questions, please feel free to contact me by phone or email. Thank you for your consideration.

Sincerely, Ron Durflinger