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Board hears concerns that changes to whole‑building pathway may complicate ResCheck/ComCheck compliance

2712220 · February 27, 2025

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Summary

Board members and staff discussed whether changes to R405/C407 will require customized ResCheck/ComCheck tools and whether national labs can produce updates in time for jurisdictions' adoption schedules.

Board members raised concerns that changes to the whole‑building simulated performance pathway (R405 for residential / C407 for commercial references in the draft) could make national compliance tools such as ResCheck and ComCheck incompatible with the draft code unless customized versions are produced.

The issue surfaced during public comment and was discussed at length by board members. Ryan (commenter, ResNet) had flagged that lines added to R405's standard reference design might make ResNet/ResCheck and ComCheck harder to use for compliance. Board member Jess relayed Ryan's concern and asked whether the changes would effectively block use of those tools.

Board staff and technical members said the situation differs by pathway. Elizabeth (board member / technical adviser) explained that ResCheck is used for prescriptive compliance (R401–R404 plus R408) and that R406 (ERI) uses ResNet. R405 is the whole‑building modeling pathway and typically relies on whole‑building modeling tools (eQuest, EnergyPlus) rather than ResNet. Adam (Energy Office staff) said the office plans to work with the national labs (PNNL and NREL) to create customized versions of ResCheck and ComCheck for the new code and to provide supporting resources, noting there is roughly a nine‑month window before jurisdictions are required to adopt the code.

Board members from several jurisdictions urged caution about relying on federal lab timelines. Tim (Broomfield) said his jurisdiction wants to adopt the code quickly after publication and needs enforceable review tools in time; he asked the board to prioritize clarity and availability of tools for local code officials. Kim (staff) said the office will gather more detailed input from commenters (for example, the commenter who raised the issue) and that staff will follow up with PNNL/NREL for a feasibility and timeline check. Ron (Boulder County) suggested the board or staff reach out directly to PNNL for a technical assessment of how large the required modifications would be.

No formal action was taken; the board directed staff to gather more information from commenters and national labs and to report back.