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Council trims predictive energy-modeling requirement; requires estimated EUI on construction documents
Summary
After a long debate about modeling burden and enforcement, the Building Code Council removed a broad predictive energy-modeling mandate and instead required that projects include an estimated energy-use-intensity (EUI) or equivalent performance target on construction documents for buildings subject to the clean buildings performance standard.
The Building Code Council voted on March 21 to remove a mandatory, project-level predictive energy-modeling requirement and replace it with a requirement that building permit submissions include an estimated annual energy-use intensity (EUI) or the jurisdiction’s analogous BPS target on construction documents.
Proponents argued the change protects owners and design teams from the cost and timing impacts of large, late-stage predictive models while still improving designer and owner awareness of a building’s expected performance. Opponents had argued that predictive models—particularly under a performance pathway—produce better design outcomes and should be required for larger projects.
The council’s final motion added a path that allows design teams to provide a documented estimated EUI (derived from benchmarking, engineering calculations, or predictive modeling) on the construction documents as an acceptable alternative to the model mandate. The tag debated several options: limiting modeling to large “tier 1” buildings, allowing estimated EUIs as a fourth option, or retaining the predictive model. After deliberations and multiple amendatory motions, the council approved the approach that keeps most of the original proposal’s documentation requirements but permits an estimated EUI on the construction documents in lieu of submitting a full predictive model.
Supporters described the compromise as a “baby step” forward that preserves many of the proposal’s helpful components — improved metering, commissioning, and project manual requirements — without imposing predictive modeling across the board. Critics said the change might reduce the design-stage evaluation of high-value efficiency measures.
The council approved the motion to substitute the estimated EUI requirement for the predictive model and to strike a proposed separate “energy performance report” requirement; the recorded vote carried 9–3 with two abstentions.
