August 4, 2025 — Comments

As HUD and USDA review their recently published Final Determination from April 25, 2024, adopting the 2021 IECC and ASHRAE 90.1-2019 energy codes as minimum requirements for programs covered under the Energy Independence and Security Act of 2007 (EISA), we write to express support for the Determination and to urge the agencies to retain this important set of standards.

The Final Determination, which found that adoption of the energy codes would have no negative impact on the affordability and availability of EISA-covered housing, paves the way for essential improvements to new building construction that will make housing more affordable for low- and moderate-income homeowners and renters by lowering utility bills while generally covering the costs of the improved standards overall. It also would provide more resilient new housing to address shelter needs in the face of increasing natural disasters. We note that the agencies also found that several alternative compliance paths, including the 2024 IECC, ENERGY STAR, and various green building standards, ensure at least as much energy savings as the codes and can be used instead.

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