ABSTRACT

Reducing greenhouse gas (GHG) emissions is urgently important for the survival of people on our planet. As energy efficiency advocates who promote more stringent building codes, we feel obligated to pull out all stops to reverse the adverse impacts of anthropogenic climate change as quickly as possible. However, it is not responsible to charge ahead without considering impacts on all people. Low-income communities and communities of color are disproportionately and negatively affected by the impacts of climate change, and a far greater share of their income goes toward energy bills than higher-income earners. It is crucial that codesand standards that aim to stop climate change do so hand-in-hand with, not off the backs of, disadvantaged communities. The authors of this paper have collectively advocated for dozens of unique changes to building codes throughout the United States. This paper examines the current code development process and what is working and what is not through the lens of equity. We recommend a path forward that would put equity as a central consideration for all code change proposals. We explore how to apply best practices and lessons learned in engaging the environmental justice community in public rulemaking processes and approaches to ensure that all people have access to and benefit from higher efficiency and lower emissions buildings.

Introduction

Ensuring that all people have access to high-performance buildings that use energy efficiently and increase occupant health and safety can avoid making occupants choose between maintaining a comfortable environment and paying their utility bills. As we strive to address climate change equitably, it is imperative that input from all impacted communities informs the regulations being proposed. We cannot assume that the needs and concerns of all communities will be met or that decision-makers know what they need. Building long-term relationships with impacted communities, actively soliciting feedback from these stakeholders, and incorporating feedback into proposed code changes is critical to ensuring historically overlooked voices are heard and that measurable progress is made toward effectively serving these communities.

The authors of this paper contribute to the code development process in California through the Statewide Utility Codes and Standards Enhancement Team (Statewide CASE Team). This team recently hosted public meetings to discuss proposed code changes for the 2022 California Energy Code (Title 24, Part 6). Stakeholder meetings held in fall 2019 and spring 2020 were attended by 622 individuals representing 405 organizations. While the public meetings were an effective mechanism to reach many stakeholders, environmental and social justice (ESJ) communities were not well represented. A key motivation for writing this paper is to reflect on current practices, gather information about ESJ communities’ perspectives on building energy codes and the code development process, and identify ways in which we can address a diverse range of ESJ interests and priorities, including those who design, develop and build of affordable housing. Considering ESJ impacts can help emphasize that code decisions have an impact on people and maintain a focus on energy equity for all people. We also anticipate that increased focus on ESJ impacts will lead to an increased emphasis on the fact thatenergy features of a building have non-energy benefits that are often overlooked or deprioritized.

To develop the content included in this paper, the authors completed a literature review and interviewed representatives from organizations that represent ESJ communities and market actors who are engaged in building affordable housing. Published literature is cited throughout, though we have intentionally anonymized feedback received during interviews, with key findings being attributed broadly to interviews as opposed to citing specific conversations with individuals or organizations. Since this outreach is occurring as the Statewide CASE Team is developing code change proposals for the 2022 California Energy Code, we also discussed the proposed code changes for the 2022 code cycle