Notice of Public Hearing
The Construction Industries Commission will convene a public hearing for the repeal and replacement of 14.7.6 NMAC – 2018 New Mexico Residential Energy Conservation Code and 14.7.9 NMAC – 2018 New Mexico Commercial Energy Conservation Code. The hearing will be held before a hearing officer, at which time any interested person is invited to submit data, views, or arguments on the proposed changes, either orally or in writing, and to examine witnesses testifying at the hearing. The hearing is scheduled for Wednesday, January 3, 2024.
The purpose of this public rule hearing is to receive public comments regarding the repeal the 2018 New Mexico Energy Conservation Codes and replaced with the 2021 Energy Conservation Codes. The Energy Conservation Codes establish minimum standards for energy conservation for residential and commercial construction in New Mexico.
The statutory authority for this rulemaking is found in the New Mexico Construction Industries Licensing Act, Subsections F and K of Section 60-13-9 and Section 60-13-44 NMSA 1978.
The hearing is scheduled as follows:
An in-person hearing shall be held on Wednesday, January 3, 2024, at the Regulation and Licensing Department, 5500 San Antonio Drive NE, Albuquerque, NM, Sandia Conference room, starting at 9:30 a.m. The hearing will remain open until 10:00 a.m. or until participants have an opportunity to make public comments, whichever is longer.
Interested persons may obtain copies of the proposed rule changes by logging onto the Construction Industries Division website (www.rld.nm.gov/construction-industries) to download the proposed rules or by written request to the Albuquerque CID Office – Regulation and Licensing Department, 5500 San Antonio Drive NE, Suite F, Albuquerque, NM 87109, attention: Quindi Otero-Robertson.
You may send written comments to: Construction Industries Division, – Regulation and Licensing Department, 5500 San Antonio Drive NE, Suite F, Albuquerque, NM 87109, Attention: Public Comments. Written comments may also be faxed to (505) 765-5670 or submitted to Quindi Otero-Robertson at her email address: Quindi.Otero@rld.nm.gov.
All written comments must be received no later than 5:00 p.m., on Tuesday, January 2, 2024. You may also review submitted comments by requesting copies from Quindi Otero-Robertson at her email address above. Public comments will be posted on the division’s website (www.rld.nm.gov/construction-industries). Written comments may also be received by the Commission at the in-person hearing until the hearing is closed. All public comments received shall be admitted into the record during the public hearing.
If you require special accommodation to attend the hearing, please notify CID by phone, email, or fax, of such needs as soon as possible to ensure adequate accommodation. Telephone: (505) 546-2195. Email: Quindi.Otero@rld.nm.gov; Fax No. (505) 765-5670.
Dear Construction Industries Division,
EV at all buildings is a great idea for our future. I see cars using the existing ones all the time-at shopping centers, by restaurants and even at the golf course. Help people help the environment by making charging easier. Thanks in advance for helping save our planet.
I am writing to express my strong support for New Mexico?s adoption of the 2021 Energy Conservation Codes for buildings along with EV-ready requirements.
In addition to keeping up with the latest code updates to improve the energy efficiency of buildings, I support the additional proposal to require all new buildings be EV-ready, making it easier for homeowners, residents of multifamily units and users of commercial parking lots to charge their electric vehicles.
The codes call for most new construction to include EV chargers at 5% of parking spaces, and another 5 to 15%, depending on the building type, must have the electrical infrastructure to accommodate future chargers.
Modern energy codes are critical for creating a safe climate and energy savings through weatherization and more efficient heating and cooling equipment. Considering the passage of Clean Cars and Trucks standards and the commercial shift to EVs announced by major automakers, these are common-sense, forward-thinking steps.
I care deeply about the climate crisis and my children?s future. Stronger energy codes reduce climate pollution and other air pollutants, improving our families? health, all while lowering utility bills, so I have more money to contribute to our local economy.
Sincerely,
Sally Hebert
305 Carlisle Blvd NE
Albuquerque, NM 87106
shebert@unm.edu
(505) 514-9786
Dear Construction Industries Division,
I am writing to express my strong support for New Mexico?s adoption of the 2021 Energy Conservation Codes for buildings along with EV-ready requirements.
In addition to keeping up with the latest code updates to improve the energy efficiency of buildings, I support the additional proposal to require all new buildings be EV-ready, making it easier for homeowners, residents of multifamily units and users of commercial parking lots to charge their electric vehicles.
The codes call for most new construction to include EV chargers at 5% of parking spaces, and another 5 to 15%, depending on the building type, must have the electrical infrastructure to accommodate future chargers.
Modern energy codes are critical for creating a safe climate and energy savings through weatherization and more efficient heating and cooling equipment. Considering the passage of Clean Cars and Trucks standards and the commercial shift to EVs announced by major automakers, these are common-sense, forward-thinking steps.
I care deeply about the climate crisis and my children?s future. Stronger energy codes reduce climate pollution and other air pollutants, improving our families? health, all while lowering utility bills, so I have more money to contribute to our local economy.
Sincerely,
Paul McDaniel
6409 Katson Ave NE
Albuquerque, NM 87109
pjxcal@yahoo.com
(505) 555-5555
Dear Construction Industries Division,
I am writing to express my strong support for New Mexico?s adoption of the 2021 Energy Conservation Codes for buildings along with EV-ready requirements.
In addition to keeping up with the latest code updates to improve the energy efficiency of buildings, I support the additional proposal to require all new buildings be EV-ready, making it easier for homeowners, residents of multifamily units and users of commercial parking lots to charge their electric vehicles.
The codes call for most new construction to include EV chargers at 5% of parking spaces, and another 5 to 15%, depending on the building type, must have the electrical infrastructure to accommodate future chargers.
Modern energy codes are critical for creating a safe climate and energy savings through weatherization and more efficient heating and cooling equipment. Considering the passage of Clean Cars and Trucks standards and the commercial shift to EVs announced by major automakers, these are common-sense, forward-thinking steps.
I care deeply about the climate crisis and my children?s future. Stronger energy codes reduce climate pollution and other air pollutants, improving our families? health, all while lowering utility bills, so I have more money to contribute to our local economy.
Sincerely,
Marcia Kellam
4123 Big Sky Rd
Santa Fe, NM 87507
marciakellam@hotmail.com
(510) 435-0389
Dear Construction Industries Division,
I am writing to express my strong support for New Mexico?s adoption of the 2021 Energy Conservation Codes for buildings along with EV-ready requirements.
In addition to keeping up with the latest code updates to improve the energy efficiency of buildings, I support the additional proposal to require all new buildings be EV-ready, making it easier for homeowners, residents of multifamily units and users of commercial parking lots to charge their electric vehicles.
The codes call for most new construction to include EV chargers at 5% of parking spaces, and another 5 to 15%, depending on the building type, must have the electrical infrastructure to accommodate future chargers.
Modern energy codes are critical for creating a safe climate and energy savings through weatherization and more efficient heating and cooling equipment. Considering the passage of Clean Cars and Trucks standards and the commercial shift to EVs announced by major automakers, these are common-sense, forward-thinking steps.
I care deeply about the climate crisis and my children?s future. Stronger energy codes reduce climate pollution and other air pollutants, improving our families? health, all while lowering utility bills, so I have more money to contribute to our local economy.
Sincerely,
Robert Wells
2601 N Kentucky Ave Apt 27
Roswell, NM 88201
roberttwells@yahoo.com
(575) 914-1322
Dear Construction Industries Division,
We are a small state and (because of Biden’s IRA) will have resources to support these improvements with our small population. Let’s join other countries worldwide and lead our own nation in developing these future-saving building codes.
I am writing to express my strong support for New Mexico?s adoption of the 2021 Energy Conservation Codes for buildings along with EV-ready requirements.
In addition to keeping up with the latest code updates to improve the energy efficiency of buildings, I support the additional proposal to require all new buildings be EV-ready, making it easier for homeowners, residents of multifamily units and users of commercial parking lots to charge their electric vehicles.
The codes call for most new construction to include EV chargers at 5% of parking spaces, and another 5 to 15%, depending on the building type, must have the electrical infrastructure to accommodate future chargers.
Modern energy codes are critical for creating a safe climate and energy savings through weatherization and more efficient heating and cooling equipment. Considering the passage of Clean Cars and Trucks standards and the commercial shift to EVs announced by major automakers, these are common-sense, forward-thinking steps.
I care deeply about the climate crisis and my children?s future. Stronger energy codes reduce climate pollution and other air pollutants, improving our families? health, all while lowering utility bills, so I have more money to contribute to our local economy.
Sincerely,
Jody Benson
3547 Pueblo Dr
Los Alamos, NM 87544
anteaterjb@gmail.com
(505) 662-4782
This message was sent by KnowWho, as a service provider, on behalf of an individual associated with Sierra Club Rio Grande Chapter. If you need more information, please contact Camilla Feibelman at Sierra Club Rio Grande Chapter at riogrande.chapter@sierraclub.org or (505) 243-7767.
Dear Construction Industries Division,
I am writing to express my strong support for New Mexico?s adoption of the 2021 Energy Conservation Codes for buildings along with EV-ready requirements.
In addition to keeping up with the latest code updates to improve the energy efficiency of buildings, I support the additional proposal to require all new buildings be EV-ready, making it easier for homeowners, residents of multifamily units and users of commercial parking lots to charge their electric vehicles.
The codes call for most new construction to include EV chargers at 5% of parking spaces, and another 5 to 15%, depending on the building type, must have the electrical infrastructure to accommodate future chargers.
Modern energy codes are critical for creating a safe climate and energy savings through weatherization and more efficient heating and cooling equipment. Considering the passage of Clean Cars and Trucks standards and the commercial shift to EVs announced by major automakers, these are common-sense, forward-thinking steps.
I care deeply about the climate crisis and my children?s future. Stronger energy codes reduce climate pollution and other air pollutants, improving our families? health, all while lowering utility bills, so I have more money to contribute to our local economy.
Sincerely,
Sarah Hayes
801 7th St Apt 8
Los Alamos, NM 87544
diru.drwho.momusu@gmail.com
(314) 856-3646
This message was sent by KnowWho, as a service provider, on behalf of an individual associated with Sierra Club Rio Grande Chapter. If you need more information, please contact Camilla Feibelman at Sierra Club Rio Grande Chapter at riogrande.chapter@sierraclub.org or (505) 243-7767.
Dear Construction Industries Division,
I am writing to express my strong support for New Mexico?s adoption of the 2021 Energy Conservation Codes for buildings along with EV-ready requirements.
In addition to keeping up with the latest code updates to improve the energy efficiency of buildings, I support the additional proposal to require all new buildings be EV-ready, making it easier for homeowners, residents of multifamily units and users of commercial parking lots to charge their electric vehicles.
The codes call for most new construction to include EV chargers at 5% of parking spaces, and another 5 to 15%, depending on the building type, must have the electrical infrastructure to accommodate future chargers.
Modern energy codes are critical for creating a safe climate and energy savings through weatherization and more efficient heating and cooling equipment. Considering the passage of Clean Cars and Trucks standards and the commercial shift to EVs announced by major automakers, these are common-sense, forward-thinking steps.
I care deeply about the climate crisis and my children?s future. Stronger energy codes reduce climate pollution and other air pollutants, improving our families? health, all while lowering utility bills, so I have more money to contribute to our local economy.
Sincerely,
Simran Khalsa
2 Lumbre Del Sol
Espanola, NM 87532
simranmati@gmail.com
(310) 980-0746
This message was sent by KnowWho, as a service provider, on behalf of an individual associated with Sierra Club Rio Grande Chapter. If you need more information, please contact Camilla Feibelman at Sierra Club Rio Grande Chapter at riogrande.chapter@sierraclub.org or (505) 243-7767.
Thank you, Commissioners.
Letter re Construction Industries Commission and New Energy Conservation Codes
My name is Michael Sweringen. I have been teaching about global heating and climate change for fifteen years.
My students have given over 35 presentations to thousands of other students, teachers, parents and churches about climate change and energy efficiency.
I have been certified in passive house construction principles for tradespeople and have taken the passive house consultant course with architects and home and building designers (note: “passive house construction” is not the same as “passive solar” construction).
Of course, I am FOR adopting more rigorous construction requirements, including those which require all new homes be EV-ready.
However, I think we are getting lost in HALF MEASURES when we need to take FULL MEASURES.
I live in Northwest Albuquerque and there is a construction boom going all around us. I can see “build ’em fast, build ’em cheap” homes with their OSB enclosures and weak insulation and air tightness standards.
But we need to build homes for the future climate changes coming our way. We have only to look west towards Phoenix and their 31 straight days of 110° temperatures. That heat is coming to Albuquerque in the next couple decades.
We can build homes that can handle this kind of heat. Homes that can last hundreds of years. Tested by physicists and builders. Thousands of homes have been built this way all over the world. They work.
And here’s the kicker: for about the same cost, these passive house buildings use about 10% of the energy to run. Instead of a $200 heating bill in January or a $200 air conditioning bill in August, a passive house building would cost $20 in January or $20 in August.
We need ALL HOMES AND BUILDINGS in New Mexico built to this very demanding – and very rewarding – building standard. Entire cities in Europe mandate this kind of building. If they can do it, we can do it.
Here are some of the principles of the passive house building standard:
1 Super insulation. Keeps the heat in during winter. And the cool in during summer.
2 Air tightness (which is physically tested to meet the standard)
3 Triple paned windows to prevent heat loss and heat gain
4 No thermal bridges (even the building foundation is insulated)
5 Ventilation and air filtering 24/7
Because homes built to the passive house standard are so efficient, they can run fully on solar panels. Especially in our beautiful, sunny climate.
These homes are quiet, comfortable in all seasons, healthy with continuous fresh filtered air, and durable. Let’s embrace this FULL MEASURE.
Michael Sweringen
Albuquerque, New Mexico
To: Hearing officer for the Construction Industries Commission
Subject: Repeal and replacement of 14.7.6 NMAC – 2018 NM Residential Energy Conservation Code and 14.7.9 NMAC – 2018 NM Commercial Energy Conservation Code.
Dear Hearing Officer, my name is Tom Solomon, co-coordinator of 350 New Mexico, speaking on behalf of our 6000 supporters who are focused on solving the climate crisis. I’ve driven an electric vehicle for 11 years and fully support EV’s and including EV infrastructure requirements in the energy code.
I know from personal experience that EV’s are vastly better than gas vehicles. They are cleaner, cheaper to operate & maintain and they eliminate tailpipe emissions- a top source of climate warming pollution. These are some reasons why US EV sales have been growing exponentially according to Argonne labs, up 30% in the last year through Nov 2023, with plug-ins now 11% of all US car sales.
And now that New Mexico is signed onto the Advanced Clean Cars II rule, EV adoption will continue to grow. According to the NM Mortgage Finance Authority about 65% of New Mexicans own their residence, where they can easily charge an EV at home. But we owe it to the other 35% of New Mexicans who rent, to make it just as easy to charge, using the charging infrastructure where they park for work, for errands or at their rental units. That’s why I support these code updates, which encourage building this charging infrastructure.
Building out EV chargers and EV-ready spaces makes the most sense during construction because it is vastly cheaper and easier then, versus the added expense and disruption of retrofitting existing parking, with all the demolition that entails.
I also note that NM electric utilities will pay to reimburse the construction costs for installing EV charging in many cases, as required by their transportation electrification programs. For example, this PNM site EV.PNM.com lists construction rebates of $2500 per charge port for multi-family dwellings, workplaces and more.
The US is moving rapidly to electric transportation. Renters will soon include EV charging capability on their list of required features when looking for an apartment. Building this capacity now is part of New Mexico being a leader and preparing for the future. And with our electric utilities offering rebates to cover the cost of construction, any objections from builders really don’t hold water.
For all these reasons, I fully support the proposed code changes and urge you to adopt them.
Thank you,
Tom Solomon, coordinator 350 New Mexico
505 328 0619
PNM’s goal is to support its customers and deliver safe, reliable, affordable, and environmentally responsible power. Regarding the proposed 2021 New Mexico Energy Conservation Code, specifically considering the preparation of residential and commercial properties for electric vehicle supply equipment (EVSE), PNM can and will support the additional load from the electrification of transportation. Planning for the transition to an electrified transportation sector while also undergoing the broader energy transition requires customer participation in programs such as the Transportation Electrification Program as well as the ability to invest in Grid Modernization. As of today, PNM has achieved 60% carbon free generation on our way to a 100% true carbon free grid by 2040. Electrifying transportation will greatly reduce carbon emissions from one of the largest emitters in State. PNM is also aware that at the customer level, comprehensive investments such as service panel upgrades and additional wiring installation may be necessary to enable widespread electrification.
The U.S. Joint Office of Energy and Transportation issued a report (attached to this comment) in April 2023 that estimates the costs of Level 2 EVSE can cost up to $2,900 for residential applications and up to $10,600 for commercial applications. While these estimates do not encompass every possible use case, it should be noted that installation costs are typically significantly lower for new construction rather than waiting for a retrofit at a later date. PNM is currently implementing a Transportation Electrification Program to encourage EV adoption and provide funding for infrastructure, customer education, and specific rates to help manage load and understand customer behavior. Today, residential customers can benefit from $500 towards a Level 2 charger, and low-income customers can receive an additional $2,000 for installation costs. Commercial customers can receive up to $2,500 per charging port for installation costs, and multifamily housing in underserved communities qualify for $5,000 per port. To address future costs concerns, PNM has proposed increased incentive funding in its 2024-2026 Transportation Electrification Plan, which includes up to $5,000 per Level 2 charging port for most commercial applications, and up to $10,000 per port for multifamily housing in underserved communities. Further, most Level 2 charging stations are dual-port, so for example a dual-port charger in an underserved community multifamily housing unit could qualify for $20,000 in incentive funds. PNM is committed to an equitable transition to an electrified transportation future. This requires that charging infrastructure be widely available to all New Mexicans, and the PNM Transportation Electrification Program is designed to remove barriers and enable PNM customers to charge forward.
Alaric J. Babej
Principal, Customer Energy Solutions
PNM
414 Silver Ave SW
Albuquerque, NM 87102
Alaric.babej@pnm.com
USDOT_EV Charging Report_April 2023
Please see the attached comments of the Responsible Energy Codes Alliance in support of the adoption of the 2021 IECC as the New Mexico Energy Conservation Code. If you have any questions, please do not hesitate to call or email me.
Thank you,
Eric
Eric Lacey, Chairman
Responsible Energy Codes Alliance
1850 M Street, NW, Suite 610
Washington, DC 20036
(202) 339-6366 office
(703) 409-0681 cell
(202) 342-0807 fax
http://www.reca-codes.com
eric@reca-codes.com
RECA Comments Supporting 2021 IECC in NM 12-28-23
To the Construction Industries Division/Commission:
As a former specialist in commuter/transportation projects for environmental programs at the national laboratory, I can assure you that federal support (and oversight of federal contractors) for electric vehicle infrastructure has been lagging behind at negligent levels. At the national laboratory level, coordination with City of ABQ initiatives, e.g., upgrades to routes and the transit system in growing sustainable commuter practices, have long been undersupported.
As a homeowner who had to have the antique solar water-heating system dismantled at my house, I have always had a dream of an integrated charging system. Unfortunately, when I had the income, the Tesla home system was unavailable, in part due to their inability to support the demand. I also had a terrible experience with Solar City declining to install a new system, determining that the 6×8 beams in my roof could not support a modern system. Now, forced into early retirement, I can’t afford to make the necessary ‘routine maintenance’ electrical upgrades to my home. In other words, the 60+-year-old electrical system of my home is failing. A debt-free home with prime orientation for maximum solar efficiency, yet that dream is dead. No, I’m not putting up a system to rent on my roof.
I needed to buy a vehicle in 2022, which I’m projecting will be my last car purchase. It’s a hybrid, because, again, the EV charging infrastructure, locally and nationwide, just has not kept pace with the accelerating onset of the needed changes.
I’d also like to mention that, only 6 years ago, when I had the income, I even tried to purchase a fixer-upper, back before housing and rental prices became insanely inflated and criminally inaccessible in our city. I’d like to give a shout-out to single moms working to house their families, college students making unimaginable tradeoffs to finish school, and the archaic, patriarchal stringency and greed of mortgage lenders and rental agencies. Once a fundamental factor in choosing to live in ABQ, affordable housing may never again be a reality.
So, when we’re talking about new construction standards, crucial transportation upgrades (locally and nationwide), the necessary 21st-Century response to the Climate Emergency, and these codes that have been gathering dust in limbo since 2021, I have some perspective and personal experience on these matters. If the construction industry does not support the adoption of the 2021 Energy Conservation Codes, that is a reflection of obsolete mindset, and will not serve to generate sustainable solutions on the commensurate scale.
I beseech and demand that the 2021 Energy Conservation codes that include EV chargers for new buildings become the standard in Albuquerque, and in New Mexico. For generations, petroleum exploitation has been our state legacy. We’re passed due in committing decisively to the energy needs of this century.
Sincerely,
Brenda Bailey-White
1412 Martha St NE 87112
Attention Ms. Otero-Robertson:
My name is Susan Gorman, residing at 2222 Uptown Loop NE Apt 5207, Albuquerque, NM 87110. Phone 602-386-7112
Today, I am submitting the following comments on the Repeal of the 2018 New Mexico Residential Energy Conservation Code and the 2018 New Mexico Commercial Energy Conservation Code and replaced with the 2021 New Mexico Residential Energy Conservation Code and the 2021 New Mexico Commercial Energy Code.
I wish to support the repeal of the existing codes and adoption of the revised codes.
In November, the Environmental Improvement Board and the Albuquerque-Bernalillo County Air Quality Board approved the Clean Cars and Clean Trucks Rules. These rules will ensure that a larger share of new cars and trucks for sale in New Mexico will be Electric Vehicles over time. As a greater proportion of vehicles will be EVs, it’s essential that the charging infrastructure should grow as well.
These code revisions will require that new apartment complexes and commercial buildings will have charging points. As an apartment dweller, I support this. I believe that as new apartments come on the market, existing apartments and commercial buildings will install charging points as well.
This ensures that the electrification of our infrastructure will increase, thus reducing New Mexico’s total carbon emissions and impacts on the climate. Overall air quality will improve, too.
I urge you to move forward with Repeal of the 2018 codes and Adoption of the revised codes.
Thank you for consideration of these comments.
Sincerely,
Susan Gorman
As the owner of one EV at the moment I support the inclusion of EV infrastructure requirements in the energy code. I know how important it is to have a 240V outlet available at home to charge. I had to have one installed as my original structure didn’t have one. When I built a new garage it was so much easier to plan and cheaper to install one for charging there. All new structures should plan ahead for the growing transition when all cars will be electric. Just as all houses should be prepared to charge vehicles, I also think all houses should be designed to include and have a minimum number of solar panels. This creates jobs and saves owners money at the same time. Because I installed solar panels on my roof 17 years ago, my last electric bill was $27 in some of the shortest days of the year after running my heat pumps and charging my car. The only maintenance on my EV after 48,000 miles has been new tires 2,000 miles ago. Since I’m on a fixed income this allows me to use my limited money on other important things. I think many people are hesitant to own an EV because they are concerned about charging. Give them the infrastructure and they will make that move much easier. I’m hoping to get a second EV and then the only problem I will have is having only one outlet for charging.
I look forward to the day when whereever I travel some distance from home onto rural areas I will be able to park at a store or restaurant or business and be able to charge enough to get home or the next destination without having to stick to interstates where chargers are mainly located now.
I support the new residential energy code because for conservation of energy to work, it needs to be encoded in policy. Also as a retiree on a fixed income as well as a renter, newer codes would help ensure that my living space is healthier and more affordable.
Attached as a pdf, please find public comments from New Mexico Voices for Children on the coming hearing on 2021 Energy Conservation Codes.
Thank you so much for your attention to this matter,
Sharon Kayne
Communications Director
New Mexico Voices for Children
625 Silver Ave. SE, Suite 195
Albuquerque, NM 87102
505-401-8709
skayne@nmvoices.org
CID energy conservation codes-1-3-24
To Whom It May Concern:
I write in opposition to the plan to mandate EV charging stations or “EV capable” charging stations in various types of commercial construction. At a price tag of $18,000 per charging unit and nearly $2,000 per “EV capable” parking space, this regulation will inevitably lead to increased costs for all kinds of commercial development. The decision of whether to include EV charging stations in developments should be one made by developers themselves and based on market conditions such as the demand for such units among their potential customers.
I’m particularly concerned about driving costs up for apartment buildings. Apartments are typically resided in by those with lower than average incomes. Conditions are particularly problematic right now thanks to an extremely tight housing market which is present in Albuquerque and other New Mexico cities.
I urge the CID to oppose this harmful regulation.
Sincerely,
Melanie Hunter
Sent from my iPhone
Hello,
I write in opposition to the plan to mandate EV charging stations or “EV capable” charging stations in various types of commercial construction. At a price tag of $18,000 per charging unit and nearly $2,000 per “EV capable” parking space, this regulation will inevitably lead to increased costs for all kinds of commercial development. The decision of whether to include EV charging stations in developments should be one made by developers themselves and based on market conditions such as the demand for such units among their potential customers.
I’m particularly concerned about driving costs up for apartment buildings. Apartments are typically resided in by those with lower than average incomes. Conditions are particularly problematic right now thanks to an extremely tight housing market which is present in Albuquerque and other New Mexico cities.
I urge the CID to oppose this harmful regulation.
—
Paul J. Gessing
President
Rio Grande Foundation
P.O. Box 40336
Albuquerque, N.M., 87196
http://www.riograndefoundation.org
Attached please find a letter from the International Code Commission (ICC) in support the adoption of the 2021 Energy Conservation Codes. Thank you for your attention to this submission for the record and please do not hesitate to let me know if you have any questions.
Regards,
Rick
Rick Bluntzer
Regional Manager, Government Relations
International Code Council
rbluntzer@iccsafe.org
ICC Comments_NM Energy Code Adoption_12.2023
I am writing to register my opposition to the downrating of roof insulation as proposed in the Residential Energy Efficiency Standards Table 402.1.3(b) from R60 down to R49. And for eliminating any real ability to test air leakage as proposed in Section R402.4.1.4 Visual Inspection Option. I make these protests as an Architect and builder, having recently completed construction for my house and 2 rentals whose R-values exceed R60 roof and R30 walls and documented 0.5 air-changes per hour thru a blower door test. While. I can attest that the incremental cost is negligible when compared to the long-term energy savings and the increase in daily thermal comfort.
I will not be able to attend the Public Hearing on Jan 3, 2024. Please register this protest accordingly.
Thanks!
Joe
Joseph E. Simmons AIA
ARCHITECT
BlueSky Studio
DENVER | SANTA FE
303-601-8956