FCSG Statement on Proposed 2022 Fort Collins Building Codes

Updated on March 8, 2022

The FCSG appreciates City Council’s support for adopting the 2021 ICC code with local amendments on first reading on February 15th.  We believe that two additional amendments would both help Fort Collins residents save money and help our community meet its greenhouse gas pollution reduction goals.  Those amendments are:

  1. Change the requirement that 40% of parking spaces in multifamily developments be EV Capable to 70%. This would result in every parking space having some level of EV capability.
  2. Require homes with gas appliances to be 10% more energy efficient than homes with all electric appliances. This document provides specific code language.

Although City staff has recently revised its cost estimates for EV capable parking spaces upward from $300 to $1,400 – $2,000, we believe that focusing on first costs would be “penny wise, pound foolish.”  In an October 2020 study, Consumer Reports found that the lifetime savings for EVs are $6,000 – $10,000 compared to owning and operating conventional vehicles, due to the lower costs of fuel and maintenance for EVs.  And the percentage savings are much greater for used EVs, which are becoming increasingly available.  Fort Collins should do everything it can to facilitate the purchase of EVs by city residents, both for transportation cost savings and to reduce greenhouse gas and other pollution.

Adopting an “electric preferred” policy by requiring homes with gas appliances to be 10% more energy efficient than homes with all electric appliances would have little to no impact on first costs.  That is because although the cost of electric appliances is greater overall that the cost of gas appliances, there is no need to put in a gas line if all appliances are electric.  The FCSG is still researching details concerning first costs and savings for new all-electric homes, but at this time it appears to us that claims that an electric preferred policy would result in higher home costs is not true.  And the health and climate benefits of not burning gas in homes are clear, as outlined in our original statement below.

We urge city council to incorporate the two amendments spelled out above into the 2022 building code ordinance.  And because the amendments would result in minimal impacts on home prices and rents and significant long-term savings, we do not believe that a “carve out” relaxing these additional requirements for affordable housing would be appropriate.


Original statement posted on February 13, 2022

The Fort Collins Sustainability Group (FCSG) has reviewed the proposed 2022 changes to the Fort Collins building codes. While the FCSG appreciates these efforts to improve the energy performance of its buildings, we believe that the City needs to be more ambitious if it wants to achieve its greenhouse gas emissions reductions goals and ensure safe indoor air. In particular, the FCSG recommends increasing the energy efficiency requirements for buildings even further, doing more to reduce the use of natural gas in buildings, providing more electric vehicle (EV) Capable parking, and requiring post-mitigation testing for radon.

FCSG views the 2021 International Code Council (ICC) codes as a bare minimum requirement for new buildings, and in fact, a Colorado House bill sponsored by Rep. Tracey Bernett would establish these as the baseline energy performance standards for new buildings in Colorado. Therefore, the FCSG strongly believes that Fort Collins should require new buildings to be at least 20% more energy efficient than the 2021 ICC codes specify. Boulder, for example, has such a requirement.

The FCSG would also like to see Fort Collins make a greater effort to reduce natural gas use in buildings. Given the 50+ year lifetime of buildings and the Our Climate Future (OCF) goals to have all new buildings be carbon neutral by 2030 and to have the City be carbon neutral by 2050, it is imperative that the City begin this process as soon as possible to avoid the need for extensive retrofitting of buildings in the future. While the proposed requirement that all new buildings be “Electric Ready” is a significant improvement over the existing building code, moving to “Electric Preferred” buildings would be even more beneficial.

With respect to indoor air quality, the FCSG would like to bring to Council’s attention a recent study by scientists at Stanford University. These researchers found that gas stoves emit significant amounts of methane (75% of which is emitted when the stove is off) and NOx, which can exceed the EPA’s outdoor standard for NO2 within a few minutes of use in a poorly ventilated kitchen. Since building envelopes are getting tighter and one quarter of all households in Fort Collins have at least one resident with respiratory issues, indoor air quality is a major health concern here. Therefore, the FCSG suggests imposing more restrictive energy efficiency standards or additional fees on the construction of buildings that use natural gas to encourage more extensive electrification of new buildings. This should include updating the Utilities Charter to require 200 amp service for all new buildings to facilitate full electrification now or in the future.

The FCSG is also concerned that the parking requirements for electric vehicles in multifamily and commercial buildings are insufficient. The percentages of parking spaces that are EVSE-Installed and EV Ready are acceptable, but given the large difference in cost for initial installation of conduit vs. later retrofitting, it seems most cost effective to require that all remaining parking spaces in these lots be EV Capable. The FCSG understands that affordable housing developers may object to such requirements because many of their residents do not own cars, but that argues for reduced parking for multifamily affordable housing, not reduced EV readiness.

Finally, the FCSG supports the radon testing and mitigation requirements in the proposed building codes but would also like to see post-mitigation testing for radon. This will ensure that either the initial mitigation measures are effective, or it will show the need for further mitigation to reduce the radon level below 4 pCi/l.

In summary, the FCSG would like to see Fort Collins adopt building codes that move the City further toward the achievement of its greenhouse gas emission reduction goals and indoor environmental quality than the current proposal. These building code enhancements will likely require additional funding for compliance checks, so the FCSG urges City Council to support a budget offer that addresses these compliance needs as well.



Author: Kevin Cross

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