The National Energy & Fuels Institute (NEFI) filed formal comments with the U.S. Department of Energy (DOE) this week on how the government calculates whether building energy codes are worth their additional costs to consumers.

Most states and localities base their building energy requirements on a model code called the IECC, which stands for the "International Energy Conservation Code." Inside that code is a point system. A new or renovated home must earn a certain number of points, and each piece of equipment is worth a set amount. Install this, earn eight points. Install that, earn one.

DOE pays for the analysis that sets those point values. A calculation done in a back office in Washington or a federal laboratory can end up deciding which equipment is practical to put in a home, whether in Presque Isle, Maine, or Hanover, Pennsylvania.

NEFI believes that those calculations are wrong, and they hurt our members and their customers. According to our reading, a boiler that improves efficiency by almost five percent earns one point, while a furnace improving 14 percent earns eight. The math does not line up, and nobody outside the process gets to check it. When DOE sets a federal appliance standard, it publishes the analysis and takes public comment. It does not do that for the analysis it hands to the IECC’s code committees.

Why does this matter to your business? These credits shape what builders spec, what utilities rebate, and eventually what your customers ask you for. If high-efficiency boilers and hydronic systems keep scoring poorly on a flawed formula, it shows up in your sales.

What we told DOE:

• Ask contractors what jobs actually cost. DOE works from catalog and wholesale prices. You quote real jobs, with parts, labor, venting, electrical, and whatever else the existing system or home throws at you.
• Count the whole job. Most boilers make domestic hot water too. Rating them on heating alone hides about a quarter of the savings a customer actually earns.
• Use real heat pump performance, not the sticker. DOE’s own laboratory measured cold-climate units performing well below their ratings once auxiliary heat and defrost are counted.
• Count the electrical work. Panel and service upgrades are real money to the homeowner and appear nowhere in the analysis.
• Count the fact that equipment wears out. A heat pump gets replaced two or three times over the thirty years a good boiler lasts.
• Stop assuming tax credits that no longer exist. Two federal credits your customers relied on ended December 31, 2025: the 25C credit for high-efficiency heating and cooling equipment and the 25D credit for residential solar.

Some good news: Under the current administration, the Department of Energy is already moving in this direction. In June it found the 2024 IECC would add as much as $14,000 to the price of a new home, and it asked the International Code Council, which writes the IECC, to refocus code development on "affordability, transparency, and fuel-neutral energy efficiency." NEFI’s comments strongly support this and hand the Department the industry data to back that up.

We offered to collect real installed-cost and field-performance data from our membership. If you can share what jobs are costing, or what you see on heat pump service calls, please email NEFI Manager for Government Affairs Liam Dotson at liam.dotson@nefi.com.

DOE is also weighing whether to hold a public workshop on these questions. We have asked the Department to convene it, and if it does, NEFI will be there.

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