Building Code Insulation Requirements for Energy Conservation

Two Ohio cities, Wooster and Cuyahoga Falls, have enacted strict insulation requirements for new construction in an effort to conserve energy. Proponents of the new ordinance estimate that the additional costs of construction caused by these insulation requirements will be more than offset by fuel savings in the long run. Meanwhile, fuel consumption will be substantially reduced.

The forerunners of these ordinances were minimum property standards for insulation promulgated in 1971 and 1972 by the Federal Housing Administration in response to CEQ requests that government agencies follow sound energy conservation practices.¹ Residential and commercial space heating and cooling account for approximately 20.4 percent of the nation's total energy consumption.² FHA-financed housing uses only a small fraction of this amount, but FHA nevertheless recognized an obligation to contribute to energy conservation by increasing insulation requirements in new construction which it financed.

The FHA standards for insulation specify the maximum total hourly heat transfer allowable through building walls, ceilings and floors. For a moderate-sized, single story home these standards require roughly three and one-half inches of glass fiber bulk insulation in the ceiling, and up to one and seven eighths inches in the sidewalls.³ In northern regions storm windows are also necessary. The Conservation Foundation estimated that if the 15.4 million living units projected to be built within 1972-1982 (mobile homes excluded) complied with these FHA standards, the amount of energy saved during 1982 would equal 10 percent of the total national fuel consumption in 1972.⁴ Unfortunately, this is a goal unlikely to be met due to the limited application of the FHA standards.

Although the FHA standards are a step in the right direction, there are strong indications that they are set too low. With an average of $900 additional investment per family unit, the efficiency of residential fuel use could be increased by 60-70 percent over efficiency rates achieved by FHA standards.⁵ The marginal utility of the additional investment clearly is great. The requisite capital investment, however, is undoubtedly the reason such insulation practices are not widely followed. This cost factor draws strong opposition from the construction industry, which wants to keep the initial cost of buying a house low to attract purchasers. But in many cases, when the initial capital investment in better insulation is balanced against fuel bill savings over periods as short as five years, it is apparent that insulation much more substantial than called for under FHA standards pays for itself.⁶

The two Ohio ordinances adopt standards for insulation far stricter than FHA's. They require six inches of insulation in ceilings, and three and one half inches of insulation in sidewalls. Although the cost of meeting such insulation standards is considerable, homeowners will save, on average, 55 percent on their fuel bills annually.⁷ At present fuel prices, it would take homeowners about twelve years to recoup their additional investment. However, as fuel prices rise, and fuel shortages continue, the practical benefits that these insulation standards have for individual homeowners will become more apparent. Meanwhile, energy consumption in newly constructed homes will be cut by more than half.

The Buyahoga ordinance applies to all new construction of single family homes, garden and high-rise apartments, townhouses, and other dwelling units. It was characterized as "an emergency measure … immediately necessaryto conserve energy."⁸ As is evidenced by its preamble, the building code amendments were primarily aimed at helping home owners meet impending energy shortages:

WHEREAS, there is an energy crisis, and

WHEREAS, prompt measures must be taken to protect the residents of the City of Cuyahoga Falls from curtailments of heating fuel, and

WHEREAS, proper insulation conserves the consumption of fuels for heating … (this ordinance is enacted).⁹

The Wooster building code insulation requirements are superior to those of Cuyahoga Falls in that they apply to newly constructed commercial and industrial as well as residential structures. The City Council made their application as broad as their need; they apply to all "heated or mechanically cooled" buildings.

The two Ohio ordinances reflect a sound understanding of insulation's potential for conserving energy. They set an example for other municipalities and states of grass-roots initiative to deal with broad environmental problems.

1. Minimum Property Standards for One and Two Living Units, FHA No. 300, Interim Revision 51A, dated April 1971, effective June 1, 1971, and Minimum Property Standards for Multifamily Housing, FHA No. 2600, General Revision No. M-21, dated June 1972, effective June 1972.

2. The Potential For Energy Conservation, Staff Study of the Office of Emergency Preparedness, Oct. 1972, Table D-1.

3. Large, Hidden Waste: Potential for Energy Conservation 19, The Conservation Foundation (May 1973) Table 2.

4. Id. at 16.

5. "Energy: Potential of Conservation," Technology Review 47 (May 1973)

6. Large, supra note 3 at 22.

7. Estimate supplied by Mr. Tom Uhl, Director of Administration, Wooster, Ohio. Although Mr. Uhl preferred to rely on fuel savings estimates derived from studies of the more lenient FHA standards just to be safe, he noted that a Wooster study showed fuel bills were reduced from $172 to $78, i.e. 55 percent.

8. "Amend Building Codes to Save Energy," 4 Rodale's Environmental Action Bulletin 7 (June 2, 1973)

9. Id.