CLIMATE COUNCIL
​PUBLIC COMMENT PERIOD - DEADLINE TUESDAY, SEPT. 24

There is a public comment period currently underway with the NYS Code Council and we need you to send comments! To make this as easy as possible, NYSBA drafted sample messages for members to send in regarding electrification and fire sprinkler mandates. Feel free to add comments based on your experiences to help bolster the arguments.

To make it easy, we've drafted sample comments that you can copy/paste and send. Please feel free to expand on these comments with any specifics from your business.  

Please send BOTH EMAILS by close of business on Tuesday, Sept. 24.

SAMPLE EMAIL LANGUAGE FOR YOU TO COPY/PASTE:

ENERGY CODE COMMENTS

To: [email protected]​
Subj: State Energy Conservation Construction Code (19 NYCRR Part 1240)​

​Dear Ms. Emma Gonzalez-Laders,

I am writing to express my opposition to the proposed mandates requiring electrification and stricter energy codes. As someone with direct experience in the residential construction industry, I am deeply concerned about the significant cost increases these mandates would impose. New York is in the midst of a severe housing crisis. These regulations will significantly heighten the shortage of available, affordable, and market-rate housing of all types, contradicting the efforts Governor Hochul has championed: to produce more housing, make housing more affordable, and cut red tape and excessive regulations—all to address this pressing issue.

Electrification Mandates: A Financial Strain on Homebuyers

While I support efforts to reduce greenhouse gas emissions, mandating all-electric homes is not a practical or affordable solution for many New Yorkers. In New York State, 72% of households cannot afford the median price of a new home. Even a modest $1,000 increase in the cost of a home would price out thousands of potential buyers. The proposed electrification mandates, which could add between $11,000 and $16,000 to the cost of a home, would make homeownership even more unattainable for families across the state.  This additional cost doesn’t even include the cost of providing sufficient power capacity to the home site.

In addition to the upfront costs, the existing electrical grid may need to be equipped to handle the increased demand from widespread electrification, particularly in regions where such solutions are not cost-effective. New homes built today are already energy efficient, and further mandates would place an unnecessary financial burden on builders, and new homebuyers.

Energy Codes: The Real Opportunity Lies in Existing Homes

The focus on tightening energy codes for new construction overlooks a more impactful solution: upgrading the existing housing stock. Homes built today are far more efficient than those constructed decades ago. According to the National Renewable Energy Laboratory, retrofitting older homes could significantly reduce national energy consumption. Mandating stricter codes for new homes ignores this more effective approach to reducing energy use and emissions.

Conclusion

The proposed mandates for electrification, and stricter energy codes will not achieve the desired outcomes of reducing emissions. Instead, they will drive up the cost of new homes, making homeownership unattainable for many families and worsening the housing crisis in New York State.

I urge the Code Council to reconsider these proposals and focus on more balanced and cost-effective solutions, such as retrofitting older homes, which will have a far greater impact on energy efficiency without burdening new homebuyers.

Thank you for your time and consideration.

FIRE SPRINKLER COMMENTS

To: [email protected]
Subj: State Uniform Fire Prevention and Building Code (19 NYCRR Parts 1219 to 1229)​

​Dear Mr. Kevin Duerr-Clark,

I am writing to express my strong opposition to the proposed mandates requiring automatic fire sprinkler systems in new homes. As someone with direct experience in the residential construction industry, I am deeply concerned about the significant cost increases these mandates would impose, further intensifying New York’s housing supply and affordability crisis.

Fire Sprinkler Mandates: Costly and Unnecessary

The proposal to mandate fire sprinkler systems in new one- and two-family homes is costly and ineffective. Data from 2019 to 2023 shows that fire fatalities overwhelmingly occur in homes built before 2000, with no fatalities in dwellings constructed after that year. This indicates that modern homes already meet safety standards without additional fire sprinkler systems.

The cost of installing fire sprinklers in new homes in New York is much higher than commonly reported, ranging from $8.42 to $10.47 per square foot. This would add $18,000 to $25,000 to the cost of a new home at a time when home prices have already risen dramatically, further limiting affordability for many New Yorkers. The focus should be on ensuring that all homes have working smoke and carbon monoxide detectors, which are proven to save lives, rather than imposing costly and unnecessary sprinkler mandates.

The proposed mandate for fire sprinklers will drive up the cost of new homes, making homeownership unattainable for many families and worsening the housing crisis in New York State. I urge the Code Council to reconsider this proposal.  

Thank you for your time and consideration.