Kansas Commercial Energy Code: Navigating IECC, ASHRAE 90.1 & COMcheck Submittals

For new commercial building permits in Lawrence, Kansas, design professionals must demonstrate compliance with the 2018 International Energy Conservation Code (IECC). The City of Lawrence has formally adopted this version, which also allows for an alternative compliance path using ANSI/ASHRAE/IES Standard 90.1-2016.

Permit submissions must include a complete energy code compliance report, with the U.S. Department of Energy's COMcheck software being the accepted and preferred format. The COMcheck report must be generated using the appropriate code selection (2018 IECC or ASHRAE 90.1-2016) and must be signed by the responsible design professional.

Key takeaways for compliance in Lawrence include:

• Governing Code: 2018 IECC, adopted by the City of Lawrence under Chapter 5, Article 7 of the City Code.

• Alternative Standard: ASHRAE 90.1-2016 is an acceptable compliance path as outlined in IECC §C401.2.

• Required Documentation: A signed COMcheck report is mandatory. This report must be supported by detailed construction documents that clearly specify all components of the building's thermal envelope, mechanical systems, and lighting systems.

• Local Amendments: The City of Lawrence has adopted the 2018 IECC with minimal technical amendments. This means the prescriptive and performance requirements for building envelope insulation, fenestration performance, HVAC system efficiency, and lighting power density (LPD) are largely identical to the model code. Always verify the latest city ordinances before finalizing design.

Context + Why This Topic Matters

Unlike many states, Kansas does not have a mandatory statewide building or energy code. Code adoption and enforcement are delegated to individual cities and counties under "home rule" authority. This makes it critically important for architects, engineers, and contractors to verify the specific codes in effect for the jurisdiction of every project. Assuming the code from a neighboring city applies is a common and costly mistake that leads to plan review rejections and construction delays.

Energy code compliance is a multi-disciplinary challenge integral to modern building design. It directly impacts:

• Permitting: A complete and accurate energy code submittal, typically a COMcheck report, is a prerequisite for receiving a building permit in jurisdictions like Lawrence.

• Project Costs: Energy code requirements influence the selection of insulation, windows, HVAC equipment, and lighting controls, affecting both upfront construction costs and long-term operational expenses for the owner.

• Coordination: Successful compliance requires seamless coordination between the architect (building envelope), the mechanical engineer (HVAC and service water heating), and the electrical engineer (lighting and controls). A failure in one area can negate the efforts of others.

Misunderstanding or misapplying the energy code often results in plan review comments, project redesign, and inspection failures. A thorough understanding of the requirements in Lawrence is essential for a smooth project delivery.

Detailed Answers to Each Question

What are the specific energy code compliance documentation requirements for a new commercial building permit submission in Lawrence, KS? Specifically, which version of COMcheck is accepted, and are there local amendments to ASHRAE 90.1 or the IECC that impact building envelope, mechanical, or lighting power density requirements?

For a new commercial building permit in Lawrence, Kansas, you must submit comprehensive documentation proving compliance with the 2018 International Energy Conservation Code (IECC). The city accepts and expects a COMcheck report generated using the "2018 IECC" or the alternative "ASHRAE 90.1-2016" standard. A review of the City of Lawrence Code of Ordinances indicates that the 2018 IECC was adopted without significant technical amendments that would alter the core requirements for the building envelope, mechanical systems, or lighting power densities found in the model code.

Deeper Explanation

1. Adopted Code and Compliance Paths

The City of Lawrence officially adopted the 2018 IECC as part of its comprehensive code update. Per 2018 IECC §C401.2, commercial buildings are permitted to demonstrate compliance through one of the following paths:

• Prescriptive Path (IECC §C402-C405): This is the most straightforward method. It involves meeting a series of specific requirements for each building system (envelope, HVAC, lighting). This path also requires selecting one additional energy efficiency package from IECC §C406.

• ASHRAE 90.1-2016: The IECC explicitly allows the entire building and its systems to be designed and constructed in accordance with ANSI/ASHRAE/IES Standard 90.1-2016. This is a common choice for projects with more complex HVAC systems.

• Total Building Performance Path (IECC §C407): This path involves using building energy simulation software (like EnergyPlus™, DOE-2, etc.) to show that the proposed design will use less energy annually than a baseline building designed to the prescriptive standard. This is typically used for unique buildings where prescriptive requirements are difficult to meet.

2. COMcheck Software and Submittal

COMcheck is the U.S. Department of Energy's software designed to simplify and standardize energy code compliance verification.

• Accepted Version: You should use the latest version of the COMcheck software available from the DOE website. When starting a new project in the software, you must select the correct code from the dropdown menu: "2018 IECC" or "ASHRAE Standard 90.1-2016".

• Required Output: The permit submittal package must include the signed Compliance Certificate page from COMcheck, along with the detailed reports for each relevant section (Envelope, Interior Lighting, Exterior Lighting, Mechanical). The values entered into COMcheck must exactly match the values, specifications, and details shown on the architectural, mechanical, and electrical drawings.

3. Local Amendments

The City of Lawrence has adopted the 2018 IECC largely as written. The local amendments found in the City Code are primarily administrative, concerning enforcement, permits, and fees. There are no notable local amendments that change the following core technical provisions:

• Building Envelope: The insulation R-values, assembly U-factors, and fenestration U-factor/SHGC requirements in 2018 IECC Tables C402.1.3, C402.1.4, and C402.4 apply directly.

• Mechanical Systems: HVAC and water heating equipment must meet or exceed the minimum efficiency ratings specified in 2018 IECC Tables C403.3.2(1) through C403.3.2(13). Requirements for economizers, duct insulation, and controls also follow the model code.

• Lighting Power Density (LPD): The maximum allowable lighting power must be calculated using the Building Area Method or Space-by-Space Method LPD values found in 2018 IECC Table C405.3.2(1) or C405.3.2(2). Lighting control requirements from Section C405.2 are also mandatory.

4. Complete Documentation Checklist

To avoid delays in plan review, a permit submission in Lawrence should include:

• Signed COMcheck Report: Including the Certificate, Envelope, Mechanical, and Lighting sections.

• Architectural Plans:

  • Wall, roof, and floor/foundation sections with all materials clearly labeled and insulation R-values specified.

  • Details showing a continuous air barrier across the entire thermal envelope.

  • Window, skylight, and door schedules that list the certified U-factor and Solar Heat Gain Coefficient (SHGC) for each product.

• Mechanical Plans:

  • Equipment schedules listing the type, capacity, and energy efficiency rating (e.g., SEER, EER, COP, Ec) for all HVAC and service water heating equipment.

  • Duct layout plans specifying duct insulation R-values.

  • A controls narrative or drawings detailing thermostats, economizers, demand control ventilation, etc.

• Electrical Plans:

  • Lighting plans showing fixture locations and types.

  • A lighting fixture schedule detailing the lamp/luminaire wattage for each type.

  • LPD calculations confirming compliance.

  • Details for all required lighting controls, including occupancy sensors, time switches, and daylight-responsive controls.

Additional Supporting Sections

Jurisdictional Variations Across Kansas

The lack of a statewide code in Kansas means that adopted codes can vary significantly from one city or county to the next. What is compliant in Lawrence may not be compliant in a neighboring jurisdiction. It is a critical best practice to verify the adopted codes for every project location.

Here is a sample of adopted commercial energy codes in other major Kansas jurisdictions (verify with AHJ for latest information):

This table illustrates the patchwork of regulations. For example, a project in Overland Park must comply with the more stringent 2021 IECC, which has different requirements for envelope, lighting, and EV-readiness compared to the 2018 IECC used in Lawrence.

Common Mistakes and Misinterpretations

Plan reviewers in Kansas frequently encounter the same energy code compliance errors. Avoiding these common pitfalls can significantly speed up the permitting process.

• Mismatched Documents: The most common error is a COMcheck report that does not match the construction drawings. For example, the COMcheck lists R-25 roof insulation, but the architectural section detail shows only R-20.

• Ignoring Mandatory Requirements: Some designers incorrectly assume that passing the performance-based calculations in COMcheck allows them to ignore mandatory provisions. This is false. Requirements like air barriers (IECC C402.5), lighting controls (IECC C405.2), and equipment efficiency minimums are always required.

• Forgetting the C406 "Additional Efficiency Package": The prescriptive path of the 2018 IECC requires projects to comply with at least one additional efficiency measure from Section C406 (e.g., more efficient HVAC, reduced lighting power, etc.). This is often overlooked.

• Incomplete Fenestration Data: Window and door schedules must include both U-factor and SHGC. Simply listing "Low-E" or "Energy Star" is insufficient for commercial plan review.

• Assuming a Statewide Code: As mentioned, designers new to Kansas often mistakenly assume a single code applies everywhere. Always verify locally.

Coordination Considerations for Design Teams

Energy code compliance is a team effort. Clear communication and defined responsibilities are essential.

• Architect/Envelope Designer:

  • Establishes the building's form, orientation, and thermal envelope.

  • Selects insulation, air barrier strategies, and fenestration products.

  • Provides all envelope data for the COMcheck report.

  • Coordinates wall/roof assembly transitions to ensure a continuous thermal and air barrier.

• Mechanical Engineer:

  • Selects HVAC and water heating systems that meet or exceed IECC efficiency tables.

  • Designs control systems, including economizers, energy recovery, and demand control ventilation.

  • Provides all equipment data and system details for the COMcheck report.

• Electrical Engineer:

  • Designs the lighting system to stay within the LPD limits.

  • Specifies and details all mandatory lighting controls (e.g., occupancy sensors, daylighting zones).

  • Provides all lighting data for the COMcheck report.

• The Integrator (Lead Professional or Code Consultant):

  • One person must be responsible for compiling all data into the final COMcheck report and ensuring it aligns perfectly with the drawing set before submittal. This prevents discrepancies and streamlines plan review.

Cluster-Level FAQ Section

1. Does Kansas have a mandatory statewide energy code? No. Kansas is a "home rule" state, meaning building and energy codes are adopted and enforced by individual city and county governments. You must verify the code for each specific project location.

2. Can I use REScheck for a commercial building in Lawrence? No. REScheck is the U.S. Department of Energy's compliance software for residential buildings (under the IRC). For commercial buildings under the IECC, you must use COMcheck.

3. Is whole-building air leakage testing required for new commercial buildings in Lawrence? Yes, in most cases. 2018 IECC §C402.5.1 requires whole-building air leakage testing (a "blower door test") for most new buildings. This is a frequently overlooked but mandatory requirement.

4. What are the basic lighting control requirements in the 2018 IECC? The 2018 IECC requires multiple layers of lighting control, including: local manual controls, automatic shutoff via occupancy sensors or time-switches in most spaces, light-reduction controls, and automatic daylight-responsive controls for areas near windows and skylights.

5. How do I find the adopted building codes for a different city in Kansas? The most reliable method is to visit the city or county's official website and search for their building department or planning and development services department. They usually publish their adopted codes online. If you cannot find it online, call the building department directly.

6. Do the energy code requirements apply to an interior tenant improvement (TI) project? Yes. If the project involves adding or altering the building's energy-consuming systems, the new work must comply. For example, if new lighting is installed, it must meet the LPD and control requirements of the 2018 IECC. If new HVAC units are installed, they must meet the efficiency requirements.

7. What are the insulation requirements for a metal building in Lawrence? A metal building must meet the same prescriptive requirements as any other construction type. The opaque wall and roof assemblies must meet the U-factor or R-value requirements in 2018 IECC Table C402.1.3. This is often achieved with liner systems (e.g., filled cavity or long-tab banded) or by using insulated metal panels (IMPs).

8. What happens if my COMcheck report doesn't match the construction drawings during plan review? The plan reviewer will issue a correction notice detailing the discrepancies. The building permit will not be issued until the drawings and the COMcheck report are revised to be consistent and fully compliant with the code.

9. Does the 2018 IECC require electric vehicle (EV) charging infrastructure? No. The 2018 IECC does not contain mandatory requirements for EV-ready or EV-installed parking spaces. These requirements were introduced in the 2021 IECC, which has not been adopted in Lawrence. However, providing this infrastructure is a common practice to future-proof a building.