Proposed Changes to the 2027 Denver Building Code

Appendix U, Embodied Carbon will become part of the Denver Building Code in early 2027. The version shown below (excluding the CECC recommendations) will be sent out for public review and comment in November of 2026 [needs to be confirmed with the Denver Planning Department (DPD) and Denver's Office of Climate Action, Sustainability and Resiliency (CASR)].

CECC is going to recommend the changes shown in red in sections U301.1.1 and U301.1.1.2, and adding Table U301.1.1. The purpose of these recommendations is to clarify what category 7 of section U301.1.1, Insulation, includes. There are a large number of insulation types (20-30) and uses (10-15) in commercial buildings, and it could require a huge amount of work to comply with the insulation portion of Appendix U without additional clarification. Also, since the text of the amendment is silent on whether a single insulation type can disqualify a project trying for Energy Code credits, we are recommending that at least 2/3 of the insulation types submitted on a project achieve the 10% reduction from the industry-average value required for Energy Code credits.

CECC wants this code appendix to be a success. Our recommended changes narrow the insulation types to these categories: Exterior Walls, Roofs, Attics, and Foundations. Using these use categories results in twelve insulation types requiring EPDs if used on a project.

One notable insulation type that has not been included due to a lack of an industry-average EPD is XPS.

This DRAFT copy is being provided for review and comment by interested parties.