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New Chicago Code Has People Looking For Ways To Prevent Energy — And Money — From Going Through The Roof

Commercial building roofs on Chicago's South Side

new energy code in Chicago is meant to significantly reduce new commercial buildings’ contributions to climate change.

But before that can happen, CRE stakeholders need to make sense of the rules the city unveiled at the beginning of the year. Some Chicago-area architects and developers worry that the code, while well-intentioned, could add a new level of complexity and expense to local building construction.

“The code is asking us to do some really challenging things,” said Jason Wilen, architect and associate principal with Chicago–based structural and architectural engineering firm Klein & Hoffman. “We're up to the task, but the question is, what does compliance with the code actually look like?”

The 2022 Chicago Energy Transformation Code is based on the 2021 International Energy Conservation Code. It is a significant update to the city’s previous energy code passed in 2019, and its goal is to improve the energy-efficiency of new commercial buildings by 5%.

“It’s critical that every construction and renovation project increases the efficiency and sustainability of our building stock as part of Chicago’s commitment to combat climate change,” Mayor Lori Lightfoot said last fall.

Among its mandates, Chicago’s updated code calls for substantial portions of the roofs of new commercial buildings up to 60 feet in height to be kept clear of obstructions to allow for the potential future addition of solar panels. It sounds straightforward enough and some exceptions are allowed, but Wilen warned that compliance with the new requirements will take careful planning and coordination among owners, contractors and designers.

The city fast-tracked the new code, forgoing the usual phase-in period provided when codes are set to change and stakeholders can make sense of how it could impact their in-progress designs of new buildings. The city appears to be motivated by a desire to get in the front of the line for some of the $1B in financial assistance available through the federal Inflation Reduction Act to encourage net-zero adoption.

“Planning for and designing buildings can take years,” Wilen said. “But if you're halfway through a design process and suddenly the rules change, that's disruptive, and that aspect of the rollout is unusual.”

But the timing isn’t the only unusual thing about the updated code. Wilen noted that the code language contains significant gray areas that the city will need to clarify with designers and builders. For example, the ordinance mandates that “total solar-ready zone surface area shall be not less than 40% of the available roof area.”

Wilen warned that, for some building types, roof space will have to be carefully planned.

“While there are some exceptions, that is quite a large roof area and the code language includes examples of things they don't want included in that 40%, such as pipes, vents, ducts, equipment and skylights,” he said. “This is particularly challenging for something like roof anchors.”

Wilen noted that window washers tie off from the anchors, which need to be installed at regular intervals on the roof perimeter to be effective.

The code also calls for additional capacity for the roof structure to support future rooftop solar equipment, a built-in interconnection pathway to accommodate electrical cables and designated space within the building to house batteries. 

“Overall, this is going to be a big adjustment for designers and for building owners, especially for buildings like hospitals that have a constantly changing need to reassess what's on the roof,” Wilen said. 

In a further code change, additional insulation must be installed at parapets and balconies. The idea is to eliminate thermal bridges that allow energy to escape. 

How that will work in the real world, however, is still to be determined, said Allison McSherry, an architect and Klein & Hoffman associate.

“It basically states that on all commercial buildings, you either have to wrap the parapets and balconies in continuous insulation or provide a thermal break,” McSherry said. 

McSherry called this significant because there is no effective way to wrap a balcony continuously with insulation. 

“This would create a lot of other issues, which means you have to have a thermal break and you can no longer use extended concrete slabs,” she said. “Now, if you want a balcony on your building, you will have to do it in a way that is significantly more expensive.”

Until issues like that are sorted out, McSherry said her firm is advising clients to not let their permits issued prior to issuance of the new code lapse. 

“If they happen to let that permit lapse, they will have to completely redesign all of those balconies at a very high cost premium,” she said. 

Wilen added that the city is also allowing designers and builders to choose one of 11 different compliance methodologies to meet the code requirements.

Each one of these paths can have a very different impact on construction sequencing, though, which means the building team has to do its homework if it wants to avoid making expensive mistakes.

“Someone has to understand all of the paths and then be able to determine which of those paths is the most desirable,” he said. “This could require the hiring of a third-party energy reviewer to confirm the path is viable. If you don’t do that, it might require on-site testing of the completed building, which could make your building cost go through the roof at the end of the project.”

Adding to the uncertainty, Lightfoot lost her re-election bid in March, meaning that the rollout of the Energy Transformation Code will continue under a new mayoral administration that might have different priorities. 

Until questions are answered, Wilen and McSherry urged commercial developers to seek out Chicago energy code expertise.

“Get your team together very early in the design process,” Wilen said. “The paths to compliance have gotten more complicated, and things are happening earlier with this new code rollout than people might be used to.”  

This article was produced in collaboration between Klein & Hoffman and Studio B. Bisnow news staff was not involved in the production of this content.

Studio B is Bisnow’s in-house content and design studio. To learn more about how Studio B can help your team, reach out to

Related Topics: Klein & Hoffman, StudioB-1254