The Consortium for Energy Efficiency (CEE) seeks your comments on a draft proposal to revise the CEESM New Construction Initiative to include updated efficiency tiers, a new carbon reporting requirement, and new prescriptive requirements. With over 30 years of market transformation experience and with membership in 38 states and 4 provinces representing 100 million electric customers and 50 million natural gas customers, CEE is where leading United States and Canadian efficiency program administrators develop consensus-based strategies to accelerate adoption of cutting-edge energy efficiency and load management solutions. The Initiative was launched in 2018 and leverages a tiered specification framework with performance-based levels designed to grow the market of high-performance new construction in North America. It creates a foundation from which program administrators, utilities, and energy efficiency stakeholders can work collaboratively to drive market transformation in the new home landscape. This works to increase the overall performance of new homes, support the advancement and uptake of future building codes that align with program goals, and promote greater alignment in a traditionally fragmented market. Over the past few years, the CEE Residential New Construction Committee has identified several opportunities for Initiative enhancements and additions, as reflected in this proposed specification. These span across both energy efficiency as well as load flexibility, to help members achieve decarbonization objectives. The scope of proposed changes includes the following: • Updated Energy Rating Index (ERI) tier levels to promote increasingly higher thresholds of whole-house energy efficiency. • Inclusion of a new carbon reporting index (CRI) reporting requirement to document and begin tracking time-of-use (TOU) greenhouse gas emissions of homes. This new metric data collection will inform future work on load shifting to minimize overall emissions. • Inclusion of new minimum prescriptive requirements for critical large loads, including space heating and cooling, water heating, and electric vehicle charging, to ensure high efficiency and grid flexibility opportunities are maximized. For details go to draft proposal to revise the CEE 5M Residential New Construction Initiative CEE invites industry stakeholders to provide comments, along with supporting data, in response to the proposal described below. Our intent is to address and incorporate supported feedback through Committee review and deliberation before bringing it to the CEE Board for authorization. We respectfully request that feedback to this letter be submitted to Shawn Torbert in writing by April 4, 2025.