1. Does not mention any passive solar in its calcsThe code they are pushing which incorporates HERS ratings and LEED standards would substantially upgrade the efficiency of inherently inefficient construction methods (stick building) but would cause problems for adobe and compressed earth block builders among others, since according to Joe adobe builders would not qualify for the NM Sustainable Building Tax Credit.
2. Cannot model passive solar well
3. Does not have the sophistication of Energy 10
4. Cannot integrate thermal mass or temperature swing
5. Cannot program Trombe walls or time delay
6. Cannot program selective surfaces or reflectors
7. Leans designers away from passive solar
8. Leans designers to expensive equipment that needs government subsidies
9. Requires 'energy experts' to use REM software to review drawings for permits
10. Calls for REM to be a requirement in new green building codes
Courtesy Solaradobe Newsletter
This illustrates how complicated regulatory issues can become. Good luck to all the natural builders in New Mexico.
Photo courtesy Leto A. by CC license and Flickr