1201 15th Street NW Washington, DC 20005

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nahb.org Government Affairs

Jim Tobin Senior vice President & Chief Lobbyist



## MEMO

To: U.S. Department of Energy

From: Jim Tobin, Senior Vice President

National Association of Home Builders (NAHB)

Date: September 30, 2013

Subject: 

### Ex Parte Memorandum

On September 24 th 

### representatives from the Na tional Association of Home Builders (NAHB) met with David Daniel son, Assistant Secretary for Energy Efficiency and Renewable Energy at the Department of Energy (DOE), and other DOE staff to discuss proposal s for the 2015 International Energy Conservation Code (IECC). Atte ndees at the meeting included:

NAHB: Jim Tobin (NAHB) Susan Asmus (NAHB) Billie Kaumaya (NAHB) Craig Drumheller (NAHB) Clayton Traylor (Leading Builders of America)

Department of Energy (DOE):

David Danielson Kathleen Hogan Kym Carey Jeremy Williams Kavita Vaidyanathan

Daniel Cohen

Jason Walsh

DOE Policy Announcement (Re: Code Development) NAHB began the meeting with a di scussion about DOE’s April 19 Federal Register announcement (78 Fed. Reg. 23550 (April 19, 2013)), clarifying its role in code development. NAHB commended the Department for their commitment to increasing transparency. NAHB believes, however, that the policy was unclear regarding how DOE int ends to exercise their right to vote during the 2015 IECC final action hearings in October. NAHB believes that DOE representatives should only vote on those proposals that were subject to public review and comment, and were published as final proposals on the DOE EnergyCodes.gov website. Thes e are the proposals that have receivedSeptember 30, 2013 Page 2



### proper vetting, ensuring that all stakehol ders have had the opportunity to weigh in.

In response, Dr. Kathleen Hogan indicated that DOE representatives would only vote on those proposals for which technical analys es had be conducted, including only the analyses that had already been posted to the DOE EnergyCodes.gov website. She added that DOE representatives would refrain from voting on all other proposals, noting that there would be no surprises regarding how DOE intended to vote.

Prescriptive vs. Performance Path NAHB presented research showing that the 2012 IECC Prescriptive path was not cost optimized. NAHB presented a graph (attached) indicating that an unrestricted Performance path could reduce construction co st by roughly $3,000, while maintaining the same level of energy efficiency.

Energy Neutral Tradeoffs NAHB expressed its support for energy neutral tradeoffs to give more flexibility to the builder, and ultimately the home owner. NA HB believes that t he most important proposals that will be heard at th e ICC Public Comment Hear ings in October are RE166 Equipment Tradeoffs, RE-72 Building Ti ghtness Tradeoffs, RE-116 Duct Tightness Testing. These proposals allow builders to cons truct an equally efficient home at a lower

cost.

Energy Efficiency Financing NAHB representatives discussed the major ba rriers to increased energy efficiency in housing, the first being cost and the second being the lack of financing options. NAHB reported on the SAVE Act, a bill currently being considered in Congress that could help

address the 2 nd 

### barrier by allowing lenders to account for energy savings in mortgages.
NAHB noted that this bill, unf ortunately has a score attached that needs to be offset with mandatory spending cuts. NAHB and DOE agreed to continue to work on this issue.

Submitted by:

Jim Tobin

Senior Vice President

National Association of Home Builders

1201 15 th 

### St., NW Washington, DC 20005 jtobin@nahb.orgSeptember 30, 2013 Page 3$2,200$2,300$2,400$2,500$2,600$2,700$2,800$2,900$3,0000% 10% 20% 30% 40% 50% 60% 

### Annual Energy + Mortgage $%EnergySavingsAnnualEnergyandIncrementalMortgageCostvs.%EnergySavingsNationalWeightedAveragePrescriptivePathOptimizedw/oHEEquipmentOptimizedw/HEEquipment2009IECC2006IECC2012IECC%Savings= 2006IECCEnergy$‐ReferenceEnergy$2006IECCHeating,Cooling&WaterHeating$$250/yrsavingsatthesameefficiency