### Department of Energy Washington, DC 20585 September 26, 2013

Mr. Tom Kositzky Executive Director, Coalition for Fair Energy Codes C/O Jerry Schwartz, Senior Director, Energy and Environmental Policy American Wood Council 1111 19 StreetNW, Suite 800 Washington, DC 20036
DearMr. Kositzky:
Thank you for your September 5, 2013 inquiry regarding the Department ofEnergy's (DOE) participation in the development ofthe 2015 International Energy Conservation Code (lECC). DOE's participation in the industry process for the review and modification ofbuilding codes is guided by Title III ofthe Energy Conservation and Production Act, as amended. The Act specifies that DOE shall "seek adoption ofall technologically feasible and economicallyjustified energy efficiency measures."
As your letter noted, DOE provided an opportunity for the public to comment on its efficiency concepts and draft proposals for the 2015 IECC, which included the topic of addingresidential equipment tradeoffs back into the code. Ofthe draft proposals, DOE selected a subset to analyze and put forward at the International Code Council (ICC) Committee Action Hearings based in part on feedback and supporting data from stakeholders regarding the energy efficiency savings. DOE received diverse opinions on the net energy savings from the equipment tradeoffs proposal, and DOE did not include it among those selected.
Also as you noted in your letter, DOE had discussed the removal ofresidential equipment tradeoffs in its determination on the 2009 IECC

. In the 2009 IECC Determination, DOE stated:
Another change [that] does not directly alter code stringency in the perfonnance path but may ultimately result in some energy savings is the removal ofthe option to trade high-efficiency HVAC equipment for reductions in other requirements in the code, such as reduced envelope insulation. Because building envelopes have substantially longer lives than HVAC and/or water heating equipment, energy savings from envelope improvements may persist for many more years than comparable equipment improvements. Also, because high-efficiency equipment is already the predominant choice in many markets, disallowing envelope/equipment tradeoffs is likely to result in improved overall efficiency in many situations. (76 Fed Reg. 42688; July 19, 2011.)
To clarify, this was included solely as a discussion noting the removal ofequipment tradeoffs from the 

## IEee performance path, and no technical analysis was conducted. 

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### 2 Finally, DOE intends to continue its participation in the ICC process consistent with the policy published by DOE on April 19, 2013. (78 FR 23550.) At the upcoming October 2013 ICC Public Comment Hearings, DOE intends to deliver testimony and vote on behalf ofits proposals, as well as deliver testimony and vote on proposals for which DOE has performed applicable analysis and that has previously been published. To the extent that DOE does deliver testimony and vote, we will do so in a manner consistent with the ICC's rules and procedures.
The Department values your support and looks forward to working together to create and implement more efficient building energy codes and standards. Ifyou have additional questions, please contactJeremiah Williams, BuildingTeclmologies Office, at (202) 287-1941. Sincerely,

Kathleen B. Hogan Deputy Assistant Secretary for Energy Efficiency Energy Efficiency and Renewable Energy