Department of Energy 

Wa sh ington, 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 Street NW, Suite 800 

Washington, DC 20036 

Dear Mr. Kositzky: 

Thank you for your September 5, 2013 inquiry regarding the Department of Energy's 

(DOE) participation in the development of the 2015 International Energy Conservation 

Code (lECC). DOE's participation in the industry process for the review and modification 

of building codes is guided by Title III of the Energy Conservation and Production Act, as 

amended. The Act specifies that DOE shall "seek adoption of all technologically feasible 

and economically justified 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 

adding residential equipment tradeoffs back into the code. Of the 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 of residential 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 of the option 

to trade high-efficiency HV AC equipment for reductions in other requirements in 

the code, such as reduced envelope insulation. Because building envelopes have 

substantially longer lives than HV AC 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 of equipment 

tradeoffs from the IEee performance path, and no technical analysis was conducted. *

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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 

of its 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. If you have additional 

questions, please contact Jeremiah Williams, Building Teclmologies Office, at 

(202) 287 -1941. 

Sincerely, 

Kathleen B. Hogan 

Deputy Assistant Secretary for Energy Efficiency 

Energy Efficiency and Renewable Energy