CAL DOOLEY PRESIDENTAND CEQ

The Honorable Dr. Ernest Moniz Secretary U.S. Department ofEnergy 1000 Independence Avenue SW Washington, D.C. 20585

Dear Secretary Moniz, 

## American® Chemistry ouncil

September 30,2013

The American Chemistry Council and our member companies share the Department ofEnergy's (DOE) beliefthat energy efficiency is one ofthe easiest and most effective ways to reduce energy demand and achieve cost savings in the residential, commercial, and industrial sectors. We have a unique perspective on energy efficiency because ofthe essentialrole that chemistry and chemical manufacturers play inthe development andproduction ofenergy efficient technologies and as one ofthe largest industrial consumers ofenergy. We support efforts to improve energy efficiency throughout our economy andbelieve efficiency shouldbe a fundamental part ofa comprehensive national energy strategy.
Inrecent years, the International Code Council (ICC) has adopted changes to various efficiency codes to require greater energy efficiency in the built environment. These changes have been put into practice and today are resulting inlower electricitybills for consumers, reduction in energy demand, and lower greenhouse gas emissions. As you may know, the ICC is meeting this week in Atlantic City, NewJersey, to consider further revisions to the InternationalResidential Code, the rllternational Energy Conservation Code, and other important efficiency standards.
Overthe years, DOE has played an invaluable role in providing technical analysis, energy modeling, and expert perspective on proposed changes to ICC codes. The importance ofDOE's perspective was validated by Congress when itpassed theEnergy Policy Act of2005.' This law requires DOEreview ofrevised codes to confirm that they will result in greater energy savings and requires DOE to recommend for or against adoptionbythe states based on this review.
It has come to our attention that DOE has been asked to refrain from providing analysis or offering a vote onpossible changes unless DOEitselfproposed the change. Employing this new approach at this week's meeting ofthe ICC would be a radical departure from pastpractice and would deprive the process ofa knowledgeable, independent voice aboutthe value, effectiveness, and potential consequences ofproposed code revisions.

americanchemistry.com® 700 2nd Street, NE, Woshington, DC 20002 

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# eliWe strongly encourage youto resistthese efforts to stifle DOE's voice and believe that DOE must maintain the Department's traditional role ofevaluating proposed code changes; offering public support for proposals that are consistent withthe Department's goal ofadvancing energy savings; and speaking against proposals that would reduce efficiency. As part ofthe Department's analysis, we encourage DOEto examine each proposed path to code compliance, whether it is prescriptive- or performance-based, to ensure that any revisions do notreduce overall energy savings without robust technicaljustification and that all means ofcompliance remain materials-neutral in order to provide the flexibility needed by designers and builders while also ensuring enhanced efficiency. DOE's support for cost-effective energy efficiency gains in our nation's residential and commercial buildings has enabled significant progress in reducing energy demand and energy costs. As new codes are considered, the presence ofDOE's thoughtful, informed, and unbiased perspective is more important than ever. We hope you will maintain DOE's leadership role in the important proceedings this week and in future code deliberations.

### American" Chemistry 

## -'Louncil

700 2nd Street, NE, Washington, DC 20002

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## 02r

- 7 2013 

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### The Honorable Dr. Ernest Moniz Secretary U.S. Department ofEnergy 1000 Independence Avenue SW Washington, D.C. 20585

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