CAL DOOLEY 

PRESIDENT AND CEQ 

The Honorable Dr. Ernest Moniz 

Secretary 

U.S. Department of Energy 

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 of Energy's 

(DOE) belief that energy efficiency is one of the 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 of the essential role that chemistry 

and chemical manufacturers play in the development and production of energy efficient 

technologies and as one of the largest industrial consumers of energy. We support efforts to 

improve energy efficiency throughout our economy and believe efficiency should be a 

fundamental part of a comprehensive national energy strategy. 

In recent 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 in lower electricity bills for consumers, reduction in energy 

demand, and lower greenhouse gas emissions. As you may know, the ICC is meeting this week 

in Atlantic City, New Jersey, to consider further revisions to the International Residential Code, 

the rllternational Energy Conservation Code, and other important efficiency standards. 

Over the years, DOE has played an invaluable role in providing technical analysis, energy 

modeling, and expert perspective on proposed changes to ICC codes. The importance of DOE's 

perspective was validated by Congress when it passed the Energy Policy Act of 2005.' This law 

requires DOE review of revised codes to confirm that they will result in greater energy savings 

and requires DOE to recommend for or against adoption by the 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 on possible changes unless DOE itself proposed the change. Employing this new 

approach at this week's meeting of the ICC would be a radical departure from past practice and 

would deprive the process of a knowledgeable, independent voice about the value, effectiveness, 

and potential consequences of proposed code revisions. 

americanchemistry.com® 700 2nd Street, NE, Woshington, DC 20002 I (202) 249.7000 eli 
We strongly encourage you to resist these efforts to stifle DOE's voice and believe that DOE 

must maintain the Department's traditional role of evaluating proposed code changes; offering 

public support for proposals that are consistent with the Department's goal of advancing energy 

savings; and speaking against proposals that would reduce efficiency. As part of the 

Department's analysis, we encourage DOE to examine each proposed path to code compliance, 

whether it is prescriptive- or performance-based, to ensure that any revisions do not reduce 

overall energy savings without robust technical justification and that all means of compliance 

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 of DOE'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 

.- >~ , •• ," 

02r - 7 2013 

SANITl7f-n ""~~=--~ 

The Honorable Dr. Ernest Moniz 

Secretary 

U.S. Department of Energy 

1000 Independence Avenue SW 

Washington, D.C. 20585 

,.. ..... -