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DATE: April 24, 2013

FROM: Tom Kositzky

Coalition for Fair Energy Codes (CFEC)

 

RE: Memorandum for the Docket on April 9, 2013 CFEC Meeting With 

Department of Energy Representatives on Proposals for the 2015 

International Energy Conservation Code 

On April 9th representatives of the Coalition for Fair Energy Codes (CFEC) met with 

Department of Energy staff to discuss proposals for the 2015 International Energy 

Conservation Code (IECC). Attendees at the meeting included: 

CFEC: 

Ken Bland (AWC)

Loren Ross (AWC) 

Tom Kositzky (CFEC) (by phone) 

Suzanne Madden (AWC) (by phone) 

Jerry Schwartz (AWC) 

Billie Kaumaya (National Association of Home Builders) 

Department of Energy (DOE): 

Joe Hagerman 

Kym Carey 

Jeremy Williams 

Kavita Vaidyanathan

Mark Lessans 

Ex Parte Communication 

DOE representatives explained how it produces International Energy Conservation 

Code (IECC) code change proposals, and participates in the ICC code development 

process. For information on the process please review the Federal Register Notice 

published on April 19, 2013 (78 FR 23550). 

DOE Response to Congressional Letter 

 Continuous Insulation Requirements 

In response to a question about DOE’s position in its letter, the agency indicated that 

there are two options in the “Prescriptive Path”: 1) follow Table R 402.1.1 or 2) meet 

the U factor alternative table (see below for discussion of parity issues in the U-factor 
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table). DOE clarified the statement that “neither option prescribes the building material 

to be used” reflects its encouragement to develop new technologies and products to 

comply with the IECC. For example, DOE believes Structural Insulated Panels (SIPs) 

could meet the requirements of Table 402.1.1. 

CFEC would like to note for the docket our concern that Table 402.1.1 is the compliance 

option that will be used by the vast majority of builders to comply with the 2012 IECC; 

the Table does not allow for a cavity-only compliance option in climate zones 6, 7, or 8, 

and it effectively mandates the use of “continuous insulation” in these same climate 

zones. Use of the U-factor table and UA methodology requires the builder to make 

assumptions, calculate values to demonstrate compliance with the U-factor table, and 

have this information available during site inspections. So, while considered 

prescriptive, the entire process is significantly more technical compared to meeting the 

R-values in Table 402.1.1. 

The true performance option in Section 405.1 requires whole-building modeling to 

demonstrate code compliance to code officials. Being more complex and expensive for 

builders to use makes these two alternatives less attractive to builders that do not have 

access to energy code experts. Further, SIPs technology, which is still unfamiliar to 

many builders, has been on the market for over 30 years, but its market share has 

never topped 1% of residential single-family houses. According to the most recent 

Structural Insulated Panel Association Survey of 2012 Production, the use of structural 

insulated panels in either floors, walls and/or roofs in new residential single-family 

construction has ranged from 0.58 - 1 percent of the market for nearly a decade. The 

market share in 2012 was estimated to be just shy of 0.9 percent. While SIP systems 

have been shown to reduce air leakage and provide high insulating properties, SIPs are 

not available to builders through traditional construction material distribution channels. 

 Equipment Tradeoffs 

DOE indicated that in its draft proposals there was a concept based on equipment 

tradeoffs, its final proposals did not include the concept and DOE will remain neutral on 

others’ equipment tradeoff proposals. 

Review of CFEC and DOE Proposals 

CFEC representatives reviewed several of their proposals. Proposals discussed in 

more detail included: 

 CFEC RE-32, which would provide a cavity-only option for climate zones 7-8.

 CFEC RE-37, which would provide a cavity-only option for climate zone 6 and 

provide consistency with the U-factor Table. 

 APA/AWC RE-177, which would provide a performance path alternative related 

to window areas less than the standard reference design; and 

 CFEC RE-178, which would allow for equipment tradeoffs. 
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CFEC representatives also discussed DOE RE-63, which would remove footnote h from 

Table 402.1.1 and instead place it in a new Section 402.2.13. CFEC is concerned that 

moving the text from a footnote with the addition of the new last sentence would add 

confusion and suggested that it remain a footnote. Alternatively, DOE could delete the 

proposed last sentence. DOE representatives stated their intent was not to change the 

substance of the footnote and that they did not intend to imply that the footnote 

correction does not apply in the U Factor compliance option. CFEC members 

appreciated DOE’s recognition of the importance of the structural performance 

component of building products. 

Role of DOE in the Code Development and Adoption Process 

DOE stated that its role is to provide technical assistance during the code development 

and adoption process. DOE also evaluates State residential codes to determine energy 

efficiency as compared to the most recent voluntary applicable residential code. 

DOE stated that they were no longer funding a grant program pursuant to a Request for 

Proposals that the agency had issued seeking advocacy assistance. DOE also 

suggested that CFEC representatives bring to DOE’s attention any instances of 

advocacy on DOE’s behalf.