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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 Cod e

On April 9 th representatives of the Coalition for Fair Energy Codes (CFEC) met with Department of Energy s taff to discuss proposals for the 2015 International Energy Conservation Code (IECC). Attendees at the meeting included:

CFEC:

Ken Bland (AW C) 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 Vaidyanat han

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-factor2

table). DOE clarified the statement that “neither option prescribes the building material

to be used” re flects it s 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 t o 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 leak age 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.3

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.