1 DATE: May 20, 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 Repres entatives on Proposals for the 2015 International Energy Conservation Code

On April 9 th 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). Atte ndees 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 Asso ciation 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 produc es International Energy Conservation Code (IECC) code change proposals, and parti cipates in the ICC code development process. For information on the process plea se review the Federal Register Notice published on April 19, 2013 (78 FR 23550).2 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 “P rescriptive Path”: 1) follo w Table R 402.1.1 or 2) meet the U factor alternative table (see below for discussion of parity issues in the U-factor table). DOE clarified the stat ement that “neither option pre scribes the building material to be used” reflects its encouragement to develop new technologies and products to comply with the IECC. For example, DOE be lieves Structural Insulated Panels (SIPs) could meet the requirem ents of Table 402.1.1.

CFEC would like to note for the docket our co ncern that Table 402. 1.1 is the compliance option that will be used by the vast majority of builders to comp ly with the 2012 IECC; the Table does not allow for a cavity-only comp liance option in climate zones 6, 7, or 8, and it effectively mandates the use of “cont inuous insulation” in these same climate

zones. Use of the U-factor table and UA methodology requires the builder to make assumptions, calculate values to demonstrat e compliance with the U- factor table, and have this information available during site inspections. So, while considered prescriptive, the entire process is significantly more techni cal compared to meeting the

R-values in Table 402.1.1.

The true performance option in Section 405. 1 requires whole-bui lding 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 t he 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 Asso ciation 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 ju st shy of 0.9 percent. While SIP systems have been shown to reduce air leakage and prov ide high insulating properties, SIPs are not available to builders through traditional construction material distribution channels.

Equipment Tradeoffs

DOE indicated that in its draft propos als there was a concept based on equipment tradeoffs, its final proposals did not include the concept and DOE will remain neutral on others’ equipment tr adeoff proposals.

Review of CFEC and DOE Proposals

CFEC representatives reviewed several of their proposals. Proposals discussed in

more detail included:3  CFEC RE-32, which would provide a ca vity-only option for climate zones 7-8.

 CFEC RE-37, which would provide a ca vity-only option for climate zone 6 and provide consistency with the U-factor Table.

 APA/AWC RE-177, which woul d 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.

CFEC representatives also discussed DOE RE- 63, which would remove footnote h from Table 402.1.1 and instead place it in a new Se ction 402.2.13. CFEC is concerned that moving the text from a foot note with the addition of the new last sentence would add confusion and suggested that it remain a footnote. Alternat ively, DOE could delete the proposed last sentence. DOE r epresentatives stated their in tent 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 im portance of the structural performance component of building products.

Role of DOE in the Code De velopment and Adoption Process

DOE stated that its role is to provide tec hnical 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 seekin g advocacy assistance. DOE also suggested that CFEC representatives bri ng to DOE’s attention any instances of advocacy on DOE’s behalf.