Statement of the Department of Energy

To the attendees of the 2005 ICC Final Action Hearings and other interested parties

September, 28, 2005
Detroit, Michigan

On September 29, 2005, a Department of Energy representative read the following DOE Policy statement. For any inquiries concerning this statement please contact (202) 586-9127. DOE proposed an extensive simplification of the 2003 International Energy Conservation Code (IECC) and the International Residential Code (IRC) at code hearings in 2003 and 2004. To obtain consensus on these changes, DOE made it clear that it would not propose or support increased stringency in the hearings leading up to the 2006 IECC and IRC. DOE's proposals were accepted at the hearings in 2003, but they were subsequently modified in the IECC through floor amendments. These amendments from the floor were not accepted in the energy chapter of the IRC; today you again hear discussion of the floor amendments.

The DOE posted information on its web-site on Monday, September 26, 2005 (see below), in order to clarify its understanding of the lack of analytical basis for the original 2004 floor amendments. In the absence of any technical documentation for the floor amendments, the Department conducted an initial analysis and posted the results on this web-site February 23, 2005. Specifically, the Department believes that more data is needed to fully address the potential cost impacts of various insulation options, and potential opportunity for the use of insulating sheathing for all building locations, including seismic and hurricane zones. The Department believes that a comprehensive analysis is needed before a confident decision can be made regarding the 2004 IECC floor amendments, yet the Department does not have that analysis and has not seen one. There is still inadequate data on the cost and implementation of the 2004 floor amendments that would allow the Department to support them in this hearing.

The Department is committed to finding the correct analytical solution for energy efficient code issues. Energy efficient building codes are among the statutory responsibilities of the Department and we look forward to working with this body in future code cycles in support of energy efficient improvements that are readily available, verifiable and properly field tested.

DOE to Perform Further Analysis Related to 2004/2005 IECC/IRC Residential Code Change Proposals

Posted September 26, 2005

DOE proposed an extensive simplification of the 2003 International Energy Conservation Code (IECC) and the International Residential Code (IRC) at code hearings in 2003 and 2004. To obtain consensus on these changes, DOE made it clear that it would not propose or support increased stringency in the hearings leading up to the 2006 IECC and IRC. DOE's proposals were accepted at the hearings in 2003, but they were subsequently modified in the IECC through floor amendments. The proposals from the floor, made wall R-values in several climate zones more stringent, and strengthened and extended trade-off limits for U-factors and solar heat gain coefficients (SHGC) on fenestration products in several climate zones. These amendments from the floor were not accepted in the energy chapter of the IRC.

In the absence of any technical documentation for the floor amendments, the Department conducted an initial analysis and posted the results on this web-site February 23, 2005. The Department has withdrawn this initial analysis pending the completion of further studies and the availability of more adequate cost information. It believes that there are deficiencies in its initial analysis and is still not satisfied by the efforts to revise the analysis. Specifically, the Department believes that more data is needed to fully address the potential cost impacts of various insulation options, and potential opportunity for the use of insulating sheathing for all building locations, including seismic and hurricane zones. DOE will use a review and comment approach before finalizing any analysis on the current IECC and IRC formulations. The Department believes that a comprehensive analysis is needed before a confident decision can be made regarding the 2004 IECC floor amendments.

For future rounds of code development, the Department anticipates performing additional studies and analysis that will address the potential for significant energy efficiency improvements based on results and findings from on-going residential and commercial building integration research and development. These future analyses will also be conducted with review and comment, and will likely go beyond the scope of the current amendments being considered.