September 20, 2010
Nation's Building News

The Official Online Weekly Newspaper of NAHB

Department of Energy Unable to Document Energy Savings From Code Change Proposal

NAHB and a group of leading building industry trade associations have asked U.S. Department of Energy (DOE) Secretary Steven Chu to explain how the agency’s proposed revisions to the 2012 International Energy Conservation Code (IECC) will result in energy savings of 30.6% over the 2006 IECC.

The request was cosigned by APA — the Engineered Wood Association, BOMA International, the Vinyl Siding Institute and the Window & Door Manufacturers Association.

Sent on Sept. 20, the letter is a follow-up to a request for information that NAHB made under the Freedom of Information Act after DOE claimed the changes would result in a “reasonable and cost-effective” payback to consumers.

Responding to NAHB, the DOE’s Office of Energy Efficiency and Renewable Energy said it could not find any documentation to support the claim, including whether the proposal meets the 30% energy savings goal, but is continuing to search its files.

A number of advocacy groups, including NAHB and other trade associations, have each submitted proposals that would result in a 30% energy savings relative to the 2006 IECC, but each has important differences.

Proposals that concentrate on new requirements for the building envelope — generally supported by the insulation industry — use different methods than those that would require specific kinds of appliances and equipment.

NAHB has long supported energy code requirements that provide builders with the flexibility to meet the needs of consumers, such as allowing the builder to choose a particular combination of insulation, windows and appliances suited to the style of home and the construction budget.

“To evaluate these proposals, it is essential to understand the methodology that the department uses to evaluate energy savings,” the industry letter said.

“For example, in May 2010, the department reported that its proposed revisions for the 2012 IECC improve energy savings by 30.6% relative to the 2006 IECC, but it does not explain how DOE calculated the 30.6% energy savings estimate for the 2012 IECC proposal,” the letter said.

“The department should release this information to ensure that all stakeholders will have an open, informed and thoughtful dialogue during the upcoming public hearings on the development of the 2012 IECC, which will impact commercial and residential builders and developers, state and local governments and the American public,” it continued.  

Since 2006, legislation has been discussed in Congress that would mandate a national energy code for new construction, and lawmakers have looked to DOE to ensure that a 30% increase is feasible and not cost-prohibitive.

“If DOE is to oversee the implementation of state energy codes, it is imperative that the department provides the tools necessary to understand how and to what extent changes in a state’s adopted energy code meets or exceeds the national energy targets,” the letter said.

“Similarly, the American public and the regulated industry should have a meaningful opportunity to participate in the development of energy efficiency requirements that will impact their businesses and livelihoods. Otherwise, the government could make determinations and enforcement decisions regarding energy efficiency requirements and standards without publicly confirming that these decisions are based upon concrete, scientifically-supported information.“

The letter asked DOE to release its “formula, equations, calculations, methodologies and standards (including all technical assumptions, criteria, computer simulation model files and variables) used to calculate energy savings from pending legislation and proposed revisions to model energy efficiency construction codes and standards prior to the October 2010 hearings on the 2012 IECC.”

For more information, e-mail Larry Brown at NAHB, or call him at 800-368-5242 x8565.

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