Once again, the International Code Council (ICC) is holding hearings to consider code changes. Once again, billions of building dollars are at stake.
In April in Dallas, the ICC held the first of two public hearings to consider changes to the 2015 editions of the International Fire, Energy Conservation, Existing Buildings and Property Maintenance codes. More than 2,200 code change proposals – almost double the number of changes submitted in 2012 – are under consideration this year. One factor driving the larger number of proposals is the fact that energy conservation proposals are on the docket this year.
The Dallas hearings were conducted by code development committees for each particular code. Their recommendations are subject to the approval of ICC voting members at hearings this fall.
Top concerns in 2013 include three issues involving the codes’ appendix chapters, which are designed to allow state and local jurisdictions to decide whether to implement their specific provisions. Specific appendices must be identified whenever state and municipal governments adopt ICC codes.
Two issues negotiated last year – sprinkler system retrofits for existing buildings and the installation of firefighter air breathing replenishment systems for all buildings – were unanimously recommended for approval in appendices. Another concern is moving the requirement for building energy and mechanical system commissioning from its current position in the code body into an appendix. This change was recommended for disapproval by a split vote of the committees.
Coordinating the model codes with federal accessibility regulations, particularly with the revised ADA standards that went into effect in March of 2012, is an ongoing effort. The ICC’s goal for next year, when the 2012-2014 development cycle concludes, is to have comprehensive requirements that help owners to ensure that their commercial properties are fully compliant with the latest ADA regulations.
A Scorecard of Nays and Ayes
In the ICC process, we expect to see scores of proposals that add costly and unnecessary mandates to new and existing buildings. In my view, this year is no exception.
In response to objections raised by real estate advocates as well as many code enforcement officials, the following 26 proposals were among those recommended for disapproval by the ICC committees in Dallas. PageBreak
- Annual verification that design energy efficiency levels continue to be met by all existing buildings,
- Extensive verification or certification of compliance with ICC’s energy code (IECC) on all construction documents,
- Increased insulation levels for wall, floor, roof and window areas,
- A 26% increase in energy efficiency over current code for all designs using a performance energy analysis approach to demonstrate compliance,
- Mandatory whole-building testing of building envelope air barrier systems,
- Significant addition of insulation levels on all hot water piping as well as limits on the length of piping from hot water equipment,
- Mandatory retrofit of auto dimming controls on garage lighting,
- Installation of automatic HVAC system shutoff switches on operable windows and sliding doors,
- Extensive additional energy and water metering of subsystems,
- Deletion of the long-standing option to comply with the ASHRAE 90.1 energy standard,
- Solar-ready provisions for all new and existing buildings, including dedicated roof space and design chases for wiring,
- Proposal to mandate auto shutoff controls for at least 50% of all electrical receptacles,
- Mandated retrocommissioning for energy and mechanical systems in existing buildings, and
- Commissioning of hot water systems.
HEALTH & SAFETY
- Extensive annual indoor environmental safety inspections,
- Mold remediation triggered by permits for all renovation projects including tenant fit-out,
- Mandatory mold inspection prior to any property sale,
- Installation of sprinkler systems in work areas during renovation or other construction even if new fire system pumps must be provided,
- Radon abatement system installation triggered by renovation permits,
- Renewal of the certificate of occupancy for all existing buildings every five years,
- Elevator emergency recall and operation retrofits for all buildings less than 55 feet in height,
- Full lead abatement requirement upon the disturbance of any painted surfaces in buildings built prior to 1957,
- Mandatory placement of an automated external defibrillator in all building lobbies without a requirement for implementing a safety program or providing training for building staff,
- Installation of an external whole-building electrical disconnect switch for emergency responder use,
- Restrictions on hand sanitizer station placement and storage of refills in medical office buildings, and
- Installation of carbon monoxide alarms in all spaces in medical office buildings.
PageBreakProposals that did receive committee support, but which I believe have negative impacts on commercial buildings, include the following:
- Disapproval of proposals to relax minimum wall insulation and window efficiencies that are unsupported by cost/benefit analysis,
- Increased minimum efficiency levels for computer room equipment,
- A significant increase in the building floor area subject to daylighting requirements,
- Recommendation for disapproval of an exemption from minimum mandatory door insulation levels for high-speed industrial doors,
- Mandatory installation of automatic garage ventilation controls,
- Required installation of drain water heat recovery systems in all buildings,
- Disapproval of reductions of minimum insulation levels for HVAC ducts entirely within the thermal envelope,
- Installation of condensing water heating equipment in all new construction and replacements in existing buildings,
- More extensive use of occupancy sensor lighting controls, and
- Installation of new construction fire alarm and detection systems upon any change of occupancy.
The next challenge will be to ensure that the successes secured in Dallas are upheld and that detrimental changes are defeated at the ICC’s public comment hearings scheduled for October 2–9 in Atlantic City, NJ. Let code officials in your area hear directly from you. It is critical that they know what is important to commercial building owners and real estate professionals. Ballots will be cast by ICC voting members at the October hearings.
Your interests – and your pocketbook – are at stake.
Ron Burton is president of PTW Advisors, LLC and the former vice president of codes, standards, and regulatory affairs for BOMA, International.