2,400 Code Changes Under Consideration in Baltimore
Code change proposals that would have a significant impact on home building practices without providing any corresponding cost-effective benefits are among the issues to be discussed in Baltimore next week when the International Code Council holds the 2009-10 Code Development Hearings and Annual Conference Oct. 24 through Nov. 11.
The hearings are the first step toward the development of the 2012 ICC family of model building codes, including the International Residential Code and International Energy Conservation Code. The 2012 editions are expected to be available for adoption in mid 2011.
Members of the NAHB Construction, Codes and Standards Committee's Provisions Oversight Groups (POGs) met in Washington in late August to develop the association’s position supporting or opposing about 1,100 of the more than 2,400 code change proposals submitted this cycle and to decide how to respond to those proposals with the greatest potential to affect home builders and home buyers, especially those that will increase the cost of new homes.
Among the proposals submitted by NAHB is EC 16, which POG members have determined is the most comprehensive, affordable and flexible way to achieve a 30% increase in energy efficiency. This efficiency goal is supported by NAHB policy and has been cited by members of Congress as a key step toward combating global warming.
Though many proposals have been submitted to achieve this 30% goal, NAHB’s proposal, based on a performance/prescriptive approach, would allow builders to use equipment tradeoffs and other measures to achieve energy efficiency goals in a more flexible — and more affordable — manner. This is a key issue for first-time home buyers and for starter and workforce housing, POG members said.
NAHB believes its proposal will be much less complicated and less expensive to implement than competing proposals submitted by some energy efficiency advocate groups that focus exclusively on the building envelope or include specific products.
POG members have developed positions on a number of other energy code proposals, including:
- EC 46. This proposal would increase insulation requirements in ceilings to R-60 — the level now required only in extremely cold parts of the country. Such a large quantity of insulation is unnecessary in more temperate regions, NAHB will argue.
- EC 99. This proposal would require whole-house mechanical ventilation systems, a mandate that could significantly increase residential electricity consumption with little verifiable, corresponding benefit, POG members said.
- EC 100. This proposal would require separate zoned heating, cooling and controls for every 1,000 square feet of living space. Committee members will argue that requiring two separate heating and cooling units for a 1,200-square-foot home, as this proposal would effectively mandate, makes no sense.
- EC 123. This proposal would prohibit the use of electric resistance space heating no matter what the climate zone. Committee members question the value of requiring an expensive heat pump or similar heating equipment in areas of the country where supplemental heat is only needed a few days a year.
Energy issues are not the only code proposals that could have an immediate impact on home builders’ projects. Among other changes in the offing:
- Residential Fire Sprinklers. A number of proposals would effectively rescind the controversial September, 2008 decision to mandate fire sprinkler systems in all one- and two-family homes through the International Residential Code. Before their inclusion in the main body of the 2009 edition, the requirements had been contained in an appendix of the IRC, giving state and local officials the option of including them as a mandate if they decide these systems are needed in their jurisdiction. Since the publication of the 2009 IRC, a number of states have elected to remove the requirements from the code during the adopting process.
In an effort to maintain affordability where the fire sprinkler mandates have been adopted, NAHB has submitted proposals that provide construction methods and materials tradeoffs to reduce the overall cost.
- Green Building and Sustainability. Proposals have been submitted to mandate sustainability as the intent of every I-Code. These proposals are premature, POG members said, because the ICC already has begun work on its new International Green Construction Code (IGCC), which will cover all but non-institutional residential construction. Those projects — which include multifamily high-rise buildings — will still use the National Green Building Standard. When complete, jurisdictions can adopt the IGCC for sustainability programs rather than mandate these practices through the IRC and IBC.
- Wind and Seismic Maps. As part of a general updating of structural provisions to coordinate with the latest edition of ASCE 7 from the American Society of Civil Engineers, the IRC and IBC wind speed and earthquake ground motion maps will be significantly revised incorporating the latest science, modeling and historic data. If approved, builders in the Northeast will likely see reductions in design wind speeds along the coast. Builders in both the Central and Eastern regions will see reductions in areas where seismic design requirements are triggered.
- Wall Bracing Requirements. The ICC Ad-Hoc Committee on Wall Bracing has wrapped up its three-year effort to clarify and improve wood wall-bracing provisions. The committee will introduce a comprehensive proposal that reorganizes these provisions to provide the builder with a logical flow through the requirements. New tables and design aids would further ease the process of selecting wall bracing.
A second proposal introduces a simplified wall bracing method for one- and two-story houses in areas of low wind and seismic hazards. The method is limited to the use of plywood, oriented strand board or structural fiberboard sheathing and for exterior walls only. If approved, the method will provide for a quick selection of wall bracing for those simple houses that do not need the additional flexibility or the special wind and seismic design requirements found in the traditional wall-bracing provisions.
- Deck Construction. NAHB is concerned about a proposal seeking to increase the design loads for residential decks that was offered as a response to deck failures reported in the media. Where such incidents have occurred, they are almost entirely attributed to durability issues or failures of the deck-to-house connection. Provisions for deck ledgers new to the 2009 IRC address these issues.
NAHB believes the load increase is not warranted, would not further address issues of durability and would conflict with existing deck provisions and documents such as the American Forest and Paper Association’s DCA6.
- “Visitability.” A proposal that would mandate accessibility in new one- and two-family homes is raising concern for NAHB members. Requirements for at least one no-step, grade elevation entry cannot be met on all lots, particularly for homes built on lots with steep topographic elevations.
- Multifamily Accessibility. New requirements have been proposed for “Type B” units in multifamily buildings that far exceed those contained in the Fair Housing Act enforced by the Department of Housing and Urban Development — including a mandate that all existing buildings undergoing a change of occupancy to multifamily residential, or the renovation of an existing multifamily residential building, must fully comply with the act. Current federal law requires only multifamily buildings constructed for first occupancy after March 13, 1991 to comply. In addition, the courts have started to impose a two-year statute of limitations of filing suits against non-compliant buildings.
- Public Health Code. Another code proposal includes public health provisions for the ICC Property Maintenance Code, which can apply to renovation work. The introduction of requirements for working with radon, formaldehyde and lead paint, NAHB says, are regulatory issues already addressed by other federal agencies and should not be part of a building code.
- Swimming Pools. A proposal to move code requirements for swimming pools from the appendix to the main body of the International Residential Code is premature, NAHB says. The International Code Council is in the process of preparing a separate code for swimming pools to address safety issues contained in new federal regulations designed to be regionally appropriate, allow pool installers more flexibility in fulfilling the requirements.
- Dryer Duct Length. A typographical error in the last code change cycle caused confusion because in some sections of that provision, the dryer duct length was limited to 25 feet while in others, the limit is 35. Building officials have said that they support a proposal that would bring the requirement to a uniform length of 35 feet, allowing architects and builders more flexibility in design and placement of laundry equipment.
In the middle of the three-week-long public hearings, four days are devoted to the ICC annual business meeting, when the ICC Board of Directors will propose bylaw changes to settle a year-long controversy over voting privileges in the wake of last year’s fire sprinkler debate.
The development timeline for the IGCC will produce a 2012 edition of the document, and be a part of the 2012 family of I-Codes.
For more information, e-mail Calli Schmidt at NAHB, or call her at 800-368-5242 x8132.