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Despite the best efforts of NAHB and representatives from home builders associations, public comment hearings last month on the International Green Construction Code (IGCC) public version 1.0 did little to address the concerns of builders.
NAHB representatives participated throughout the nine days of hearings on more than 1,500 comments on the new green code.
Sweeping changes were not made because a new committee seated by the International Code Council (ICC) to hear testimony and take action was composed primarily of members of the Sustainable Building Technology Committee (SBTC), the same group that prepared the first public draft of the code.
A key issue for NAHB is a reference to the National Green Building Standard (ICC-700). While the provisions of the IGCC are intended for commercial and industrial buildings, its scoping provisions stipulate that the requirements of ICC-700 shall apply to all residential occupancies.
The only exception is for high-rise residential buildings greater than 75 feet in height, which have the option of using either ICC-700 or the IGCC.
NAHB supported a proposal to delete this reference from the IGCC, because its inclusion would mandate building homes to the green standard in any jurisdiction adopting the IGCC, unless the jurisdiction amends it out.
NAHB also submitted a proposal to amend the current requirement by adding a simple “yes/no” checkbox for the inclusion of residential occupancies and the reference to ICC-700.
This would allow jurisdictions when adopting the IGCC to decide if it applies to housing — without having to amend the code, which is often difficult.
The IGCC Public Comment Hearing Committee rejected these and similar changes to the IGCC. Further, only the ICC Board of Directors has the authority to remove residential occupancies from the scope of the proposed green code, an action that the committee did not recommend.
Anticipating these decisions by the committee and knowing that any changes to the scoping provisions of the IGCC would require approval by the ICC board, NAHB has met with the ICC leadership on the need for this change.
Additionally, NAHB submitted a total of 51 comments and offered testimony on more than 480 other comments during the lengthy public hearings on the IGCC.
The current IGCC is written in mandatory language and seeks “to produce environmental benefits on a massive scale.” It mandates stringent minimum requirements and performance thresholds for the conservation of energy, water, natural resource and materials, as well as for indoor air quality, building operation/maintenance and owner education.
In testimony at the hearing, NAHB sought instead to set a reasonable entry level for communities seeking to establish green building requirements.
Since cost considerations were largely ignored during the drafting process, NAHB supported proposals to reduce more stringent provisions of the IGCC or to adopt them as “electives.”
For the most part, the committee rejected such proposals, choosing instead to follow a philosophy that the IGCC impose stringent mandates for green building.
A summary of the committee’s actions will be included in the full “Report of the IGCC Public Comment Hearing” scheduled to be posted on the ICC website by Oct 1.
While the drafting process may be nearing completion, the code development process is not.
After incorporating the approved changes, the ICC will release public version 2.0 by Nov. 3. This second public draft of the IGCC will then be subjected to a full code development cycle with two rounds of hearings in 2011.
NAHB will continue to seek changing the scoping of the IGCC for residential occupancies and giving jurisdictions more flexibility in selecting minimum requirements and performance thresholds for green building in their communities.
NAHB is preparing IGCC code change proposals that it will submit by the ICC’s Jan 3 deadline. The association is also seeking representation on the ICC code committee that will hear the proposed changes to the IGCC in 2011.
For more information on the IGCC public hearing results and code development activities in 2011, e-mail Don Surrena at NAHB, or call him at 800-368-5242 x8574.
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