The Future of the International Green Construction Code
If you build it, will they come? Or, more specifically, if you publish a new model code, should you assume it will be adopted and enforced? If you develop a new way to participate in code development, should you assume that your target audience (active code officials) will participate in that new process?
The International Code Council operated under the first assumption with the advent of the InternationalCodes in the late 1990s and early 2000s, and they were proven correct. The International Codes are now the most widely adopted, and enforced, set of construction codes in U.S. history.
The ICC operated under a similar assumption when they developed and published the InternationalPerformance Code. That code has not been adopted statewide in any state. Although it has been adopted by 16 local jurisdictions, it is not widely used or enforced.
About the same time period as the advent of the 2000 International Building Code and 2000 InternationalResidential Code, the National Fire Protection Association developed and published its own building code. The purpose of this code was to compete with the new I-codes. Who remembers NFPA 5000 Building Construction and Safety Code? NFPA could not even give it away. They offered to provide the book free of charge to jurisdictions that adopted it. Although initially there was some response to this offer, itquickly faded away.
ICC also partnered with the National Association of Home Builders in 2007 to develop ICC 700/NAHB National Green Building Standard - 12. That document has only been adopted by a couple of jurisdictions. According to the NAHB, however, thousands of dwelling units and developed lots have been certified as being in compliance with it.
Which brings us to the International Green Construction Code. It has been adopted on a non-mandatory basis in five states, and on a mandatory basis in the District of Columbia. Surely the revenue received by the ICC from the sale of IgCC code books in these areas cannot begin to cover the expenses they have incurred (both with regards to time and money) to develop this code? So the question becomes – how viable is the IgCC going forward? At what point will or should the ICC cut its losses and discontinue this new product line?
The question of adoptability was discussed during the ICC Sustainability Council meeting on April 27 before the IgCC Hearings began in Memphis. Some parties argued that adoption of the 2000 IRC and 2000 IBC was also scant, and there was no reason to be concerned about the tepid response to the 2012 IgCC. Others countered that the 2000 IBC and 2000 IRC replaced the legacy codes that adopting jurisdictions had relied on prior to the publication of the International Codes. Therefore, jurisdictions that wishedto update their codes had little choice but to adopt the International Building Code and the International Residential Code eventually. That scenario does not exist with regards to the IgCC.
If the IgCC does not begin to generate significant revenue for the ICC within the next few years, will the ICC have any choice but to discontinue their maintenance of the document? The ICC has continued to offer the IPC even though it is not widely used. But maintenance of that document has been of little to no expense. This is not the case with the IgCC.
The ICC has stated it remains committed to the IgCC. They have indicated they have no plans to discontinue its ongoing maintenance and development any time soon.
The ICC has also invested significant funds in the development of the cdpAccess system. The purpose of this system is to permit those active code officials who cannot come to the ICC hearings to still be able to participate in the process used to develop the codes their jurisdiction will hopefully adopt and enforce.
So, if you have a code that is not being adopted, and you have a new process you want to test, then thelogical thing to do, of course, is to test the new process on the code that is not being adopted. After all, you certainly would not want to test it on a product line that is successful.
The problem with that logic is that the ICC is now relying upon this unproven process to take a code that is not viable and make it viable. Selection of code change committee members who were dedicated to the development of a code that is adoptable and enforceable would have helped bring this about. But the ICC missed that opportunity. The committees disapproved almost all proposals that were submitted to improve the usability and adoptability of the IgCC.
The number of voters indicated in ICC’s recently released 2014 Report on the Committee Action Hearingsdoes not seem to indicate a significant increase in the code development process by those who actively enforce the codes, either. And this is the group whose input is needed to take the IgCC from its current form into a document that can be adopted and enforced by local jurisdictions across the country.
2015 IgCC Update
In the meantime, development of the 2015 IgCC continues. Some of the more significant results from the ICC Group C Code Change Hearings in Memphis, with regards to fenestration in commercial buildings, are as follows:
- Whole Building Life Cycle Assessment
The committee approved replacing some of the existing Whole Building LCA provisions of the IgCC, alongwith reference to ISO 14044, with reference to ASTM E2921 (GG85). ASTM E2921 is based upon ISO 14044, but provides more detail on just how LCA is to be conducted.
- Environmental Product Declarations
Several proposals to recognize products with EPDs were considered at the Committee Action Hearings. The committee approved adding definitions of Type III EPD and Program Operator (GG212), and enhanced recognition of EPDs (GG194) in the 2015 IgCC. The enhanced recognition is intended to be achieved by applying a multiplier of 1.5 to materials with EPDs that also meet the existing criteria of the IgCC for used, recycled, recyclable, bio-based or indigenous materials. The proposal that was approved, however, is vague and could be misapplied. The American Architectural Manufacturers Association will submit a public comment to correct this.
- Permanent Shading Devices
Several proposed alternatives to required permanent shading devices for fenestration were also consid-ered. All were disapproved, except one for exterior or interior reflective automatic shading devices (GEW72). AAMA had opposed all of these proposals as not being equivalent to the current provisions. AAMA also opposed the use of interior reflective automatic shading devices due to potential heat buildup in the glass exterior to the reflective shades.
- Prescriptive Energy
The 2012 IgCC requires the U-factor and SHGC of commercial fenestration to be 10 percent lower than that required by the 2012 IECC for the same climate zone and product category when the prescriptive design path is used. Multiple proposals were submitted to remove or revise these criteria. Although AAMA supported their full removal (GEW64), the committee approved a proposal that retained the requirement, but lowered the reduction from 10 percent to 5 percent (GEW66). AAMA will submit a public commentto remove the provisions entirely.
- Mandatory Daylighting Locations
Proposals by AAMA and the Aluminum Extruders Council to require mandatory daylighting in the same type and size of spaces under the 2015 IgCC as that which will be required in the 2015 IECC (GG260 and GG262) were approved. These spaces include office spaces, research and testing laboratories, and retail spaces larger than 2500 square feet in area but smaller than 10,000 sq. ft. in area. The 2012 IgCC requires mandatory daylighting in retail spaces over 10,000 sq. ft. in area.
- Moisture Control
The committee approved a proposal that will require special inspections of the installation of exterior window and door flashing, along with other moisture control provisions of the IBC (GG272). Special Inspections are to be provided by a third party agency, at a level above and beyond what can be provided by the local code official. AAMA supported this proposal, and will submit a public comment to correct an erratic cross reference.
- Replacement Fenestration
Multiple proposals regarding replacement fenestration were also considered by the committee. They approved a proposal that would require replacement fenestration to comply with the prescriptive provisions of the 2015 IECC when the entire existing fenestration unit is being replaced (GG290). AAMAhad supported this proposal.
- Exterior Sound Transmission
The committee also considered multiple proposals regarding exterior sound transmission, including one that would have banned use of single pane fenestration in some areas (GG248). AAMA opposed all of these proposals, and they were disapproved.
AAMA, and other interested parties, are now developing the public comments they intend to submit in response to the Committee Action. The deadline to submit public comments was July 16th. The public comments will be heard during the ICC public comment hearings, Oct. 1-7 in Fort Lauderdale, Fla.