Many Issues Still to be Tackled in IgCC
As many of you are probably aware, the International Code Council is developing an International Green Construction Code. The IgCC is designed to provide a “codified” document that can be adopted if a jurisdiction wishes to mandate green construction.
The IgCC differs from the Leadership in Energy and Environmental Design program. LEEDS is intended for use on a voluntary, project by project basis. The IgCC would be used for all new commercial buildings built within an adopting jurisdiction’s boundaries, which could bring “green construction” into the mainstream. Instead of just isolated instances of green construction across the country, as occurs with LEEDS, entire communities might adopt green construction practices. The intent is that “building green” would become the new “standard practice.”
This is a lofty ideal. I suppose it’s one worth aspiring to. Unfortunately, actual practice appears to be falling short. The document being promoted by ICC at this time–IgCC Public Version 2–contains language that is vague, conflicting and often simply unenforceable. The code change committees charged with moving this document one step closer to adoptability at the IgCC Code Development Hearings in May chose to rely quite heavily on “someone fixing this at the final action hearings,” scheduled for November.
It seems unlikely that everything that needs to be addressed in the IgCC will be “fixed” during those upcoming hearings. Resolving the concerns with the document would require the code officials who will be attending to come prepared to fix, within a few days, a mess that the IgCC committees have assembled over the course of the past couple years. To do this the potential voters would need to first find the time to review the entire document, the submitted code change proposals and public comments and their supporting statements and develop a thorough understanding of the concepts and issues at hand before the hearings. The possibility of this occurring is tiny.
The problem seems to be that code officials and the green advocates who have assembled this code speak two different languages. The green advocates do not understand the language of the code officials or their concerns. And having spoken “codese” myself for over 20 years, I have to confess trying to understand the language of the green advocates is just plain baffling to me. Are they aware that when buildings that too tight it means the occupants don’t get enough air to breathe? Or that gas fires in such buildings will go out if there is insufficient oxygen and that by doing so they could fill the air with gases that can a) kill people and b) explode? And what on earth is “acidification potential”? And how does one calculate what percentage of the material in a window, by mass or cost, is recycled, recyclable, biobased, used or indigenous?
That being said, some of AAMA’s largest concerns with the IgCC were addressed during the IgCC code development hearings that were held in Dallas in May. Specifically, a requirement that fenestration values “exceed the 2012 IECC by 10 percent” was replaced with language that specifies that both the U-factor and SHGC of fenestration in commercial buildings are to be “10 percent lower than that of the 2012 IECC” when the prescriptive method is used for energy conservation. AAMA opposed the application of a 10 percent reduction to the fenestration values, particularly to SHGC, but the approved language at least clarifies how “exceeds by 10 percent” is to be applied.
AAMA was successful in limiting the 10 percent provision to the prescriptive method for energy conservation only. It will not apply when performance-based or outcome-based design is used for energy conservation. AAMA was also successful in preventing another new prescriptive energy table from being added to the ICC family of codes by maintaining reference to the IECC.
The replacement of requirements for minimum fenestration area with requirements for minimum effective aperture was approved. The minimum effective aperture establishes a specific minimum ratio between the amount of daylighting provided and the size of the area daylit. Other sections of the IgCC contain requirements for specific sizes of daylit areas. So the net effect of this is to require a specific amount of daylighting to be provided into the interior space of the building.
Removal of the vague "component design life" provisions, as sought by AAMA, was approved. Three life cycle assessment alternatives to the criteria that 55 percent of materials, by mass or cost, are to be recycled, recyclable, used, and indigenous or biobased, were also approved. A life cycle assessment is an evaluation of the environmental impact of the materials used in a building "from cradle to grave." The three alternates are as follows:
- The entire building has a 10 percent improvement in overall energy performance and a life cycle assessment of the entire building demonstrates a 5 improvement in 3 of the 5 measures included in the table below (not including primary energy).
- A life cycle assessment of the whole project demonstrates a 10 percent improvement in 3 of the 5 factors listed in Item 1 above, or
- The environmental impact of the assemblies selected for the project for at least 3 of the 6 measures is less than the environmental targets established by the IgCC for that particular type of component, with at least 1 of the 3 complying measures being primary energy. (The environmental targets for windows are shown in Table 1).
|Environmental Targets for Windows|
|Nonrenewable Primary Energy Use (MJ) |
|Global Warming Potential (tons CO2 equiv.) |
|Acidification Potentinal (moles of H+ equiv.) |
|Eutrophication Potential |
(g N equiv.)
|Ozone Depletion Potential |
(mg CFC-11 equiv.)
|Buildings 5 stories or greater in height|
|Buildings 5 stories or less in height|
Now, do you know if your product meets any of these environmental limits? I have to confess, I do not have a clue myself if anyone’s product does, if everyone’s product does, etc. Nor does the IgCC provide any real guidance to determining this.
Probably the biggest disappointment to AAMA with regards to the IgCC code development hearings has to do with the use of ASHRAE 189.1. AAMA and several other interested parties had sought to give the building designer the option of choosing to comply with ASHRAE 189.1 or the IgCC. All the proposals that would have established this were disapproved. The jurisdiction that adopts the IgCC will have the right and responsibility to decide if ASHRAE 189.1 is to be used to demonstrate compliance with the IgCC. The designer or building owner will not have that option.
AAMA is developing public comments for consideration during the final action hearings of the IgCC. These hearings will be held November 2 to 6, 2011 in Phoenix, Ariz.