ICC Hearings Produce Some Disparities, But Also Some Favorable Results
My one prediction for the International Code Council final action hearings that took place in Minneapolis in September was that they were going to be quite lively— particularly with regards to the energy code discussions. There were 27 public comments that dealt with maximum U-factors for residential construction, and another 18 for maximum SHGC, also for residential construction. The hope of many of us involved in the process was that the final values in the 2009 International Energy Conservation Code and 2009 International Residential Code for the same exact building would be the same.
My fear was that the wide disparity that came out of the Palm Springs hearings last February would be upheld. To some extent, things worked out, in that the disparity between the IECC and IRC created last February was not upheld. At the same time, complete harmony between the 2009 editions of the two codes was not created, either. And the disparity that will occur between the IRC and the other International Codes will not be limited to just energy conservation. Examples of these include the disparity that will exist between the 2009 IRC and the 2009 International Building Code with regards to window sill heights and door opening size.
RESIDENTIAL U-FACTORS AND SHGC
Fueled by a push from the U.S. Department of Energy to achieve 30 percent energy savings for residential construction in the IECC by the year 2010, a significant part of the energy code hearings discussion focused upon maximum U-factors and SHGC in climate zones 1 to 4 for residential construction. Changes to U-factor were approved by both the IECC and IRC committees during the Palm Spring hearings, but the changes approved for the IECC were much more drastic than those approved for the IRC. The IECC committee also approved a drastic reduction in SHGC in climate zones 1 to 3, while the IRC committee approved a footnote that some might argue actually reduced the stringency of the IRC with regard to SHGC in southern climate zones.
As can be imagined, there were a number of parties that had their own idea of just how to help the ICC achieve the 30 percent target set by DOE. Fortunately for AAMA, U-values very similar to those proposed by AAMA for both the IECC and IRC were embraced by one of the more powerful groups involved in this discussion, the Advanced Building Coalition and the U-values supported by the Advanced Building Coalition were approved for both the 2009 IECC and IRC for residential construction.
Table 1 shows the current U-values for residential construction in the 2006 IECC and IRC, the values approved in Palm Springs by the IECC committee and the IRC committee, the values submitted by AAMA for consideration during the 2008 final action hearings and the values approved for the 2009 IECC and 2009 IRC.
Given the success of having the same U-values approved for both the 2009 IECC and 2009 IRC, and those being ones there were quite similar to those submitted by AAMA—both with regards to the U-values for regular windows and that given for impact resistant windows—it seemed reasonable to hope for the same results with regard to SHGC. Such, however, was not to be the case.
While the code officials assembled in Minneapolis voted to move the maximum SHGC permitted in climate zones 1 to 3 for residential construction to somewhat middle ground between IECC committee- and the IRC committee-approved levels in Palm Springs for the 2009 IRC, they did not make the same move for the 2009 IECC. Therefore, the maximum SHGC for fenestration in residential construction will be different in the 2009 IECC than it will be in the 2009 IRC. Table 2 shows the current SHGC values in both codes, the values approved in Palm Springs, the values submitted by AAMA and the values approved for the 2009 IECC and 2009 IRC.
So the U-factors for residential construction will be the same in the 2009 IRC as they are in the 2009 IECC, but the SHGC will not be. As a point of reference–the IRC applies to one- and two-family homes and townhouses three stories or less in height. The scope of the IECC for residential construction applies to one- and two-family homes and townhouses as well, but also includes other multifamily buildings such as apartment buildings, as well as dormitories and assisted living facilities, all three stories or less in height.
SILL HEIGHTS AND WINDOW OPENING LIMITING DEVICES
The disparity between the 2009 IRC and the 2009 edition of other International Codes will not be limited to energy conservation. Two other divergent areas of interest to our industry include the requirement for minimum window sill heights, and minimum door size.
As many of you are probably aware, provisions requiring the sill of operable windows to be at least 24 inches above the interior floor, when certain other conditions apply, exist in both the 2006 IRC and IBC. The intent of these provisions, although no evidence has been provided to support it, is to try to reduce the likelihood that young children will fall out of the window.
There are a couple of exceptions to this provision, but they are rather unsatisfactory, particularly for windows that are required to meet the emergency escape and rescue opening requirements of the IBC or IRC. The exceptions include limiting the opening of the window to no more than 4 inches or equipping the window with a window guard that meets ASTM F2006 or ASTM F2090. Limiting the window opening to no more than 4 inches is not an option if the window is required to meet the emergency escape and rescue opening requirements. And while window guards may be an effective mechanism for preventing falls, there is a concern that the homeowner who wants to look at the view out the window and not at a window guard, may be inclined to remove them once they have taken occupancy of the home.
Due to the amount of time that was spent on this issue during past code hearings, the ICC board of directors assigned the topic of Window Falls to the ICC Code Technology Committee in 2006. The committee studied the issue and came back with a recommendation that an additional option be added–that of equipping the window with what came to be known as a window opening limiting device (WOLD) or window opening control device (WOCD). A proposal to provide an exception to the 24 inch sill height requirement for windows equipped with these devices was considered in February and disapproved for both the IRC and IBC. The Code Technology Committee came back with three Public Comments that would have 1) raised the minimum sill height from 24 inches to 36 inches, 2) revised the language of the original proposal or 3) replaced language in the original proposal for Window Opening Limiting Devices with reference to a revised edition of ASTM F2090 that added provisions for window opening control devices to the existing standard for window fall prevention devices.
Although AAMA supported the public comment that referenced ASTM F2090 for window opening control devices, this support was contingent upon the completion of a revision of the standard that adequately addressed these devices. Concerns with the proposed revisions to F2090 were not completely resolved within the ASTM committee prior to the onset of the hearings. Some members of industry with experience in residential and commercial construction have a concern over the liability that might be established when WOCDs become considered part of a fall prevention device standard. Their preference is that a standard for WOCDs be separate from the standards that apply to window fall preventions devices (ASTM F2090 and ASTM F2006). The public comment to reference ASTM F2090 was withdrawn by its proponent, and AAMA supported the public comment that revised the original language and added an exception for window opening limiting devices to the minimum sill height requirements.
These provisions were approved for the IRC, but not for the IBC. Specifically, the 2009 IRC will include an exception to the minimum sill height requirements for windows that are equipped with window opening limiting devices that restrict the initial opening of the window to no more than 4 inches, but which, when released, permit the window to open further. The window opening limiting device is to:
➣ Release with no more than 15 lbs force;
➣ Be operable in all kinds of weather;
➣ Be clearly identified for use and;
➣ Not reduce the minimum net clear opening below that required for an emergency escape and rescue window, if the window is required to meet those size limits.
Another disparity that will occur between the 2009 IRC and 2009 IBC has to do with the height of egress doors. While a code change proposal by AAMA that would have established a minimum clear opening width of 32 inches and a minimum clear opening height of 78 inches was approved by the IRC committee, it was modified by the IBC committee to increase the minimum clear opening height to 80 inches. The action of the IRC committee was upheld during the final action hearings, while the change approved by the IBC committee to increase the clear opening height to 80 inches was withdrawn from consideration. The net result is that both the 2009 IRC and 2009 IBC will require the clear opening width of means of egress doors to be 32 inches, measured from the door stop to the face of the door; but the 2009 IRC will require the clear opening height of that same door be 78 inches, while the 2009 IBC will require the door itself to be a minimum height of 80 inches.
A number of other code change proposals and public comments of interest to our industry were disapproved in Minneapolis. These included the S141 provisions to require all exterior doors to be tested and labeled to AAMA/WDMA/CSA 101/I.S.2/A440, changes to the requirements that specify when a PE signed report is needed if the framing supporting glazing deflects more than L/175 when tested, provisions to recognize the use of ANSI/SDI A250.13 for the interchangeability of door components and provisions to require daylighting in large, open spaces of certain occupancies.
The AAMA membership will be considering the results of these and other code change proposals over the next few months, as preparations begin for the 2009/2010 ICC code change cycle. Like the song that never ends, code development just goes on and on my friends. And we cannot afford to just sit idly by as it does. The deadline for 2009/2010 code change proposals is March 24, 2009. It will be here sooner than any of us think.