IgCC Means Change, Not Catastrophe

Julie Ruth
December 2, 2011
COLUMN : Code Arena | Codes & Standards, Energy Efficiency

“Will Your Business Survive when Green Becomes Code?” was the title of the webinar. The promotional e-mail for the event implied that green construction would soon become code mandated due to the completion of the 2012 International Green Construction Code and that mandated compliance could threaten the survival of many businesses due to liability concerns.

Now, I am not a lawyer and I certainly am not in a position to provide you with complete assurance that the recent completion of the 2012 IgCC poses no threat to you from a product liability standpoint. But hopefully I can lessen the fear of the 2012 IgCC that this webinar seemed intended to impart.

First of all, just because the 2012 IgCC was completed in November 2011 does not mean it is now being mandated across the country. The published version of the 2012 IgCC will not be available until spring of this year. Once it is published, we can anticipate that it will begin to be adopted and implemented in a patchwork fashion across the country, as occurred with the other International Codes when they first became available.

The codes published by the International Code Council are model construction codes. They do not become law until they are adopted by a jurisdiction such as a state, county or city government. Also, if jurisdictions adopt the 2012 IgCC and implement it as an option only, it will not be a mandated requirement. Such has been the case with all jurisdictions that adopted one of the draft versions of the IgCC prior to its completion.

Bottom line: it is likely you will encounter one or more projects that call for compliance with the IgCC within the next few years. But it will more likely be because a builder, designer or owner has chosen to require it for a particular project rather than the jurisdiction mandating it. And it's quite unlikely that it will be required for all projects any time soon. This would literally take an act of Congress. The chance of that occurring is slight.

Secondly, although there are always concerns with how new code requirements are going to be interpreted and applied to building products, some level of success in reducing that concern did occur at the IgCC final action hearings in Phoenix last fall. Some of these issues included requirements for minimum component design life and life cycle assessment.

Minimum Component Design Life
The requirements for minimum component design life were based upon the new code's Building Service Life Plan for a building. A BSLP provides guidance for the ongoing maintenance and operation of the building–similar to a care and maintenance manual for a new automobile.

The draft versions of the IgCC would have required a minimum BSLP of 25 or 60 years, with electives for 100 or 200 year BSLPs. Part of the BSLP requirements were provisions for minimum component design life. The minimum component design life provisions were vague. It was not clear how the provisions applied to fenestration. Representatives of several different industries were also concerned that the requirements basically constituted an implied product warranty.

The 2012 IgCC will not specify minimum component design life. And there will not be a requirement for a 25 or 60 year BSLP for all buildings. The 2012 IgCC will allow its users to achieve one project elective by providing a BSLP for 100 years or two project electives for a 200 year BSLP for a building. So some benefit can be obtained for products that are demonstrated to have long service lives, but no minimum design life of components will be put into place.

LCA Defined, but Not Required
The proposed life cycle assessment provisions for the IgCC required evaluation of characteristics such as acidification, eutrophication, smog potential, ozone depletion potential and primary energy use. According to the testifiers at the IgCC hearings, scientists around the world agree on how to measure these characteristics. Unfortunately, this information had not been shared in the form of proposed code text. Instead, the proponents advocated the use of software assessment tools whose criteria were not defined.

Therefore, requirements for their measurement were determined to be vague and unenforceable. All the proposals that relied upon evaluation of these characteristics were disapproved. The end result is that the only reference to life cycle assessment that will be included in the 2012 IgCC is a definition of the phrase.

One of the reasons such drastic changes to the IgCC occurred between the previous drafts and the 2012 edition was a single code change proposal. That particular proposal, GG34, was strongly supported by some very influential active ICC members. These supporters understood many of the concerns industry and others had with the original drafts. They were also keenly aware of ICC’s commitment to publish the first model code for green construction in 2012.

GG34 drastically reduced the length of the IgCC by removing many of the provisions of concern, including the minimum component design life provisions and the LCA provisions. Had it been approved, it would have been a huge deal. Ultimately it was disapproved, but the proposal's potential to eliminate much of the IgCC text served as an incentive to the ICC active members to address some of these areas of greatest concern, with a positive result for industry overall.  Some of the other aspects of the IgCC of interest to our industry were the use of ASHRAE 189.1 and the energy conservation provisions.

ASHRAE 189.1
A proposal by AAMA (GG14) was approved with a modification from the American Iron and Steel Institute. GG14 allows the building designer or contractor to decide if they wish to use ASHRAE 189.1 with Chapter 11 of the IgCC, or the IgCC in its entirety. The approval of GG14 with this modification will be recommended to the ICC Board of Directors, and they will make the final decision with regards to the final reference to ASHRAE 189.1 in the 2012 IgCC.

Energy Efficiency in the IgCC
The 2012 IgCC requires the U-factor and SHGC for fenestration to be 10 percent lower than that of the 2012 IECC when the prescriptive energy compliance path is chosen. The prescriptive path will be limited to buildings less than 25,000 square feet in area. Buildings greater than 25,000 square feet will need to be designed to use 10 percent less energy than buildings designed in accordance with the 2012 IECC, using the performance-based path of that document.

Finally, in the 20+ years that I have been involved with construction codes, I have never seen new code requirements completely kill a product industry. I have seen dramatic product changes needed for an industry to survive. An example is the change to fenestration that we have seen due to energy conservation codes. But these changes have not killed the industry.

My daughter has a quote posted on her Facebook page that I believe is applicable here–“It is not the strongest of the species that survives, nor the most intelligent, but the one most responsive to change.”–Charles Darwin.



Code Arena is brought to you by the America Architectural Manufacturers Association. Julie Ruth may be reached through AAMA at 847/303-5664 or via e-mail at julruth@aol.com.