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EC26
Sparks Debate; Approved as Modified
The International Code Council's Final Action Hearings experienced
a stalled pace yesterday when it reached EC26 of the International
Energy Conservation Code (IECC). The proposal generated an abundance
of interest and dragged out discussions for nearly one half hour.
Discussions especially slowed amid public comment number four. A
back and forth session among attendees included debate over a possible
conflict between impact-resistant requirements and energy codes.
As submitted, EC26 would effectively change the glazed fenestration
solar heat gain coefficient (SHGC) from 0.37 in climate zones one
and two to 0.35, and from 0.40 to 0.35 in zone three. Committee
action, which was approved yesterday, however, called for a 0.30
requirement across all zones.
The committee stated previously that it believed a 0.30 maximum
SHGC rating for fenestration in these zones was reasonable. It further
reported that it believed an ample number of products are available
to achieve this value. The committee suggested that its move to
go from 0.35 to 0.30 reflected a more aggressive value that would
be consistent with the level of stringency that present energy conservation
concerns call for.
The committee heard debate previously from industry representatives
stating that 0.35 was more reasonable than the suggested 0.30 from
a product availability point of view, but it ultimately decided
to stick with its 0.30. Debate re-ensued yesterday.
Public Comment One: 0.35 is Reasonable
Public comment number one, provided by Julie Ruth of JRuth Code
Consulting who also represented the American Architectural Manufacturers'
Association (AAMA), requested approval as submitted and stated:
"As originally submitted, EC26 established a maximum SHGC
of 0.35 in Climate Zones one, two and three for residential glazed
fenestration in the IECC. This would have been a 12.5-percent
reduction in the SHGC. This provided for some reduction in solar
heat gain, and hence anticipated cooling load, in the building,
while still allowing a certain amount of daylighting through the
fenestration products."
Comment one suggested that lowering the SHGC from 0.40 to 0.35
in the IECC would be a reasonable compromise that should result
in some net energy savings. Others felt 0.35 wasn't in sync with
current needs.
"Unfortunately, since the time the [original] proposal was
submitted, it has now become obsolete," said Mike Fischer,
representing the Window and Door Manufacturers Association (WDMA).
Fischer supported a 0.30 requirement, arguing that requirement changes
were moving at a slower pace than industry needs. "Guys, this
is a moving target. Please support the 0.30 not the 0.35,"
he further urged.
Zone Differences
Public comment number two expressed concerns over having the same
requirements for zones one, two and three. Issued by Ron Nickson
of the National Multi Housing Council, comment two suggested adjusting
zones one and two to a 0.35 requirement, while setting a 0.40 requirement
for zone 3. Nickson cited full building simulations as a tool for
determining requirements. Concerns were expressed by some individuals
over the data used, but Nickson rebutted by explaining only one
source currently was available.
Public comment number four, supplied by Thomas S. Zaremba, representing
Pilkington North America, and Tom Mewbourne, representing AGC Flat
Glass North America Inc, proposed modification to the committee's
action to afford greater flexibility in the design and use of hurricane
resistant-glass that complies with section 1609.1.2 of the International
Building Code. Opposing arguments zeroed in on possible conflicts
between IRC and IECC requirements and further focused on the need
for EC26 to focus on energy conservation needs, not public safety.
Fischer voiced concerns in this area as well.
"I think you've been sold a bill of goods today that we need
impact resistance," Fischer stated. "People will die this
year from house fires, because they're using space heaters and can't
afford to pay their energy bills ... lets not bring public safety
into this."
Proponents of public comment number four cited a conflict between
the use of single-pane, impact-resistant products and proposed energy
requirements.
"If you're a designer and you're going to design a piece of
glass in a hurricane-prone area, number one you're going to try
to minimize the amount of glass," argued Zaremba. "Most
of the glass involved in breakage in a hurricane is going to be
annealed glass ... it breaks into shards and it can kill you. That's
the cause for single panes of glass."
Ultimately discussions over EC26 re-centered on energy conservation.
Vicki Lovell, representing 3M and the Association of Industrial
Metallizers, Coaters and Laminators (AIMCAL), suggested a 0.35 requirement
would be more reasonable in the current times, arguing that product
availability would become an issue at 0.30 requirements.
"Energy efficiency doesn't work if we can't deliver the products,"
Lovell argued. "If you keep it at 0.35 and a builder wants
to exceed code, they can ... this is a minimum that everyone can
live with."
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