Commenters Find Fenestration-Related “Flaws” in Draft of ICC Green Code
July 14, 2010

The International Code Council (ICC) is continuing its efforts to develop its International Green Construction Code (IGCC), and has posted the first set of formal public comments in the code’s development. Building envelope systems, including fenestration, are included in the document and a number of comments related to proposed changes to this section. For some commenters, however, parts of the document, particularly chapter 6 on Energy Conservation, Efficiency and Atmospheric Quality, still need major revisions.

Thomas D. Culp, Birch Point Consulting LLC, representing the Aluminum Extruders Council; Amanda Hickman, InterCode Inc., representing 3M Renewable Energy Division and The International Window Film Association; Thomas S. Zaremba, Roetzel & Andress, representing AGC Flat Glass North America Inc. and Pilkington North America Inc.; Henry Gorry, Guardian Industries Corp.; and Paul Bush, PPG Industries commented on section 606.1.1 and were critical of some references.

The comments state, “The current draft of this section contains many flaws including incorrect section references, references to R, C, and F-factors that don’t exist, missing product categories, and technically flawed criteria. For example, the fenestration criteria appear to partially come from an old ASHRAE proposal that was never approved, and three out of the four different categories for fenestration were also inadvertently removed, including curtainwall/storefront, heavy commercial metal-framed windows, and commercial entrance doors. As a consequence, only the values for residential-style nonmetal windows were kept, which simply do not apply to structural commercial products. This technical oversight raises life-safety issues based on the differences in structural performance, and results in criteria that make no technical sense.”

The comments continue, “For heavy commercial windows, this would require triple glazing in Hawaii, and sometimes even quadruple glazing in the middle and north of the country. Also of significant concern, ADA-compliant commercial entrance doors would not be able to comply. Finally, the inconsistency with the format of ICC’s own International Energy Conservation Code, as well as other standards like ASHRAE 90.1, ASHRAE 189.1, and ANSI/GBI 01, will create confusion for building code officials, designers, and manufacturers.

“Rather than force IGCC to start from scratch and develop a technically justified proposal, the correction proposed here is to simply reference the prescriptive tables of ANSI/ASHRAE/USGBC/IES Standard 189.1. With the new partnership between IGCC and ASHRAE 189.1, it makes sense to simply refer to the prescriptive tables of ASHRAE 189.1, as an appropriate high performance green standard that has already gone through a consensus based process.”

Public comment hearings will take place August 14-22 at the Westin O’Hare in Chicago. The Public Version 2.0 will then be posted for code change submittals on November 3. The deadline for submitting those code change proposals is January 3, 2011, with hearings scheduled for May 16-22, 2011 at the Sheraton Dallas Hotel in Dallas.

CLICK HERE to read all of the public comments.

CLICK HERE for the full development schedule and additional information on the IGCC.

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