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 codes
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 dont 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 ICCs
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
OHare 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.
HERE to read all of the public comments.
HERE for the full development schedule and additional information
on the IGCC.
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