IECC Debates Lead to Disapproval of EC14
Debates went past 2 a.m. Monday morning, but in the end the Advanced
Building Coalition (ABC) defeated the Energy Efficient Codes Coalition's
(EECC) International Energy Conservation Code (IECC) E14 proposal
and its companion appendix. Thom Zaremba represented the ABC, which
consists of the Association of Industrial Metalized Coaters &
Laminators - Window Film Committee; the International Window Film
Association; The Aluminum Extruders Council; APA; Nu-Wool Co. Inc.;
Pilkington North America Inc.; AGC Flat Glass North America Inc.;
Icynene Inc.; Craig Conner, Building Quality; and, Birch Point Consulting.
The group's objective is to promote a significant, cost-effective
increase in building energy efficiency and sustainability.
The EECC's website says EC14 was proposed to "boost the energy
efficiency of the 2009 IECC by 30 percent over the current model
code." EC 14 has been dubbed by EECC as "The 30% Solution."
EC 14 proposed changing fenestration U-factors for climate zones
one through four. Opponents said this would create inconsistencies
with the International Residential Code (IRC).
According to hearing documents, the ABC opposed EC14, as it represented
an "effort on the part of its proponents to actually introduce
inconsistencies into the ICC family of codes
while we strongly
support a cost-effective increase in the building energy codes,
the proposed 'solution' in EC14 is flawed." Comments from ABC
in the documents said, "as part of a strategy to eliminate
the energy provisions from the IRC, the proponents of EC14 did not
submit a single corresponding change to Chapter 11 of the IRC. Both
the IRC and IECC are widely used, and deviations between the two
codes will create confusion and enforcement complications.
Other reasons ABC opposed EC14 included:
- Structural and Life Safety Issues: The ABC claimed that
the energy codes must be viewed in conjunction with the building
codes, recognizing the importance of other building constraints
such as life safety and structural requirements. The group argued
that several components of EC14 did not account for these issues,
specifically, by ignoring the different considerations for hurricane
impact windows and wall-bracing design.
- Product Specificity: ABC representatives spoke in opposition,
saying the proposed code changes must be non-proprietary. The
group said EC14 would introduce code provisions that would give
certain products a competitive advantage in the marketplace, reducing
significantly the flexibility otherwise afforded by the IECC's
alternate performance path.
- Cost Effectiveness: ABC representatives commented that
during committee hearings, EC14 proponents did not provide any
detailed analysis of the cost impact of this proposal. Thos speaking
in opposition spoke of the importance of cost effectiveness and
affordability in terms of a building code's adoptability. Testimony
at the committee hearing demonstrated unacceptably long payback
periods for EC14 and its component proposals, according to ABC
- Procedural Flaws: ABC's comments noted that EC14 proposed
more than 100 additions and deletions to the existing code, and
that Rule 3.3.4 of CP# 28-05 provides that: "Proposals which
add or delete requirements shall be supported by a logical explanation
which clearly shows why the current code provisions are inadequate
or overly restrictive, specifies the shortcomings of the current
code provisions and explains how such proposals will improve the
code." ABC claimed that the proponent's statement in support
its code changes does not provide any information required by
Rule 3.3.4 and, as such "neither the committee nor the ICC
membership should be put to the burden of analyzing lengthy, complex
proposals that contain multiple parts to determine whether each
facet of the proposed change is technically justified."
Need more info and analysis about the issues?
HERE to subscribe to USGlass magazine.