DOE IgCC Proposals Spark Some Concern Within the Fenestration Industry
March 30, 2011

The U.S. Department of Energy’s (DOE) proposed changes to the International Green Construction Code (IgCC) have been met with concern by some in the glass and fenestration industry. Among the concerns, Rich Walker, president and chief executive officer of the American Architectural Manufacturers Association, notes that even with proposals relating directly to the fenestration and glazing industry, the DOE still developed and submitted the code change proposals without industry input.

“Given the strong relationship between DOE and the window and door industry over the years, it is disconcerting that DOE developed and submitted IgCC code change proposals with no input from window and door manufacturers and suppliers,” says Walker. “This is in stark contrast to the industry's collaboration with DOE in the development of Energy Star® criteria and joint support of the 30-percent reduction in energy usage in the 2012 International Energy Conservation Code (IECC).”

Also a concern, Walker says some of the proposals submitted are inconsistent with the IECC in that they place more emphasis on a performance or outcome basis, which is measured after the building is built.

“Focusing on the actual performance of a building rather than prescriptive criteria is a better measure of the building's sustainability,” he says. “The concern is that many of the provisions proposed by the DOE will be difficult for code officials and many in the construction industry to meet. Examples of these provisions include the testing of an entire building for air leakage, the calculations of anticipated annual energy use and direct and indirect air emissions of carbon dioxide. While these measurements are certainly possible, there is very little guidance provided.”

Walker also says one of the DOE proposals would prohibit the use of ASHRAE 189.1 for low-rise residential buildings.

“ASHRAE 189.1 is not intended for use with one- and two-family dwellings and apartment buildings under three stories in height, as stated in its own scope. In effect, this DOE position is counter to AAMA Code Action Committee's support of the designer's right to choose compliance with ASHRAE 189.1 or the IgCC for buildings within jurisdictions that choose to adopt regulations for green or sustainable construction,” says Walker.

He adds, “Another DOE proposal includes a table that specifies maximum annual energy use by building occupancy in different climate zones. For buildings not specifically covered in the table of this proposal, the building must have an annual energy use not exceeding 67 percent of the baseline building calculated in accordance with Appendix G to ASHRAE Standard 90.1.”

Walker continues, “Codifying annual energy use by a building is very complicated and is another provision that both code officials and building industry professionals are not currently prepared for.”

The DOE will host a public meeting on April 14, 2011 from 9 a.m. to 4 p.m., at the Holiday Inn at 550 C Street SW in Washington, D.C., to discuss its proposed code changes. The proposals will be considered at the ICC public hearings taking place May 16-22, 2010 in Dallas.

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