Lengthy 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 Percent 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 comments.
• 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."
  

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