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November - December 2003

CODE/CONCERNS
MFischer

ICC Cycle Update
Window and Skylight Industry Stays Focused

by Michael Fischer

The 2003 International Codes were released earlier this year and the 2003/2004 International Code Congress (ICC) code development cycle is well underway. 

Important Deadlines
Code committee hearings were held in Nashville, Tenn., in September, and the “Report of the Committee Hearings” is due to be published by the ICC in mid-November. Public comments to the committee hearing results are due back to the ICC by January 14, 2004, with “Final Action Consideration” hearings set for May. All of this activity will result in the 2004 supplements to the International Codes, but the deadline for submittals to the ICC for the next code cycle—which will result in the publication of the 2006 I-Codes—is August 2004. 

The ICC calendar will set the agenda for the code and regulatory activity of the window and door industry as we continue our involvement in code development. One of the other considerations for standards-writing organizations is the standard revision calendar. Correlating the release of newer versions of standards with the ICC calendar and code proposal submittal deadlines will be a critical step in ensuring that the most recent, up-to-date technical standards are included in the building codes. 

DOE Proposal
There are many important issues under consideration during the current code cycle. One of the most important to the window industry is expected to dominate the testimony during this cycle. 

The U.S. Department of Energy (DOE) has proposed a comprehensive re-write of the residential energy code prescriptions in the International Energy Conservation Code (IECC). This proposal, if approved, would:

• Eliminate window area restrictions for residential construction;

• Revise the climate maps to correlate more closely to Energy Star® provisions; and

• Further define prescriptive requirements for room additions, including sunrooms.

The DOE has been working on this proposal for several years. In October 2001, Pacific Northwest National Laboratory (PNNL) published a white paper on the elimination of window wall ratios, the cornerstone of prescriptive window requirements in the IECC. The PNNL report contained detailed data regarding architectural window usage and makes the case that even in areas where there are no regulatory restrictions on the maximum allowable window-to-wall ratios, residential design generally falls within widely accepted norms. According to the PNNL white paper, “The available data offers no evidence that window areas will rise significantly in the absence of an area restrictive code. Although it is certainly possible, even likely, that a few homes will be built with a very high window area that otherwise would have had less glazing and/or higher insulation levels, the number of such homes will be very small. Natural market forces are a much stronger determinant of glazing areas than energy codes.” 

The DOE believes its proposal could have a positive impact on the energy performance of residential construction in the United States. “DOE believes this proposed change, if adopted, will result in a much easier to use code, easier and hence more widespread adoption of IRC/IECC based state codes, easier and less expensive enforcement and more consistent compliance even in jurisdictions with minimal enforcement infrastructure,” said the DOE’s Ron Majette.

Key Points of Proposal
The elimination of the window-to-wall ratios, while controversial, would certainly simplify the IECC. The PNNL report addresses likely effects of the simplification. An excerpt from the overview chapter of the report reads:

Eliminating window-area dependence will increase code adoption, compliance and enforcement. Simplifying the code will lead to increased compliance in locations that use the IECC and less resistance to adopting the IECC in jurisdictions that have not adopted the code.

Eliminating window-area restrictions will not have a detrimental impact on energy use. Although a potential exists for an increase in energy use, the increase is smaller than might be expected and can be negated easily on average by carefully designed revised code provisions. (Our proposal would result in windows that meet or exceed Energy Star specifications in at least half of the United States.)

Window-area restrictive codes appear to have little effect on the actual window areas of houses. Evidence shows that natural market forces keep window areas at reasonable levels even without the presence of an area-restrictive energy code. 

Energy savings will increase overall. The energy neutrality of the proposed new requirements combined with the increased likelihood of adoption, enforcement and compliance will lead to increased energy savings.

The DOE proposal to the IECC is one of the most comprehensive code changes yet. The results of the code cycle have yet to be determined, but it is clear that the effects of the proposal on the window and skylight industry are potentially enormous. While this proposal is being addressed during this supplemental code cycle, be assured that attempts will be made to reintroduce some elements or to provide further refinements via future amendments, especially during the 2006 ICC code development cycle. 


Michael Fischer serves as director of codes and regulatory compliance for the Window and Door Manufacturers Association, based in Des Plaines, Ill.

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