Tuesday, March 8, 2011

4 - The IGCC is totally unnecessary – It requires extensive municipal code-effort to comply with

As a continuation to my previous commentary on the IGCC; this article involves two aspects: a) the effort by a municipality to perform permit-reviews; and, b) the effort by the A/E to prepare documents for permit-submission.

a) Getting a building permit in the City of Houston (my hometown jurisdiction – C of H) is a pain. That’s because the C of H utilizes a “thorough-plan-review” system, which gives broad powers to the plans examiners, and less power to the field-inspectors. Unfortunately, the pain increased when the city underfunded its pension obligations, and many experienced plan-examiners / inspectors “retired” to take advantage of generous benefits. Now that the C of H has a true “budget crisis” (endemic to most municipalities), I expect the pain to increase further. The C of H recently announced that “pink slips” will be distributed through all departments – including the permit-review department. So not only will the C of H be understaffed, but the experience-level of the plans-examiners was already, and now is further, weakened. Don’t believe me? Click on this link to see the wide-spread financial problems impacting cities – click on the second link to see the impact on states:



Enter the International Green Construction Code (IGCC). A review of the code provisions shows that the plans-examiner must be educated and capable in reviewing the following required permit (submitted) documents:

· Inventory and assessment of “natural resources and baseline conditions” of the building site (402.3.1),
· Design to elimination of potable water abuse - for irrigation systems (402.3.*),
· Design of “reclaimed or collected rainwater” systems - for ornamental fountains and water features (402.3.4),
· A Soil and water quality protection plan (402.3.5.1)(406.6),
· Calculations for compliance with the limitations on “turfgrass” planting on the project site (402.3.5.7),
· A building site waste management plan – including methodology toward recycling or salvaging 75+% of site soils, “rocks, trees, stumps, and associated vegetation” (402.3.6),
· Calculations for compliance with the requirement for showering and changing facilities (if long-term bicycle parking is required in 403.3) (403.2) – documentation of the facility-design is required if compliance is mandated,
· Calculations for compliance with the requirement for long term and short term bicycle parking (chart of compliance requirements included in IGCC (403.3) – documentation showing bicycle locations and signage is required if compliance is mandated,
· Calculations for compliance with the requirement for preferred “high-occupancy vehicle parking” (403.4.1) – documentation showing parking locations and signage is required if compliance is mandated,
· Calculations for compliance with the requirement for preferred “low-emission, hybrid, and electric vehicle parking” (403.4.2) – documentation showing parking locations and signage is required if compliance is mandated,
· Submission of 10-year canopy growth of all planted trees, and canopy-contribution of existing trees – including shading calculations (404.2.3),
· Calculations for reduction or elimination of light pollution (405.1),
· Written periodic maintenance protocol for all landscaping and stormwater management systems (406.6(3)),
· Basis-of-design utilized in determining compliance with the building material design-life (minimum mandated percentage) (503.2),
· A building-service-life-plan (505),
· The schedule-of-inspections (by an approved agency) for review of moisture control preventative measures – outside envelope,
· Details for compliance with the Zero-energy performance index (602.1),
· Usability of the building energy (model) simulation (603.5),
· Documentation reflecting the methods for ensuring energy metering-monitoring-reporting (604),
· Documentation ensuring offsite control of HVAC and lighting through Auto-DR interface (605.1,605.3,605.4),
· Design for rough-ins for “future” solar-hot-water systems (608.4),
· Design for plug load controls (609.6),
· Verification of inclusion (on the design team) of a commissioning agent (610.3.1),
· Design and delineation of on-site renewable power provisions – physical devices (611),
· Notations requiring post-occupancy re-commissioning-repeated 18-24 months after issuance of the C of O (612.3.5),
· Documentation requiring building envelope commissioning prior to issuance of the C of O (612.4),
· An indoor air quality management plan (in-place during construction) (801.2),
· Documentation stipulating the requirement for indoor air quality testing (after construction) – flush-out or IAQ-testing (804.3),
· Location and specification for required entry mats (804.4),
· Documentation reflecting the emission limits for “glued wood products” – interior and exterior (part of the “weather covering”) (806.1),
· STC ratings for exterior wall and roof assemblies (807.1-.5),
· Specifications for acoustics verification and testing (post construction) demonstrating compliance with the acoustic sections (807.5),
· “Daylit area” calculations to verify compliance with the required percentage of interior day-lighting (808.3),
· Commissioning Specifications and timetable for commissioning (903),
· Specifications stipulating O & M documentation, maintenance, and education (904.1-904.4),
· Specifications indicating the intervals and format for submission to the “local jurisdiction” of energy reporting / audits (904.1.1)(1003.3.1),

Frankly, there’s no way that the plans-examiner (primarily due to skills, pay, and energy levels) will review all (if any) of these code-mandated requirements; so guess what, the list of requirements will turn into a checklist – a checklist that (you guessed it) the architect (and other consultants) will be required to complete and verify through the construction documents. And this leads me to “b” – the second aspect of this article.

b) Envision the amount of additional work that the A/E will be required to perform in order to submit and obtain a building permit, since all of the submission-requirements listed above must be included in the “construction documents”. The IGCC is very specific:
“Documentation for compliance verification is based upon:

“Construction documents [that] shall be dimensioned and drawn upon suitable material. …Construction documents shall be of sufficient clarity to indicate the location, nature and extent of the work proposed and show in detail that such work will conform to the provisions of this code and relevant laws, ordinances, rules and regulations, as determined by the code official. The construction documents shall contain a listing of the applicable project electives in accordance with Section 303, and shall include the applicable commissioning requirements in accordance with Section 903. Where special conditions exist, the code official is authorized to require additional construction documents.

“Project Electives (if required by the jurisdiction) shall be selected by the owner. “Such project electives shall be applied as mandatory requirements to the project and shall be indicated to the code official by means of completion of Table 303.1. The submitted construction documents shall include a completed copy of Table 303.1 indicating which project electives that the owner has selected as a means to comply with Section 303.1. The total number of project electives selected shall be in accordance with the minimum number of project electives indicated by the jurisdiction in Table 302.1. The Project electives selected shall be applied and enforced as mandatory requirements.”

What joy – more effort and more liability – because, what now is an additional, elective service (LEED), would become (if the IGCC is adopted) multiple code-mandated requirements.

There’s no doubt that the IGCC requires extensive municipal code-effort to comply with its provisions – mostly falling on the shoulders of the A/E professional. For this reason, I contend that the IGCC is totally unnecessary.

Next time: 5 - The IGCC is totally unnecessary – It financially rewards those who promote its “necessity”…

BTW: LEED is a trademark of the U. S. Green Building Council’s Leadership in Energy and Environmental Design rating system.

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