Memorandum

City of Lawrence

Planning & Development Services

TO:	David L. Corliss, City Manager
FROM:	Barry Walthall, Building Inspections Manager
C:	Scott McCullough, Planning & Development Services Director Kurt Schroeder, Asst. Director of Planning & Development Services Mark Bradford, Fire Chief Building Code Board of Appeals Electrical Code Board of Appeals Fire Code Board of Appeals Mechanical Code Board of Appeals Plumbing Code Board of Appeals
DATE:	April 15, 2015
RE:	Review of 2015 International Code Council Model Building Codes

Planning and Development Services Department (PDS) and Fire and Medical Department staff has begun work with advisory boards on review of the 2015 International Code Council (ICC) model building codes for possible adoption by the City. The ICC model building codes are a “family” of codes (also known as “I-Codes”) that regulate the construction of buildings, installation of building systems and fire protection systems, handicap accessibility and energy conservation. The City has currently adopted the 2012 editions of the I-Codes, including:

· International Building Code (IBC)

· International Residential Code (IRC)

· International Fire Code (IFC)

· International Existing Building Code (IEBC)

· International Energy Conservation Code (IECC)

· International Fuel Gas Code (IFGC)

· International Mechanical Code (IMC)

· International Plumbing Code (IPC)

· International Property Maintenance Code (IPMC)

· National Electrical Code (NEC)

A listing of advisory Boards involved with reviewing these codes, the codes for which they are responsible, and a brief summary of the intended purpose of each of the codes under review is included at the end of this memorandum. Staff anticipates reviews will be complete and ordinances drafted for City Commission consideration in the last quarter of 2015 for a recommended effective date of July 1, 2016.

The City currently reviews building permit applications under the 2012 I-Codes, which became effective on July 1, 2013. ICC updates these codes on a three-year cycle and the City strives to update the codes on the same cycle. Timely adoption of the most current building codes has been identified by consultants in the past as an improvement of the City’s development process, and by the Insurance Services Office, Inc. (ISO) as an important factor in the evaluation of the community’s ISO Building Code Effectiveness Grading Classification (BCEG). The City’s current BCEG classifications are 4 for one- and two-family residential construction, and 3 for all other construction. According to the ISO website, only 16% of building departments achieve classification ratings of 3 or better, and 67% are rated between 4 and 6. Ratings are assigned on a scale of one to ten, with one being best.

The public may provide input concerning the 2015 codes during the advisory board review period and directly to the City Commission when draft ordinances are brought forward for consideration. Staff informs known stakeholders of the review process and solicits input throughout the advisory boards’ reviews. The community will be kept informed through communication with professional organizations such as the Lawrence Home Builders Association as well as the City’s list services for the advisory boards. The building community is heavily represented on the advisory boards, the membership of which includes builders; mechanical, electrical, and plumbing contractors and trades workers; and design professionals such as architects and engineers.

Identified Code Issues in this Review Cycle

Energy Conservation Code

Since the adoption of energy conservation standards with the 2006 I-Codes, which became effective in Lawrence on January 1, 2008, energy conservation measures have consistently been among the most significant code changes as newer codes have been developed. The 2015 I-Codes continue this trend, with changes estimated to improve energy conservation of new residential buildings by approximately sixteen percent (16%) compared to the 2012 editions of the I-Codes, and by forty-six percent (46%) cumulatively over the last three code cycles when compared to energy conservation requirements in the 2006 editions of the I-Codes.

The 2015 IRC incorporates an “Energy Rating Index” (ERI) approach for energy code compliance that is similar to a current City Code amendment that allows builders to demonstrate equivalent compliance using the Home Energy Rating System (HERS). HERS is an ERI approach that could continue to be recognized by the City of Lawrence under the 2015 I-Codes. An ERI is a system of evaluating design and construction of a home based on a numerical scale of 1 to 100 which is performed by a certified rater. A home with a rating of 100 is considered to be equivalent to a home constructed in compliance with the prescriptive requirements of the 2006 IRC. A rating of 70 is considered equivalent to the prescriptive requirements of the 2012 IRC; and a rating of 54 is designated as equivalent to the 2015 IRC. The benefit of utilizing an ERI approach is that builders can get credit for elements of the building that exceed energy code requirements to make up for other elements that are less energy efficient. For instance, exterior wall insulation requirements increased in the 2012 IRC. Rather than build thicker walls to accommodate more insulation, or supplementing wall cavity insulation with exterior foam sheathing, the builder could provide some combination of improvement in other components, such as higher efficiency heating and air conditioning equipment, additional attic insulation, or higher efficiency windows.

The City amendment to the 2012 IRC recognizing the HERS alternative compliance method was developed through a collaborative effort among the Building Code Board of Appeals, the Lawrence Home Builders Association and PDS staff, and became effective with the adoption of the 2012 I-Codes on July 1, 2013. The minimum required HERS rating was assigned an incremental schedule for implementation to allow builders to become acquainted and gain experience with the construction methods necessary to achieve minimum ratings; the minimum score was 80 for homes during the first year of adoption (July 1, 2013 through June 30, 2014), 75 for the second year (July 1, 2014 through June 30, 2015), and ultimately achieving scores of 70 or lower thereafter.

Feedback from the LHBA has been that achieving a score of 54 or lower may be a challenge for some types of homes, especially smaller homes and homes that are built on a slab foundation. The LHBA opinion is that Lawrence is a leader in the state of Kansas and Midwest region for energy code stringency. Based on this opinion, the LHBA questions whether now is the time to continue to lower the index score. The Building Code Board of Appeals has received this feedback and will deliberate on a recommendation to the City Commission on setting index scores for the 2015 IRC. The goal for staff is for there to be a consensus reached between all stakeholders on the ERI index score/s. An option may be to assign index scores based on criteria such as foundation type or the total conditioned area of the home.

Arc-Fault Circuit-Interrupters

The Electrical Code Board of Appeals will also have an issue requiring significant debate – the required installation of electrical devices known as “arc-fault circuit-interrupters” (AFCI’s). An AFCI is defined in the 2015 IRC as “a device intended to provide protection from the effects of arc-faults by recognizing characteristics unique to arcing and by functioning to de-energize the circuit when an arc-fault is detected”. More simply put, an AFCI is a circuit breaker or receptacle outlet that senses when there is a problem in the electrical circuit and shuts the power off to prevent loss of life and property due to fire. Such problems may occur within the permanent wiring of the house, or within cord connected appliances or equipment.

Requirements for installation of AFCI devices first appeared in the 1999 National Electrical Code, and the AFCI electrical provisions of the IRC have mirrored the provisions of the NEC ever since. The 1999 NEC required AFCI protection only for receptacle outlets in bedrooms. Since the initial requirements for AFCI protection, subsequent NEC and IRC code editions have incrementally increased the locations where AFCI protection is required in dwelling units, including kitchens, family rooms, dining rooms, living rooms, parlors, libraries, dens, bedrooms, sunrooms, recreation rooms, closets, hallways, laundry areas and similar rooms or areas. Kitchens and laundry areas are new to the list in the 2014 NEC and 2015 IRC.

The City of Lawrence Code has not kept pace with the incremental expansion of AFCI protection requirements in the NEC and IRC. The City Code currently amends the NEC and IRC to require AFCI protection only for bedroom outlets. Justification for amending these requirements has been based on concerns that the technology was not fully developed and tested prior to inclusion in the codes, and on reports from electrical contractors of excessive nuisance tripping; there has also been concern about the cost of the AFCI devices. Staff is recommending that the Electrical Code Board of Appeals thoroughly review the AFCI requirements as part of the current code review. Staff is not aware of any recent reports of malfunctions of AFCI devices, and concerns about the technology may no longer be valid since the requirements continue to expand. Costs may continue to be an issue, but as the locations requiring protection are expanding, so too are methods to provide protection. Cost impacts may be less than some builders currently anticipate due to new wiring methods; greater demand may also reduce cost as suppliers would routinely stock these items rather than carry them as specialty items.

Plumbing Fixtures

Although there are not significant changes being made to requirements for numbers of plumbing fixtures and restrooms in the 2015 codes, staff has had frequent input from designers and business owners that requirements for some types of businesses, particularly in existing buildings, are too stringent. Staff is therefore recommending that the Building Code Board of Appeals and Plumbing Code Board of Appeals review these requirements as well, including a study of how these requirements have changed over time.

Advisory Boards Reviewing 2015 International Codes

Building Code Board of Appeals

· International Building Code

o The IBC is the foundation for the complete set of I-Codes with principles based on protection of public health, safety and welfare. The IBC establishes code provisions for structural and non-structural building elements for all structures other than one- and two-family dwellings and townhouses that are regulated under the IRC.

· International Residential Code – Chapters 1-10, Building Planning and Construction

o Chapters 1-10 of the IRC address building planning and construction for one- and two-family dwellings and townhouses up to three stories.

· International Residential Code – Chapter 11, Energy Conservation

o Chapter 11 of the IRC addresses energy conservation requirements for one- and two-family dwellings and townhouses up to three stories, including building requirements for the building envelope and installation of mechanical, electrical, and plumbing systems. Chapter 11 is jointly reviewed by the Building Code Board of Appeals, Electrical Code Board of Appeals, Mechanical Code Board of Appeals, and Plumbing Code Board of Appeals.

· 2015 International Existing Building Code

o The IEBC contains requirements intended to encourage the use and reuse of existing buildings. The scope covers repair, alteration, addition and change of occupancy for existing buildings and historic buildings, while achieving appropriate levels of safety without requiring full compliance with the new construction requirements contained in the other I-Codes.

· 2015 International Energy Conservation Code

o The IECC establishes minimum regulations for energy-efficient buildings using prescriptive and performance-related provisions.

· 2015 International Property Maintenance Code

o The IPMC provides requirements for continued use and maintenance of existing residential and nonresidential structures.

Fire Code Board of Appeals

· 2015 International Fire Code (IFC)

o The IFC contains regulations to safeguard life and property from fires and explosion hazards. Topics include general precautions, emergency planning and preparedness, fire department access and water supplies, automatic sprinkler systems, fire alarm systems, special hazards, and the storage and use of hazardous materials.

Electrical Code Board of Appeals

· 2014 National Electrical Code

o The NEC is not included in the I-Codes family of codes, but is published by the National Fire Protection Association. The NEC is the electrical code standard referenced by the I-Codes, and is the source document for the electrical provisions contained in the IRC. The NEC addresses the design and installation of electrical systems not regulated by the IRC.

· International Residential Code – Chapter 11, Energy Conservation

· International Residential Code – Chapters 34-43, Electrical

o Chapters 34-43 of the IRC address installation of electrical systems in one- and two-family dwellings and townhouses up to three stories.

Mechanical Code Board of Appeals

· International Mechanical Code

o The IMC addresses the design and installation of mechanical systems (heating, ventilation and air-conditioning) not regulated by the IRC.

· International Fuel Gas Code

o The IFGC addresses the design and installation of fuel gas systems and gas-fire appliances not regulated by the IRC. The IFGC is reviewed jointly with the Plumbing Code Board of Appeals.

· International Residential Code – Chapter 11, Energy Conservation

· International Residential Code – Chapters 12-23, Mechanical

o Chapters 12-23 of the IRC address installation of mechanical systems in one- and two-family dwellings and townhouses up to three stories.

· International Residential Code – Chapter 24, Fuel Gas

o Chapter 24 of the IRC addresses installation of fuel gas systems and gas-fire appliances in one- and two-family dwellings and townhouses up to three stories. IRC Chapter 24 is reviewed jointly by the Mechanical Code Board of Appeals and Plumbing Code Board of Appeals.

Plumbing Code Board of Appeals

· International Plumbing Code

o The IPC addresses the design and installation of plumbing systems not regulated by the IRC.

· International Fuel Gas Code

o The IFGC addresses the design and installation of fuel gas systems and gas-fired appliances not regulated by the IRC. The IFGC is reviewed jointly with the Mechanical Code Board of Appeals.

· International Residential Code – Chapter 11, Energy Conservation

· International Residential Code – Chapter 24, Fuel Gas

· International Residential Code – Chapters 25-33, Plumbing

o Chapters 25-33 of the IRC address installation of plumbing systems in one- and two-family dwellings and townhouses up to three stories.