lDB CODE SERVICES, INC.

Date: October 30, 2009

To: Paula Ford, Clerk of the Commission
Florida State Department of Community Affairs

From: Joe Belcher, Code Consultant
Representing the Aluminum Association of Florida (AAF)
41 Oak Village Boulevard
Homosassa, Florida 34446
Vox: 352-450-2631 ,
Fax: 81-925-4152

Richard Moore, President,
AAF

P.O. Box 140532
Orlando, Florida 32814
Vox: 407-896-1015
Fax: 407-894-7673

Subject: Petition for Declaratory Statement before the Florida Building
Commission RE: Florida Building Code, 2007 with 2009 Supplements,
Sections 102.1 and 102.4

Please consider this a request for a declaratory statement related to the prospective

application of Sections 102.1 and 102.4 as they relate to the installation of receptacle

outlets in Category I, II, and III sunrooms as specified by the Florida Building Code and

AAMA 2100. This request is not related to an interpretation by a building official on a

specific project, but is intended to address future application of the differing provisions

of two adopted standards.

The Aluminum Association of Florida (AAF) is an organization of contractors specializing in the construction of aluminum structures. AAF has an interest in this issue because a number of AAF members sell and build sunrooms in Florida. AAF is requesting the petition on behalf of Gary Whigham, an AAF member. Mr. Whigham is in the process of planning for a project to attach a sunroom to a single family dwelling and has noted the differences between NFPA 70 and AAMA 2100 and believes there may be room for differing interpretations.

Discussion: Receptacle outlets in sunrooms are addressed by two separate standards adopted by reference by the Florida Building Code, Building, and the Florida Building Code, Residential (FBC). The FBC adopts a standard of the National Fire Protection

Association, NFPA 70-08 and a standard of the American Architectural Manufacturers

Association/National Patio Enclosure Association/National Sunroom Association

AAMAlNPEAlNSA2100-02 i. (FBCB §2701.1; §2002.6; and FBCR §E3301.1;

§R30 1.2.1.1.2) The two standards differ regarding when the installation of receptacle

outlets in sunrooms is required. The Aluminum Association of Florida contends that

since the NFPA provisions are general in nature and the AAMA provisions are specific

to sunrooms, the AAMA provisions prevail and the outlets are required in Category IV

and Category V sunrooms only.

The Florida Building Code at Chapter 1 states that when there is a conflict between a

general and a specific requirement, the specific requirement applies. (FBCB, 2007,

§102.1) The code further states standards referenced in the code are to be considered

as part of the requirements of the code. Where there are differences between the code

and referenced codes and standards, the provisions of the code apply. (FBCB, 2007,

In the case of NFPA 70, Article 210.52 (A), the term sunroom is contained within a general list of rooms in a section entitled "General Provisions". The section contains general provisions listing rooms and areas within dwelling units where the installation of receptacle outlets is required. The standard contains no definition of sunroom, or differentiation between habitable or non-habitable space in relation to sunrooms. (Please see excerpt from NFPA 70,2008, Article 210 below.)

In the case of AAMAlNPEAlNSA 2100, the standard is specific to sunrooms. In fact, the standard applies solely to sunrooms as demonstrated by the title, "Voluntary Specifications for Sunrooms". Regarding specificity, AAMA 2100 is very specific in separating sunrooms into five distinct categories based primarily on habitability and conditioning. In addition to the five categories being delineated in the standard, the same five categories are specified by the Florida Building Code. (FBCB §2002.6 and FBCR §301.2.1.1.2) The standard specifically states which categories of sunrooms are required to have receptacle outlets installed in a section entitled "Receptacle Outlets". (Please see excerpt from AAMAlNPEAlNSA 2100,2002, §7.7, Electrical, and §7.7.2 below.)

The Aluminum Association of Florida (AAF) contends the specific provisions of the AAMA 2100 standard, including the Exception, prevail over the NFPA 70 general provisions. Specifically, Category I, II, and III Sunrooms, as listed by the FBC and AAMA 2100, are exempt from the general provisions of NFPA 70 requiring receptacle outlets in sunrooms. This position is supported by BOAF Informal Interpretation Report #6285 issued upon a request submitted by a building department. (Please see attached report following.)

I Note: The provisions in question are unchanged between the 2004 and 2007 Editions of the FBC and between the 2005 and 2008 Editions of NFPA 70.

JDBCS/AAF· Dec Petition 10·30·2009 P 2 of 6

In light of the above, the Aluminum Association of Florida requests the Commission answer the following question:

In the case of sunrooms attached to single family dwellings, do the provisions of AAMA 2100 related to receptacle outlets prevail?

Should there be any questions, you need further information, or you wish to discuss this request, please do not hesitate to contact me at your earliest convenience.

Respectfully yours,

Joseph D. Belcher, Code Consultant

cc: Mo Madani, Florida State Department of Community Affairs
Richard Moore, President, AAF

JOBCS/AAF -Dec Petition 10-30-2009 P 3 of 6

"102.1 General. Where, in any specific case, different sections of this code specify different materials, methods of construction or other requirements, the most restrictive shall govern. Where there is a conflict between a general requirement and a specific requirement, the specific requirement shall be applicable.

1 02.4 Referenced codes and standards. The codes and standards referenced in this code shall be considered part of the requirements of this code to the prescribed extent of each such reference. Where differences occur between provisions of this code and referenced codes and standards, the provisions of this code shaH apply."

{A} General Provi~jons. In every kitchen. family room. dining room. living room, parlor, library. den, sunroom. bedroom, recreation room, or ~imilar room or area of dwelling units, receptacle outlets "hall be installed in accordnnce with the general pro'iisioll~ specified in 21O,52(A)( J) through fA){J).

AAMAINPEAlNSA 2100, 2002:

"7.7 Electrical

7.7.1 Exit and Stairway Illumination: All sunrooms shall provide stairway and egress illumination as required by local code.

JDBCS/AAF Dec Petition 10-30-2009 P 4 or 6

Exception: Category I sunrooms are not required to have exit lighting.

JDBCSIAAF -Dec Petition 10-30-2009 P 5 or 6

JDBCSIAAF -Dec Petition 10-30-2009 P 6 or 6