Proposed Modification to the Florida Building Code

Modification #: Section 553.73, Fla Stat

Name: Joseph D. Belcher

Address: 41 Oak Village Boulevard Homosassa, 34446

E-mail: Joe@JDBCodeservices.com

Phone: 352-450-2631

Fax: 813-925-4152

Code: Florida Building Code – Energy Conservation

Section #: Table 502.1.1.1(1)

Text of Modification [additions underlined; deletions stricken]:

TABLE 502.1.1.1 (1)

ENVELOPE PRESCRIPTIVE MEASURES FOR SHELL BUILDINGS^1,2

Building Element	Mandatory Requirement
Roof: Absorptance R-value (U-value)	≤0.22 R-40 (≤U-0.025)
Wall: Above grade wall: Absorptance R-value (U-value) Below grade wall:	≤0.3 R-30 (≤ U-0.032) No requirement
Raised Floor Insulation R-value (U-value)	R-30 (≤ U-0.032)
Window: U-factor SHGC 0-40% WW Ratio 40-50% WW Ratio > 50% WW Ratio	≤0.45 0.25 0.19 Not allowed^3
Door: U-value Swinging Non-swinging	U-0.70 U-1.45
Skylights: SHGC Skylight U-value	≤0.19 ≤1.36

¹Equipment and lighting shall meet the efficiencies of Section 503, 504 and 505, respectively.

²Per Section 101.4.9 of the FBC-EC, the building shall demonstrate compliance with Section 506 when completion of the building is permitted.

³Buildings with greater than 50% WW Ratio shall comply with Section 506.

Fiscal Impact Statement [Provide documentation of the costs and benefits of the proposed modifications to the code for each of the following entities. Cost data should be accompanied by a list of assumptions and supporting documentation. Explain expected benefits.]:

A. Impact to local entity relative to enforcement of code:

No impact to local entity relative to enforcement of code.

B. Impact to building and property owners relative to cost of compliance with code:

Approval of the change will result in a reduction in costs to building and property owners by correcting the title of a column requiring R-30 in walls and R-40 in roofs for all commercial structures.

C. Impact to industry relative to cost of compliance with code:

Approval of the proposed change will reduce costs relative to compliance with the code by removing the mandatory R-30 in walls and R-40 in roofs for commercial buildings.

D. Impact to small business:

The proposal will not impact small business unless constructing a building. Approval of the modification will correct an overly restrictive provision thereby reducing the cost of construction.

Rationale [Provide an explanation of why you would like this Proposed Modification to the Florida Building Code.]:

The current provisions fall within the glitch criteria because the provisions of the column are not intended to be mandatory in the sense of the term used by the FBC – Energy Conservation. Typically, the term mandatory is taken to mean the provision is applicable to both prescriptive measures and performance measures. As such this would make R-30 for walls and R-40 for roofs the minimum R-values for all commercial construction

“501.2 Application. The commercial building project for shell buildings, renovations, alterations and lighting and equipment changeouts shall comply with the requirements in Sections 502 (Building envelope requirements), 503 (Building mechanical systems), 504 (Service water heating) and 505 (Electrical power and lighting systems) as applicable.

The new commercial building construction or addition project shall comply with the requirements of Section 506, provided that the applicable prescriptive and/or mandatory provisions of Sections 502, 503, 504, and 505 are each satisfied.” (Emphasis provided.)

A considerable number of architects and building officials are reading the table to mean these R-Values are minimums even when demonstrating code compliance by the performance method which is required for commercial buildings. Discussion with both Ann Stanton, DBP
R, and Phillip Fairey, FSEC, indicate this is not the intent of the table.

The impact on small business if this glitch is allowed to stand will be increased costs for the construction of buildings.

Please explain how the proposed modification meets the following requirements:

1. Has a reasonable and substantial connection with the health, safety, and welfare of the general public: The proposed amendment will positively affect the health, safety, and welfare of the general public by eliminating a glitch requiring excessive R-Values for walls and roofs of all commercial buildings.

2. Strengthens or improves the code, and provides equivalent or better products, methods, or systems of construction: The proposed amendment will improve the code by eliminating a glitch requiring excessive R-Values for walls and roofs of all commercial buildings.

3. Does not discriminate against materials, products, methods, or systems of construction of demonstrated capabilities: The proposed amendment does not discriminate against materials, products, methods, or systems of construction of demonstrated capabilities.

4. Does not degrade the effectiveness of the code: The proposed amendment will correct a glitch requiring excessive R-Values for walls and roofs of all commercial buildings which does not degrade the effectiveness of the code.

5. The provisions are not addressed in the IBC 2009 as the table is a Florida Specific Amendment.

6. The amendment demonstrates by evidence or data that the geographical jurisdiction of Florida exhibits a need to strengthen the foundation code beyond the needs or regional variations addressed by the foundation code, and why the proposed amendment applies to this state.

The amendment is intended to address a glitch in a Florida Specific Amendment to the code and is not addressed in the base code.

5. The proposed amendment was submitted or attempted to be included in the foundation codes to avoid resubmission to the Florida Building Code amendment process.

The amendment will not be submitted to the base code as it is a Florida Specific Amendment.