Issue DS 2018-070: The Petitioner Michael L. Savage Jr. is seeking a declaratory statement on whether the adopted provisions of the Florida Building Code, notably Sections 102.4, 102.4.1, and E3901.2, require sunrooms, namely Category III, to comply with the receptacles spacing requirements of the FBC, Residential. Specifically, the Petitioner provides for the following question:

Question: Due to the adopted provisions of the Florida Building Code, notably Sections 102.4, 102.4.1, and E3901.2, are sun rooms, namely Category III, required to comply with the receptacles spacing requirements specifically required under the FBC Residential code?

Background:

There is the need due to conflicts in a standard and the adopted code to address, under the current Florida Building Code (FBC), whether Declaratory Statement DCA09-DEC-351, released sometime in April 2010-under the 2007 Florida Building Code, is still a valid statement based on several items. Since the Florida Building Code {2007) was adopted there has been three new editions released and superseded and we are now utilizing the 6th edition (while the 7th edition is under review), as such the provisions of Section R301.2.1.1.1 Sunrooms, and AAMA 2100 has changed accordingly.

AAMA/NPEA/NSA 2100 is a referenced standard, according to Chapter 46 of the FBC, as it represents the provisions of another document. The application of the referenced standards, according to Chapter 46, shall be as specified in Section 102.4. Therein lies part of the conflict with the standard and the adopted FBC Section 102.4, Referenced codes and standards, the codes and standards referenced in the code shall be considered part of the requirements of this code to the prescribed extent of each such reference and as further regulated in Sections 102.4.1 and 102.4.2.

Marion County has had plan review and/or inspection issues with several contractors on permit numbers 2018020361, 031844, 050670, 051325, 051330, 062041, 060245 and 062267, where the county has required Cat Ill sunrooms to have general purpose receptacles installed in accordance with the FBC Residential Section listed above. Currently Marion County is inspecting SFR's that are requesting the installation of Category Ill sun rooms, as noted by the permit numbers above, that are affected by this declaratory statement with regards to the wiring of those rooms. I have issued a "hold" on the implementation pending the outcome of the declaratory statement.

6^th Edition (2017) Florida Building Code, Building Chapter 1

[A]102.1 General.

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

[A]102.4 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 and as further regulated in Sections 102.4.1 and 102.4.2.

[A]102.4.1 Conflicts.

Where conflicts occur between provisions of this code and referenced codes and standards, the provisions of this code shall apply.

6^th Edition (2017) Florida Building Code, Residential

CHAPTER 2 DEFINITIONS

[RB] SUNROOM.

1. A one-story structure attached to a dwelling with a glazing area in excess of 40 percent of the gross area of the structure’s exterior walls and roof.

2. A one-story structure added to a dwelling with solid roof panels without sloped glazing. The sunroom walls may have any configuration, provided the open areas consisting of operable or fixed glass or windows or side hinged or sliding glass doors of the longer wall and one

additional wall is equal to at least 65 percent of the area below 6 foot 8 inches (2032 mm) of each wall, measured from the floor. For the purposes of this code the term sunroom as used herein shall include conservatories sunspaces, solariums, and porch or patio covers or

enclosures.

See also Section R202 of the Florida Building Code, Energy Conservation.

R301.2.1.1.1Sunrooms.

Sunrooms shall comply with AAMA/NPEA/NSA 2100. For the purpose of applying the criteria of AAMA/NPEA/NSA 2100 based on the intended use, sunrooms shall be identified as one of the following categories by the permit applicant, design professional or the property owner or owner’s agent in the construction documents. Component and cladding pressures shall be used for the design of elements that do not qualify as main wind force-resisting systems. Main wind force-resisting system pressures shall be used for the design of elements assigned to provide support and stability for the overall sunroom.

Category I: A thermally isolated sunroom with walls that are open or enclosed with insect screening or 0.5 mm (20 mil) maximum thickness plastic film. The space is nonhabitable and unconditioned.

Category II: A thermally isolated sunroom with enclosed walls. The openings are enclosed with translucent or transparent plastic or glass. The space is nonhabitable and unconditioned.

Category III: A thermally isolated sunroom with enclosed walls. The openings are enclosed with translucent or transparent plastic or glass. The sunroom fenestration complies with additional requirements for air infiltration resistance and water penetration resistance. The space is nonhabitable and unconditioned.

Category IV: A thermally isolated sunroom with enclosed walls. The sunroom is designed to be heated or cooled by a separate temperature control or system and is thermally isolated from the primary structure. The sunroom fenestration complies with additional requirements for water penetration resistance, air infiltration resistance and thermal performance. The space is nonhabitable and conditioned.

Category V: A sunroom with enclosed walls. The sunroom is designed to be heated or cooled and is open to the main structure. The sunroom fenestration complies with additional requirements for water penetration resistance, air infiltration resistance and thermal performance. The space is habitable and conditioned.

CHAPTER 46 REFERENCED STANDARDS

AAMA/NPEA/NSA 2100—12 Specifications for Sunrooms.

8.6 Electrical

8.6.2 Receptacle Outlets

Receptacle Outlets in Category IV and V sunrooms shall be installed in accordance with NFPA 70 Article 314.

Exception 3: Category I, II and III sunrooms are exempt from requirements for receptacle outlets.

6^th Edition (2017) Florida Building Code (FBC), Residential

E3901.2 General purpose receptacle distribution. In every kitchen, family room, dining room, living room, parlor, library, den, sun room, bedroom, recreation room, or similar room or area of dwelling units, receptacle outlets shall be installed in accordance with the general provisions specified in Sections E3901.2.1 through E3901.2.3 (see Figure E3901.2).

E3901.2.1 Spacing.

Receptacles shall be installed so that no point measured horizontally along the floor line of any wall space is more than 6 feet (1829 mm), from a receptacle outlet. [210.52(A)(1)]

E3901.2.2 Wall space.

As used in this section, a wall space shall include the following: [210.52(A)(2)]

1.Any space that is 2 feet (610 mm) or more in width, including space measured around corners, and that is unbroken along the floor line by doorways and similar openings, fireplaces, and fixed cabinets.
2.The space occupied by fixed panels in exterior walls, excluding sliding panels.
3.The space created by fixed room dividers such as railings and freestanding bar-type counters.

E3901.2.3 Floor receptacles.

Receptacle outlets in floors shall not be counted as part of the required number of receptacle outlets except where located within 18 inches (457 mm) of the wall. [210.52(A)(3)]

DCA09-DEC-351

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

Answer: AAMA 2100 is more specific than NFPA 70 with regard to the definition of sunrooms and the placement of receptacle outlets, and therefore in according to Section 102.1 of the FBC, Building, and AAMA 2100’s provisions prevail over NFPA 70 with regard to the subject in question.

Staff Analysis:

Answer:

Option #1/Petitioner:

The Petitioner respectfully believes the answer to the question is yes. Due to the prescriptive requirements of the Code as noted in E3901.2, E3901.2 and E3901.2.2, and the conflicts provision noted under Section 102.4.1, then it is clear sun rooms are required to meet the receptacles spacing requirements of the code.

Option #2/Staff:

No. The provisions of Section R301.2.1.1 of the FBC, Residential and AAMA 2100 as referenced from within section R301.2.1.1 are more specific than the provisions of Section E3901.2 of the FBC, Residential with regard to the definition of sunrooms and the placement of receptacle outlets, and therefore in according to Section 102.1 of the FBC, Building, the requirements of Section E3901.2 including the receptacles spacing requirements do not apply to the projects in question. The electrical requirements for the project in question are subject to the requirements of AAMA 2100.