Executive Activities

Dear Mr. Price:

I am writing to offer comments on behalf of the Codes & Energy Resource Group of the Washington Council of the American Institute of Architects, representing architects statewide. These comments come from architects in Seattle, Spokane, Everett and other communities who design a wide variety of building types for residential, commercial and institutional owners.

First of all, we would like to commend the work of the State Building Code Council and the Technical Advisory Groups in adopting the International Building, Residential, Fire and Mechanical Codes and amending them to coordinate with our other construction codes and regulations. We know that the effort involved is substantial, and much of it is by volunteers who are providing service of great value to the citizens of our state.

Adopting the International Codes meets the AIA's goal of adoption and enforcement of consensus-based codes and standards that are the product of informed education, research and review. The International Codes align with the positions of architects nationally and in Washington State regarding building regulations:

Set forth only the minimum standards for safety, health, and welfare in building construction;

Are developed by rationally conceived criteria;

Are designed to serve performance rather than prescriptive criteria wherever possible;

Consist of a single set of comprehensive, coordinated, and contemporary codes for the nation;

Are without favoritism or bias to any special interest; and

Are cost-effective in relation to public benefit.

We support amendments to these codes only to the extent necessary for conditions truly unique to the state of Washington. These conditions include administrative coordination with other state laws and regulations, and characteristics such as seismic risk, energy generation, and climate. Having codes in common with other jurisdictions reduces the cost of design and construction. It makes our state's design and construction industry more competitive, and makes development of facilities (and jobs) more competitive in Washington State.

We support continued improvement of the codes through research and the open code development process of the International Code Conference, the NFPA, and other organizations. We oppose piecemeal amendments at the state or local level to satisfy special interests.

Second, we would like to commend the work of the State building Code Council in maintaining the Washington State codes that are not ICC codes, including the Washington State Energy Code and the Washington State Ventilation and Indoor Air Quality Code. As these are our State codes, the must be updated and maintained by the State Building Code Council. Specifically, we commend the State Building Code Council for updating the Washington State Energy Code to achieve energy saving closer to that in ASHRAE/IESNA Standard 90.1 (cited in the U.S. National Energy Policy Act as the basis for State nonresidential Energy Codes).

Our comments on specific code amendments follow.

International Building Code (IBC):

Chapter 3: We support the amendments needed to define daycare, adult family homes, assisted living, and licensed care occupancy groups, for coordination with unique Washington state regulations.

903.2: The State Building code should include amendment paragraph 903.2.1.2 Group A-2 from the State Fire code amendments, regarding required sprinklers where occupant load is 100 or more. It is not consistent to include the State Fire code paragraph 903.2.2 Group E in the State Building code without including the similar A-occupancy amendment.

Chapter 11: We commend the effort to minimize amendments to the IBC chapter 11, which recognizes that the IBC now is close to the intent and content of Washington's amendments to the 1997 UBC.

It is a burden for architects, particularly those designing government facilities or facilities with government funded programs, to have to follow complex state amendments and the national ANSI/ADAAG standards. We encourage the SBCC and all advocates for barrier-free access, which include architects, to use the ICC code development process to minimize the need for any state amendments to Chapter 11.

1107.6.2.1.1 Type A Units: We oppose the change from 2 percent to 5 percent required in R-2 buildings with more than 20 units. Washington does not have a demonstrable difference in population that would require such a change from the other states. Please see separate testimony submitted by Sue Alden, FAIA. We support the Minority Report on this provision.

1203: We support the amendments required to coordinate with the Ventilation and Indoor Air Quality Code.

1208.2: We support Option 1 for the minimum ceiling height amendment as preferable to Option 2.We question the need for a state amendment to the provision without evidence that people in Washington require different ceiling heights than people in other states. This is a new area of regulation for occupancies other than residential. It may be misguided and beyond what is needed for minimum standard for health, safety or general welfare. Nevertheless, the ICC code development process would be a more appropriate venue for proposing a change.

3407.7.9 A typo should be corrected. unisex toilet for bathing facilities should be restored to unisex toilet or bathing facilities The amendment to number of fixtures may be justified due to Washington's unique amendments to Chapter 29.

International Residential Code (IRC)

We support the limitation of amendments to only those necessary for coordination with other codes and regulations unique to Washington. G2439.5.3 Protection for dryer ducts: We question the need for this amendment.

International Mechanical Code (IMC)

We support the limitation of amendments to only those necessary for coordination with other codes and regulations unique to Washington.

504.6.3 Protection for dryer ducts: We question the need for this amendment.

International Fire Code (IFC)

The number and extent of proposed amendments to this code and the origin of this code from a different model code organization would produce a code unique to Washington State. Such a code does not meet the goals of architects and other design professionals in Washington. At a minimum, the number of amendments should be reduced to only those necessary for coordination with other Washington codes and regulations, so that the plumbing code will at least conform to a regional model code.

509.1.2 Access for water heaters: We object to this sections requirements for permanent ladder access. There are many situations where vertical ladder access is not as practical or as safe as use of a portable ladder.

Washington State Energy Code

201.1 Definitions, p. 9, Heated space (Fully heated):

Sub-paragraph 'b' has a typo:"...2.0 Btu/(h*ft-2)ÉÓ should be "...20 Btu/(h*ft-2)..."

Thank you for the opportunity to comment.

Respectfully submitted,

Don Brubeck, AIA
Chair, Codes & Energy Resource Group
AIA Washington Council