| Action | Update the Virginia Uniform Statewide Building Code |
| Stage | Proposed |
| Comment Period | Ended on 1/25/2010 |
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6 comments
We request approval of the following code change proposals, as submitted by the VSAIA:
As a representative of the Virginia Society of the American Institute of Architects (VSAIA), we do not support the following proposed code change (as was included in the January 12, 2010, Code Update Meeting Package).
1. David Thomas’ code change proposal regarding Section 109 and the means of egress. a. Such requirements were not included in the USBC when we switched model codes from BOCA to ICC, and as such, have not been required since. b. Including “detail” and “character” of the exit discharge on the documents could prove problematic. It would appear this would require occupancy loads be provided for all sidewalks, plazas, and perhaps even parking lots and open areas especially if they are not considered part of the “public way”. c. Providing occupant loads “in all rooms and spaces” is contrary to what Chapter 10 allows when assigning occupants to a particular space or room. i. For example, Chapter 10 does not require occupant loads be assigned to toilets, corridors, closets, stairs (egress capacity, but not occupant loads), vestibules, and other such spaces. ii. A larger example would be a “Business” use, which Chapter 10 allows to be taken at “gross”...thus avoiding the need to identify occupants “in all rooms and spaces”. d. The current system works, where LAHJ can be flexible in what they will require, and what they do not require. The proposed code change eliminates the flexibility and in our opinion, has the potential to add confusion as to what must be indicated on the documents and how. e. If the Codes and Standards Committee and/or the BHCD believe something should be added back to the code, we propose you accept the VSAIA proposal, which more closely parallels what Virginia required through the “legacy” BOCA codes, and what Virginia architects and LAHJ are more familiar with.
As a representative of the Virginia Society of the American Institute of Architects (VSAIA), we do not support the following proposed code changes (as was included in the January 12, 2010, Code Update Meeting Package).
1. Adoption of the International Wildland-Urban Interface Code (IWUIC) a. We believe the adoption of an entire “code” without being vetted through some committee begs for confusion and unanticipated consequences. This is especially true for a code such as this one that dictates construction materials and other construction requirements that may be contrary to the ICC and/or the USBC. b. This model code should first be vetted through a committee or ad-hoc group of potentially affected stakeholders – similar to what Virginia did with the International Existing Building Code (IEBC). c. Some areas of concern are as follows: i. Appears there may be numerous conflicts with current USBC requirements (e.g., retroactive requirements – 101.5; maintenance requirements – 101.6; existing conditions – 102.6; Sections 104, 109, and 202 to name a few; and fire apparatus roads – 403.1) ii. Should re-write Chapter 1 to make it comport to the USBC. iii. The latest mapping of these areas (Section 302.2) appear to be dated from the year 2000. Being that this is for the 2009 code cycle, we believe updated mapping should be conducted prior to incorporating the IWUIC into the USBC to determine its potential impact to construction throughout Virginia. iv. It appears Section 404.1 (water sources) could prove problematic for numerous rural areas. v. Requirements for a Fire Protection Plan (Section 405) will certainly add additional costs to all proposed buildings and/or developments. vi. Chapter 5 includes requirements for how and of what materials buildings can be constructed with. How does this comport with the VCC, IBC and/or IRC? vii. Sprinkler systems would be required for all buildings meeting certain criteria (Section 602). How does this comport with the VCC, IBC and/or IRC? viii. Defensible space would most certainly reduce the size of a number of buildings and/or developments. 1. It may be possible now to control and/or limit development and/or growth through this code. Is this the ultimate intent, and if so, it appears this is best handled as a zoning issue – not a code issue. ix. Would the appendices also be adopted? Although we endorse the concept of trying to protect such wildland areas, we believe Virginia should not adopt the IWUIC without a vetting process to address the concerns noted above, as well as others.
As a representative of the Virginia Society of the American Institute of Architects (VSAIA), we do not support the following proposed code changes (as was included in the January 12, 2010, Code Update Meeting Package).
1. Frank Herzog’s code change proposal regarding Section 708.14 and elevator lobbies. a. Lobbies can lessen visibility for security purposes; can make orientation more difficult; when engaged, they “zone off” the spaces leading to them, thus potentially impacting the egress (clear path) ability from or through the elevator lobby; b. Supporting statement by proponent does not support the case for a code change: i. Appears to imply the elevator “shaft” is not protected. The shaft is protected as required by Sections 708, 3002 and 3004. ii. Statistical data submitted includes number of fires, injuries, and/or deaths; however, they do not indicate if any of those were as a direct (or indirect) result of the lack of an elevator lobby. 1. Given their own data, it appears the number of fires are actually decreasing (114 in 2008 and, if interpolated, would be 52 in 2009). Over a 50% reduction in the number of fires in such high rises. 2. Is there data supporting that elevator lobbies actually save lives? 3. Are there specific incidents (in Virginia or elsewhere) that would support such a change be considered in Virginia, when we have had no such incidents? iii. Appears to imply the elevator “hoistway” is not protected. The hoistway is protected as required by Sections 708, 3002 and 3004. iv. This is not a hoistway nor shaft issue – it is a lobby issue. c. The code change proposal could have unintended consequences when dealing with existing and/or historic buildings, including those with elevators, thus potentially no longer serving as encouragement to develop existing buildings in the first place. d. This code change would add costs to the buildings, and potentially reduce the rentable space for office buildings. e. This code change goes contrary to what Virginia has enforced for nearly 30 years through its “legacy” and current ICC codes.
As a representative of the Virginia Society of the American Institute of Architects (VSAIA), we do not support the following proposed code change.
IRC R313.2 regarding sprinklering one-and two-family dwellings - as currently written in the 2009 IRC. We might be supportive of other exceptions, such as: lack of adequate water source; separation distances; and rated construction. We may also be supportive of incentives for providing sprinklers.
Well looking at the present condition of the things there is a fair bit of opposion to this new uniform building code. But even the public agrees that some of these are indeed benificial. So i think the government must take a note of what is acceptable with the citizens and then move on.