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.