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.