Proposed Modification to the Florida Building Code
Modification #:
Section 553.73, Fla Stat
Name: Joseph D. Belcher
Address: 41 Oak Village Boulevard Homosassa, 34446
E-mail: Joe@JDBCodeservices.com
Phone: 352-450-2631
Fax: 813-925-4152
Code: Florida Building Code – Energy Conservation
Section #: Table 502.1.1.1(1)
Text of Modification [additions underlined; deletions stricken]:
TABLE 502.1.1.1 (1)
ENVELOPE PRESCRIPTIVE MEASURES FOR SHELL BUILDINGS1,2
Building Element
Mandatory Requirement
Roof:
Absorptance
≤?0.22
R-value (U-value)
R-40 (≤U-0.025)
Wall:
Above grade wall:
Absorptance
≤?0.3
R-value (U-value)
R-30 (≤ U-0.032)
Below grade wall:
No requirement
Raised Floor Insulation
R-value (U-value)
R-30 (≤ U-0.032)
Window:
≤?0.45
U-factor
SHGC
0-40% WW Ratio
0.25
40-50% WW Ratio
0.19
> 50% WW Ratio
Not allowed3
Door:
U-value
Swinging
U-0.70
Non-swinging
U-1.45
Skylights:
SHGC
≤?0.19
Skylight U-value
≤?1.36
1Equipment and lighting shall meet the efficiencies of Section 503, 504 and
505, respectively.
2Per Section 101.4.9 of the FBC-EC, the building shall demonstrate
compliance with Section 506 when completion of the building is permitted.
3
Buildings with greater than 50% WW Ratio shall comply with Section 506.
Fiscal Impact Statement [Provide documentation of the costs and benefits
of the proposed modifications to the code for each of the following entities.
Cost data should be accompanied by a list of assumptions and supporting
documentation. Explain expected benefits.]:
A.
Impact to local entity relative to enforcement of code:
No impact to local entity relative to enforcement of code.
B.
Impact to building and property owners relative to cost of compliance
with code:
Approval of the change will result in a reduction in costs to building
and property owners by correcting the title of a column requiring R30 in walls and R-40 in roofs for all commercial structures.
C.
Impact to industry relative to cost of compliance with code:
Approval of the proposed change will reduce costs relative to
compliance with the code by removing the mandatory R-30 in walls
and R-40 in roofs for commercial buildings.
D.
Impact to small business:
The proposal will not impact small business unless constructing a
building. Approval of the modification will correct an overly restrictive
provision thereby reducing the cost of construction.
Rationale [Provide an explanation of why you would like this Proposed
Modification to the Florida Building Code.]:
The current provisions fall within the glitch criteria because the provisions
of the column are not intended to be mandatory in the sense of the term
used by the FBC – Energy Conservation. Typically, the term mandatory is
taken to mean the provision is applicable to both prescriptive measures
and performance measures. As such this would make R-30 for walls and R40 for roofs the minimum R-values for all commercial construction
“501.2 Application. The commercial building project for shell buildings,
renovations, alterations and lighting and equipment changeouts shall
comply with the requirements in Sections 502 (Building envelope
requirements), 503 (Building mechanical systems), 504 (Service water
heating) and 505 (Electrical power and lighting systems) as applicable.
The new commercial building construction or addition project
shall comply with the requirements of Section 506, provided that the
applicable prescriptive and/or mandatory provisions of Sections 502,
503, 504, and 505 are each satisfied.” (Emphasis provided.)
A considerable number of architects and building officials are reading the
table to mean these R-Values are minimums even when demonstrating
code compliance by the performance method which is required for
commercial buildings. Discussion with both Ann Stanton, DBP
R, and Phillip Fairey, FSEC, indicate this is not the intent of the table.
The impact on small business if this glitch is allowed to stand will be
increased costs for the construction of buildings.
Please explain how the proposed modification meets the following
requirements:
1. Has a reasonable and substantial connection with the health, safety,
and welfare of the general public: The proposed amendment will
positively affect the health, safety, and welfare of the general public
by eliminating a glitch requiring excessive R-Values for walls and
roofs of all commercial buildings.
2. Strengthens or improves the code, and provides equivalent or better
products, methods, or systems of construction: The proposed
amendment will improve the code by eliminating a glitch requiring
excessive R-Values for walls and roofs of all commercial buildings.
3. Does not discriminate against materials, products, methods, or
systems of construction of demonstrated capabilities: The proposed
amendment does not discriminate against materials, products,
methods, or systems of construction of demonstrated capabilities.
4. Does not degrade the effectiveness of the code: The proposed
amendment will correct a glitch requiring excessive R-Values for
walls and roofs of all commercial buildings which does not degrade
the effectiveness of the code.
5. The provisions are not addressed in the IBC 2009 as the table is a
Florida Specific Amendment.
6. The amendment demonstrates by evidence or data that the
geographical jurisdiction of Florida exhibits a need to strengthen the
foundation code beyond the needs or regional variations addressed
by the foundation code, and why the proposed amendment applies
to this state.
The amendment is intended to address a glitch in a Florida Specific
Amendment to the code and is not addressed in the base code.
5. The proposed amendment was submitted or attempted to be
included in the foundation codes to avoid resubmission to the
Florida Building Code amendment process.
The amendment will not be submitted to the base code as it is a
Florida Specific Amendment.