Green Code in Final Stages

The latest revisions to the International Green Construction Code (IgCC) are scheduled be made later this summer with hearings planned for the ASHRAE meetings in Long Beach, California in late June. ASHRAE Standard 189.1 is a jointly developed green code that is being marketed as a foundation for LEED certification. The IgCC partnership includes the American Society of Heating, Refrigeration and Air-conditioning Engineers (ASHRAE), the International Code Council (ICC), the American Institute of Architects (AIA), the Illuminating Engineering Society (IES) and the U.S. Green Building Council (USGBC).

In a previous column, I reported about the organizations agreeing to work together using the ASHRAE Standard 189.1 titled: Standard for the Design of High-Performance Green Buildings Except Low-Rise Residential Buildings with ICC’s IgCC into one single model code.

The AIA, IES and USGBC will work together to provide technical review and support for an integrated document that will become the 2018 version of the IgCC, which is due to be published in late summer of 2018, if everything stays on track.

The new document has not yet been adopted by any jurisdictions. The normal procedure for adoption of a new code is for a state to review the proposed document, and for a panel or committee to assure there aren’t any issues or need to provide any local amendments. As water and energy conservation efforts push forward, there have been many people in the industry who have concerns with the newer plumbing codes, with respect to system performance and health and safety issues. I suspect the same concerns will be brought forward with comments to the new combined document. The new document has many new water conservation requirements that further reduce water flows and energy conservation requirements that arguably were causing water quality and drain line performance issues at the old flow rates.  

The green code hearings that I attended at ICC appeared to be sparsely populated with respect to plumbing industry representatives. The recent hearings in Las Vegas for ASHRAE 189.1, which will be the basis for the new IgCC, were held at the same time as many other plumbing related standards committees at ASHRAE. 

This is a big problem because the ASHRAE TC 6.6 Service Water Heating Systems standard, the ASHRAE 3.6 Standard for Water Treatment, the ASHRAE 188 standard titled Legionellosis: Risk Management for Building Water Systems, ASHRAE Guideline 12 Minimizing the Risk of Legionellosis Associated with Building Water Systems and many other plumbing related standards committee meetings are held simultaneously with the ASHRAE 189.1 committee meetings, which makes it nearly impossible for plumbing industry experts to attend all of the plumbing-related meetings. 

Some people are concerned that there may be health and safety issues associated with the code changes. Still, others I talked to are concerned about efforts to normalize the green code requirements and mandate them. The green codes and other partner conservation programs like LEED are private, for profit, voluntary conservation programs that collect money to certify buildings and people to the certification program requirements. There are many well-intentioned jurisdictions that may adopt the codes in good faith not realizing the consequences associated with these untested new code requirements. There has been no testing or research on many of the new ultra-low-flow requirements, which may lead to poor water quality due to water treatment chemical dissipation that will allow bacteria to grow in water supply pipes and cause drain line transport issues related to lower water flows.   

Recent research projects and increased incidents of poor water quality in buildings that have very low water flows have created the need for research into water quality issues associated with water conservation projects. 

Currently, there are two different independent university studies ongoing funded by the Environmental Protection Agency (EPA) that should be looking into water quality issues associated with water conservation programs. However, I’m not sure if they are looking at the former water flow rates or at the currently proposed water flow rates. The Plumbing Efficiency Research Coalition (PERC) has provided reports that show there are drain line transport issues with respect to flushing solids including toilet paper and a few types of flushable wipes. Additional research is needed to expand these studies to cover other flushable products, like feminine products, larger adult wipes, toilet seat covers, etc., at the even lower flow rates which have been recently proposed to the codes.  

The IgCC will reportedly provide the design and construction industry with a green code that is harmonized and correlated with the other international codes. By collaborating on developing the 2018-IgCC, the goal of these organizations is to provide a new International Green Construction Code that theoretically includes environmental health and safety concerns, however, they are currently untested at the proposed code minimums. The stated goal of the 2018-IgCC is to provide fundamental criteria for energy efficiency, resource conservation, water safety, land use, site development, indoor environmental quality and building performance that can be adopted broadly. The first jurisdictions to adopt the new IgCC will be the test sites for the performance of these ultra-low-flow plumbing systems. 

The plumbing industry will be watching to see if there is a success or will there be a notable increase of bacteria in the building water distribution systems that leads to more incidents of Legionnaires’ disease, a notable increase in the number of sanitary sewer overflow (SSO) incidents and an increase in the number of drain and sewer cleaning companies. 

ASHRAE’s process for these proposed changes to the standard will be wrapping up this summer, with a final agenda currently under public review. Later this year, the final set of changes for the 2017 version of Standard 189.1 will be delivered to ICC. At that time, ICC will develop the administrative procedures for the document and publish it as the 2018 IgCC.

In anticipation of this timeline, ICC did not keep the IgCC committee members from 2015. Members of the ICC Sustainability, Energy & High Performance Building Code Action Committee and other interested parties have, however, contributed to the 189.1 process, providing recommendations and proposals within the 189.1 process that seek to carry over provisions from the 2015 IgCC into 189.1.