Institute for Market Transformation’s (IMT’s) Commercial Roofing Document is Oversimplified and Misleading

NRCA is expressing concern about the accuracy of a document published by IMT, which addresses the International Energy Conversion Code and the commercial roofing industry. The document, International Energy Conservation Code as applied to: Alterations, Renovations and Repairs—Commercial Roofing which was published in 2014, is, in NRCA’s opinion deficient and misleading to professional roofing contractors who reference it.

The most troubling aspect of the document is the lack of an acknowledgement that there are different editions of the International Energy Code (IECC). Many states adopt IECC as their state energy code and roofing-related provisions vary from among IECC editions. The information in the document seems to be referencing IECC 2015 provisions, an IECC edition that is not yet in force in any states. At best, only about 40 states will have adopted IECC 2012 for commercial buildings by the end of 2015, and just a few will have adopted IECC 2015 by 2016.

NRCA also is concerned information presented in the “Does My Project Have to Comply” and “Requirements” sections is oversimplified and misleading. Statements such as “Insulation must comply with IECC provisions…” and “project is exempt from IECC provisions” are meaningless without the context of a code edition (especially considering the requirements for when minimum roof insulation values apply are some of the most contentious issues in energy code enforcement). Additionally, the document perpetuates the myth there is only one “code” that establishes requirements such as minimum R-value for roof insulation.

NRCA urges IMT to update the document to correct the deficiencies. Those using the current edition of IMT’s International Energy Conservation Code as applied to: Alterations, Renovations and Repairs—Commercial Roofing will be making decisions based on information not necessarily applicable.

Energy Codes cover (2)

NRCA’s Guidelines for Complying With Energy Code Requirements for Roof Assemblies: International Energy Conservation Code, 2009 and 2012 Editions – Provides a step-by-step guide for complying with the requirements of the International Energy Conservation Code’s (IECC’s) 2009 and 2012 editions and ASHRAE 90.1, “Energy Standard for Buildings Except Low-Rise Residential Buildings,” 2007 and 2010 editions, which are referenced in IECC’s 2009 and 2012 editions, respectively.

To assist roofing professionals, NRCA maintains an up-to-date database of states’ current energy code adoption at www.nrca.net/energy. Information can also be found in NRCA’s Guidelines for Complying with Energy Code Requirements for Roof Assemblies: International Energy Conservation Code, 2009 and 2012 Editions. Roofing professionals are also encouraged to contact the government agency having jurisdiction to verify the specific energy code(s) applicable to their projects.

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