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Interpretations Request Input

Original Request

  • Request ID: 8529
  • Requested By: Brian Law
  • Requester E-Mail: blaw@cityofsab.org
  • Code Version: 2021
  • Code: ENERGY
  • Code Description:
  • Chapter:
  • Section: R503.1.1.1
  • Topic: Replacement Fenestration
  • Question: Is it the intent of section R503.1.1.1 to require replacement fenestration products in R-2 occupancies to comply with the minimum SHGC of 0.25 and minimum U factor of 0.40 for a climate zone 2 area. The project is for replacement of all windows and doors in a single unit in an existing condominium complex.
  • Comment: None

Existing Interpretations and/or Declaratory Statements Related to this request

Input Received:

it is my opinion that if the building is considered a "renovated building" defined as; estimated costs exceed 30% of assessed value of the structure, (see R101.4.2 and Definitions in chapter 2) then the replacement fenestration products need to meet a maximum SHGC of .25 and a maximum U factor of .40 for a building in climate zone 2 (see Table 402.1.2 note a.) if it is an existing building and not considered a renovated building then it is exempt from the provisions of the Energy Code
Michael Grimm on 04/30/2021 at 3:50 PM
I want to say YES, but the code language has changed since the FBC Binding Interp. was done. (Which I could not find). I still want to say yes, due to the full replacement and that this chapter is on existing buildings.
However, we go back to the definition of "renovated" and 30% it makes me hesitate. So I will allow this comment to stay and let others put their two cents in.
Linda Patrick on 05/04/2021 at 2:36 PM

Answer:

If the building is considered a "renovated building" defined as; estimated costs exceed 30% of assessed value of the structure, (see R101.4.2 and Definitions in chapter 2) then the replacement fenestration products need to meet a maximum SHGC of .25 and a maximum U factor of .40 for a building in climate zone 2 (see Table 402.1.2 note a.) if it is an existing building and not considered a renovated building then it is exempt from the provisions of the Energy Code
On 05/21/2021 at 11:29 AM

Commentary:

In 1992, the Florida Legislature passed the wording in F.S. 553.902 (6) and 553.903 which was then carried over into Code language which exempts structures that are being altered when the value of the work does not exceed the 30% threshold.

Comments on Draft:

I agree with draft response
Pedro Quintela on 05/19/2021 at 5:05 PM
While I agree with the response, I believe the "While this may not make sense," phrase should be deleted.
Joseph Belcher on 05/19/2021 at 7:52 PM
I agree with draft
Andrew Bruhn on 05/19/2021 at 8:17 PM
I agree with the draft and I like the deep dive on the comment but maybe get rid of the "while this may not make sense" part of it
Michael Grimm on 05/19/2021 at 10:18 PM
Like the response and agree with the others on the comment.
Linda Patrick on 05/20/2021 at 11:29 AM
I also agree
Timothy Moore on 05/31/2021 at 5:51 PM
Publish Draft Interpretation