Illinois Energy Conservation Code Training and Support Program
2012 IECC - Frequently Asked Questions - 2012 IECC

I. SCOPING & ADDITIONS, ALTERATIONS, RENNOVATIONS OR REPAIRS

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Q: Work proposed to a home consists of replacing existing window units in their entirety. Currently we do not require permits for window replacements. How do others interpret or enforce window replacements?

A: The 2012 IECC considers window replacements alterations to the building. Yet for some time, many Illinois municipalities have considered the replacement window issue a matter of jurisdictional choice by way of a jurisdiction’s unique adopting ordinance; most often reading, “If it fits into the same opening, then you do not need to obtain a building permit. Where the new window size is different than the size of the opening, a permit application is required.”

With the onset of energy efficiency requirements for residential buildings effective January 29, 2010, all window replacements, as with alterations, require a permit in accordance with the IECC. Jurisdictions subject to the Illinois Energy Efficient Building Act will use the 2012 IECC to perform compliance assessment for both residential buildings, and thereby to inspect and verify fenestration thermal performance (U-factor, Solar Heat Gain Coefficient and Air leakage) for homeowners in their communities.

Documentation shall be provided with the permit application indicating that the replacement window products afford a fenestration U-factor and SHGC no greater than required by the IECC. This will take some extra public relations and communications to get the word out for the new permit requirement; a perfect opportunity for Building Safety Month.

Section 600.110, Part c) 2) of the Act, Privately Funded Commercial Facilities and Residential Buildings, reads:

“The Code as [2009 IECC] described in Subparts C [Privately Funded Commercial Facilities] and D [Residential Building] of this Part applies to any new building or structure in this State for which a building permit application is received by a municipality or county. [20 ILCS 3125/20]
A) Additions, alterations, renovations or repairs to an existing building, building system or portion thereof shall conform to the provisions of the Code [2009 IECC] as they relate to new construction without requiring the unaltered portion of the existing building or building system to comply with the Code [2012 IECC]. [20 ILCS 3125/20(c)]
B) All exceptions listed in the Code [2012 IECC] related to additions, alterations, renovations or repairs to an existing building are acceptable provided the energy use of the building is not increased.

[Emphasis intended] (2012 IECC C101.4.3 or R101.4.3)

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Q: If you install some form of permanent heating (radiant, warm-air forced-air, or heat-pump) into a garage does the garage, then; have to meet the thermal envelope requirements of the IECC?

A: Yes. Once the input capacity of the heater (or unit heater) exceeds 3.4 Btu/h • ft2 (1.0 W/ ft2) of floor area, the space, in this case the garage, is considered "conditioned." Therefore, the surrounding walls, windows, doors, overhead doors, roof, and slab-edge become the boundary of the building thermal envelope and must be insulated. Note also that the air-leakage requirements of the code apply to the enclosing doors and windows as well. (2012 IECC C101.5.2 or R101.5.2, 202 – BUILDING THERMAL ENVELOPE, CONDITIONED SPACE)

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Q:  I was wondering, will Senate Bill 3724 have any impact on the adoption and implementation of the 2012 IECC, and if so, when will the new, 2012 IECC apply to a project?

A:  SB3724 has passed has passed the “required” three readings in the Senate and House, unopposed.

3/29/2012 Senate Third Reading - Passed; 056-000-000
5/26/2012 House Third Reading - Short Debate - Passed 109-000-000
5/26/2012 Senate Passed Both Houses

At this point, if SB3724 were to be signed into law by the Governor, it would set back the effective date of the 2012 IECC to January 1, 2013.  So the impact would be roughly, a 5-month reprieve.  This would allow stakeholders more time for training and preparation to build, design, and enforce to the 2012 IECC. 

The Administrative Rules to adopt the 2012 IECC with amendments were filed with the Secretary of State and published in Issue 18 of the Illinois Register on May 4, 2012. The First Notice period commences upon publication of an agency's Notice of Rulemaking in the Illinois Register. First Notice lasts a minimum of 45 days and terminates when the agency files with JCAR, commencing the Second Notice period. The general public can submit comment on the rulemaking proposal to the agency.  The Illinois CDB contact information is included at the end of the notice. 

Until the rules are updated, the 2009 IECC will stay in effect; with Illinois CDB continuing to move forward with the tentative August 1, 2012 effective date for the 2012 IECC.

If/When the 2012 IECC becomes effective, only projects for which permit applications are applied for “on or after” the “effective date” will be subject to the provisions of the Act.

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Q: Our legal department has determined that since we have adopted by reference the 2006 IECC before May, 15 2009 our jurisdiction is not required to enforce the 2012 IECC for residential construction.

A: On issues pertaining to the provisions of the Illinois Energy Efficient Building Act [20 ILCS 3125] specific to Home rule communities, please note the following language as excerpted from the Act [20 ILCS 3125/45(b)], addressing Home rule units, “… the following entities may regulate energy efficient building standards for residential buildings in a manner that is more stringent than the provisions contained in this Act.” [Emphasis intended].

Therefore, the jurisdiction in question could elect to enforce a residential energy code locally; in a manner that is more stringent than the residential provisions of the 2012 IECC, but only if the jurisdiction had adopted the 2006 IECC on or before May 15, 2009. Alternatively, the provisions of the 2012 IECC for residential buildings are to be enforced at a minimum, in accordance with the Act. Put another way, the 2012 IECC represents a minimum standard.

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Q: If a wood-framed wall of a residential building is being re-insulated, what is the minimum required R-value based on our Climate Zone 5A? This is not for the whole wall assembly; the scope of work simply consists of removing and replacing wall cavity insulation and then applying an interior drywall finish.

A: The work constitutes an “alteration” as outlined in Section R101.4.3, Exception 3, requiring replacement with insulation having a density of at least R-3/inch. Note that many of the exceptions outlined in Section R101.4.3 are derivations, in whole or in part, from language appearing in ASHRAE Standard 90.1-2010. In particular, note Section 5.1.3(c) of the Standard. [2012 IECC R101.4.3, 90.1-2010 5.1.3(c)]

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COMMERCIAL, Chapter 5

Q: For commercial buildings, do 2012 IECC Sections C401.1, Scope, and 401.2, Application, allow the permit applicant to mix-and-match provisions of IECC Chapter C4 and ASHRAE Standard 90.1-2010 on a single permit application for compliance assessment?

A: No, designers are not permitted to select a customized path to compliance by combining provisions of both Standard 90.1 and the IECC. In fact, Sections C401.1 and C401.2 now require the designer to demonstrate compliance with either the provisions of IECC Chapter C4 (in its entirety) or the provisions of Standard 90.1 (in its entirety); no combination thereof is permitted.

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Q: With respect to Lighting Alterations, Section C101.4.3, Exception 7 allows alterations that replace less than 50 percent of the luminaires in a space, provided that such alterations do not increase the installed interior lighting power. There are a variety of ways that this exception can be interpreted, please explain?

A: If the scope of the work includes lighting and other IECC regulated systems, and less than 50% of the luminaires are replaced, the lighting alterations (alone) are exempt, provided that the lighting alterations (alone) do not increase interior connected lighting power beyond the former level of connected lighting power for the altered/affected spaces.

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