The first public version of the International Green Construction Code was made available in March of 2010 and immediately started a firestorm in the Commercial Modular Building Industry. Modular as well as other forms of pre-fab buildings always view new codes and regulations with a wary eye for the simple reason that the framers of these documents never consider alternative forms of construction when authoring new codes. The new IgCC is a perfect example.
Before I get too deep into the negative impact of this document, let me say something that will come across as contradictory. We support the intent of the IgCC. Energy conservation, effective use of recycled and renewable materials and the efficient use of natural resources are all very important. That being said, the perfect green storm that was created by the media has opened the door to many new rules and regulations “because it’s the right thing to do” without determining its affects on building owners, small business, the A&E community, small contractors and a slow to recover economy.
The Modular Building Institute has circled the wagons by soliciting volunteers and hiring consultants to analyze the IgCC in order to format comments in an attempt to seek relief from some of the more onerous requirements as it applies to re-locatable modular buildings. Efforts so far have been largely a learning experience and unfortunately have not been successful in changing the minds of the committee. MBI’s efforts should be applauded. Their campaign includes a comprehensive strategy to analyze potential threats, develop public comments, solicit allies in the cause, and to sell the virtues of an inherently greener forms of construction – modular. Due to off-site construction techniques and working in a controlled environment, modular construction generates significantly less construction waste than conventional construction. Additionally, the de-constructability of modular buildings allows for re-location and re-purposing of a building rather than demolition. That amounts to the ultimate diversion from landfills.
Studies generated by MBI indicate the IgCC will generate significant cost impacts to our industry’s core markets. It would cost on average an additional 36% to construct a new IgCC compliant portable classroom over one built to the 2006 IBC and IECC.
Please understand that the 2006 edition of the IECC, International Energy Conservation Code and ASHRAE Standard 90.1 already provide design requirements for building energy performance that have become more stringent with each new code edition with the goal of making buildings more energy efficient. So if a building is not built under strict compliance to the IgCC, realize it is already constructed with energy conservation in mind.
Cost to retrofit an existing building approach 100% of the initial purchase price. As the code is written now, retrofit of an existing building would be required whenever the building is re-located. I would think a large metropolitan school district such as Los Angeles, Houston, Miami, Atlanta or Phoenix may relocate over 100 portable classroom buildings each year to meet their expansion and changing enrollment needs. This law would virtually make their current buildings obsolete, costing each district millions of dollars. It is also important to note these cost impacts only address hard construction costs to the building. Increased design costs, increased site costs, additional metering, and enhanced commissioning would increase the overall project costs significantly more.
One area that has been discussed and should be pushed for is an implementation square foot threshold for all new construction in an effort to provide relief for small businesses. Virtually all modular buildings as well as most prefab buildings cater to small businesses where the price point is the largest single factor in the buying decision. It is feared that most small business owners when faced with expansion needs will make do with existing structures rather than incur a steeply inflated cost for new construction brought on by the IgCC. MBI has quoted a study by the National Renewable Energy Laboratory which cited the average-sized non-residential building is 14,500 square feet. Across all categories of buildings in the study, no average was smaller than 5,500 square feet. Seeking an exemption for buildings below 5,000 square feet seems a reasonable request and would encompass the majority of temporary modular buildings as well as most permanent offerings.
The IgCC makes perfect sense for new sports stadiums, high-rise office towers, big government buildings, commercial office parks, extensive educational facilities or large scale public housing where the additional compliance costs can be amortized across huge square footages. But the IgCC makes no sense at all for a small business seeking a 2,500 square foot office or a school district seeking portable classrooms to address isolated campus over-crowding. These are users that typically turn to modular buildings for quick and cost effective solutions, but because of the IgCC, they’ll get neither…
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Linc Moss is President of Ramtech Building Systems, Inc. He has been in the modular construction industry for 36 years, has twice been President of the Modular Building Institute, and has represented the commercial modular building industry before Congress.
