Proposed Modification to the Florida Building Code by vYcL52D

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									Proposed Modification to the Florida Building Code
Modification #:                             Section 553.73, Fla Stat

Name: Joseph D. Belcher
Address: 41 Oak Village Boulevard Homosassa, 34446
E-mail: JDBCodeservices@tampabay.rr.com
Phone: 352-450-2631
Fax: 813-925-4152
Code: Florida Building Code - Residential
Section #: R301.2.1.2.1

Text of Modification [additions underlined; deletions stricken]:

R301.2.1.2.1 Modifications to ASTM E 1996. Section 6.2.2 of ASTM E 1996 shall be modified
as follows:
6.2.2 Unless otherwise specified, select the wind zone based on the basic wind speed as
follows:
6.2.2.1WindZone 1 - 130 mph ≤ basic wind speed < 140 mph, and Hawaii.
6.2.2.2 Wind Zone 2 - 140 mph ≤ basic wind speed < 150 mph at greater than 1.6 km (one
mile) from the coastline. The coastline shall be measured from the mean high water mark.
6.2.2.3 Wind Zone 3 - 150 mph (58 m/s) ≤ basic wind speed < 160 170 mph (63 m/s), or 140
mph (54 m/s) ≤ basic wind speed ≤ 160 170 mph (63 m/s) and within 1.6 km (one mile) of
the coastline. The coastline shall be measured from the mean high water mark.
6.2.2.4 Wind Zone 4-basic wind speed > 160 170 mph (63 m/s).



Fiscal Impact Statement [Provide documentation of the costs and benefits
of the proposed modifications to the code for each of the following entities.
Cost data should be accompanied by a list of assumptions and supporting
documentation. Explain expected benefits.]:

A.   Impact to local entity relative to enforcement of code:
       No impact to local entity relative to enforcement of code.

B.   Impact to building and property owners relative to cost of compliance
     with code:
       Will result in a reduction in cost to building and property owners in
       areas currently included in Wind Zone 4 that are not intended by
       ASTM to be included in Wind Zone 4.

C.   Impact to industry relative to cost of compliance with code:
       Reduction in costs as only products with approval for use in HVHZ
       have been designed and tested to meet the increased impact
       requirements and the offset criteria intended for Wind Zone 4.

D.   Impact to small business:
     Failure to accept the proposal and properly correlate the wind speeds
     between the standards and the code will result in products currently
     acceptable in many areas to no longer be acceptable without revising
     product approvals, retesting, and possibly requiring redesign. This
     would cost the small business in the hurricane protection industry
    thousands and perhaps hundreds of thousands of dollars. In the short
    term, a small business working in the areas where Wind Zone 4 has
    been expanded may not have any product to sell and could be driven
    out of business.

Glitch Criteria:
The provisions modifying ASTM E 1996 within the code constitute a glitch
because they expand the standard beyond the intended area for Wind Zone
4. This is an unintended consequence from a Florida Specific Amendment
which changes an adopted standard and will extend provisions related to
testing and deflection provisions beyond the area intended by the standard
to be affected by the provisions. The change results in a standard that is
not the equivalent of the standard being changed and should be adjusted
to rectify the application of provisions intended for the most southern part
of the State to other areas of the state.


Rationale [Provide an explanation of why you would like this Proposed
Modification to the Florida Building Code.]: 1. I have spoken with the
proponent of the change, Eric Stafford, P.E. Mr. Stafford states the intent of
the change was to correlate the provisions of ASTM E 1996 and the
ultimate wind speeds of ASCE 7-2010 within the code. There was no
intention to expand Wind Zone 4 into new areas of the State. The
correlating change does much more than correlate the code by expanding
Wind Zone 4 provisions for impact resistive systems intended for Miami-
Dade County into more areas of the State than intended by ASTM.

2. The creation of Wind Zone 4 within ASTM E 1996 first appeared in the
2002 Edition of ASTM E 1996 at the request of the Miami-Dade County
representative on the ASTM Committee. The wind zone was intended to
apply to Miami-Dade County and Monroe County. Broward County,
although not a greater than 140 mph wind speed area, indirectly adopted
the wind zone throughout by accepting only products approved for use in
the HVHZ which have to meet HVHZ Protocols, which incorporate the more
stringent provisions for Wind Zone 4. In addition, the FBCR prohibits
deformation of impact protective systems from contact with glass. (FBCR
§4403.16.2.6.1; §4403.16.3.6.1)

The wind zone was created by ASTM to address the more stringent
provisions adopted by Miami-Dade County to encourage the use of ASTM E
1996 by Miami-Dade County. The Miami-Dade County (M-DC) standards
(TAS 201 and 203) are more stringent than those of ASTM E 1996 for Wind
Zones 1, 2, and 3 and ASTM E 1996 Wind Zone 4 was created to allow the
use of ASTM E 1996 in Miami-Dade County. The downturn in the economy
prevented the continued participation by the county and as a result the
task was not completed. Specific differences are found in the number of
strikes and the offset criteria of the standard.

The M-DC test standards and ASTM E 1996, Wind Zone 4, require each
specimen to withstand two strikes for the large missile test; ASTM E-1996
Wind Zones 1, 2, and 3 requires a single strike to each specimen. In
addition, in Wind Zone 4 the standard calls for strikes directly on integral
mullions and other intermediate members. The added requirements add
cost to the products as well as to the testing of the products and go
beyond the intent of the adopted standard.

Even more disconcerting are the requirements related to the offset of the
impact protective systems. In Wind Zone 4 all impact protective systems
are required to comply with the greater of the maximum deflection
measured in accordance with Section 5.5, plus 25%, or the sum of the
maximum deflection and residual deflection, as measured at Section 5.5,
plus 25%. (ASTM E 1996-2005) ASTM E 1996-2006 and 2009 modify the
requirements to apply to all non-porous systems in Wind Zone 4 requiring
an offset of the greater of the maximum dynamic deflection measured at
Section 5.5, plus 2 mm, or the sum of the maximum deflection and residual
deflection as measured at Section 5.5, plus 2 mm. (ASTM E 1996-2006 and
2009, §8.3) In the field these requirements result in an offset of from three
inches to more than eight inches depending on the materials used in the
impact protective system. The added requirements add cost to the
products as well as to the testing of the products and go beyond the intent
of the adopted standard.




Please explain how the proposed modification meets the following
requirements:
   1. Has a reasonable and substantial connection with the health, safety,
      and welfare of the general public: The proposed amendment properly
      correlates the adoption of ASCE 7-10 with ASTM E 1996 within the
      Florida Building Code, Residential which has a reasonable
      connection with the health, safety, and welfare of the general public
      by not posing provisions greater than intended by the adopted
      reference standard.

   2. Strengthens or improves the code, and provides equivalent or better
      products, methods, or systems of construction: The proposed
      amendment properly correlates the adoption of ASCE 7-10 with
      ASTM E 1996 within the Florida Building Code, Residential which
      strengthens and improves the by not posing provisions greater than
      intended by the adopted reference standard.

   3. Does not discriminate against materials, products, methods, or
      systems of construction of demonstrated capabilities: The proposed
      amendment does not discriminate against materials, products,
      methods, or systems of construction of demonstrated capabilities
      and, in fact, removes what could be considered a discriminatory
      provision.

   4. Does not degrade the effectiveness of the code: The proposed
   amendment properly correlates the adoption of ASCE 7-10 with
   ASTM E 1996 within the Florida Building Code, Residential which
   does not degrade the effectiveness of the code.

5. The provisions contained in the proposed amendment are addressed
   in the applicable international code.

   The provisions are not addressed in the IBC 2009 as they were a
   Florida Specific Amendment intended to correlate the code and the
   ASTM standard with the adoption of ASCE 7-10. The same provisions
   appear in the 2012 IBC and the proponent intends to submit a
   revision in the next available IBC Code Change Cycle.

6. The amendment demonstrates by evidence or data that the
   geographical jurisdiction of Florida exhibits a need to strengthen the
   foundation code beyond the needs or regional variations addressed
   by the foundation code, and why the proposed amendment applies
   to this state.

   The amendment is intended to address a correlation issue between
   the code, the adopted ASTM standard, and the Florida adoption of
   ASCE 7-10. The change was intended to correlate the three
   documents, but the correlation did not occur. Wind Zone 4 in the
   ASTM standard is intended to address Miami-Dade County and
   Monroe County. The revision as adopted expands shutter
   requirements intended for Miami-Dade County to numerous other
   counties in the State of Florida.

7. The proposed amendment was submitted or attempted to be
   included in the foundation codes to avoid resubmission to the
   Florida Building Code amendment process.

   The amendment will be submitted to the ICC Group B Code Change
   Cycle for the 2015 International Residential Code.
To Whom It May Concern:

I am the proponent of the change to Section 1609.1.2.4 of the Florida Building
Code and Section 1609.1.2.2 of the International Building Code that modified the
wind speeds that establish the Wind Zones in ASTM E 1996. The intent of the
change was to correlate the new wind speeds in ASCE 7-2010 with the code and
ASTM E 1996. It was not the intent to make any technical changes to the
applicability of ASTM E 1996. It is my understanding that the effect of this code
change results in an expansion of Wind Zone 4 beyond what was required in the
2007 Florida Building Code.
Since proposing the change I have been told that Wind Zone 4 first appeared in
the 2002 Edition of ASTM E 1996 due to contributions from Miami-Dade County
personnel while serving on the ASTM Committee. Miami-Dade County intended
to propose specific modifications to ASTM E 1996 that would provide
requirements for Miami-Dade County that were equivalent to the HVHZ Test
Protocols TAS 201 and 203. Such modifications to ASTM E 1996 would permit a
direct reference to ASTM E 1996 in the HVHZ and a subsequent phasing out of
TAS 201 and 203. The establishment of Wind Zone 4 was intended to apply
strictly to Miami-Dade County and a portion of Monroe County.
I understand the proposed code change results in an expansion of Wind Zone 4
and is an unintended consequence. As a result of this unintended consequence,
I would support changes to the code that would essentially reestablish the
applicability of Wind Zone 4 consistent with the applicability in the 2007 Florida
Building Code.

T. Eric Stafford, P.E.
Code Consultant

								
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