On December 9, APGA submitted comments in response to the International Code Council’s (ICC) request for feedback on its Cost Impact Guide. This guide is intended to aid code change proponents in better understanding ICC’s cost impact requirements.
According to ICC’s Council Policy 28, the proponent of a code change must identify the proposal’s estimated immediate cost impacts, as well as identify how that number or range was calculated and what data sources were used. For proponents of code changes to the International Energy Conservation Code (IECC), a life-cycle cost impact must also be provided but is optional for all other I-Code change proposals.
Through the comments, APGA urged ICC to make a number of updates to the Cost Impact guidance. For instance, APGA requested that the ICC build out the “Reference Material” section to include a more diverse list of sources and also clarify that the list is not all inclusive. APGA asked that ICC also include a requirement that all code change proponents utilize at least two different reference sources to support their cost impact analyses to help reduce bias in the calculation. Furthermore, APGA also requested that a committee be created to help settle disputes over the accuracy of cost impact analyses and for ICC to require a conflict-of-interest disclosure if any cited data was developed by the proponent’s company or sponsor.
APGA will continue to advocate for transparent cost impact analyses in the building code development process, both through processes like this request for feedback as well as in code development committee meetings.
For questions on this article, please contact Stuart Saulters of APGA staff by phone at 202-802-0493 or by email at ssaulters@apga.org.