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9/25/20  2:51 pm
Commenter: Virginia Plumbing and Mechanical Inspectors Association

Strongly Oppose Mandatory Use of ASHRAE 62.1 and 62.2
The Virginia Uniform Statewide Building Code (USBC) Part I incorporates the 2015 International Mechanical Code per Section 101.2, which provides ventilation requirements for new construction in Chapter 4. ASHRAE 62.1 or 62.2, in whole, are not referenced in the USBC. In fact, the only reference is to Appendix A of ASHRAE 62.1 for system ventilation efficiency as an option and ASHREA 62.2 is not referenced at all. Aside from the incredible cost of retrofitting existing buildings in order to provide compliance to 2019 ASHRAE Standards 62.1 and 62.2, USBC Part II incorporates the 2015 International Existing Building Code per Section 101.2, which provides limited retrofit requirements referenced in Section 103.3. These retrofit requirements do not include provisions for ventilation upgrades. Code of Virginia section 36-98 states “The Board [Board of Housing and Community Development] is hereby directed and empowered to adopt and promulgate a Uniform Statewide Building Code. Such building code shall supersede the building codes and regulations of the counties, municipalities and other political subdivisions and state agencies.”. The proposed ASHRAE standards are building code regulations, which are superseded by the USBC.
CommentID: 86310