According to National Multifamily Housing Council (www.nmhc.org), noise has been identified as a major issue by residents of multifamily residential buildings. In addition, according to Alexandria, VA Office of Housing, noise transmission is one of the biggest issues for renters in
multifamily buildings. The problem is worst in buildings constructed of wood above concrete podiums, and better in steel and concrete high rises. Further, thousands of resident reviews are available on the internet citing poor sound insulation of multifamily residential buildings including those recently constructed so it appears that the existing building codes/construction techniques do not result in the adequate level of the sound insulation in multifamily buildings; finally, when the residents move into brand new multifamily residential buildings there is no way for the residents to know what the building sound insulation will be. 

December 22, 2021

To:  Board of Housing and Community Development
c/o Kyle Flanders, Department of Community Development

From:  Virginia Clinicians for Climate Action

Re:  Comments on NOIRA for 2021 Cycle to Update the Building Code

These comments are submitted on behalf of Virginia Clinicians for Climate Action (VCCA). VCCA was founded in 2017 in order to bring the clinician voice in support of local  and statewide climate policy solutions that protect the health of our patients and communities in the Commonwealth. As clinicians, we are concerned about the building code as it relates to the impact of home efficiency, air quality and harmful exposures on the health of Virginians. 

The health benefits of strong building codes are significant.1 Numerous scientific studies have demonstrated that housing renovations that improve ventilation, insulation, and heating/ cooling equipment result in reduced pollutants, better controlled indoor temperature and moisture, and avoidance of building materials that contain hazardous substances. Increased insulation protects against cold or heat-related deaths in areas that experience extreme temperatures.2  Warmer, drier indoor air protects against symptoms of respiratory disease including asthma and Chronic Obstructive Pulmonary Disease.3 Upgraded heating and ventilation systems can limit exposure to particulates, gaseous pollutants, and mold. These improvements can decrease symptoms of respiratory and heart disease and reduce risk of cancer.2  

Moreover, improved indoor air quality can particularly benefit the health outcomes of low-income populations.4 A study conducted in 2014 found that low-income, multi-family households living in green buildings experienced fewer symptoms pertaining to illness. They also observed a significant improvement in the health of individuals who moved into green housing and significant decreases in exposure to harmful indoor air pollutants.5 Furthermore, energy-efficient homes can improve the well-being of Virginians through decreasing the financial burden associated with energy costs.

New buildings and updated older buildings will be occupied for years to come. Thus, the health, energy, and cost savings from energy-efficient homes have a long-term positive impact on Virginians’ health that will accrue over decades. Structural efficiency improvements are much less costly to install during initial construction. Missing that opportunity reduces the chances that such improvements will ever be made or the health benefits realized by occupants. Energy production and emissions also contribute to air pollution and climate change, both of which are associated with a multitude of direct and indirect health consequences.6

For the reasons stated above, VCCA supports the adoption of the full 2021 IECC without any weakening amendments in order to best serve the public interest as prescribed by Virginia Code Section 36.99A.  Section 36-99A of the Virginia Code prescribes  “The provisions of the Building Code and modifications thereof shall be such as to protect the health, safety and welfare of the residents of the Commonwealth….” In order to achieve optimal health benefits to current and future Virginians, the review process should begin with the 2021 IECC and conclude with adoption of standards at least as stringent as those in this IECC. 

Adopting such standards would perform the important function of keeping Virginia’s building code “in sync with the national model codes,” except where more stringent standards are feasible. Doing so would also be consistent with H2227, which requires consideration of standards “at least as stringent” as those in the IECC and even more stringent when the benefits to residents and the public over time exceed the incremental cost of construction.

VCCA urges the Board to expeditiously adopt and implement updated building codes that are at least as stringent as the 2021 IECC.  Doing so will best protect the health of Virginians for decades to come.

Respectfully submitted, 

Samantha Ahdoot, MD

Chair, Virginia Clinicians for Climate Action

1 Sharpe RA, Taylor T, Fleming LE, Morrissey K, Morris G, Wigglesworth R. Making the Case for "Whole System" Approaches: Integrating Public Health and Housing. Int J Environ Res Public Health. 2018;15(11):2345. Published 2018 Oct 24. doi:10.3390/ijerph15112345

2 Wilson J, Jacobs D, Reddy A, Tohn E, Cohen J, Jacobsohn E. Home rx: The health benefits of home performance. National Center for Healthy Housing, U.S. Department of Energy. 2016;DOE/EE-1505 7861

3 E4The Future I. Occupant health benefits of residential energy efficiency. E4The Future, Inc. 2016

4 Breysse J, Jacobs DE, Weber W, et al. Health outcomes and green renovation of affordable housing. Public Health Rep. 2011;126 Suppl 1(Suppl 1):64-75. doi:10.1177/00333549111260S110

5 Colton MD, MacNaughton P, Vallarino J, et al. Indoor air quality in green vs conventional multifamily low-income housing. Environmental science & technology. 2014;48(14):7833-7841. http://dx.doi.org/10.1021/es501489u. doi: 10.1021/es501489u.

6 Romanello M, McGushin A, Di Napoli C, et al. The 2021 report of the Lancet Countdown on health and climate change: code red for a healthy future. Lancet. 2021 Oct 30;398(10311):1619-1662. doi: 10.1016/S0140-6736(21)01787-6. Epub 2021 Oct 20. Erratum in: Lancet. 2021 Dec 11;398(10317):2148. PMID: 34687662.