| Action | Update the Uniform Statewide Building Code |
| Stage | Proposed |
| Comment Period | Ended on 5/9/2023 |
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4 comments
Comments: Because the Virginia USBC uses the same administrative procedures to administer all codes, we recommend parity with the IBC and IRC (Sec. R109.1.3 and R109.1.6.1), by referencing both Section 1612 (building) and Section R322 (residential), as applicable. If both are not referenced, it can be misinterpreted that documentation required by Sec. R322 is not required to be submitted at the times specified. If not included here, permittees could submit whenever they chose.
REQUEST REVISION TO ADD changes to Section 113 H. and I., as follows to add in two places the phrase "or Section R322, as applicable," (shown using bold underline):
H. 113.3.2 Lowest floor elevation. In flood hazard areas, upon placement of the lowest floor, including the basement, and prior to further vertical construction, the elevation certification required in Section 1612.5 1612.4, or Section R322, as applicable, shall be submitted to the building official.
I. 113.3.3 Flood hazard documentation. If located in a flood hazard area, documentation of the elevation of the lowest floor as required in Section 1612.5 1612.4, or Section R322, as applicable, shall be submitted to the building official prior to the final inspection.
Comments: There is confusion between “design flood elevation” (which is the water elevation) and the “elevation required in Sec. R322.3.2” which is where the minimum elevation of the lowest horizontal structural member relative to the water is specified. FEMA deliberately changed to “required elevation” in the 2018 IRC (and Virginia picked up those changes in its 2018 edition). FEMA previously comments to use phrasing that matches the IRC.
REQUEST REVISION TO DELETE, shown without underline for clarity. Remove the words “design flood” as shown with bold Strike-through.
R322.3.6 Enclosed areas below required elevation. Enclosed areas lower than the design flood elevation required in Section R322.3.2 are prohibited in Coastal A Zones and Coastal High Hazard Areas.
Comments: There is confusion between “design flood elevation” (which is the water elevation) and the “elevation required in Sec. R322.3.2” which is where the minimum elevation of the lowest horizontal structural member relative to the water is specified. FEMA deliberately changed to “required elevation” in the 2018 IRC (and Virginia picked up those changes in its 2018 edition). FEMA previously comments to use phrasing that matches the IRC. Citing “design flood” could mean a tank is lower than the dwelling it serves.
REQUEST REVISION TO DELETE shown without underline for clarity. Remove the words “design flood” as shown with bold strike-through.
R322.3.10 Tanks. Underground tanks are prohibited in Coastal A Zones or Coastal High Hazard Areas. Aboveground tanks shall be installed at or above the design flood elevation required in Section R322.3.2. Where elevated on platforms, the platforms shall be cantilevered from or knee braced to the building or shall be supported on foundations that conform to the requirements of Section R322.3.