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.