Adam Smith

1342 N Main St. #11, Ann Arbor, MI 48104

734/ 926-5593 - hello@synecdoche.design

April 4, 2024

Michigan Department of Licensing and Regulatory Affairs (LARA)

Bureau of Construction Codes

Via email to LARA-BCC-RULES@michigan.gov

Re: Support for Mass Timber incorporated in 2022-57 LR Construction Code – Part 4. Building

Code, “Draft Rule”

Dear Bureau of Construction Codes Team,

We support the adoption into the 2021 Michigan Building Code the 2021 International Building Code,

particularly the mass timber elements identiﬁed as building types IV-A, IV-B, IV-C, and IV-HT. We request one

amendment to Type IV-B 602.4.2.2 Interior Protection that, if adopted, will enable Michigan practitioners to

deliver mass timber buildings more aﬀordably and to optimize the architectural and sustainability beneﬁts of

the materials.

Speciﬁcally, The Tall Wood Building Ad Hoc Committee (TWBAHC) had only wanted to include provisions in

the 2021 IBC that had been tested. Since the time the Ad Hoc Committee ﬁnished their work until the Group

A CAH period ended, additional testing was conducted on several building types. Based on based on testing

and data provided by the RISE institute (ref 2-4), the 2021 TWBAHC recommended that the 2024 IBC

update Type IV-B language to allow for up to 100% exposure of mass timber ceilings, based on the following

justiﬁcation;

“The proposed revisions above are based upon recently completed research conducted at the

Research Institute of Sweden (RISE). These ﬁre tests demonstrated that the proposed amounts

of unprotected areas on the ceiling and walls, as a function of ﬂoor area, can be safely

implemented while still achieving the performance objectives speciﬁed by the ICC Tall Wood

Building Ad-Hoc Committee in the development of the tall building mass timber provisions in the

2021 I-codes. Speciﬁcally, Test 1 of the test series conducted at RISE involved a ceiling in which

100% of the area was unprotected mass timber. Tests 2 and 5 had unprotected mass timber on

100% of the ceiling area, in addition to unprotected areas on the two opposing side walls,

equivalent to 78% of the ﬂoor area. These tests exhibited satisfactory performance in that no

signiﬁcant ﬁre re-growth was observed and temperatures within the compartment decreased

continuously from the time of the fully-developed phase until the end of the four-hour test”

- (ref. 1)

1 of 3

Based on this, we support sections 602.4.2.2.2 in the draft 2021 Michigan Building Code with the minor

exceptions below which are presented below and have been adopted in the 2024 International Building

Code:

602.4.2.2 Interior protection. Interior faces of all mass timber elements, including the inside face of

exterior mass timber walls and mass timber roofs, shall be protected, as required by this section, with

materials complying with Section 703.3.

602.4.2.2.1 Protection time. Noncombustible protection shall contribute a time equal to or greater than

times assigned in Table 722.7.1(1), but not less than 80 minutes. The use of materials and their

respective protection contributions specified in Table 722.7.1(2) shall be permitted to be used for

compliance with Section 722.7.1.

602.4.2.2.2 Protected area. Interior faces of mass timber elements, including the inside face of exterior

mass timber walls and mass timber roofs, shall be protected in accordance with Section 602.4.2.2.1.

Exceptions: Unprotected portions of mass timber ceilings and walls complying with Section

602.4.2.2.4 and the following:

1. Unprotected portions of mass timber ceilings and walls complying with one of the following:

1.1

Unprotected portions of mass timber ceilings, including attached beams, shall be

permitted and shall be limited to an area less than or equal to 20100 percent of the ﬂoor area in

any dwelling unit Or ﬁre area.”

1.2

Unprotected portions of mass timber walls, including attached columns, shall be

permitted and shall be limited to an area less than or equal to 40 percent of the ﬂoor area in any

dwelling unit or ﬁre area

As a practicing architect in Michigan, adding this amendment will help us deliver designs for buildings,

particularly critically needed housing, that achieve the design and sustainability goals of our communities.

Having to go through a variance for each project of this type adds cost and time onto an already long and

expensive process in which the ultimate ﬁnancial burden is placed on tenants of the building. Additionally

removing the need to have extensive coverage of timber elements reduces construction cost and enhances

livability without reduction in life safety.

Sincerely,

Adam Smith AIA, NCARB

Director of Design - Synecdoche

Lisa Sauve, AIA, NCARB

Principal - Synecdoche

Founder, Executive Director - Do Good Work

______

2 of 3

Reference 1 (Code): G147-21 ICC Ad-Hoc Committee on Tall Buildings recommendation for change to

IBC 602.4.2.2.2 -

Reference 2 (Technical): USDA Forest Products Laboratory General Technical Report FPL-GTR-247 -

May 2018

Reference 3 (Technical): RISE Report 2021:40 Final Report - Fire Safe implementation of visible mass

timber in tall buildings - compartment ﬁre testing - 2021

Reference 4 (Technical): RISE Report 2020:94 Summary Report - Fire Safe implementation of visible

mass timber in tall buildings - compartment ﬁre testing - 2021

Reference 5 (Technical): 2022 FDS Fire design Speciﬁcation for Wood Construction by The American

Wood Council

Reference 6 (Technical): RISE Report 2021:63 Predictive method for ﬁres in C L T a nd glulam structures -

A priori modeling versus real scale compartment ﬁre tests and an improved method - 2021

3 of 3

Steven Banchero

Dr. R.J. Webber

Superintendent

Steve Banchero

Director of Operations

April 4, 2024

Tony Williamson

State of Michigan

Bureau of Construction Codes

P.O. Box 30254

Lansing, MI 48909

sent via (Lara-bcc-rules@michigan.gov) and (WilliamsonT5@michigan.gov)

Re: Rule Set 2022-57 LR-Public Comment

Mr. Williamson,

I am submitting a comment regarding the proposed rule changes to the Michigan Construction Code -Part

4—Building Code rule set. The proposed rules incorporate by reference the 2021 International Building

Code with Michigan amendments, additional or deletions. The topic of my comment is regarding Section

423 Storm Shelters.

My position at Northville Public Schools is the Director of Operations; part of my responsibilities is

managing and overseeing capital projects within the school district. I have a Bachelor's degree in Civil

Engineering from Michigan Technological University and a Master's in Applied Science and Construction

Management from Eastern Michigan University. Before being employed by Northville Public Schools, I

spent almost all of my career building and renovating public schools throughout southeast Michigan with a

prominent construction management firm in Farmington Hills, Michigan.

I am requesting the Michigan Bureau of Construction Codes evaluate the implementation of Section 423

for use Group E. The Bureau adopted the 2015 IBC without the storm shelter provision in the prior code

update cycle. The same concerns that moved the state to remove the requirement exist today.

The State of Michigan does not fund capital improvements for local school districts. Outside of recent

Federal and State grants, the vast majority of funding is accomplished by the local district asking voters to

approve issuing bonds or local sinking funds. The process of assessing facilities, gathering community

input, school board authorization, voting, design, and construction takes years to accomplish.

During the capital improvement planning stages, care is taken to budget for current and future

construction costs. If adopted, Section 423 will have a significant negative impact on projects that were

planned for and financed without the requirement.

In 2022, Northville Public Schools performed a facility evaluation. We gathered community input, and the

Board of Education authorized a bond initiative to be put on the ballot. In March of 2023, the voters

approved the bond initiative. Currently, two significant projects are in the design process. Part of the

scope of the projects is building additions to an elementary and middle school. If the projects are

submitted for plan review after the implementation of the new proposed code, it is likely that a significant

amount of the proposed scope will have to be eliminated to fund the cost of the storm shelter requirement.

Future projects will face a very similar situation as we budget the projects without the requirement of

Section 423. We are not in a unique situation. School districts that already have financing in place will see

considerable unanticipated cost increases with the storm shelter requirement.

The State of Ohio faced a similar situation during a code cycle update. I have included a 2019 report from

the Ohio Facilities Construction Commission and a 2022 memo from the Ohio Board of Building

Standards. The summary of the two documents indicates an extensive study and review process for the

implementation of Section 423. The stakeholders realized that it would have a significant impact on

projects that had already secured financing. Ohio phased the implementation in and developed a specific

timeline so that the planning for future projects could be budgeted at the appropriate level to incorporate

the new code requirement.

The State of Michigan BCC should develop a similar review and implementation process so that the new

code requirement does not negatively impact projects already underway.

Steve Banchero

Northville Public Schools

Director of Operations

bancherost@northvilleschools.org

405 W. Main Street

Northville, Michigan 48167

248.344.3510

Fax: 248.344.3506

BBS MEMO

Ohio Board of Building Standards

December 2, 2022

6606 Tussing Road, P.O. Box 4009, Reynoldsburg, Ohio 43068-9009

December 2022 Update: The moratorium in R.C. 3781.1010 which prohibited the Board’s rules from

requiring the installation of a storm shelter in any school building operated by a public or private school

expired on November 30, 2022. The moratorium also expired for any school building undergoing or about

to undergo construction, alteration, repair, or maintenance unless “financing has been secured” prior to

November 30, 2022. The Ohio Attorney General issued Opinion 2019-027 in response to the Board’s request

for guidance on the meaning of “financing has been secured” in R.C. 3781.1010. The Opinion is available

here .

September 2020 Update: HB 164 adopted by the Ohio General Assembly on June 11, 2020, amended R.C.

3781.1010 to extend the storm shelter moratorium to November 30, 2022.

August 2019 Update: HB 166 adopted by the Ohio General Assembly on July 17, 2019, amended R.C.

3781.1010 to extend the storm shelter moratorium to September 15, 2020. Additionally, the Ohio Attorney

General has issued Opinion 2019-027 in response to the Board’s request for guidance on the meaning of

“financing has been secured” in R.C. 3781.1010. The Opinion is available here .

On June 7, 2018, the Ohio General Assembly adopted House Bill (HB) 21 effective September 28, 2018

which includes new Revised Code (R.C.) § 3781.1010 enacting a moratorium on the building code

requirement for schools to have storm shelters until September 15, 2019. The 2017 Ohio Building Code

(OBC) adopted by the Board last year and effective November 1, 2017 included new Section 423.4

requiring storm shelters constructed in accordance with ICC 500 in Group E occupancies. New R.C. §

3781.1010 provides:

No rule of the board of building standards for the erection, construction, repair, alteration, and

maintenance of buildings adopted under section 3781.10 of the Revised Code shall require the

installation of a storm shelter in any school building operated by a public or private school prior to

September 15, 2019, or in any such school building undergoing or about to undergo construction,

alteration, repair, or maintenance for which financing has been secured prior to that date. Any rule

adopted by the board that conflicts with this section shall not be effective with respect to any school

building prior to September 15, 2019.

As used in this section, ‘school building,’ ‘public school,’ and ‘private school’ have the same meanings

as in section 3781.106 of the Revised Code.

Building departments and school districts should consider the following when evaluating how new R.C. §

3781.1010 may affect proposed school construction project designs and submittals:

(1) Projects submitted before November 1, 2017: Proposed school building designs (new buildings,

additions, alterations) submitted to the building department prior November 1, 2017 are subject to

the requirements of the code in effect at the time of application. Therefore, OBC § 423.4 does not

apply and would not be affected by HB 21.

(2) Projects submitted between November 1, 2017 and September 28, 2018: In R.C. § 3781.1010, the

General Assembly prohibited requiring storm shelters in schools until September 15, 2019. Building

FINANCIAL INSTITUTIONS•INDUSTRIAL COMPLIANCE•LIQUOR CONTROL•REAL ESTATE AND PROFESSIONAL LICENSING•SECURITIES•STATE FIRE MARSHAL•UNCLAIMED FUNDS

“An Equal Opportunity Employer and Service Provider”

Officials should consult with their legal counsel regarding whether resubmittal of the project is

needed for the moratorium to apply.

(3) Projects submitted on or after September 28, 2018: The moratorium applies; therefore, a storm

shelter constructed in accordance with ICC 500 is not required if the project is submitted prior to

September 15, 2019. Additionally, if financing has been secured for a project prior to September 15,

2019 the moratorium applies regardless of when the project is submitted. Building Officials should

consult with their legal counsel regarding what constitutes the securing of financing for the purposes

of R.C. § 3781.1010.

After the expiration of the moratorium on September 15, 2019, a storm shelter constructed in accordance

with ICC 500 will be required in Group E occupancies unless one of the above conditions apply, the project

falls within a listed exception in OBC § 423.4, a variance is granted, or the project is for an alteration of

an existing building and a storm shelter would not otherwise be required under OBC Chapter 34.

SCHOOL STORM SHELTER STUDY REPORT

to the 133^rdOhio General Assembly

Prepared by the

Ohio Facilities Construction Commission

December 2019

Introduction

In July 2019, Amended Substitute House Bill 166 of the 133^rdGeneral Assembly included a

statutory directive in Section 287.90, titled School Storm Shelter Study:

The Ohio Facilities Construction Commission shall conduct a study to evaluate and make

recommendations regarding appropriate requirements for storm shelters for Ohio

school buildings. The Commission shall conduct this study in consultation with

stakeholders, including school district officials, and submit a report of its findings to the

General Assembly not later than December 31, 2019.

OFCC is the central agency responsible for oversight of state-funded public building construction

projects, including projects in K-12 schools, state agencies, and state-assisted colleges and

universities. Under Ohio Revised Code (ORC) Chapter 3318, OFCC administers the state’s

facilities assistance to certain public schools for the construction or renovation of its facilities,

which to date has exceeded $12.3 billion. OFCC also provides grants to community and private

schools under separate legislative authority. In order to manage state’s facilities assistance

program, OFCC publishes the Ohio School Design Manual (OSDM), a set of design standards and

specifications for schools choosing to participate in its state-funded programs. The manual was

developed by Commission staff, in cooperation with architects and nationally recognized

educational planners. The design manual is updated annually and sets standards of quality for

the state’s educational facilities funded through OFCC programs.

Consultation with Stakeholders

Because the OSDM incorporates building code standards, in response to this legislative charge,

the OFCC staff consulted with the Department of Commerce’s Ohio Board of Building Standards

(BBS). BBS is the entity charged with adopting and enforcing rules governing the erection,

construction, alteration, and maintenance of all buildings or classes of buildings specified in ORC

Section 3781.06 (which is relevant to the school buildings). In addition to the statutory

requirements, the rules regulating non-residential buildings are codified in Ohio Administrative

Code Division 4101:1 and are collectively known as the Ohio Building Code (OBC). The OBC

provides the minimum requirements for the construction of school buildings, and the OSDM

provides additional standards, details or options above those required in code.

OFCC staff also met with and sought input from the following stakeholders:

•

School district officials suggested by the Buckeye Association of School Administrators

(BASA) and the Ohio Association of School Business Officials (OASBO);

Professional design experts suggested by the American Institute of Architects (AIA) and

the American Council of Engineering Companies (ACEC); and

Representatives from the Ohio Department of Public Safety, Ohio School Safety Center

Based on input from stakeholders, OFCC’s findings and recommendations are set forth below.

December 2019

Page 2 of 9

Building Code Requirements for School Storm Shelters

In July 2000, the Federal Emergency Management Agency (FEMA) published its first edition of

FEMA P-361, Safe Rooms for Tornadoes and Hurricanes: Guidance for Community and Residential

Safe Room. Now in its third edition, this document sets forth design and construction guidance

for tornado and hurricane shelters. FEMA also helped develop the International Code Council

(ICC) Standard for the Design and Construction of Storm Shelters, known as ICC 500, originally

published in 2008 and updated in 2014. ICC, in partnership with the National Storm Shelter

Association (NSSA), intended the ICC 500 standard to be adopted by government agencies and

organizations in creating model codes for storm shelters.

Beginning in 2009 and continuing through the present, the ICC 500 has been referenced in the

IBC as the governing standard for storm shelters. The IBC may be adopted by local jurisdictions

with or without amendments, and with the timing of adoption determined locally. The current

OBC is based on the IBC’s 2015 edition and requires certain buildings, based upon building

function and geographic location, to include storm shelters.

For building code purposes, structures are classified into one of ten occupancy groups. In 2015,

the IBC required the application of the storm shelter requirement to Educational Group E, which

includes K-12 schools, among other structures. The IBC further narrowed the requirement to

Educational Group E buildings in the geographic locations within the 250 mile per hour (mph)

wind speed zone as identified in the ICC 500 standard. This requirement affects 23 U.S. states,

including Ohio.

December 2019

Page 3 of 9

In June 2017, BBS adopted an update to the OBC that included a new Section 423.4, requiring

buildings to include storm shelters constructed in accordance with ICC 500 in Group E

occupancies. This code update, and storm shelter requirement, became effective on November

1, 2017.

The 2015 Storm Shelter code requires a design that buildings provide a space large enough to

house all the typical occupants and strong enough to withstand a tornado. More specifically, the

code requires:

•

Space for at least five square feet per person, based upon total occupancy

Designed to allow for two hour a minimum of 2 hour occupancy after the tornado

Shelter envelope components including doors and windows designed for debris missile

impact based on a design wind speed of 250 mph

•

Protection of any shelter opening greater than 3 ½ sq. in. or 2 1/16 in. diameter

Sanitation facilities within the shelter, including minimum number of toilets

Mechanical or natural ventilation

Design for roof live load of 100 pounds per square foot minimum

December 2019

Page 4 of 9

The storm shelter code also requires a quality assurance plan, special inspections, and peer

review by an independent registered design professional. The peer reviewer provides a signed

and sealed report, submitted with the construction documents to the code authority having

jurisdiction over the proposed building, prior to the issuance of a permit. The report includes

reference to structural design elements, means of egress and accessibility, fire safety, ventilation,

and other essential features. The report describes the items reviewed, the compliance of those

items, and a recommendation for acceptance or rejection.

The storm shelter code requirement can be met through a stand-alone structure, or as a

specifically designed hardened area within the existing building footprint.¹

Storm Shelter Cost Impact on OFCC Projects

In anticipation of the November 2017 effective date, OFCC contracted with a consulting firm to

develop an estimating cost model for the storm shelter requirements. OFCC also compiled a list

of its K-12 projects that were then in design and could be affected by the code requirement.

Using the estimating model, OFCC staff estimated a potential additional cost of about $40 million

for 68 active projects within 31 school districts, with an estimated additional state share of $18.5

million. This calculated to an average increase of 3.8% in construction costs or approximately

$589,000 per school.

At its October 2017 meeting, OFCC adopted a resolution authorizing co-funding of project-

specific allowances to address the new storm shelter requirement. Because the referenced

projects were in various stages of design, it was uncertain whether the requirement would apply

to all projects as application of the storm shelter requirement dependent on the date designs

were submitted to BBS or other applicable building department. Application of the requirement

was addressed on a case-by-case basis in coordination with BBS and local code officials, which

BBS later formalized by a BBS Memo on July 13, 2018. See Exhibit A.

Of the original list of 68 projects, two have incorporated the storm shelter code requirement:

Fairborn City School District and Dover City Schools. Both projects are currently in construction.

2018 Moratorium

As a result of concerns about costs and uncertainty about implementation that were raised by

several school districts and the above-noted school associations, on June 7, 2018, the Ohio

General Assembly adopted Substitute House Bill 21, effective September 28, 2018, which

included a new ORC Section 3781.1010 enacting a moratorium on the school storm shelter

requirement until September 15, 2019. In addition to the September 15, 2019 moratorium

requirement, the new language stated that the requirement shall also not take effect if “financing

has been secured prior to” September 15, 2019. On May 13, 2019, BBS requested a formal

opinion from the Ohio Attorney General (OAG) for interpretation of the “financing has been

1

To implement this solution, the designer would need to fortify the foundation, walls and roof

of the designated area to provide a continuous load path and provide necessary life safety and

anti-panic amenities.

December 2019

Page 5 of 9

secured” language. On August 7, 2019 the OAG issued Opinion No. 2019-027 providing clarity on

the language, including multiple options for a school to satisfy its obligation to secure financing.

See Exhibit B.

2019 Moratorium and Study Requirement

On July 17, 2019, the Ohio General Assembly adopted Amended Substitute House Bill 166, which,

in addition to the above-noted study directive, amended ORC Section 3781.1010 to extend

further the storm shelter moratorium until September 15, 2020.

Study Findings

Tornadoes as a Risk Factor

Tornadoes are among the most destructive weather events on Earth. Although tornadoes occur

worldwide, the United States has by far the most tornadoes of any country, averaging more than

1,200 annually. Since tornadoes are short-lived and unpredictable, many are never seen or

recorded. While most tornadoes do not result in fatalities, they are responsible for an average

of 80 deaths and 1,500 injuries annually in the U.S.²

In an average year, Ohio experiences 17 tornadoes causing four fatalities. Since 1950, every

county in Ohio has experienced at least one tornado, with 14 counties experiencing more than

$100 million in cumulative damages from 1950-2017. While Ohio is not among the top states for

numbers of tornadoes, it ranks among the top 20 states for fatalities, injuries, and dollar losses.³

And although tornadoes have struck school buildings in Ohio, including in the spring of 2019,

there has been just one recorded fatality (1887).⁴

Other states have not been as fortunate. Part of the reason for the storm shelter requirement

addition to the 2015 IBC was the finding that even schools built to modern building codes are

susceptible to collapse during tornadoes. For example, in 2013, seven school children died in

Oklahoma at the Plaza Towers Elementary School during a tornado. The children were taking

refuge in the hallway, which was their designated tornado safety area, when the masonry hallway

walls collapsed on them.

2

National Oceanic and Atmospheric Administration, National Centers for Environmental

Information, retrieved November 25, 2019 at https://www.ncdc.noaa.gov/climate-

information/extreme-events/us-tornado-climatology

3

Grazulis, Thomas P. (1993). Significant Tornadoes 1680-1991: A Chronology and Analysis of

Events. St. Johnsbury, VT: The Tornado Project of Environmental Films. pp. 139–40.

⁴Ohio Department of Public Safety, Ohio Emergency Management Agency, 2019 State of Ohio

Enhanced Hazard Mitigation Plan, February 2019, Section 2.3.

December 2019

Page 6 of 9

Stakeholder Feedback

Throughout the meetings with the stakeholder groups, all participants noted the desire to ensure

appropriate safety needs in schools, and there was universal recognition of the potential risk that

tornados pose to building occupants.

Understanding that student and staff safety is a paramount concern for building construction and

renovation, stakeholder feedback noted two primary issues regarding implementation of the

school storm shelter code requirement: (1) uncertainty about the conditions under which the

storm shelter requirement would apply for school building renovations and additions, and the

(2) cost impacts to school building construction and renovation.

From the school district official perspective, participants noted that school districts plan for and

address a multitude of health and safety issues daily. Among the issues facing school

administrators are active shooter situations, fire, bomb threats, bullying and cyberbullying,

physical health outbreaks, and mental health issues. Each of these health and safety issues

requires the allocation of resources – money, people, planning time– to reduce risk and provide

the best, safest educational environment for students and staff.

In addition, while physical safety was important to all school districts providing input for this

report, participants reported that tornado safety was not among the top concerns expressed by

citizens, parents and staff to school administrators. When factoring in cost-effectiveness,

participants suggested that the school districts would prefer the flexibility of an optional storm

shelter requirement. Recognizing, however, that building code requirements typically are not

options, participants indicated that should the storm shelter requirement remain in place after

the expiration of the September 2020 moratorium, school district officials encouraged the code

officials and design professionals to work to provide the enhanced safety requirements at the

least possible cost.

Representatives of the professional design community expressed confidence in designing spaces

to meet any current storm shelter requirement. ICC 500 requires thoughtful design and

configuration of known building materials and techniques, rather than the application of

untested technologies or materials. Design officials noted, however, that much of the

professional experience with these storm shelter requirements currently lies out of state, as

there is limited real-world experience with building ICC 500 compliant storm shelters in Ohio.

Based on this limited experience and the information provided, OFCC staff notes that there is not

currently one specific path for designing a cost-effective and compliant storm shelter.

While there are many potential compliance paths, the goal would be to provide the most cost-

effective solution to meet the requirements for a particular school’s design. The design industry

was open to any avenues for clarification of the code’s requirements. During the meeting

discussions, questions were raised about the applicability of the code and whether the

requirements extended beyond tornadoes to the hurricane requirements of ICC 500 (which have

additional hardening requirements and cost impacts). Though it was later clarified that the

hurricane requirements do not apply, the feedback received suggested that additional discussion

between the design community and BBS would help all involved parties better understand

December 2019

Page 7 of 9

requirements and lead to better and more cost-effective implementation. The group offered

some alternative, lower cost compliance paths if certain code elements were modified.

Clarification could also take the form of additional detailed guidance from BBS, local code

officials, and training on the requirements. As Ohio gains more experience in these

requirements, it is expected that the compliance cost will be reduced.

Neighboring State Implementation

Ohio is not alone in addressing and evaluating the storm shelter requirements. Despite the

adoption of the ICC 500, not all states in the 250 mph wind zone have adopted the storm shelter

requirement. For those neighboring states within the 250 mph zone, adoption of the

requirements has been varied. Michigan initially adopted the storm shelter requirement for

schools in 2017, but it then added emergency rules that suspended that adoption and

implementation. Kentucky’s mandatory requirement became effective on January 1, 2019.

Indiana has no formal requirement, but this past summer, several news stories began reporting

additional calls for its implementation. Outside of Ohio’s border neighbors, Illinois adopted the

requirement in 2014.

Other states in the 250 mph wind zone have considered adoption but have not yet made it

mandatory. In 2013 the Governor of Oklahoma requested that schools consider constructing

shelters, but that state has not adopted the code requirement. From all available accounts,

resistance to mandatory adoption is primarily triggered by cost impact concerns. Ohio is unique

in the scope of its state supported school construction program administered by OFCC.

Recommendations

New building code requirements, especially those requirements that have cost impacts, are often

met with initial concerns. This happened previously with Americans with Disabilities Act

requirements. It also happened with non-code requirements for OFCC’s implementation of the

Leadership in Energy and Environmental Design (LEED) requirements. The initial concerns, consistent

with the feedback received from this study’s participants, are typically based on cost impacts,

particularly for early adopters. And cost is certainly an important factor, especially when

evaluating proposed new construction and renovation projects in the current tight construction

market.

But history also shows that these concerns often dissipate once the early cost impacts are

mitigated. As with other requirements, including OFCC’s experience with the LEED

implementation in its school programs, the additional cost associated with the storm shelter

requirement is anticipated to decrease as the storm shelter designs become more widespread.

With full implementation and much wider design and use of storm shelters, the storm shelters

will become much less of a specialty item from a design and construction standpoint. Similarly,

once the market widens for the products included in the storm shelters, then we anticipate that

other cost reductions will follow.

Consistent with this context, these recommendations are made within the context of the

moratorium ending and are offered for incorporating the storm shelter requirement for Ohio

December 2019

Page 8 of 9

schools scheduled to take effect on September 15, 2020. These recommendations should be

implemented prior to the effective date of the requirement.

1) School district officials are encouraged to participate directly in the BBS rule development

process, either formally or informally, to share their perspective on building code impacts

on their districts.

2) BBS is encouraged to provide additional detailed guidance on the code requirement for

school renovations and additions. This guidance should address the conditions under which

the requirement is applicable, and the design occupancy for the shelter space in the case of

renovations or additions.

3) BBS and the design community are encouraged to meet for technical discussions on the

interpretation of ICC 500, with particular attention to requirements that may be modified

for tornadoes. The focus should be on compliance paths that provide the necessary level of

safety for the least cost. The result of these discussions could be communicated through

written guidance and/or training opportunities

4) To the extent possible with a small sample size of projects, OFCC and the design and

construction community should widely share real-world experiences on storm shelters in

Ohio, with the goal of reducing risk and cost through lessons learned. Information may be

shared through conferences, webinars, meetings or other appropriate venues.

December 2019

Page 9 of 9

Brain Craig

mifbi.org

institute@mifbi.org

April 3, 2024

Bureau of Construction Codes

Michigan Department of Licensing and Regulatory Affairs (LARA)

via email to LARA-BCC-RULES@michigan.gov

Re: Public Comment on the Proposed 2021 Michigan Building Code

Dear Bureau of Construction Codes,

As a Michigan architect since 1981, an educator of future architects, and Board Chair of the

Michigan Forest Biomaterials Institute (MIFBI), I am writing to express strong approval and

support for the mass timber elements incorporated in 2022-57 LR Construction Code – Part 4.

Building Code, the “Draft Rule,” as presented for review.

Having been part of this conversation over the last several years, I very much appreciate the

effort that the Bureau has put into making the new Code forward thinking and of benefit to both

the AEC industry and public health, safety, and welfare. Perhaps as importantly, as an educator

of future architects I see this code leading in the same direction that they are heading. There is

tremendous interest in a sustainable future among students and young architects. Mass timber

is a realistic tool in reaching that future, one that my students have been exploring at their own

initiative since 2018 and before.

The increased options and clarity provided by incorporating the 2021 IBC mass timber elements

will enhance our ability to build safe, efficient, and beautiful mass timber buildings in Michigan,

creating places that support the State’s net zero carbon goals as well as its role as a mass

timber leader in the Great Lakes region. Please adopt the mass timber elements of the Draft

Rule as presented. Thank you for your time and consideration.

Sincerely,

Brian K Craig, FAIA, Architect

Board Chair, Michigan Forest Biomaterials Institute

Founding Director Emeritus, Graduate Program in Architecture

Kendall College of Art and Design of Ferris State University

Janelle Rai

April 4^th, 2024

Janelle Rai

Grand Rapids, MI

Michigan Department of Licensing and Affairs (LARA)

Bureau of Construction Codes

Ottawa Building

611 W. Ottawa

P.O. Box 30004

Lansing, MI 48909

Dear Bureau of Construction Codes Team:

I am a structural engineer in Grand Rapids, Michigan. I work in the building industry and support the use

of Mass Timber as a structural system in buildings. Mass Timber is an important building material.

Removing obstacles within the Michigan Building Code to use Mass Timber extensively is a good idea.

We structural engineers in the building industry are trying to make buildings more sustainable, so future

generations can enjoy life in Michigan. If we can use Mass Timber as a structural system in buildings in

Michigan, we can better achieve that goal. Our goals as building designers align directly with State of

Michigan climate and sustainability goals.

I support Michigan joining the 22 U.S. states and Puerto Rico in adopting the Mass Timber elements of the

2021 International Building Code. Michigan is behind schedule when it comes to updating its codes, even

as demand for mass timber quickly rises in our state. I urge the State of Michigan to adopt the 2021

Michigan Building Code with all the mass timber elements included in the draft intact.

Sincerely,

Janelle Rai

Structural Engineer, EIT

Grand Rapids, MI

Diane Hallinen

LARA-BCC-Rules

From:

Sent:

To:

Hallinen <hallinen@gmail.com>

Wednesday, March 13, 2024 12:14 AM

LARA-BCC-Rules

Subject:

Building code suggestions

CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov

All new construcꢀon should be able to be fully electriﬁed without retroﬁts. For example, roofs ready for solar panels,

ability to have bidirecꢀonal charging for an EV, heat pump ducꢀng in place. Also energy recovery venꢀlaꢀon in homes, to

be energy eﬃcient means a ꢀght house, which means too many VOCs. Building codes to make it easy for local building

inspectors to approve energy upgrades. Also, we need ground sourced hot water systems at the uꢀlity scale instead of

methane geꢁng pumped to homes. I don’t know if that’s something a building code can help facilitate, but we have to

stop using methane.

Use the Internaꢀonal Code Council, including appendices, as a guide.

Building for zero carbon saves money, sure, it costs more up front, but we can’t aﬀord not to eliminate fossil fuels in

homes.

Diane Hallinen

Highland, Mi

1

Fabrice Smieliauskas

LARA-BCC-Rules

From:

Sent:

To:

Fabrice Smieliauskas <fab.smieliauskas@gmail.com>

Wednesday, April 3, 2024 10:42 AM

LARA-BCC-Rules

public comment in support of Mass Timber elements of 2022-57 LR Construction Code – Part 4.

Building Code, “Draft Rule”

Subject:

CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov

Dear Bureau of Construction Codes Team,

Mass timber construction, defined and provided for in building types IV-A, IV-B, IV-C, and IV-HT in the 2021 International

Building Code (2021 IBC), is quickly increasing in popularity in Michigan and across the United States. Since 2018, the

number of mass timber projects in the U.S. has more than quadrupled and demand is expected to at least double every

two years until the mid-2030s. At the time of this writing, project teams in Michigan are developing at least 45 projects

where mass timber will definitely comprise the building’s structure, or where mass timber is the top choice, and teams

are researching the best path to deliver it to their clients. A key part of clearing that path is to ensure that the 2021

Michigan Building Code (2021 MBC) provides the greatest possible permission and clarity as relates to mass timber. I

commend the BCC for including all the 2021 IBC mass timber elements in the 2022-57 LR Construction Code – Part 4.

Building Code, “Draft Rule,” and I strongly encourage and support their adoption in the final code.

Mass timber is an umbrella term for an array of engineered wood building materials used in structural and non-

structural applications to construct beautiful, strong, safe, cost-effective, and sustainable buildings, including large and

taller buildings. By providing for the greatest permission and clarity for mass timber in the 2021 Michigan Building Code,

the State will open a door that will allow a broad array of Michigan stakeholders to harness the myriad benefits of mass

timber, which include:

• Constructing safe, cost-effective buildings, faster

o Mass timber buildings are constructed with thick manufactured floor and wall panels, and posts and beams

comprising multiple layers of wood. These large pieces usually arrive at the building site as a prefabricated kit-of-parts,

which can:

. Minimize construction noise and waste; and

. Reduce construction times and costs. That means building occupants can start living and working in buildings

sooner, which has important positive implications for State goals related to business and economic development as well

as housing, including affordable housing.

o Mass timber is a high-performance material that fares well in high winds as well as in fire; only the outer layers of

mass timber are likely to char in fire and can be repairedand replaced without threatening the building’s structure.

• Creating economic development opportunities

o Ensuring Michigan has the most up-to-date mass timber building codes could help attract a mass timber

manufacturer to Michigan as major companies seek to build headquarters or hubs using sustainable materials.

o Making mass timber from wood sourced from Michigan forests or reclaimed from Michigan buildings can help

spur economic development opportunities in both rural and non-rural areas.

• Realizing climate and sustainability benefits

o Trees absorb carbon dioxide and store it as carbon in their branches, trunks, roots, and ultimately in forest soils.

1

Harvesting forests sustainably contributes to forest health and overall carbon storage. Making mass timber buildings

from sustainably harvested wood stores the trees’ carbon in the building for as long as it stands. By deconstructing and

re- using mass timber at the

end of a building’s life, we extend the wood’s carbon storage, keeping carbon

dioxide out of the atmosphere where it contributes to climate change.

o Mass timber, made from a renewable resource, can substitute for more carbon-intensive building materials made

from non-renewable resources.

o These benefits align directly with State of Michigan climate and sustainability goals, which is why the MI

Healthy Climate Plan highlights mass timber construction as an important way to reduce the carbon footprints of our

buildings and promote the carbon benefits of forests.

It is worth noting that at least 22 U.S. states and Puerto Rico have already adopted the mass timber elements of the

2021 International Building Code. That puts Michigan behind schedule when it comes to updating its codes, even as

demand for mass timber quickly rises in our state. Adopting the 2021 MI Building Code with all the 2021 IBC mass timber

elements in place will enable these projects to move forward without unnecessary barriers and enable Michigan to

secure its place as the mass timber leader in the Great Lakes Region, and the Eastern United States.

Acknowledging the myriad benefits of mass timber and embracing it as an important emerging technology in our

industry in Michigan, the Great Lakes region, and across the United States, I urge the State of Michigan to adopt the

2021 Michigan Building Code with all the mass timber elements included in the draft intact. This action will enhance

demand for safe, efficient, and beautiful mass timber buildings in Michigan and the likelihood that mass timber

manufacture will take place here. Both activities support the State’s net zero carbon goals as well as its role as a mass

timber leader in the Great Lakes region.

Sincerely,

Fabrice Smieliauskas

Troy, MI

2

Gerald McClelland

Pages 22-23

LARA-BCC-Rules

From:

Sent:

To:

Gerald E.McClelland <GMcClelland@auchconstruction.com>

Friday, February 16, 2024 2:44 PM

LARA-BCC-Rules

Subject:

Code update

CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov

Attn: Tony Williamson,

I hope this email finds you well. I am writing to express my concerns regarding the recent

announcement of storm shelter requirements being added to the upcoming building codes,

particularly in relation to its impact on school building budgets.

While I understand the importance of ensuring safety and resilience in our built environment, the

timing of this change presents significant challenges for schools that have already budgeted for

construction projects prior to the implementation of these new regulations, set to take effect this

April.

The addition of storm shelters to school buildings represents a commendable effort to enhance

preparedness and protect students and staff during severe weather events. However, the financial

implications of retrofitting or integrating these shelters into existing construction plans can be

substantial, potentially leading to delays or cancellations of vital projects aimed at improving

educational facilities.

School districts across Michigan have meticulously planned and allocated funds for construction

projects based on the prevailing building codes and requirements at the time. The sudden

introduction of storm shelter mandates jeopardizes the feasibility of these plans and puts undue

strain on already constrained budgets.

I urge the Michigan Bureau of Construction Code to consider the potential negative impact on school

building budgets and the broader educational community. It is essential to assess the feasibility of

implementing these new requirements in a manner that minimizes financial burdens on school

districts while still prioritizing safety.

I propose exploring alternative solutions or phasing in the storm shelter requirements over a

reasonable timeline to allow for proper planning and budget adjustments. Additionally, providing

support or incentives for schools to comply with the new regulations could help mitigate the financial

burden and ensure equitable access to safe learning environments for all students.

1

I appreciate your attention to this matter and urge you to carefully consider the concerns raised by

stakeholders in the education sector. Collaborative efforts between regulatory bodies and educational

institutions are crucial to achieving a balance between safety enhancements and fiscal responsibility.

Thank you for your time and consideration. I look forward to a constructive dialogue on this issue and

finding mutually beneficial solutions.

Regards,

Gerry McClelland, CPE, LEED AP BD+C |

AUCH Construction

2

Jason Wadaga

Pages 24-25

43636 Woodward Avenue

Bloomfield Hills, MI 48302-3204

Phone: (248) 972-1000

Fax: (248) 972-1001

www.BuildwithCAM.com

February 20, 2024

Dear Michigan Bureau of Construction Code,

I hope this email finds you well. I am writing to express my concerns regarding the recent

announcement of storm shelter requirements being added to the upcoming building codes,

particularly in relation to its impact on school building budgets.

While I understand the importance of ensuring safety and resilience in our built environment, the

timing of this change presents significant challenges for schools that have already budgeted for

construction projects prior to the implementation of these new regulations, set to take effect this

April.

The addition of storm shelters to school buildings represents a commendable effort to enhance

preparedness and protect students and staff during severe weather events. However, the financial

implications of retrofitting or integrating these shelters into existing construction plans can be

substantial, potentially leading to delays or cancellations of vital projects aimed at improving

educational facilities.

School districts across Michigan have meticulously planned and allocated funds for construction

projects based on the prevailing building codes and requirements at the time. The sudden

introduction of storm shelter mandates jeopardizes the feasibility of these plans and puts undue

strain on already constrained budgets.

I urge the Michigan Bureau of Construction Code to consider the potential negative impact on

school building budgets and the broader educational community. It is essential to assess the

feasibility of implementing these new requirements in a manner that minimizes financial burdens

on school districts while still prioritizing safety.

I propose exploring alternative solutions or phasing in the storm shelter requirements over a

reasonable timeline to allow for proper planning and budget adjustments. Additionally, providing

support or incentives for schools to comply with the new regulations could help mitigate the

financial burden and ensure equitable access to safe learning environments for all students.

I appreciate your attention to this matter and urge you to carefully consider the concerns raised

by stakeholders in the education sector. Collaborative efforts between regulatory bodies and

educational institutions are crucial to achieving a balance between safety enhancements and fiscal

responsibility.

Thank you for your time and consideration. I look forward to a constructive dialogue on this issue

and finding mutually beneficial solutions.

Sincerely,

Kevin N. Koehler

President

Construction Association of Michigan

Koehler@buildwithcam.com

Cell: 248-421-4500

PROPOSED RULE/CODE CHANGE REQUEST

Michigan Department of Licensing and Regulatory Affairs

Bureau of Construction Codes/Administrative Section

Point of Contact:

Kerry Sutton

Pages 26-28

Attn: Amanda Johnson Attn:Katherine Place Attn: Tony Williamson

Cell: (517) 582-5519

Cell: (517) 388-3613

Cell: (517) 388-3536

Submission Options:

PO Box 30254, Lansing, MI 48909

Fax (517) 241-0130

ACTION:

Email: LARA-BCC-Rules@michigan.gov

D

ATE:

2/27/2024

_REA_PRm_ESe_ENr_Tic_INa_G:n Concrete Institute

NAME:

STATE:

ZIP:

48331

ADDRESS:

PHONE:

CITY:

kerry.sutton@concrete.org

EMAIL:

FAX:

RULE/CODE SECTIONS/TABLES/FIGURES PROPOSED FOR REVISION (Note: If the proposal is for a new

section, indicate “new”)

New Section to amend the 2021 IBC: 1901.2.1 Structural concrete with GFRP reinforcement.

PROPOSED LANGUAGE: Show proposed text in accordance with the following format: Strikeout/Bold & underline proposed added text

Add new text as follows:

1901.2.1 Structural concrete with GFRP reinforcement. Cast-in-place structural concrete internally

reinforced with glass fiber reinforced polymer (GFRP) reinforcement conforming to ASTM D7957 and

designed in accordance with ACI CODE 440.11 shall be permitted where fire resistance ratings are not

required and only for structures assigned to Seismic Design Category A.

REASON: Thoroughly explain the need and reason for the proposed change to include the following:

-Identify the problem.

-Explain the rational for the proposed change.

-Describe the environmental impact.

-Is the proposed change comparable to federal rules or national or regional standards in similarly situated states, based upon geographic location,

topography, natural resources, commonalities, or economic similarities? If the proposed change exceeds standards in those states, explain why and

specify costs and benefits.

-Identify individuals and groups affected by the proposed change and the impact on these groups.

-Are there any reasonable alternatives to the proposed change? If so, please provide those alternatives.

-What is the fiscal impact for the proposed change? Provide a cost/benefit analysis.

-Estimate the actual statewide compliance costs of the proposed rule.

-What are the primary and direct benefits of the rule?

-Estimate any cost increases or reductions to businesses, individuals, groups, or governmental units as a result of the rule.

As well as any other information appropriate to assist with a clear understanding of the issue. During the rulemaking process, the need and reasoning

of all proposed rule changes should be identified. By including a detailed explanation, the general public will gain a better understanding on all aspects

of the proposal. Providing an explanation on the need and rationale for the proposal is optional; however, MCL 24.245 requires the department to pro-

vide proper justification for each proposal. Without this important information, the department may not be able to document appropriate justification

and merit for a proposal. For further information, please refer to the Administrative Procedures Act of 1969.

See Attached Reason Statement.

□ Back Up/Graphic Material Included

BCC-3016 (11/22)

ATTACHMENT

2021 IBC Option for ACI 440.11

Chapter 19 – Concrete

Section – 1901 General

1901.2 Plain and reinforced concrete. Structural concrete shall be designed and constructed in accordance with

the requirements of this chapter and ACI 318 as amended in Section 1905 of this code. Except for the provisions of

Sections 1904 and 1907, the design and construction of slabs on gradeshallnotbegovernedbythischapterunless

theytransmitverticalloads orlateralforces fromotherparts ofthestructuretothesoil.

Add new text as follows:

1901.2.1 Structural concrete with GFRP reinforcement. Cast-in-place structural concrete internally

reinforced with glass fiber reinforced polymer (GFRP) reinforcement conforming to ASTM D7957 and

designed in accordance with ACI CODE 440.11 shall be permitted where fire resistance ratings arenot

requiredandonly forstructures assignedtoSeismic DesignCategory A.

Add new standard(s) as follows:

American Concrete Institute

38800 Country Club Drive

Farmington Hills, MI 48331

ACI

Standard

Referenced in code

section number

reference Title

number

ACI CODE-440.11-22: Building Code Requirements for Structural

Concrete Reinforced with Glass Fiber-Reinforced Polymer (GFRP)

Bars – Code and Commentary

440.11-22

1901.2.1

ASTM

International 100 Barr

Harbor Drive, PO Box C700

West Conshohocken, PA 19428

Referenced in code

ASTM

Standard

reference

number

Title

section number

Standard Specification for Solid Round Glass Fiber Reinforced

Polymer Bars for Concrete

D7957/D7957M-17

Reinforcement

1901.2.1

Background and rationale - This proposaladds anewreferencedstandard: ACI CODE440.11-22: Building

Code Requirements for Structural Concrete Reinforced with Glass Fiber-Reinforced Polymer (GFRP) Bars –

CodeandCommentary. Theadditionofthis newstandardallows thedesignandconstructionofcast-in-place

reinforcedconcreteusing non-metallic reinforcementbars. While the design and construct requirements

contained in the standard are limited to use in structures assigned to Seismic Design Category A and structural

elements not part of seismic force-resisting systems in SDC B and C, for simplicity this proposal limits the use to

structures assigned to SDC A. ACI Committee 440 developed this standard to provide for public health and safety by

establishing minimum requirements for strength, stability, serviceability, durability, and integrity of GFRPreinforced

concrete structures.

Thestandardnotonlyprovidesameansofestablishingminimumrequirementsforthedesignandconstructionof

GFRPreinforcedconcrete,butfor acceptance of design and construction of GFRP reinforced concrete structures by

the building officials or their designated representatives.

Due to the performance of other types of FRP reinforcement and the lack of research and testing of other types, the

standard only applies to reinforced concrete structures designed and constructed with GFRP manufactured in

accordance with ASTM D7957 Standard Specification for Solid Round Glass Fiber Reinforced Polymer Bars for

Concrete

GFRP reinforced concrete is especially beneficial for satisfying a demand for improved resistance to corrosion in

highly corrosive environments, such as reinforced concrete exposed to water and de-icing salts.

This standard establishes minimum requirements for GFRP reinforced concrete in a similar fashion as ACI 318 -19

Building Code Requirements for Structural Concrete establishes minimum requirements for structural concrete

reinforced with steel reinforcement. A separate standard is needed, as GFRP reinforcement behaves differently than

steel reinforcement. The preliminary results of the ICC Online Governmental Consensus Voting show approval of the

inclusion of ACI CODE 440.11 in the 2024 International Building Code.

Currently GFRP is accepted for use toreinforce highway bridge decks. Acceptanceis primarily inareas where

deicingsalts are used onthe roads andcause severe corrosiontoconventionalsteelreinforcement. This proposed

changeprovides minimum requirements for other applications where GFRP reinforced concrete is being

considered, such as marine and coastal structures, parking garages, water tanks, and structures supporting MRI

machines. Design reasons to use GFRP bars in structures are: resistance to corrosion in the presence of chloride

ions, lack of interference with electromagnetic fields, and low thermal conductivity.

Currently the standard prohibits the use concrete internally reinforced with GFRP for applications where fire

resistance ratings are required. Chapter6oftheMichigan BuildingCodecitesapplicationsforfloors,roofs,walls,

partitions,andprimaryandsecondarystructuralframeswherefire resistance ratings are notrequired.

Cost Impact: The code change proposal will not increase or decrease the cost of construction

ThisproposaladdsalternativematerialsforthedesignandconstructionofreinforcedstructuralconcreteinSeismic

DesignCategoryAanddoes notprecludetheuseofconventionalreinforcedconcrete. Thus, thereisnocostimpact.

Mark Stimac

Pages 28-31

Compliant by Design LLC

Building Code Consulting

31695 Karolyn Lane

Fraser, MI 48026

April 4, 2024

Tony Williamson

Bureau of Construction Codes

P.O. Box 30254, Lansing, MI 48909

Re: Public Comment on proposed Michigan Building Code

Part 4 Rules of Public Act 230 of 1972

Dear Sir:

I will be unable to attend the public hearing scheduled for 4/4/24. Enclosed are my comments on the

proposed rules which would adopt and amend the 2021 International Building Code to become the 2021

Michigan Building Code.

Rule 401

Section 104.2 is proposed to be excepted from the MBC. However, Section 104.2.1 is proposed to be

adopted as written. Since the topic of Section 104.2.1 is dealing with applications for reconstruction,

rehabilitation, repair, alteration, addition, or other improvement of existing buildings these provisions

should be located in the Michigan Rehabilitation Code for Existing Buildings based upon the provisions

of Section 101.4.7.

Sections 2902 through 2902.6 are proposed to be excepted from the MBC. However, Sections 2902.7

and Section 2903 are proposed to be adopted as written. If the intent is to direct users to the Michigan

Plumbing Code for the requirements for the installation of plumbing fixtures these other “orphaned

sections” should be deleted as well.

Rule 412

Section 111.2 and 111.2.1 are proposed to be amended. These sections address requirements for the

change of occupancy of an existing building. In accordance with the provisions of Section 101.4.7 these

topics are regulated by the Michigan Rehabilitation Code for Existing Buildings. If the language is

desired it should be located there.

Rule 415a

The definition of "Registered design professional" is intended to be amended to mean an individual who

is licensed under the occupational code, 1980 PA 299, MCL 339.101 to 339.2919 339.2677.

www.compliantbydesignllc.com

Compliant by Design LLC

Building Code Consulting

31695 Karolyn Lane

Fraser, MI 48026

There are numerous professions that are licensed under 1980 PA 299. These include barbers,

accountants and appraisers. The correct reference should be to individuals who is licensed under article

20 of the occupational code, 1980 PA 299. That is the article that licenses architects, engineers and land

surveyors who should be the licensed professionals that are submitting plans for approval with building

permit applications.

Rule 418

Rule 418 proposes to modify Section 1203.1 to read as follows:

R 408.30418 Maximum floor area allowances per occupant. Occupiable space heating systems.

Rule 418. Table 1004.1.21004.5 1203.1 of the code is amended to read as follows:

1203.1. Equipment and systems. Interior spaces intended for human occupancy shall be provided

with heating facilities capable of maintaining a minimum interior room temperature of 68 degrees

Fahrenheit at a point 3 feet above the floor and 2 feet from exterior walls at the required design

temperature. The installation of portable space heaters shall not be used to comply with this section.

Exceptions:

(a) Interior spaces where the primary purpose is not associated with human contact.

(b) Group F, H, S, or U occupancies.

(c) Interior, seasonal spaces unoccupied during cold weather months, including restrooms, shower

buildings, day-use restrooms, concession stands, press boxes, ticket booths, and locker rooms.

Although “titles” do not contain enforceable language, the word “maximum” in the title should be

deleted along with the rest of the current title. The term “human contact” in Exception (a) is perhaps a

“typo” and should read “human comfort” as it does in the Michigan Mechanical Code.

Rule 419

Part of Rule 419 is to amend Section 1210.5 to read as follows:

1210.5. Baby changing stations. A building or structure that has with baby changing stations in the

women's restrooms shall have baby changing stations in the men's restrooms.

As proposed, the rule would not require that a baby changing station be provided in a women’s

restroom if one were installed in a men’s restroom. It is my belief that the intent of this rule was to be

gender neutral and require equal facilities. The language should be revised to require equal facilities be

provided in both gender’s toilet rooms.

Proposed new rule.

I proposed that Section 101.4.8 be added to the code to read as follows:

101.4.8 Electrical. The provisions of the Michigan Electrical Code shall apply to the installation,

alterations, repairs and replacement of electrical equipment.

www.compliantbydesignllc.com

Compliant by Design LLC

Building Code Consulting

31695 Karolyn Lane

Fraser, MI 48026

Reason for Code Change:

Within Section 101.4 we have provisions for the application of the other International (Michigan) codes

relating to gas, mechanical, plumbing, property maintenance, fire protection, energy, and existing

buildings. The one category that is currently missing from the section is electrical. This proposed code

change would close that hole.

I appreciate the opportunity to submit these public comments. I can be reached via email at

marks@compliantbydesignllc.com.

Respectfully submitted.

Mark Stimac, R.A., C.B.O.

Compliant by Design LLC

www.compliantbydesignllc.com

Ron Ritchey

Pages 32-33

NFSA Proposed Rule Change

Proposed Draꢀ Part 9A. Mechanical Code Eﬀecꢁve March 12, 2024

Add New Excepꢁon, Secꢁon 5 below.

107.1 Construcꢀon documents.

(1) Construcꢀon documents, engineering calculaꢀons, diagrams, and other data shall be submiꢁed in 2

or more sets with each applicaꢀon for a permit. Code oﬃcials may require addiꢀonal construcꢀon

documents at any point during construcꢀon. The code oﬃcial shall require construcꢀon documents,

computaꢀons, and speciﬁcaꢀons to be prepared and designed by a registered design professional,

licensed in accordance with the occupaꢀonal code, 1980 PA 299, MCL 339.101 to 339.2677.

Excepꢀons:

1. The code oﬃcial may waive the submission of construcꢀon documents, calculaꢀons, or other data if

the nature of the work applied for is such that reviewing of construcꢀon documents is not necessary to

determine compliance with the code.

2. Construcꢀon documents shall not be required when obtaining a permit from the bureau of

construcꢀon codes for any of the following circumstances:

a. Alteraꢀons and repair work determined by the mechanical oﬃcial to be of a minor nature.

b. Business, mercanꢀle, and storage use group buildings having HVAC equipment only, with 1 ﬁre area

and not more than 3,500 square feet.

c. Work completed by a governmental subdivision or state agency cosꢀng less than $15,000.00.

(2) Where special condiꢀons exist, the code oﬃcial may require addiꢀonal construcꢀon documents to be

prepared by a registered design professional.

(3) Construcꢀon documents shall be drawn to scale and shall be of suﬃcient clarity to indicate the

locaꢀon, nature, and extent of the work proposed and show in detail that the work conforms to the

provisions of this code.

(4) Construcꢀon documents for buildings more than 2 stories in height shall indicate where penetraꢀons

will be made for mechanical systems, and the materials and methods for maintaining required structural

safety, ﬁre-resistance raꢀng, and ﬁre blocking

(5) Automaꢁc Fire Sprinkler Plans submiꢂed by an individual who possesses at least a Water-Based

Systems Layout Level III or IV cerꢁﬁed by the Naꢁonal Insꢁtute of Cerꢁﬁcaꢁon in Engineering

Technologies (NICET).

107.1 Construcꢀon Documents.

Jusꢁﬁcaꢁon:

The State of Michigan currently permits “Cerꢀﬁcaꢀon of Firms for Fire Alarm Systems and Fire

Suppression Systems in State-Regulated Faciliꢀes, under 1941 PA 207, MCL 29.1 et seq., plans and

speciﬁcaꢀons to be submiꢁed for high-risk faciliꢀes by “Qualiﬁed” individual under R29.2805 (g) to

maintain a NICET LEVEL III or higher category.

Addiꢀonally, an overwhelming majority of the state and local jurisdicꢀon across the country accept

NICET Leve III or higher as qualiﬁed to submit ﬁre sprinkler drawings to the authority having jurisdicꢀon.

Ryan Leestma

Page 34

LARA-BCC-Rules

From:

Sent:

To:

Ryan Leestma <RML@leestmamanagement.com>

Friday, March 1, 2024 12:20 PM

LARA-BCC-Rules

Subject:

Mass Timber

CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov

As the leading developer in the State of Michigan for Mass timber constructed buildings, I would like to wholeheartedly

support the adoption of the 2021 international building code without any amendments or supplemental notations

related to Mass timber construction. I believe that this construction method is important for Michigan to develop as

sustainability and environmental preservation are critical to the long-term future of the state.

Sincerely,

Ryan Leestma

Ryan M. Leestma

Founder and Owner

Leestma Management, LLC

(M) 616-633-6020

1

Sandra Lupien

Pages 34-36

April 2, 2024

Michigan Department of Licensing and Regulatory Affairs (LARA)

Bureau of Construction Codes

Via email to LARA-BCC-RULES@michigan.gov

Re: Support for Mass Timber incorporated in 2022-57 LR Construction Code – Part 4. Building Code,

“Draft Rule”

Dear Bureau of Construction Codes Team,

Mass timber construction, defined and provided for in building types IV-A, IV-B, IV-C, and IV-HT in the

2021 International Building Code (2021 IBC), is quickly increasing in popularity in Michigan and across

the United States. Since 2018, the number of mass timber projects in the U.S. has more than quadrupled

and demand is expected to at least double every two years until the mid-2030s. At the time of this

writing, project teams in Michigan are developing at least 45 projects where mass timber will definitely

comprise the building’s structure, or where mass timber is the top choice, and teams are researching the

best path to deliver it to their clients. A key part of clearing that path is to ensure that the 2021

Michigan Building Code (2021 MBC) provides the greatest possible permission and clarity as relates to

mass timber. I commend the BCC for including all the 2021 IBC mass timber elements in the 2022-57

LR Construction Code – Part 4. Building Code, “Draft Rule,” and I strongly encourage and

support their adoption in the final code.

Mass timber is an umbrella term for an array of engineered wood building materials used in structural

and non-structural applications to construct beautiful, strong, safe, cost-effective, and sustainable

buildings, including large and taller buildings. By providing for the greatest permission and clarity for

mass timber in the 2021 Michigan Building Code, the State will open a door that will allow a broad array

of Michigan stakeholders to harness the myriad benefits of mass timber, which include:

•

Constructing safe, cost-effective buildings, faster

o

Mass timber buildings are constructed with thick manufactured floor and wall panels,

and posts and beams comprising multiple layers of wood. These large pieces usually

arrive at the building site as a prefabricated kit-of-parts, which can:

.

Minimize construction noise and waste; and

.

Reduce construction times and costs. That means building occupants can start

living and working in buildings sooner, which has important positive implications

for State goals related to business and economic development as well as

housing, including affordable housing.

o

Mass timber is a high-performance material that fares well in high winds as well as in

fire; only the outer layers of mass timber are likely to char in fire and can be repaired

and replaced without threatening the building’s structure.

•

Creating economic development opportunities

o

Ensuring Michigan has the most up-to-date mass timber building codes could help

attract a mass timber manufacturer to Michigan as major companies seek to build

headquarters or hubs using sustainable materials.

1

o

Making mass timber from wood sourced from Michigan forests or reclaimed from

Michigan buildings can help spur economic development opportunities in both rural and

non-rural areas.

•

Realizing climate and sustainability benefits

o

Trees absorb carbon dioxide and store it as carbon in their branches, trunks, roots, and

ultimately in forest soils. Harvesting forests sustainably contributes to forest health and

overall carbon storage. Making mass timber buildings from sustainably harvested wood

stores the trees’ carbon in the building for as long as it stands. By deconstructing and re-

using mass timber at the end of a building’s life, we extend the wood’s carbon storage,

keeping carbon dioxide out of the atmosphere where it contributes to climate change.

Mass timber, made from a renewable resource, can substitute for more carbon-

intensive building materials made from non-renewable resources.

These benefits align directly with State of Michigan climate and sustainability

goals, which is why the MI Healthy Climate Plan highlights mass timber

construction as an important way to reduce the carbon footprints of our

buildings and promote the carbon benefits of forests.

o

It is worth noting that at least 22 U.S. states and Puerto Rico have already adopted the mass timber

elements of the 2021 International Building Code. That puts Michigan behind schedule when it comes to

updating its codes, even as demand for mass timber quickly rises in our state. Adopting the 2021 MI

Building Code with all the 2021 IBC mass timber elements in place will enable these projects to move

forward without unnecessary barriers and enable Michigan to secure its place as the mass timber leader

in the Great Lakes Region, and the Eastern United States.

Acknowledging the myriad benefits of mass timber and embracing it as an important emerging

technology in our industry in Michigan, the Great Lakes region, and across the United States, I urge the

State of Michigan to adopt the 2021 Michigan Building Code with all the mass timber elements

included in the draft intact. This action will enhance demand for safe, efficient, and beautiful mass

timber buildings in Michigan and the likelihood that mass timber manufacture will take place here. Both

activities support the State’s net zero carbon goals as well as its role as a mass timber leader in the

Great Lakes region.

Sincerely,

Sandra Lupien

Director, MassTimber@MSU

Michigan State University

480 Wilson Road #121

East Lansing, MI 48824

Contact: lupiensa@msu.edu

2

Tom Archie

Pages 37-45

CODE WORKS!

Words from Director IRVIN J. POKE, AIA

WWW.MICHIGAN.GOV/BCC

summer 2011

When a governmental subdivision is granted the authority to administer and

enforce the Michigan Construction Codes, they must also enforce the Stille-

DeRossett-Hale Single State Construction Act, 1972 PA 230. As an enforcing

agency, it may not amend the code or any provision of the Act. The enforcing

agency does not adapt codes which are adopted by the state. It is the director

of the Department of Licensing and Regulatory Affairs (LARA) who is vested

with the sole authority to adopt the codes. The enforcing agency must adopt an

ordinance or ordinances to enforce the Act and the codes, set up an agency, adopt

a fee structure, and establish a board of appeals.

What’s inside

*Page 1* Words from the director

*Page 2 *board & commission

schedule

*Page 2*certificate inspections

and insepctor’s duties

*Page 3* vestibule requirements in

the 2009 michigan uniform energy

code

*Page 3* asme b20.1 safety

standard for conveyors and

related equipment

While the primary function of an enforcing agency is to issue permits, conduct

plan reviews, inspections, and issue certiﬁcates of use and occupancy, there are

other functions that are sometimes overlooked. The enforcing agency is the front

line of license enforcement. The enforcing agency must take reasonable action

to assure that properly licensed personnel perform all work. This includes and

is not limited to the building, electrical, mechanical, and plumbing trades as well

as professional services of architects and professional engineers. When there is

a licensing investigation, the enforcing agency is responsible for providing any

records and conducting necessary inspections.

*page 4 & 5* Michigan Residential

Smoke Alarm Requirements

*page 5* bcc contact information

*page 6* do you hold the proper

license classification?

*Page 6* license renewal

dependent upon 2009 plumbing

code update

*page 7* Wiring methods for

patient care areas in health care

facilities

It is also important that the enforcing agency have a process in place to handle

complaints. One of the most critical complaints is that of a dangerous building.

If a governmental subdivision elects to enforce the codes, the responsibility for

investigating such complaints goes with this authority. The Bureau of Construction

Codes will not intervene and the enforcing agency is responsible for any legal

action that may ensue as a result of an investigation.

*Page 7* Michigan codes & rules

*page 8* title vesting authority

of vacated public areas within

recorded subdivisions

*Page 9* license examination dates

*Page 9* online services

Finally, a code enforcement program is not a means of generating revenue for

a unit of government. Section 22, MCL 125.1522, makes it clear that the fees must

be set to resemble the cost of services and that revenue from the program can be

used only for code administration and enforcement. The Michigan Department

of Treasury issued two memorandums, 200-2 and 200-6 dated March 31, 2000,

and June 2, 2000, respectively, which detail how an enforcing agency must handle

its ﬁnances. These memorandums are available on the Department of Treasury

website.

In conclusion, every enforcing agency must have a working knowledge of 1972

PA 230, all licensing statutes, environmental regulation, Freedom of Information

Act (FOIA), Open Meetings Act, and the Administrative Procedures Act. All of

which should be in the agency’s library, along with all codes and standards, and

available for public review. These documents should be periodically reviewed to

assure that the agency operates correctly.

bcc oFFICES closed

September 5

November 11

www.michigan.gov/bcc - Page 1

Board and Commission Meetings

Meeting

Date

Time

Location

Barrier Free Design Board

Board of Boiler Rules

Construction Code Commission

Electrical Administrative Board

Elevator Safety Board

Manufactured Housing Commission

Board of Mechanical Rules

State Boundary Commission

Sep 9, Nov 18

Sep 13

Oct 5

Aug 25, Nov 3

Aug 24, Nov4

Aug 17, Oct 19

Aug 24, Nov 16

Sep 15

9:30 am

10:00 am

9:00 am

10:00 am

1:30 pm

10:00 am

Okemos – Conf Room 3

Oct 20

Sep 20

State Plumbing Board

Okemos – Conf Room 3

Dates and times are subject to change. Visit the BCC website for updates.

BOILER DIVISION

Certificate Inspections and Inspector’s Duties

By William Vallance, Chief

Boiler Division

PA 290 of 1965, as “an inspection, the report of which is

used by the chief inspector to decide whether a certiﬁcate

Boilers coming under the jurisdiction of the State of . . . shall be issued. The certiﬁcate inspection shall be an

Michigan boiler law fall into three categories of inspection internal inspection if construction allows; otherwise the

frequency:

certiﬁcate inspection shall be as complete an inspection as

possible [emphasis added].” The deﬁnition of “certiﬁcate

Annually

inspection” in the law requires an internal inspection on all

•

High pressure boilers that produce steam at pressures

boilers where construction allows. Inspectors should refer to

above 15 psi, or those that produce hot water at pressures rule R 408.4057 (c) and (g) which grants some discretion for

above 160 psi and/or temperatures above 250 deg. F.

Low pressure process boilers that evacuate more than

10% of their capacity.

hot water heating, hot water supply, and cast boilers.

Rule 57 allows an inspector to forego the internal

inspection on hot water heat and hot water supply boilers

because historically boilers in this use category do not usually

degrade internally. A main cause of internal degradation in

this type system is the introduction of scale and corrosion.

Draining and opening a system for internal inspection can

allow the introduction of scale and corrosion. The inspector

must be critical during the inspection to look for external signs

that would indicate a problem. The same concern is true for

cast boilers because their typical construction does not make

an internal inspection practicable.

Bi-Annually

Boilers that produce steam for heating and operate at

pressures of 15 psi or less.

•

Tri-Annually

Boilers used for hot water heating and hot water

•

supply that do not operate above pressures of 160 psi or

temperatures above 250 deg. F.

Boilers must receive a certiﬁcate inspection by a licensed

In-service and internal inspection of all boilers is to be

conducted in accordance with the National Board Inspection

Code and the Michigan Boiler Rules as speciﬁed in boiler

rule R 408.4057. Please refer to these documents for further

information on boiler inspection. If you have questions or

concerns contact the Boiler Division at (517) 241-9334.

boiler inspector at least once during the inspection frequency.

Once a boiler has passed its certiﬁcate inspection and a

certiﬁcate has been issued the boiler is approved for operation

until the next certiﬁcate inspection is due.

A certiﬁcate of inspection is deﬁned in the Boiler Act,

ATTENTION READERS!

If you know of an organization or individual that would beneﬁt from the

information posted in BCC’s newsletter, please direct them to our website at

www.michigan.gov/bcc. Then, click on the “Publications/Bulletins/Interpretations/Advisories” link

for more information on how to subscribe to and receive an electronic notiﬁcation of when each quarterly

newsletter is posted.

www.michigan.gov/bcc - Page 2

plan review Division

VESTIBULE REQUIREMENTS IN THE 2009 MICHIGAN UNIFORM

ENGERY CODE

d. Building entrances in buildings located in climate

zone 1 or 2.

By Todd Cordill, NCARB, Chief

Plan Review Division

e. Building entrances in buildings located in climate

zone 3 or 4 that are less than four stories

above grade and less than 10,000 square feet in area.

Under what circumstances are vestibules required for

new buildings or building additions? For buildings other than

one-and two-family dwellings or low-rise residential buildings

(three or fewer stories above grade) the requirements are found

in section 501.1 of the 2009 Michigan Uniform Energy Code

that references ANSI/ASHRAE/IESNA Standard 90.1-2007.

Section 5.4.3.4 of the standard states:

f.

Building entrances in buildings located in climate

zone 5,6,7, or 8 that are less than 1,000 square feet in

area.

g. Doors that open directly from a space that is less

than 3,000 square feet in area.

Building entrances that separate conditioned space from the

exterior shall be protected with an enclosed vestibule, with

all doors opening into and out of the vestibule equipped

with self-closing devices. Vestibules shall be designed so

that in passing through the vestibule it is not necessary for

the interior and exterior doors to open at the same time.

Section 5.4.3.4 and its exceptions are clear except for the

application to tenant spaces. When we consulted the staff

at ASHRAE we did not get a clear answer regarding tenant

space. To apply this section we will look to the deﬁnition of

“building entrance” in section 3.2 of the standard. When the

deﬁnition is applied it is clear that a tenant space entrance is

not a “building entrance.” We then may apply exception g, and

if the tenant space is less than 3,000 square feet, a vestibule is

not required.

Exceptions:

a. Building entrances with revolving doors.

b. Doors not intended to be used as a building

entrance.

Questions may be addressed to the Plan Review Division

at (517) 241-9328 or the Building Division at (517) 241-9317.

c. Doors opening directly from a dwelling unit.

ELEVATOR SAFETY division

ASME B20.1 Safety Standard for Conveyors and Related Equipment

of the letters and ﬁgures should be not less than 3.2 mm

(0.125 in.). The data plate should help assure the device is

not mistaken for a device which the Elevator Safety Division

does regulate. All warning signs as required by the B20.1

Safety Standard for Conveyors and Related Equipment must

also be properly posted or we may assume the device to be

an elevator, and enforce the Michigan Elevator Rules, ASME

A17.1 requirements, and write violations accordingly.

By Cal Rogler, Chief

Elevator Safety Division

The Elevator Safety Division has reviewed the Michigan

Elevator Laws and the Michigan Elevator Rules with regard

to a conveyor built to the American Society of Mechanical

Engineers (ASME) B20.1 Safety Standard for Conveyors and

Related Equipment. It is our determination that conveyors and

conveying systems which are designed, constructed, installed,

maintained, inspected, and operated to the provisions of

the ASME B20.1 Standard, do not fall within the scope the

Elevator Safety Board Act, PA 227 of 1967, as amended. This

means the Elevator Safety Division does not have jurisdiction

of and will not regulate equipment which is certiﬁed compliant

with the American Society of Mechanical Engineers (ASME)

B20.1 and maintained and operated accordingly.

The installation of a B20.1 device shall comply with

the Michigan Building Code and requires a building permit

be obtained for supports, structures, etc. Local zoning

requirements must also be followed. The B20.1 Standard

contains requirements for the safe installation, maintence and

use of the device.

The Michigan Elevator Rules may be found on the Elevator

Safety Division website www.michign.gov/bcc.

However, it is recommended that a data plate should be

securely attached in plain view to the main line disconnect or

controller. The data plate should indicate the Standard and

the edition in effect at the time of installation. The data plate

should be of such material and construction that the letters

and ﬁgures stamped, etched, cast, or otherwise applied to the

face shall remain permanently and readily legible. The height

If you have any questions or need assistance with accessing

the website, please call the Elevator Safety Division at (517)

241-9337.

www.michigan.gov/bcc - Page 3

building division

Michigan Residential Smoke Alarm Requirements

By Larry Lehman, Chief

Building Division

Issue

2. Installation, alteration or repairs of plumbing or

mechanical systems are exempt from the requirements of

this section.

Must smoke alarms be hard wired with battery back up and

interconnected as required for newly constructed residential

dwellings? Must these smoke alarms be installed in the same

manner when alterations, repairs, and additions requiring a

permit occur in existing residential dwellings?

This section applies a unique provision in the code

requiring smoke alarms to be installed and located as required

for new dwellings when a building or an electrical permit is

required for building or electrical installations, while exempting

work involving exterior surfaces, the addition of a porch or

deck, and the installation, alteration, or repairs of plumbing or

mechanical systems.

Discussion

There are different installation requirements for smoke

alarms depending on whether the installation is in a newly

constructed dwelling or is part of an alteration, repair, or

addition to an existing dwelling.

The 2009 MRC, R314.4 requires smoke alarms to receive

their primary power from the building wiring when such wiring

is served from a commercial source, and requires smoke alarms

to be interconnected.

New dwelling requirements:

The 2009 Michigan Residential Code (MRC) R314.3

requires the installation of smoke alarms for new construction

in the following locations:

Exceptions:

1. Smoke alarms shall be permitted to be battery operated

when installed in buildings without commercial power.

2. Interconnection and hard-wiring of smoke alarms

in existing areas shall not be required where the

alterations or repairs do not result in the removal

of the interior wall or ceiling ﬁnishes exposing the

structure, unless there is an attic, crawl space or basement

available which could provide access for hard wiring

and interconnection without the removal of interior

ﬁnishes.

1. In each sleeping room.

2. Outside each separate sleeping area in the immediate

vicinity of the bedrooms.

3. On each additional story of the dwelling, including

basements and habitable attics but not including crawl

spaces and uninhabitable attics. In dwelling units with

split levels and without an intervening door between the

adjacent levels, a smoke alarm installed on the upper level

shall sufﬁce for the adjacent lower level provided that

the lower level is less than one full story below the upper

level.

The second exemption clearly indicates interior ﬁnishes do

not need to be removed. Additionally, this code section does

not address the ﬁshing of wiring that may be necessary for the

interconnection and hard wiring of smoke alarms, which also

may require the removal and replacement of building insulation

and vapor retarders, penetration of required ﬁreblocking, and

installationof wiringinstudcavitiesnecessarytoaccommodate

the ﬁshing of wires.

The 2009 MRC, R314.3 also requires smoke alarms to be

interconnected when there is more than one alarm device in

such a manner that the activation of one alarm will activate all

the alarms in the individual unit..

Existing dwelling requirements concerning alterations,

repairs and additions:

The 2009 MRC, R314.3.1 provides language for alterations,

repairs, and additions. When alterations, repairs or additions

requiring a permit occur, or when one or more sleeping rooms

are added or created in existing dwellings, the individual

dwelling unit shall be equipped with smoke alarms located as

required for new dwellings.

Rationale:

Section 4, (3) (d) of the Stille-DeRrossett-Hale-Single

State Construction Code Act, 1972 PA 230, states: “The code

shall be designed to effectuate the general purposes of this act

and the following objectives and standards: . . . To eliminate

restrictive, obsolete, conﬂicting, and unnecessary construction

regulations that tend to increase construction costs

unnecessarily or restrict the use of new materials, products,

or methods of construction, or provide preferential treatment

to types or classes of materials or products or methods of

construction.”

Exceptions:

1. Work involving the exterior surfaces of dwellings, such

as the replacement of rooﬁng or siding, or the addition or

replacement of windows or doors, or the addition of a

porch or deck, are exempt from the requirements of this

section.

www.michigan.gov/bcc - Page 4

building division (con’t)

is exposed, the smoke alarms shall be interconnected and

hard-wired when the building has wiring from a commercial

source except as noted in the 2009 MRC 314.4, Exception 2.

The 2009 MRC, R104.10 states in part “Wherever there are

practical difﬁculties involved in carrying out the provisions

of this code, the building ofﬁcial shall have the authority to

grant modiﬁcations for individual cases, provided the building

ofﬁcial shall ﬁrst ﬁnd that special individual reason makes the

strict letter of this code impractical and the modiﬁcation is in

compliance with the intent and purpose of this code and that

such modiﬁcation does not lessen health, life and ﬁre safety . .

. .”

When interior ﬁnishes have to be removed such

as cutting out interior ﬁnishes to mount an electrical

box, and ﬁshing wires to accomplish hard-wiring and

interconnection, additional smoke alarms may be battery

operated smoke alarms in accordance with MRC 314.4,

Exception 2, and the additional smoke alarms are not

required to be interconnected.

The requirements for smoke alarms to be installed in

buildings and structures at speciﬁed locations comes from

chapter 9 of the Michigan Building Code (MBC) and NFPA

72. Therefore, since they are referenced standards from

the 2009 Michigan Residential Code (MRC), the Building

Ofﬁcial or Building Inspector shall determine when smoke

alarms or additional smoke alarms are required, if they are to

be hard-wired or wireless systems, and whether they require

interconnection.

It should also be noted, 2009 MRC, Section 314.3.1,

exception 1, exempts work on the exterior of a structure.

As an example, when the installation of a swimming pool or

hot tub occurs on the exterior of a home, exception 1 would

allow the installation of a swimming pool or hot tub without

expanding the project to include smoke alarms regardless of

whether a building or electrical permit are required as part

of the swimming pool or hot tub installation. Exception

2 exempts the installations, alterations or repairs of

plumbing or mechanical systems from the requirements

of adding smoke alarms regardless of whether a building

or electrical permit is required as part of the plumbing or

mechanical system. As an example, this exception would allow

the replacement of equipment such as a furnace without

expanding the project to include smoke alarms regardless of

whether a building or electrical permit are required as part of

a furnace replacement.

The building ofﬁcial or building inspector should consider

that wireless smoke alarms which are part of an interconnected

system are widely available, and provide an acceptable cost

effective and safe solution when installed in accordance with

manufacturers’ installation instructions and are adequately

maintained. Removing interior ﬁnish and ﬁshing wires presents

a practical difﬁculty while greatly increasing construction

costs.

Conclusion

Furthermore, it is the building ofﬁcial or building inspector

who determines whether additional smoke alarms are required,

if they are to be hard-wired or wireless systems, and whether

they require interconnection.

When alterations, repairs, or additions requiring a building

or electrical permit occur, or when one or more sleeping

rooms are added or created in existing dwellings, the individual

dwelling unit shall be equipped with smoke alarms located as

required for new dwellings. When access is provided by means

of a crawl space, basement, or attic, and the building framing

Questions may be directed to the Building Division at

(517) 241-9317.

BCC Contact Information

Facsimile Numbers:

Telephone Numbers:

Administration & Ofﬁce of Administrative Services (517) 241-9570

Ofﬁce of Management Svcs, & Plumbing Division(517) 373-8547

Building, Electrical, Mechanical, Plan Review, (517) 241-9308

Ofﬁce of Land Survey & Remonumentation, Elevator Safety &

Boiler Divisions (517) 241-6301

Administration (517) 241-9302

Ofﬁce of Administrative Services ( 517) 335-2972

Ofﬁce of Management Services (517) 241-9313

Boiler Division (517) 241-9334

Building Division (517) 241-9317

Act 54 Registration (517) 241-9317

Electrical Division (517) 241-9320

Elevator Safety Division (517) 241-9337

Mechanical Division (517) 241-9325

Ofﬁce of Land Survey & Remonumentation (517) 241-6321

(includes State Boundary Commission)

Plan Review Division (517) 241-9328

Plumbing Division (517) 241-9330

Mailing Addresses:

P.O. Box 30254 (Codes: general correspondence)

P.O. Box 30255 (Codes: permits, licenses, and other documents

containing payment)

P.O. Box 30704 (Ofﬁice of Land Survey & Remonumentation)

Lansing, MI 48909

www.michigan.gov/bcc - Page 5

MECHANICAL DIVISION

DO YOU HOLD THE PROPER LICENSE CLASSIFICATION?

By Kevin Kalakay, Chief

Mechanical Division

denial, revocation, or suspension of the license. A licensee

may also be required to pay restitution to the party for whom

the unlicensed mechanical work was performed.

The Mechanical Division receives calls daily concerning

the validity of a mechanical contractor’s license and the scope

of work that can be performed with such license. Routinely,

it is found that the licensee in question does not possess

the proper license classiﬁcations for the work he or she has

performed or has contracted to perform.

It is appropriate to ﬁle licensing complaints with the

Ofﬁce of Adminstrative Services regarding contractors that

performed mechanical work for which they are not properly

licensed. Complaint information can be found at www.

michigan.gov/bcc.

Performing unlicensed mechanical work is a direct

violation of the Forbes Mechanical Contractors Act, 1984 PA

192.

Deﬁnitions of the licensing classiﬁcations are located in

the Forbes Mechanical Contractors Act, 1984 PA 192, Sec

2. which can be found at the following link: http://ww w .

michigan.gov/lara/0,1607,7-154-10575---,00.html.

Any individual, partnership, association, or corporation

found performing mechanical work without ﬁrst obtaining

the proper license and classiﬁcation(s) through written

examination is guilty of a misdemeanor and subject to ﬁnes,

imprisonment, and sanctions, including, but not limited to,

Any questions may be directed to the Mechanical Division

at (517) 241-9325.

plumbing division

LICENSE RENEWAL DEPENDENT UPON 2009 PLUMBING CODE

UPDATE COURSE

By Robert Konyndyk, Chief

Plumbing Division

Individuals who have not completed the class will not

receive license renewal notices and will not be able to renew

The State Plumbing Act, 2002 PA 733, Sections 23 (2) their plumbing license as required by law. Further, the act

and 25 (2), requires licensed master and journey plumbers to clearly states that a license not renewed within a three-year time

complete approved code update classes within 12 months after frame becomes void and the individual will have to reexamine.

the plumbing code change.

Section 15 of the act clariﬁes who shall be licensed to install

plumbing and Section 49 mandates that individuals not licensed

The ﬁve hours of instruction addressing the 2009 Michigan and performing plumbing will be guilty of a misdemeanor

Plumbing Code and the State Plumbing Act began on the 2009 punishable by a ﬁne of not less than $1,000 per day.

code, effective date of August 20, 2010. For that reason, master

and journey plumbers shall complete an approved course for

We urge you to take the class as soon as possible and call

the 2009 code by August 19, 2011. Notices have been provided the Plumbing Division if you have any questions. Class course

to all licensees reminding them of the requirement. The law instructor’s information is available on the Bureau website at

requirement was enacted to insure that all licensees have the www.michigan.gov/bcc.

most recent code information to operate in a safe manner

while serving the public.

Questions regarding this matter may be directed to the

Plumbing Division at (517) 241-9330.

Providing for Michigan’s Safety

in the Built Environment

www.michigan.gov/bcc - Page 6

Electrical division

Wiring Methods for Patient Care Areas in Health Care

Facilities

By Dan O’Donnell, Chief

are used for simple interviews or invasive procedures.

Electrical Division

Health care facilities offer many challenges for both

electrical contractors and electrical inspectors with respect to

the proper wiring method required given the complexity that

these types of buildings present. The current electrical code

for health care facilities in effect in the State of Michigan is the

2008 Michigan Electrical Code (MEC). The MEC includes

the Electrical Part 8 Rules and by reference adopts the 2008

National Electrical Code (NEC)/ NFPA 70 with the Michigan

amendments. Article 517 in the 2008 NEC deals with health

care facilities. The scope of article 517.1 as deﬁned in the code

states that “the provisions of this article shall apply to electrical

construction and installation criteria in health care facilities

that provide services to human beings.” Health care facilities

are deﬁned in the code as “buildings or portions of buildings

in which medical, dental, psychiatric, nursing, obstetrical or

surgical care are provided.” The deﬁnition further states that

“health care facilities include but are not limited to hospitals,

nursing homes, limited care facilities, clinics, medical and dental

ofﬁces, and ambulatory care centers, whether permanent or

movable.” Patient care areas are also clearly deﬁned in the

code as “any portion of a health care facility wherein patients

are intended to be examined or treated.” There is no reference

in the deﬁnition of patient care areas as to whether these areas

Article 517.1 states that “a doctor’s examining room

located within a limited care facility would be required to

meet the provisions of 517.10.” Article 517.10 (A) states

that “part II shall apply to patient care areas of all health care

facilities”. Article 517.10 (B) points out the areas where part II

of Article 517 would not apply and includes “business ofﬁces,

corridors, waiting rooms, and the like in clinics, medical and

dental ofﬁces, and outpatient facilities.” Simply put, the code

is clear that areas other than the patient examining rooms in

doctors’ ofﬁces, clinics, and the like may be wired using an

acceptable wiring method recognized in chapters 1 through 4

of the code which would include Type NM Cable. However,

the patient examining rooms must be wired in accordance

with the requirements speciﬁed in Article 517.10.

Electrical inspectors and contractors alike need to be

mindful of the requirements for health care facilities as

speciﬁed for in article 517 of the NEC. Researching the code

and communication between contractors and inspectors can

help avoid costly mistakes and jobsite delays.

If you have questions feel free to contact the Electrical

Division at (517) 241-9320.

****** electrical reminders******

Code update classes will not be required for renewal of 2012 licenses for master and journey electricians, ﬁre alarm

specialty technicians, and sign specialist.

Apprentice electrician registrations expire on August 31. Each electrical apprentice currently registered with the State of

Michigan was sent a renewal form in mid June which was due in our ofﬁce by July 31, 2011 for processing. Hope everyone is

enjoying a safe and prosperous summer.

michigan codes & rules currenlty in effect

Boiler Fees

Boiler Rules - General

Boiler Operators & Stationary Engineers Qualiﬁcation & Registration Program Rules

Building/Residential Codes (Part 4)

Electrical Code (Part 8)

Elevator Safety - General

Manufactured Housing General Rules

Mechanical Code

Plumbing Code (Part 7)

Rehabilitation Code

09/04/2007

07/27/2009

07/30/2010

03/09/2011

12/02/2009

06/21/2010

09/02/2008

10/21/2010

08/20/2010

03/09/2011

06/16/2008

03/09/2011

Subdivisions of Land

Uniform Energy Code

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www.michigan.gov/bcc - Page 7

office of land survey and

remonumentation

Title Vesting Authority of Vacated Public Areas Within Recorded

Subdivisions

By Nicholas J. Clever, P.S.

Traverse Closure [R 560.112]

Amended plats ﬁled under section 229

State Plat Review Fee and Filing and Recording Fee [MCL

560.229 & 560.241]

Floodplain Restrictions (if applicable) [MCL 560.194]

Recorded County Road Commission Resolution (if

applicable) [MCL 560.226]

Ofﬁce of Land Survey and Remonumentation

The Ofﬁce of Land Survey and Remonumentation

(OLS&R) is the agency responsible for the review and approval

/ rejection of subdivision plats ﬁled with the State of Michigan

under the Land Division Act, 1967 PA 288, MCL 560.101 et

seq. (LDA).

Recorded Municipal Resolution (if applicable) [MCL

560.226 & 560.256]

When a subdivision plat is submitted for review to the

OLS&R pursuant to either section 169 (proprietor plats),

section 210 (assessor plats) or section 229 (amended plats) of

the LDA, it shall be accompanied by the following:

Recorded Court Judgment [MCL 560.228]

Final Plat on Approved Material [R 560.104]

Land Corner Recordation Certiﬁcates [R 560.112]

Recorded Easements (if applicable) [R 560.112]

Title Search for Easements of Record [R 560.112]

Traverse Closure [R 560.112]

Proprietor plats ﬁled under section 169

Preliminary Plat [MCL 560.111]

Preliminary plat approvals (as applicable):

Road Commission [MCL 560.113]

Drain Commissioner [MCL 560.114]

State Transportation [MCL 560.115]

Natural Resources and Environment [MCL 560.116 &

560.117]

In accordance with section 171 of the LDA and upon

OLS&R’s completion of the plat review the plat will be either:

(1) approved and forwarded to the county register of deeds

for recording or (2) rejected. Upon rejection of a plat, a letter

providing the reasons for rejection shall be provided to the

following parties as follows:

Health Department [MCL 560.118]

Municipality [MCL 560.120]

(1) Proprietor plats – Rejection letter, plat mylar, and

markup copies will be issued to the proprietor with the

majority interest, with copies of the rejection letter being

provided to other proprietors and the surveyor of record.

Upon authorization by the proprietor, the plat mylar

and markup copies may be provided to the surveyor of

record.

State Plat Review Fee and Filing and Recording Fee [MCL

560.142 & 560.241]

Certiﬁed True Copies of Plat [MCL 560.169]

Floodplain Restrictions (if applicable) [MCL 560.194]

Owner’s Policy of Title Insurance [MCL 560.245]

Governmentally Imposed Subdivision Restrictions [R

560.103]

Final Plat on Approved Material [R 560.104]

Land Corner Recordation Certiﬁcates [R 560.112]

Recorded Easements [R 560.112]

(2) Assessor plats – Rejection letter, plat mylar and markup

copies will be issued to the surveyor of record, with a copy

of the rejection letter being provided to the assessor.

Traverse Closure [R 560.112]

State Issued Constructions Permits and Proof of Surety

(if applicable) [R 560.121]

(3) Amended plats – Rejection letter, plat mylar and markup

copies will be issued to the surveyor of record, with copies

of the plat rejection letter being provided to the Ofﬁce of

the Attorney General and the plaintiff’s attorney.

Assessor plats ﬁled under section 210

State Plat Review Fee and Filing and Recording Fee [MCL

560.142& 560.241]

Subdivision plat re-submittals, resulting from the rejection

of a plat by the OLS&R, are considered new submittals and

shall be accompanied by a new state plat review fee and any of

the above listed required documentation, as applicable.

Municipal Resolution Ordering Assessor Plat [MCL

560.201]

Current Year’s Tax Roll & Preliminary Map [MCL

560.204]

Recorded Lot Line Agreements [MCL 560.206]

Proof of Public Notice [MCL 560.209]

Final Plat on Approved Material [R 560.104]

Land Corner Recordation Certiﬁcates [R 560.112]

Recorded Easements [R 560.112]

Questions regarding this matter may be directed to the

Ofﬁce of Land Survey and Remonumentation at (517) 241-

6321.

www.michigan.gov/bcc - Page 8

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www.michigan.gov/bcc - Page 9

Scott Walkowicz

Pages 46-48

March 21, 2024

LARA-BCC-Rules

Attention:

Tony Williamson, Bureau of Construction Codes

Via email: LARA-BCC-Rules@michigan.gov

RE: Storm Shelter Provisions in 2021 Michigan Building Code

Dear Mr. Williamson and LARA:

I am writing to oppose late amendments to the proposed rules that would adopt the 2021 IBC as

our next MBC. I am writing as a Michigan resident; as a parent who has had students in

Michigan schools; as a son whose mother survived the 1953 Flint-Beecher EF5 tornado; as a

friend to police, firefighters, doctors and nurses and others would benefit from storm shelters in

their new buildings; as a Professional Engineer who practices structural engineering; as an

engineer who has a great deal of experience working with systems that can provide economical

storm shelter; and, as a consultant for the Michigan Masonry Coalition.

First, I have watched the current, proposed rules since their inception and there previously were

no exceptions to the storm shelter requirements provided in Section 423. I am currently traveling,

and on a whim and prior to tomorrow’s Public Hearing, I went to the BCC’s website. There I

found two notable changes - Sections 423.3 and 423.4 were now excepted in the proposed rules,.

These added exceptions were not in reference to any written comments that were shared in the

BCC documents related to the proposed new MBC – I reviewed the published letters/comments.

I had seen that there were comments related to other aspects of the code, but none related to the

storm shelter provisions. As such, I was going to write a brief letter in support of maintaining the

full adoption of Section 423. It appears, however, and as in prior adoption processes, that actions

have taken place outside of the Public Hearing process and without public knowledge, that led to

the new storm shelter exceptions. A person would not have known of those recent changes

unless, and until, they had re-visited the BCC’s website and notices the undated but changed

proposed rules. I have checked various websites every couple months, through the 2021 adoption

process, and was becoming convinced that Section 423 was going to be adopted in whole… until

this evening. This seems entirely inappropriate for a public safety related process both with

regard to the lack of announcement of changes and with regard to the late timing of the changes.

Second, during the 2018 MBC adoption process, previously withdrawn, I, and others, had spoken

in support of maintaining the storm shelter provisions and in opposition to poorly or unsupported

letters of objection to shelters, particularly in schools. I will recap my general opinions here and

would very much like to share updated data with you, and other appropriate bodies of influence

for our code adoption process, in the future and prior to finalizing the proposed rule language.

With regard to storm (tornado) shelters being required in Michigan’s Building Code:

▄▀ Specialists in Masonry and Structures ▀▄

5870 Chartres Way ■ East Lansing ■ Michigan 48823 ■ (517) 648-9319 ■ scott@walkowiczce.com

Part 4 – Building Code – Proposed Rules

Page 2 of 3

Storm (Tornado) Shelter Requirements Exceptions

April 3, 2024

1. Tornadoes happen in Michigan. Prior data that I had cited noted 58 significant tornadoes

(EF3-5) having occurred in Michigan between 1950 and 2017. 2510 injuries and 195

deaths occurred from those tornados according to NOAA. That data can be updated, and

please note – we have already had tornadoes in Michigan this year….

2. Storm shelters requirements were retained, in the former proposed rules, for Critical

Emergency Operations buildings.

3. There was strong opposition to the late addition of storm shelter requirement exceptions

for Group-E buildings in the former proposed rules.

4. While conventional construction for schools and critical emergency operations buildings

is done to higher wind design standards than for typical use buildings, their conventional

construction design IS NOT SUFFICIENT for tornado level wind loads and flying debris

resistance.

a. Current shelter spaces in schools would be classified as ‘best available’ shelter

space and they may or may not have better protective structural capacity than

other parts of the building, but they will definitely not have sufficient structural

capacity to protect occupants during an EF3 or greater tornado. They may, also,

prove insufficient for lesser level tornadoes.

b. EF3 tornadoes have wind speeds 36.5% greater than typical school design wind

speeds, and the resulting design wind pressure is 89% greater (load is 189% of

design capacity).

c. EF4 tornadoes have wind speeds 66.7% greater, and design wind pressures 175%

greater (275% of design capacity).

d. EF5 tornadoes have wind speeds 100% greater, and design wind pressures 332%

greater (432% of design capacity).

e. Structural failure often occurs at 200 % to 250% of design capacity.

5. It had been said, during the former process, that Michigan was the only state that would

require tornado shelter construction in schools that didn’t fully fund school construction.

My former research showed that many states were constructing school shelters without

any funding, or with very low funding, from the state. I, also, noted that FEMA provided

(and still provides) grants for the premium costs associated with shelter construction.

6. It was also previously presented that school districts, especially small, rural districts,

could not afford to construct new schools, or school additions, due to the significant cost

of shelter construction.

a. Shelters are typically constructed using spaces planned for other activities and the

only cost is the premium cost for the shelter construction which will include

greater structure for the roofs, walls and possibly the foundations. That premium

cost, however has been shown to be very small relative to the overall construction

budget – typically a percent or two.

b. One of the apparent strongest objections was related to small additions for rural

schools. Note that occupancies less than 50 do not require shelter spaces. For

spaces with 50, or more, occupants a shelter space will be required for at least the

occupants of the addition.

c. I previously ran, and presented, a quick financial analysis for a small, 6,000

square foot addition, or about six classrooms and ancillary space. The whole

space was considered as a shelter, rather than only a portion of it, to shelter only

the occupants of the addition – so a net increase in sheltered students beyond the

Part 4 – Building Code – Proposed Rules

Page 3 of 3

Storm (Tornado) Shelter Requirements Exceptions

April 3, 2024

addition at increased cost for the whole addition. The base construction at time

would have been approximately $1.8 million while the shelter cost would have

been approximately $2.4 million, or about $600 thousand more. That number

could be off-putting, but when considering the bonded cost, it amounted to about

$10/year in my small community of Bath Township, based on our taxable units,

values and rates. That is a very palatable cost to any community member and

would be easily presentable and defensible. The cost of the shelter would not have

to be in place of other aspects of construction, with proper presentation and

education of the local public.

d. The premium cost differential decreases as the overall construction project size

increases.

7. There is a premium cost to building shelter spaces. There is also a cost to not sheltering

students or other occupants in tornado prone areas. The current data for 2022, from the

U.S Department of Transportation, lists the value of a statistical life (VSL) as $12.5

million. With one statistical life valued at $12.5 million, the relative cost of a tornado

shelter is very small in comparison. We cannot afford to not shelter where the code

currently suggests that shelters should be provided.

8. Masonry and concrete provide economical envelope and structural systems to create

shelter spaces within new construction. They have been, and are being, used in many

states around Michigan and occupants of Critical Emergency Operations and Group-E

buildings are being properly protected. Many, possibly most of those states (I’d need to

update my research) are doing so with no state funding or low state funding levels.

Additional systems are being developed to provide other options for the structure and

envelope.

9. Other aspects of shelter construction can be managed via the code language to limit the

nature, and related costs, of hand-washing, toilet and lighting facilities. Ventilation

systems are recommended and must be protected, but other options are available to

provide natural ventilation. The MEP system costs can be managed, and to some degree,

mitigated if needed.

There are, likely, other points that I could make, and certainly updated and greater depth of detail

can be provided as the process proceeds. I encourage you to review the substance of the

information submitted during the prior process. I invite you to further consider the above points

and to allow the process to properly and fully address the realities of the benefits and potential

costs related to shelter construction. I, and others, are happy to assist with that process.

Please contact me if you have any questions regarding WCE’s evaluation relative to this

information. Please, also, let me know if/when alternative viewpoints and data can be provided.

Thank you for your time in considering my comments.

Sincerely,

Scott W. Walkowicz

PE_{AL/AR/CA/CO/FL/GA/IA/IN/KS/LA/MI/MO/MS/NC/NY/OH/SC/SD/TN/TX/VA/WA/WI}, SE_UT, FTMS, NCEES MLE

Owner/WCE

https://walkowiczce-my.sharepoint.com/personal/scott_walkowiczce_com/Documents/Documents/001 Masonry Coalition/Tornado Sheltering/2021 MBC

Adoption/Walkowicz Letter - Support of Storm Shelter Provisions 20240403.docx

William Hordyk

Pages 49-50

To Whom it may concern,

In review of the proposed changes to the Michigan Building Code, I present the following on behalf of

the Metro Building Inspectors Association of Greater Grand Rapids, and myself.

General

‐

In several modifications to rule language there appears a change from a metric

measurement symbol to a metric word. For example, “mm millimeter” the symbol "mm"

appears 2,434 times in the model code. To be clear, the short forms for metric units (such as

mm for millimeter) are symbols, not abbreviations. These correct ways to use the Système

international d’unités, and other related units are set by the international standards that

define the SI. There is no need to create additional confusion of measurements or additional

rules that will need to be reviewed in the next promulgation process. Please allow the

symbol mm to remain where used in the model code.

Rule 401

‐

It is proposed to newly except 18 sections of chapter one of the model building code from

being included in the Michigan Building Code including 104.2, 104.3, 104.8.1, 104.10, 105.3,

105.3.1, 105.3.2, 105.6, 111.2, 111.3, 113.2, 113.3, 113.4, 114.1, 114.2, 114.4, and 115.1 to

115.4. We ask the director to specifically identify why these sections, which have been

allowed to remain in prior versions of the Michigan Building Code are now being removed.

The Stille Derosett‐Hale Single State Construction Act which grants authority to promulgate

the Building Code has not changed in a manner that would affect the sections proposed to

be removed. Nor, has the model code changed these sections in such a way that they would

contradict the authority of Public Act 230. Given that the enacting legislation and the model

code have not changed language and I know of no judicial rulings pertaining to the sections

in question, there should not be a change in the rules to remove them now.

Rule 415a

‐

The definition for “Act” should not be written into code language. There are references

within established rules and draft rules that reference different Public Acts of Michigan,

such as the Skilled Trades Regulation Act, the Occupation Code, the Adult Foster Care

Licensing Act, as well as the Stille Derosett‐Hale Single State Construction Act. Where any

Act is referenced within code language it is, and properly so, identified using it’s full name.

PA 230 is named the “Stille Derosett‐Hale Single State Construction Act” within the Act. It

does not need to be redefined in code language that is subordinate to the Act.

"Cold Weather Months" should not be added as a definition. The language used here

should, instead, be added to the code section you intend to modify; that being 1203.1

The definition of “Occupiable Space” should not be changed. This definition is a bedrock

definition applicable to every other section of code in some manner. The seemingly minor

change will have many unforeseeable issues with interpretation of the code. As an

alternative to redefining “Occupiable Space”. The desired exceptions to it should be

identified in sections 1203.1 of this code and 309.1 of the Mechanical Code.

‐

Rule 418

‐

To effect the desired outcome of defining “cold weather months” and redefining

“occupiable space” the draft language of 1203.1 should word the proposed exception 2 as

follows:

“Exception 2: Interior, seasonal spaces that are unoccupied during November 1 through

April 1 in climate zone 5A and from October 15 through May 1 in climate zones 6A and 7,

including spaces such as restrooms, shower buildings, day use restrooms, concession stands,

press boxes, ticket booths and locker rooms.”

Rule 421

‐

Rule 421 was not proposed to be modified, however,

The modifications to section 1025.1 can be struck from rule 421.

Rule 421 was not proposed to be modified, however, with the striking of the Michigan’s

definition of “High‐Rise Building” (408.30415a), Rule 421 does not need to correct the

language of the 2021 model code.

‐

Rule 421 proports to modify section 1030.1 retaining to Emergency escape and rescue

opening. The model code section has been renumbered to 1031.2. The rule needs to be

changed to reflect the renumbering. In addition, the model code language should be

reviewed considering the changes made to this section of the model code, the prior

Michigan language is substantially similar to the 2021 model code and can be rescinded.

Rule 429

‐

Rule 429 was not proposed to be modified, however,

With the striking of the Michigan’s definition of “High‐Rise Building” (408.30415a), Rule 429

does not need to correct the language of the 2021 model code.

Rule 429 can be rescinded.

‐

Rule 429b

‐

Rule 429 was not proposed to be modified, however,

The section references within this existing Michigan rule do not point to the correct 2021

model code sections.

‐

More appropriately this rule can be rescinded to allow 3006.3 clear directions on when

elevator lobbies are required.

Rule 447

‐

Rule 429 was not proposed to be modified, however,

The reference to section 1023.11 needs to be changed to 1023.12.

Thank you for the consideration of these items and honestly (honestly, because inflection can be

misread in written communication) thank you for your diligence in updating the codes.

William A Hordyk, MCP

Tracie Pack

Page 51

LARA-BCC-Rules

From:

Sent:

To:

Tracie Pack <paxnmac@gmail.com>

Thursday, April 4, 2024 11:57 AM

LARA-BCC-Rules

Subject:

Building Code Rules

CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov

Good afternoon. I'm recommending that the Bureau of Construction Codes keep the current building code rules as they

are with no amendments.

Thank you,

Tracie Pack

1