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The Cost of Inaction of not Updating the Chicago Plumbing Code

2021 0427 Ideas Post
Apr 27, 2021
Ed Feibel

This time-sensitive issue has a real impact on economic development the longer it languishes in discussion between city workers, unions, and developers.

Chicago is in the process of updating the plumbing code, and there is an ongoing discussion regarding the use of Polyvinyl Chloride (PVC) piping in projects and some additional changes to the plumbing code. This could seriously impact development in your neighborhood or a project you are working on in Chicago if not addressed.

We ask for your support as MAPS works with many developers that have observed the financial impact of these changes to the Plumbing Code. We spoke with Alderman Cappleman, Ghian Foreman of Emerald South Economic Collab, Ken DeMuth with Pappageorge Haymes Partners, and Heather Morrison, President of MAPS to discuss the real cost of inaction of not adopting this code change. These changes could impact a project to a degree of several hundred thousand dollars and could be up to 3.5% of a project’s construction cost.

We spoke with Alderman Cappleman regarding the proposal, and he stated that "We're now at a point in Chicago where too many people are rent-burdened due to the high costs of housing. It's critical that we do everything we can to bring down those costs because when we do, it can also help in reducing rents. Updating the Chicago Plumbing Code to expand the use of PVC piping is one easy step to help make Chicago more affordable."

Chicago Plumbing Code (CPC) currently limits the use of PVC heavily. Per CPC 18-29-701.1 “the use of PVC plastic pipe shall be limited to buildings three stories or less in height intended for residential occupancy.” Additionally, the use of PVC is limited to gravity drainage and venting only and shall not be allowed for draining, waste, or venting in other applications. This creates a large additional cost for projects, as cast iron and other pipes are more expensive and more difficult to work with, which will limit the possibility of some development, as there is a large upfront cost to those materials as well as a higher labor cost to work with them. In addition, there is a storage cost to secure the materials from the possibility of theft.

Ghian Foreman, President and CEO of the Emerald South Economic Development Collaborative; the group generates community wealth and amplifies local culture through shared pride, power, and investment for Chicago's mid-South Side. He stated “This proposal provides an opportunity for the entire city, as the use of these materials is a solution to lower the cost of rehabilitation of existing buildings in all neighborhoods while providing a forward-thinking plumbing code for the city. PVC also enables a wealth-building pipeline within the community as individuals will be able to learn and develop skills in construction that can lead to future careers and allow for economic growth.”

Ken noted that “PVC is an environmentally friendly material for construction. PVC has a lower embedded energy factor and its durability means it can last almost indefinitely in a building. PVC can be ground up and recycled as pipe just as metals can. And since the raw materials are petroleum-based rather than ore, less environmental damage, and waste material is likely to result when comparing drilling to strip mining. Using PVC facilitates prefabricated ‘manifolds’ produced in a controlled environment which is an advantage for quality control. A manifold design favors above-the-floor rough-ins, meaning toilet rooms can take advantage of wall-hung fixtures that allow greater maneuvering clearances for accessibility, smaller bathroom footprints, and better sanitary conditions along with the sleek-looking appearance that results from the design.”

The Department of Buildings understands this, and has been running a pilot program, originally announced in October of 2017, which allows for the use of PVC beyond what is permitted in the code in the below projects:

1. New construction of buildings of exclusively residential occupancy, not more than four stories in height; or

2. Any work in an existing building (constructed prior to 2010) of any occupancy, and not more than four stories in height, including additions to such buildings.

Note that the pilot program is on a project-by-project basis, and has been extended to through June 1, 2021. While the program has been extended each time the expiration date has been reached, the continuous changes and uncertainty make it difficult to plan ahead for developers/contractors to move forward with projects. In the three and a half years of the program, 2500 projects have been submitted, saving the developers of those projects $38,304,593. The number of projects submitted makes it clear that the use of PVC in developments is a major cost-saving item that project owners are willing to pursue through additional administrative work in order to utilize it. Additionally, many of the projects that have been submitted are small-scale, single-family homes, with small contractors working on them, seeking to use PVC for underground applications. This program has not only helped larger developers and projects, but also small contractors and private citizens alike.

It is understood that the proposed changes would bring Chicago to be more in line with other municipalities and the model code. The CPC is 20 years old at this point, and a commitment was made to update the code 5 years ago as a part of the third phase of the Chicago Construction Codes Modernization along with the mechanical code. While this process may have been stalled due to the ongoing COVID-19 pandemic, we believe that this needs to be restarted and pushed forward, as it is currently affecting many projects around the city.

The proposal would permit PVC to be used in a wider range of projects, including projects up to 5 stories and occupancies other than just residential, for drainage and vent piping. This would greatly benefit smaller projects, as many mixed-use, 5-story buildings that previously were not permitted to utilize PVC could now, and the savings on the piping could be used to make larger or allow for more developments with less up-front costs. Note that this would not preclude the use of cast iron in these projects if desired, but would just allow for more flexibility in the choice of materials and design.

One project that was previously submitted through the pilot program and given an exception to be 5 stories, rather than 4, was the building at 2908 W. Roosevelt, which is a low-income housing development for Veterans. This project saved $372,000 through the use of PVC, which is 3.5% of the $10,500,000.00 estimated construction cost. These savings could easily break the budget of similar projects if they were not permitted to utilize PVC, or would highly limit the scale of new construction.

Heather Morrison, president of MAPS, notes that “At MAPS, we have submitted 100s of Alternative Code Approval Requests (ACARs) through this pilot program to allow our clients to utilize PVC. Preparing and processing these requests takes many man-hours, both within our office and within City Hall. Approval of this proposal would free up workers to focus on other issues and allow for faster processing of building applications.”

Additionally, the proposal would change the plumbing fixture requirements in the CPC, bringing it more in line with the state requirements. This reduction in the number of plumbing fixtures would allow for more small-scale dining or assembly projects, as less square footage will be required to be used for non-revenue generating items. In addition, the new proposal will allow for Gender-Neutral toilet rooms.

PVC has been an accepted material in the model codes and other municipalities for some time and we believe that this should be implemented in Chicago to both bring parity to the standards as well as allow for greater cost savings and time savings to projects in the city.

The new code will also address the issue of health concerns with the use of lead in pipes. Where cast iron pipes are used in construction, the DOB Proposal will no longer require the use of lead and oakum for open joint connections. Based on our research, Chicago is currently the only municipality to require this technique to be used for cast iron pipes.
Please reach out to us to discuss the possibility of using PVC for your project or to help us let the Department of Buildings know that you support these proposed changes.

We ask for your support as a private consultant that works with many developers and has observed the financial impact of these changes to the Plumbing Code. Please reach out to your alderman or contact the mayor's office directly to get the message out to Mayor Lightfoot to get an ordinance introduced to City Council by May.

Sign the Petition