The Chamber of Commerce of the United States, on behalf of its 82,000 members, which include business firms, associations, and state and local chambers of commerce, is pleased to have the opportunity to comment on the National Institute of Building Sciences (NIBS) appropriation request.

The National Chamber supports funding the full appropriation request of $750,000 for NIBS as provided in the President's budget for fiscal year 1980. The Chamber believes there is a vital need for a non-governmental approach to dealing with issues and problems in the fields of building codes, standards and regulations. NIBS meets this need. It provides the basis for a public-private partnership to address common concerns in this area.

The construction industry should have a full opportunity to utilize the best available building products, components and systems. However, development and application of innovations and improvements in the construction field require research, development and testing efforts. The sources of advancements in this

field can range from persons to individual business firms to broadly based private or public joint ventures.

Communication and coordination among the various aspects of this market structure should exist to provide the timely, efficient, and safe introduction of new technology to the building industry. The National Institute of Building Sciences can perform these functions.

Through its Board of Directors and Consultative Council, NIBS provides a forum for sharing ideas and the candid exchange of views. It also provides an objective source of evaluation and prequalification of new and improved technology.

*Associate Director, Construction, Housing and Community Development, Chamber of Commerce of the United States

This effort can reduce duplication, point out gaps in existing or proposed projects and highlight potentially promising areas for new work. Because responsibility for improving communication and coordination should be shared by government and private enterprise, both sectors should contribute to the financial support of NIBS.

History of NIBS

NIBS was created under Title VIII, Section 809, of the Housing and Community Development Act of 1974 (Public Law (93-383) as a non-profit, non-governmental organization. The President of the United States was to name the initial and succeeding board of directors with the advice and consent of the Senate. NIBS purpose was to act as an authoritative source of information and advice to the construction industry and all levels of government.

The basic mission of NIBS is to bring about a more rational regulatory environment for the construction industry and provide an effective mechanism for encouraging and facilitating the rapid and widespread introduction of new and improved technology. In accomplishing this mission, NIBS also seeks to reduce housing and building costs and improve the overall quality of our built environment. The principal means of accomplishing these tasks is through achieving acceptance of NIBS as the authoritative national source of findings and advice for both the public and private sectors of the construction community.

The basic NIBS legislative mandate as stated in the Housing and Community Development Act requires NIBS to:

o Develop, promulgate, and maintain nationally recognized
performance criteria and standards for adoption by building
regulatory jurisdictions;

o Evaluate and prequalify existing and new building technology;

o Conduct needed investigation in the fields of codes, standards,
and regulation as they impact construction technology; and

o Assemble, store, and disseminate technical data.

In fulfilling this mandate, NIBS was to:

o Create a Consultative Council to provide a forum for
discussion among all segments of the construction community;

o Use existing private and public organizations, institutes,
and agencies in the field to the maximum degree possible;

o Coordinate NIBS' program with other community and environ-
mental development efforts; and

o Consult with the Department of Justice and other agencies
of government to the degree it is necessary to ensure that
the national interest is protected and promoted in the
exercise of NIBS' functions and responsibilities.

In April 1976, the President nominated the first 18 members of the NIBS Board. They were confirmed by the Senate in June 1976, and sworn in by the Secretary of Housing and Urban Development acting for the President during the same month.

On June 28, 1976, the National Academy of Sciences contracted with HUD to advise and assist in organizing NIBS. NIBS was incorporated in the District of Columbia on September 8, 1976, and received its first appropriation from Congress of $1 million for fiscal year 1978. These funds were part of a five year authorization of $10 million in start-up costs for NIBS. With this funding, NIBS was able to begin hiring a staff in November 1977. NIBS received $750,000 for fiscal year 1979.

Current Activities

NIBS is presently undertaking a wide ranging program of activities related to its mandate. It is working with various Federal agencies such as: o The Consumer Product Safety Commission on architectural glazing standards;

o The Office of Science and Technology Policy in the
National Bureau of Standards on improving seismic design
provisions for buildings;

o The General Accounting Office on various studies dealing
with housing costs, computer aided design, and building
energy performance standards; and

o HUD which has retained NIBS to develop a set of model
rehabilitation guidelines for existing buildings as
directed by the Housing and Community Development Act
of 1978.

The Federal Trade Commission has recognized NIBS' unique role by naming it the sole member of a separate group for questioning witnesses on the FTC's proposed rule concerning codes and standards.

NIBS is also consulting with a wide range of private organizations that are vital participants in the voluntary criteria, standards, and code process. Included in this process are private industry elements that are essential in the development of technological innovation.

As part of its continuing efforts to establish communication channels with all parts of the building industry, NIBS is establishing the Congressionally mandated Consultative Council. Because membership is open to all who wish to participate, NIBS has established a wide range of memberships which should allow all interested organizations and individuals to take part in the Council and be part of NIBS. In the little over three months that NIBS has been recruiting members, over 250 firms and individuals have joined. NIBS anticipates the Council will be selfsustaining through membership dues by the end of this coming fiscal year.

Under Title III of the Energy Conservation and Production Act of 1976, NIBS was given specific responsibilities to assist in the development and promulgation of energy conservation performance standards for new buildings. Last Spring, three surveys on the status of state legislative and regulatory enforcement efforts in the field of building energy conservation were completed. Last November, NIBS held an all-day briefing session on Department of Energy's advanced notice of proposed rulemaking for building energy performance standards to assist firms and individuals in understanding and commenting on the DOE proposal.

Finally, NIBS continues to pursue basic research in the area of building codes, standards, and regulations. Using funds appropriated specifically for NIBS, the Institute has undertaken three baseline studies. They involve creation of effective national systems for:

o The generation and maintenance of performance criteria, standards,
and codes;

o The evaluation and prequalification of existing and new building
technology for the benefit of producers, builders, and users; and

o The collection, storage, and dissemination of information dealing
with criteria standards and codes.

These studies, when completed, will provide an overview of the current state of
the art in each area and suggest basic options for achieving improvements.

Future and Direction

While many of NIBS current activities are timely and important, the National Chamber believes NIBS should not lose sight of its primary mission of bringing about a more rational and effective regulatory environment for housing and building.