HomeMy WebLinkAboutCOM 0281.077 2020-2022 /. BUILD BETTER. LIVE BETTER. C i
�i c { " August 3,2021
Dear Council Chair David, Ld,EL l 1{ ;G — r a : °°'
I would like to submit this letter and testimony in support of Bill 44 relating to the County Construction
Code. I would further like to request Bill 44 be passed without any further amendment to the sections and
appendices of the code and in particular,as it pertains to Factory-Built Housing.
As you are aware,our community continues to struggle with a housing shortage and crisis. Barriers or
obstacles that prevent the development and construction of much needed attainable housing must be addressed.
As noted in multiple reports,Hawaii Island will need an additional 13,300 plus housing units by 2025. This figure
translates to the completion and opening of roughly seven(7)new housing units each and every day over a five-
year period. Given the diversity of our population to include household income levels,the options and solutions
need to be equally diverse.
Bill 44 as drafted,and in conjunction with the exiting County Code framework will provide for the proper
regulation,oversight,and processes to support the construction of safe code-compliant housing. Further,the
adoption of the 2018 State Building Code will provide stability with regards to those same processes and standards
used by our design community and the construction industry to facilitate effective home construction for the next
few years and through the migration to a future,yet to be adopted code.
In addition to my support of Bill 44, I would like to express my reservations and opposition of the
proposed amendment as contained in Communication 281.20. This amendment intendeds to establish additional
and unnecessary inspections of Factory Built Housing products that will result in costs and construction delays that
directly impact the consumer or prospective homeowner. Although I can understand the perception that
transporting a structure may present with structural compromise or damage that could result in hazardous
conditions such as a fire potential,there is no evidence to support such assertions. In fact,evidence collected
through the research of various safety data and direct contact with a number of regulatory agencies and subject
matter resources to include the International Code Council, National Fire Protection Association,and various state
agencies show that the transporting of Factory Built Housing has not presented with any elevated or increased risk.
The data and analysis also show that Factory Built Housing(FBH)has demonstrated to be stronger and more
resilient than site-built structures due the inherent nature of its designs and methods of assembly. Therefore,to
impose additional inspections without justification or need and based purely on a perception would only create
barriers and impediments to an effective housing solution and option with those impacts passed along to the
consumer. Please consider that FBH is a proven industry and product that has been widely accepted across the
continental United States for nearly 100 years. Given this significant span of time and the documented track
record of FBH, if such risks and hazardous conditions were present and documented,the studies,data,and code
development would reflect that. Simply stated,those perceived risks and hazards are unsubstantiated.
In closing,I would like to thank you for the opportunity to provide testimony in support of Bill 44 and
strongly encourage passing it without amendment. I would also like to respectfully oppose the proposed
amendments as outlined in Communication 281.20 as that amendment would establish unnecessary and
redundant inspections in the field and special inspections that would adversely impact the efficiencies and
effectiveness of Factory Built Housing as a viable solution and option for attainable housing for our community.
Now is the time to explore all safe and quality housing solutions and not limit the options for our families and
friends.
Sincerely,
/fi
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HPM :
BUILDING SUPPLY NJ
D arryl Oliveira
Director of Risk Management PHONE 808 966 5466•FAX 808 966 7564 ti
16-166 MELEKAHIWA STREET•KEA'AU,HI 96749 , r
HPM Building Supply
HPMHAWAII COM •
Comm. No
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Ref. Date AUG — 4 2021