HomeMy WebLinkAboutCOM 0281.085 2020-2022 cin
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Testimony of
Pacific Resource Partnership
County of Hawaii
County Council
Hawaii County Building
Council Member Maile Medeiros David, Chair
Council Member Aaron S.Y. Chung,Vice Chair
Bill 44—Relating To The County Construction Code
Wednesday,August 18, 2021
Aloha Chair David,Vice Chair Chung and Members of the Council:
PRP writes in strong support of Council Member Villegas' proposed amendments in communications
281.19, 281.20, 281.50, 281.51 and 281.52.
Communication No.281.19
The proposed amendment removes this subpart referring to "manufacturer's label" because it has
nothing to do with the pre-approval process.The label is to be affixed to the FBH structure as prescribed
in Appendix U, relating to FBH.
Communication No.281.20
Proposed amendments under 58-3-22 relating to 0101.7 in Communication No. 281.20 will create a level
playing field for all homebuilders and ensure the homes are safe for the people who live in them.
Conventional homes are inspected on-site before people move into the home to ensure the safety of the
homeowner or renter. Factory-built housing should also be required to have an on-site inspection for the
same reasons, especially since factory-built structures and components can shift during transportation,
via boat or truck, when transported from the factory to the site. On-site inspections will allow the county
and homeowner to identify problems early on to give the manufacturer of the home an opportunity to
make repairs before individuals and families move into the home.This will ensure that homeowners are
not left with a dangerous and defective home requiring them to make costly repairs, especially when they
cannot afford it.
Communication No.281.50
Council Member Villegas' proposed amendments appropriately delete language that is confusing,
unnecessary, and not aligned with the definitions of"Building" in the model building codes.
The definition of"Building" under the 2018 International Residential Code(IRC), 2018 International
Building Code, and the 2018 International Existing Building Code does not include any language referring
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to structures on wheels. Moreover,the City and County of Honolulu's definition of"Building" in the
residential building code does not include this language.
1. 2018 IRC defines"Building" as any one-or two-family dwelling or portion thereof, including
townhouses, used or intended to be used for human habitation,for living,sleeping,cooking or
eating purposes,or any combination thereof, or any accessory structure.
2. 2018 IEBC defines"Building" as any structure utilized or intended for supporting or sheltering
occupancy.
3. 2018 IBC defined "Building" as any structure utilized or intended for supporting or sheltering any
occupancy.
4. City and County of Honolulu's definition of"Building"adopts the 2012 IRC definition: "Building
shall mean one-or two-family dwelling or portion thereof, including townhouses, used or
intended to be used for human habitation,for living, sleeping, cooking or eating purposes, or any
combination thereof, and shall include accessory structures thereto."
Communication No.281.51
Council Member Villegas' proposed amendments ensure that appendices are a part of the residential
building code, not"this code". The term "this code" includes more than the residential building code, it
also includes the"construction administrative code." Since Bill 44 is adopting appendices as a part of the
residential building code,then the language in the bill should explicitly say this to avoid confusion.
Communication No. 281.52
This new proposed amendment will ensure that Bill 44 does not include a loophole that would allow tiny
houses built within the factory to bypass the permitting and inspection processes required in Appendix U
for factory-built housing.All homes built within the factory should be permitted and inspected within the
factory and at the site to ensure the safety of its occupants.
Given the above,we respectfully request your favorable decision on these proposed amendments.Thank
you for this opportunity to provide written comments.