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COUNTY OF WAI'I
Maile David,Chair tt%4 �
CEI D August 18,2021
Tim. RE
Hawaii County Council —L
Dear Council Chair David, Date AUG1 t 2021
1 would like to submit this testimony in support of Bill 44 Draft 2 relating to the County Construction Code
and my opposition of all amendments aimed at further regulating and restricting Factory Built Housing.
Bill 44 Draft 2 will provide for the adoption of the most current State Building Code and establish much
desired and needed stability and longevity of appropriate design and building standards for safe construction in
our community. Further, Bill 44 Draft 2 will establish Chapters 5B(Residential Building Code)and SC(Existing
Building Code)and support the seamless incorporation of the State Building Code into the County Code
framework.
Factory Built Housing(FBH)has been a longstanding industry and a proven safe housing solution across
the continental United States and parts of the world for the past century. Given its demonstrated value,cost
effectiveness,and proven safety record, FBH provides consumers with additional options for fundamental shelter
needs.Evidence and data of product performance,safety,and resiliency have been collected and published in
multiple studies and analysis. Communication 281.20 proposes to require additional"on-site"inspections that are
not based on any evidence of demonstrated compromise of structural or occupant safety. Assertions that the
transportation and movement of factory-built structures results in deformation and compromise of structural
elements and utility systems that would present with hazardous conditions are unfounded and would prohibit FBH
as a viable housing option through unnecessary over-regulation. Requiring redundant unjustified on-site framing,
insulation, electrical and plumbing rough-in inspections would eliminate factory build efficiencies that benefit the
consumer. In addition,the redundant on-site inspections would result in a burden and impact to the County of
Hawaii Building Division by requiring inspectors to reinspect construction that they had previously inspected and
approved, Once again,with no evidence to support any need for such redundant inspections.
On August 4,2021,verbal testimony was provided to the Council by a member of the design professional
community and included his personal experiences with factory built housing products shipped to Hawaii. In his
testimony he alluded to damages to the wall panels during shipping. After that hearing I made personal contact
with the testifier and confirmed that the type of product he had referenced consisted of panels or pieces shipped
in a shipping container for assembly on the installation site. I also confirmed that those products were not
comparable to the concept of a fully assembled structure transported intact. Further in review of written
testimony submitted that referenced a recent installation of two"shipping containers"as factory-built housing, I
would again stress this not a comparable product and even question whether it was permitted and inspected.
Both of these referenced testimonies clearly illustrate that there are many interpretations of factory-built housing
and reinforce the need to establish adequate safety controls for products imported into our community. Products
that are constructed locally are well regulated by the County of Hawaii and currently subjected to the appropriate
type and nature of inspections that ensure the safety of all occupants and our community.
I strongly encourage the passage of Bill 44 Draft 2 without amendments. All amendments that have been
drafted to further regulate and restrict Factory Built Housing should not be considered as there is no demonstrated
need or evidence to support those regulations. As previously cited as an example,one proposed amendment
would require 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 or
irresponsibly overregulate the options for our families and friends.
Xa
HPMBUILDING SUPPLY
eira
Director of Risk Management PHONE 808 966 5466 a FAX 808 966 7564
HPM Building Supply 6-166 MELEKAHIWA STREET m KEAM,HI 967A9
HPMHAWAII COM
Comm. F40. 1
Ref, To: (,, XAVVI/
ef, hate AUG 1 8 2021