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HomeMy WebLinkAboutCOM 0766.019 2008-2010Yoshimoto, J From: Shaun Roth [shaunroth @alum.mit.edu] Sent: Monday, March 29, 2010 12:54 PM To: Dominic Yagong; Donald Ikeda; J Yoshimoto; Dennis Onishi; Emily Naeole - e son; Guy Enriques; Brenda Ford; Kelly Greenwell; Pete Hoffmann o Subject: Hawaii County IECC C) to on 7J Attachments: Bill385- testemony.pdf z r0 cre d Bill testemany.pdf (52 6 Dear County of Hawaii Council members; e rn Z rn c0 f---' CO This email is in response to Councilmember Naeole - Beason's request for input regarding Hawaii County's implementation of the IECC. Ordinance 09 -48, Bill No. 385 (Draft.2) amended section 101.5.2 of the IECC so that it would no longer exempt "2. Those that do not contain conditioned space." If a building will not have heating or air conditioning equipment then there will be NO direct economic payback to offset the cost of added insulation, high performance windows, radiant barriers, etc. The structures will likely be more comfortable, but there will be no change in the amount of energy used. The County should simply reinsert the standard IECC exemption language back into section 101.5.2 and you will have much happier constituents with no increase in energy use. (In fact, there will be less energy used in some home construction because they will be using less and simpler materials.) In February 2009 I submitted testimony to the Council which included concern about the inclusion of unconditioned spaces in the thermal envelope requirements. A copy of this testimony is attached. I have also voiced these concerns to those involved with the Code at the State level. Many of the power brokers seem to think that the entire state looks like the Ewa plain or Waikoloa and not the diverse microclimates and elevations that we actually inhabit. Aloha, Shaun Roth, AIA 1 Comm. No. 1 C Ref. To: Ref, Date . APR 0 7 2010 February 18, 2009 Hawaii County Council 25 Aupuni Street Hilo, Hawai'i 96720 RECE I ED 2010 APR 6 AR 8 18 GOVAN `"r OLE1-u{ COUN1'r t f HAWAII Thank you for this opportunity to testify regarding Bill 385. Shaun Roth PO Box 624 Holualoa, Hawai'i 96725 808 - 324 -6073 shaunroth @alum.mit.edu Re: Bill 385 Dear Council Member; At the February 17 hearing regarding Bill 385 I did not read quickly enough to get through my full testimony. My apologies for being slow and /or long winded. Following is the full text. My name is Shaun Roth, I am a registered Architect in the State of Hawaii, a member of the American Institute of Architects, and a member of the International Code Council. My testimony today is my own personal opinion and does not necessarily reflect the position of any of these groups. I am in support of the adoption of the International Energy Conservation Code, IECC, with proper amendments. I think there is strong consensus in the design and construction community that buildings should be made more efficiently. As the saying goes though, the devil is in the details. I have three areas of concern with current language of Bill 385; The process of adopting the code, Certifications and Inspections, and Unconditioned Buildings. To be successful this code needs to be adopted in a way that is clear to all stakeholders and does not add uncertainty to the process of designing and constructing buildings. In its current form Bill 385 adopts the IECC with the only amendment being the provision for indigenous architecture. The State Building Code Council is currently working on a lengthy list of proposed amendments to the IECC to be adopted by the State. I have seen recommendations for amendments by the National Renewable Energy Laboratory. An article in West Hawaii Today implied that Bill 385 was to be adopted as -is and then State amendments would be added later. This would be a disaster. Transitioning from one code to another requires an extensive amount of education of designers, code officials, and builders. The County is already in this process for the IBC, transition from the '91 Uniform Building Code to the '06 International Building Code. To choose to do it twice for the IECC would be irresponsible. These codes are very technical, the change of one word or number can have far reaching implications. Each change needs to be thoroughly vetted before adoption. Do it correctly and only one time. Page 1 of 2 My comments on the next two topics are based in part on December 2008 draft amendments being considered by the State Building Code Council. This is not an official document but I think that this committee should be aware of the implications of some the proposed amendments. Compliance: Certification and Inspections: The Hawaii County Energy Code currently requires that a design professional certify the design. A proposed State amendment would require that a design professionafcertify the "Project ". "Project" is not defined and could be taken to include the final construction not just the design. In this same draft the entire Inspections section was deleted from the IECC. Design professionals will be opposed to any legislation that potentially transfers so much responsibility and thus liability from government to design professionals. The un- amended IECC requires inspections by code officials. As a design professional I think this is a good thing. However, this is potentially an administrative mess for the building officials and contractors. For this Bill to be successful and effective, compliance measures need to work for all stakeholders and be compatible with the existing legal frameworks. Unconditioned Buildings: Hawaii County Code currently exempts R -3 buildings without air conditioning from the energy code. The un- amended IECC still exempts the thermal envelope of unconditioned R -3 buildings, and the interior lighting. Proposed State amendments would bring all R -3 buildings into the code. This would bring a dramatic increase in the number of projects that will require certifications and inspections. It will add to the complexity of administering the code. The code official could grant variances, but too much of this would add uncertainty and subjectivity to a process that should be clear and objective. If an amendment such as this were to be included, the County would need to raise fees and /or provide substantial additional funds to administer the added scope of the code. In conclusion; If implemented properly Bill 385 should receive broad support; if it is rushed, or if un- vetted amendments are added, then it will be strongly opposed. Please bring International Code Council consultants to the island to conduct a series of seminars for code officials, designers, and contractors on the IECC, similar to what has been done for the International Building Code. Then proceed with amendments and hearings for Bill 385. Thank you. Shaun Roth Page 2 of 2