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HomeMy WebLinkAboutCOM 0766.018 2008-2010Murashige, Laura Sat 234(Co 1..(L4 7(oca From: Sent: To: Subject: Council Members, 4/6/2010 Emily Naeole [enaeole @co.hawaii.hi.us] Monday, April 05, 2010 11:49 AM counciltestimony@co.hawaii.hi.us FW: Energy Conservation Code Attachments: Energy Code.rtf I am attaching a letter outlining some of these problems. Dennis Preston Davis, Architect Page 1 of 1 P/Co RED i. iVED 2010 RPR 6 1119 7 95 COUN' r CLERK COUNTY OF HAWAII From: Dennis Preston Davis [mailto:mangolay @gmail.com] Sent: Wednesday, March 31, 2010 11:38 AM To: dyagon @co.hawaii.hi.us; dikeda @co.hawaii.hi.us; jyoshimoto @co.hawaii.hi.us; donishi @co.hawaii.hi.us; enaeole @co.hawaii.hi.us; genriques @co.hawaii.hi.us; bford @co.hawaii.hi.us; kgreenwell @co.hawaii.hi.us; phoffman @co.hawaii.hi.us Subject: Energy Conservation Code I urge you to postpone the adoption of the Energy Conservation Code for 6 months. As an architect, I see several severe problems for new and remodeled housing with the code as it is now written. Costs will be increased greatly. Energy costs in most instances will not be reduced but will actually be increased. Comm. No. Ref. To : Ref. Date APR 0 7 2010 DENNIS PRESTON DAVIS ARCHITECT P.O. BOX 401, PAHOA, HI 96778 TELEPHONE (808) 217 -2508 March 31, 2010 Hawaii County Council Re: International Energy Conservation Code of the County of Hawaii I urge the Council to postpone the adoption of the above code for 6 months and to change those portions of the code that will have severe economic and counter productive effects on housing for our citizens. Problems with the code as adopted are: 1. The code lumps all of our eleven climate zones into one. In reality, there are considerable climatic variations from Volcano to Kona. 2. The intent of the code is to reduce energy usage in conditioning the interior spaces with either heating or cooling. In Hawaii County the vast majority of houses have no heating or cooling systems. The code would require extensive changes in building insulation and types of windows. There would be no reduction in the building's energy usage. However, the extra and superfluous requirements would require more energy to produce, being counter productive to the code's intent. 3. Section 101.5.2 as modified by the County code eliminates the clause that buildings "that do not contain conditioned space" shall be exempt from the building thermal envelope provisions of this code. If that clause had been retained the code as adopted would be more reasonable. It would address the problems outlined in 2 above. 4. As adopted, the code prevents an architect to intelligently adapt a house to local climate conditions. In areas like Waimea and Volcano where winter temperatures are cooler and rain and fog more common, we rely on winter heat gain from south facing windows to provide free heat. The code's requirements for fully shaded windows and for windows having high SHGC values (appropriate only in areas with hotter, sunnier climates) prevent desirable heat gain. Again, these requirements are counter productive causing a greater use of energy. 5. For an unconditioned house, the cost increases are considerable and completely unwarranted with absolutely no gain in reducing energy costs. The windows required to achieve an SHGC (solar heat gain coefficient) need to be either tinted or reflective single glazing or dual - glazed windows with low -e glass. In both cases, the required windows cost from 50% to 100% more that the typical windows used here. Further they reduce the amount of light entering and reduce solar heat gain where desired as discussed in 4 above. Tinted and/ or reflected glazing requires greater dependence on artificial lighting, increasing energy usage. 6. For most of our climate zones, the amount of roof insulation required is excessive. In unconditioned houses in our hottest zones, R -19 is more than sufficient to control solar heat gain. R -30 is excessive. In an unconditioned house with light colored exterior walls no exterior walls are necessary. With open windows the r value of the wall is irrelevant as the thermal envelop is broken. The energy code as now proposed would have severe impact on new housing, driving building costs unnecessarily up. For all new unconditioned houses, the code would save no energy whatsoever and would actually increase energy usage to order produce the unnecessary added material requirements. I urge you to postpone the passage of the code for 6 months in order to modify it to be more appropriate for our County. A far more effective means of saving energy would be to ban the sale of incandescent light bulbs, electric hot water heaters and space heaters. Dennis Preston Davis, Architect