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HomeMy WebLinkAboutCOM 0766.016 2008-2010International Energy Conserfation Code - Hawaii county Ordinaance 09 -48 Murashige, Laura From: Sent: To: John Parazette [j parazette@hawaiiantel.net] Thursday, April 01, 2010 5:16 PM Counciltestimony@co.hawaii.hi.us Subject: International Energy Conserfation Code - Hawaii county Ordinaance09 -48 Dear Councilmembers OAt. 234F_/coltU. l Page 1 of 1 P /Gouni Cn. i"ED 2010 APR 6 All 7 44 COUh t CLERK COUNTY i IF HAWAII As a professional architect, I support Councilmember Naeole - Beason's effort to extend the effective date of this ordinance to January 11, 2011. The international Energy Conservation Code (IECC) which is being amended here provides in Sect. 101.5.2, item 2, as in our current Hawaii Model Energy Code (HMEC), exemption from building envelope requirements for buildings without conditioned spaces; that is those that are not mechanically heated or cooled. Ordinance no. 09 48 removes that exception which means that all walls and roof of all structures must be insulated. There seems to be no recognition of the beneficial effects that natural ventilation can provide. The HMEC recognizes natural ventilation and exempts walls of structures that do not enclose space that is air conditioned from insulation requirements (P. 3 -10). There are descriptions within the HMEC of acceptable means of providing ventilation. Given the fact that we are usually building on sloping ground on the side of tall mountains, there is always air movement, even on the Lee side due to the diurnal wind patterns; up -slope during the day, down at night. Wall insulation should not be a general requirement; the un- amended IECC and the HMEC have that part right. By removing the exemption for unconditioned spaces, it appears that industrial buildings would likewise require wall insulation; is that intended? Shipping costs for insulation are a huge factor; this material is light and fluffy and is shipped at a cubage rate. Cost for insulating all exterior walls would be disproportionally higher than on mainland in areas where heating is common and it may really be needed. Provisions for controlling heat gain through the roof are certainly appropriate however roof color as a measure of solar absorptance doesn't appear to be as well addressed as in the HMEC. And while the addition of 402.1.1.1 offers more options for roof /ceiling systems, further study or editing may be indicated; item 6. on page 4 says "...a cool roof shall have an infrared emittance of no more than 0.75..." and then below states "A cool roof has (should have)...a high emittance... "which is correct; cool roofs are commonly between 0.80 and 0.90. 1 respectfully recommend that the effective date of Ordinance 09 -48 be extended as requested and would hope that further study and opportunity for study and input by local professionals might reduce the impact and looming costs of this measure. Respectfully submitted John Parazette Licensed Architect A 5225 4/6/2010 Comm. No " 1G(o•)(0 Ref. To: 211444(..i Ref. Date . APR 0 7 2010