HomeMy WebLinkAboutCOM 0766.011 2008-2010Murashige, Laura
For your information - letter sent via email 4/1/10
Dear Councilman Pete Hoffmann
tam_ _234 cowl M._766
From: Emily Naeole [enaeole @co.hawaii.hi.us]
Sent: Monday, April 05, 2010 11 48 AM
To: counciltestimony @co.hawaii hi.us
Subject: FW: Bill 234, Co. Energy Conservation Code
Page 1 of 2
PI COUN
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2010 APR 6 AM 7 95
COUP CLEEK
COUN1' i Hry PJI
From: KJ Long [mailto:kahukai1288 @yahoo.com]
Sent: Thursday, April 01, 2010 12:30 PM
To: dyagong @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
Subject: Bill 234, Co. Energy Conservation Code
I would like to respond to your comments made in the Tribune Herald article of 3/28/10 regarding the
new County Energy Conservation Code. I have studied both the Ordinance and the IECC in anticipation
of its implementation on May 11, 2010. As background information, during my carrier as a Fire
Protection Engineer, I have written and enforced numerous codes, standards, and ordinances in San
Francisco and for the State of California. After my review of this new Code I came to the conclusion
that the effective date had to be postponed in order that further evaluations and reviews could be made to
correct many omissions, errors, and oversights. The adopting Ordinance (09 -48) has many errors,
omissions, ambiguities, and will create compliance and enforcement nightmares. The new Energy
Conservation Code is extremely complex and technical for which few, if any; local professionals fully
understand and know how to implement this new code.
You mentioned that the Code was tailored to fit Hawaii's environment. This is not necessarily true. It is
believed that the Code addresses the climate zones of the Big Island, but in fact it does not. The IECC
stipulates that the State of Hawaii, including the Big Island is all in their zone 1. Even though the Big
Island has 13 different climate zones, it will be treated as a single zone for the Energy Code application.
You must admit that East Hawaii, West Hawaii, Volcano, Waimea, top of Mona Kea, all have much
different climate /temperature conditions. Yet they will all be treated the same. As a result the costal
areas, with its very temperate, humid conditions will have over restrictive regulations, while the colder
dryer higher elevation areas will have inadequate regulations. To meet the intent of the Code, this has to
be addressed.
Energy efficient construction will definitely cost extra money. Any time you add additional materials to
a construction project you are adding costs. Also, many of the materials and assemblies that will be •
needed are presently not readily available and special ordering may be required. The design costs will
escalate tremendously since an Engineer qualified in energy conservation calculations will have to do
extensive calculations and design review to comply with the new Code. There is also additional
administrative costs that will be incurred by the County in there need to review, approve and inspect all
of the new energy requirements. This cost to the County could be considerable.
The pay back is not immediate in that with the additional requirements there is no return on the
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investment, it is all cost outlay. The only way you can have a savings is through decreased energy use.
With residential construction that means the elimination,of HVAC systems which few or none presently
exist and will probably never exist. The vast majority of people are more than satisfied with the natural
cooling and heating and do not need to rely on air conditioning or heating systems. For the homeowner
you are not delaying any savings because as stated above there really isn't any savings, but only
additional expenses. Electric bills will not decrease because you are not eliminating or removing energy
using devices because they do not have them or plan to have them in the first place.
The present opposition has come about because the people who, are interested in, or will be responsible
for implementing the new Code, like me, have just now started to thoroughly study the new regulations.
As all do, just like kids with their homework, they all procrastinate to the very last minute. So it is only
now that the serious problems are coming to light. It is not a total opposition, but more a discovery that
the new Code, as written will not work, is overly complex and ambiguous. Because the effective date is
so close, there is no time to properly review and modify the ordinance to correct the problems. It also is
totally counter productive to allow the Ordinance to go into effect and then months later develop
revisions. The best solution is to just postpone the effective day to give time to make the necessary
corrections in a timely and efficient manor Then, when the code becomes effective it will be a viable
and useable Code that can be properly complied with and enforced. I appreciate the fact that a delay
may impact federal stimulus monies, but I am sure, under the circumstances something can be done to
address that issue. I think it is better to loose some funding than to regret after the fact, implementing a
code that just will not be properly complied with or properly enforced.
With all this in mind, I think it is very worthwhile that all Council members, including yourself, support
the new Ordinance modifying the effective date. I believe one of Council member Emily Naeole-
Beason's desires is to form a review committee made of local professionals and constituents to do a
thorough review to make sure it will be a Code that accomplishes the goal in a cost effective, reasonable
and technically correct manor that can be easily complied with and enforced. This last objective should
also be supported and the entire Council and they all should take part in formulating the review
committee.
Thank you for you considerations on this matter.
Kenneth J. Long
Puna Resident
Cc: All Council members
4/6/2010