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HomeMy WebLinkAboutCOM 0876.006 2008-2010 P/Cowsvcn. . _ Shaun Roth PO Box 624 Holualoa, Hawaii 96725 Jji3 SEP 7 Pig 1 ? `_ 808- 324 -6073 shaunroth @alum.mit.edu September 7, 2010 Hawaii County Council 25 Aupuni Street Hilo, Hawai'i 96720 Re: Bill 270 Dear Council Members; 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. This testimony is my own personal opinion and does not necessarily reflect the position of either of these groups. I am in support of Bill 270 draft 2, adoption of the 2006 International Building Code (IBC), as submitted by Director Warren Lee in Communication 876.004 which includes 2006 IECC language identical to ordinances 09 -48 and 10 -68. I am adamantly opposed to amendments proposed in Communication 876.002; Changing from the 2006 IECC to the 2009 IECC. Bill 270 is not the proper time nor place to attempt to adopt the 2009 IECC. The International Building Code (IBC) amendments as presented in Bill 270 have undergone a thorough process of review and are relatively consistent with the State code. The IBC adoption timeline has allowed design processionals and building officials plenty of time for training. The same cannot be said for the 2009 IECC. These are my top 10 reasons why the 2009 IECC should not be adopted in Hawaii County at this time. 1. State amendments to the 2009 IECC are not yet complete. Hawaii County should wait until the State version is complete. Let them work out the major problems for us. 2. There is no reason to rush. ARRA funding has been raised as an issue in past Council meetings as justification for rapid code adoption, however, ARRA guidelines do not require compliance until 2017. Take a look at your calendars, it is still 2010. I have spoken with many Federal and State officials and not one could say that ARRA funding would be cut off if the 2009 IECC is not passed by this County this year. 3. The ARRA guidelines require 2009 IECC or BETTER by 2017. The amendments presented in Communication 876.002 make the adoption LESS strict than the unamended 2009 IECC, potentially jeopardizing compliance with the guidelines. Don't rush, get it right the first time. 4. Training is required for any code to be properly implemented. The County has had time to train their personnel in the 2006 IECC and the professional community has been given sufficient time to prepare for the 2006 IECC. I don't believe that there has been time for any 2009 IECC training. Come %. (70 ps No, Ref. To :r i Ref. Date 5EP n 9 1018 5. As of 8/25/2010 only 12 States out of 50 have adopted the 2009 IECC. Why4 It has a potentially devastating effect on many industries. Windows and steel framing in particular. I believe that this is why it it taking so long for the State Code Committee to agree on language. 6. Walk before running. The County needs to work with the 2006 IECC, see what works and doesn't work, get peopled educated and accustomed to the new format, then move on towards the 2009 IECC. 7. The 2009 IECC as presented in Communication 876.002 has not been vetted and discussed in the design and construction communities. 8. There has been no readily apparent public notice of the intention to change to the 2009 IECC. Only people who spend their spare time reading County Council Communications would know that this is coming. Remember the backlash that the Council got for rushing the 2006 IECC? An under the table, unreviewed 2009 IECC is going to be worse. 9. There is plenty of economic uncertainty in this County right now. Proposing to adopt the 2009 IECC now greatly increases the amount of uncertainty. Adopting the 2009 IECC now is an anti - jobs position. 10.The 2009 IECC is NOT being proposed by the Department of Public Works. Their version of Bill 270 includes the 2006 IECC. Communication 876.002 looks like Kauai's amendments. It includes language that does not work well with the remainder of Chapter 5 as proposed for Hawaii County. Please do NOT approve Communication 876.002 (2009 IECC). Please approve Communication 876.004, Bill 270 draft 2, with the 2006 IECC. Thank you. Shaun Roth, AIA