Loading...
HomeMy WebLinkAboutCOM 0128.011 2010-2012PIcouNrg. Bill 270, Building Code, Stakeholders Questions, Comments, and Yxfkl. I2 .2 Recommendations Webmail rcel (rcel @isp.com) Wed 7/20/11 3:11 AM counciltestimony @co.hawaii.hi.us Aloha Council Members, The stakeholders are committed to work with the County Council, c r— N collectively and or individually, The Public Works Committee, The Public Works director and staff, and the inhabitants of Hawaii Is1 ,d r to create a common sense building code with clear and precise tU language, written for Hawaii Island, on Hawaii Island, that will provide for: an affordable building cost, an efficient building process - permit application to certificate of occupancy, design standards for a safe structure, and the lowest energy consumption possible. That is our criteria. Why adopt these codes ( these codes are expensive to buy and ship ) written on the mainland ( page 1, Section 5 -3. International Building Code, 2006 Edition adopted. (IBC), and page 80, Article 5. Adoption of the International Energy Conservation Code (IECC). and then try to amend them to apply to Hawaii Island? ( Zone 1 assigned to Hawaii Island is written for Miami, Florida. Be assured, the climate zone of Miami has nothing to do with the 13 climate zones on Hawaii Island. ) Page 1, Section 5 -3., (a) and page 2 (b), (c) and pages 21 - 40, Article 3 and page 40 Article 4 ARE ALL AMENDMENTS TO THE IBC. Why not write a Hawaii Island Building Code, on Hawaii Island, by the inhabitants of Hawaii Island, for the inhabitants of Hawaii Island? An overriding concern of the stakeholders' review was the additional cost for the building of affordable housing. We humbly request that before you vote on this Bill 270 that you and all Hawaii Island inhabitants know specifically by regulation and cumulatively what that cost will be. A cost analysis and cost benefit analysis must be done! The stakeholders have fast tracked a review of Bill 270 following the first reading on July 7, 2011, with numerous meetings and varied inputs. Our questions and comments follow and we thank you for the opportunity to bring this information to you. STAKEHOLDER QUESTIONS: 1. Why does Bill 270 not have an index? It made review difficult without an index so we created our own major topic index. The State of Hawaii "State Building Code" is very similar in length and content as Bill 270 and it has a 2 page complete index. The other adopted codes in the Bill also have complete indexes. This is a major / deficiency of Bill 270. COMM: NO. - "�' Ref. ToPrei% Co W+4: 2. Page 1, Section 5 -3. What is the bonafide demonstrated need toRef. Date wsdJUL 22C62"01144:'' 2011 adopt The International Building Code 2006 Edition ( IBC ) ? Single wall and frame homes originated on this Island with the arrival of the missionaries in the early 1800s. The Lyman house was built in 1839 and was one of the first wood frame structures built on the Island, and wood frame homes have been built on the Island to date. And this building was all done without the 1738 page, $179.00 plus shipping IBC, that was written with little or no knowledge of the needs of Hawaii Island. Another option rather than outright adoption of the IBC, is to adopt it with the language on page 4, Section 5 -12 (3), (5), ( "shall be deemed only guidelines and not mandatory" ). What regulations in this IBC code affect building costs and are they absolutely necessary? 3. Page 12, Section 5 -35. IMPACT FEES. WHY ARE IMPACT FEES IN BILL 270? We were astonished to find Impact Fees included in Bill 270. We understood that Impact Fees would be properly publicly vetted in Bill 304 to be heard at a future time and date. Section 5 -35. allows Impact Fees to be promulgated and imposed administratively without public input or County Counsel review. How much will the impact fee add to the building costs? Are you going to vote for Bill 270 not knowing how much it will increase the cost of housing on Hawaii Island? 4. Pages 46 -62, Appendix U, Hawaii Hurricane Sheltering Provisions for New Construction, and Appendix W, Hawaii Wind Design Provisions for New Constructions. This is a very troubling and building cost adding section of Bill 270. Is there any bonafide documentation that these Appendixes should apply to Hawaii Island? For known history, the past 150 years, no hurricane has struck this island, not one person has been injured by a hurricane, there has not been one fatal injury from a hurricane, and there has not been one cent of property damage from a hurricane. Furthermore the design standards for seismic design requirements may in fact provide a more wind resistant structure than the above Appendixes do. Seismic design standards do not include protection of openings but is there a bonafide demonstrated need for this? Design standards for seismic ( earthquake are justifiably included for a real, bonafide threat exists. What will be the increase of building costs for these two Appendixes? 5. Pages 80 -86, Article 5. Adoption of the International Energy Conservation Code. ( IECC ) Why are we adopting an energy code written in Chicago for Climate Zone 1, Miami, Florida and then devoting 7 pages to amending it? In that space or less we can write our own HIECC ( Hawaii Island Energy Conservation Code ) that would be specific to the 13 climate zones of Hawaii Island. Where specifically is the Non - conditioned building exemption? No matter how much you insulate and provide thermal windows to a non - conditioned building it will not provide one cent of energy saving, and in fact may make it less energy efficient, and make it a less desirable building to live in. That is because Non - conditioned buildings use no energy for HVAC, Heat, Ventilation, and /or Air Conditioning! If this is really about energy conservation, a prohibition of all HVAC in buildings on Hawaii Island would be the ultimate energy conservation. Importing oil - derived Owens- Corning fiberglass insulation to Hawaii Island is not energy efficient or sustainable, in fact it is an energy hog. And most of Hawaii Island inhabitants would not be affected because they do not have HVAC installed in their homes. What will be the increase in building costs if the IECC is adopted? STAKEHOLDER COMMENTS AND RECOMMENDATIONS: 1. Provide a cost analysis and a cost /benefit analysis specifically by regulation and cumulatively to document the increase of building cost Bill 270 will cause. 2. Provide a comprehensive index for Bill 270 fashioned after the State Building Code. 3. Page 1, Section 5 -3. International Building Code adopted. Do not adopt IBC. See question above. See alternative to outright adoption above. 4. Page 2, Section 5 -6. Existing structures. How does this section affect restoring our historic culture plantation single wall homes? 5. Page 8, Section 5 -22. Expiration. Delete 120 day permit expiration provision. In these tough economic times a family building a home may need more time. The three year time limit remains. 6. Page 8, Section 5 -25. Construction documents required. Add a provision; For all plans that meet Hawaii Island Design Standards ( RIDS ) an architect /engineer stamp is not required. For plans that do not meet RIDS the stamp is required. 7. Page 12, Section 5 -35. IMPACT FEES. DELETE this section. See discussion in stakeholder questions. 8. Page 13. section 5 -41. Inspection requests. Add; Inspection requests received by 3:00 pm will be inspected the next day. Between 3:OOpm and office closing office staff makes a inspection route for inspectors ) If no time for next day inspection permittee /requester will be notified inspection will be the next day. 9. Page 19. Section 5 -61. Criminal prosecution. Is this really necessary? When Section 5 -60, Administrative enforcement., and section. 5 -62 Injunctive action., are available. Where is the ALOHA? 10. Page 21 -41. Article 3. Installation Requirements. Sections 5- 71,77,78. Amendments to adopted International Building Code. These sections on pages 21 -41 can be deleted if IBC is not adopted. See discussion in Stakeholder Questions above. 11. Page 40. Section 5 -76. Amendments to Appendix C; Group U - Agricultural Buildings. C101.2. Horticulture buildings. Add; Nonresidential farm /ranch buildings are exempt from this code. Nonresidential farm /ranch building means any building that is used for agricultural purposes, is located on a farm /ranch and is not used as a residential dwelling, and is located on land that is an integral part of a farm /ranch operation and is classified as agricultural land. 12. Page 41 -43. Appendix L. Factory -Built Housing. Stakeholders did not review this Appendix since we did not know if was applicable. 13. Pages 46 -62. Appendix U, HAWAII HURRICANE SHELTERING PROVISIONS FOR NEW CONSTRUCTION, Appendix W, HAWAII WIND DESIGN PROVISIONS FOR NEW CONSTRUCTIONS, See discussion under Stakeholder questions. Until an analysis is done to document a bonafide need for these appendixes, both should be deleted. 14. Page 63. Appendix X. Indigenous Hawaiian Architecture Structures. This appendix seems to be well done. Especially pages 68 -79, Section X 401, Design Standards. Good references are listed on page 63, Section X 101.2. Publications incorporated by reference. 15. Add; Hawaii Island Design Standards for double wall and single wall R -3 building. 16. Add; Permittee shall be allowed to transfer building permit. We the stakeholders again thank the Hawaii Island County Council Members for giving us the opportunity to provide our review input on Bill 270, Building Code. If the County Council is receptive, the stakeholders working together with others, offer to present a proposal regarding the preparation of a Hawaii Island Building Code reflecting the criteria mentioned above, at the next scheduled County Council meeting, August 3, 2011.