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HomeMy WebLinkAboutCOM 0128.038 2010-2012PI CfluN Cu Webmail rcel <rce1 at isp.com> , , STAKEHOLDER COUNCIL TESTIMONY AND ATTACHMENTS, AUGUST 17, 2011, RECONSIDERATION Webmail rcel <rcel @isp.com> Tue, Aug 16, 2011 at 8:34 AM To: counciltestimony <counciltestimony @co. hawaii. hi. us> Cc: dyagong <dyagong @co.hawaii.hi.us >, apilago <apilago @co.hawaii.hi.us >, fblas <lblas@co.hawaii.hi.us >, bford <bford @co.hawaii.hi.us >, phoffmann <phoffmann @co.hawaii.hi.us >, dikeda <dikeda@co.hawaii.hi.us >, donishi <donishi @co. hawaii. hi. us> , bsmart <bsmart @co. hawaii. hi. us> , jyoshimoto <jyoshimoto @co. hawaii. hi. us> Bcc: margotemst <margoternst @hotmail.com> Aloha Hawaii County Council Members, The Bill 270 Stakeholders urge you to vote for reconsideration and to postpone approval of Bill 270, to allow us to work wi you and County Staff to improve Bill 270 and to promulgate an improved Building Code for Hawaii Island. We are submitting the following documents to clarify issues pertaining to Bill 270: 1. STAKEHOLDER REVIEW CRITERIA FOR BILL 270 2. Bill 270, Building Code, Stakeholders Questions, Comments, and Recommendations 3. HURRICANE QUESTIONS HAWAII ISLAND 4. HURRICANE INSURANCE HAWAII ISLAND 5. INTERNATIONAL CODE COUNCIL 6. INTERNATIONAL RESIDENTIAL CODE (IRC ) 7. PUBLIC WORKS ANSWERS TO STAKEHOLDER QUESTIONS The Bill 270 Stakeholders look forward to working with the County Council and Public Works staff to bring forward an improved Bill 270 that all inhabitants of Hawaii Island will support. Mahalo for supporting our efforts, Bob Ernst, Stakeholder Bill 270 Review Comm. No. 128.38 Ref. Toy Preseeked CouPtq l Ref. Dote AUG 1 7 2'011 Webmail rcel <rce1cisp.com> . STAKEHOLDER REVIEW CRITERIA FOR BILL 270 Webmail rcel <rce1 @isp.com> To: counciltestimony ©co.hawaii.hi.us Bcc: margotemst <margotemst ©hotmail.com> Aloha Hawaii County Council Members, The stakeholders are currently reviewing Bill 270, Building. Our review is based on the following criteria. Are there any other criteria that you wish us to consider? REVIEW CRITERIA BILL 270 Does the addition /deletion /change affect: 1. The building cost - higher /lower /same. 2. The building process - permit application to certificate of occupancy. 3. The safety of the structure. 4. The energy consumption of the completed project. We will have our review completed by the July 22, 2011 second reading and will present our comments at that time. Mahlo, Bob Ernst 968 -8611 Wed, Jul 13, 2011 at 11:19 AM 1 • Bill 270, Building Code, Stakeholders Questions, Comments, and 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, collectively and or individually, The Public Works Committee, The Public Works director and staff, and the inhabitants of Hawaii Island, to create a common sense building code with clear and precise 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. 2. Page 1, Section 5 -3. What is the bonafide demonstrated need to 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? 2b 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 HIDS ) an architect /engineer stamp is not required. For plans that do not meet HIDS 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. i:.i00.1ra HURRICANE QUESTIONS HAWAII ISLAND Webmail rcel <rce1 @isp.com> Webmail rcel <rcel @isp.com> To: w- hfo.webmaster @noaa.gov Cc: repherkes <repherkes ©capitol.hawaii.gov>, dyagong <dyagong ©co.hawaii.hi.us> Bcc: margotemst <margotemst ©hotmail.com> Aloha Central Pacific Hurricane Center, The Hawaii Island County Council is currently promulgating a building code. Of course hurricane exposure is a component of that building code. Historical research of past hurricanes shows that Hawaii Island has had little or no hurricane wind exposure. Has any scientific research been completed on the reason(s) Hawaii Island has been hurricane wind immune? Has any research been completed on the affect of the 14000 foot mountains and the lesser mountains on Hawaii island as to their affect on hurricane winds and hurricane formation and the mountain contribution to the hurricane immunity of Hawaii Island? Hurricane experience in the Carribean and Southeast mainland U.S. demonstrates the destructive impacts to hurricane formations by the small hills that exist on the islands of Hispaniola, Puerto Rico and Cuba etc. and the hills of Georgia and the Carolinas etc. Is there any other place in the world hurricane vulnerable zone where mountains of this magnitude as are on Hawaii Island exist and if there is has the affect of these mountains on hurricane winds been studied? Mahalo, Bob Ernst, Stakeholder Bill 270 Review 1- 808 -968 -8611 Thu, Aug 4, 2011 at 8:59 PM 3 I►l►^' cxrn Webmail rcel <rcel @isp.com> HURRICANE INSURANCE HAWAII ISLAND Webmail rcel <rcel@isp.com> To: insurance @dcca.hawaii.gov Cc: repherkes <repherkes @capitol.hawaii.gov>, dyagong <dyagong@co.hawaii.hi.us> Bcc: margotemst <margoternst @hotmail.com> Aloha Insurance Commissioner Ito, I have the following questions regarding hurricane insurance on Hawaii island: 1. In your annual reports are the premiums and claims paid for hurricane insurance on Hawaii Island listed? If not, is this information available from your office? If not, where may this information be obtained? 2. What is the actuarial basis for establishing the rates for hurricane insurance on Hawaii Island? What exposure history is used to establish those rates? Presently the Hawaii Island County Council is promulgating a Building Code. This information would be very helpful guidance in establishing that code. Mahalo, Bob Ernst, Stakeholder Bill 270 Review 1- 808 - 968 -8611 Thu, Aug 4, 2011 at 8:54 PM v Click here for PAO S ibscrnptior1s • Selections o International • International Building Code • International Residential Code for One - and Two - Family Dwellings • International Existing Building Code • International Fire Code • International Plumbing Code • International Mechanical Code • International. 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For technical support using this product, please call International Code Council® at 888 - 422 -7233 ext 33822. COPYRIGHT 2007 by INTERNATIONAL CODE COUNCIL NOTE: The International Codes are designed for adoption by state or local governments by reference only. Jurisdictions adopting them may make necessary additions, deletions and amendments in their adopting document. Incorporation of any part of the International Codes in codes published by states, local governments, regulatory agencies, individuals or organizations is expressly prohibited. ALL RIGHTS RESERVED. The International Codes® are a copyrighted work owned by the International Code Council, Inc. Without advance written permission from the copyright owner, no part of this book may be reproduced, distributed, or transmitted in any form or by any means, including, without limitation, electronic, optical or mechanical means (by way of example and not limitation, photocopying, or recording by or in an t� NOTICE OF PUBLIC HEARINGS STATE BUILDING CODE COUNCIL STATE OF HAWAII ON PROPOSED HAWAII ADMINISTRATIVE RULES TITLE 3, CHAPTER 185 Pursuant to the provisions of Chapters 91 and 107, Hawaii Revised Statutes (HRS), notice is hereby given that the State Building Code Council will hold a public hearing on August 5, 201 1, at 9 :00 a.m. at the following locations. Island Date and Time Location Oahu August 5, 2011 Keoni Ana Building Videoconference Center 9 :00 a.m. Keoni Ana Building 1177 Alakea Street, Room 302 Honolulu, Hawaii 96813 Hawaii August 5, 2011 Hilo Videoconference Center 9:00 a.m. Hilo State Office Building 75 Aupuni Street, Basement Hilo Hawaii 96720 Maui Kauai August 5, 2011 9:00 a.m. August 5, 2011 9:00 a.m. Wailuku Videoconference Center Wailuku Judiciary Building 2145 Main Street, First Floor Wailuku, Hawaii 96793 Lihue Videoconference Center Lihue State Office Building 3060 Eiwa Street, Basement Lihue, Hawaii 96766 The State Building Code Council will receive testimony on a proposed Title 3, chapter 3 -185, Hawaii Administrative Rules. The proposed chapter is intended to implement a State Residential Code as required by the "State Building Code and Design Standards," Chapter 107, Part II, HRS, to establish a statewide building code that is applicable to all construction in the State of Hawaii and based on nationally published codes or standards, to promote uniformity and consistency across the state, to improve the public's health and safety, efficiency in its application by design professionals, developers, and construction entities. The proposed chapter is based on the 2006 International Residential Code. Proposed amendments to the 2006 International Residential Code are made to address the specific geography, statutory requirements (such as hurricane resistant shelter criteria), and cultural aspects of the State of Hawaii. 6 Page 2 of.7 I am writing this letter in regards to Bill 270, and to request that you consider postponing a vote on the Bill for at least a month so that Stakeholders in Hawaii County affected by this Bill can work with Public Works and craft a Building code that takes into account the unique nature of our Island. Below please find the letter as written by my fellow Stakeholder group that has met and discussed in detail the proposed Bill. From my perspective they raise many valid points that should be considered, but my first and foremost issue is "what is the cost "? We live on an Island which is and will continue to suffer due to the economic chaos throughout the world. We have another Bill that is proposing Impact Fee that is and will be considered by the Council, and in this Bill we find that there are further impact fees proposed. "What is the cost ?" Hurricane safe rooms and insulation. Are these really necessary? We have a variety of climate zones on this Island and while some areas would need insulation, other areas may not, but to include in the code that they are necessary can only raise the cost to build. "What is that cost ?" Finally, as an aggregate there have been many Bills that are coming forward this session which raises the cost of doing business and living on this Island (i.e. Plastic Bag ban, Impact Fees, etc.). While they all arguably have their own merits and sound reasoning for moving forward, I humbly ask that the Council consider as a whole the decisions being made today which affect the affordability of living and working on our Island home. Adopting a Building Code which raises the cost of building and then includes impact fees on top of that cost directly affects that affordability. Thank you for your time and consideration, as mentioned, below is the letter submitted by a group of Stakeholders that have been working on coming up with both question, concerns and suggestion for change in the current code. Sincerely, Caleb Yamanaka (R), BIC Yamanaka Enterprises Inc. The stakeholders are committed to work with the County Council, collectively and or Individually, The Public Works Committee, The Public Works director and staff, and the inhabitants of Hawaii Island, to create a common sense building code with clear and precise 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 8/4/2011 • Page 3 of 7 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. Since the Index has been created by the Stakeholder, we would appreciate a copy to share with others 2. Page 1, Section 5 -3, What is the bonafide demonstrated need to 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? As you know, this code was required to be adopted by the State Code Council for consistency throughout the state. The code is updated every three years to reflect improvements in construction means and methods based on our continued understanding of improved heath and safety in It's application. Many items of the new building code are LESS stringent than previously used such as fire protection between a dwelling and a garage. To anticipate the change of cost to a construction project would depend on many factors and, in some cases, could be less than under the current code (note garage separation changes above). The current building code, the 1991 UBC was adopted in November 1996 - 5 years after it's publication. Prior to that the 1982 UBC was adopted in January of 1985. Changes to the codes since 1991 reflect better understanding of fire safety, earthquake, and high wind provisions based Kobe earthquake of 1989, Hurricane Eva, lniki, Katrina, and the Mexico City Earthquakes of 1985, and 1991. 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? 8/4/2011 ib Page 4 of 7 Bill 270 is not tied to IMPACT FEES and should not be confused with building codes that provide greater Public safety and standards for construction. 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? The 2006 IBC places Hawaii County in a "high wind debris" region. The standards for protection for debris are much less than a Hurricane might impose and use a "missile" test which requires that building exteriors be able to withstand a 24" long 2x4 moving at approximately 30 miles per hour. A hurricane may not strike the island directly but could cause considerable damage and threaten lives. Seismic design and wind design are both required to be reviewed for all structures and the more stringent will apply - not both. Protection of openings as defined by ASCE 7 -05 is specific and, in normal cases, will not be required. 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? Most Commercial buildings are already designed to meet these standards and the costs will not change because the newer version of the IECC. Residences without air conditioning are exempt from this provision. 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. Without a specific example of a structure, this is impossible. For example, what is the value of one life? 8/4/2011 / 2. Page 5 of :7 2. Provide a comprehensive index for Bill 270 fashioned after the State Building Code. My understanding is that the Stakeholder group has done this. Most professionals modify their building Code to reflect where the changes have been made by amendment and refer to those sections. The amendments are not the entire code and an index to the building code is included. 3. Page 1, Section 5 -3. International Building Code adopted. Do not adopt IBC. See question above. See alternative to outright adoption above. Now is the time to update our codes. To adopt portions is beyond the resources the department can devote to modifying the code to meet special interests. 4. Page 2, Section 5 -6. Existing structures. How does this section affect restoring our historic culture plantation single wall homes? Architects and Engineers will be able to design single family home as have been done in the past. It will be their responsibility to ensure that the structure meets the performance requirements of the code. 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. It is not unreasonable to begin construction within three months following the issuance of the building permit. A written letter requesting and extension of that time can be considered by the director. 6. Page 8, Section 5-25. Construction documents required. Add a provision; For all plans that meet Hawaii Island Design Standards ( HIDS) an architect/engineer stamp is not required. For plans that do not meet HIDS the stamp is required. The code recognizes the design standards of the SBCCI and AF&PA. State Law allows dwellings to be designed and constructed without an architect or engineer review within stated limits of construction costs. Please provide a copy of the HIDS as a Google search yielded no results. 7. Page 12, Section 5 -35. IMPACT FEES. DELETE this section. See discussion in stakeholder questions. Not applicable to Bill 270 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. Inspectors' set schedules every morning before 9 :00 am and are out in the field doing inspections the balance of the day. The proposed 48 hour rule is more reasonable and practical as proposed. 9. Page 19. Section 5-61. Criminal prosecution. Is this really 8/4/2011 Page 6 of :7 necessary? When Section 5 -60, Administrative enforcement., and section. 5 -62 Injunctive action., are available. Where is the ALOHA? This was originally proposed as a criminal matter but now as a misdemeanor. I defer to the Deputy Director for his expertise in this are of distinction between the two. Generally, work without a permit is against the law. To what degree is left to the interpretation of the inspector and willingness of the violator to cooperate. We generally do not take a hard -line approach over innocent mistakes. 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. A great deal of Article 3 is to preserve the current status quo of residential construction. Much has been lifted directly from the 1991 UBC until a version of the International Residential Code is adopted by the State and reviewed for amendments for Hawaii County. This because the IBC is intended to be supplemented with a residential code or, as done in the proposed amendments, provisions for R -3 construction. 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. Any building that is used for agricultural purposes clearly includes the above and the code allows construction of "unlimited" area for one -story buildings of this type. Exempting building from the code does not take in consideration the need for safe travel distance to exits; separation from other uses or buildings, or storage of hazardous materials that, when combined, could become letal. 12. Page 41 -43. Appendix L. Factory-Built Housing. Stakeholders did not review this Appendix since we did not know if was applicable. Factory built houses are one way of reducing costs. Inspections happen periodically but allow entire homes to be constructed off -site without addtional inspections until complete. 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. This is a State Code that are required to adopt. Hurricane shelters are an option for construction in as much as the choice of fireplace in the home. How the building is designed will dictated whether it is considered "Open", "Enclosed'; or "Partially Enclosed" based on ASCE7 or the exceptions noted (South Code Council International Standard SS10 or American Forest and Paper Association "Wood Frame Construction Manual ". 8/4/2011 Page 7 of 7 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. Note that under the proposed amendments, one accessory building to be used for "non- residential" use will be allowed up to 120 square feet and not more than 12' high. Indigenous Hawaiian structures may also be built, following the traditional methods outlined, with a permit. 15. Add; Hawaii Island Design Standards for double wall and single wall R -3 building. Please provide a copy of the "Hawaii Island Design Standards" to be considered. This would need to be vetted and approved by the Council as an alternative to the construction standards allowed by the code above. 16. Add; Permittee shall be allowed to transfer building permit. This has already been changed based on public testimony. Caleb Yamanaka (R), BIC Yamanaka Enterprises Inc. 1266 Kamehameha Ave. Hilo, HI96720 (808) 935 -9766 office [808) 969 -1783 fax (808) 938 -2926 cell 8/4/2011 11-V-