HomeMy WebLinkAboutCOM 0989.001 2018-2020hty OF JV
From the office of- gyp• Office: (808)961-8396
Council Member r Fax: (808)961-8912
District 3 Email• sue.leeloy@hawaiicounty.gov
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SUSAN L.K. LEE LJ Y
25 Aupuni Street,Hilo,Hawaii 96720
MEMORANDUM
a,. y
DATE: June 25, 2020 F
TO: Aaron S.Y. Chung, Council Chair
and Members of the Hawaii unty Councila
FROM: Sue Lee Loy, Council e r
SUBJECT: Bill No. 179: Public co en ceived and answered
Prior to submittal to the Council, an early version of Bill No. 179 was released to the public on
May 29, 2020, with instructions to provide written comments to the Building Division by June 5,
2020.
The Building Division replied to numerous comments, questions, and suggestions received
during this period, and categorized the comments as follows:
Proposed Chapter 5 (Construction Administrative Code) — 111 comments
Proposed Chapter 5A (Building Code)- 10 comments
Proposed Chapter 5D (Electrical Code)—2 comments
Proposed Chapter 5E (Energy Conservation Code)—2 comments
Proposed Chapter 5F (Plumbing Code)—4 comments
In addition, nine comments were characterized as "out of scope" of this bill.
A matrix of those comments,the justifications, the Building Division's actions in response, and
the letters are attached hereto.
SL:ps
Att.
To:-.P .r
i. . .
Date 0 s 2020
Hawaii County Is an Equal Opportunity Provider And Employer
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StewFullert-,vrt
i Architect * Land Planner * Consultant
6 Kuakini Hwy. , Suite 103
rKailua Kona, Hawaii 96740 ® C l 326-961 1
June 4,2020
Hawaii County Building Division
West Hawaii Civic Center
74-5044 Ane Keohokalole Highway
Kailua Kona, HI 96740
Comments to consider for adoption of the new construction code for the County of Hawaii.
Proposed Code Amendments, continued research for 5E the energy conservation code.
Justification, amend to consider Health and safety issues
Contact information, See Letterhead
To whom it may concern:
The IECC was developed on the mainland where standards and codes considered
primarily the Four Seasons as a paras cons2guentl, all thought Rid—tOrn_s.
concepts, research methods theories, postulates, and scientific standards formed the
Lasts for the IECC. There are two Hawaiian seasons described as winter"Kau", November
to April with an average temperature of 78 degrees Fahrenheit, and summer, "Hooilo", with an
average temperature of 85 degrees Fahrenheit The average temperature difference is 7
degmes (emphases added).
There are obvious omissions and conflicts in ft IECCIHCECC. Extremely important for
the Hawaii Islands are humidity, mold, dry rot, fungi, and mildew, which have been virtuallyignored. Average ambient relative humidity in Hawaii, ranges from the 60`s to the 80`s. Fungi
grows in temperatures from 68 to 87 degrees Fahrenheit and are killed at 104 degrees
Fahrenheit, which means that the year around temperature range in Hawaii is nearly perfectforfungigrowth. Fungi growth is encouraged by high humidity. The high humidity in Hawaii,
exacerbates Respiratory disease conditions such as asthma, colds, flu, and pandemics. All
buildings and occupants are at risk when buildings are not allowed Io breathe Colds,
flu, and certain other respiratory conditions caused by high humidity needs to be carefully
considered.
Building Mycology:
Building affects the health of occupants in many ways, for example, Building RelatedIllnesses (BRI), Sick Building Syndrome(SBS). Respiratory Syncajal Virus (RSV).
Allergy and Environmental Health Problems (AERP} The most common building health
problems are attributed to the lack of natural and proper ventilation, dampness and
condensation resulting in mold growth, mildew, house dust mites, airborne fungi spores, and a
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range of other fungal and insect pests, aggravating respiratory roble s and allergies. We
must learn the basics learned from the past and present flu and pandemics. The population
spends 90 percent of their time indoors.
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Hawaii County has eight recognized climate zones and two subordinate sub zones. The
other islands in Hawaii, have apparently, not identified climate zones. Most residents of
Hawaii live on the coastal areas where year around temperature averages are comfortable as
compared to all other States. Heating and/or cooling (HVAC), for single family dwellings has
not been required or necessary. When HVAC is required by a client,Architects, Mechanical
Engineers, and the IECC should apply. Relative humidity defines comfort levels and needs to
be considered seriously) Over 90 percent of construction on the Island of Hawaii i
single family residential without HVAC!
It is unfortunate that Hawaii is being subjected to serious energy measures prevalent
in temperate zones and the erroneous heat loss adaptations for heat gain in our
tropical zone. The result of the IECC standards, for most of Hawaii, are,the significant
increases in the already high construction costs and Building Permit delays.
Protection of the public life safety must be the first consideration!
I strongly encourage that Hawaii County reexamine the Hawaii County IECC with licensed
professionals. At present, confusion is rampant!
Walter Stewart Fullerton,Architect
Expiration: 4-30-
2022IM7
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erton
Architect * Land Planner * Consultant
75-5656 Kuakini Hwy. , Suite I Oa
Kallue Kona, Hawaii 96740 (SOS) 326-961 1
CURRICULUM MIMa WALTER!ELT EULILEBLO
Licensed Architect Hawaii, No. AR-10857 (2003)
Licensed Architect, Nevada, No.7 1 (1972)
Licensed General Contractor, Nevada No. 16728 (no limit)
University of Nevada, Reno, NTI, School of Engineering:
Lectured seven years—Engineering, codes and construction technology
Northern Nevada Community College, Reno
Lectured three years—Codes, architecture and construction technology
Carpenters Union, Northern Nevada:
Lecture/workshop—Codes, plan reading and construction estimating
Journeymen Carpenters)
UBC & IM "Special Inspector", construction, certified Nevada
High rise, Large commercial, Mutt-family and Industrial)
HUD—Nationally certified construction inspector, multi-family residential.
Construction forensic Investigator, expert witness:
FBI— Investigation, research and testimony—construction fraud.
FDIC— Investigation, research and testimony—construction fraud.
Private sector—Architecture, engineering, construction, ADA, Codes, Fire,
a .,
A,,.Construction fraud and trip/slip and fall.
INTERNATIONAL COUNCIL OF BUILDING OFFICIALS—Professional member:
Contract"Plans Examiner" Life Safety; Structural and ADA.
INTERNATIONAL CODE COUNCIL—Professional member.
Nevada State Board of Architecture:
Founder and Chairman of Code of Ethics Committee
Founder and Chairman of Investigative Committee
Chairman of Legislative Committee
Licensing Judge for NCARB Design and Site Planning examinations.
Originated and followed through to Law the Nevada Residential Designer
licensing addition to NRS 623.
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Western ou in region AIA Design Awards Chairman,
IPlumasCounty, Caldbmia, Certified ns Examiner, Structural and Life Safety, I
Uniform Building Code, International Residential Code, International BuildingCode, and California Building Code.
Truss
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designer, Silver State Truss, Inc., Garnerville, Nevada.
Cl, CONSTRUCTION INSPECTORS, founded by Walter Stewart Fullerton, in1979. Providing Special Inspection services for Lenders, and Governmental
Agencies on complex projects, viz. High rise, Commercial, Industrial,
Educational, Multifamily projects, Single family Subdivisions, and Federal
Agencies. All Inspectors were certified by [CBO and ICC in all disciplines.
SPECIAL INSPECTOR, Nevada, Hawaii, and Cal' mia,,t single familydwellings, condominiums andmultifamily dwellings. Investigated and collected
samples for laboratory testing and recommended remediation measures.
As a General Contractor, projects Included, Nigh rise, Commercial, Industrial,
Condominiums, Multifamily, Residential Subdivisions, and educational projects.
Architect for LEAR JET and LEAR FAN aircraft hangers and production facilities,Reno, Nevada.
Special Inspector for Nellis Air Force Base facilities, Las Vegas, Nevada.
7"'
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Bata, Shelly
From: Jack Gaw <jackgaw@gmail.com>
Sent: Saturday, May 30, 2020 3:46 PM
To: Building Div internet mail; counciltestimony@hawaiicounty.com
Subject: Building Code Changes
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Sirs and Madam:
I
I am emailing my input regarding proposed changes to the Building Code. As the code and changes are
complex, I would like to only submit my general opinion regarding the proposal. As you work on the changes,
please keep in mind the impact on costs and expenses that these proposals will have on housing costs. Changes
are not without economics costs and does a disservice to citizens if you drive us housing costs for
everyone. The marginal benefit must be weighed against costs and impact on housing
construction. Furthermore, keep in mind whether these proposals are changes addressing problems that are
non-existent or minimal.
Please, let's not increase housing construction costs without good cause and where there is a non-existent
problem.
Thank you.
I
Jack Gaw
Hilo Resident
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Bata, Shelly
From: richard@bidleman.net <rbidleman@gmail.com>
Sent: Monday,June 01, 2020 9:49 AM
To: Building Div internet mail
Subject: Building code changes/modifications
The single biggest criticisms I haveear ver the yearsa
been the adoption pretty muchoft e universal building code
which applies more to the mainland and does take into
consideration that this is the tropics. With that thought in
id, modify the code accordingly.
I have built two homes here.
Richard Bidleman
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Bata, S ell
From: Daniel Bona <bonadesign@aol.com>
Sent: Sunday, May 31, 2020 1:36 PM
To: Building Div internet mail
Subject:code amendments input
Aloha,
Just saw on a Facebook post that there is a 5 day comment period on the last draft of the Building code.
Seems like there should be a better way to let the island professionals know about these things, But anyway......
The Residential parts are not in the draft, I assume because it will not be adopted until November.
When will those proposed changes be available?
Only question that confused me in the text was,
For the commercial Adoption Article 2 (5A-2-1) says you will be adopting the 2006 IBC.
Is this correct?
The biggest NEW thing in this code that should be evaluated and defined thoroughly is the plan review fees and
resubmit fees.
The addition of a plan review fee is reasonable and hope that the money will go to increased staff, and expediting the
process.
Part 5-7-1(b)which says the second submittal (for corrections) is free, but the third is an additional $250, fourth, $500 and
1000 for subsequent .
This seems like it will be a good deterrent to not reading directions and wasting the plan reviewers time,
BUT,
If you will be charging this resubmitted fee, It is imperative and Reasonable that
ONLY ONE PLAN REVIEWER SHOULD BE INVOLVED WITH THE PLAN SUBMITTAL.
I have personally gotten plan review rejections two to 3 times because a different plan checker looks at the plans each
time it is dropped off, and each finds something new that they think should be addressed.
And what about plan rejections from (plan review comments) Other departments?
It is very common for plans to be rejected by Planning.
Then rejected by engineering for something else.
Then rejected by Heath,
so can be submitted 3 times before even getting to Building.
Wording should be included that the plan review fee is only for building department or it is for all departments?
Thanks for allowing some input into this, and looking forward to being part of the discussion on Residential amendments,
Daniel Bona
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From: Daniel Bona <bonadesign@aol.com> I
Sent: Sunday, May 31, 2020 2:45 PM
To: Building Div internet mail
Subject:code ammendment input 5-3-22 (4)
E
I
Just noticed 5-3-22 (4)
At first glance I didn't give it any regard because it looked like it did before.
But that is the problem.
The Building code has had this random $4000 limit on repairs (Over a 12 month period) for at least 20 years.
Has anyone tried to have repairs done by a licensed contractor recently?
There is almost Nothing that can be done for less than $4000 in present economy.
This Number should be looked at, and really should be raised to reflect that prices have gone up considerably in 20 years.
Thanks,
Daniel Bona
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Bata, Shelly
From: Nimr Tamimi <nimr.tamimi@epinc.pro>
Sent: Friday,June 05, 2020 2:18 PM
To: Building Div internet mail
Subject:COH Draft Construction Code
Attachments: COH Draft Construction Code 5-26-20 Comments nimr tamimi.pdf
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Aloha,thank you very much for this opportunity, please find attached our comments for the Draft Construction Code.
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Have a wonderful weekend!
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Thank you 3
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Nimr Tamimi,P.E.,LEER AP Principal/CEO
ENGINEERING PARTNERS
Direct(808)930-7823 I Main(808)933-7900 I
nimr.tamim I nr.einc.pro
Hawaii I Las Vegas I Manila
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County a all
Construction Code Draft
5-26-20
Review Comments by:
NimrTamimi, P.E.
808) 930-7823
nimr.tamimiOeninc.pro
June 5,2020
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Comments:
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General:
1
Reference is made to the use of EnerGov, my last interaction/discussion with people familiar
with this program is that it is not properly functioning. Have the issues been resolved? Is it
ready to be released?
j
Section 5-1-3.Scope; exceptions
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Item 8,Agriculture Buildings—can we please provide a special exception/amendment that
makes it easier to construct greenhouses for ag purposes. There is also a national/international
push on indoor agriculture(controlled environments in existing/new buildings). In an effort to j
promote food safety and security for our community,can we make it easier to permit/construct
these types of facilities through exemptions or other means?
Section 5-4-2. Plans, specifications, and other data.
Item 1, Be drawn to scale upon substantial 24 inch by 36-inch paper
o Please consider other sizes,some state and county departments/agencies use different
standard size sheets (22 x 34, 22 x 36,etc.). We also sometimes use 30 x 42. It would
also be nice to be able to submit on 11 x 17 or 8'l2 x 11 depending on what is being
submitted and that all items are legible without needing magnification.
Item 3, c,the name and address of the person who prepared the plans
o Should we add phone numbers also?
Section 5-4-3. Engineers and architects;work
Item h, Mechanical plans, ........
o Please clarify that the engineer should be a licensed Mechanical Engineer vs just
professional engineer. This happens in other area of this document, please review and
clarify the intent.
Item j,The authority having jurisdiction may........
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o Please clarify that the engineer should be a licensed Mechanical Engineer vs just
professional engineer. This happens in other area of this document, please review and
clarify the intent.
Section 5-4-4. Review of application.
Provide a maximum time frame for the review process
Provide for certified 3rd party review similar to the City and County of Honolulu
Provide a permitting option like Seattle's STFI program,Subject to Field Inspection. This can fast
track some easier types of projects.
Section 5-4-6. Cancellation of application.
Please delete or revise this section, sometimes there are delays in obtaining permits other than
the construction permit that may cause the people running the permit to not pick up the
construction permit in the time allocated. Having to reprocess the permit will add more time,
cost and work for everyone involved.
Section 5-4-21. Model plans for residential dwellings; preapproval.
Item c, 1 To apply for pre-approval of a model plan, ...........
o Please clarify what type of engineer is meant by professional engineer. This happens in
other area of this document, please review and clarify the intent.
Item f, 2 Construction drawings for pre-approved model home designs, ........
o Please clarify what type of engineer is meant by professional engineer. This happens in
other area of this document, please review and clarify the intent.
Section 5-5-4. Expiration.
Itema, 1 &2
o Delete these items or increase the time allowed for construction
There may be other permitting items that are pending that might push the
project completion time
The timeframe may be too short for certain types of projects.
There could be other issues beyond the control of the permit holder that could
push the completion of the project further and cause them not to be able to
comply with this requirement.
Item a, 3 180 consecutive days after the date of issuance........
o Delete or increase the time allowed for commencement of construction
There may be other permitting items that are pending that might push the
project start time
There may be other issues beyond the control of the owners that cause the
construction start date to be pushed. Some may include but not be limited to
funding, availability of materials/equipment, contractor is busy with other
projects, etc.
Section 5-7-1. Permit plan review; general.
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Item a,A fee shall be assessed for plan reviews......
o Please clarify when would this get assessed
Item b, No additional plan review fee will be........................
o Please delete this section or find another way to get the people submitting the plans to
reduce the number of resubmittals. There are occasions where the reason for the
multiple submittals is the plan review process itself. 4
Section 5-8-2.Work shall be visible for inspection.
Item b, 2 Non-Residential Installations...........
o Allow for verification of the work through a letter by the architect/engineer similar to I
the allowance made in Section 5-8-2.b.1 Residential Installations(the previous
paragraph)
Section 5F-2-1. Uniform plumbing code adopted.
Item c, 20,Subsection 1327.3.......
o Please delete the requirement for a licensed mechanical engineer to provide a
statement of compliance. Since the county is requiring the medical gas systems be
installed by a qualified Medical Gas Installer and inspection/approval by a Certified
Medical Gas System Verifier,there is no need for an additional layer of
review/approval/verification above and beyond what is normally done by the engineer
of record for other plumbing systems.
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From: Paul Donoho <paul@pdonoho.com>
Sent: Thursday,June 04, 2020 5:14 PM
To: Building Div internet mail
Subject: Commentary regarding Hawai'i County 2020 Draft Construction Code
Attachments: LET Building Code Comments 200604.pdf
Mahalo for allowing the professional community to be a part of the process.
11paul M. Donoho,Architect
PO Box 1727
Honoka'a,111 96727
P: 808.756.4061
W: htt-o://wwcv.pdonoho.com/
houzz :Mhouzz ri houzz t houzz N houzz'
CONFIDENTIALITY MESSAGE:
This e-mail and all attachments are CONFIDENTIAL and intended SOLELY for the recipients as identified in the "To",
Cc" and"Bcc" lines of this e-mail. If you are not an intended recipient,your receipt of this e-mail and its attachments is the
result of an inadvertent disclosure or unauthorized transmittal. Sender reserves and asserts all rights to confidentiality,
including all privileges that may apply.Pursuant to those rights and privileges,immediately DELETE and DESTROY all
copies of the e-mail and its attachments,in whatever form,and immediately NOTIFY the sender of your receipt of this e-mail.
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k
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PAUL M . DONOHO
ARCHITECT
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June 4,2020
County of Hawaii Department of Public Works
Building Division
Aupuni Center, 101 Pauahi Street,Suite 7
Hilo,Hawaii 96720-4224
RE: Commentary regarding Hawaii County 2020 Draft Construction Code
Chapters 5B and 5C
uestion: Why are these chapters not included in this draft of the construction code? In section 2 of the
proposed ordinance it appears as though Chapter 5 is repealed in its entirety. Chapter 5A is intended to apply
to commercial construction.Where does one go for residential construction during the period before Chapter
5B is adopted?If residential is intended to use Chapter 5A for the interim that confuses the new structure of
the Construction Code.Not including Chapters 5B and 5C at this time will require more extensive modification
to Chapter 5 when those chapters are adopted.
Suggestion:Why not include abbreviated Chapters 5B and 5C and use those chapters to clearly state how these
types of construction will be treated in the interim.. e.g. Chapter 5B,R-3 uses chapter 5A or the 2012 IRC with
State amendments until the IRC is adopted by the County;Chapter 5C,existing buildings use 2006 IBC Chapter
34 until the existing building code is adopted.
Section 5-1-4. Existing Buildings
Comment:The IBC version is given in Chapter 5A but not in Chapter 5,Section 5-1-4(b)
Comment: It appears that the twelve-month period and valuation criteria for upgrade requirements is being
deleted in favor of an unamended IBC Chapter 34. It appears this will make the code more restrictive in some
cases and less restrictive in others.
Comment:Previous IBC amendments to 2006 IBC sections 3405.1 and 3410.3.2 are no longer included.These
may not be needed since there is no longer valuation criteria.
Section 5-2-22
Comment: GREAT to see the code explicitly support used material, especially here in Hawaii to relieve the
overburdening of our landfills.
Section 5-3-22. Building work;exempt
Comment: (a)(4)replacement for maintenance of components,$4,000 permit threshold.This is far too low for
this category and most especially in light of the cost of construction in Hawaii. A single door panel can cost
4,000. It is ridiculous for an owner to have to go through the whole permit process to replace a couple of
doors with the same,thus many won't get permits.The value was too low before,and is still too low.Electrical
and Plumbing don't have the valuation threshold for repairs and can often cost well over $4,000 themselves,
why do other repairs need it?
Suggestion:Value should be changed to$10,000 or eliminated. Also considering the rate at which construction
costs change setting such a low limit, or any limit at all, means a constant and consistent need to revise this
language to keep this in touch with reality on the ground and encourage compliance.
PO BOX 1727
HONOKA'A, HI • 96727
P: 808.756.4061
E: PAUL@PDONOHO.COM
2—
Section 5-4-1.Application for permit
Comment: (a)(8)(9)(10) information for each contractor or subcontractor engaged to do work. At the time of
building permit submittal all of the contractors and subcontractors for a project my not have been selected.
Suggestion:This section should explicitly allow this information to be provided at a later time. Especially for
non-profit groups, religious organizations, low income projects, we need to be able to "go out to bid" with
completed sets of documents to at least attempt to get the best value for these less advantaged groups to even
carry out their projects. Forcing this to happen before the very long permit approval process only lengthens
the already long process further stressing these folks who do not have the margins to continue to absorb this.
Section 5-4-2. Plans, specifications, and other data.
Comment: (c)(1)it appears that 24"06"is the only sheet size that will be accepted.
24x36 is excessively large for some small projects and may not be large enough for other projects and is an
entirely random and arbitrary decision. Please be aware that arbitrarily large sheet sizes do in fact increase cost
to our residents trying to get the structures they need,not only for the printing ofthose sets required for permits
but for the printing for all those involved in the process (contractors, subs, suppliers, clients, banks, bonding
agencies, etc...).
Suggestion:It would be better to have a range, 11x17 minimum to 36x48 maximum.
SuV,gesdon: (c)(4)(E) Certified flood zone elevation mark should be explicitly exempted for renovations and
alterations which are not changing existing floors or adding additional floor area.
Section 5-4-3. Engineers and architects;work
Suggestion: (b)(2) Trusses manufactured per 2006 IBC section 2303.4.2 Metal-plate-connected trusses, 2012
IBC section 000, 2012 IRC section R802.10.2 & R804.3.7. The truss manufacturer's design print-outs which
include the design drawing data listed in the IBC/IRC should be accepted with a single cover stamp.
Comment:
c)(7) Structures in high seismic zones.For Hawaii Island it very often requires an architect and/or engineer to
determine if a project is in Category E. Use and configuration of construction can determine if a location that
might normally be E can be constructed as D2 and vice versa.
Suggestion: (h) HVAC design for one and two family single-family dwellings should be able to use IRC
prescriptive design in lieu of an engineer.
Section 5-4-6. Cancellation of application.
b)Thirty days to take action on deficient application. (c) 180 days to obtain permit.
Question: How is it solely the applicant's responsibility to secure a permit within a 180-day time frame when
the County and State control the review times?Some SHPD reviews require that a building permit application
be made before they will start looking at a project, then their timeline can be years.Add this as well on top of
archeological reviews, subdivision process, etc... and a simple local developer just trying to get some quality,
decent,usable space onto the market has to float this thing for years upon years.
Suggestion: Time should be counted against the 180 days only when the application has been returned to the
applicant for corrections. Time in County or State review should not be counted. 180 days for the review of
single family-residential does seem entirely out of scale.
Section 5-5-3.Designation ofperson,contractor,or subcontractor who will do work.1
Comment:If the new"one permit"requires that plumbing and electrical subcontractors are selected before the
issuance of the building permit that will be a big problem for many projects. s
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Section 5-4-7.Applications made prior to subsequent changes in applicable laws.
Comment: Same question and suggestion as Cancellation of Application section. Time in County or State
review should not be counted against the 180 days.
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Section 5-7-3. Permit I
Comment: (b) Fee Schedule. Dwellings over 1,401 sf fees are no longer based on square footage unless it is a
pre-approved model plan. Item C from the old fee table was moved into the pre-approved table in section 5-
7-2 but was not included in section 5-7-3 (b). i
Question: (c) Valuation. The ICC building valuation data appears to require a permit fee multiplier unique to
each jurisdiction in order to calculate a valuation. Where will this value be published? How often will it be
updated?
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Chapter 5A.Article 2. Section 5A-2-1
Comment: The previous adoption of the 2006 IBC, Chapter 5 Section 5-3, adopts the 2006 IBC, excludes
Chapter 1 of the IBC.
This ordinance does not appear to exclude Chapter 1 yet many of the sections in Chapter 5 are covering similar
topics.This could lead to confusion over which sections are applicable.
Comment: At the end of this section the draft ordinance says "insert rest of provisions presently found in 5- I
71, 5-74 through 5-76,and 5-78 through 5-83
The current amendment to section 903.2.7 Group R. Automatic sprinkler. is brought in and continues to
exempt R-3 from the sprinkler requirement.
Chapter 5E. Energy Conservation Code.
Comment:There does not appear to be any changes to the previously adopted amendments to the 2015 IECC.
If changes have been made the County should make professionals and the public aware of them with enough
time for our community to be able to effectively react.
Chapter 5F. Plumbing.
Suggestions:
Section 508.4.5 Access.An exception should be added.No permanent ladder required for R-3
Section 1101.11.1 Primary Roof Drainage.An exception should be added.No roof drains or gutters required
for R-3 roofs without parapets.
SECTION 13.
Suggestion: Since the exact date of final approval will not be known in advance the effective date should be
two weeks after approval so that there is time to notify design professionals and the public.
Sincerely, J
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From: Ryan Takahashi <ryan@hemep.com>
Sent: Thursday,June 04, 2020 5:38 PM
To: Building Div internet mail; Matsumoto, Robyn; Tanaka, Neal
Subject: Comments from the Electrical Industry on Proposed County Building Administrative
Code
Attachments: HEM EPA ICounty.BuldingAdminCode.comments.060420.pdf
Dear Division Chief Robyn Matsumoto and Deputy Chief Neal Tanaka:
Thank you for requesting public input on these matters.
Attached you will find comments from a large conglomerate of stakeholders in the electrical industry of the
State of Hawaii and County of Hawaii.
Please feel free to contact me with any questions or comments.
Aloha,
Ryan Takahashi
Hawaii Electricians Market Enhancement Program
808) 846-2374
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A W A I
ELECTRICIANS
1935 HAU STREET, ROOM 300 ® HONOLULU, HAWAII 9681 ® PHONE(606)641-6169 ® FAX( 06)647-4596
June 4,2020
County of Hawaii
Department of Public Works Building Division
101 Pauahi Street, Suite 7
Hilo,HI 96720
VIA EMAIL TO: cohbuild@hawaiicounty.gov
RE: Proposed Amendments to the County's Building Administrative Code
Dear Public Works Building Division:
Hawaii Electricians Market Enhancement Program (HEMEP), an organization representing over 100
Hawaii State Licensed Electrical Contractors,the Electrical Contractors Association of Hawaii, and
nearly 3,400 Members of the IBEW Local 1186,would like to submit comments on the proposed
amendments to the Building Administrative Code.
ELECTRICAL PERMITS ISSUED TO LICENSED ELECTRICAL CONTRACTORS
As public and worker safety is the top priority ofthe County's Building Division,it is important to have
strict policies of"to whom"electrical permits may be issued,and"who"may perform electrical work.
Electrical Contractors(using Licensed Electricians)adhere to the training,continuing education, safetX
standards, and installation methods that are outlined in the National Electric Code(NEC), and should
always and exclusively be the responsible contractor to which a permit is issued for electrical work.
We fully support the County moving towards the adoption of the 2017 NEC,as updated versions include
the most current safe installation requirements.
The County also requires electrical work to be performed by a"qualified person"(Section 5D-1-6),
which is defined as an electrician licensed under HRS 448E. We again, fully support this requirement as
it truly considers public and worker safety, and is an important term to apply to any and all electrical work
that is performed in the County.
IMPORTANT DISTINCTIONS IN THE CONTRACTOR LAW AND ELECTRICIAN LAW
Hawaii has an important"dual licensing"requirement when it comes to electrical work. It is essential to
understand that HRS 444 is the Contractor Law that regulates who may"contract,or offer,to perform
work";while HRS 448E is the"performance"regulations for electrical work;requiring specific licensing
for person(s)actually performing the work that was contracted or offered.
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Hawaii County Public Works Building Division
June 4, 2020
Page 2 of 2
The Board of Electricians and Plumbers(BEP),the governing authority of HRS 448E,has consistently
stated that their jurisdiction to require licensing is within premises, or property/boundary lines(BEP-Aug.
1999; BEP-April 2005;BEP-Oct. 2008; BEP-Dec. 2015).
BEP also stated that County Building Departments have the jurisdiction to require licensing related to
permit requirements(BEP-Aug. 2009),where they specifically stated"ifthe county requires an electrical
permit, it may be clearer that licensed electrical contractors and licensed JE or JS licenses are also
required to perform the work".
We would ask the County of Hawaii to continue with that clarity by requiring that permits issued for
electrical are only issued to licensed Electrical Contractors using licensed Electricians.
COMMON MISAPPLICATION BY"A"GENERAL ENGINEERING CONTRACTORS
A-General Contractors often refer to a Hawaii Administrative Rule(HAR) Section 16-77-32(b). A
portion of this rule states: "A general engineering contractor may also install duct lines,provided that the
installation ofconductors is performed by a contractor holding the C-13 electrical classification". The
term"duct line"is used broadly in construction,but it may also include"electrical conduit".
The rule clearly reflects that to actually complete the electrical installation; an electrical contractor would
be required. By referencing only this administrative rule,proponents also fail to recognize the"dual
licensing requirements"that this State has related to ALL electrical work.
While the administrative rule may indicate that an A-General could contract to install duct lines in
accordance with HRS 444,the A-General would still be required to adhere to the NEC for the installation
and be subject to HRS 448E, in that a duly licensed electrician would be required to perform the duct line
work inside premiseslpropertylboundary lines.
Again,the often referred to carve out for duct line(electrical conduit)work in the administrative rule,
DOES NOT offer an exemption to the licensing laws in HRS 448E—Electricians and Plumbers;nor
should it be an exclusion from the County's permit requirements ofissuing electrical permits to licensed
electrical contractors and requiring performance by"qualified person(s)"aka Licensed Electricians.
CONTINUE WITH THE EXISTING PROCEDURES
For these reasons,HEMEP requests that the County Public.Works Building Division continue with the
longstanding requirement to have a duly licensed Electrical Contractor be required to pull any permit with
electrical phases. In a"1-permit"system,an Electrical Contractor should be declared on such a permit,
and for permits that ONLY have electrical work,an Electrical Contractor should be the issued party.
This provides the best practices for public and worker safety, as well as for the County. Permits with
electrical work are issued for properties(premises,property,boundary lines)within thejurisdiction ofthe
County. All the existing ordinances,laws, and codes line up so that as the County enforces compliance
with the permit,the applicable NEC, electrical contractors, and licensed electricians work in sync.
Thank you very much for the opportunity to provide comments. We thank you for your continued efforts
in adopting current codes. We are available to respond to any questions or comments you may have.
Sincerely,
Ryan Takahashi
Director of Compliance
ata, She
From: Lisa <ls.vollbrecht@gmail.com>
Sent: Friday,June 05, 2020 10:35 AM
To: Building Div internet mail
Subject:Comments on County Building Administrative Code amendments
Proposed code amendment:
Section 5A-3- 27. Appendix Y;Tiny Houses
ADD -Grandfather clause to exempt already existing tiny homes from the proposed amendments and only
require compliance for new home construction.
Justification for the amendment:
We appreciate that the county would like to update codes to allow for more affordable housing in tiny homes.
To uphold the intent of this idea, it is an imperative to include a clause that would allow for the proposed
codes to only apply to future tiny homes, while allowing exemptions for those already existing. Without this,
the passing of the code amendments would make many existing tiny homes illegal. Many of these homes have
been lived in safely and securely by the owners for many years. Making existing tiny homes illegal would be
counter to increasing public access to more affordable housing opportunities. As builders of our own tiny
home, being acknowledged and exempted from the proposed amendments is extremely important to us so
that we may not suddenly become regulated out of our home.
We have not yet been able to review the burden of applying the entirety of the International Residential Code
in relation to new tiny home construction. We hope there is another opportunity for public comment so that
we may address this more fully with additional time beyond the week that was available during this comment
period.
Contact information for additional follow-up:
Email: Is.vollbrecht@gmaii.com
Phone: 808-343-5327
Thank you for this opportunity to comment,
Lisa Vollbrecht and Dakin Retzlaff
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Bata, Shelly
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From: John Hetherington <hetharch@gmail.com>
Sent: Friday, June 05, 2020 3:01 PM
To: Building Div internet mail
Subject:comments regarding proposed new "Construction Code"
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Aloha All,
We were given very short notice to review this document and the proposed changes, but here are a few
comments and notes based on my preliminary review.
1) It would be nice to see the tables noted in "Section 1. Background" before finalizing any changes.
2)Regarding Section "5-1-2. Purpose". It is not clear from this statement how requests for permits would be
handled. It would be nice to see a sample form before finalizing and changes. Will there be only 1 form and if
so....can we assume that for a single family dwelling that one permit will cover plumbing, electrical and
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building work.
3) How will fees be structured/assessed if a permit is requested for only electrical, or only plumbing work?
Does the ICC valuation data mentioned in the table in "Section 5-7-3.Permit" deal with electrical or plumbing
repair items that would need a permit?
4) Section 5-4-3(i) states that "Plumbing plans and diagrams shall be required for R-3 single and two family
dwellings and townhouses that include four or more bathrooms.Will this require a mechanical engineers Stamp.
This will definitely add cost for mid-range construction and delay preparation of plans.
5) Section 5-7-1 under Article 7 Fees. Ifthis modest increase in permitting cost actually allows the County to
hire more workers in the DPW for plan review then I am all for it.
6) Section 5-7-5 "Extra or regulatory inspections". Item (a) is understandable as it is often that inspections are
called for "in hopes ofbeing ready.......or depending on weather in the case of concrete pours there may be
issues out the control of an owner or contractor.
7) Section 5-7-5 "Extra or regulatory inspections" Item (b) If I understand this correctly then for a single family
home.Normally there are at least:
a. underslab inspections which could include building, electrical and plumbing work. (3)
b. framing,plumbing and electrical rough-in (3)
c. plumbing, electrical and building finals (3)
So the total fees paid for such a residential project for inspections would be $900.00. How would that be paid,
when would that be paid?Paid when calling for inspection?Paid if inspection passes cleanly? because fees are
noted for "second inspections" i
8) Section 5-8-2. "Work shall be visible for inspection" Item (b)(1). While I understand the need to deal with as-
built conditions, there are a ton ofthem on this Island......the phrasing of this paragraph is an open door for s
abuse in my opinion. Should be reconsidered. In the past this was considered acceptable, of late the county has
not been accepting such letters. This definitely needs to be clarified and have input from the Architects and
Engineers who will be dealing with this type of situation.
9) Tiny home section is good... happy it's there
10) it may be because this is a draft or that no changes to these are proposed, but there appear to be several
appendices missing.
No Appendix M for thatched roofs
No Amendments to Appendix C: Group U for agricultural buildings
No Appendix U for hurricane sheltering
No Appendix W for Hawaii Wind design provisions
No Appendix X, for Indigenous Hawaiian Architecture Structures
Aloha John
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contact information is below
Hetherington Architecture, LLC
John L. Hetherington,Architect
73-4520 Aniani Street
Kailua Kona, HI 96740 4
808-938-3498
hetharch 2mail.com
Hawaii Lic. AR-14938
htt-o-,I/hetheringion-architecture.com
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ata, Shelly
From: John Makoff <johnm@goodfellowbros.com>
Sent: Wednesday,June 03, 2020 9:35 AM
To: Building Div internet mail
Subject:Comments to Draft Construction Code
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Dear County i
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The current draft construction code fails to address several state laws that effect licensed contractor in the county of
Hawaii.
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HAR Title 16 Chapter 77 C-37A and C43 (Both a subset of an "A" licensed Contractor in the state of Hawaii.)I
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C-37a Sewer and drain line contractor. To install sewer lines from house to city sewer with connections, and to 3
install septic tanks, package sewage treatment plants, and related work,within property lines.
C43 Sewer,sewage disposal, drain, and pipe laying contractor. To Construct concrete and masonry sewer
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disposal plants,sewage lift stations,septic tanks, and appurtenances thereto;to lay all types of piping for storm
drains,water,and gas lines, irrigation and sewers, manholes in connection with the above work; and repairing I
and reconditioning of the pipelines, including the excavation,grading,trenching, backfilling, paying, and
surfacing in connection therewith:
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HAR Title 16 Chapter 22 Chapter 77 Subchapter 6 16-77-32 (b)
b)The"A" General engineering contractor may also install poles in all new pole lines and replace poles,I
provided that the installation of the ground wires, insulators,and conductors is performed by a contractor
holding the C-62 pole and line classification. The "A"general engineering contractor may also install ductlines,
provided that in the installation of conductors is performed by a contractor holding the C-13 electrical
classification.
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HAIR Title 16 Chapter 80 16-80-3 Definitions
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Plumbing Work"..... However,this provision shall not prohibit other properly licensed contractors from
performing any exterior piping work five feet or more outside the building line without licensed plumbers. ....
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In summary. The draft construction code fails to recognize that an "A" licensed contractor in that state of Hawaii has the
right under state law to install sewer, drain,septic tanks, storm drains, water,gas lines, irrigation 5 feet outside the
building without having a licensed plumber or plumbing license. It also fails to recognize that an "A"licensed contractor
in the state of Hawaii can install electrical ductlines 5 feet outside the building without a licensed electrician.
The current DPW requires a plumbing or electrical permit(conduits only) when working outside the 5 foot perimeter of
a building. Assuming this permit is still going to be required. Article 6. Eligibility to Work fails to address that a "A"
licensed contractor in the state of Hawaii can complete Plumbing work and Electrical work(ductlines only) 5 feet outside I
the building without a licensed plumber or electrician. This Clarification needs to be added to Section 5-6-1 (b) and
Section 5-6-1 (c) to prevent licensed contractors under the state of Hawaii law from completing work within the county
of Hawaii.
Section 5-6-2 (b) and (c)also fail to address the same facts.
Thank you for your time.3
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John Makoff
Regional Manager--Big island
Goodfellow Bros
PO Box 383729
Waikoloa, HI 96738
O 808.887.65111 M 808.960.4648
www.goodfellowb ros.com
GOA FELLOW BROS.
Our Mission To be the contractor ofchoice by our Clients,
Employees and the Communities in which we live and work.
Equal Opportunity Employer
Disclaimer
The information contained in this communication from the sender is confidential. It is intended solely for use by the recipient and
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From: Maria Gacula <maria.gacula@hpmhawaii.com>
Sent: Friday,June 05, 2020 2:33 PM
To: Building Div internet mail
Cc: Darryl Oliveira
Subject:Construction Code Draft Comments
Attachments: Construction Code Draft Comments (HPM).pdf
Aloha,
Please see enclosed and attached, comments and proposed amendments to the new Construction Code for the County
of Hawaii.
Prepared by:Maria Gacula
345 Kanoelehua Ave
Hilo,HI 96749
808)934-4255
maria.gacula@hpmhawaii.com
Construction Code Draft—Requests for Clarification
Reference: Cover letter, section A, regarding use ofEnerGov Software.
Is this software intended to launch to the public when this Construction Code becomes effective? If so,what is the
implementation plan or guidelines for submitting applications and construction documents?
Reference:Section 5-2-33. Building work; exempt. D)regarding detached one-story accessory structures ofU occupancy.
Does Construction Code address and/or provide justification of the omission of one-story detached accessory structures
that do not exceed 600 square feet for agricultural zoned lands currently cited in Hawaii County Code 5-19.Permit
required,Exception#18?
Reference:Section 5-4-6. Cancellation ofapplication. (c) 180 days to obtain permit
Does this exclude applications that haven't completed by all department reviews or received a"recommend for issuance"
or"recommend return with correction"notice? For instance, if a"recommend return for corrections"notice is sent prior
to Engineering or Building reviews, is time suspended?
Reference:Appendix Y Tiny Houses
Are Tiny Homes allowed on any type of zoned lot?
Construction Code Draft—Proposed Amendments
Reference:Section 5-1-5. Definitions
Proposed Code Amendment:
Factory-built home"means a dwelling or dwelling unit[housing, afty ntfuetHfe of peffie„thefee a deli e
which is either entirely prefabricated or assembled at a
place other than the building site.
Justification: Use of"dwelling"and "dwelling unit"suggests a residential occupancy. Omitting "structure or portion A
thereof"provides clarity that homes utilizingpre-manufactured trusses, wallpanels or other built components are
excludedfrom this definition. 1
Reference:Section 5-4-5. Action on application
Add:
c)Upon receipt of all required construction documents,the building official shall provide such documents to
appropriate state and county departments for comments. In addition, the building official shall review such
documents for compliance with this code and other codes the building official is responsible for administering.
The departments shall provide their concurrence or provide substantive written comments on the construction
1
documents no later than 30 calendar days from the date the building official sends the required documents to
the departments (15 calendar days for second submittal and 5 calendar days for subsequent submittals). The
building official may defer consideration of the building permit pending receipt of additional information from
either the applicant or comments from a reviewing department, in which case the running of time is suspended.
If reviewing departments do not provide comments within the required time period,the building official shall
consider the department as having no comment on the construction documents, unless the building official
requires a response from a reviewing agency as specified above. The failure of any reviewing department to
comment within the specified time period shall not relieve the applicant ofthe responsibility to comply with all
applicable laws,whether required by the County, State or United States governments, which may include
obtaining other required permits prior to construction.Neither the building official in issuing a permit nor the
County of Hawaii shall be responsible for the applicant's failure to comply with any applicable laws. After the
time frame for comments has elapsed and the building official has received all required documents,the building
official shall review the comments provided and shall approve the permit as submitted, or as it may be
modified, or shall disapprove the same and shall express the disapproval and the reasons therefor in writing.
Maui Code of Ordinances, Title 16-Buildings and Construction, Chapter.16.26E—Building Code)
Justification: To provide measure of accountability and encourage reducedpermit processing time and standardized
procedures as described on S'ectien5-1-2. Purpose ofthis code.I
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Reference: Section 5-7-1. Permitplan review;general.
Proposed code amendment:
b)No additional plan review fee will be assessed for a second submittal,provided all building officials and
agencies have completed their reviews and included code references and justification of comments with the
recommend return for correction"notice. Where comments remain unaddressed plan review fees for subsequent
submittals shall be: $250 for a third submittal; $500 for a fourth submittal; and$1000 for each additional
submittal.
Justification: To ensure design professionals have clear understanding ofbuilding official's interpretation ofcode and
can address claimed deficiencies within a single re-submittal. It is highly recommended that there is consistent
interpretation and enforcement ofcode and requirements among all building officials to discourage new comments
arising in the event multiple building officials review plans, as well as educate the design community so that new and
future plan submittals are developed accurately and completely in thefirst submittal at the onset ofthe permitting
process.
Reference: Section 11
Proposed code amendments:
Work preformed under a permit issued before the effective date ofthis ordinance and which is inspected on or
after the effective date shall be approved if it meets the requirements of[eithef this eed nq the code [beifrg
feplaeed by this er-dinane in effect at time of the permit was issued.
Justification: To provide consistent enforcement and mitigatefinancial burden placed on owners to submit revisions and
delay the construction progress.
Reference: Section 12
Proposed code amendments:
This ordinance shall apply to all applications for permits to be issued pursuant to chapters 5, 9,and 17,Hawaii
County Code,that are deemed complete by the Department of Public Works on or after the effective date ofthis
ordinance. An application accepted before the effective date shall be approvable ifit meets the requirements of
eithef this efdinanee ef] the code [being feplaeed by the efdia in effect at the time the application was
submitted.
Justification: To provide consistent enforcement and mitigatefinancial burden placed on owners to submit multiple plan
review submittals andlor revisions and delay project progress.
Prepared by: Darryl Oliveira
16-166 Melekahiwa Street
Keaau,HI 96749
808)966-5622
Darrvll.oliveria u)hpnzha,waii.com
Article 1, Section 5-1-5.Definitions,page 5
1) Factory-built home. Request confirmation ofcitation as noted 15-79, citing L101.2 of UBC that defines
factory-built housing.} The citation appears to be from the Hawaii County Code 5-79 and referring to IBC
Appendix L not the UBC as specified.
Article 4 Division 2.Pre-approval, Section 5-4-21. Model plans for residential dwellings: pre-approval, (c)Application
for model plan pre-approval(2), page 24
1) Propose to strike language stating"Factory-built homes shall include a manufacturer's seal as required by
Appendix L of chapter 5A,the commercial building code." Manufacturer's label is the proper terminology
and is not required for plan pre-approval. The label is to be affixed to the structure and therefore not part of
the plans pre-approval process or permitting process. More in line with inspection process as set forth in
Appendix L.
Thank you,
3
Maria Gacula
HPM HOMES PROGRAM MANAGER
OFFICE (808)934-4255 9 FAX(808)934-4364
380 KANOELEHUA AVENUE• HILO, HI 96720
HPMBUILDBETTERtE x
FINES US ON FACEBOOK,TWITTER&INSTAGRAM s WWW.HPMHAWAII.COM
Please consider the environment before printing
CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, is for the sole use ofthe
intended recipient(s) and may contain confidential and/or privileged information. Any unauthorized review,use,
copying, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender
immediately by reply e-mail and destroy the original message and all copies.
4
MPMBUILDBETTERRulurmIUMT
380 KANOEFEHUA AVENUE •Hilt7,HAWAII 96720
PHONE 1808)935-0875 •FAX(808(934-4355
June 5, 2020
County of Hawaii Public Works— Building Division
Aupuni Center, 101 Pauahi St, Suite 7
Hilo, HI 96720
Subject: Construction Code Draft Comments
Aloha,
Please see enclosed within this document, comments and proposed amendments to the draft of the New
Construction Code for the County of Hawaii.
Sincerely,
Maria Gacula
NPM Homes Program Manager
n ac lath mhawaii.com
808) 9934-4255
HIPMBUILDBETTERNUROMG,SUPPLY
380 KANOELEHUA AVENUE*HILO,HAWAII 96720
PHONE(808)935-0875*FAX)808)434-4355
Prepared by: Maria Gacula
345 Kanoelehua Ave
Hilo, HI 96749
808) 934-4255
maria.gacula@hpmhawaii.com
Construction Code Draft— Requests for Clarification
Reference: Cover letter, section A, regarding use of EnerGov Software.
Is this software intended to launch to the public when this Construction Code becomes effective? If so, what is the
implementation plan or guidelines for submitting applications and construction documents?
Reference: Section 5-2-33. Building work; exempt. D) regarding detached one-story accessory structures of U
occupancy.
Does Construction Code address and/or provide justification of the omission of one-story detached accessory
structures that do not exceed 600 square feet for agricultural zoned lands currently cited in Hawaii County Code 5-
19. Permit required, Exception #18?
Reference: Section 5-4-6. Cancellation of application. (c) 180 days to obtain permit
Does this exclude applications that haven't completed by all department reviews or received a "recommend for
issuance" or"recommend return with correction" notice? For instance, if a "recommend return for corrections"
notice is sent prior to Engineering or Building reviews, is time suspended?
Reference:Appendix Y Tiny Houses
Are Tiny Homes allowed on any type of zoned lot?
NPMBUILDBETTERsuammSIAMY
384 KANOEI,EHUA AVENUE •HILO,HAWAII 96724
PHONE{848)935-4875•FAX(808)934-4355
Construction Code Draft— Proposed Amendments
Reference: Section 5-1-5. Definitions
Proposed Code Amendment:
Factory-built home" means a dwelling or dwelling unit [hatising, any structure or poi4ion thereof, design
primarily for residential aeeupaney by human bein which is either entirely prefabricated or assembled at a
place other than the building site.
Justification: Use of"dwelling" and "dwelling unit"suggests a residential occupancy. Omitting "structure or portion
thereof"provides clarity that homes utilizing pre-manufactured trusses, wall panels or other built components are
excluded from this definition.
Reference: Section 5-4-5. Action on application
Add:
c) Upon receipt of all required construction documents, the building official shall provide such documents
to appropriate state and county departments for comments. In addition, the building official shall review
such documents for compliance with this code and other codes the building official is responsible for
administering. The departments shall provide their concurrence or provide substantive written comments on
the construction documents no later than 30 calendar days from the date the building official sends the
required documents to the departments (15 calendar days for second submittal and 5 calendar days for
subsequent submittals). The building official may defer consideration of the building permit pending receipt
of additional information from either the applicant or comments from a reviewing department, in which
case the running of time is suspended. If reviewing departments do not provide comments within the
required time period, the building official shall consider the department as having no comment on the
construction documents, unless the building official requires a response from a reviewing agency as
specified above. The failure of any reviewing department to comment within the specified time period shall
not relieve the applicant of the responsibility to comply with all applicable laws, whether required by the
County, State or United States governments, which may include obtaining other required permits prior to
construction. Neither the building official in issuing a permit nor the County of Hawaii shall be responsible
for the applicant's failure to comply with any applicable laws. After the time frame for comments has
elapsed and the building official has received all required documents, the building official shall review the
comments provided and shall approve the permit as submitted, or as it may be modified, or shall
disapprove the some and shall express the disapproval and the reasons therefor in writing. {Maui Code of
Ordinances, Title 16-Buildings and Construction, Chapter 16.26B — Building Code}
Justification: To provide measure of accountability and encourage reduced permit processing time and standardized
procedures as described on Section5-7-2. Purpose of this code.
iii
MPMBUILDBETTERSEINQSUPPM
380 KANOEI.EHUA AVENUE•HILO,HAWAII 96720
PHONE{808)935-0875 •FAX(808193"355
Reference: Section 5-7-1. Permit plan review; general.
Proposed code amendment:
b) No additional plan review fee will be assessed for a second submittal, provided all building officials and
agencies have completed their reviews and included code references and justification of comments with the
recommend return for correction" notice Where comments remain unaddressed plan review fees for
subsequent submittals shall be: $250 for a third submittal; $500 for a fourth submittal; and $1000 for each
additional submittal
Justification: To ensure design professionals have clear understanding of building official's interpretation of code and
can address claimed deficiencies within a single re-submittal. It is highly recommended that there is consistent
interpretation and enforcement of code and requirements among all building officials to discourage new comments
arising in the event multiple building officials review plans, as well as educate the design community so that new and
future plan submittals are developed accurately and completely in the first submittal at the onset of the permitting
process.
Reference: Section 1 I
Proposed code amendments:
Work preformed under a permit issued before the effective date of this ordinance and which is inspected on or
after the effective date shall be approved if it meets the requirements of [either this e0d 0 the code [being
i-epleeed by this ardinan in effect at time of the permit was issued.
Justification: To provide consistent enforcement and mitigate financial burden placed on owners to submit revisions
and delay the construction progress.
Reference: Section 12
Proposed code amendments:
This ordinance shall apply to all applications for permits to be issued pursuant to chapters 5, 9, and 17,
Hawaii County Code, that are deemed complete by the Department of Public Works on or after the effective
date of this ordinance. An application accepted before the effective date shall be approvable if it meets the
requirements of [ the code [ in effect at the time the
application was submitted.
Justification: To provide consistent enforcement and mitigate financial burden placed on owners to submit multiple
plan review submittals andlor revisions and delay project progress.I
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HPMBUILDBETTERSuitDIMSU. X
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380 KANOELEHUA AVENUE +HILO,HAWAII 96720
PHONE(808)935-0875 FAX(808)934.4355
Prepared by: Darryl Oliveira l
16-166 Melekahiwa Street
Keaau, HI 96749
808) 966-5622
Dar , l.oliveria cx ho ha aii.corn
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Article 1, Section 5-1-5. Definitions, page 5
1) Factory-built home. Request confirmation of citation as noted {5-79, citing Ll 01 .2 of UBC that defines
factory-built housing.} The citation appears to be from the Hawaii County Code 5-79 and referring to IBC
Appendix L not the UBC as specified.
Article 4 Division 2. Pre-approval, Section 5-4-21. Model plans for residential dwellings: pre-approval, (c)
Application for model plan pre-approval (2), page 24
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1) Propose to strike language stating "Factory-built homes shall include a manufacturer's seal as required by
Appendix L of chapter 5A, the commercial building code." Manufacturer's label is the proper terminology
and is not required for plan pre-approval. The label is to be affixed to the structure and therefore not part
of the plans pre-approval process or permitting process. More in line with inspection process as set forth
in Appendix L.I
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aa, Shelly
From: Wilson, Kelly
Sent: Tuesday,June 02, 2020 2:11 PM
To: Tanaka, Neal; Erickson, Neil
Subject: FW: County Codes
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From:Aaron Spielman<aaron@naneastudios.com>
Sent: Monday,June 01, 2020 9:50 AM
To:Wilson, Kelly<Kelly.Wilson@hawaiicounty.gov>
Subject: Re: County Codes
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Hi Kelly—happy Monday. Hope you are keeping your sanity?
Just saw this...do you know why there is not more time to submit amendments?
htt s://bigislandnow.com/2020J05/301count -seeking-input-on-code-amendments/-not the best written article
Anything that you want me to submit?
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I want to submit:
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1. DPW can stop work order for residential or commercial work,without complaint required.The shame game in
Hawaii is outdated,and people need to be held responsible for decisions that affect life safety.3
2. DPW will no longer accept plan-stamped drawings submitted by draftsman.
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Mahalo Aaron
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Aaron J.Spielman,AIA,NCARB i
Principal Architect i
Nanea Studios Inc.
PO Box 437301 3
Kamuela, HI 96743
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v. (808)937-5511 1
e. aaron naneastudios.com
www,na neastud ios.com 3i
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Bata, Shelly
From: Mendonca,Ashlee
Sent: Thursday,June 04, 2020 4:07 PM
To: Tanaka, Neal; Matsumoto, Robyn
Cc: Atalig,Adeloisa; Pent, Naomi
Subject: FW: IECC input
Attachments: 20200604 034906.PDF
Aloha Neal and/or Robyn,
For your review and handling. Received via Public Works email.
Thank you,
Ashlee
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From:Walter Fullerton [mailto:wsfkona@gmail.com]
Sent:Thursday,June 04, 2020 4:02 PM
To: public works email<public_works@hawaiicounty.gov>
Subject: IECC input
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Attached is my input.3
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Thank you for your time,
Walter S. Fullerton
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yVy: 4 [ € ,y .3 .
a . $ .,
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pg S kl ,w ` ,
FYI
Architect F'tConsultant
76-SB56 Kuakini Hwy. , Suite 103
Kailua Kana, Hawaii 96 740 E3®3l 328-9B1 1
June 4,2020
Hawaii County Building Division
West Hawaii Civic Center
745044 Ane Keohokalole HighwayKailuaKona, HI 96740
Comments to consider for adoption of the new construction code for the County of Hawaii.
Proposed Code Amendments, continued research for 5E the energy conservation code.Justification, amend to consider Health and safety issuesContactinformation, See Letterhead
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To whom it may concern:
The IECC was develo ed n the mainland where standards and codes c nsideredprimarilytheFourSeasonsaaaradimcopseuentlaI! thou ht patterns,
concepts, research methods, theories, postulates. and scientific standards formed thepansfortheIECC. There are two Hawaiian seasons described as winter "Kau", NovembertoAprilwithanaveragetemperatureof78degreesFahrenheit, and summer, "Hooilo", with anaveragetemperatureof85degreesFahrenheit. The average temperature difference is 7dereel (emphases added).
There are_obvious omissions and conflicts in the IECC/HCECC Extremely important fortheHawaiiIslandsarehumidity, mold, dry rot, fungi, and mildew, which have been virtuallyignored. Average ambient relative humidity in Hawaii, ranges from the 60's to the 80's. Fungigrowsintemperaturesfromfibto87degreesFahrenheitandarekilledat104degreesFahrenheit, which means that the year around temperature range in Hawaii is nearly perfectforfungigrowth. Fungi growth is encouraged by high humidity. The high humidity in Hawaii,exacerbates Respiratory disease conditions such as asthma, colds, flu, and pandemics. AllbuildingsandoccupantsareatriskwhenbuildingsarenotallowedtobreatheColds,flu, and certain other respiratory conditions caused by high humidity needs to be carefullyconsidered.
Building Mycology:
Building affects the health of occupants in many ways, for example, Building RelatedIllnessesBRISickByfidingSyndome ,RBS Rlesviratory Syncytial Virus RSVAllergyandEnvironmentalHealthProblems {AEHP) The most common building healthproblemsareattributedtothelackofnaturalandproperventilation, dampness andcondensationresultinginmoldgrowth, mildew, house dust mites, airborne fungi spores, and a
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range of other fungal and insect pests, aggravating respiratory problems and allergies. We
must learn the basics learned from the past and present flu and pandemics. The population
spends 90 percent of their time indoors.
Hawaii County has eight recognized climate zones and two subordinate sub zones. The
other islands in Hawaii, have apparently, not identified climate zones. Most residents of
Hawaii live on the coastal areas where year around temperature averages are comfortable as
compared to all other States. Heating and/or cooling (HVAC), for single family dwellings has
not been required or necessary. When HVAC is required by a client, Architects, Mechanical
Engineers, and the IECC should apply. Relative humidity defines comfort levels and needs to
be considered seriously! Over 90 percent of construction on the Island of Hawaii is
single family residential without HVAC1
It is unfortunate that Hawaii is being subjected to serious energy measures prevalent
in temperate zones and the erroneous heat loss adaptations for heat gain in our 1
tropical zone. The result of the IECC standards, for most of Hawaii, are the significant
increases in the already high construction costs and Building Permit delays.
Protection of the public life safety must be the first consideration!
I strongly encourage that Hawaii County reexamine the Hawaii County IECC with licensed
professionals. At present, confusion is rampant!
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Walter Stewart Fullerton, Archi LI D
Expiration: 4-30-2022
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Bata, Shelly
From: Val Colter <val.colter@yahoo.com>
Sent: Tuesday,June 02, 2020 7:09 PM
To: Building Div internet mail
Subject: Fw:Testimony in OPPOSITION to portions of new Public Works Bill
I could rewrite all this in my own words. But why? I agree with Taylor 100%
Aloha,
Val Colter
808-769-2949
val.colter@yahoo.com
Forwarded Message-----
From: Taylor McMahel <tmcmahel@yahoo.com>
To: cohbuild@hawaiicounty.gov<cohbuild@hawaiicounty.gov>
Sent: Tuesday, June 2, 2020, 1:57:29 PM HST
Subject: Testimony in OPPOSITION to portions of new Public Works Bill
Testimony in OPPOSITION to portions of new Public Works Bill
Aloha;
I would like to offer my feedback I testimony in OPPOSITION to certain portions of the
drafted Public Works Bill. In particular, my two (2) points of opposition lie in the plan review fees
section 5-7-1), as well as the timelines given in building permit applications (section 5-4-6).
I understand the needs for a review plan fee to help cover the expense of county
departments reviewing and approving a building permit application, then the owner either (a) changes
their mind on the design and subsequently cancels the application, or (b) owners sell the land and
new owners cancel an application so they may design their own. With the cancellation, the county
does not get any fees to cover their time spent.
However, I am in opposition to the fee schedule of increasing the plan review fee depending
on the amount of times a plan is returned for corrections.
As a draftsman myself, I have encountered numerous times where one (1) plan reviewer
would reject the plans for a correction, then another plan reviewer would review it after a correction is
done and subsequently reject based on their review for a different issue altogether. The proposed
plan fee increases would open the county reviewers to "penalize" any draftsman or owner they do not
like, either professionally or personally. In addition, it could open the doors for the countyto
encourage rejections, just to increase profits.
The fee schedule is not clear either if the rejection "count" is based on all departments that
review the set of plans, or only the building division. This is important because each department has
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their own set of regulations and if each department rejects it just once for petty things, that could be
between 4 or 5 rejections total. Currently policy is all departments are to review the plans and reject
at the end, but that is not happening consistently.
This could encourage abuse by county personnel.
If this situation was to occur, it stands to reason that every time a plan is rejected, it is easier
and financially more viable for the client to "cancel the application", correct the drawings, and then
resubmit new. Five (5) resubmittals at $50 proposed is cheaper than the schedule shows for the
same plan being returned five times. Is the county willing to do all those cancellations and new
applications that will happening just so clients don't pay so much. (Keep in mind the way it is written,
the increase in fee structure is for the same application, not subsequent ones with different
application numbers)
I feel a better option would be for the county to review the plans as a "team" and all
be on the same page of what is needed. Many times, I have been asked to provide things that are
clearly not required in the published regulations, but the next project I do with the same situation does
not need it because someone else reviewed it.
To minimize the amount of times a project is returned for corrections, the county should be
proactive and complete their rejection notices accurately. So far, all they do is note what is rejected,
but do not reference a section of the code they are basing the rejection on, even though that portion
reference) is on their rejection page. This would help draftsman, even owners that submit their own
plans, from knowing where to look for clarification.
The second portion of the bill I strongly oppose is the time deadlines currently (section 5-4-
6). 1 know from experience some owners leave their projects at the county for months on end,
sometimes even years. But the time lines given in the bill are not long enough.
The county is proposing 30 days to pickup a permit or plan review letter (section 5-4-
6a). What if the owner is out of state and needs to pickup a permit? Currently, the county only
accepts original signatures for all paperwork, so currently, we as the draftsman, needs to pickup the
application and mail to the out of state client, then wait for them to sign it and return it. The proposed
time frame is not adequate in case of unexpected emergencies (incoming hurricane that will delay
mailings, pandemics, etc.)
In some situations, a customer needs to get a check from the bank as part of a "draw" for
their permits, and those can take time as well. Please consider given a longer time frame.
In section 5-4-6b, it mentions that if"action" is not taken within 60 days of picking up a
rejected application, the application is deemed cancelled. In some situations, 60 days is not needed
if the rejection is asking for a new design, or if the rejection is asking for additional structural calcs
the two portions of an application that can take the longest to accomplish). What does it mean
action", and how would the county work with the design professionals if it is determined a correction
is in the process of being completed, but not within the timelines.
A more reasonable correction to all time lines would be 180 days.
2
Please reconsider the portions of the bills referenced above and please consider how it
would impact owners, which we are all trying to serve, with a goal of mutual understanding and
respect between everyone.
ahalo for allowing me to submit this testimony.
Taylor McMahel
McMahel Design LLC
Owner of McMahel Design LLC, a drafting company servicing the state since 2000
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ata, Shelly
From: Alayna Kilkuskie <alaynakilkuskie@gmail.com>
Sent: Friday,June 05, 2020 5:20 PM
To: Building Div internet mail
Subject: Input Sought on Upcoming County Code Changes
Sorry I'm a bit late!
The following are observations and questions/issues that arose while reviewing the proposed construction
code.
Thanks for your consideration! U
Alayna Lokelani Kilkuskie I Architect
ph.530-219-2897 ( aiavnakilkuskie@gmail.com
74-5606 Pawai PI.Ste. 204 ( Kailua-Kona, Hawaii 96740
License#AR-17390
A. Regarding: Section 5-3-3 (b) (3): Temporary permits required.
Structures, buildings, platforms, construction trailers, water tanks, or fences used during the construction of a
permitted structure.
Issue:
There doesn't seem to be any description of the application process for temporary permits, namely, how long it
might take for a temporary permit to be issued, and what is required for approval.
If it is subject to the same process for a regular building permit, this will greatly increase the timeline for
completing projectS.
Proposed solutions:
1. Omit item 3) and reinstate its original position under previous Chapter 5 section 5-19.1 (and per IBC
2012 105.2 (8)); OR
2. Describe the temporary permit process and add a time limit, i.e. a temporary permit will be issued within
5 working days.
B. Regarding: Section 5-3-22 (C)---
Issue: Does this mean that any attached decks under 30" above grade will now require a building permit? For
example, if someone wants to add a deck to their existing house, or extend their existing deck, they now j
require a building permit even if it's under 30" above grade? Does this apply to slabs as well?
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C. Regarding: Section 5-3-22 -
Issue: Previous Chapter 5 section 5-19.1 (5) has been omitted--- does this mean that TV and radio equipment
accessory to R-1 and R-3 occupancies will now require a building permit?
D. Regarding: Section 5-4-1 (8, 9, 10): Application for permit.
Issue: People generally need time to "shop around" for contractors once the plans are completed. Requiring
this information at the time the plans are submitted will likely cause delays and potential for changing them
later.
Proposed solution:
1. Give applicants the option to submit the information at the time the application is submitted OR prior to
issuance of the building permit. This way, they will have the time between submitting the application
and issuance of permit to find contractors, and be less likely to change contractors later.
E. Regarding: Section 5-4-6 - Cancellation of application.
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Issue: Verbiage is hard to understand here--- Do we have 30 days or 60 days? Does this mean we have 30
days to notify you that we are working on it, and an additional 30 days to re-submit?What happens on day 31?
F. Regarding: Section 5-7-5. Extra or regulatory inspections
Issue: Previous Chapter 5 section 5-36(b) has been removed. So what about people who want an inspection
where no permit has been issued, or are seeking general requirements regarding the health, safety, or welfare
of people?
G. Regarding: Section 5-8-2 (b) (1) Residential Installations.
In residential installation, if the permitted work is covered or concealed without an inspection, the contractor
will provide verification that the concealed work complies with all the provisions of the construction code in a
letter stamped and signed by the professional of record who is licensed in the State of Hawaii, as an architect
or professional civil or structural engineer.... "
Further, section 5-43 (e) of previous Chapter 5 states "Owner builders will be required to have inspections,
unless done by a licensed contractor or certified by licensed architects/engineers" has been removed.
Issue: Is it being proposed that the only condition that architects and engineers will be allowed to conduct
inspections is if the AHJ does not respond within 2 days after the scheduled inspection?
H. Regarding: Appendix Y, Tiny Houses.
Issue: Appendix Y does not address the use of approved trailers in lieu of traditional foundations. Is this code
proposing that tiny homes cannot be built on trailers?
1. Regarding: Y105.1.5- Maximum loft size.
The aggregate floor area of a loft shall not be greater than one-third of the floor area of the room or space in
which they are located."
Issue:
If a tiny house is 20' x 8', then the maximum loft size is 53.33 sf, or 8'x 6.67' This is barely larger than a queen-
sized bed (roughly 5' x 7'). It is likely that a loft would be especially needed the smaller the footprint becomes,
but with this provision, the loft gets smaller as the total footprint decreases...
Proposed Solution: Increase the ratio?
J. Regarding: Y105.2.3 ---Alternating tread devices.
Issue: This section references lofts with a maximum of 200 sf.
If the definition of a tiny house (Y102) states a maximum area of 500 sf, and Y105.1.5 states that the loft can't
exceed '1 of the room that it's in, then the absolute maximum a loft can ever be is 500sf/3= 166.67 sf, not 200
sf...
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Virus-free. www,avast.com
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Bata, Shelly
From: Shaun Roth <shaunroth@hawaii.twcbc.com>
Sent: Wednesday,June 03, 2020 11:55 AM
To: Building Div internet mail
Cc: Matsumoto, Robyn;Tanaka, Neal
Subject: Input Sought on Upcoming County Code Changes
Attachments: 2020-CofH-ConstructionCode-Comment-ShaunRoth-060320.pdf
County of Hawaii;
I am submitting comments and suggestions related to the CONSTRUCTION CODE-DRAFT 5126120.
Onepdf file is attached.
Aloha,
Shaun Roth,AIA
Roth Kimura LLP
PO Box 624, Holualoa HI 96725
808-324-6073 office
shaunroth@alum.mit.edu
1
Hawaii County 2020 Draft Construction Code Shaun Roth,AIA
Comments on 5/26/20 proposed code amendments June 3, 2020
The following comments, proposed code amendments, and justification are submitted by Shaun Roth.
These are my personal comments and do not necessarily reflect the position of AIA Hawaii State Council,
AIA Honolulu, or AIA Hawaii Island Section.
Shaun Roth,AIA
Roth Kimura LLP
PO Box 624, Holualoa HI 96725
808-324-6073 office
shaunroth@alum.mit.edu
Chapters 513 and 5C
Question:Why are these chapters not included in this draft of the construction code? In section 2 of the
proposed ordinance it appears as though Chapter 5 is repealed in its entirety. Chapter 5A is intended to
apply to commercial construction. Where does one go for residential construction during the period
before Chapter 5B is adopted? If residential is intended to use Chapter 5A for the interim that confuses
the new structure of the Construction Code. Not including Chapters 5B and 5C at this time will require
more extensive modification to Chapter 5 when those chapters are adopted.
Suggestion: Why not include abbreviated Chapters 5B and 5C and use those chapters to clearly state
how these types of construction will be treated in the interim. e.g. Chapter 513, R-3 uses chapter 5A or
the 2012 IRC with State amendments until the IRC is adopted by the County;Chapter 5C, existing
buildings use 2006 IBC Chapter 34 until the existing building code is adopted.
Section 5-1-4. Existing Buildings
Comment:The IBC version is given in Chapter 5A but not in Chapter 5, Section 5-1-4(b)
Comment: It appears that the twelve month period and valuation criteria for upgrade requirements is
being deleted in favor of an unamended IBC Chapter 34. It appears this will make the code more
restrictive in some cases and less restrictive in others.
Comment: Previous IBC amendments to 2006 IBC sections 3405.1 and 3410.3.2 are no longer included.
These may not be needed since there is no longer valuation criteria.
Section 5-2-22
Comment: Good to see the code explicitly support used material.
Pagel of 4
Hawaii County 2020 Draft Construction Code Shaun Roth,AIA
Comments on 5/26/20 proposed code amendments lune 3, 2020
Section 5-3-22. Building work;exempt
Comment: (a)(4) replacement for maintenance of components, $4,000 permit threshold. This is far too
low for this category. A single door panel can cost$4,000. It is ridiculous for an owner to have to go
through the whole permit process to replace a couple of doors with the same,thus many won't get
permits. The value was too low before, and is still too low. Electrical and Plumbing don't have the
valuation threshold for repairs,why do other repairs need it?
Suggestion:Value should be changed to $10,000 or eliminated.
Section 5-4-1.Application for permit
Comment: (a)(8)(9)(10) information for each contractor or subcontractor engaged to do work.At the
time of building permit submittal all of the contractors and subcontractors for a project my not have
been selected.
Suggestion:This section should explicitly allow this information to be provided at a later time.
Section 5-4-2. Plans,specifications,and other data.
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Comment: (c)(1) it appears that 24"x36" is the only sheet size that will be accepted.
24x36 is excessively large for some small projects and may not be large enough for other projects.
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Suggestion: It would be better to have a range, maybe 11x17 minimum to 36x48 maximum.
Suggestion: (c)(4)(E)Certified flood zone elevation mark should be explicitly exempted for renovations
and alterations which are not changing existing floors or adding additional floor area.
Section 5-4-3. Engineers and architects;work
Suggestion: (b)(2)Trusses manufactured per 2006 IBC section 2303.4.2 Metal-plate-connected trusses,
2012 IBC section 000, 2012 IRC section R802.10.2 & R804.3.7. The truss manufacturer's design print-
outs which include the design drawing data listed in the IBC/IRC should be accepted with a single cover
stamp.
Comment:
c)(2) No architect or engineer required for R-3 under 600 sf.
c)(7)Structures in high seismic zones. For Hawaii Island it very often requires an architect and/or
engineer to determine if a project is in Category E. Use and configuration of construction can determine
if a location that might normally be E can be constructed as D2 and vice versa.
Suggestion: Eliminate the exemption for structures under 600 sf.
Suggestion: (d)consider changing the retaining wall height requiring a permit from 48"to greater than
30". A 4' high un-designed retaining wall can be very dangerous. 30"would be consistent with the i
requirement for decks.
Suggestion:tion: (h) HVAC design for one and two family single-family dwellings should be able to use IRC 3
prescriptive design in lieu of an engineer.
Page 2 of 4
Hawai'i County 2020 Draft Construction Code Shaun Roth,AIA
Comments on 5/26/20 proposed code amendments June 3, 2020
Section 5-4-6. Cancellation of application.
b)Thirty days to take action on deficient application. (c) 180 days to obtain permit.
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Question: How is it solely the applicant's responsibility to secure a permit within a 180 day time frame
when the County and State control the review times? Some SHPD reviews require that a building permit 1
application be made before they will start looking at a project,then their timeline can be years.
Suggestion: Time should be counted against the 180 days only when the application has been returned
to the applicant for corrections. Time in County or State review should not be counted.
Section 5-5-3. Designation of person, contractor,or subcontractor who will do work.
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Comment: If the new"one permit" requires that plumbing and electrical subcontractors are selected
before the issuance of the building permit that will be a big problem for many projects.
Section 5-4-7.Applications made prior to subsequent changes in applicable laws.
Comment:Same question and suggestion as Cancellation of Application section.Time in County or State
review should not be counted against the 180 days.
Section 5-7-3. Permit
Comment: (b) Fee Schedule. Dwellings over 1,401 sf fees are no longer based on square footage unless
it is a pre-approved model plan. Item C from the old fee table was moved into the pre-approved table in
section 5-7-2 but was not included in section 5-7-3 (b).
Question: (c)Valuation. The ICC building valuation data appears to require a permit fee multiplier
unique to each jurisdiction in order to calculate a valuation. Where will this value be published? How
often will it be updated?
Chapter 5A.Article 2.Section 5A-2-1
Comment:The previous adoption of the 2006 IBC, Chapter 5 Section 5-3, adopts the 2006 IBC,excludes
Chapter 1 of the IBC.
This ordinance does not appear to exclude Chapter 1 yet many of the sections in Chapter 5 are covering
similar topics. This could lead to confusion over which sections are applicable.
Comment:At the end of this section the draft ordinance says"insert rest of provisions presently found
in 5-71,5-74 through 5-76,and 5-78 through 5-83
The current amendment to section 903.2.7 Group R.Automatic sprinkler. is brought in and continues to
exempt R-3 from the sprinkler requirement.
Chapter 5E. Energy Conservation Code.
Comment:There does not appear to be any changes to the previously adopted amendments to the 2015
IECC. If changes have been made the County should make professionals and the public aware of them.
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Page 3 of 4
Hawaii County 2020 Draft Construction Code Shaun Roth,AIA
Comments on 5/26/20 proposed code amendments June 3, 2020
Chapter 5F. Plumbing.
Suggestions:
Section 505.4.5 Access.An exception should be added. No permanent ladder required for R-3
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Section 1101.11.1 Primary Roof Drainage.An exception should be added. No roof drains or
gutters required for R-3 roofs without parapets.
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SECTION 13.
Suggestion:Since the exact date of final approval will not be known in advance the effective date should
be two weeks after approval so that there is time to notify design professionals and the public.
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Page 4 of 4
Bata, Shelly
From: Wendy Laros <wendy@kona-kohala.com>
Sent: Friday,June 05, 2020 2:49 PM
To: Building Div internet mail
Cc: Dennis Boyd
Subject: Kona-Kohala Chamber Input for County Code Changes
Attachments: Kona-Kohala Chamber Code Comments lune 5, 2020.pdf
Aloha Department of Public Works Building Division,
Attached you will find comments from the Kona-Kohala Chamber of Commerce Permitting Task
Force on Hawaii County's proposed new Administrative Code Bill, Chapter 5.
Please note, we apologize if some of this information doesn't line up, but we did our best to provide
comments to specific areas in the code.
Would you be so kind to let me know that you received this email and have the document with our
cover letter and comments? Appreciate it!
Sincerely,
Wendy J. Laros,
Executive Director, Kona-Kohala Chamber of Commerce
Kona-Kohala Chamber of Commerce
75-5737 Kuakini Hwy, Ste. 208
Kailua-Kona, HI 96740
808) 329-1.758
wendy@kona-kohala.com
1
Kona = Kohala
CHAMBER OF COMMERCE
June 5, 2020
David Yamamoto, P.E.
Department of Public Works Director
County of Hawaii
101 Pauahi Street, Suite 7
Hilo, Hawaii 96720
Dear Mr. Yamamoto,
Attached you will find comments from the Kona-Kohala Chamber of Commerce Permitting Task
Force on Hawaii County's proposed new Administrative Code Bill, Chapter 5. The Chamber
has designated Permitting as one of its top three priorities. Our Permitting Task Force includes
Chamber members from throughout the development and small business community who have
been working for over a year on developing input to support improvements and efficiency in the
county permitting process.
These efforts began as a result of Chamber members' consensus that the current Hawaii
County permitting process constitutes a significant barrier to economic development and that it's
in all of our best interests to work towards clarification of the process, the regulations, and the
practice of permitting in the county. Now, with the current economic crisis that places a premium
on innovative thinking and efficient execution, those interests are more apparent than ever
before.
The Permitting Task Force has heard firsthand from the Department of Public Works and
County Council personnel regarding the current status of permitting in the county and plans for
the future, is participating in EnerGov implementation planning, and has had wide-ranging
discussions and solicited input from concerned parties in the business community. These efforts
have all contributed to our comments.
We are concerned that while the proposed Rules as currently constituted include many
deadlines and requirements for the public, there are none for the county.
We look forward to working with the Council's Committee on Public Works, the Council at large,
and the Department of Public Works in continuing efforts towards the development of a
permitting process that works more efficiently for all the parties in the community.
Sincerely,
Wendy Laros Dennis Boyd
Executive Director Permitting Task Force Chair
Kona-Kohala Chamber of Commerce Kona-Kohala Chamber of Commerce
1
Kana-Kohala Chamber of Commerce
75-5737 Kuakini Highway, Suite 208( Kailua-Kona, Hawaii 96740
info@kona-kohala.com (808-329-1758 1 www.kona-kohala.com
i
i
i
Konawlohala
CHAMBER OF COMMERCE
I
Kona-Kohala Chamber of Commerce
Permitting Task Force Comments on Proposed Chapter 5, Construction Code
June 5, 2020 i
5-1-4i4
Establish methods for non-compliant/as-built buildings to "catch up"
Older as-built structure to be reviewed based on the code in effect at the time of construction,
which would be determined by property's appearance in Real Property Tax record
Have a free code compliance inspection option for people to get older homes inspected by
Building officials without fear of a notice of violation and encourage them to update
Eliminates punitive measures and promotes re-use and potential upgrade of existing
structures 4
5-1-5
Either delete requirement for Director of PW to be an Engineer or add to requirements MBA or
significant administrative experience (realize this is a Charter Amendment issue)
Administration and public accountability are totally different from engineering, and
qualification changes realign the position's duties with the actual jab
i
5-1-5
Add Replacement Cost Definition using the Uniform Standards of Professional Appraisal
Practice (USPAP)
Replacement Cost is the Estimated cost to construct, at current prices in Hawaii as of the
effective appraisal date, a substitute for the building being appraised, using modern materials
and current standards, design, and layout as determined by a Hawaii licensed property
appraiser, or shall be the value set by the national average in the IBC Building Valuation Data
plus 70% Hawaii cost factor as defined by USPAP or a Hawaii licensed property appraiser."
Common-sense and consistent methodology
5-2-2
Adopt Rules Making Structure
Codifies procedurelensures predictability
5-2-23
Encourage alternative new building techniques (local materials, liaison with UH R&D, adopt
affordable housing "smart Code", update zoning to allow more creative neighborhoods,
encourage and facilitate ohana or second dwellings, support 3D printed concrete housing)
Promote sustainability, innovation, cost savings, addresses affordability
2
Kona-Kohala Chamber of Commerce
75-5737 Kuakini Highway, Suite 208 1 Kailua-Kona, Hawaii 96740
info@kona-kohala.com 1808-329-1758 1 www.kona-kohala.com
KonawKohala
CHAMBER OF COMMERCE
i
5-2-3
Collect, calculate, and report Building Division performance data
Establish and enforce meaningful performance measures for the Division and
personnel
Implement an internal audit function
Adds accountability and transparency for a government function that is currently lacking,
forms the basis for continuous system improvement
5-3-22
Eliminate need for Site Drainage Study if no change to permeable surfaces, or run off changes
1% of property size
Unnecessary
5-3-22(4)
Change value of threshold repair costs
4000 is a 9973 valuation—in 2020 dollars that is$23,098
5-3-23
Allow Electrical Contractor as sufficient for authorized work for residential, small Ag, as-built
work<200 amp
Simplification, few safety concerns
5-4-1
Create a separate `track"for Residential and Commercial plan reviews; within Commercial track
separate New Build from Tenant Improvements
Prioritizes building application types, allows less complex applications to be reviewed
quicker
5-4-1
Adopt a consistent checklist of intake items and a flow chart of the permitting process clearly
denoting the sequence of required submissions and inspections that can be expected
Eliminates customer confusion
5-4-1(b)
RE paper vs electronic submission, language change: "After the authority having jurisdiction
implements its electronic filing system, applicants may must submit documents in wFitiRg er
electronically."
The county is moving to electronic review that requires electronic submission. An
applicant who is unable to submit electronically can come to the counter and be assisted
to create an EnerGov account and file. Planning and Public Works will have counter
kiosks in Kona and Hilo for this purpose.
3
Kana-Kohala Chamber of Commerce
75-5737 Kuakini Highway, Suite 2081 Kailua-Kona, Hawaii 96740
info@kona-kohala.com 1808-329-1758 1 www.kona-kohala.com
Cft)Ar Konawlohala
CHAMBER OF COMMERCE
5-4-2(c)(4)
Eliminate absolute requirement for plot plan detail for properties over 20 acres or some size limit
Super excessive on large acreagelranches
5-4-3(c)(2)
Wording
single story structure of more than 600 square feet"
5-4-3(h)
Add "or architect" as authorized profession for mechanical plans
Eliminates architect for residential work. See state statute 464-1, which allows architects
to perform professional services . . .in connection with any projects or the equipment or
utilities thereof, or the accessories thereto". Also, former County wording, Section 5-
25(c)— "all plans . . . for which a building permit is required shall be prepared, designed
or stamped by a duly registered professional engineer or architect"
5-4-3 (1)
Re threshold requirement for plumbing plans: Excessive regulation for dwellings > 4 bathrooms
No additional threat to life or safety in a large residence
5-4-3; 5-5-1
Eliminate new building permit requirement for minor electrical or plumbing add-ons during
construction (e.g., single circuits, up to 10 switches, one plumbing fixture of a given type, etc.)
Issue supplemental E/P permit only. Ditto for>5% residential square footage additions
Recognition of the realities of construction exigencies; time saver at no safety risk
5-4-4
Piggyback fast track permitting as incentive in designated special use districts, e.g., Opportunity
Zone, Affordable Housing, other areas with relationships to other County priorities to be
determined
Boost existing development that boosts the community
5-4-4
Remove Fire Dept from the Review Process as currently configured and hire dedicated Fire
Code reviewers within the Building Dept
Eliminates a role inconsistent with the main purpose of FD personnel duties and
eliminates cross-department delays
5-4-4
Eliminate SHPD (historical preservation) review for interior tenant improvements
Unnecessarily time consuming and generally irrelevant to SHPD mission
4
Kona-Kohala Chamber of Commerce
75-5737 Kuakini Highway, Suite 208 1.Kailua-Kona, Hawaii 96740
infoa@kona-kohala.com 1808-329-1758 1 www.kona-kohala.com
Kona = Kohala
CHAMBER OF COMMERCE
5-4-4
Allow option for third party plan review by accredited professional review organizations at
applicant expense
Reduces DPW workload, expedites process
5-4-4; 5-8-
Develop system to reduce inconsistency from different reviewers and inspectors—establish and
adhere to protocols
Builds in efficiency as builder knows what to expect from prior experience
5-4-5
Establish system where, upon satisfactory response to first round of reviewer comments any
new comments denying permit must be directed to what the reviewer determines to be an
additional problematic area, not the same one already corrected but with another set of eyes
looking at it
Controls multiple "bites at the apple"and defends against reviewer inconsistency
5-4-6 (a) and (b)
Make days consistent on permit pickup and applicant action
30 days too short a time, both 30 and 60 days quoted in (b)—make all 60 days
5-4-6(c) 5-4-7
Too short a time to obtain permit
Unless this is intentional benchmark for County, does not consider County delays
5-4-21 c; 5-4-21 f2
Adopt e-filings and e-signatures instead of wet signatures
Consistent with modern usage in every other professional field and with EnerGov
implementation
5-5-1(c)
Language revisions on permit issuance: "The authority having jurisdiction may shall issue a
permit . . . provided ante all pertinent information and detailed statements . . ..
5-7-3(h)
RE exemption from permit fees, add "(3) or any project by a registered 501.c.3 non-profit
organization"
5
Kona-Kohala Chamber of Commerce
75-5737 Kuakini Highway, Suite 208 1 Kailua-Kona, Hawaii 96740
info@kona-kohala.com 1808-329-1758 1 www.kona-kohala.com
i
KonaaaKohala
CHAMBER OF COMMERCE
i
5-5-6
Develop reliable, consistent repository of archived permit records and a process to prove out
missing permits
Solves problem of missing or unreliable permits, codifies what records (e.g., HELCO
records, field book) can be used to substantiate initial permit and usage
5-7-1(b)
RE additional plan review fees, add phrase at end of sentence after"submittal'to cover review
omissions: "caused by the applicant. No fee shall be charged for subsequent submittal cause
by a reviewer error or oversight."
5-7-1(c)
RE Permit fees, delete paragraph
Excessive for minor revisions
5-7-3(c)
RE Valuation of construction costs, change language to "the most recent issue of the
International Code Council building valuation data"
5-7-3(d)
Remove punitive penalties for work begun without permit
Does not necessarily create more compliance
i
5-7-5(b)
RE fees for extra inspections, delete paragraph
Should be part of the more expensive permit fees
5-11-1
Adopt a simple Building Code Variance process
5A-1-5
Unclear if intention is to include language regarding "As Built" construction here or elsewhere,
but it needs to be addressed in more detail in the Rule
5D-1-3
Eliminate requirement for Electrical Engineer to do the electric plan pages for an R3 residence
A licensed contractor taking responsibility is assurance enough
Eliminate need for an Electrical Engineer for work on one 110 V circuit provided work is done by
licensed electrician
Notjust on his or her own property but for all R3 properties
6
Kona-Kohala Chamber of Commerce
75-5737 Kuakini Highway, Suite 208 1 Kailua-Kona, Hawai"i 96740
info@kona-kohala.com 1808-329-1758 1 www.kona-kohala.com
ata, Shelly
From: Joe Belisario <joe@hawaiidesigngroup.com>
Sent: Friday,June 05, 2020 7:34 AM
To: Building Div internet mail
Cc: Kim, Harry; Kamelamela,Joe;Yee, Michael;Yamamoto, David;Tanaka, Neal; Matsumoto,
Robyn
Subject: New Construction Code, comments to draft bill
Aloha
The new construction code actually has some good stuff in it. However there are some internal personnel
and culture of execution that is not addressed these key obstacles are still there,which destines this new code
to multiple interpretation and changes as we experience today with the current code. I submit my comments,
but I'm sure they will fall on deaf ears. Here are some ofthe recommendation and thoughts that may make the
changes to any part of the code more efficient and evenly applied to community as whole
1. Public Notification: Draftsman and Licenced professionals started spreading this document around on
Sunday May 31st media releases came on June 2nd and 4th. via AIA Shaun Roth resulting in 5 days to
comment on a 116 page document.
Solution: HOLD until proper responses can be made,rather than 5 days notice from Social media and the
coconut wireless.
2. Directors Still have the ability to make rules, and we know that dosent work, Solution? Rule making by
committee with public input and county council approval based on thier districts needs and concerns.
3. Deputizing county employees: it appears the new code will allow the director to deputize a county employee
to change work description i.e plan reviewer to inspector, Clerk to inspector ? this point is not defined
clearly,which leads me to my next point.
4. Educational Qualifications: ALL Planning and DPW employees should have a minimum 2 year Associate in
Science degree or equivalent in plan reading, and or drafting technology , I'm all for OJT just not in this field of
work. At the very least any applicant will have the basic knowledge of plan development and the ability to read
it. I know for a fact that we have un or under qualified persons on levels in thier chain of command. equal to
have 2 year med student doing surgery.
5. I love the one time review, very good part if executed efficiently.
6. 30 days to return corrected work: This is unreasonable as some rejections could entail justification of the
rejection, and or just plain technical complexity ofthe revision. not to mention, COH vacations, sick calls,
etc. a lot ofthese positions are one man shows. Passing a rejection
response to another reviewer has inherent problems which we experience today
7. To implement these code changes under the current mechanism of execution will result in the same or worse
debacle we the public experience today. The mechanism of execution needs an overhaul
i
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CONFIDENTIAL COMMUNICATION
This email message and any attachments are intended only for the use ofthe addressee named above and may
contain information that is privileged and confidential. If you are not the intended recipient, any dissemination,
distribution, or copying is strictly prohibited. If you received this email message in error,please immediately
notify the sender by replying to this email message or by telephone. Thank you.
2
Bata, Shelly
From: Jim Brown <JCBrown_99@yahoo.com>
Sent: Friday,June 05, 2020 8:53 AM
To: Building Div internet mail
Subject: Proposed amendment County Building Code
I would like to submit the following additions for consideration:
Article 6, Sec 5-6-1 should allow for owner builder to obtain a permit for work without identifying an electrical or plumbing
contractor. For small projects owner builders should be able to obtain permits and then shop the project to multiple
licences contractors. This would give more control to the home owner.
Article 6, Sec 5-6-2 should allow for owner builders to perform limited electrical and plumbing work without hiring a
licensed contractor. As the code is currently written, a home owner cannot even change a light switch without hiring an
electrician. This is cumbersome, and possibly causing small jobs that should be permitted to go unregulated creating a
safety hazard.
Thank you.
Jim Brown
1
ata, S ell
From: Jim Brown <JCBrown_99@yahoo.com>
Sent: Friday,June 05, 2020 8:53 AM
To: Building Div internet mail
Subject: Proposed amendment County Building Code
I would like to submit the following additions for consideration:
Article 6, Sec 5-6-1 should allow for owner builder to obtain a permit for work without identifying an electrical or plumbing
contractor. For small projects owner builders should be able to obtain permits and then shop the project to multiple
licences contractors. This would give more control to the home owner.
Article 6, Sec 5-6-2 should allow for owner builders to perform limited electrical and plumbing work without hiring a
licensed contractor. As the code is currently written, a home owner cannot even change a light switch without hiring an
electrician. This is cumbersome, and possibly causing small jobs that should be permitted to go unregulated creating a
safety hazard.
Thank you.
Jim Brown
1
Bata, Shelly
From: Heidi Jaworski <mskonasunshine@gmail.com>
Sent: Monday,lune 01, 2020 4:21 PM
To: Building Div internet mail
Subject: Re: Comments Regarding Updating county building codes
Seriously Hawaii County Building Department, why bother-when there is only enforcement in very few places. Why
not work on updating the system to actually provide enforcement on existing codes? Many rural areas here are full
of completely unpermitted shacks and dwellings where NO county codes have ever been followed. This brings down
property values for the law abiding residents, poses a fire danger to everyone, and also poses health dangers
because of dwellings with no septic or other way to effectively deal with human waste.
Heidi Jaworski
Ocean View, Hawaii 96737
t
ata, Shelly
From: Taylor McMahel <tmcmahel@yahoo.com>
Sent: Tuesday,lune 02, 2020 1:57 PM
To: Building Div internet mail
Subject:Testimony in OPPOSITION to portions of new Public Works Bill
Testimony in OPPOSITION to portions of new Public Works Bill
Aloha;
I would like to offer my feedback/testimony in OPPOSITION to certain portions of the
drafted Public Works Bill. In particular, my two (2) points of opposition lie in the plan review fees
section 5-7-1), as well as the timelines given in building permit applications (section 5-4-6).
1 understand the needs for a review plan fee to help cover the expense of county
departments reviewing and approving a building permit application, then the owner either (a) changes
their mind on the design and subsequently cancels the application, or (b) owners sell the land and
new owners cancel an application so they may design their own. With the cancellation, the county
does not get any fees to cover their time spent.
However, I am in opposition to the fee schedule of increasing the plan review fee depending
on the amount of times a plan is returned for corrections.
As a draftsman myself, I have encountered numerous times where one (1) plan reviewer
would reject the plans for a correction, then another plan reviewer would review it after a correction is
done and subsequently reject based on their review for a different issue altogether. The proposed
plan fee increases would open the county reviewers to "penalize" any draftsman or owner they do not
like, either professionally or personally. In addition, it could open the doors for the county to
encourage rejections, just to increase profits.
The fee schedule is not clear either if the rejection "count" is based on all departments that
review the set of plans, or only the building division. This is important because each department has
their own set of regulations and if each department rejects it just once for petty things, that could be
between 4 or 5 rejections total. Currently policy is all departments are to review the plans and reject
at the end, but that is not happening consistently.
This could encourage abuse by county personnel
If this situation was to occur, it stands to reason that every time a plan is rejected, it is easier
and financially more viable for the client to "cancel the application", correct the drawings, and then
resubmit new. Five (5) resubmittals at $50 proposed is cheaper than the schedule shows for the
same plan being returned five times. Is the county willing to do all those cancellations and new
applications that will happening just so clients don't pay so much. (Keep in mind the way it is written,
the increase in fee structure is for the same application, not subsequent ones with different
application numbers)
1
I feel a better option would be for the county to review the plans as a "team" and all
be on the same page of what is needed. Many times, I have been asked to provide things that are
clearly not required in the published regulations, but the next project 1 do with the same situation does
not need it because someone else reviewed it.
To minimize the amount of times a project is returned for corrections, the county should be
proactive and complete their rejection notices accurately. Bo far, all they do is note what is rejected,3
but do not reference a section of the code they are basing the rejection on, even though that portion
reference) is on their rejection page. This would help draftsman, even owners that submit their own
plans, from knowing where to look for clarification.
3
I
The second portion of the bill I strongly oppose is the time deadlines currently (section 5-4-
6). 1 know from experience some owners leave their projects at the county for months on end,
sometimes even years. But the time lines given in the bill are not long enough.
The county is proposing 30 days to pickup a permit or plan review letter (section 5-4-
6x). What if the owner is out of state and needs to pickup a permit? Currently, the county only
accepts original signatures for all paperwork, so currently, we as the draftsman, needs to pickup the
application and mail to the out of state client, then wait for them to sign it and return it. The proposed
time frame is not adequate in case of unexpected emergencies (incoming hurricane that will delay I
mailings, pandemics, etc.) 3
In some situations, a customer needs to get a check from the bank as part of a "draw" for
their permits, and those can take time as well. Please consider given a longer time frame.
ii
In section 5-4-6b, it mentions that if"action" is not taken within 60 days of picking up a
rejected application, the application is deemed cancelled. In some situations, 60 days is not needed
if the rejection is asking for a new design, or if the rejection is asking for additional structural calcs 3
the two portions of an application that can take the longest to accomplish). What does it mean
action", and how would the county work with the design professionals if it is determined a correction
is in the process of being completed, but not within the timelines.
3
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A more reasonable correction to all time lines would be 180 days.
3I
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Please reconsider the portions of the bills referenced above and please consider how it
would impact owners, which we are all trying to serve, with a goal of mutual understanding and 3
respect between everyone.
Mahalo for allowing me to submit this testimony.
i
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Taylor McMahel
McMahel Design LLC
Owner of McMahel Design LLC, a drafting company servicing the state since 2000
2
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3