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local amendments to green building code

From: Henry Riggs <hlriggs_at_(domain_name_was_removed)>
Date: Tue, 24 May 2011 16:09:57 -0700


Honorable council members,

The state mandated upgrade from the recently approved "green" energy code is ironic for our town - in one of the mildest climates in California. Note the state mandate includes the requirement:

The local jurisdiction is required to make specific or express findings that such changes are reasonably necessary because of local geological, climatic, or topographic conditions.

Our climate is milder than nearly all California locales, and thus cannot honestly make the findings.

I personally support and recommend to clients the wall insulation, furnace and window upgrades. But some upgrades for our area depend on the building site; we are different from Tahoe, Sacramento, Bakersfield or even Concord, all of which have heating and/or cooling loads very different from ours. Some examples of issues:

COOL ROOF
This is for a sun-intense area with added solar gain. For commercial, lighting often implies the need for 10 months of air conditioning so a cool roof is a benefit. For residential, half of the year we do not benefit - in Winter we actually lose desirable solar heating; there are also significant aesthetic issues with white or light grey roofs on traditional homes. Generally, for flat roofs, this is not an aesthetic issue.

PRESCRIPTIVE VERSUS PERFORMANCE CALCS
Except for larger buildings and offices, which already use prescriptive calc, this essentially adds $1000 engineering to the cost of residential and smaller tenant improvement project by removing the "baseline" conservative approval method. The minimal gain on a few projects does not warrant forcing all projects into this added cost.

LEED CERTIFICATION
The original purpose of LEED was to encourage better building performance - the reward is design and/or construction trade recognition and bragging rights. Encouragement is more appropriate given the tens of thousands of dollars the cert process requires - again, not warranted as a mandate on the backs of property owners.

DUCT LEAKAGE AND OTHER SUBMITTALS
Most such reports are part of good practice and owners should require them from contractors, as the AIA contract documents require for final payment. If these are made a city requirement, it is critical that council direct that approval and inspection do not add cost or time to the process; to date, both of these have been burdens, often expensively so. (This is an ongoing issue.)

I urge council to submit this proposed ordinance to a task force of stakeholders and professionals, including owners, merchants contractors and architects to assure that we are not adding yet more straws on the camel's back.

With thanks,

Henry Riggs Received on Tue May 24 2011 - 16:11:16 PDT


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