PUBLIC HEARING PART 10

Administrative Rules for Construction Code

February 22, 2024

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·1· · · · · · · · · · · · · ·STATE OF MICHIGAN

·2· · · · · · ·DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

·3· · · · · · · · · · · BUREAU OF CONSTRUCTION CODES

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10· · · · · · · · · · · · · · ·PUBLIC HEARING

11· · ·Administrative Rules for Construction Code - Part 10, Michigan

· · · · · · · · · Uniform Energy Code Rule Set 2021-48 LR

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· · · · · · · ·702 West Kalamazoo Street, Lansing, Michigan

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· · · · · · · · · ·Thursday, February 22, 2024, 9:08 a.m.

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22· ·RECORDED BY:· · · · · · ·Marcy A. Klingshirn, CER 6924

· · · · · · · · · · · · · · · Certified Electronic Recorder

23· · · · · · · · · · · · · · Esquire Deposition Solutions

· · · · · · · · · · · · · · · Firm Registration Number 8035

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PUBLIC HEARING PART 10

Administrative Rules for Construction Code

February 22, 2024

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·1· ·APPEARANCES:

·2· ·For the Department of· · TONY WILLIAMSON

· · ·Licensing and· · · · · · Departmental Analyst

·3· ·Regulatory Affairs:· · · Bureau of Construction Code

· · · · · · · · · · · · · · · PO Box 30254

·4· · · · · · · · · · · · · · Lansing, Michigan 48909

· · · · · · · · · · · · · · · (517) 243-9100

·5· · · · · · · · · · · · · · williamsont5@michigan.gov

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PUBLIC HEARING PART 10

Administrative Rules for Construction Code

February 22, 2024

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·1· · · · · · · · · · · TABLE OF CONTENTS

·2· · · · · · · · · · · · · · · · · · · · · · · · · · · · · ·PAGE

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· · ·Statement by Mr. Williamson· · · · · · · · · · · · · · · ·4

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· · ·Statement by Mr. Bob Filka· · · · · · · · · · · · · · · · 5

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· · ·Statement by Ms. Grace Michienzi· · · · · · · · · · · · · 8

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· · ·Statement by Ms. Jan Culbertson· · · · · · · · · · · · · 10

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· · ·Statement by Mr. Jason Vandever· · · · · · · · · · · · · 12

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· · ·Statement by Mr. Don Nelson· · · · · · · · · · · · · · · 14

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· · ·Statement by Mr. Keith Nelson· · · · · · · · · · · · · · 14

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· · ·Statement by Mr. Andy Kosick· · · · · · · · · · · · · · ·15

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· · ·Statement by Ms. Sonya Pouncy· · · · · · · · · · · · · · 17

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· · ·Statement by Mr. Chris McTaggart· · · · · · · · · · · · ·18

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February 22, 2024

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·1· · · · · · ·Lansing, Michigan

·2· · · · · · ·Thursday, February 22, 2024 - 9:08 a.m.

·3· · · · · · ·MR. WILLIAMSON:· Good morning, everybody.· We will

·4· ·now proceed with starting.· My name is Tony Williamson, and

·5· ·I am a departmental analyst for the Bureau of Code

·6· ·Construction in the Department of Licensing and Regulatory

·7· ·Affairs, and I will be conducting this hearing today.

·8· · · · · · ·This is a public hearing on proposed

·9· ·administration of rules entitled "Part 10 Michigan Uniform

10· ·Code - Rule Set 2021-48 LR."· We are conducting this hearing

11· ·under the authority of the Administrative Procedure Act,

12· ·Public Act 306 of 1969, on behalf of the Department of

13· ·Licensing and Regulatory Affairs, Bureau of Construction

14· ·Code.· We are calling this hearing to order at 9:09 a.m. on

15· ·February 22nd, 2024, at the Michigan Library & Historical

16· ·Center, First Floor Forum, 702 West Kalamazoo Street,

17· ·Lansing, Michigan 48915.

18· · · · · · ·Notice of public hearing was published in the

19· ·Michigan Register, Issue 2-2024, on February 15th, 2024, and

20· ·in the following newspaper of general circulation:· The

21· ·Morning Sun and Oakland Press on February 1st, 2024; and the

22· ·Mining Journal on January 31st, 2024.

23· · · · · · ·Please know we are here today to receive comments

24· ·or suggestions on the proposed rules.· Please make sure that

25· ·they relate directly to the proposed rules and reasons why

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·1· ·the changes would be in the public interest.· If you wish to

·2· ·speak, make sure you have signed in and indicated that you

·3· ·wish to speak.· We will call on speakers in the order in

·4· ·which names are listed on the sign-in sheet.· Each speaker

·5· ·is limited to three minutes and only allowed one time to

·6· ·speak during the public hearing.

·7· · · · · · ·For those making comments today, please clearly

·8· ·state and spell your name slowly for the record, and if you

·9· ·are speaking on behalf of an organization, please identify

10· ·that organization as well.

11· · · · · · ·If you have already submitted comments to the

12· ·Department in writing or by mail, those comments will be

13· ·considered in the same manner as the comments made during

14· ·the public hearing today.· If you have written comments, you

15· ·may submit them directly to me.· The Department will also

16· ·accept written comments postmarked or e-mailed until

17· ·2-22-2024 at 5:00 p.m.· Thank you.

18· · · · · · ·I will now call the first speaker, Bob Filka.

19· · · · · · · · · · · · · BOB FILKA

20· · · · · · ·MR. BOB FILKA:· Lots of paper for you, Tony.

21· · · · · · ·MR. WILLIAMSON:· Okay.· Thank you.

22· · · · · · ·MR. BOB FILKA:· And that's the summer of

23· ·everything.

24· · · · · · ·I'm Bob Filka.· I'm the CEO of the Home Builders

25· ·Association of Michigan representing roughly 5,000 builders,

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·1· ·contractors, and others providing services in the

·2· ·residential construction space across the state.

·3· · · · · · ·Most important thing I want to point out today,

·4· ·and some people in the audience might be surprised, but in

·5· ·that stack we are offering a proposed change, an alternative

·6· ·proposal that actually we just had a report done by the Home

·7· ·Innovation Research Labs report on our proposed changes that

·8· ·show our proposed changes would increase energy efficiency

·9· ·in the state from the current code by 13.6 percent, which,

10· ·interestingly enough, compares to your own proposal's data

11· ·suggesting that what you're proposing by the 2021 IECC is

12· ·improving that by 10.7 percent.

13· · · · · · ·So I want the record to show the Home Builders

14· ·Association is not opposed to improving energy efficiency

15· ·standards in the state.· In fact, we are suggesting our

16· ·proposal goes beyond what is being proposed by the state and

17· ·we would encourage the department to seriously consider it

18· ·and we've -- you know, I think there's been some concerns

19· ·raised by the department suggesting that you have to adopt

20· ·the model code.· There is nothing in statute that requires

21· ·that.

22· · · · · · ·I would also like to point out that, as I stated

23· ·at the last public hearing in July, and nothing has changed

24· ·from what the state proposed last year other than some

25· ·modifications to the regulatory impact statement, that

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February 22, 2024

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·1· ·Michigan has a law that requires a seven-year simple payback

·2· ·for any proposed energy efficiency changes.· The Department

·3· ·of Energy -- U.S. Department of Energy's own analysis of

·4· ·what this could -- what your proposal could mean for

·5· ·Michigan indicated that there's a 12-year simple payback

·6· ·under the proposed 2021 IECC.· So I will again reiterate

·7· ·that the proposal that the State is promulgating at this

·8· ·point unless it's amended is in violation of that state law,

·9· ·the seven year payback.

10· · · · · · ·Lastly, I'd like to just ask a question.· Can I

11· ·ask a question?

12· · · · · · ·MR. WILLIAMSON:· No.· This proceeding is

13· ·one-sided.

14· · · · · · ·MR. BOB FILKA:· So the Administrative Procedures

15· ·Act which requires the ability to interact and ask questions

16· ·is not being followed here in this instance?

17· · · · · · ·MR. WILLIAMSON:· We don't give comments back to

18· ·your questions through this proceeding.· For --

19· · · · · · ·MR. BOB FILKA:· Okay.· Well, then I will just

20· ·simply point out that we FOIA'd the State on the documents

21· ·that it said it used to develop this proposal and we were

22· ·told that LARA was not in possession of any of those dozen

23· ·documents.· So my question would be, for the record, would

24· ·be --

25· · · · · · ·MR. WILLIAMSON:· Time, sir.

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February 22, 2024

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·1· · · · · · ·MR. BOB FILKA:· Okay.· Thank you.

·2· · · · · · ·MR. WILLIAMSON:· Thank you.· Grace Michienzi.

·3· · · · · · · · · · · ·GRACE MICHIENZI

·4· · · · · · ·MS. GRACE MICHIENZI:· Sorry, I'm pretty short.

·5· ·I'm going to submit my written comment via e-mail, but I

·6· ·just want to give a few comments verbally.· So thank you to

·7· ·the Bureau of Construction Codes for the opportunity to --

·8· ·to speak in support of the proposed rule set.· My name is

·9· ·Grace Michienzi.· Do you need me to spell it?

10· · · · · · ·MR. WILLIAMSON:· Sure.

11· · · · · · ·MS. GRACE MICHIENZI:· Okay.· It's G-R-A-C-E and

12· ·last name is M-I-C-H-I-E-N-Z-I.· I'm the senior director of

13· ·policy with the Michigan Energy Innovation Business Council

14· ·or Michigan EIBC.· We're a business trade organization

15· ·representing over 160 companies across advanced energy

16· ·including energy efficiency, electric vehicles, renewables,

17· ·demand response, and more.· Our mission is to grow

18· ·Michigan's advanced energy economy by fostering

19· ·opportunities for innovation and business growth.

20· · · · · · ·Updating our building codes is one of the greatest

21· ·tools this state has to make necessary advancements in

22· ·energy efficiency and other energy technologies in the

23· ·state.· Because of this, Michigan EIBC strongly supports

24· ·LARA's decision to include significant and necessary energy

25· ·efficiency improvements in this code.

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February 22, 2024

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·1· · · · · · ·The 2021 residential edition of the International

·2· ·Energy Conservation Code represents approximately a 10.7

·3· ·percent improvement in efficiency through more efficient

·4· ·thermal envelopes, improved mechanical system efficiency,

·5· ·improved lighting, and other cost effective improvements

·6· ·compared to the 2015 code.· Implementing the residential

·7· ·IECC will save Michigan residents money on their energy

·8· ·bills, continue to support the growing industry in advanced

·9· ·energy efficiency, and advance the work in future proofing

10· ·Michigan's building stock.

11· · · · · · ·Research completed by the Pacific Northwest

12· ·National Laboratory for the Department of Energy showed that

13· ·updating the 2021 IECC is cost effective.· A 10.7 percent

14· ·improvement in energy efficiency equates to $327 in annual

15· ·utility bill savings for the average Michigan home and the

16· ·study showed that the average life cycle cost savings of

17· ·implementing the 2021 IECC is over $4,000.· The study

18· ·appropriately balances both incremental costs of

19· ·construction against longer term energy savings over a

20· ·30-year period.

21· · · · · · ·Additionally, the research suggests that in its

22· ·just -- its first year of implementation, the 2021 IECC will

23· ·save Michigan homes statewide about 3.8 million in energy

24· ·cost savings.· Updating to more energy efficient codes is

25· ·cost effective and will result in increased affordability in

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·1· ·terms of year to year household costs rather than solely the

·2· ·initial sale.

·3· · · · · · ·I also just want to say Michigan EIBC strongly

·4· ·supports the BCC's decision to pull back the code regarding

·5· ·the drafting errors that were issued and we encourage the

·6· ·BCC to also open up the 2024 code shortly after the

·7· ·conclusion of this one.· That's all.

·8· · · · · · ·MR. WILLIAMSON:· Thank you.

·9· · · · · · · · · · · · JAN CULBERTSON

10· · · · · · ·MS. JAN CULBERTSON:· Good morning.· I'm Jan

11· ·Culbertson, J-A-N C-U-L-B-E-R-T-S-O-N, and I'm here

12· ·representing two organizations, one, AIA Michigan and the

13· ·Michigan 2030 Districts which exist in Detroit, Ann Arbor,

14· ·Grand Rapids, and an emerging district in Lansing.· First of

15· ·all, I will submit written comments.

16· · · · · · ·I do want to say that both organizations support

17· ·the adoption of the proposed Michigan Uniform Energy Code

18· ·Part 10.· And we note that you did add appendix RB which is

19· ·an important addition.· However, we would like to also

20· ·propose that you include appendix RC which will improve

21· ·building efficiency resilience and is easier to implement

22· ·due to recent legislation and utility renewable power

23· ·programs.

24· · · · · · ·I want to point out that onsite renewable energy

25· ·increases building efficiency, especially if you compare

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·1· ·source energy and site energy.· ENERGY START Portfolio

·2· ·Manager actually uses a 2.8 versus 1.1 for source versus

·3· ·site energy which means you are generating 2.8 times the

·4· ·energy if you are not using onsite renewable energy.· Very

·5· ·important energy efficiency.

·6· · · · · · ·The pieces of the legislation and renewable power

·7· ·programs, the distributed energy cap has been increased from

·8· ·one percent to 2 -- 10 percent, enabling the growth of

·9· ·onsite solar and the amount of onsite solar generation has

10· ·been increased to 1 -- 110 percent of a building's annual

11· ·energy use, enabling larger systems.· As an option to onsite

12· ·renewable power, which is offered in this appendix, an

13· ·example is MIGreenPower which is DTE's current green power

14· ·program, which actually reduces the kilowatt hour price for

15· ·anyone enrolled.· In addition, several utilities have now

16· ·established residential time of day rates and some -- most

17· ·of those overlap with solar generation and peak electricity

18· ·demand, resulting in additional savings for customers who

19· ·have onsite renewable power.

20· · · · · · ·In addition, Michigan will be eligible for over

21· ·$1.7 million in additional federal funds for code

22· ·implementation and education with the adoption of Appendix

23· ·RC.· These funds are made specifically for the adoption and

24· ·education and implementation of that appendices.

25· · · · · · ·I -- I just want to say that installers are

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·1· ·reporting a seven to nine-year payback depending on

·2· ·orientation and an 8 to 12 percent internal rate of return

·3· ·over 25 years.· Onsite solar systems can be financed with

·4· ·low interest loans from Michigan state or installed through

·5· ·a power purchase agreement with no capital up front cost.

·6· ·Thank you very much.

·7· · · · · · ·MR. WILLIAMSON:· Thank you.

·8· · · · · · ·MS. JAN CULBERTSON:· I'll submit these to you.

·9· · · · · · ·MR. WILLIAMSON:· Thank you.

10· · · · · · ·MS. JAN CULBERTSON:· Thank you.

11· · · · · · ·MR. WILLIAMSON:· Jason Vandever.

12· · · · · · · · · · · · JASON VANDEVER

13· · · · · · ·MR. JASON VANDEVER:· I'm Jason Vandever, J-A-S-O-N

14· ·V-A-N-D-EVER, with North American Insulation Manufacturers

15· ·Association.· I'm here to testify to encourage Michigan to

16· ·adopt the 2021 as listed in the rule sets.· Certainly a lot

17· ·of times I'm testifying in opposition to the builders, but I

18· ·want to give credit to the builders here today who have gone

19· ·through the Home Innovation Research Lab and come up with a

20· ·builder, a package for you to consider.· I would encourage

21· ·you if you do consider the builder package -- so a couple of

22· ·things to think about.

23· · · · · · ·One, the 2021 IECC as published already has ready-

24· ·to-go software that's needed for permit and plan review

25· ·compliance.· That software off-the-shelf, whether it's

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·1· ·Ekotrope or REM/Rate or REScheck, is up and ready to go for

·2· ·the 2021 IECC as published.· And then so -- so that's --

·3· ·that's -- that would be an advantage that the builders could

·4· ·use day one.· Hey, we can show compliance with ready to go,

·5· ·off-the-shelf software.

·6· · · · · · ·If you are to consider the builder's package, I

·7· ·think making it an alternative compliance path would

·8· ·certainly be a way to go.· That way, the -- because when

·9· ·you're -- when you're looking at the funding from the

10· ·Inflation Reduction Act and other federal funds, the --

11· ·they're going to use the Pacific Northwest National Lab

12· ·calculations and HIRL, the Home Innovation Research Lab's

13· ·cost and energy savings are oftentimes -- don't -- let's say

14· ·they just don't always align.· They're -- they're typically

15· ·a little higher as far as energy savings and a little lower

16· ·as far -- far as cost.· So that would -- that would resolve

17· ·that potential issue making it an alternative compliance

18· ·path.· And that's all I have.

19· · · · · · ·MR. WILLIAMSON:· Thank you.· Don Nelson?

20· · · · · · ·MR. KEITH NELSON:· I'm going to take Don's.· I'm

21· ·Keith.· Do you want me to wait for me or -- he's not going

22· ·to talk.

23· · · · · · ·MR. WILLIAMSON:· All right.· Don Nelson is not

24· ·going to talk.· All right.

25· · · · · · ·MR. DON NELSON:· Is Keith next?

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·1· · · · · · ·MR. KEITH NELSON:· No.

·2· · · · · · ·MR. WILLIAMSON:· No.· You were first, sir.

·3· · · · · · ·MR. DON NELSON:· Okay.

·4· · · · · · · · · · · · · DON NELSON

·5· · · · · · ·MR. DON NELSON:· Don Nelson, D-O-N N-E-L-S-O-N. I

·6· ·spent 43 years promoting energy efficient construction and

·7· ·making it easier, as easy I can for builders.· And my one

·8· ·complaint about the 2021 International Energy Conservation

·9· ·Code is that it focuses all on insulation.· There's no

10· ·credit given for appliance efficiencies and other

11· ·efficiencies in the house.· It's all based on R-value which

12· ·I don't think serves the industry as well as it could.· My

13· ·son Keith will elaborate on that point when it's his turn.

14· · · · · · ·MR. WILLIAMSON:· Thank you, sir.· Keith Nelson,

15· ·it's your turn now.

16· · · · · · · · · · · · ·KEITH NELSON

17· · · · · · ·MR. KEITH NELSON:· Keith Nelson, DR Nelson &

18· ·Associates.· K-E-I-T-H N-E-L-S-O-N.· Just as my dad said,

19· ·for over 40 years been promoting energy efficiency and

20· ·working with builders on air sealing and techniques to

21· ·deliver cost effective homes for their end users that are

22· ·efficient and don't have drafts.

23· · · · · · ·A couple things with the 2021 IEC's -- 2021 IECC

24· ·specifically are 405.2, items one and two; and 405.4.2.

25· ·Both of these rules remove credit for reduced air leakage

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·1· ·and remove credit for high efficiency furnaces.· As this

·2· ·code is, you can put an 80 percent furnace in or a 98

·3· ·percent efficient furnace in.· The code views it as the same

·4· ·and that's why we want to strike these two items from the

·5· ·code council, or from the IECC's 2021 book.· One of them is

·6· ·air leakage as well.· It reduces credit for air leakage.· So

·7· ·we're de-incentivizing builders for air tightness and high

·8· ·efficiency equipment and all the focus is on R-value which

·9· ·has been proven once you get to minimum levels of

10· ·insulation, there's significant diminished returns.

11· · · · · · ·For example, going from R-38 to a ceiling to R-60

12· ·in a ceiling might save a homeowner a dollar to two dollars

13· ·a month.· It might cost the builder $1,000 to build.· So,

14· ·and that cost is just going to be passed along to the end

15· ·user, the homeowner that purchases that home.

16· · · · · · ·So we're for the advancement of the codes, but in

17· ·ways that make economical sense and that aren't geared

18· ·toward special interests like insulation lobbies that

19· ·clearly got their way in this code.· Thank you.

20· · · · · · ·MR. WILLIAMSON:· Thank you, sir.· Andy Kosick.

21· · · · · · · · · · · · ·ANDY KOSICK

22· · · · · · ·MR. ANDY KOSICK:· Yes.· I'm Andy Kosick.· I -- I

23· ·am currently actually president of the Home Builders

24· ·Association of Midland, but I am speaking as myself today

25· ·because my comments are a little each way.

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·1· · · · · · ·So I think my -- my comments are more around

·2· ·process at this point.· I stand at a strange position of

·3· ·being for homebuilding, but also being in favor of energy

·4· ·efficiency and improved building performance.· I think there

·5· ·are a lot of issues pressing on housing right now from

·6· ·energy efficiency, energy transition around electrification,

·7· ·and the need for housing.· And I think balancing all these

·8· ·things is really important.· I think there's some issues

·9· ·around this from a process perspective that are frustrating,

10· ·and I think I'm going to spend most of my time with that

11· ·here.

12· · · · · · ·Basically I'm for improving efficiency, but

13· ·there's a lot of ways to do that and do that effectively and

14· ·that's at a performance standpoint, not prescriptively.· And

15· ·there's a lot of argument over the prescriptive nature of

16· ·the code and perhaps we should focus more on getting there

17· ·in a more -- you know, finding the best way to do that.

18· · · · · · ·I think the issue I -- I want to point out the

19· ·most right now that Bob didn't spend much time with is this

20· ·process seems really strange.· We're here talking about the

21· ·2020 IECC which doesn't even affect residential housing in

22· ·the state because the resident -- International -- the

23· ·Residential Energy Code is what actually is what the

24· ·residential housing pays attention to.· So the process here

25· ·is very strange.· And I'll go far as to say the people --

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·1· ·the process of promulgating this code seems to be coming

·2· ·from a place of, like, minimal competency.· I'll be the one

·3· ·to say that.

·4· · · · · · ·The -- the other problem is if we put this code

·5· ·through and it just ends up tied up in the courts, that

·6· ·doesn't do anybody any good.· Even if I want more energy

·7· ·efficiency, putting these things forward in a way that

·8· ·doesn't have them be implemented smoothly and carried out

·9· ·effectively, doesn't make a lot of sense.· So I just think

10· ·there's a handful of issues to be concer- -- concerned with

11· ·around this.· If the code goes forward and it just ends up

12· ·in lawsuits, I don't think that makes any sense for anyone.

13· · · · · · ·And I guess I will just leave it broadly with I

14· ·think it might be a really good move at this point to skip

15· ·2021, look at the 2024, and maybe figure out how to make

16· ·this happen in a way that makes a logistical sense within

17· ·the law and everything.· So I'll leave it at that.

18· · · · · · ·MR. WILLIAMSON:· All right.· Thank you.· Thank

19· ·you.· Sonya -- Sonya Pouncy.

20· · · · · · · · · · · · ·SONYA POUNCY

21· · · · · · ·MS. SONYA POUNCY:· Good morning.· My name is

22· ·Sonya, S-O-N-Y-A, Pouncy, P as in Paul, O-U-N as in Nancy, C

23· ·as in cat, Y.· I'm speaking at this moment on behalf of

24· ·myself as a homeowner in the state of Michigan.

25· · · · · · ·My understanding is that we are looking at

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February 22, 2024

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·1· ·adopting a new code that -- and we are looking to exclude

·2· ·provisions for zero energy.· As a Michigan homeowner, I know

·3· ·that a number of people are looking to improve the

·4· ·performance of their homes and zero energy is one of the

·5· ·things that people are considering.· I think that it is

·6· ·important that we include this as an alternate path of

·7· ·compliance for those that choose to -- to use it.· We have

·8· ·within our code currently other options for people to use.

·9· ·So we have prescriptive.· We have performance paths. I

10· ·think this is an important pathway to consider.· Thank you.

11· · · · · · ·MR. WILLIAMSON:· Thank you.· Chris McTaggart.

12· · · · · · · · · · · ·CHRIS MCTAGGART

13· · · · · · ·MR. CHRIS MCTAGGART:· Hello.· Morning.· So I was

14· ·here for the last hearing a couple years ago when we were

15· ·talking about changing the energy code here in Michigan.· My

16· ·role here in the state is that I own a company called

17· ·Building Efficiency Resources.· We are a resonant quality

18· ·assurance provider and we work with a lot of energy raters

19· ·throughout the state who are working with builders in

20· ·implementing the current Michigan energy code.

21· · · · · · ·So while my company -- we're generally advocates

22· ·for energy efficiency and improvements to building energy

23· ·codes, I am here to make testimony basically in encouraging

24· ·whatever changes are made to the energy code at the state

25· ·level, whether it's adoption of the version of the 2021 IECC

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February 22, 2024

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·1· ·or looking to the 2024, or potentially even, you know,

·2· ·keeping us closer to where we are with the current version

·3· ·of the 2015 IECC, it's very critical that the State removes

·4· ·the weakening amendment that was included in the 2015 IECC

·5· ·as it pertains to the location of ducts for the reference

·6· ·home within the performance path, section R405.

·7· · · · · · ·Michigan has a unique outlier addition to its

·8· ·version of the 2015 IECC that specifically amends the

·9· ·location of the ducts for the reference home in this

10· ·performance approach that ends up resulting in completely

11· ·unreasonable savings for homes that are following the

12· ·performance path and comparing a proposed home to the

13· ·reference home.

14· · · · · · ·In Michigan, most of our homes are built on

15· ·conditioned basements and as a result most of the ductwork

16· ·is naturally kept with inside condition space anyways.· The

17· ·way that the 2015 amended version of the Michigan code reads

18· ·is that if you're using the performance path of the code,

19· ·the reference home has 100 percent of ductwork located in an

20· ·unconditioned attic, therefore unlocking potentially 20 to

21· ·30 percent savings for a proposed home just by building a

22· ·home normally the way that a builder would.· This is a

23· ·completely unnatural amendment to the 2015 IECC and it has

24· ·basically weakened our current code to the point where it is

25· ·actually sub-2009 in terms of actual performance.

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·1· · · · · · ·So if you're making a change, please make the

·2· ·change to remove that weakened amendment, whatever version

·3· ·of the code we choose to stay on.· And I do have a little

·4· ·writeup I'd like to present for this.· Thank you.

·5· · · · · · ·MR. WILLIAMSON:· Thank you.· That's conclude our

·6· ·list of signed in speakers.· We will now proceed to the

·7· ·closing of the hearing.· If there are no further comments at

·8· ·this time, I hereby declare this hearing closed.· The record

·9· ·will remain open until 2-22-2024 at 5:00 p.m. for any other

10· ·comments you may wish to share about the proposed rules.

11· ·Thank you for attending.

12· · · · · · ·(Proceedings concluded at 9:34 a.m.)

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February 22, 2024

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·1· · · · · · · · · · · · ·CERTIFICATE

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·4· · · · I, Marcy A. Klingshirn, a Certified Electronic Recorder

·5· ·and Notary Public within and for the State of Michigan, do

·6· ·hereby certify:

·7· · · · That this transcript, consisting of 20 pages, is a

·8· ·complete, true, and correct record given in this case on

·9· ·February 22nd, 2024.

10· · · · I further certify that I am not related to any of the

11· ·parties to this action by blood or marriage; and that I am

12· ·not interested in the outcome of this matter, financial or

13· ·otherwise.

14· · · · IN WITNESS THEREOF, I have hereunto set my hand this

15· ·23rd day of February, 2024.

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21· · · · · · · · · · · ·Marcy A. Klingshirn, CER 6924

· · · · · · · · · · · · ·Notary Public, State of Michigan

22· · · · · · · · · · · ·County of Eaton

· · · · · · · · · · · · ·My commission expires:· March 30, 2029

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