REQUEST FROM FBC STAFF TO MAKE SUGGESTIONS TO THE ECONOMIC IMPACT ANALYSIS AND EVALUATION OF PROPERTY INSURANCE RATE IMPACT RESULTING FROM POTENTIAL CHANGES TO THE FLORIDA BUILDING CODE FROM THE ICC BASE CODE PROVISIONS.

It is believed in the report dated June 1, 2018 that research conducted to the actual changes from the ICC base code to Florida Statute 1021 will weaken the Florida Building Code. The report states that the weakened Florida Building Code will raise insurance rates and will create a negative overall economic impact on the residents and industry in the State of Florida. I do not support this report.

I recommend that the report be structured on using the existing base code as directed by FS 1021 at the minimum and assume that any modifications will be to strengthen the code and not weakening it. The overwhelming direction that this research was developed from suggests that the code will be watered down to the point that it will become a financial burden to Florida. There was no mention of safety concerns, only financial. I cannot envision that any TAC Committee person or Florida Building Commission Board member would vote to lessen the code. This type of action would be a very irresponsible on the part of the many experts who volunteer their time and knowledge to uphold the Florida Building Code, to assume that these professionals would agree to weaken the code is improper at best. The base code in my opinion is a safe code and the only code modifications that should be approved would be modifications that strengthen the code in relation to the specific needs of Florida.

The research is flawed because the FS 1021 is not yet in effect and no history is available to base a positive or negative impact to the State. Actuarial data cannot accurately project costs without some history which is the reason why Actuarial projections were not used in the report. An analysis should be attempted if possible with what little information that could be obtained by using the 6^th Edition of the FBC and assume no code modifications were presented. This could give us a baseline to work from.

The report does not specify protections related to health, safety and welfare that are not going to be met if the ICC is not adopted in its latest form. It would be beneficial to list these specifics to obtain relevant information to base a decision on to whether to approve the document or not. More information is needed in this area.

Flood protection in Florida is consistent with the National Insurance Flood Program and will provide insurance discounts. Please show these discounts in a table and include them in the overall report.

The research plan and methodology should only be used assuming the code stays the same or is strengthened and not weakened. Examples of what is going to be strengthened, what will be weakened and what the impacts of each should be shown. Both situations are pure speculation, but positive examples should be given priority over negative ones. If nothing changes how can there be a negative result? Please specify.

I agree that the code should be updated every three years.

Chapter 27 of the FBC lists the National Electrical Code as a Standard Code. Florida is two cycles behind the most current code available in the United States. I believe this has a negative effect on our economy. Data should be researched on the current negative NEC code cycle monetary affect to Florida. A recommendation to update the NEC to its latest issue based on a positive economic impact to the State of Florida would be beneficial to the report.

Show the overall discount given by receiving a favorable ISO-BCES rating.

Please provide a hurricane loss model comparison before and after 1996. Compare inland damage to coastal damage. If there is a correlation between stronger building codes and insurance premiums the loss model comparison could confirm this assumption.

Insurance companies accept the risk to insure homes and businesses within the State, rates are determined based on risk. There has been no objection, concern or input by the insurance industry to the code change that we know of. If there are materials or statements from insurance companies concerning that the code change would negatively affect Florida that is available, then we should be provided with it.

In conclusion, the report should give a clear explanation based on current verifiable information to help the reader determine objectively the impact of the code changes. The author qualified this report with a statement that he is “not an experienced code professional”, this is cause for concern, another concerning matter is that the author does not warranty the material in the study. The amount of loss projected to the State of Florida in the report is alarming. The author stated that the reported values were “conservative” based on the method of determining these values. There is no verifiable evidence that the new code will be weakened, all changes in phase one were approved by the Electrical TAC Committee, so far as I can see the negative report should be changes using positive theories.

Sincerely,

Kenneth Castronovo

July 18, 2018