Good morning Tom,
Thank you for sending the
draft rule. The proposed rule is much more readable.
I would respectfully like to
make a couple of suggestions.
Amend proposed section (1)(c) to read:
Commission staff shall review the model codes and identify any
provisions which overlap with the provisions of the Florida Building Code,
correlate directly with the provisions of the Florida Building Code, have an
economic impact on consumers, or are necessary to maintain eligibility for
federal funding and discounts from the National Flood Insurance Program, the
Federal Emergency Management Agency, or the United States Department of Housing
and Urban Development, or provide for energy efficiency
standards that meet or exceed the national energy standards as mandated by
Title III of the Energy Conservation and Protection Act.
Amend proposed section (1)(e) 2. To read:
That the Commission approve certain model
code provisions by consent agenda. When considering whether to recommend
inclusion on a consent agenda for approval, the TACs shall consider such
criteria as whether the model code provisions are editorial or organizational
in nature, correct an error, provide clarification, provide for alternative design
methods and industry practices, are uncontroversial to affected
stakeholders, are necessary for coordination with the Florida Fire
Prevention Code, or whose inclusion are mandated by law.
My reasoning for the recommendations is as follows:
1. There are powerful stakeholders in our area that will be in knee-jerk opposition to excluding the energy provision clause. Including it will circumvent that lengthy discussion (and hopefully avoid my having to make any more untenable proposals on their behalf).
2. There was considerable debate in TAC meetings this cycle regarding the meaning of “industry standards.” The industry is evolving technologically faster than the codes are able to adapt. Allowing the TACs to approve measures that accommodate that evolution will make enforcement of the code considerably easier.
3. The Florida Fire Prevention Code contains many provisions relating to construction features. Conflicts between the FBC and the FFPC can be very difficult to resolve for building officials. Allowing TACs to approve proposals that maintain that coordination will save time and reduce frustration to the industry.
Thank you for your kind consideration of these recommendations.
Sincerely,
John
John T. Hall
Board
and Code Administration Division
Senior
Code Officer (Electrical)
Miami-Dade County Department of Regulatory and Economic
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