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Office Phone: 509-489-3860
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My letter below was not allowed to be passed on
to the Washington State Building Code Council
so I'm putting in print so all in the state can read
it. The Governor and many on the State Building
Code Council want to end the use of natural gas
in all commercial building. Using the codes as a
mechanism they would end natural gas use in
commercial buildings and then I believe the next will
be our homes.Here is my letter that was not allowed
to be sent to the State Building Code Council. I
have since made some additions to the letter now
that I have had more time. For those of you who
don't know the proposals to the Washington State
Building Code Council below, they are to remove
natural gas from our state in commercial buildings.
I am a licensed contractor who performs HVAC,
refrigeration and plumbing work for residential
and commercial customers in Eastern Washington
and Northern Idaho. I am not now or have I ever
been against efficiency and reducing carbon
and greenhouse gas. I just know what works for
my customers and want to make sure everyone
understands the dangers of the policies being
proposed and mandates by RCW 70A.45.020
I am totally opposed to the proposals log in numbers
21-GP-1-103, 21-GP1-136, and 21-GP1-179 and
others. Our electric grid is already overloaded as
it is this only going to make things worse. We are
already having rolling brown outs in the Spokane
area as it is. These will only make things worse.
As for 21-GP1-179 requiring a wire sized large
enough to run the system on electrical for heating
our buildings and water heating, I would like to
see what Duanne Jonlin put down for this extra
cost. For I am not able to bring up the sheet online
that Duanne Jonlin had to start this thing going.
You know this would require major update of the
electrical service and panels going from a 200-amp
service to 400- amp or even 600-amp maybe even
1,000-amp services and panels. These costs are
huge for the hopes someday they may want to go
to electric. What a waste.
As for Heat Pump Space Heating Proposal (21-
GP1-103), the duct work would be required to be
double the size to even think of this. Larger buildings
to hold such ducts mean more heat loss and heat
gain. Remember the more you raise the static
pressure on a duct to move the air around the more
horsepower it takes, and more horsepower is more
energy. In the Spokane area with temperatures
that do dip to -20 degrees, heat pumps become
worthless. Also, with equipment manufacturers
getting COP (Coefficient of Performance) up higher
has come with much shorter life of these heat
pumps. The copper coils are made much thinner to
get better efficiency upfront but are now wearing
out much faster. Commercially most equipment
has only a one-year warranty. Compressors are
failing much faster too. This year alone we had two
10-ton heat pumps fail that were 1-1/2 years old,
and without back-up electric resistance heat they
would have been out of heat for three months.
Copeland compressors were failing left and right
and Copeland had no answers why. The cost for
each of these failures was $10,000 plus tax. Just
think how much carbon footprint that took to fix
these units. Compressors in our area don't last
as long due to the extreme cold weather here. In
fact, when you start to look at the defrost cycles
when it gets below 20 degrees outside, they are
in defrost more than they are heating. The COP
rating doesn't include the resistance heat during
defrost in its calculation. I have limited time and I
will later share more problems with heat pumps like
the reversing valves that we replace, contactors,
and then the coils. One thing to think about is many
of our churches. When they need to replace their
systems, they are going to have to bear the cost
of these heat pumps and the cost to convert them
over. Most churches can barely cover the cost to
keep them running now, let alone to make a total
change over to a heat pump system. As this new
requirement by this code, on the electrical side,
electrical engineers will be required on many jobs
to replace units that are two or more replacements
in a two-year period. The larger electrical services
will increase the cost to the building owner would
be astronomical to the building owners of these
buildings. These are not my words; they are from
electricians that I work with. As for what McKinstry
said in letters on September 27, 2021, to the State
Building Code Council, a lot of these projects are
totally funded by government grants and there is
no way the average building owner could afford
such projects. Also, these projects are not sent out
for bid.
Now we come to Energy Code Proposal (21-GP1-
136) This proposal makes it necessary to have all
commercial water heating done with air-source
heat pump water heaters. Unless you live in an
area which has an outside temperature above 40
degrees outside there, they're useless and have
no place in the Spokane area. They are just costing
people more than just straight electric resistance.
In the Spokane area we heat eight months out of
the year. I can see this working out in the Seattle
area with basements, but in Spokane we on the
losing side of things with these units. This does give
a builder more points for energy credits, but we are
not reducing energy at all. In fact, we are using more
energy than before. In fact, the last service call I
had, one of these units was well over $450 plus tax
for the service call, and the unit had only been in
operation for two years. The house was heated with
straight electric, and they had a crawlspace under the house.
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So, first they paid to heat the house
with straight electric then the heat pump water
heater grabs its energy from the straight heated
electric house. So, the straight heated electric
house heat had to come on and feed the heat pump
water heater, but they got energy credits points
for doing this. Remember anything mechanical has
energy loss when the compressor turns on. Where
are the economics for this? What about when a
restaurant that needs 400,000 BTUs per hour just
to keep up with the dishes, or how about a hotel
with 1,000,000-plus BTUs per hour? To put this
in perspective that's 25 home gas water heaters.
Then there are the retirement homes where they
need to have more than 1,000,000 BTUs per hour
for water heated usage with large laundries, and
most of these have to have the water heated to
180 degrees. How are they going to do that with
a heat pump water heater? The last time I looked,
heat pump water heaters can only give about 118
degrees of water temperature, well under the 180
degrees Fahrenheit needed. That is just about one
200-amp panel for constant electrical use alone,
where one 400,000 BTU gas water heater is now
used.
We need to be able to offer different codes for
different areas to reduce energy usage. One code
for all climates in Washington State is not the
answer.
The next paragraphs are all pertinent since all
the proposals above are about reducing global
warming. Without natural gas our electric will
most likely run about 30 to 40 cents a kilowatthour. Right now, in states they have electrified as
Washington State wants to do are paying over 18
cents a kilowatt-hour right now. What is going to
happen to the retired people who are going to have
pay for this power? The power bill could be more
than their house payment. Some people want to
remove the dams now, with the Governor along with
Maria Cantwell, and Patty Murray is on board with
this idea too. Why not just pay the Nez Perce Tribe
of Idaho for the fish so they don't put the gill nets
across the Snake and Columbia rivers, so the fish
can get back home to spawn? It would be a lot more
cost-effective to do this. Add more hatcheries.
Compounding this is the potential removal of four
dams along the Snake River in Idaho, as proposed
by the Nez Perce Tribe of Idaho to address fish
population concerns. I remember the movie in
EXPO 74 at the IMAX: "Man belongs to the earth."
Chief Dan George said in the movie, "Never destroy
fish for the fun of it." You should look at this short
movie. I lived with this all my life if I am not going to
eat them and need it for my life, I will not kill them.
I look back at this movie and see how far we have
come, but now everything is such a rush, look at the
gains we have made in the past 47 years. I think we
can all say we can go for some years without fishing
and let the fish population come back again or at
least cut way back on fishing. I put this in due
to the fact all the power we get from these dams,
each dam help supply the electric grid and gives
the farmers a way to get their crops to market,
plus all recreational use behind the dams, let's not
go back words. Shouldn't we give like five years at
this and see if the fish come back. Just look at the
investment by all the citizen of the U.S. did for this
area, to put the dams in. This investment by the
whole United States was for power for the area and
the farmers that's why the locks were put in for the
vessels move from the ocean to into Idaho.
Then they have talked about how hot this summer
was and being the hottest on record. You are
comparing apples and oranges. Think about this
in 1928 and in 1961 we just beat this out by one
degree. Which year do you think was hotter in
Spokane? It was 1928 by far and here's why: in 1928
there were no server farms, no computers, very
few autos, no A/C or heat pumps running which
raised the outside temperature greatly. Just think
how many trillions of BTUs are put outside from our
A/C and heat pumps. These all run on electricity
not natural gas. Our problem is not natural gas,
our problem is our use of energy period, and until
we understand that we are just wasting our time
and money. I don't how many of you would not go
on breathing anymore to slow the gain of CO2 or
stop drinking a soda pop. I have been tracking CO2
in Spokane for years. It goes up in the winter and
down in the summer. Then you have the people in
Spokane that want to conserve water, so they let
their grass dry out. Well, that grass was turning CO2
into O2. You know we have one largest bodies of
water in the world under us and all this water ends
up in the ocean anyway, plus it has never dropped
in depth. Then we have the 'let it burn' Washington
State policy so forest and fields that could remove
CO2 don't now that they have burned up in the last
few years. And they wonder why our CO2 level is
rising? What we need is to be more pro-active and
get 10 of the United States 53 C5A airplanes set
up with mobile water tanks so these planes could
each drop 25,000 gallons of water. This would be
250,000 gallons of water, which they could deliver
starting during the early summer and put some
real amount of water on these fires. We need to
start earlier and not let the fire get to such a level.
We need to change our policies. If we can level all
Europe during World War II, we can surely put some
fires out, we just have to put the idea forward that
this is not going to happen anymore, and find ways
to do this. This way the smoke from the fires won't
keep the heat and CO2 next to ground any more.
The trees and fields that we will have saved can do
the job of removing CO2 and making O2 again.
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To be frank I think the Governor's policy has made
all this happen. Our Governor has been in office
all this time and is not helping. We were on a good
path of better insulation of our buildings and that
has changed. When you look at the heat gain and
losses the major, and I mean major, energy losses
now are air exchange. Anybody who does heat loss
and gains should know this.
Insulating the under-slab floor over 2 inches thick
is a total loss no gain. And I mean no gain is made.
All the calculations prove that. So how many
people have wasted their money on a new code
that has no gain at all? I am seeing more of these
codes happening all the time in Washington State
Building Code. What a waste! Avista will not provide
incentive money for commercial projects unless it
can be paid back in 15 years most of the time. Yet
some of these proposal for energy code will never
pay themselves back. Why are we allowing such
proposals to come forth without economic analysis
that have factual documentation? These proposals
will not pay back before the equipment will wear
out and needs to be replaced. In these proposals,
people have been working on them for a year, but
we the public only get two months at best to read
and understand what is going on. There needs to be
much more time given for the State Building Code
Council and the public to get a grip on what would
happen if this were to take place. What would
be the true cost if these things were to happen?
Myself and many others do not believe this joke of
a study that was put forward. Some of the study's
findings were not even conducted in our state or
using our wage rates and equipment.
Until we all stand up and say this is enough, we will
have brown outs and shutdowns much like others
have who done these things. Look at the article in
The Spokesman-Review OPINION section Tuesday
October 12, 2021, that talks about how California
is rolling back these types of proposals and codes
because there is not enough power to feed them.
In fact, our state carbon rollback codes that are
coming will cause these problems too. The average
person has no idea what could be coming if we keep
going down this path. It takes 50 years to even
think of starting to achieve these types of changes
without breaking everybody financially, plus brown
outs. We're trying do it in eight years.
I was wondering where these code changes were
coming from, then I found out about the new RCW
70A.45.020 that was passed by the Governor and
a totally Democrat vote. No Republicans voted
for this. Remember this happened during the
pandemic/plague where all businesses are just
trying to survive during the pandemic/plague, and
Democrats and the governor pass such legislation
when everyone is beating down and many don't
have time to even begin to react to such legislation.
This is going to affect every citizen in this state.
This legislation put our targeted millions of metric
tons CO2 from about 90 million ton of CO2 down
to 50 metric tons by 2030 then by 2050 down to
near zero metric ton CO2.
This could break nearly every small- and
medium-size business in this state. Would you
not think that this type of legislation would
be put before the public in an open forum
after the pandemic was over and people and
business could catch a breath? Then put this
kind of legislation to a vote of the people in this
state. This will drastically affect life for every
citizen in our state. That would mean no more
combustion engines and no natural gas-heated
buildings in 2050. Every person will have to
have some type of heat pump to heat these
buildings. It will mean knocking down buildings
to achieve this including our churches.
Remember, when it gets real cold outside the
wind does not blow and it cloudy outside. This
means no wind power and no photovoltaic
power, just like what happened in Texas in 2021.
No power.
Here are five Prager University YouTube videos,
five minutes to view each. These could shed
some light to what has happened in other
states and what will happen in our state with
what the Governor is doing. 1. The great Texas
Freeze of 2021. 2. What's wrong with Wind and
Solar? 3. Why are Utilities So Expensive? 4. Is
California going up in flames? 5. Trees are the
answer.
One last thing. Why is the state rolling the CO2
back to near zero? In the 1970s we were going
into an Ice Age, and we were at 52.6 metric
tons of carbon dioxide during those years. Look
at the article about planes that had landed in
Greenland in 1942. There were two B-17s and
6- P38s which were found under 250 feet of ice
in Greenland in 2015. Our CO2 level was much
lower in 1942 than it is now. But the planes are
still under 250 feet of ice now.
Those people who don't like this should contact
your legislator in your area.
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The State Building Code Council email address is sbcc@des.wa.gov,
and the Governor's office phone number is 360-
902-4111, or all this will come true.
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Respectfully
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Larry Andrews
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I can be reached @ the email address below:
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Larryandrews.co2mandates@outlook.com
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