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HomeMy WebLinkAboutCOUNCIL - AGENDA ITEM - 02/10/2004 - DISCUSSION OF THE 2003 INTERNATIONAL RESIDENTIAL C DATE: February 10, 2004 STUDY SESSION ITEM STAFF: Felix Lee FORT COLLINS CITY COUNCIL Brian Woodruff SUBJECT FOR DISCUSSION Staff is seeking direction on which provisions City Council wishes to consider as part of the package of code changes and amendments related to the adoption of the model residential building code,the 2003INTERNATIONAL RESIDENTIAL CODE(IRC)®,scheduled for First Reading on March 2, 2004. GENERAL DIRECTION SOUGHT AND SPECIFIC QUESTIONS TO BE ANSWERED 1. As Council requested at its May 2003 study session, additional medical and epidemiological testimony will be presented identifying radon exposure as a health hazard. 2. Which options does Council wish to consider on First Reading on March 2, 2004: a) Radon 1. No change 2. Passive required 3. Active required 4. Active required for homes with basements, passive required for all others 5. Passive required, unless original home buyer"opts out" 6. Passive required, test required, and activation required based on test result 7. Passive required, except caulking not required 8. Sub-slab preparation required 9. Mitigation required to below 4 picoCuries/liter b) Energy 1. Change, retain current standards 2. Provisions for increased wall insulation and window performance,and local amendments for HVAC testing and sealing plus AC 2007 federal standards 3. Provisions for increased wall insulation and window performance, and HVAC design criteria 4. IRC provisions with local amendments plus current wall insulation for homes 1,600 sq. ft or less c) Other provisions 1. No change, retain current obsolete UBC code 2. New IRC including larger stair geometry and moisture backing behind siding 3. Retain UBC stair geometry February 10, 2004 Page 2 3. Does Council wish to consider a transition period for the effective date when the new Codes would become effective? 4. Does Council have any other comments or questions on the proposed code changes and amendments? BACKGROUND AND CURRENT STATUS: Since the December 16 City Council public-comment hearing, staff has performed additional cost analysis and research primarily related to the key draft provisions for radon-reduction systems and energy conservation summarized below. Details are provided in the attachments. Radon: • Costs —A recent meeting with builders, radon mitigation contractors, the HBA government affairs liaison, and the AQAB Chair presented a convincing argument that the minimum cost estimate for passive radon-reduction system installed in the"example home"(two stories,2,000 sq.ft. above a full-basement foundation)by a professional mitigation contractor starting around $1,000,is consistent with the estimate previously presented to Council. This cost replicates the current "market" price to a builder. • Benefits — City staff calculated (Attachment B) that requiring passive radon systems each costing$1,000 would result in avoiding about 150 lung cancer cases during the first 75 years the homes are occupied, at a cost of about $99,000 per lung cancer avoided. Requiring active systems, each costing $1,300 to install and $62 per year to operate and maintain, would result in avoiding about 270 lung cancer cases at a cost of about $317,000 per lung cancer avoided. The Poudre Health Services District independently examined the costs and benefits of RRNC (Attachment Q. District staff calculated that requiring passive systems would cost in the range of $10,300 to $28,000 per life year gained, which falls within the "good buy" range when compared with other strategies for prevention of disease and premature death. Requiring active systems would cost in the range of$35,000 to$93,000 per life year gained. The Health Services District Board voted to support the requirement of passive mitigation systems in new construction. • Options — From the May 2003 study session, Council directed staff to develop the code provisions mandating in all new homes either: (a) a passive radon-reduction system— still the staff recommendation—or, (b)an active radon-reduction system,for consideration. Since then, several variations have been suggested by Council Members and others. Several of these are discussed further in the attachments. Energy Code: New exemption for compact homes—In response to the concerns raised by the Affordable Housing Board, the draft IRC®energy provisions have been revised to allow homes not exceeding 1,600 sq. ft. of floor area above grade, which in 2003 accounted for around 25% of new single-family homes, the ability to retain the current minimum R-15 insulation value in above-grade exterior walls. This item alone would cut estimated cost increase for this housing segment ranging from approximately $2,600 to $4,500, or by as much as 40%, while still providing a significant level of energy savings and initial cost savings,as well. The proposed standards for higher performing windows and HVAC systems would be retained for all new housing. February 10, 2004 Page 3 New Code Transition: Given the extensive changes contained in the "complete" draft IRC®package beyond the current UBC standards, relative to proposed new radon-reduction, energy-conservation, and larger stair geometry, staff is recommending that the effective date of the regulations begins a minimum of 180 days after passage on First Reading. This interim period would allow code compliance staff to put new procedures in place, provide training for builders and staff alike; and allow builders a date- certain for redesign work and implementing new production methods and scheduling. Public Outreach: In addition to the December 16, 2003 City Council Public Hearing, staff has presented the IRC® proposed code and amendments to the following boards: Affordable Housing Board, Air Quality Advisory Board, Building Review Board, Electric Board, and Natural Resources Advisory Board. The AQAB has endorsed the IRC® package (including the proposed new energy-conservation regulations and moisture-control provisions) with a mandatory fan-powered "active" radon- reduction system in all new homes. The NRAB has endorsed the IRC®package with a mandatory naturally-vented "passive" radon-reduction system in all new homes. The Affordable Housing Board, Building Review Board, and Electric Board are scheduled to consider the draft code and amendments further before making a final recommendation prior to the First Reading. ATTACHMENTS A. Radon alternatives B. Staff analysis: Costs and benefits of Radon Resistant New Construction (with estimated cost worksheet) C. PHSD analysis: Radon Overview and Analysis of the City of Fort Collins D. Proposal to Require Radon Control Systems in New Residential Construction E. A Citizen's Guide to Radon F. Larimer County Radon Policy G. Historical Comparisons of Impact Fees to Sales Price H. Energy Bill and Mortgage Payments comparison I. IRC Status Summary J. IRC Cost Matrix K. Power Point Presentation: Indoor Radon - Science or Myth • Radon Alternatives Several alternatives have been suggested to handle the issue of radon-resistant new construction. These have come from Council members, staff members, and the public. The alternatives are listed below,followed by descriptions, advantages, and disadvantages of each alternative. 1. No change Passive required 3. Active required 4. Active required for homes with basements, passive required for all others 5..-Passive required, unless home buyer"opts out" 6,—Passive required, test required, and activation required based on test result 7. Passive required,,except caulking not required 8, -Sub-slab preparation required �. Mitigation required to below 4 picoCuries/liter 1. No change • Descrivtion s1P1 option leaves th`mgs as they are. Some builders will continue to install RRNC voluntarily;the current rate is 10%of new homes. Some owners of new homes will fix radon after they move in. Some mitigations will not be successful due to lack of sub-slab preparation(e.g.,when concrete slab is poured on native soil). Advantages • Market forces—the preferences of builders and buyers—determine whether RRNC is used. • No construction costs incurred for consumers who don't want,or buildings that don't need, radon mitigation Disadvantages • Many people assume that building codes handle preventable health issues like radaa. • Some builders do not install radon systems and do not offer this as a choice to buyers. • Some builders have received legal advice that:if-they-offer radon*redu bxIb ca__ customers,they may become liable for radon-induced lung cancer that may occur. This factor may help explain why only 10%of homes in 2000-03 were built with passive systems. Homebuyers who decide to mitigate after construction must install an active system, usually with a vent pipe outside the building envelope. They will incur operating costs for electricity and maintenance and compromised building appearance. 2. Passive required Description This is the option recommended by staff—require a passive radon reduction system in new homes, consistent with the Model International Residential Code, Appendix F. Components include gas-permeable layer,plastic sheeting in crawlspace, sealing and caulking,vent pipe, &junction box for optional fan A placard would be placed in the home advising the homeowner to do a radon test after moving in, and to activate system if needed. Advantages • Consistent with USEPA recommendation to install passive systems in areas designated zone-one (all of Larimer County is so designated) • Passive system specification is accepted by national and international model code developers, after extensive stakeholder involvement, as a building code option for high radon areas. • Reduces radon by 47% on average • Many people assume that building codes handle preventable health issues like radon • Since the passive system removes about half the radon,the homeowner gets a benefit from the added cost without taking further action. • Offers an element of choice: system can easily be made active if desired. Disadvantages • Increases cost of construction,reduces choice 3. Active required Description Require installation of a fan in addition to the passive radon reduction system,thus making it an active system. The homeowner is advised to monitor system operation using the provided indicator. Advantages • Assumed to reduce radon to near-background level: 0.4 pCi/L • Occupant exposure is limited to near-background radon levels without further action on his or her part. • Testing not needed Disadvantages • Highest cost alternative • Increases cost, reduces choice 4. Active required for homes with basements, passive required for all others Description An active radon reduction system would be required in any home that has a basement. Homes without basements would be required to have the passive system, including the placard advising the buyer to test for radon after moving in. This alternative responds to the fact that basement radon tests average twice as high as ground-floor radon tests. Advantages • Reduced costs,because radon systems are matched somewhat with expected radon levels. • See other advantages of passive &active systems, above. Disadvantages • See other disadvantages of passive and active systems, above. 5. Passive required, unless home buyer opts out • Description • Passive radon system would be placed in every home, except that the home-buyer [the initial occupant] can"opt out"of getting a radon system. Homes built on speculation would have to have a radon system, since the initial occupant is not known prior to construction. The homebuyer who decides to opt out would sign a form which would be sent to the Building and Zoning Department. Building inspectors would enforce the opt-out provision at the point when the sub-slab plumbing is inspected, i.e., before the concrete slab is poured. If the radon system components are missing, then the inspector would "place a hold" on the concrete pour, unless the opt-out form had been received. To assure that the first owner's decision to opt out does not jeopardize subsequent owners' ability to mitigate, minimal sub-slab preparation would be required as in option 8. Advantages • Avoids costs and increases choice for a first occupant who does not want a radon system. This option is most similar to the City's current program to encourage mitigation of existing homes,the"information-at-point-of-sale" ordinance, because it relies on homeowner preference. Disadvantages • It may be hard to properly define"home-buyer" so that the buyer who opts out is a person who will actually live in the new home, as opposed to a realtor, agent,or institutional buyer. • A subsequent owner who decides to mitigate would have to pay more than the cost of • a passive system, with higher electricity usage and compromised building appearance. 6. Passive required, test required, activation required based on test result Description Require a passive radon reduction system in new homes. Require that each new home be tested for radon. If the radon test is high,.require that the radon system be made active by installing a fan. The radon test would be done after occupancy,when testing conditions are more accurate than during construction. This option would be enforced by issuing a conditional Certificate of Occupancy(CO). A permanent CO would be issued following completion of a radon test and activation of the radon system, if needed. Advantages • The alternative would be more cost-effective than requiring active systems in all homes, because the system would only be activated if needed to reduce radon levels. Disadvantages • City would have to specify a performance standard(radon level),the manner of testing, and a testing procedure. 7. Passive required, except caulking not required Description All the components of the passive system would be required except for caulking the floor-to-wall joints, expansion joints, and utility penetrations. This alternative is based on the idea that caulking and sealing is no more difficuh or expensive for-the homeowner to complete than for the builder. The home would have a placard attached that states the passive system is incomplete, recommending a radon test and system completion and activation if needed, and that cracks must be sealed prior to finish However, in homes where the lowest living area of the home is"finished"during construction, so that the concrete joints and penetrations are no longer accessible, caulking and sealing would be required during construction. Advantages • Delays the cost of caulking and sealing until the homeowner finishes the lowest living area of the home, when cracks and joints are required to be sealed. • Limits requirements to only those components that must be installed during construction. Disadvantages • Because there is less radon reduction from the incomplete passive system,the owner receives less benefit from the money invested in other parts of the system, unless he/she opts to complete the system later. This factor would reduce cost-effectiveness. • Sealing and caulking, although technically possible, may be more difficult after construction. Many homeowners are likely to finish such areas without obtaining a building permit and inspection, which may cause the slab joints and penetrations to be inaccessible. • Description 8. Sub-slab preparation required This is a minimal alternative that would assure that every home could be successfully mitigated after construction. Sub-slab preparation would allow soil gasses to pass freely under the slab, assuring the effectiveness of a later-installed sub-slab depressurization system. Sub-slab preparation alternatives include: aggregate,perforated pipe loop, or soil mat. The latter two alternatives would have to be stubbed through the slab and capped, since it would be difficult to locate the pipe or soil mat after the slab is poured. A placard would be attached to home indicating how home has been prepared for radon mitigation, and recommending radon testing and mitigation, if needed Advantages • This is the least-cost alternative that assures that each home can be mitigated after construction. Disadvantages • No radon reduction benefit, unless the homeowner opts to mitigate after construction. • Mitigation requires an active system, usually with a vent pipe outside the building envelope. Homeowner loses the benefit of the stack effect that occurs when the vent pipe lies within the building envelope. 9. Mitigation required to below 4 picoCuries/liter Description • Require that each finished building be tested and that the test result must fall below a specific level. This gives the builder a choice whether to install passive or active systems during construction, or install retrofit systems after construction. The City would specify the performance standard (radon level), manner of testing, and enforcement mechanism Cost: not estimated Advantages • Less prescriptive -- focuses directly on limiting radon exposure. • Market forces and individual initiative determine radon mitigation practice within the limits of the performance standard. • Potentially less costly overall, if only houses that need radon reduction are equipped with radon systems. Disadvantages • More complicated for builders. Requires builders to become skilled in judging which building sites and housing types are more likely to need radon mitigation. • City must specify a performance standard(radon level),the manner of testing, testing procedure, and an enforcement mechanism • Although testing is desirable, it is hard to get an accurate test in the period of real estate transactions. • If the City denies Certificate of Occupancy unless the house is at or below 4 pCi/L on a short-term test,then about 70%of the houses would need at least a passive system Under that scenario, probably all builders would routinely install passive systems, and • the testing requirement would makes this alternative more costly than requiring passive systems. City of Fort Collins,Natural Resources Department January 28, 2004 • COSTS AND BENFITS OF RADON-RESISTANT NEW CONSTRUCTION The City of Fort Collins will soon decide whether to require radon-resistant new construction(RRNC) for single-family units as part of the Building Code. It is important to keep some questions in mind. What happens if we do nothing, i.e., leave things as they are? What are the benefits and costs of requiring a passive radon reduction system? What if an active system were required? Calculation details follow the narrative. What happens if we do nothing? About 14,400 single-family dwelling units would be built in the Fort Collins Growth Management Area before we run out of land. About 9,600 multi-family units would also be built, but they would not be covered by the current proposal. About 35,300 people would live in those homes. Radon exposure inside these homes would be about 3.0 pCi/L, which is the average of long-term, first-floor measurements in Fort Collins homes. Each new home is assumed to have about the same useful life as a person's lifespan, about 75 years. The above radon exposure over the homes' lifetime would result in about 311 lung cancer cases. USEPA reports that cancer risk estimates are uncertain by about a factor of two, so the expected number of cancer cases if we do nothing would lie in the range of about 150 to 600. If the City"does nothing,"the cancer risk would still be • reduced somewhat by voluntary installation of RRNC and by voluntary mitigation of homes after construction, but these are not included in the cost-benefit calculation. What are the benefits and costs of requiring a PASSIVE radon reduction system? Adding a passive system to each new home would reduce radon exposure by about 47%, with a consequent reduction in cancer cases of about 146. It would cost about $14.4 million to add passive systems to 14,400 new homes. It would therefore cost about $99,000 to avoid one case of lung cancer(range $50,000 to $200,000). What are the benefits and costs of requiring an ACTIVE radon reductions sum? An active system includes all the components of the passive system plus a fan. Adding an active system to each new home would reduce radon exposure to near-background level, or about 87%total reduction, with a consequent reduction in cancer cases of about 270. It would cost about $86 million to add active systems to 14,400 new homes, and to operate and maintain them for 75 years. It would therefore cost about $317,000 to avoid one case of lung cancer(range $150,000 to $600,000). • City of Fort Collins,Natural Resources Department January 28, 2004 • Calculation details Formula Definition Data Data source l or formula symbo NO RADON REDUCTION SYSTEM Units Number of new single-family 14,400 City of Fort Collins, dwelling units to be built Advance Planning Occupancy Occupants per dwelling unit 2.45 2000 Census People Number of people benefiting from 35,300 Units x Occupancy lifetime radon reduction Annual Rate Larimer County age-adjusted lung Males: 51.4 PHSD cancer rate, deaths/year Females: 27.9 Life-years Life expectancy, yeas Males: 75.2 PHSD Females: 77.7 Lifetime Lifetime lung cancer risk from all Males: 3865 Annual Rate x Life-yeas Baseline sources,per 100,000 population Females:2168 Risk Radon Fraction of lung cancers Males: 9.45% BEIR VI Fraction attributable to radon per Ci/L Females: 10.28% Radon Risk Lifetime lung cancer risk from Males: 365 Lifetime Baseline Risk x radon exposure, per 100,000 Females: 223 Radon Fraction population, per pCi/L Both: 294 -Exposure Average radon exposure 3.0 pCWL Borak Expected Number of cancer cases expected 311 People/100,000 x Radon • without mitigation Risk x Exposure PASSIVE RADON REDUCTION SYSTEM Reduction Avg. radon reduction achieved by 0.47 (47%) Kladder , citing three passive system studies Passive- Number of cancer cases avoided by 146 Expected x Reduction avoided passive systems Passive-cost Avg. cost of passive system $1,000 City of Fort Collins Passive-total Total cost of passive systems $14.4 million Units x Passive-cost installed Cost per cancer avoided with $99,000 Passive-total/Passive- passive radon reductions stems I avoided ACTIVE RADON REDUCTION SYSTEM (passive + fan) Background Avg. radon level achieved by 0.4 pCi/L Assumption: same as active system outdoor background, or about 87%total reduction Active- Number of cancer cases avoided by 270 People/100,000 x Radon avoided active systems Risk x(Exposure— Background Active-cost Avg. cost of active system $1,300 $1,000+$300 Operating Annual cost to operate& maintain $62 Electricity: $32/yea actives stem Maintenance: $30/ ear7 Active-total Total cost of active systems $86 million Units x [Active-cost+ installation and operation (Operating x 75 ears • Cost per cancer avoided with $317,000 Active-total/Active- active radon reductions stems I avoided City of Fort Collins,Natural Resources Department January 28, 2004 • 1 Bruce Cooper, Poudre Health Services District, personal communication 2 David Pawel, US Environmental Protection Agency, personal communication, based on Health Effects of Exposure to Radon: BEIR VI, Board on Life Sciences,National Academy of Sciences, 1999. The risk per pCi/L is calculated by dividing the geometric mean of two preferred risk models(page 96) by 1.25, the national average indoor radon level. 3 Borak, T.B., et al.;A Survey of Winter, Summer, and Annual Average Rn-222 Concentrations in Family Dwellings, Health Physics Vol. 57,No. 3 (September),pp. 465- 470, 1989. The average of first-floor, 12-month tests in a study of 100 Fort Collins homes is 3.0 pCi/L. ° Madder, D.L.; Proposal for the Addition of Radon Resistant Construction Techniques to the Appendix Of the Uniform Building Code— Supplemental Information, submitted to the International Conference of Building Officials, 1996 ' City of Fort Collins estimate, based on current market conditions 'Electricity assumptions: 60 watt fan operated continuously @ 6 cents per kilowatt hour. 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O n Radon Overview and Analysis of the City of Fort Collins Proposal to Require Radon Control Systems in New Residential Construction • Health District of Northern Larimer County Board of Directors—December 12,2003 Prepared by Bruce Cooper,MD and Polly Anderson Background Radon is an odorless,gaseous radioactive element that occurs naturally in earth and rock,well water and some building materials. It has been classified by the Environmental Protection Agency(EPA)and others as a Class A carcinogen because of the known connection between exposure and lung cancer. It is found throughout the United States,with higher than average levels in Colorado. Radon is drawn into homes and other buildings through cracks and openings in basements,crawl spaces and slabs. Radon levels vary from house to house,and are higher on the lowest level of a house. According to the EPA,exposure to radon has no immediate effect. However,over a person's lifetime,radon particles can enter the lungs,attach themselves and eventually lead to lung cancer. The EPA estimates that between 15,000 and 22,000 lung cancer deaths in the United States can be attributed to radon. Radon is the second leading cause of lung cancer in the United States,accounting for about 101/o of lung cancer deaths.' Studies show that smokers are at a higher risk of developing radon-induced lung cancer. The Health Effects of Radon Exposure From what is known about the biological mechanisms involved in the development of cancer,radon is an ideal suspect. Radon is radioactive—that means that radon atoms spontaneously decay to other atoms called radon progeny,releasing alpha radiation as they change.The electrically charged radon progeny can attach to dust particles in indoor air and be inhaled into the lunge where they continue to decay and emit alpha radiation.The radiation can disrupt DNA in lung cells which can be the initiating step in the development of cancer. Since alpha radiation can only travel short distances and cannot penetrate tissues like skin,lung cancer is the only potentially important cancer hazard from indoor radon. Evidence that radon indeed causes lung cancer comes from studies of underground miners whose high rates of lung cancer • have been linked to high levels of radon exposure and higher rates of smoking. The concern is that much lower levels of radon in indoor air in homes might pose an important cancer hazard.The most direct way to assess the risk posed by radon in homes is to compare life-long radon exposures among people who developed lung cancer with exposures among healthy controls,accounting for other causes of lung cancer such as smoking. About a dozen such studies have been conducted to date,but they haven't provided a precise answer on the level of risk because the risk is very small and it is difficult to estimate exposures over a lifetime. The combined evidence from these studies suggests that the risk is about the size that has been postulated on the basis of lung cancer data from miners(Darby, 1998).The most comprehensive examination of the evidence to date is the BEIR VI study sponsored by the U.S.National Research Council completed in 1999(BEIR VI). City of Fort Collins Current Indoor Air Radon Reduction Efforts Radon education and mitigation is central to the City of Fort Collins 2000-2003 Air Quality Action Plan. Efforts include: Information—Encouraging radon testing and mitigation Incentive—Low cost testing kit sales Ordinances—Radon information given at point of We,building code standards for voluntarily installed mitigation systems and inspector/mitigator certification requirements The Problem:Compliance with Current Recommendations The City's current radon program,which relies both on voluntary testing and mitigation,is similar to the programs of other municipalities in Colorado and across the nation. The problem with a voluntary system is that—even with fairly intensive public education—relatively few people test for radon,retest or mitigate when needed. A study of a community intervention radon program in the Washington,D.C. area(which has similarly high levels of radon)found the following behaviors related to radon testing and mitigation (Doyle et al, 1991): • 1 Home owners purchasing short term-test 6.5% Using short term-test if purchased 55.8% Using long-term test if purchased 55.8% Mitigating(if needed) 25% It should be noted that the radon program in this study utilized public education to increase both testing and mitigation. Low compliance levels can dramatically reduce the effectiveness and cost effectiveness of a voluntary program.Using the probability estimates from this Washington,D.C.study,and applying it to all Region 1 areas of the U.S.,Ford et.al. estimated that a radon remediation program recommending testing and remediation at or above the current threshold of 4pCi/L would cost about$320,000 to prevent one death from radon-associated lung cancer while preventing about 1317 lung cancer deaths. In contrast,using a full compliance estimate(everyone tests and everyone with high levels mitigates), about 122,000 deaths could be prevented at a cost of about$35,000 each. Radon in Fort Collins Average indoor radon levels from long term tests: Fort Collins National EPA Thrmhold 3.0 i/L 1.25 i/L 4 Ci/L The Fort Collins level is the mean level from a survey using first-floor,long-term tests conducted in 1989(Borah, Woodruff and Toohey, 1989). Short-term tests are often conducted in the lowest level of house(i.e. a basement or crawl space). The average of 6,900 short-term tests in Fort Collins have yield a higher average(7.1 pCi/L). The City's New Proposal:Active Radon Reduction Systems in New Construction In May of 2003 the City Council considered a proposal to require passive radon mitigation systems in all new construction. At the May 13 study session,Council directed City staff to look into an active mitigation system proposal. As with the passive system,City staff are soliciting public comment to help formulate their recommendation to Council. The Council is now considering the radon-resistant new construction as part of a major building code update (International Residential Code or IRC). The schedule(subject to change)for the IRC changes is: • December 16,2003—public hearing on the IRC(including radon) • February 10,2004—IRC discussion by Council • March 2004—adoption The new radon proposal under discussion is to require active radon mitigation systems for all new construction. The basic component of this system is identical to the passive system,with the addition of an electric fan. The passive system consists of a PVC pipe running from the gravel or dirt beneath the slab to the roof for gas venting. A polyethylene or plastic gas-retardant layer is placed and sealed between the slab and gravel or over the exposed soil or rock. The passive system also includes installation of an electric supply,should the homeowner or builder desire to install a fan. [Note: staff did not describe this component of the passive system in the March analysis,though this piece was included in the cost estimates.] The passive system was estimated in March 2003 to cost$522 per dwelling 3 New estimates from September 2003`are: Passive Foundation Options System Cost Sub-slab depressurization with gravel most common—described above $590 Sub-slab depressurization with perforated pipe 1 $1 101 h slab '%crawlspacc depressurization S494 2 Activation of the system requires installation of a$310 fans The annuatized cost for maintenance and operation of the • active system is$40/year(electricity is$4.75/year and fan replacement is expected every eight years). The City of Fort Collins estimates that radon levels are reduced as follows with each system: Passive: 47%reduction in radon levels Active: 87%reduction in radon levels City of Fort Collins estimates that 24,000 new homes housing 59,000 people will be built in the Fort Collins Growth Management area before the city runs out of land. Sixty percent of these(14,000 homes housing 24,000 people)will be single-family units and therefore subject to the proposed radon regulation. The EPA recommends testing homes with the passive system and if the radon level in elevated above 4 pCi/L,activating the system by adding a fan. Cost Effectiveness Analysis(CEA) City cost estimates Using risk estimates from the EPA based on BEIR VI risk models and exposure estimates based on radon levels measured in Fort Collins homes,staff in the City of Fort Collins Natural Resources Department constructed cost analyses using two different exposure estimates,one a worst-case exposure estimate from 6,900 consecutive short-term lower level radon tests in Fort Collins zip codes and another best case exposure estimate based on a one-year scientific survey of 56 fast floor Fort Collins dwellings conducted in 1988. The City's estimated that in a hypothetical community of 14,400 dwellings and 35,300(the predicted capacity for new single family dwellings in Fort Collins): Passive: Cancer reduction 146 cases(range 75 to 300)at a cost of$51,000 per case(range$25,000 to$100,000) • Note:The March analysis reported that the City concluded 200 cases would be averted with the passive system. Active: Cancer reduction 270 cases(range 150 to 600)at a cost of$42,600 per case(range$20,000 to$80,000) Health District cast estimates Expressing costs per lung cancer case averted does not fully reflect the savings and coats of resulting outcomes. Nor can this measure of cost be compared to cost-effectiveness ratios of other interventions with different purposes and outcomes. To make estimates more comparable,we conducted a cost-effectiveness analysis of the same hypothetical population using outcomes of years of life saved(YLS)and disability adjusted life years(DALYs). The analysis of the passive system uses the current approach as the comparison;the analysis of the active system uses the passive system as the comparison. Table 1—Incremental cost per life year gained Cost Estimated Lung Cancer Deaths Lung Cancer Deaths (perlife year ) Averted No Program 151 _ Current $21 900 148 3 Passive $17,405 130 21 18 over current Active $58,900 115 36 15 overpassive) Because the costs and outcomes of these interventions are spread over many years and because individuals prefer to receive benefits today rather than 20 or 25 years into the future,future costs and benefits were discounted at 3%per year as is standard in a cost effectiveness analysis(Siegel, 1996).We estimated that the useful life of the radon control system was a lifetime,and that the latency period to the first cases of radon induced cancer is 25 years.We used estimates on effectiveness of the system from the City's analysis. Estimates of the risk reduction were taken from the BEIR VI study. Baseline lung cancer rates and life expectancies were derived from county and state vital statistics,respectively.Costs of • 3 treating lung cancer and estimates of lost productivity were taken from other U.S.studies(analysis available upon request).All costs were adjusted to 1993 dollars to facilitate comparison with other studies(see Table 1). The most uncertain parameter in our model is the estimate of risk attributable to radon exposure in households.Using most and least favorable estimates of risk,the cost effectiveness ratio range as follows: Current:$12,800-$35,600 per life year gained Passive: $10,300-$28,000 per life year gained Active:$35,400-$93,000 per life year gained Table 2—Comparison of Select Health Interventions Life-saving intervention Cod per life- Reference year saved 1993 dollars Radon Control Radon remediation m homes with levels 2 4 i/L modified $80,000 Ford,SF et al(19") Radon remediation in homes with levels 2 4 i/L S 140,000 Pushkin JS(1989) Radon remediation in homes with levels 2 8.11 PM $35,000 Mos®an KL(1991) Radon remediation in homes with levels 2 21.6 $6,100 Nero AV(1988) Asbestos Control Ban asbestos in brake pads blocks S29 000 T 1994 Ban asbestos in clutch facinits blocks $2 700 000 T 1994 Ban asbestos in roof coatings $5 00 000 Tengs 0994 screening Pap smear far cervical cancer $15 600 Frieden RM 2002 Mammography for breast cancer $24 100 Friedenber RM 2002 COR M0 for colon cancer S 127,000 Frieder RM 2002 CXR and sputum to screening for lung cancer $93,000 Frieder RM 2002 Smoking cessation tw QO to S2,900 T 1994 Add NRT,and $1 00-53 00 Song F 2002 Add bumypion SR, $90042,150 Song F 2002 Add NRT plus bupropion SR $1,300-$2,800 Son F 2002 Hypertension screening,age 40(for heart disease and stroke) Men: $23,000 Littenberg B(1990) Women:$36,000 Public Health Initiatives Routine childhood vaccines and influenza in bwh risk adults <$0 T 1994 Fluoridation to prervent dental caries <SO Tengs 1994 Automobile Desizn Improvements Driver automatic vs.manual belts QO T 1994 Dual master Tinder brakes $13 000 Terms 1994 Collapsible columns $63 OOO T 1994 Side structure improvements to reduce door intrusion upon $110,000 Tengs(1994) crash Our estimate can be compared with a)other interventions to reduce exposure to residential radon,b)other prevention strategies our society has adopted,and c)alternative interventions targeted at primary prevention of lung cancer. Table 2 gives some estimates of the cost per YLL(1993 dollars)of a variety of prevention measures from published studies. First, note from Table 1,that the passive radon intervention has a more favorable cost-effectiveness ratio than both the current radon remediation strategy and the active system. Comparing both the passive and the active regulations with other prevention strategies shows that the passive falls within the range of cost considered"a good buy"and that the active is quite a bit more. An alternative intervention targeted at primary prevention of lung cancer—smoking cessation treatment—is very cost effective. Studies of smoking cessation advice have been conducted. Estimates of cost per life year saved range from<$0 to$2,900(Tengs, 1994). Using pharmacotherapy(quit aids like nicotine replacement or other pharmaceuticals)roughly doubles the cost(Song F,2002).Of course,the advantage of a requirement of new homes to include passive radon 4 reduction systems over smoking cessation interventions is that the former does not require any behavior changes. Smoking cessation programs are only effective for those motivated to quit • Because 70%to 901/6 of lung cancer deaths attributable to radon exposure occur among current and former smokers,it is more cost-effective to target radon-reduction programs at smokers than at non-smokers(Ford, 1999). Of course,if the choice were between radon reduction and smoking cessation,it would be more desirable to have smoker's quit smoking. However,because the interaction between these two risk factors is believed to be multiplicative,lung cancer prevention will be most effective if efforts are made to reduce risk from both. Other Options for Risk Abatement The City's proposals to require passive or active radon mitigation systems in all new construction is only one of many options the City has considered or could consider to lower the risk of radon exposure and consequent illness. A partial listing follows: 1. Status quo • Information at point-of-sale • Mitigation system installation standards • Mitigation/testing certification requirements 2. Increase education efforts to increase testing and mitigation by homeowners and/or builders 3. Required testing on all homes(new or new and old) 4. Required mitigation system installation on all homes(without testing) 5. Required mitigation system installation on all homes or home sites with certain actual or expected radon levels (new or new and old) 6. Targeted radon-reduction intervention for smokers Reasons to support the City's active mitigation system proposal: • Residential radon exposure is a known health risk in Fort Collins. • • The active system is more effective at reducing radon levels than both the passive system and the City's current program of voluntary testing and mitigation and will save more lives. • Active radon reduction requirements in new construction do not require owners to take action. Owners do not need to purchase radon-screening devices,retest their homes or mitigate in order for their families to benefit • It is easier and less expensive to install the active(and passive)system during construction rather than after. • Public comments appearing on the City's web page solicited as part of the public input process include the following ideas(note:most were written in response to the City's original proposal for a passive system): • Costs for the system are nothing compared to cancer. • Passive requirement is better than requiring active. • Passive systems don't do enough to lower levels so active is better(from an anonymous radon professional). Reasons to oppose the City's actor mitigation system proposal: • The active system is less cost effective than the passive system and is expensive when compared to other prevention strategies. [The passive system compares favorably with other strategies.] • The added expense of the fan for the active system is unnecessary for homes with low radon levels. • Public comments appearing on the City's web page(some on the active system some on the passive system) include the following ideas: • It is the City's responsibility to educate on this issue,not regulate. • Additional regulations will increase the already high cost of housing in Fort Collins. • The addition of the fan should be the responsibility and choice of the homeowner,not the builder or government. • Radon levels vary too dramatically to mandate one system for all new construction. • 5 Some who argue against mandatory(or even voluntary)radon mitigation or testing call into question the use of the linear no-threshold(LRT)model to The LRT model applies the fact that a estimate risk(see box at right). The critics of the science behind establishing single particle of radiation hitting a radiation thresholds have suggested that background radiation—such as the single biological cell can initiate a relatively low-levels of naturally occurring radon—might actually stimulate canner,and then assumes that the our biological defense mechanisms.However,it should be noted that: number of these initiating events would be proportional to the number 1. The LRT model is the scientific standard for calculating radiation of particles of radiation(dose and risk. response). To simplify further,the 2. Knowledge about the health effects of radon gas exposure has theory uses data extrapolated from increased markedly in the last few years(Kennedy,2002).Work such high-level radiation doses—such as as BEIR VI and the findings of several multinational collaborative the radon exposure and related lung groups have provided exposure-risk estimates with greater cancer rate of miners—to calculate confidence. acceptable low-dose exposure for the 3. Risk measures from meta-analyses of epiderniologic studies of general public. Critics of this theory residential radon exposure using case-control studies that don't rely say that this model igaorea the on modeling suggest that risk at lower levels of exposure is about that can price]defense numerous exposures that that would be predicted from extrapolating miner data using the LRT cm prevent numerous exposures from model(Darby, 1998,Stigum,2003). alternating into of the. The alternative to usea of the linear no- threshold hypothesis is a threshold hypothesis. In this hypothesis, Board of Directors position: radiation results in cancer only when On December 12,2003,the Board of Directors of the Health District of there is enough radiation to Northern Larimer County voted to uphold their March 2003 decision to overwhelm the threshold mechanism. recommend that the City of Fort Collins require installation of passive radon-redaction systems in new construction. This recommendation is made over both the City's current education program and over the current proposal to require installation of active radon-reduction systems in new construction. Literature Reference List BEIR VI.Health Risks of Exposure to Radon:BEIR VI.Washington,DC:National Academy Press; 1999. Borak T.B.,Woodruff B.,Toohey,RE.A survey of winter,summer and annual average Rn concentrations in family dwellings. Health Physics. 1989;57(3):465-470. Darby,S.;Hill,D.,and Doll,R.(Clinical Trial Service Unit,University of Oxford,UK.sarah.darbyQa ctsu.ox.ac.uk).Radon:a likely carcinogen at all exposures.[Review][58 refs].Annals of Oncology.2001 Oct; 12(10):1341-51. Darby,S.;Whitley,E.;Silcocks,P.;Thakrar,B.;Green,M.;Lomas,P.;Miles,J.;Reeves,G.;Feam,T.,and Doll,R.(ICRF Cancer Epidemiology Unit,University of Oxford,Radcliffe Infirmary,UK).Risk of lung cancer associated with residential radon exposure in south-west England:a caw control smdy.[eomment].British Journal of Cancer. 1998 Aug; 78(3):394-408. Doyle J.K.;McClelland G.H.;Schulze W.D.;Elliott SR.,and Russell G.W.,Protective responses to household risk:a case study of radon mitigation. Risk Analysis. 1991; 11121-134. Ford,E.S.;Kelly,A.E.;Teutsch,S.M.;Thacker,S.B.,and Garbe,P.L.(National Center for Environmental Health,Centers for Disease Control and Prevention,Atlanta,GA,USA,esf2®cdc.gov).Radon and lung cancer:a cost-effectiveness analysis. American Journal of Public Health. 1999 Mar,89(3):351-7. Friedenberg R.M.The 21st century:The age of screening. Radiology.2002;223:1-4. Kennedy,C.A.and Grey,A.M.(Health Economics Research Centre,Institute of Health Sciences,University of Oxford,UK. christine.kennedy@institute-of-health-sciences.oxford.ac.uk).Cost effectiveness analysis of radon remediation programmes. Science of the Total Environment.2001 May 14;272(1-3):9-15. Kennedy,C.A.;Grey,A.M.;Denman,A.R.,and Phillips,P.S.(Health Economics Research Centre,Institute of Health Sciences, University of Oxford,UK).A cost-effectiveness analysis of a residential radon remediation programme in the United Kingdom.British Journal of Cancer. 1999 Dec;81(7):1243-7. Kennedy,C.A.The cost-effectiveness of residential radon remediation programmes:assumptions about benefits stream profiles over time.Journal of Environmental Radioactivity.2002;59(1):19-28. 6 Lagarde,F.;Perahagen,G.;Akerblom,G.;Axelson,0.;Baverstam,U.;Damber,L.;Enflo,A.;Svarwngten,M.,and Swedjemark,G. A.(Institute of Environmental Medicine,Karolinska Institute,Stockholm,Sweden).Residential radon and lung cancer in Sweden:tick analysis accounting for random error in the exposure asseasment[comment].Health Physics. 1997 Feb; • 72(2):269-76. Littenberg B.;Garber A.M.,and Sox I.I.C.Screening for hypertension.Ann Intern Med. 1990; 112 192-202. Lubin,J.H.and Boice,J.D.Jr(Epidemiology and Biostatistics Program,National Cancer Institute,Bethesda,MD,USA).Lung cancer risk from residential radon:meta-analysis of eight epidemiologic studies.[commem].Journal of the National Cancer Institute. 1997 Jan 1;89(1):49-57. Lubin,J.H.;Boice,J.D.Jr;Eding,C.;Hornung,R.W.;Howe,G.R.;Kunz,E.;Kusiak,R.A.;Morrison,H.I.;Radford,E.P.; Samet,J.M.and others(Epidemiology and Biostatistics Program,Division of Cancer Etiology,National Cancer Institute, Bethesda,Md 20892-7368,USA).Lung cancer in radon-exposed miners and estimation of risk from indoor exposure.Journal of the National Cancer Institute. 1995 Jun 7;87(11):817-27. Mossman,K.L.and Sollitto,M.A.(Department of Radiation Science,Graduate School,Georgetown University,Washington,DC 20007).Regulatory control of indoor Rn.[conu ent].Health Physics. 1991 Feb;60(2):169-76. Nero AV.Elements of a strain for control of indoor radon.in.Radon and Its Decay Products in Indoor Air.New York:John Wiley; 1988. Pushkin J.S.and Nelson C.B.EPA's perspective on risks from residential radon exposure.J.Air Pollut Control Asso. 1989;39:915- 920. Siegel,J.E.;Weinstein,M.C.;Russell,L.B.,and Gold,M.R.(Department of Maternal and Child Health,Harvard School of Public Health,Boston,Mass,USA).Recommendations for reporting cost-effectiveness analyses.Panel on Cost-Effectiveness in Health and Medicine.[comment].[Review][17 refs].JAMA. 1996 Oct 23-1996 Oct 30;276(16):1339-41. Song,F.;Raftery,J.;Aveyard,P.;Hyde,C.;Barton,P.,and W oolacott,N.(Department of Public Health and Epidemiology, University of Birmingham,Edgbaston,Birmingham,B15 2TT,UK.f sonS@bham.ac.0 k).Cost-effectiveness of pharmacological interventions for smoking cessation:a literature review and a decision analytic analysis.[Review][39 refs]. Medical Decision Making.2002 Sep-2002 Oct 31;22(5 Suppl):S26-37. Tongs T.;Adams M.E.;Pliskin I.S.;Safran D.G.;Siegel J.E.;Weinstein M.C.,and Graham J.D..Five-humdrted life-saving interventions and their cost-effectiveness.Risk Analysis. 1994; 15(3):369-390. • Environmental Protection Agency Radon Frequently Asked Questions,U.S.Environmental Protection Agency(http://www.epa.gov/iag/radon/radoncial.htinl) t The Costa and Benefits of Passive Radon Control Systems in New Residential Construction,City of Fort Collin&,2/28/03. `Coffitruhction Cost Estimate City of Fort Collins:Radon Mitigation Program New Smglo-Farmly Dwellings,B&C Project Services for the City of Fort Collins,Natural Resource Department.September 22,2003. 'Ibid About this Analysis This analysis was prepared by Health District of Northern Latimer County staff to assist the Health District Board of Directors in determining whether to take an official stand on various heahh-related issues. Analyses are based on bills or issues at the time of their consideration by the Board and are accurate to the best of staff knowledge.To see whether the Health District Beard of Directors took a position on this or other policy issues,please visit www.healthdistria.org/policy. About the Health District The Health District is a special district of the northern two-thirds of Latimer County,Colorado,supported by local property tax dollars and governed by a publicly elected five-member board. The Health District provides medical,mental health,dental, preventive and health planning services to the communities it serves. For more information about this analysis or the Health District,please contact Polly Anderson,community projects coordinator at • (970)224-5209 or panderwn@healthdiatdct.org, This publication is on file in the Office of the City Clerk at City Hall West, 300 LaPorte Avenue =,EPA A Citizen's Guide To Radon (Fourth Edition) The Guide To Protecting CDC Yourself And Your Family From Radon �! L 3, �f Y 4 5: A f J •, . I• , Ilr an \„Yi�V•i 1 .,y1. i .w.A00, Printed on Recycled Paper(50% Post-Consumer Content) http://www.epa.gov/iaq/radon/pubs/citguide.htmi • LARIWR COUNTY RADON REQUIREMENTS Summary New homes in new subdivisions must be built with passive radon reduction systems and must be tested for radon before occupancy. These requirements originate in recommendations from the Colorado Geological Survey, which reviews all county subdivision plans. The requirements are included in both the subdivision agreement and in building permits issued for each home in the subdivision. Details 1. Whenever land is subdivided into parcels less than 35 acres, Planning& Building Services requests a land use review by the Colorado Geological Survey(CGS), as required by Senate Bill 35 (1972). CGS notes the potential for indoor radon among the many geologic factors it reviews. In practice, every subdivision review comes back with a notation about radon, because all of Latimer County is designated a Zone-I radon area, where indoor levels likely to exceed four picoCuries per liter of air (4 pCi/L). 2. The Board of County Commissioners then places a condition of approval on the new subdivision. A statement such as the following is placed on the final plat and included in the Resolution of the Board of County Commissioners that approves the • plat: Passive radon mitigation measures shall be included in construction of residential structures on these lots. The results of a radon detection test conducted in new dwellings once the structure is enclosed but prior to issuance of a certificate of occupancy shall be submitted to the Planning Department. As an alternative, a builder may present a prepaid receipt from a radon tester which specifies that a test will be done within 30 days. A permanent certificate of occupancy can be issued when the prepaid receipt is submitted. 3. Planning & Building Services includes a parallel requirement in each building permit. Included with the building permit are drawings that illustrate the passive radon reduction system recommended by USEPA, as guidance to the builder. 4. Planning and Building Services inspects the passive radon system twice: first the below-slab components, second the above-slab components. 5. Testing for radon is required as a precondition to receive a Certificate of Occupancy. Test results become part of the permanent record for each building. The builder is expected, though not required,to pass along the radon test results to the homebuyer. In addition, Planning & Building Services may also inform the homebuyer by letter, if the radon test comes out higher than a selected level, currently 10 pCi/L. • Source: Fort Collins Natural Resources Department, based on conversations with Larimer County Planning &Building Services staff, April 2003 O �a C) �+ O Apr OD N + ii p a� n L N N M _ � O U) co LL V = fl. Ln M ci rl � O Z C) y IT � d LL N G ro :::;: co i II ° to CL +� Oil V L�I�yF U , 01 :.lie74 _..:...._�;.._.._ O M _ eYf V O ■i O O �E 0 0 0 0 0 0 0 ■� o 0 0 0 0 0 0 33I21d 31VS MON AIIWV:J 319NIS D" ........... ....... ...... ............ ....... . ...... . .... .... ..... . . ......... ..... ......... .... ... ...... . ....... ............. ........ 5 4, n*n -fl'i ........... pMM; UP.11.. . . .. .. Ng •zo: .M.E.q. 24. 1 14. • • r,.�,,�;;;,;`n,.�:!r ily{rv; ><IY' :;_7�::1:,.,::-!,=;:n=-'�`':�'�-II�w::x. .:'�!r �;- �;�yr.:: rs�r`;=y';m •ka`,1,C,.F:q;;.,l::..,,IJ..i !�;a:�;..:J;;Ni"::1�:.,.:,: ::.rx„ 1 If" c'!i:': r,�. .,,a.'•H'i rFi��:,. r H.;_�rh'.;,g4�::�,i,.'S;II �r>. ,.:1�+,':�'ji.,,:;1.-auNi . ...f, �j`[Ill'iYY.^:ipp-gnl•:n•�::ai{.i:nIua.:l!iq.(�.:ra'� "` ..1 '� � J �� :1- :. ..... Y`I:�'%li :IF .1:..,h,F .5, ,,,N f- ,:., .ll. r J@1 r:r :::1..:.i ky. r,_ .� { ^:;.1+: ,,1y _ 1. .� 1ptt Mi Ilr:rl r� L'.: 'TNAu.,l..�N,.r.ry F'. : .a uMi16^ILLHxi;, i:i1 '�.T16S ad 'kira al'k'' : � OR'?'" tuj 144 � ! Iii3�r��.L..td 1p.rS:: o t q : • • ',zH kP ; ' P� 1 21.TIE-IN !— 1Ii B,1t '='3�...:!�!..yd f'`-,;11�;:,! :.].I y�;, ����"i�: pp41 : ,In..:O.T.; ' 1 9! �1 Ar '�4 e, -�?y_' ,Q 1 fi't ' N r '�tBiI!0 4".,I�III �,W(, r, { h�� IN 1�i- TF I�judlrPl,l1s'dn' prNie�tH'Sth f hhn • '�s ,r ,.,_ r,,,,., r�a::.. I i�n t II I DI tl} �'6. 1L, H nnl� i ,.,.. • Q . ..Ir{:..r.,:: .. . yi .IV.:�.r..i.., .. :. .1 ' r�, =r'�:.�'+. .;14.1 1:1 ... . fl5r :.1_ r:dr::�a:.l.r:.,:r:::; • 1 • ■ ! , ul. .u:.: .. �vltyAdN�' r i..r[ ...............::.::.a:__!:a::..ay.:::.Si.irv:a.:via_ :ii;a�Wi6:ii:�' �"Au'1I11rui.ic�;a::W;: r • / 1 1 1 milli • • :,; Y I r.: .. ... ... ..... .... :4 del, od � ...,. �...'sn.:.....: :...:::.... .......... !'lirr i v _p. :::_ 1 1 �■ • \ ■ the building dt zoning dept. Fort Collins Community Planning and Environmental Services P.M BM FAX 13 22A 61_ GN aft 1 CHANGES IN NEW RESIDENTIAL BUILDING CODE February 3,2004 On December 16, 2003,the Fort Collins City Council held the first public forum on the proposed 2003 INTERNATIONAL RESIDENTML CODE (IRQ8 prior to the adoption hearing and First Reading, tentatively set for March 2nd. The new code, published by the INTERNATIONAL CODE COUNCIL, Inc. specifically for new one- and two-family dwellings and townhouses, is the latest model building code now in effect for much of the country. A City Council study session set for February I to review testimony from the December public forum and to give staff guidance on the array of possible draft amendments. Although the initial costs associated with the new code and all amendments are estimated in the range of 2% to 4% of purchase price, the savings from the proposed new energy conservation standards is expected to reduce monthly energy bills by 15%to 30%. The draft changes have undergone an extensive sixteen-month review by a task group of Fort Collins and Larimer County code officials, public board members, various builders, technical specialists, and representatives from the Home Builders Association of Northern Colorado. Key new provisions in the IRC and local amendments are highlighted below. • Safer, less steep stairways that add 20 inches to overall stairway length. • A continuous structural connection from foundation to roof to resist wind uplift. • • A water barrier behind fiberboard lap siding to protect structural sheathing and building interior. • Updated energy-conservation construction standards providing increased energy-conservation and performance— A Exterior wall insulation increased from R-15 to R-18 in new homes except for homes no larger than 1,600 sq. it. could retain current minimum R-15 wall insulation. Window performance increased from R-2 to R-3 with added solar shading factor. Heating &Cooling (HVAC)— o All ductwork must be sealed with approved sealants. o Concealed return-air framed cavities must be leak-tested. o All HVAC systems must be sized&tested to national standards for safety and operation. o New AC systems must meet 2007 Federal minimum energy-efficiency rating. • Indoor air quality(IAQ)— sA Required moisture control and ventilation for interior under-floor spaces with exposed ground surfaces,to prevent damage from excessive moisture and potential mold. sA Fiberglass insulation on basement walls must be protected from damage and release of airborne glass particles by permanent wall covering materials (gypsum wallboard,paneling, etc.) • Possible radon venting methods now on the table— sA Basic naturally-vented(`passive's system with provisions for firture ("active') fan. 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E a O o N N mao E y0 p E -0 m dca0 W o cjJ >`N Co N .0 Z y C U U > N"' N > C 0O7 ` UNLaN Uj -OC N Tr OC •O- 8 O N N N p m - C m m 0cc (� E Y C? 3 a) C `g C, C OG C y O Ma fl N - � E �co N 3 -9 a) Hw yam do Ey:2 t °N' taoapit� L � ood HEI— N"OH� F-dcia December 16, 2003 Excerpt from Draft City Council Minutes Public Hearing on Draft Changes and Amendments to the 2003 International Residential Code(IRC) ®. Held. The following is staff s memorandum on this item. EXECUTIVE SUMMARY The purpose of this hearing is to provide Council a public forum in which to hear a variety of responses to the draft changes and amendments to the 2003 International Residential Code(IRC)® (the latest version of the nationally-recognized "model"residential building code); and to obtain information on which to base an informed decision for adoption. Following the public hearing, the proposed changes and amendments are scheduled to be considered by the City Council at a study session on February 10, 2004, after which staff will present ordinances proposing the changes and amendments at a regular Council meeting. The draft changes and amendments to thelRC®have undergone a sixteen-month review by staffand a joint Fort Collins-Larimer County task group. This latest residential building code, already in effect in much of the country, replaces the now-obsolete Uniform Building Code currently adopted by Fort Collins. It specifically covers only new one- and two-family dwellings and contains some ofthe most significant potential changes to the Fort Collins Building Code in many years, including important new provisions for: • Indoor Air Quality: Radon-reducing venting systems and interior moisture control/ventilation systems. • Energy Conservation: Updated energy-conservation construction standards providing increased energy- conservation and performance, and a new optional simplified compliance table. • Architectural Features: 1) Safer, less steep stair geometry with lower risers and greater step depth. 2) Lower minimum ceiling height. • Structural and Exterior Elements: 1) Structural connection from foundation to roof. 2) Weather-resistant membrane backing behind lap siding. FINANCIAL IMPACT Fees The draft amendments relocate buildingpermit and plan review fees from the building code to the 1 December 16, 2003 Excerpt from Draft City Council Minutes City Code, Chapter 7.5, "Administrative Fees", which is administered by the City Manager. The change provides greater responsiveness and flexibility to adapt to changing economic conditions and service demands. No fees changes are proposed except for anew amendment that codifies the current policy for issuing "Foundation and Framing" (F& F)permits and increases the amount of the flatfee from $150 to $200. An "F& F"is a limited conditional permit that allows builders to start and complete construction up to the unfinished structure and shell without paying the full building permit fee and associated Capital Improvement Expansion Fees, and other related utility fees. Increased Construction Costs Some provisions of the 2003 INTERNATIONAL RESIDENTIAL CODE (IRC) ®and amendments as drafted will have an impact on the cost of new housing construction. BACKGROUND (A) TASK GROUP A local volunteer group, made up of building code off cials from Fort Collins and Larimer County, City board members, builders, private building specialists, and representatives from the Home Builders Association of Northern Colorado, has been meetingfor thepast 16 months examining the model code plus local amendments. Although the Task Group's purpose is to represent a range of perspectives and not to achieve consensus, general agreement was achieved on many issues. Members were encouraged to, and often did express opinions/suggestions on the draft code update package. The major remaining issues are: Roof to Foundation Connection: No significant net cost increase. Cost of IRC requirement for a continuous roof-to-foundation connection to resist wind-uplift forces will be offset by more extensive wall-bracing provisions currently in effect. Stairs: The modest cost for actual stairway construction is not the significant issue.More important are the constraints associated with compact home designs and the greater floor opening dimensions created by the added 20 inches of horizontal stair length. This requirement would have the greatest effect on newer higher-density developments containing homes have compact floor plans on smaller lots, where a two foot increase in stair length can affect the entire exterior footprint. Under floor moisture control: A vapor retarder is now required on any exposed interior ground surfaces. The draft amendments would require sealing and attaching the membrane to the foundation wall. Additionally, in the 10% - 15% of new homes with suspended structural 2 December 16, 2003 Excerpt from Draft City Council Minutes basement f oor systems, the new provisions require special criteria for the under floor space below if the basement f oor is wood, and therefore subject to moisture damage and f ngal growth. In such cases, the draft amendments specify enclosed-combustion or power-vented heating and water-heating appliances to reduce thepossibility of"down-drafting"combustion products into the living space when they are located in basement space above;and a moisture ventilation system with a continuously operating fan. Radon-resistant construction: The IRC® does not mandate radon systems, but provides an optional appendix chapter for jurisdictions that opt to do so. One of the following three mandatory draft options for only new construction are provided; a) passive system, b) a continuously-operatingfan "active"system, orc)active systemfor homes with basements and passive systems elsewhere. Siding Weather Backing: The IRC®specifies water-resistant membrane("house wrap')attached to exterior sheathing behind fiber board or hardboard lap siding. Energy Conservation: IRC®increases wall insulation performance fromR-13 to R-18. IRC®increases windows thermal performancefrom U-0.5(R-2)to U-0.35(R-3)and specifies solar filtering factor(SHGC) of 0.4. HVAC IRC®requires sealing all ductwork. Amendment requires frame cavities used as ducts be tested for leakage. Amendment stipulates testingfor manufacturer's specification and for combustion safety. Amendment specifies newA C equipment must meet the 2007Federal efficiency standard upon adoption. (B) SCHEDULED PUBLIC MEETINGS DATE/TIME PUBLIC HEARING TYPE • November 20, 2003, 1:00 p.m. Building Review Board • November 20, 2003, 5:00 p.m. Air Quality Advisory Board • December 3, 2003, 6:00 p.m. Natural Resources Advisory Board • December 4, 2003, 4:00 p.m. Affordable Housing Board • December 16, 2003, 4:00 p.m. City Council—Public Hearing • December 18, 2003, 1:00 p.m. Building Review Board • January 21, 2004, 5:00 p.m. Electric Board • February 10, 2004, 6:00 p.m. City Council -Study Session • March (?), 2004, 6:00 p.m. City Council -First Reading 3 December 16, 2003 Excerpt from Draft City Council Minutes (C) RANGE OF OPTIONS The draft code changes could have long-term effects in terms of both housing costs and public benefit. " Mayor Martinez stated that this was a public hearing. City Manager Fischbach introduced the agenda item. Greg Byrne, CPES Director, presented background information regarding the agenda item. He stated that this public hearing would lead to a Study Session on February 10 and that this was an opportunity for the public to be heard. He stated that extensive background materials had been given to the Council. He stated that all of the options were technically sound and had the endorsement of the Building Official. He stated that there were important cost considerations and policy options for the Council to consider. He stated that staff wanted to hear questions and concerns from the Council and the public. Felix Lee,Director of Building and Zoning, stated that the purpose of revising the current building codes was two-fold. He stated that the building code review process occurred on a regular three- year cycle when model codes were updated and published. He stated that the City had historically adopted the new building code with its own local amendments. He stated that the code review and adoption process was an opportune time to include any new provisions that offered improved health, safety and welfare benefits to the community. He stated that this code cycle offered an opportunity to correct many of the current energy efficiency problems in current construction practices identified in the New Home Energy Efficiency Study of July 2002. He stated that this code cycle was unique in that the City would be considering a published code that was the product of a historic merger of three national principal code writing organizations. He stated that the 1997 Uniform Building Code was being phased out nationally and that the UBC had been adopted by the City since 1958. He stated that the International Residential Code contained all needed regulations in a single code book. He stated that a volunteer group which had convened twice monthly over the past 16 months included code officials, public board members, builders, building specialists, nonprofit energy specialists and representatives from the Homebuilders Association of Northern Colorado. He stated that the process was not consensus driven at the outset and that it was made clear that the idea was to represent as many perspectives as possible. He stated that the draft code had been presented to the Building Review Board,the Air Quality Advisory Board,the Natural Resources Advisory Board, and the Electrical Board and that it would be presented to the Affordable Housing Board in January. He stated that the Building Review Board would be conducting a second review with the added cost data that was included in the Council's material. He stated that the draft code amendments included administrative housekeeping changes and several important technical revisions. He stated that the major changes that would have the most impact on home construction practices related to safety, architectural features, indoor air quality, and energy conservation. He explained in detail the 4 December 16, 2003 Excerpt from Draft City Council Minutes proposed changes in requirements relating to minimum ceiling height in habitable rooms(from 7.5 feet to 7 feet),a less steep and safer stair geometry, fan-powered moisture exhaust ventilation pipe, and energy efficient enclosed combustion of power vented heating and water heating appliances. He explained the radon system options: a passive radon system with provisions for a future fan installation, fan installation at the time of construction, fan installation only in new homes with basements, or a sub-slab area beneath the basement floor slab which would have a layer of gravel vented to the roof. He described the proscriptive compliance method in the energy code and explained new thermal criteria that would specify an increase in the wall insulation (from R-15 to R-18) and window thermal performance (from R-2 to R-3) with the added required feature of a minimum solar shading factor to reduce summer cooling loads. He stated that all joints and seams in HVAC systems must be sealed with approved sealants and that frame cavities used as part of the duct system must be pressure tested for leakage. He stated that new air conditioning systems must meet seven federal standards and that all systems must be tested. He stated that the size of heating and cooling systems would be limited to the size set out in industry standards. He stated that vinyl faced fiberglass insulation would be required to be protected from damage to prevent the release of carcinogenic materials. He presented visual information relating to the range of options and the range of associated buyer costs. He stated that 52 other jurisdictions in the State had adopted the IRC and that 30 had adopted the new energy standards. He stated that no other jurisdiction in Colorado was requiring radon mitigation with the exception of Latimer County in specific subdivisions. Mayor Martinez stated that each participant would have three minutes to speak at the public hearing. Greg Snyder, 619 Bear Creek, stated that Fort Collins was below the State and national averages in lung cancer rates. He stated that radon mitigation would be fixing a problem that did not exist. He stated that he had seen an article in Forbes magazine that discussed studies that had been done to show that low levels of radon and radium were beneficial to people's health. He presented copies of the article to the City Council. Leo Bucellato spoke regarding the dangers of radon and the benefits of radon mitigation. He asked that the Council not underestimate environmental problems facing the community. Juliette Wilson spoke regarding the benefits of radon mitigation. She stated that the costs of radon mitigation systems would be less than the costs of cancer. Jim Lane stated that he had seen no definitive scientific studies showing that radon was an issue. He stated that the EPA had never issued a final rule regarding radon, and that science should lead regulation. He questioned how radon could be a problem when Colorado had the third lowest lung cancer rate in the country. He stated that those in the mitigation business and City staff would gain from passage of radon mitigation requirements. 5 December 16, 2003 Excerpt from Draft City Council Minutes Bob Peterson, small business owner and builder, spoke regarding the impact of the model energy code of 1997 on affordable housing and remodeling and renovation projects. He stated that the regulations needed to be adjusted so that local builders could make a living. He stated that more regulations equated to more cost. He stated that the IRC was a good code but that the proposed amendments to the IRC such as radon mitigation and the energy code were an invasion of our rights to make choices. He stated that the cost of the radon system in the future had never been addressed. ("Secretary's Note: The Council took a brief recess at this point.) Darrel Schriner, construction employee, stated that some of the code changes would raise the price of homes. He requested that the Council consider some of the projects that were currently underway. He stated that he was requesting that some existing approved plats grandfathered to allow them to remain under the 1997 code. He stated that some plats would have to change if they were required to meet the new requirements, that some model homes would have to be remodeled, and that there would be confusion on the part of homebuyers. He stated that the best way to mitigate radon was to open doors and windows on a daily basis. Jamie Basler stated that the costs of running the fans in an active radon mitigation system had not been addressed. He stated that the energy demand of a radon fan was 60 watts (.06 kilowatt) and that the life of home was 75 years. He stated that the energy used per system was 39,420 KW and that the current cost would be 6¢per kilowatt. He stated that the operational cost for the life of the home would be$2,365 and that the cost to consumers for the 14,400 new homes built over the next 20 years would be S34 million. Peter Benson, Village Homes, supported the IRC and spoke against adding the other options. He stated that his company already offered some of the options as a choice but that not every builder or homeowner should be forced to pay for the options. He stated that radon mitigation was based on "bad science." He asked that the IRC be approved without the radon mitigation requirement. Will Harper, Fort Collins Board of Realtors, stated that all homeowners should have full use and enjoyment of their homes as free government interference as possible while maintaining the public good. He supported the current process of informed choice regarding radon mitigation. He stated that the adoption of an ordinance requiring radon mitigation in new construction would eliminate informed choice for new homebuyers. He asked that the City consider the impact on the increasing cost of new home construction. He stated that the ability to have affordable housing for all citizens was further eroded by the passage of each new ordinance that added to the cost of new homes. He stated that passive radon mitigation systems were adequate in most cases to preserve the integrity of housing costs without compromising health and quality of life for homebuyers. He stated that homebuyers could choose to enhance the system. He stated that the Board of Realtors would support a requirement for passive radon mitigation systems rather than active radon mitigation systems. 6 December 16, 2003 Excerptfrom Draft City Council Minutes Eric Levine, 145 North Meldrum Street,spoke in support of active radon mitigation systems in new housing. He stated that lowering exposure to powerful cancer-causing agents such as radon would lower the incidence of cancer and save lives. He stated that Larimer County required passive radon mitigation systems in nearly all new subdivisions. He stated that animal studies agreed that radon was dangerous and caused cancer. He stated that this was probably the single most important issue the Council would wrestle with and that it was a "life or death" issue for hundreds of people purchasing new homes in Fort Collins. He stated that much of what was before Council had been recommended many years ago by the Air Quality Advisory Board and that no action had been taken. He stated that radon was deadly and that the City's program fell short of what the County had been doing for the last seven years. Rondell Ferguson, Fort Collins Board of Realtors, stated that there was no sufficient data to make any conclusive statement linking lung cancer with elevated radon levels. She stated that an EPA study found that no significant change in the relationship between radon levels and lung cancer had been observed. She stated that outdoor air contained about one part radon for every two trillion parts of air. She stated that there was no concrete evidence that radon was linked to lung cancer. Harry Pullman,remodeling contractor,urged the Council not to require mandatory radon mitigation systems. He stated that staff was proposing that heaving and cooling systems not be oversized,yet the proposal was to put radon mitigation in every house whether it was needed or not. He stated that his company always encouraged customers to test for radon during basement remodels. He stated that if radon mitigation was installed in new housing that it would not take into consideration how basements would be finished in the future and the cost of having to do it more than once. Jim Wetzler,Fort Collins Board of Realtors,stated that active radon mitigation systems would need to be replaced every three to five years at a cost of approximately $300 for parts and labor. He stated that Larimer County had one of the lowest lung cancer mortality rates in the country. He stated that a passive mitigation system might be sufficient and cost effective. He stated that passive systems could easily be turned into active systems if necessary. He stated that the cost for adding radon mitigation during construction was approximately$350-$500 per unit building as opposed to $800-$2,500 for retrofitting an existing structure. He stated that the citizens should have the right to make personal choices concerning their own homes. He stated that the proposed regulation for adding passive or active mitigation systems to new homes would remove personal choice and would drive housing costs up. He stated that the Board of Realtors advocated a passive system if one must be mandated at all. Dr. Bruce Cooper, Medical Director of Health District of Northern Larimer County, stated that the Board of the Health District considered the issue of radon reduction system systems, gave careful consideration to the exposure levels in this area, considered the science behind the risks of radon at those concentrations,and discussed the costs of regulation. He stated that the Board recommended that the City add passive radon reduction systems to building codes. He stated that the Board had 7 December 16, 2003 Excerpt from Draft City Council Minutes recently discussed whether active systems would be better. He stated that active systems would save more lives but that after consideration of cost effectiveness issues the Board supported passive systems as being more cost effective than active systems. He stated that there was undisputable evidence that radon exposure for miners caused significant lung cancer and that there was accumulating evidence that exposure to the radon levels in housing caused lung cancer. He stated that the National Research Council had said that between 10-14%of lung cancers were caused by radon exposure at the levels seen on average across the nation. He stated that the levels in Fort Collins were twice as high as the national average. He stated that the Board of the Health District strongly supported the addition of passive radon mitigation systems to the building code. Paul Olan, 3336 Gunnison Drive, spoke in opposition to reducing ceiling heights to seven feet because of the impact on taller people. An unidentified man stated that reducing ceiling heights would be inappropriate because it would work against spaciousness in homes. He spoke regarding radon studies and stated that EPA regulators were wasting money on scaring people about radon. Eric Crohnwall, Fort Collins Board of Realtors, spoke regarding the cost effectiveness of passive and active systems. He stated that the Natural Resources Department attempted to address the issue in a study entitled "Health Benefits of Radon Resistant New Construction and Associated Costs." He stated that the study did not include the operational expense of active systems. He stated to run an active system in all affected homes would cost $34 million, which would be about three times the estimated costs for construction. He stated that an active system would cost$168,500 per cancer avoided and that a passive system would cost $51,000 per cancer avoided. Tom Horn, 1601 Quail Hollow Drive, stated that Larimer County's code required that some new subdivisions required radon tests on finished homes before a Certificate of Occupancy and that certain areas required that passive radon systems be installed. He stated that the issue was whether radon mitigation should be required at all based on inadequate science. He stated that people should have a choice regarding whether it should be done. He stated that it was unknown whether radon systems would reduce the levels of radon exposure and that it was unfair to lead people to think that they would be protected. He stated that the there was a cumulative effect of code changes on the cost of housing. Arnold Drennen, 3412 Canadian Parkway, stated that he had installed radon mitigation in about 2,000 houses. He urged the Council to consider requiring at least a skeleton passive system to ensure that all houses could be mitigated in the future. He stated that a passive system would guarantee future mitigation at the minimal expense of$400-$500 including a post-mitigation test. Bill Kiche, Northern Colorado builder, stated that the Council was underestimating the building 8 December 16, 2003 Excerptfrom Draft City Council Minutes community and potential homeowners. He stated that radon mitigation should be their choice. He stated that the City required that the realtor disclose radon to buyers of new construction and existing properties. He stated that this allowed the homeowner to make a choice about what to do. Gil Paven, representing the Homebuilder's Association of Northern Colorado, stated that an ordinance was passed in 1996 requiring that radon information be provided at the time of contract signing for all residential sales. He stated that radon mitigation providers increased their business more than tenfold. He stated that this proved that radon awareness and installation of systems could be market driven. He stated that 70-75%of homes in Fort Collins were above EPA guidelines and that 25-30%were not. He stated that the radon ordinance being discussed would be unfair to those homes that were below EPA guidelines. He stated that there were builders installing systems voluntarily. He stated that the average cost for a retrofit system was approximately $850 and that retrofits were being bid competitively by approximately five mitigators listed with the National Environmental Health Association. He spoke regarding the methods used to reduce costs in installations. He stated that it would be most fair to allow the general public to make the decision regarding whether they want to retrofit or use a passive reduction system. Carl Glaser, contractor and architect, stated that he had voluntarily installed passive systems in multifamily dwellings since 1996. He stated that passive systems were less expensive at the outset. He stated that one issue was monitoring and inspection. He stated that classes in Fort Collins to qualify inspectors had been discontinued, that it was costly and time consuming to attend a course in Colorado Springs to become licensed to inspect work, and that it was necessary for most installers to hire outside consultants to inspect work on passive systems. He asked that if the Council decided to require a passive system that testing be conducted in the City to allow contractors and City inspection forces to become qualified to inspect the work. Nancy York, Air Quality Advisory Board, stated that 3 out of 4 homes in Fort Collins had high radon levels. She stated that the EPA had stated that no level of radon was safe and that all of the major health organizations agreed that many lung cancers could be prevented with radon mitigation. She spoke in favor of the code as presented and stated that energy conservation would reduce costs and consumption of finite resources over time. She stated that the issue of radon mitigation went beyond money. She supported the adoption of at least a requirement for passive radon mitigation in new residential construction and testing of the systems. She stated that passive mitigation would lower radon levels by an average of 47%and that active systems would render an overall reduction of between 85-90%. Linda Stanley, chair of the Air Quality Advisory Board, 2040 Bennington Circle, stated that the Board recommended that City Council adopt the proposed amendments to the following sections of the International Residential Code: interior moisture control and ventilation,energy conservation and radon. She stated that the Board recommended active mitigation. She stated that the Board felt that the adoption of the energy code was a big step forward. She stated that the Board reviewed a 9 December 16, 2003 Excerpt from Draft City Council Minutes report that found that most new homes in Fort Collins were not meeting the energy code and that these amendments to the code would help correct that problem. She stated that the changes would also save builders costs in call-backs and warranties. She stated that price was not the same thing as cost. She stated that the Board recommended active mitigation for radon because of significant health risks. She stated that at a minimum there should be passive systems with some sort of testing and owner notification. Randy Fisher, chair of the Natural Resources Advisory Board,stated that the majority of the Board voted to recommend some sort of passive system for radon mitigation and to support the interior moisture control and indoor ventilation provisions of the new code. He stated that the Board discussed radon reduction and mitigation at length and that the Board had supported some kind of radon mitigation for a long time. He stated that the risk for unmitigated radon was about 10 to the minus 3 and as high as 10 to the minus 2 if there were existing health issues. He stated that this meant that there could be as much as one excess cancer per 1,000 people or even 100 people. He stated that this was an unacceptable risk for this society when the minimal mitigation measures required by these codes would be very cost effective in reducing risks. He stated that he personally felt that an active mitigation system was the best. David May,president of the Fort Collins Area Chamber of Commerce,stated that the real issue was science versus myth. He stated that there were studies on both sides of the issue of risks associated with radon. He stated that the Chamber of Commerce believed that any government regulations that were imposed on the community should be based on strong scientific data, especially when the regulations would cost the citizens of the community money. He stated that costs issues must be kept in mind and that these kinds of costs impacted affordable housing. He stated that no other community in Colorado required radon resistant new construction even though those communities had the same radon levels as Fort Collins. He stated that there was not enough hard science to warrant mandatory government intervention on this issue. He stated that the Chamber of Commerce opposed the adoption of any type of mandatory radon resistant new construction in the building code. He stated that the market should decide what choices to make. Michelle Jacobs, Director of Community Affairs for the Homebuilder's Association of Northern Colorado, stated that members of the Association had participated in the dialogue on the code and local amendments. She stated that the Association supported the international codes as more user friendly and self-contained document but that the Association had concerns about the energy conservation code and the inclusion of appendix relating to radon control methods. She stated that a survey was sent by the City to local realtors to determine the effectiveness of the current radon program and that 77%of buyers and sellers were informed about radon, 76%had radon inspections done, 84% encouraged buyers to test for radon, 76% of buyers requested mitigation when levels were above EPA standards,and that in 91% of sales the buyer and seller came to agreement on the cost of mitigation. She stated that this demonstrated that the public was aware of radon and that homebuyers would take the necessary actions that they deem appropriate for their families. She 10 December 16, 2003 Excerpt from Draft City Council Minutes stated that Fort Collins had been active since 1997 in pursuing public awareness of indoor air quality. She stated that decisions should be made based on sound scientific evidence, which was absent from the radon discussion. She stated that homebuyers had the choice now to mitigate for radon or not and that the decision should be left in their hands. She presented an official position paper for distribution to the Council. Mayor Martinez asked if Councilmembers had any requests for follow-up. City Manager Fischbach stated that there would be a Study Session on this issue. 11