September is shaping up to be a busy month on the regulatory affairs front. Members with questions should contact Nick Erickson, senior director of housing policy.
Housing First Minnesota Comments on Water Quality Fees
Housing First Minnesota sent a letter to the MPCA opposing significant construction stormwater fee hikes. Under a proposal from the Minnesota Pollution Control Agency, Construction Stormwater Permit fees would be increased significantly and residential developers would be charged a new $100 subdivision registration fee.
In addition to opposing the fee hikes, Housing First Minnesota asked that any fee increases be phased in over several years s the agency proposed for local government MS4 permit fees.
Housing First Minnesota also took issue with the MPCA’s inability to provide information on how these fees were calculated.
“The inability for the MPCA to show us their math on these significant fee increases raises questions to the agency’s ability,” said Nick Erickson, senior director of housing policy. “More troublingly, it prohibits the public from making informed comments.”
2021 Energy Code Review
On Aug. 23, the Department of Labor and Industry held a hearing before Administrative Law Judge Eric Lipman. This hearing required under federal law, was to review the United States Department of Energy’s analysis of the 2021 Internaltional Energy Conservation Code. Mark Foster, vice president of legislative and political affairs, attended the virtual meeting on behalf of the association.
Housing First Minnesota, in its comments to Judge Lipman, said that the 2020 judicial recommendation be followed and that any decision on opening rulemaking be postponed until the next code cycle, which would review the 2024 series of model codes for adoption in 2026.
“Opening Minnesota Rules Chapter 1322 to an off-cycle adoption under the 2021 IECC is not only unwarranted and unnecessary, but also poses a significant roadblock to Minnesota’s already stressed housing market,” wrote Nick Erickson, senior director of housing policy.
The comment period closed on Monday, Sept. 12. A rebuttal comment window opened on Sept. 13 and continues through Sept. 19.
Joining Housing first Minnesota in opposing the 2021 IEEC was Central Minnesota Builder’s Association.
2023 National Electrical Code
Housing First Minnesota called on the Board of Electricity to delay the technical review of the 2023 National Electrical Code (NEC). The review, scheduled to begin on Sept. 22, would happen before the National Fire Protection Association has published the final version of the 2023 NEC.
In its memo to the Board, Housing First Minnesota shared the results of a survey showing both residential electrical contractors and homebuilders:
- Lack confidence in the Board of Electricity’s ability to balance safety and affordability;
- Do not feel the Board conducts a rigorous review of the NEC;
- The Board adopts new versions of the NEC too frequently; and,
- The Board will not fairly consider any amendments put forward.
