The Summit County Builders Association would like to state that it does not support at this time the proposed additional sustainable codes for net zero ready homes that are looking to be adopted by the various towns and county for the following reasons:

Constructability:

• Concerns that the proposed continuous exterior insulation wall assembly has not been proven in climate zone 7. There needs to be further discussions on interior vapor barriers and exterior wall venting design. In Fort Collins, a similar code was enacted and was later found that the building envelope was so tight, homes could not be properly ventilated, which later led to moisture and mold issues.
• The lack of Home Energy Rating System raters available in Summit County for the building process, including certifying plans for submittal; reviewing and documenting during construction; and qualifying the finished project for Department of Energy certification.

Associated additional costs:

• HERS rater fees, there currently is no fee structure.
• Architectural fees required prior to permit for a HERS rater approval.
• Certifications required by a HERS rater, the associated fees and time for this process.
• Labor and materials required to implement.
• Additional time added to the overall building process to achieve the code requirements.
• The additional costs incurred are likely to never be recovered. We respectfully disagree with the 1% to 2% increase that has been quoted and believe the increase could reach 12% to 15% according to modeling that has been assessed by the association.

We would like to propose that the additional codes not be government mandated, but be a choice by the owners and builders and be incentivized to the owners and builders.