Office Phone: 509-489-3860  
Real World Financial Implication of
RCW 70A.45.020, a CO2 Mandate

My letter below was not allowed to be passed on to the Washington State Building Code Council so I'm putting in print so all in the state can read it. The Governor and many on the State Building Code Council want to end the use of natural gas in all commercial building. Using the codes as a mechanism they would end natural gas use in commercial buildings and then I believe the next will be our homes.Here is my letter that was not allowed to be sent to the State Building Code Council. I have since made some additions to the letter now that I have had more time. For those of you who don't know the proposals to the Washington State Building Code Council below, they are to remove natural gas from our state in commercial buildings. I am a licensed contractor who performs HVAC, refrigeration and plumbing work for residential and commercial customers in Eastern Washington and Northern Idaho. I am not now or have I ever been against efficiency and reducing carbon and greenhouse gas. I just know what works for my customers and want to make sure everyone understands the dangers of the policies being proposed and mandates by RCW 70A.45.020 I am totally opposed to the proposals log in numbers 21-GP-1-103, 21-GP1-136, and 21-GP1-179 and others. Our electric grid is already overloaded as it is this only going to make things worse. We are already having rolling brown outs in the Spokane area as it is. These will only make things worse. As for 21-GP1-179 requiring a wire sized large enough to run the system on electrical for heating our buildings and water heating, I would like to see what Duanne Jonlin put down for this extra cost. For I am not able to bring up the sheet online that Duanne Jonlin had to start this thing going. You know this would require major update of the electrical service and panels going from a 200-amp service to 400- amp or even 600-amp maybe even 1,000-amp services and panels. These costs are huge for the hopes someday they may want to go to electric. What a waste. As for Heat Pump Space Heating Proposal (21- GP1-103), the duct work would be required to be double the size to even think of this. Larger buildings to hold such ducts mean more heat loss and heat gain. Remember the more you raise the static pressure on a duct to move the air around the more horsepower it takes, and more horsepower is more energy. In the Spokane area with temperatures that do dip to -20 degrees, heat pumps become worthless. Also, with equipment manufacturers getting COP (Coefficient of Performance) up higher has come with much shorter life of these heat pumps. The copper coils are made much thinner to get better efficiency upfront but are now wearing out much faster. Commercially most equipment has only a one-year warranty. Compressors are failing much faster too. This year alone we had two 10-ton heat pumps fail that were 1-1/2 years old, and without back-up electric resistance heat they would have been out of heat for three months. Copeland compressors were failing left and right and Copeland had no answers why. The cost for each of these failures was $10,000 plus tax. Just think how much carbon footprint that took to fix these units. Compressors in our area don't last as long due to the extreme cold weather here. In fact, when you start to look at the defrost cycles when it gets below 20 degrees outside, they are in defrost more than they are heating. The COP rating doesn't include the resistance heat during defrost in its calculation. I have limited time and I will later share more problems with heat pumps like the reversing valves that we replace, contactors, and then the coils. One thing to think about is many of our churches. When they need to replace their systems, they are going to have to bear the cost of these heat pumps and the cost to convert them over. Most churches can barely cover the cost to keep them running now, let alone to make a total change over to a heat pump system. As this new requirement by this code, on the electrical side, electrical engineers will be required on many jobs to replace units that are two or more replacements in a two-year period. The larger electrical services will increase the cost to the building owner would be astronomical to the building owners of these buildings. These are not my words; they are from electricians that I work with. As for what McKinstry said in letters on September 27, 2021, to the State Building Code Council, a lot of these projects are totally funded by government grants and there is no way the average building owner could afford such projects. Also, these projects are not sent out for bid. Now we come to Energy Code Proposal (21-GP1- 136) This proposal makes it necessary to have all commercial water heating done with air-source heat pump water heaters. Unless you live in an area which has an outside temperature above 40 degrees outside there, they're useless and have no place in the Spokane area. They are just costing people more than just straight electric resistance. In the Spokane area we heat eight months out of the year. I can see this working out in the Seattle area with basements, but in Spokane we on the losing side of things with these units. This does give a builder more points for energy credits, but we are not reducing energy at all. In fact, we are using more energy than before. In fact, the last service call I had, one of these units was well over $450 plus tax for the service call, and the unit had only been in operation for two years. The house was heated with straight electric, and they had a crawlspace under the house.

So, first they paid to heat the house with straight electric then the heat pump water heater grabs its energy from the straight heated electric house. So, the straight heated electric house heat had to come on and feed the heat pump water heater, but they got energy credits points for doing this. Remember anything mechanical has energy loss when the compressor turns on. Where are the economics for this? What about when a restaurant that needs 400,000 BTUs per hour just to keep up with the dishes, or how about a hotel with 1,000,000-plus BTUs per hour? To put this in perspective that's 25 home gas water heaters. Then there are the retirement homes where they need to have more than 1,000,000 BTUs per hour for water heated usage with large laundries, and most of these have to have the water heated to 180 degrees. How are they going to do that with a heat pump water heater? The last time I looked, heat pump water heaters can only give about 118 degrees of water temperature, well under the 180 degrees Fahrenheit needed. That is just about one 200-amp panel for constant electrical use alone, where one 400,000 BTU gas water heater is now used. We need to be able to offer different codes for different areas to reduce energy usage. One code for all climates in Washington State is not the answer. The next paragraphs are all pertinent since all the proposals above are about reducing global warming. Without natural gas our electric will most likely run about 30 to 40 cents a kilowatthour. Right now, in states they have electrified as Washington State wants to do are paying over 18 cents a kilowatt-hour right now. What is going to happen to the retired people who are going to have pay for this power? The power bill could be more than their house payment. Some people want to remove the dams now, with the Governor along with Maria Cantwell, and Patty Murray is on board with this idea too. Why not just pay the Nez Perce Tribe of Idaho for the fish so they don't put the gill nets across the Snake and Columbia rivers, so the fish can get back home to spawn? It would be a lot more cost-effective to do this. Add more hatcheries. Compounding this is the potential removal of four dams along the Snake River in Idaho, as proposed by the Nez Perce Tribe of Idaho to address fish population concerns. I remember the movie in EXPO 74 at the IMAX: "Man belongs to the earth." Chief Dan George said in the movie, "Never destroy fish for the fun of it." You should look at this short movie. I lived with this all my life if I am not going to eat them and need it for my life, I will not kill them. I look back at this movie and see how far we have come, but now everything is such a rush, look at the gains we have made in the past 47 years. I think we can all say we can go for some years without fishing and let the fish population come back again or at least cut way back on fishing. I put this in due to the fact all the power we get from these dams, each dam help supply the electric grid and gives the farmers a way to get their crops to market, plus all recreational use behind the dams, let's not go back words. Shouldn't we give like five years at this and see if the fish come back. Just look at the investment by all the citizen of the U.S. did for this area, to put the dams in. This investment by the whole United States was for power for the area and the farmers that's why the locks were put in for the vessels move from the ocean to into Idaho. Then they have talked about how hot this summer was and being the hottest on record. You are comparing apples and oranges. Think about this in 1928 and in 1961 we just beat this out by one degree. Which year do you think was hotter in Spokane? It was 1928 by far and here's why: in 1928 there were no server farms, no computers, very few autos, no A/C or heat pumps running which raised the outside temperature greatly. Just think how many trillions of BTUs are put outside from our A/C and heat pumps. These all run on electricity not natural gas. Our problem is not natural gas, our problem is our use of energy period, and until we understand that we are just wasting our time and money. I don't how many of you would not go on breathing anymore to slow the gain of CO2 or stop drinking a soda pop. I have been tracking CO2 in Spokane for years. It goes up in the winter and down in the summer. Then you have the people in Spokane that want to conserve water, so they let their grass dry out. Well, that grass was turning CO2 into O2. You know we have one largest bodies of water in the world under us and all this water ends up in the ocean anyway, plus it has never dropped in depth. Then we have the 'let it burn' Washington State policy so forest and fields that could remove CO2 don't now that they have burned up in the last few years. And they wonder why our CO2 level is rising? What we need is to be more pro-active and get 10 of the United States 53 C5A airplanes set up with mobile water tanks so these planes could each drop 25,000 gallons of water. This would be 250,000 gallons of water, which they could deliver starting during the early summer and put some real amount of water on these fires. We need to start earlier and not let the fire get to such a level. We need to change our policies. If we can level all Europe during World War II, we can surely put some fires out, we just have to put the idea forward that this is not going to happen anymore, and find ways to do this. This way the smoke from the fires won't keep the heat and CO2 next to ground any more. The trees and fields that we will have saved can do the job of removing CO2 and making O2 again.

To be frank I think the Governor's policy has made all this happen. Our Governor has been in office all this time and is not helping. We were on a good path of better insulation of our buildings and that has changed. When you look at the heat gain and losses the major, and I mean major, energy losses now are air exchange. Anybody who does heat loss and gains should know this. Insulating the under-slab floor over 2 inches thick is a total loss no gain. And I mean no gain is made. All the calculations prove that. So how many people have wasted their money on a new code that has no gain at all? I am seeing more of these codes happening all the time in Washington State Building Code. What a waste! Avista will not provide incentive money for commercial projects unless it can be paid back in 15 years most of the time. Yet some of these proposal for energy code will never pay themselves back. Why are we allowing such proposals to come forth without economic analysis that have factual documentation? These proposals will not pay back before the equipment will wear out and needs to be replaced. In these proposals, people have been working on them for a year, but we the public only get two months at best to read and understand what is going on. There needs to be much more time given for the State Building Code Council and the public to get a grip on what would happen if this were to take place. What would be the true cost if these things were to happen? Myself and many others do not believe this joke of a study that was put forward. Some of the study's findings were not even conducted in our state or using our wage rates and equipment. Until we all stand up and say this is enough, we will have brown outs and shutdowns much like others have who done these things. Look at the article in The Spokesman-Review OPINION section Tuesday October 12, 2021, that talks about how California is rolling back these types of proposals and codes because there is not enough power to feed them. In fact, our state carbon rollback codes that are coming will cause these problems too. The average person has no idea what could be coming if we keep going down this path. It takes 50 years to even think of starting to achieve these types of changes without breaking everybody financially, plus brown outs. We're trying do it in eight years. I was wondering where these code changes were coming from, then I found out about the new RCW 70A.45.020 that was passed by the Governor and a totally Democrat vote. No Republicans voted for this. Remember this happened during the pandemic/plague where all businesses are just trying to survive during the pandemic/plague, and Democrats and the governor pass such legislation when everyone is beating down and many don't have time to even begin to react to such legislation. This is going to affect every citizen in this state. This legislation put our targeted millions of metric tons CO2 from about 90 million ton of CO2 down to 50 metric tons by 2030 then by 2050 down to near zero metric ton CO2. This could break nearly every small- and medium-size business in this state. Would you not think that this type of legislation would be put before the public in an open forum after the pandemic was over and people and business could catch a breath? Then put this kind of legislation to a vote of the people in this state. This will drastically affect life for every citizen in our state. That would mean no more combustion engines and no natural gas-heated buildings in 2050. Every person will have to have some type of heat pump to heat these buildings. It will mean knocking down buildings to achieve this including our churches. Remember, when it gets real cold outside the wind does not blow and it cloudy outside. This means no wind power and no photovoltaic power, just like what happened in Texas in 2021. No power. Here are five Prager University YouTube videos, five minutes to view each. These could shed some light to what has happened in other states and what will happen in our state with what the Governor is doing. 1. The great Texas Freeze of 2021. 2. What's wrong with Wind and Solar? 3. Why are Utilities So Expensive? 4. Is California going up in flames? 5. Trees are the answer. One last thing. Why is the state rolling the CO2 back to near zero? In the 1970s we were going into an Ice Age, and we were at 52.6 metric tons of carbon dioxide during those years. Look at the article about planes that had landed in Greenland in 1942. There were two B-17s and 6- P38s which were found under 250 feet of ice in Greenland in 2015. Our CO2 level was much lower in 1942 than it is now. But the planes are still under 250 feet of ice now. Those people who don't like this should contact your legislator in your area.

The State Building Code Council email address is, and the Governor's office phone number is 360- 902-4111, or all this will come true.


Larry Andrews

I can be reached @ the email address below:


© 2022 Andrews Mechanical, Inc.

Contact Us Andrews Mechanical