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FEMANonrulemakingFEMA-2010-0004

National Disaster Recovery Framework

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National Association of Home Builders filings
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National Association of Home Builders filed 1 comment on this docket between Feb 26, 2010 and Feb 26, 2010. 35 other organizations filed here. The comment window closed 5996d ago.

What National Association of Home Builders filed (1)

Feb 26, 2010· Comment Submitted by Gary J. Ehrlich, National Association of Home Builders· FEMA-2010-0004-0076

Attached please find comments from the National Association of Home Builders on the draft Framework. Many of our comments are concerned with making sure the Framework reflects how the process of developing and adopting building codes and standards in the US actually works. These documents are not just "architectural standards"; they cover all areas of construction including structural design, egress, fire protection, mechanical/electrical, and landscaping/site design aspects. Similarly, there is no need to repeatedly single out accessibility as those requirements are already a key part of the building codes. Another group of comments addresses concerns with use of "resilience", "sustainability" and other terms. This is particularly true when the Framework talks about "resilience-building measures". We are not aware of a measurable, quantified, agreed-on set of what those practices or measures are. Contrast this with "mitigation" which is a well understood term in the building community and addressed both quantitatively and qualitatively in adopted codes, standards, and federal programs. Finally, the Framework needs to avoid promoting a "don't build/rebuild there" mentality as a general rule. While some hazards (flood, wildfire) may require looking at overall land development and zoning/planning issues to address, others (seismic, wind) can be addressed primarily through improved building construction and code enforcement.

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