Building Industry Essential Public Comment from National Assoc. of Homebuilders
Post Office Box 576, Missoula, MT 59806 ◊ (406) 542-2434 ◊ Fax (406) 543-2321 ◊
www.charterconst.com
March 25, 2020
Mayor Mark Johnson
City of Kalispell
Via Email Only
Dear Mayor Johnson
On behalf of the National Association of Home Builders of the United States (NAHB), I have been elected to
represent the state of Montana as the National State Representative. I write to urge you to consider policy
proposals to support the housing sector of the economy during the COVID-19 pandemic. NAHB’s members
stand with you during these uncertain times and look to your leadership to help steer the community through
uncharted waters. To help stabilize the housing sector in the near term, I ask you to designate home
construction as an “Essential Infrastructure Business” in Missoula.
A Federation of more than 700 state and local associations, NAHB represents more than 140,000 members.
Each year, NAHB’s members construct about 80% of the new homes built in the United States, both single-
family and multifamily.
As cities and states issue declarations and public health orders as a result of the crisis, it is essential that
communities have access to our professionals to build and maintain essential services including: building,
plumbing, electrical, HVAC systems, waste/wastewater treatment plants and power generations. Home
construction should be designated as “essential” because it is necessary to maintain safety, sanitation, and
economic security.
I encourage you to consider four main factors:
• Recognize that construction of housing is essential and should be allowed to continue under a remain
in place order;
• Government functions related to the building and development process, such as inspections,
permitting and plan review services can be modified to protect the public health, but fundamentally should
continue and serve the construction of housing (E.g., Allow qualified private third-party inspections in case
of government shutdown);
• Supply stores necessary to serve the construction, repair and maintenance of housing should be
allowed to operate; and
• Those working in building trades must be allowed to continue to maintain the essential operation of
residences and other operating businesses.
Our industry continues to adhere to public health guidelines set forth by the Occupational Safety and Health
Administration (OSHA) and the Centers for Disease Control (CDC).
According to OSHA, “Lower exposure risk (caution) jobs are those that do not require contact with people
known to be, or suspected of being, infected with SARS-CoV-2 nor frequent close contact with (i.e., within 6
feet of) the general public. Workers in this category have minimal occupational contact with the public and
other coworkers.” Guidance on Preparing Workplaces for COVID-19, p.20.
Post Office Box 576, Missoula, MT 59806 ◊ (406) 542-2434 ◊ Fax (406) 543-2321 ◊
www.charterconst.com
A large majority, if not all land development and residential construction job tasks fall within OSHA’s Lower
Exposure Risk jobs. Obviously, working on a new unfinished home site occurs primarily outdoors and does
not involve going onto a location occupied by residents or a public location, and there is minimal (if any)
physical or transactional contact with customers compared to other customer/client relationships.
Homebuilding (including remodeling and repair) is highly regulated and therefore cannot occur without
support from the locality where it occurs. Builders require governmental approvals and permits to begin a
project and they are needed through project completion. Therefore, governmental inspections occur along the
entire process from the land development to final certificate of occupancy.
As part of the Essential Infrastructure, residential construction requires that government building and zoning
departments continue to operate. Furthermore, for the safety and wellbeing of current and future occupants,
governments must allow inspections to occur in a timely manner.
I have personally contacted several of the Building Inspection departments across the state and have spoken
to the head of the department about what other states are doing to continue their inspections and permitting.
The inspection process may benefit from these modifications. For example, if possible, inspectors may work
“off hours” to minimize any contact with the construction team. Or they can make other arrangements with
the owner or general contractor to safeguard their health by ensuring nobody will be on site during an
inspection. And what seems to be the most widely appreciated is to video conference with the trusted
contractor and building inspector while the contractor is on-site. It may be necessary for home builders to
request one of these options if local governments are closing their building department during the pandemic.
Housing is currently 14.6% of Gross Domestic Product and a major engine of the economy. Keeping the men
and women of the industry building must be a priority. If construction is disrupted, it creates a domino effect
leading to dire negative economic repercussions for an already-burdened economy.
I request that you consider construction an essential service, so that individuals may continue to perform
work necessary to the operations and maintenance of “Essential Infrastructure.” I appreciate your leadership
and the work of your staff and those who are spending every waking hour keeping us safe and I have also sent
a letter to Gov. Bullock very similar to this and would appreciate your support to him.
Respectively & Sincerely,
Kimberly Chambers
National Association of Home Builders
State Representative of Montana