yAN-ei-1903 2:08 David J, Tomassoni, Sonator ~ District 5 St, Louis County Senate State of Minnesota December 18, 2006 VIA FACSIMILE AND U.S. MATL, Scott Brener, Commissioner ‘Minnesota Department of Labor &: Industry 443 Lafayette Road St. Paul, MN 55155 Dear Commissioner Brener: We have‘reviewed a receat request for comments regarding possible revisions and/or amendments to the Minnesota State Plombing Code daring the next rule-making session in 2007, Among other things, this request references possible amendments regarding the 5 permissibitity of plumbing devices that could include so-called waterless or water-free ‘usinals as well as “air admittance valves” (“AAVS"). “Wé both have serious concems about the manner and methods by which building and construction codes have been adopted in recent years. We have watched as recommendations of advisory boards, whose members have been tasked with protecting the health and safety of Minnesotans, has been disregarded. We are not convinced that the current process of maintaining building and construction codes in Minnesota best serves the public interest. We intend to take-a serious look at this issue during the ‘coming legislative session. We have particular concems regarding waterless urinals and AAVs. Waterless/water free urinals are expressly prohibited by the Code. Yet recently, the cities of Bloomington and Maple Grove permitted such devices ut specific locations. After the permitting was brought to DOLI’s attention, the Department issued cease-and-desist leters to these citics and subsequently issued a notice to all Minnesota cities thet such devices are specifically prohibited by the Plumbing Code. As these devices violate basic plumbing principles of sanitation, their use should not have been authorized by these cities in the first place nor should DOLI authorize their use statewide in the future, oF — 21 Stata Copia + Slat Paul YN 85155-1609» (651) 206-9017 + Fax (651) 290-0011 ane EMail tan deldtorsenconi@renatemn