Dear Chairman Ainslie:

On behalf of Loudoun County Combined Fire and Rescue System and the Virginia Fire Chiefs Association, I am writing about the proposed changes to the Virginia Statewide Fire Prevention Code.  I am aware that you have received in-depth input from the Virginia Fire Chiefs Association (VFCA) and others.  The Virginia Fire Service Council concurs with these concerns.

As indicated by others, we too believe that the Statewide Fire Prevention Code, as presented in the “final regulations,” will create confusion due to the various conflicts that will be created, will cause the need for significant local amendments and potentially reduce the safety of Virginia’s citizens, businesses and visitors, as well as our own firefighters.  These concerns are shared by virtually all of the major Fire/EMS organizations in the Commonwealth and have been previously expressed.  Further, the extensive explanation submitted by the VFCA amply describes the concerns.

Therefore, pursuant to the Code of Virginia, Sec. 2.2-4007.06, in order to provide additional time for comment, discussion and hopefully amendments, we are formally petitioning the Board of Housing and Community Development to reconsider their approval from the October 2017 meeting of the Statewide Fire Prevention Code published on April 30, 2018 in the Register of Regulations.  We would respectfully ask that the Board reconsider their approval of those sections and allow only the consensus document created by workgroup 2 that consists of Chapters 1-10 be adopted, and that all other provisions that were removed in the subsequent chapters and sections be reinserted to allow time for consensus to be reached in the next code cycle.  If the Board still feels that a total rewrite during this code cycle is necessary, we would respectfully request additional time to allow the stakeholder review process to finish its consensus work which will ensure a workable Statewide Fire Prevention Code that will protect all the citizens of the Commonwealth.

Should the 2015 Statewide Prevention Code be adopted, the Virginia Fire Service Council believes, at a minimum, the Board should consider the following amendments:

• Item F-107.2(2) Dawson/Dean – Reactive and exploding targets
• Item F-107.2(2) Dawson/Dean – Mobile food cooking operations
• Item F-107.11 Sites – State FM Inspection fees
• Item F-112.5 Andrews – Appeals application activities
• Item F-301.3 Milliken – Certificate of occupancy requests
• Item F-507.5.1 Toalson – Water supplies for infill developments
• Item F-609.3.3.1 Mullens – Commercial hood system tags
• Item F-703.1(2) Dawson – Exception to visual inspection of rated assemblies
• Item F-703.4 Dawson – Testing of opening protectives
• Item F-1030.1 Milliken – Emergency escape and rescue openings in R-4 use groups

NOTE – This approved change was voided by the SFPC re-write provisions which are being challenged.

• Item F-3103.2 Milliken – Tent clarification
• Item F-3501.2 Dean – Permit notation correction
• Item F-5605.1 Sites – Reference standards for manufacture of blasting agents
• Item F-5706.1.1 Dawson – Mobile fueling operations
• Item F-6701.2 Dean – Permit notification correction

I am hopeful that you and the Board of Housing and Community Development will seriously consider the input from our organization and other Fire/EMS organizations and individuals.

Sincerely,

System Fire Chief Keith H. Johnson

Loudoun County Combined Fire and Rescue System

Vice President Virginia Fire Chief Association, Region 7