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8/8/18  4:04 pm
Commenter: Glenn Dean

SFPC re-write or update
 

I urge the Board to reverse its decision to adopt any and all proposals listed or enumerated under Tabs, 1, 2, 3 and 6 in the document titled "Virginia Fire Services Board and Board of Housing and Community Development, STATEWIDE FIRE PREVENTION CODE DEVELOPMENT COMMITTEE, 2015 CODE CHANGE CYCLE - BOOK 5 - PART 2" dated September 18, 2017 and which may have been subsequently listed, enumerated and BHCD approved under Tab 2 of the document titled, "2015 CODE CHANGE CYCLE - BOOK 7 (VIRGINIA STATEWIDE FIRE PREVENTION CODE)" dated October 16, 2017 and then published as part of the Final Regulations. I urge this based upon the lack of a full debate by impacted interest groups and the need for the BHCD itself to conduct or direct that a more comprehensive review be performed before adopting a fire code so riddled with conflicts, gaps and consequences published as "Final Regulations" on April 30, 2018 in The Virginia Register of Regulations, Volume 34, Issue 18. To repeat, and paraphrase a previous comment of mine, compared to the promulgation process of the IFC model code which is the base document for the SFPC, the BHCD has NOT caused or invested a sufficient amount of time for informed debate on such an expansive set of changes as those found in the above referenced documents.