The Virginia Statewide Fire Prevention Code as brought forth for the 2015 edition is the result of a long and open process based on the premise that a maintenance/operational code should not contain language which can be mistakenly perceived to be standards for construction. Even though scoped primarily for maintenance of existing systems and conditions of use, the referenced International Fire Code is developed and written with construction provisions so as to be used as such where administrative authorities are enabled and choose to do so without the adoption of other minimum codes or standards.  As a result of correlation by the ICC, those construction provisions are incorporated in the International Building Code.  Since the IBC serves as the technical reference for the USBC, those provisions of the IFC are redundant, misleading and unnecessary in the Commonwealth.  I urge the Board to adopt the SFPC as approved in the final stage of the regulatory process.