As a retired Battalion Chief of a large Surburban Fire Department, citizen of the Commonwealth, and 1st Vice President of the Virginia Fire Prevention Association I urge the consideration of supporting the Virginia Fire Prevention Association and Virginia Fire Chiefs Associaiation's position to approve the seventeen (17) proposed code changes found in Book 5 – Part 1 – Tabs 1 & 3  to the existing Proposed SFPC as printed in the Virginia  Register  February 20, 2017.  These are the Statewide Fire Prevention Code proposals which were approved in October 2017 and and represent the consensus changes to the Code. Code changes made by consensus are a basis of modern building and fire code development at the national and state levels. Any c, hanges made to the 2015 Fire Prevention Code, as proposed by BHCD, that are not consensus changes and do not account for the need for Fire Inspectors and Fire Marshals, who are charged with enforcement of the Fire Prevention Code, to have a document that provides them the necessary Fire Prevention Code that contains the necessary code verbiage to be able require owners and occupants of buildings and structures throughout the Commonwealth to maintain their facilities in compliance with the building code they were constructed under. In Virginia, the Building Code is used to regulate the materials and method of construction. The Fire Code is used to MAINTAIN the building or structure and to regulate the fire and life safety of processes, activities, and actions that are not related to the construction of the building or structure. If it is the desire of the BHCD to have buildings maintained according to the applicable code then the Fire Inspectors and Fire Marshals need to have a section inserted into the Fire Prevention Code providing them the ability to enforce the maintenance provisions of the Building Code which is not currently contained in the proposed amendments. It is interesting to see the Fire Code amendments delete construction and other of the Fire Code only to have the Building Code refer back to the 2015 IFC for guideance in many areas. (The same areas that were deleted by the amendments.)