I would like my comments to be added to those of the Virginia Fire Chiefs Association as well as the Virginia Fire Prevention Association, and include the following added commentary. 

As the proponent on behalf of the Virginia Fire Services Board in 2017 - while a member of the Board of Housing - I requested the Board of Housing to defer any action on the SFPC rewrite to include those proposals submitted under my name for chapters 1-10 of the SFPC. The rational for that request was clear in the complex nature of the SFPC and how many later chapters relate to or references are drawn from other chapters, and the true consensus process that was undertaken by the Fire Board Code Committee while laborious was far from complete. 

The Board as rules making body, nor I who was deeply involved in the workgroup process from the beginning, had never reviewed the document that has become the final regulations and were not able to evaluate the relationships of the changes that were approved by the Board in October. This action has lead to the problems outlined clearly in the attachments provided by Chief McDowell, and expanded on by others in this comment period. 

I would urge the Board of Housing reconsider their actions on the code rewrite proposals, to include the proposals submitted under my name (consistent with my request at the 2017 Board of Housing Meeting), and to revert back to the base 2015 edition of the IFC with the individual SFPC amendments that were fully and completely vetted by the Workgroups and the Board and allow a more complete review of the SFPC in the coming years by the appropriate organizations and interest groups.