Chairman Carr and members of the BHCD:

I support adoption of the 2015 SFPC as currently approved by the board. The effort initiated by the board to remove the unenforceble provisions from the adopted model ICC Fire Code was a good decision and necessary to create a Virginia Statewide Fire Prevention Code that is easier to enforce in a uniform manner across the state. Code of Virginia 27-96 limits the SFPC, as it applies to strucutures, to maintanence of the structure's fire protection systems, materials and devices; new construction provisions are outside of the scope of the SFPC per COV 27-69 and 27-34.4.  The effort to removed the new construction provisions from the model code rather than rely on a statement in SFPC chapter 1, which invalidates the unenforceble construction provisions, is legally sound and makes the code much easier to use and apply uniformly. I commend the board for choosing to use the regulatory action APA process to formally vet the removal of the unenforceble code provisions in an open and cooperative consensus process, as it could have been done editorially by the agency.

In the interest of building safety,

With kind regards,

Ron Clements

Chesterfield County

Assistant Building Official