My comments for this phase of review are copied below, and are reinforced by this comment. It is my understanding that there has been direction at the BHCD Meeting on July 30 that specific code change proposals shoudl be submitted for consideration in lieu of the currently approved SFPC rewrite. That task is not realistic to complete in that timeframe. The Fire Services Board Code Committee took 10 months and more than 25 meetings to produce revisions to the first 10 chapters just to illustrate the level of scrutiny need to ensure an enforcable code. It is an impossible task to take the entire SFPC as proposed and re-edit the rewrite to a suitable and enforcable document. 

I continue to urge the Board of Housing to reverse thier decision to approve the FSB Code Change (submitted under my name) rewrite and the DHCD rewrite (submitted under Cindy Davis' name) for the SFPC. I would also point out that the BHCD has directed the stakeholders to continue working on the rewrite in anticipation of the adoption of 2018 edition of the model codes. This would approve those SFPC changes that were properly vetted by the Workgroups and the Board and update the balance of the SFPC to the 2015 edition of the IFC.

Additionally, there has been no demonstrated critical need for this revision, and therefore, this process should proceed with caution as requested by this and other pubilc commments previously posted. 

JRD

<<<<6/26/18 coments follow>>>>

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.