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. 

I urge the Board to reverse its decision to adopt any and all proposals listed or enumerated under Tabs, 1, 2, 3 and 6 in the document titled "Virginia Fire Services Board and Board of Housing and Community Development, STATEWIDE FIRE PREVENTION CODE DEVELOPMENT COMMITTEE, 2015 CODE CHANGE CYCLE - BOOK 5 - PART 2" dated September 18, 2017 and which may have been subsequently listed, enumerated and BHCD approved under Tab 2 of the document titled, "2015 CODE CHANGE CYCLE - BOOK 7 (VIRGINIA STATEWIDE FIRE PREVENTION CODE)" dated October 16, 2017 and then published as part of the Final Regulations. I urge this based upon the lack of a full debate by impacted interest groups and the need for the BHCD itself to conduct or direct that a more comprehensive review be performed before adopting a fire code so riddled with conflicts, gaps and consequences published as "Final Regulations" on April 30, 2018 in The Virginia Register of Regulations, Volume 34, Issue 18. To repeat, and paraphrase a previous comment of mine, compared to the promulgation process of the IFC model code which is the base document for the SFPC, the BHCD has NOT caused or invested a sufficient amount of time for informed debate on such an expansive set of changes as those found in the above referenced documents.

Virginia Petroleum Convenience and Grocery Associaiton is a statewide nonprofit trade assocition representing the Commonwealth's petroleum marketers and convenince store operators.   We are an advocate of the change to the fire prevention code to prohibit mobile fueling operations exept in emergenices and farm vehicles.  This proposal was reviewed in depth during the stakeholder meetings and emerged without opposition, supported by the public safety and business communities alike.   We urge your favorable consideration on this consensus item.  Thank you for your consideration.

Michael J. O'Connor

President

VPCGA

5706.1.1 Mobile fueling operations. Delivery of Class I, Class II, and Class III liquids to the fuel tank of a highway vehicle from a tank vehicle, a tank carried on a vehicle, or a nonportable container is prohibited.

Exceptions:

1. The refueling of highway vehicles in an emergency.

2. The refueling of vehicles in compliance with Sections 5706.5.4.1 through 5706.5.4.5.

3. Vehicles used for farm operations and machinery.

2. Change Section 5706.2.4.2 to read:

Proposal:

Approve the seventeen (17) proposed code changes found in Book 5 – Part 1 – Tabs 1 & 3 (listed in tables below), 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 this will ultimately undo the controversial and problematic SFPC rewrite changes that the BHCD had previously passed by a small margin. 

Background:

The Proposed Statewide Fire Prevention Code (SFPC) that was presented to, and passed by,  the Board of Housing and Community Development (BHCD) on December 19, 2016 contains the :

• The base document of the Statewide Fire Prevention Code (SFPC) is the 2015 International Fire Code (ICF)

• The current Virginia amendments to the SFPC

• And Three (3) SFPC proposals recommended by the Workgroups as Consensus for approval as presented in Book 1 – Part 1-- Tab 2 of the Virginia Fire Services Board and Board of Housing and Community Development 2015 Code Change Cycle (October 24, 2016)

These proposed regulations are not in question and are the base document for which the BHCD must consider any further proposed regulations.

During the September 18, 2017 Virginia Fire Services Board and Board of Housing and Community Development SFPC Proposals recommended by the Workgroups as Consensus for approval were presented in Book 5 – Part 1 -- Tab 1.  These fifteen (15) consensus proposals have been fully vetted through the workgroups, and have withstood the scrutiny of the stakeholders as being proper to be adopted.

Further during the BHCD meeting to consider these consensus based proposals there were two (2) other non-consensus SFPC proposals that the BHCD chose to adopt and they are found in Book 5 – Part 1 --  Tab 3 :  proposal number F-107.11 “State Fire Marshal’s Office permit fees for explosives, blasting agents, theatrical flame effects, and fireworks” and proposal number F-507.5.1 “Where required” which allows for two exceptions to the requirement for a fire hydrant/water supply system when building and/or rehabilitating single family homes.  We understand that the BHCD, after a great deal of conversation, debate, and research feels that these are necessary and those also are acceptable inclusions into the Final SFPC that is to be adopted.

Virginia Fire Services Board and Board of Housing and Community Development

STATEWIDE FIRE PREVENTION CODE DEVELOPMENT COMMITTEE

2015 CODE CHANGE CYCLE – BOOK 5 – PART 1

September 18, 2017

TAB 1 – SFPC Proposals Recommended by Workgroups as Consensus for Approval (approve individually or as a block)

TAB 3 – SFPC Proposals Recommended by Workgroups as Non-consensus

Thank you for the opportunity to recommend to the Board of Housing and Community Development specifici code language to be considered during the final stage of the 2015 Statewide Fire Prevention Code Change Cycle. As an advocate for the safety of all Virginians, I would like to add my name is support of the proposal made by the Virginia Fire Prevention Association.

Sincerely 

Darl W. Jewell Jr. / Captain/Deputy Fire Marshal/Haz Mat Coord.

Department of Fire and Emergency Services, Richmond VA

The Fire Marshal office within the City of Richmond supports the proposed code changes identified in book 5-1 as printed in the 2017 issue of the SFPC - the prolonging of these adoptions are problematic for Richmond and the Fire Marshal's office with the understanding we also adpted Code in its current form. This may prevent ammendments to some ordinances being impacted as mentioned in some commemts one bieng permit fees etc.

To Whom It May Concern:

Thank you for the opportunity to recommend to the Board of Housing and Community Development specific code language to be considered during final stage of the 2015 Statewide Fire Prevention Code Change Cycle.  As an advocate for the safety of all Virginians, I would like to add my name in support of the proposal made by the Virginia Fire Prevention Association.

Sincerely,

John F. McCormick, CBO-CFO

Fire Chief / Fire Official

Town of Abingdon Fire Department

To Whom It May Concern:

Thank you for the opportunity to recommend to the Board of Housing and Community Development specific code language to be considered during final stage of the 2015 Statewide Fire Prevention Code Change Cycle.  As an advocate for the safety of all Virginians, I would like to add my name in support of the proposal made by the Virginia Fire Prevention Association.

Sincerely,

Brian K Bennett, CFO

Deputy Fire Chief,

New Kent Fire-Rescue

To Whom It May Concern:

Thank you for the opportunity to recommend to the Board of Housing and Community Development specific code language to be considered during final stage of the 2015 Statewide Fire Prevention Code Change Cycle.  As an advocate for the safety of all Virginians, I would like to add my name in support of the proposal made by the Virginia Fire Prevention Association.

Sincerely,

Claiborne Cofer

Fire Marshal

Virginia Beach Fire Department

The Virginia Fire Chiefs Association recommends the DHCD Board adopt only the seventeen (17) proposed code changes (found in Book 5 – Part 1 – Tabs 1 & 3) to the SFPC that were printed in the Virginia Register on February 20, 2017, and approved by the Board in October 2017.  This limited adoption of proposed changes will resolve the controversial and problematic full document SFPC “re-write” that the DHCD Board subsequently passed by a small margin. 

To Whom It May Concern:

Thank you for the opportunity to recommend to the Board of Housing and Community Development specific code language to be considered during final stage of the 2015 Statewide Fire Prevention Code Change Cycle.  As an advocate for the safety of all Virginians, I would like to add my name in support of the proposal made by the Virginia Fire Prevention Association.

Sincerely,

Peter Surran

Fire Inspector

County of Accomack Department of Public Safety

During the BHCD meeting on July 30th, it was recommended by the board that specific code changes be submitted for review during the open comment period before the September 7th meeting. However, the changes incorporated are too voluminous to evaluate and write recommendations within such a short timeframe. In addition, during the last open comment period, problems with specific code sections were clearly outlined.

Although a workgroup was able to perform a re-write of the “unenforceable” codes, mainly through the first ten chapters, it is evident from previous comments they are riddled with issues, concerns, and apparent unintended consequences. The sheer volume of changes with identified issues should have anyone concerned there are undeniably more unidentified issues.

I urge the board to adopt only the seventeen proposed code changes (Book 5, Part 1, Tabs 1&3) to the SFPC.  In addition I support the proposal made by the Virginia Fire Prevention Association.

Type over this te

To Whom It May Concern:

Thank you for the opportunity to recommend to the Board of Housing and Community Development specific code language to be considered during final stage of the 2015 Statewide Fire Prevention Code Change Cycle.  As an advocate for the safety of all Virginians, I would like to add my name in support of the proposal made by the Virginia Fire Prevention Association.

Sincerely,

Dwight Spangler

Fire Official

Town of South Boston, VA

In support of further review.

I recommend the DHCD Board adopt only the seventeen (17) proposed code changes (found in Book 5 – Part 1 – Tabs 1 & 3) to the SFPC that were printed in the Virginia Register on February 20, 2017, and approved by the Board in October 2017.  This limited adoption of proposed changes should resolve most of the controversial and problematic SFPC “re-write” that the DHCD Board passed.

Sincerely,
Perry Weller
Deputy Fire Marshal
City of Staunton Fire Marshal's Office

To Whom It May Concern:

Thank you for the opportunity to recommend to the Board of Housing and Community Development specific code language to be considered during final stage of the 2015 Statewide Fire Prevention Code Change Cycle.  As an advocate for the safety of all Virginians, I would like to add my name in support of the proposal made by the Virginia Fire Chiefs Association. 

Sincerely,

Kevin Duck, Commissioner

Carrsville Fire & Rescue

Carrsville, VA

To Whom it may concern:

Thank you for the opportunity to recommend to the Board of Housing and Community Development specific code language to be considered during final stage of the 2015 Statewide Fire Prevention Code Change Cycle.  As an advocate for the safety of all Virginians, I would like to add my name in support of the proposal made by the Virginia Fire Chiefs Association.

Sincerely,

Chris Eudailey

Fire Chief (Ret.)

TypI fully support the actions of the Virginia Fire Chief's Association in the rewrite of the Fire Prevention Code to include the changes they have proposed. Their actions would certainly make the Commonwealth of Virginia a much safer state for our citizens as well as guest who may be visiting in the Commonwealth. e over this text and enter your comments here. You are limited to approximately 3000 words.

As a citizen of the Commonwealth in which is protected by fire prevention code, I am in full support of the Virginia FIre Prevention Associations and the Virginia Fire Chiefs Associations recommendations to approve the seventeen (17) proposed code changes found in Book 5 – Part 1 – Tabs 1 & 3 (listed in tables below), 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 this will ultimately undo the controversial and problematic SFPC rewrite changes that the BHCD had previously passed by a small margin.  

To Whom It May Concern:

Thank you for the opportunity to recommend to the Board of Housing and Community Development specific code language to be considered during final stage of the 2015 Statewide Fire Prevention Code Change Cycle.  As an advocate for the safety of all Virginians, I would like to add my name in support of the proposal made by the Virginia Fire Prevention Association.

Sincerely,

Ty Dickerson

Fire Chief

City of Lexington Fire Department

Thank you for the opportunity to recommend to the Board of Housing and Community Development specific code language to be considered during final stage of the 2015 Statewide Fire Prevention Code Change Cycle.  As an advocate for the safety of the Commonwealth, I would like to add my name in support of the proposal made by the Virginia Fire Prevention Association.

Safest regards,

Jeremy Luttrell

Fire Marshal

City of Winchester

To: The Board of Housing and Community Development

Thank you for the opportunity to recommend to the Board of Housing and Community Development specific code language to be considered during final stage of the 2015 Statewide Fire Prevention Code Change Cycle.  As the Fire Marshal and Building Official for the City of Fairfax, and with over 30  years experience in fire prevention, I am an  advocate for the safety of all Virginians.  I hereby add my name in support of the proposal made by the Virginia Fire Prevention Association.

Having participated in many of the meetings held during the discussion of the proposed changes to this code, I can attest to the fact that the process used by the DHCD staff was flawed. I have been a part of this process for many years and have never seen a simiar process where industry (fire service) profssonals were ignored and their input was dismissed. 

I regret that I will not be available to adress you in person at your September meeting. 

We can, and must, do better for those we serve.

Thank you.

Andrew S. Wilson

Building Official/Fire Marshal

City of Fairfax, Virginia

As the former Fire Chief in Loudoun County, and still having children living in Virginia, I remainy concerned with the process being used by DHCD to rewrite the SFPC.  No one disagrees with the removal of "unenforceable" sections of the SFPC.  However, the language of the Code of Virginia directing a "joint" process with VFSB in the development of the SFPC was ignored; the Virginia Fire Service was informed of the process and "invited" to participate.  Still today there is no written statement of the problem. 

Full time staff at DHCD staff had already written their changes when the Fire Service was engaged. I and others intervened with the Secretary of Commerce and Trade to buy more time to work on the drafts, but there was not time to complete the work when the BHCD voted last fall.  The BHCD should in good conscience provide more time for the work groups to complete the task or move the process to the 2018 Code cycle.  

I do support the VFCA proposal as it does cover 17 changes to mitigate certain problems with the BHCD apporved draft.  However, we should not be here in this situation, and it does not reflect well upon the code development process that is supposed to be the among the best in the country.

Mr. Chairman and Board Members,

I would like to thank you for your patience, hard work, and open process during the Virginia code development process. As a former Board member I went through two plus code development cycles and understand the challenges you faced. I urge you to deny any petitions and move forward with the Virginia Statewide Fire Prevention Code.as previously approved. While you are being inundated with second bite at the apple comments, please keep in mind that the document that you have previously approved will now comport with state law and was fully vetted and discussed in an open and transparent process. That is the most important fact and while it doesn't set well with some folks, it enable the public and those being regulated better understand the requirements in order to maintain structures and not have to interpret whether a requirement is valid.

Sincerely,

Richard C. Witt

Director of Building Inspections

Chesterfield County

To Whom It May Concern:

Thank you for the opportunity to recommend to the Board of Housing and Community Development specific code language to be considered during final stage of the 2015 Statewide Fire Prevention Code Change Cycle.  As an advocate for the safety of all Virginians, I would like to add my name in support of the proposal made by the Virginia Fire Chiefs Association.

Sincerely,

R. Scott Garber

Fire Chief

City of Staunton Fire & Rescue

Dear Chairman Carr and Board Members,

On behalf of the approximately 1,000 members of the Virginia Building and Code Officials Association (VBCOA), I am writing in support of the Board of Housing and Community Development decision to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved. I also want to commend the great work provided by the Department of Housing and Community Development staff and all of the stakeholders and code officials who invested countless hours in this effort. The Virginia Statewide Fire Prevention Code was an open process consisting of 11 public meetings from October 15, 2015 through August 26, 2016. The meetings were attended by Building Officials, Fire Officials and affected stakeholders to review and comment on the proposed code changes. Many opportunities were provided to address any concerns, including time extensions and additional meetings. An incredible effort was invested in this code. It was an open and transparent process and no evidence has been presented to date that would demonstrate lowering of life safety or creating unintended consequences by adoption of the regulations. In fact, life safety should improve through a better understanding of the requirements by eliminating confusing and unenforceable language.

Respectfully Submitted,

Gregg Fields

President, VBCOA

To Whom It May Concern:

Thank you for the opportunity to recommend to the Board of Housing and Community Development specific code language to be considered during final stage of the 2015 Statewide Fire Prevention Code Change Cycle.  As an advocate for the safety of all Virginians, I would like to add my name in support of the proposal made by the Virginia Fire Prevention Association.

Sincerely,

C. David Throckmorton

Fire Marshal

Powhatan County Fire and Rescue

September 5, 2018

Dear Mr. Carr and Board Members,

I am writing in support of the Board of Housing and Community Development decision to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved. I also want to commend the great work provided by the Department of Housing and Community Development staff and all of the stakeholders and code officials who invested their time.

The meetings were attended by Building Officials, Fire Officials and affected stakeholders to review and comment on the proposed code changes. Many opportunities were provided to address any concerns, including time extensions and additional meetings. An incredible effort was invested in this code. It was an open and transparent process; therefore, I respectfully urge the Board to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved.

Sincerely,

Lynn Underwood, MCP, CBO

Retiring Building Official

Past-President of VBCOA

C: Gregg Fields

I support the Board on SFPC adoption.

Don Williams, CBO

Page County Va.

Dear Mr. Carr and Board Members,

I am writing in support of the Board of Housing and Community Development decision to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved. I also want to commend the great work provided by the Department of Housing and Community Development staff and all of the stakeholders and code officials who invested their time.

The meetings were attended by Building Officials, Fire Officials and affected stakeholders to review and comment on the proposed code changes. Many opportunities were provided to address any concerns, including time extensions and additional meetings. An incredible effort was invested in this code. It was an open and transparent process; therefore, I respectfully urge the Board to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved.

Sincerely,

Matt Westheimer, MCP, CBO

Chief Building Official

?Williamsburg, VA 23185

Dear Mr. Carr and Board Members,

I am writing in support of the Board of Housing and Community Development decision to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved. I also want to commend the great work provided by the Department of Housing and Community Development staff and all of the stakeholders and code officials who invested their time.

The meetings were attended by Building Officials, Fire Officials and affected stakeholders to review and comment on the proposed code changes. Many opportunities were provided to address any concerns, including time extensions and additional meetings. An incredible effort was invested in this code. It was an open and transparent process; therefore, I respectfully urge the Board to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved.

Sincerely,

Lauri Springsteen?, Residential Building Inspector

Dear Mr. Carr and Board Members,

I am writing in support of the Virginia Board of Housing and Community Development decision to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved. I recognize and commend the incredible amount of dedicated effort and time of the many stakeholders who invested their subject matter expertise and technical and administrative knowledge. The regulatory development process and its related code meetings were publically open to and attended by Building Officials, Fire Officials and affected stakeholders to develop, review, and comment on the proposed codes and any related changes. During the transparent process, numerous opportunities were equally provided to all stakeholders to address any concerns, including time extensions and additional meetings. The VSFPC has for many, many years warranted a throrough and detailed review and edit to identify and clarify the maintenance and operational code provisions that are enforceable throughout Virginia by the local Fire Officials, and to differentiate them from the VUSBC code provisions affecting new construction and alteration under the purview and authority of the local Building Officials. I respectfully request and urge the Board to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved.

Sincerely,

Paula Eubank

Arlington County, Department of Community Planning, Housing, & Development,  Inspection Services Division

Dear Board Members,

I am writing in support of the Board of Housing and Community Development decision to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved. I also want to commend the great work provided by the Department of Housing and Community Development staff and all of the stakeholders and code officials who invested their time.

The meetings were attended by Building Officials, including me, Fire Officials and affected stakeholders to review and comment on the proposed code changes. Many opportunities were provided to address all concerns, including time extensions and additional meetings. An unprecedented effort was invested in the development of this code. In my opinion, it was an open and transparent process; therefore, I respectfully urge the Board to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved.

Sincerely,

Tom Coghill, CBO, CFM

Director, Building Safety and Permits

101 Mounts Bay Rd, Building E 
Williamsburg, VA 23185
P: 757-253-6628

www.jamescitycountyva.gov

Dear Mr. Carr and Board Members,

 I am writing in support of the Board of Housing and Community Development decision to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved. I also want to commend the great work provided by the Department of Housing and Community Development staff and all of the stakeholders and code officials who invested their time.

 The meetings were attended by Building Officials, Fire Officials and affected stakeholders to review and comment on the proposed code changes. Many opportunities were provided to address any concerns, including time extensions and additional meetings. An incredible effort was invested in this code. It was an open and transparent process; therefore, I respectfully urge the Board to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved.

Sincerely,

.Douglas K. Smith, MCP; Building /Code Official

I would like to take this opportunity to support the Board of Housing and Community Developement's decision to adopt the 2015 Statewide Fire Prevention Code as initially approved. Additionally, I would like to thank and commend the staff of the Department and all of the stakeholders and code officials who invested their time and effort in developing this document.

This code is the result of an incredible effort in an open and transparent process. The meetings were attended by Fire Officials, Building Officials and affected stakeholders who gave a great deal of their time to reviewing and commenting on the proposed code changes. These meetings offered more than adequate opportunity  to address any concerns the stakeholders may have presented and continuing to delay the adoption of this code would be a disservice to the citizens of the Commonwealth.

I respectfully urge the Board to adopt the 2015 Statewide Fire Prevention Code as initially approved.

Sincerely,

First off I would like to say thank you for the oppurtunity to voice my opinion on this matter. As a resident of the state and as a Fire Official for a locality, i strongly encourage you to adopt only the 17 proposed code changes to the SFPC that were posted to the Virginia Register on February 20th 2017 and approved by the board in October of 2017. I fully support the recommendations of The Virginia Fire Prevention Association and im asking you to do the same.

Respectfully,

Mike Perdue

Fire Marshal

Salem Fire-EMS Department

Dear Mr. Carr and Board Members,

I am writing in support of the Board of Housing and Community Development decision to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved. I also want to commend the great work provided by the Department of Housing and Community Development staff and all of the stakeholders and code officials who invested their time.

The meetings were attended by Building Officials, Fire Officials and affected stakeholders to review and comment on the proposed code changes. Many opportunities were provided to address any concerns, including time extensions and additional meetings. An incredible effort was invested in this code. It was an open and transparent process; therefore, I respectfully urge the Board to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved.

Sincerely,

Philip Pugh, Division Chief, Property Maintenance

City of Alexandria, VA

Department of Code Administration

To Whom It May Concern:

Thank you for the opportunity to recommend to the Board of Housing and Community Development specific code language to be considered during final stage of the 2015 Statewide Fire Prevention Code Change Cycle.  As an advocate for the safety of all Virginians, I would like to add my name in support of the proposal made by the Virginia Fire Chiefs Association.

Sincerely,

Robert Gilmer 

City of Manassas Park, Fire Marshal 

Dear Mr. Carr and Board Members,

I am writing in support of the Board of Housing and Community Development decision to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved. I also want to commend the great work provided by the Department of Housing and Community Development staff and all of the stakeholders and code officials who invested their time.

The meetings were attended by Building Officials, Fire Officials and affected stakeholders to review and comment on the proposed code changes. Many opportunities were provided to address any concerns, including time extensions and additional meetings. An incredible effort was invested in this code. It was an open and transparent process; therefore, I respectfully urge the Board to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved.

Sincerely,

Rodger A Slate

Chief of Commercial Plan Review

Department of Building Inspection

Chesterfield, VA

Dear Mr.Carr and Board Members:

I am writing in support of the Board of Housing and Community Development's decision to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved. I also want to commend the great work provided by the Department of Housing and Community Development staff and all of the stakeholders and code officials who invested their time.

The meetings were attended by Building Officials, Fire Officials and affected stakeholders to review and comment on the proposed code changes. Many opportunities were provided to address any concerns, including time extensions and additional meetings. An incredible effort was invested in this code, it was an open and transparent process; therefore I respectfully urge the Board to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved.

Sincerely,

Steven Shapiro, Building Official

City of Hampton 

Dear Mr. Carr and Board Members,

I am writting in support of the Bord of Housing and Community Development decision to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved. I would like to commend the Department Of Housing and Community Development staff and all of the stakeholders and code officials who invested in this process.

Having been involved in this process I was proud of the efforts put fort by the Fire Officials, Building Officials and all the Stakeholders who reviewed and commented on the proposed changes. With the many extensions and additional meetings provided for the process to be inclusive of all desiring to be involved the Code Development Process is a transparent open process that delivered a document that met the intended outcome.

I respectfully urge the Board to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved.

Thank you,

James Moss

Dear Mr. Carr and Board Members,

I am writing in support of the Board of Housing and Community Development decision to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved. I also want to commend the great work provided by the Department of Housing and Community Development staff and all of the stakeholders and code officials who invested their time.

The meetings were attended by Building Officials, Fire Officials and affected stakeholders to review and comment on the proposed code changes. Many opportunities were provided to address any concerns, including time extensions and additional meetings. An incredible effort was invested in this code. It was an open and transparent process; therefore, I respectfully urge the Board to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved.

Sincerely,

Ronald J. Schuett CBO, MCP

Building Official

City of Harrisonburg

Harrisonburg, VA 22801

Dear Chairman Carr and Board Members,

I am writing in support of the Board of Housing and Community Development’s decision to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved. I also want to commend the great work provided by the Department of Housing and Community Development staff, and all the stakeholders and code officials who invested countless hours and energy. This was a collaborative effort made by the leading safety professionals in Virginia. The 2015 Virginia Statewide Fire Prevention Code development meetings were attended by Building Officials, Fire Officials and affected stakeholders to review and comment on the proposed code changes. Multiple opportunities were provided by this group to address any concerns, including time extensions and additional meetings. An exceptional amount of time and expertise was invested in development of this code. It was an open and transparent process; therefore, I respectfully urge the Board to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved.

Respectfully Yours,

Pete Mensinger

First Vice President, VBCOA

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

Dear Mr. Carr and Board Members,

I am writing in support of the Board of Housing and Community Development decision to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved. I also want to commend the great work provided by the Department of Housing and Community Development staff and all of the stakeholders and code officials who invested their time.

The meetings were attended by Building Officials, Fire Officials and affected stakeholders to review and comment on the proposed code changes. Many opportunities were provided to address any concerns, including time extensions and additional meetings. An incredible effort was invested in this code. It was an open and transparent process; therefore, I respectfully urge the Board to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved.

Sincerely,

Cary K. Jamison

Building Official

Stafford County, VA.

540-658-8657

cjamison@staffordcountyva.gov

Type over this text and enter your comments here. You are limited to approximately 3000 words.

Dear Mr. Carr and Board Members,

I am writing in support of the Board of Housing and Community Development decision to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved. I also want to commend the great work provided by the Department of Housing and Community Development staff and all of the stakeholders and code officials who invested their time.

The meetings were attended by Building Officials, Fire Officials and affected stakeholders to review and comment on the proposed code changes. Many opportunities were provided to address any concerns, including time extensions and additional meetings. An incredible effort was invested in this code. It was an open and transparent process; therefore, I respectfully urge the Board to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved.

Sincerely,

Mark Robinson

Deputy Building Official

Warren County , Va.

As the Board of Housing and Community Development directed all unenforceable language to be deleted from the VMC and the VSFPC, I am in support of the adoption of such as initially approved.  As with every code change process there are changes not everyone finds favorable.  However with previous involvement on code change committees I am positive that the vetting process was open, transparent, and conducted as required for every stakeholders input.  I would like to thank everyone’s involvement through this tedious task.

Respectfully submitted,

Michael Dellinger, CBO

Building Official

Albemarle County

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.

Dear Mr. Carr and Board Members,

I am writting in support of the Bord of Housing and Community Development decision to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved. I would like to commend the Department Of Housing and Community Development staff and all of the stakeholders and code officials who invested in this process.

Having been involved in this process I was proud of the efforts put fort by the Fire Officials, Building Officials and all the Stakeholders who reviewed and commented on the proposed changes. With the many extensions and additional meetings provided for the process to be inclusive of all desiring to be involved the Code Development Process is a transparent open process that delivered a document that met the intended outcome.

I respectfully urge the Board to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved.

Thank you,

Michelle Coward

Dear Mr. Carr and Board Members,

I am writing in support of the Board of Housing and Community Development decision to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved. I also want to commend the great work provided by the Department of Housing and Community Development staff and all of the stakeholders and code officials who invested their time.

The meetings were attended by Building Officials, Fire Officials and affected stakeholders to review and comment on the proposed code changes. Many opportunities were provided to address any concerns, including time extensions and additional meetings. An incredible effort was invested in this code. It was an open and transparent process; therefore, I respectfully urge the Board to adopt the 2015 Virginia Statewide Fire Prevention Code as initially approved.

Sincerely,

David C. Beahm

Warren County Building Official