City of Buena Park Office of the Mayor April 22, 2003 Frederick P. Horn Presiding Judge of the Superior Court*

There is a lack of uniformity in local building codes involving roofs for identical environments conditions within Orange County. Response: We acknowledge that there are different standards being enforced in Orange County concerning roofs. However, we believe that there are different conditions that exist in the County and one standard is not appropriate for all jurisdictions. Although the environmental conditions are somewhat consistent throughout the County, the geographic and topographic conditions differ considerably. The perceived "lack of uniformity" may have a very logical basis as to allowing each locale to determine the level of mitigation of hazards necessary to provide for the degree of safety that is "actually equal" to other areas of the County and that the citizens of the locale desire.

The testing and qualifications standards of wood shakes and shingles are below the environmental conditions of Orange County. Response: The standards for fire retardant pressure treatment of wood, used for up to a Class "A" roof assembly, to the best of our knowledge, has proved to be on track with the State Fire Marshal's recommendations and requirements. We do not have any data that would support this finding in our jurisdiction. Nevertheless, local jurisdictions do not establish testing criteria and qualification standards. National testing agencies such as the International Code Council (ICC), American Society for Testing and Materials (ASTM), and Underwriters Laboratories (UL) are the appropriate agencies to respond to this finding.

The cities' and county's roofing codes do not adequately take into account the climate, particularly the Santa Ana winds, and topographical conditions unique to Orange County. Response: This may be the case with some jurisdictions; however, we believe that we have adequately considered these conditions as they relate to our community. City of Buena Park has adopted a Class "C" as the minimum standard for all occupancies, where the State codes would have allowed non- rated installations. Fire conflagrations stress finite fire fighting resources especially during the period 4. of Santa Ana winds. Response: This is primarily true of communities with wildland/urban interface, designated as Very High Fire Severity Zones. Buena Park does not have any such zones and the record of the past decades does not support this finding as it relates to our jurisdiction. We recognize that some areas of the County, that may include heavy brush and vegetation, have caused this referenced demand on available resources on adjoining jurisdictions with mutual aid agreements. Frederick P. Horn Presiding Judge of the Superior Court April 22, 2003 Re: Orange County Grand Jury Report - Wood Roofs are Dangerous .