City of Santa Ana Mayor Miguel A. Pulido*

There is a lack of uniformity in local building codes involving roofs for identical environmental conditions within Orange County. City Response: While we concur there is lack of uniform local building codes involving roofs in Orange County; we strongly disagree with the concept that environmental conditions are the same throughout the county. The relatively flat topographical conditions of our community are uniquely different from those communities with major hillside and wooded areas. And, while we agree that our climatic conditions are similar, we strongly believe it is the topological conditions which have the more significant impact upon roof type standards.

The testing and qualification standards of wood shakes and shingles are below the environmental conditions of Orange County. City Response: We have no ability to determine whether the testing and qualification standards of wood shakes and shingles fall below the environmental conditions of Orange County. We adopted a County-wide minimum standard with our adoption of the California Building Code and believe that to be the appropriate standard for this city. We mandate and enforce the California Building Code requirement that all roofing materials be tested and approved by recognized testing labs or meet established prescriptive standards.

The cities' and county's roofing standards do not adequately take into account the climate, particularly the Santa Ana winds, and topographical conditions unique to Orange County. City Response: We don't believe the environmental conditions of Orange County to be so uniform that the cities and the county have a responsibility to have a uniform maximum standard. We acknowledge that California Building Code establishes an appropriate minimum standard for roofing and roofing assemblies. Those cities that have unique topographical and climatic conditions, can (and have) altered their individual codes to meet their locale needs.

Fire conflagrations stress fire fighting resources especially during the period of Santa Ana winds. City Response: We concur. Dr. T. W. Staple, M.D. October 27, 2003 Response to the Recommendations 1. Each respondent jurisdictional agency should consider amending the building code to require the most fire retardant class of roof covering (Class A) for new construction of all residential structures (Group R) in all fire zones. City Response: We do not believe that it is prudent public policy to require a Class A standard of roofing in our community, in which there is no unique environmental, topological, or topographical need. The requests for wood shake or shingle roofing is a rare exception in our process and does not justify the city mandating an ordinance amendment. We are strong proponents of the California Building Code, and the current regional amendment regarding roofing that is in place, it has served our community appropriately.