California 92548*

The approach of combining all of Orange County together as "...identical environmental conditions..." does not seem logical due to a number of reasons.

The enactment of an ordinance that affects all future new roofs would not change any of the conditions that now exist and there was no data on the percentage of new roofs that were being replaced with wood. For these reasons and other issues that are identified below, we do not believe that a stringent ordinance for wood roofs is needed or will accomplish a high level of fire safety in our community. First of all, we do not believe that the combination of all of Orange County into essentially one "...very high fire hazard..." is appropriate. This is the type of language that is in the State Code and determines what type of roof needs to be applied due to the fire hazard of the area. It makes perfect sense for the designated high hazard areas to have more stringent standards and this accounts for much of the lack of uniformity throughout the county. What is missing is that our jurisdiction is an Ocean community TELEPHONE (714) 536-5553 Anjo, Japan Waster and a second FAX (714) 536-5233 . . . . . . . . . . . . . . . . . . . . . and it is not as hot or dry as other communities. In addition, we do not have the hills, narrow streets, large open areas or some of the other negative physical attributes that inhibit access for fire fighting. The second issue is that the proposed ordinance would only affect new roofs. We analyzed what this would accomplish in Huntington Beach. Huntington Beach had much of its growth in the 60's and 70's and these roofs are at or past their life. The wood roofs are predominantly being replaced with asphalt shingles, tile or composite tile materials. Our experience is that very few roofs are being replaced with wood. The old non-rated roofs are disappearing due to age, the market, insurance companies and simply style. All this without dictating a code to the public that is dramatically more stringent than the State Building Code. Another area that separates Huntington Beach from many of the cities in Orange County is that in 1990 we adopted the standard that all new wood roofs must be a minimum of Class C. This just became the standard in the State Building Code, thus for 13 years we have already had a higher standard than many other jurisdictions. What this means is that even the small number of Huntington Beach wood roofs that have been installed in recent years are fire resistive. In conclusion, our analysis indicates that a more stringent requirement for wood roofs would not accomplish the goals of the Grand Jury Report. Our jurisdiction simply does not have the same high fire hazards as other cities in Orange County and our experience is that the replacement roofs are not wood. Enforcing codes is a constant balance between proven safety problems, the market place and rights of property owners. There is simply not a compelling argument for this ordinance in Huntington Beach. Per the letter from Foreman Carlos Olvera, we are required to respond to both the findings and the recommendations. Both are listed below with a short response to each using the logic already stated. Findings 1. There is a lack of uniformity in local building codes involving roofs for identical environmental conditions within Orange County. Response: We acknowledge that there is are different standards being enforced in Orange County concerning wood roofs. We do not consider this a bad thing just an acknowledgment that there are different conditions that exist in the County and one standard is not appropriate.

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: We have taken this into account when we increased our standards from non-rated to requiring a Class C roof in 1990. We would say that the report did not adequately take in account the variation in climate in the County as it relates to Huntington Beach.

Fire conflagrations stress finite fire fighting resources especially during the period of Santa Ana Winds. Response: This is primarily true of the inland communities.