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~RRD p~SU~a~$pR s Mo hannam, Kathleen BAR ~ 12 S nm. Fridas Mach 11620 1e8:36rAM fre.ca.gov] Vl~~~ ca~l~aRNlp Y, > To: Wahl, Larry; Lambert, Steve; Kirk, Maureen; Connelly, Biil; Yamaguchi, Kim; Hahn, Paul; Alpert, Bruce Cc: Moghannam, Kathleen; Snellings, Tim; Springer, Nancy; Damon, Matt; Pickett, Andy; Kim, Sang Sub]ect: Residential Sprinklers in mobile homes Attachments: di301020110216145733.pdf; MHletter2.pdf Board members, As you know, the requirements to install residential sprinklers are governed by two separate articles of Title 24 of the California Code of Regulations. These two articles are commonly referred to as the California Fire Code, fire flow requirements, and the California Residential Code, respectively. Beginning in 2008 the Butte County Fire Department began enforcing the fire flaw requirements of the California Fire Code in all residential occupancies. This law ensures that there is sufficient water available for fire suppression at any given residence, by requiring that a residence be within 1000 feet from a recognized hydrant system that produces a minimum of 1000 gallons of water per minute for at least two hours. However, in the event that a residence does not meet these requirements, residential sprinklers can be used as mitigation to insufficient fire flow. The builder has the option to extend or develop a hydrant system to within 1000' of the structure or install residential sprinklers. This requirement has been applied to onsite built homes and mobile/manufactured homes equally. On January 1, 2011, an updated California Residential Code went into effect. This law requires that all residences have sprinklers. In mid February a local mobile home distributor sent a fetter to the Board of Supervisors asking why residential sprinklers were being required in Butte County given the letter from HCD. They went on to say that, "Yuba, Sutter, Glenn and Colusa are a few counties that said they would not require 1•tre sprinklers because of the bulletin". Per the HCD letter, mobile and manufactured homes are exempt from the California Residential Code. After talking to the State Fire Marshals Office (SFM) and HCD it appears that they may be exempt from residentia! sprinklers as fire flow mitigation as well. Given the information from HCD and SFM there is enough uncertainty on my part that the fire department will suspend its policy related to sprinklers as mitigation to the fire flow requirements of the California Fire Code immediately. For the fire department this poses several challenges going forward: All onsite built homes are now required to install residential sprinklers regardless of their location relative to a recognized hydrant system as described above. The position of HCD and SFM appears to be that we cannot apply the fire flow requirements of the California Fire Code to mobile/manufactured homes at all. This sets up a situation of homes on the same street and at the same distance from a fire hydrant system having different requirements. An onsite built home will be required to have sprinklers (CRC) but the mobile home installed next door will not (HCD exemption). We have been applying fire flow requirements to mobilelmanufactured homes since 2008. There are recently approved mobilelmanufactured home permits that required sprinklers. We are now in the process of making changes to their requirements as appropriate. Although this brief email provides you with some information, I will need to present this to the full Board for discussion. will be bringing forward options on how to proceed, along with a recommendation. 1 will be detailing these options and recommendations in the staff report to the agenda item. Sincerely, George George Morris Chief Butte County Fire Department 530-370-3504 Jan 2~ 2[]11 S:33PM HP E_RSERJET FRX p.2 S7a'rRrlFCal.~c(~Rji]A_RI]glt~EiiS~_TRniVCWIRTa7YtlNA7df7Hf1ItS1Tif5,yG~_Y ARN!"il e-c~ - DEPAR~MENT t3F H+DUS~NG AND C4TJ"N~TY DEYVEL[3PMEN'~' Dllr'ISiOt~ dF CODES AND ST.AND~I~.DS tBQQ TllsrdStrrc[, Sufic 264, P. 4.8rax 1407 sacranm,so, Ca ~sgtz-t~nl E ; _ (4i 61 ii45~47! {'ft7{ (9IG) 327-4712 Prom "!'L)t~ Ptlones: i-8D4-735-Z9z4 ~nr~v.]rcd_ce.ga~ ~~c~~leE~a ~~, ao~a IR~FdRA~A'FiQI~I BULLETIN 2[F'Ia-04 ~~t}i-b~ T(): Gity and County Bctildi>r;g ~fici.ails City a>nd Gaud f=loe f31'ftcials. ~ll~rnlufactureoi i"EQrrn~ [IJiareufactuiresl~ and E]ealers [e~teresfed Parties Givislartr Staff Sl~t~.fEC~': k1~kNlti`=~G'~'Ui~E[? i-!C?1NIE SIRE SPRii~Kt~ER SYSTEIf~IS This lnforma~tian Bu[ketin does oat replace [nformatiort Bulletin (IB} number ZQO'l-D4 (MHO which announcet~ preert~ptive requirements for th.e design and installafion v# fire sprinkler systerxts, it such systems are installed in nevu ar asset manufactured hcrrtes, rrlobilehomes and m[~Itifamily manufactured homes cvntainir>;g two civvellir}g units.' IB 2a0'I-04 may fie oEatainecf on the ©epartTrtent's website a# the fall4uving address: h :lCw4nfw_ficd.ca. ovfcodeslmh ~r1<fr~tau[ls_htt~l an .~anuary '{, 2Q1'!, the 2Q10 California Building Standards Codes, ire Ca{ifarrlia Cade af~ Regulations (CCR}, Title 24, will become effective, including (new) Part 2.5, California Residential Code {CRC), which rrtartciates the installation of fire sprinkler systems in dwelling units pursuant to section F~3'13. This requirement is applicable to townfratases and one-arid two-farnify dvveliings. This [nforrnation Bi~llel?in provides in€orrnation to ktacal building anei fire enforcement agencies that the provisions of E~oth the California Health and Safety Cade section 'lS9f]9(g)~ excluding manufactured housing and the preemptive requirements of CCR, Title 25, ©ivisian 'i, Chapter 3, Article 2.5, the implerrterrtatior~ of t[~e 2D10 CRG wild not rr~andate the installation of fire sprinkler systems in manufactured blames, mobilehomes ar mt~ftitamiily rnar>iufactured homes with two d~rrelling units. Tfle GCR, Title 25, Division '[, Article ~.5 establishes requirements Far the ii-tstallation of fire sprinkler systems in rnar>iufactured homes, mabiieharrles and multifamily manufactured homes with two dwelling units, which i~nly apply uvhen either fire sprintCier systert~s are req~ttrect throt~gli enacting ordinances by a !Deaf goverr~rnent ar authority having jurisdiction or w[aere th+? purchaser, dealt=r or owner eiecis to install a #ire sprirtklfr system t "illiuttiFamiiy manufactured homes vvkh two d~xeliing ~rsits are deidned in F4eelth and Safely Coc#e Section 180t~.7. i~kese ilk sprinkler regulatkors da not appty to muftiramiSy manufad:ureci homes ctxtitafRing mare than two dwe[fing units. ~ "~ui~d'~g Standard' dyes not incivde any regulation, rule, order, or standard that pertains to mobitehomes, manufactured homes, wmmercial coaches, special purpose commercial coaches ur reaeationat vetlides. .tan ~~ 2011 5:33!'M HP LRSERJET FR}{ ~nfa-mation Bultetin 2Lf9p-Q4 (MH) Page 2 of 2 p.3 in a ne~rnr or used rnanuFactured home, mobitehnme or muttiFamily manufactured i~ome with two dwelling un"rts. Anyone having questions concerning the rnanuFactured housing fire spriniCler rrigulations may contact #Cevin Cimini, iUtanufaCtured Ha+~sing t'rogram tanager. at (9'!8) 4et5-333g_ Kim Strange Deputy Direc6vr ~~- ~-- BCFD VOLUNTEER FIRE COMPANIES Co. 12 Stirifng 6Ity Co. 2i Cohassel Co. 2a Forest Ranch Go. 25 Penh Valley Co. 2l3 Butte Creek Canyor Co. 33 Upper Rldge Co. 37 Gofden.Feaiher Co, a2 Ghieq Metro Cq. 45 Durham Co. 52 Feather Falls Co. 55 Bangor C.o. B1 Pioneer Co. 84 Keffy Ridge Co. 87 Cherokee Co. 7i Richvefe. co. 7a Gridley r Biggs BCFD CAREER FIRE STATIONS Sta. 39 Upper Ridge Sia. 41 Nord Sla. 42 North Chleo Sta. 44 South Chico Sta. 4S Durham Sta. 55 Bangor Sta. 63 Orovil[e Sta. 84 Kelly fudge Sta. 71 Richvale Sta. 72 Palermo Sta. 73 Biggs Sta. 74 Gridley CAL FIRE F1RE STATIONS SW, t1 Butte Meadows Sta. i3 Slirling Ciiy Sta. 22 Cohasset SW. 23 Forest Ranch Sta. 35 Paradise 51a. 38 Jarbo Gap Sla. 51 Feather Falls Sta. 54 Robinson MITI Sta. 62 Harts Mil! Sta. 63 Orovllle HO CHlCO AIR ATTACK BASE ALSO PROUDLY SERVING city of Biggs City of Gridley <:~; ~. Wendy Auer Executive Homes 3042 Esplanade Chico, Ca. 95973 Wendy, ~~: -.. . ~ u~te Ltk~D. OF NRTLfRAI. tNEiA:LTH AND BI;ALJ.'T1f BUTTE COUNTY FIRE DEPARTMENT CAI_IFORNlA DEPARTMENT OF FORESTRY AND FIRE PROTECTION "Cooperative-Fire Protection since 1931" 176 NELSON AVENUE OROWLLE, CALIFORNIA 95965-3495 TELEPHONE:- (5$D) 538-711 i FAX: (530) 538-7461 March ~ 0, 2011 As you know, the requirements to instal! residential sprinklers are governed by two separate articles of Title 24 ofi the California Code of Regulations. These two articles are commonly referred to as the California Fire Code fire flow requirement and the California Residential Code, respectively. Beginning in 200$ the Butte County Fire Department began enforcing the fire flow requirements of the California Fire Code in all residential occupancies. This law ensures that there is sufficient water available for fire suppression at any given residence, by requiring that a residence be within 1000 feet from a recognized hydrant system that produces a minimum of 10.00 gallons of water per minute for at least two hours. However, in the event that a residence does not meet these requirements, residential sprinklers can be used as mitigation to insufficient fire flow. The builder has the option to extend or develop a hydrant system to within 1000` of the structure or install residential sprinklers. This requirement has been applied to onsite built homes and mabilelmanufiactured homes equally. On January 1, 2011, an updated California Residential Code went into effect. This law requires that all residences have sprinklers. On December 22, 2010, with the pending adoption of the 2010 California Residential Codes, The Department of Housing and Community Development (HCD) issued a letter to interested parties about mobile homes and residential fire sprinklers. In that letter, HCD expressly exempted mobile and manufactured homes from the requirement to instaN residential sprinklers as required by the California Residentia! Cade. W. Auer Page 2 The Butte County Fire Department has complied with this directive from HCD by not applying the Califomia Residential Code sprinkler requirements to manufactured and mobile homes, but has continued to apply the fire flow requirements. Your letter to Supervisor Wahl dated February 1 S, 2Q11 raises the question of whether the fire flow requirements apply to manufactured or mobile homes. The Butte County Fire Department has asked for clarification on this subject. I'd like to say that the issue is very simple, but it`s not. There is enough uncertainty with these laws that the fire department will suspend its policy related to sprinklers as mitigation to the fire flow requirements of the California Fire Code immediately. The Butte County Fire Department will present this issue to the Board of Supervisors to discuss what would be required to apply the fre flow requirements to manufactured and mobile .homes. If you have any questions please feel free to call. Sincerely, George W. orris ,tr. Chief Butte County Fire Department tp