HomeMy WebLinkAboutStaff Report 4.C 02/23/2004a
CITY OFTETALUMA, CALIFORNIA
AGENDA ILL February ,
A' ends Title:
troduction of Ordinance Incorporating Recommendations Made
Meeting Date: February 23, 2004
y5the Fireworks Taskforce and Amending Petaluma's Fireworks
Ordinance.
Meeting Time X 3:00 PM
Category (check one) ❑Consent Calendar Public Hearing New Business "
X Unfinished Business ❑ Pre ntation
Department
Contact Person
Phone Number.
Fire Department
b its
Michael Ginn
Albertson 778 -4390
of
Fire Marshal
Ginn 778 -4389
Cost of Proposal N/A
Account Number N/A
Amount Budgeted N/A
Name of Fund: N/A
Attachments to Agenda Packet. Item
1. Agenda Report
2. Ordinance with 2004 amendments
M mmary Statement:
his Agenda Bill recommends the Council approve amended changes to the Petaluma Municipal Fire
Code. The genesis for these code changes arise from earlier recommendations presented to the Council by
a fireworks task force and the Fire Chief. The.proposed amendments address two changes to the fireworks
ordinance:
• Banning the retail sales -of "piccolo Pete" or'other similar devices
• Amendments to violation'arid,penalty language for fireworks violations
An additional amendment unrelated to fireworks is also being recommended for consideration. This
language developed by the City Attorney clarifies and prescribes specific procedures for an appeal process
to a fire code interpretation.
Recommended City Council Action /Su Bested Motion
Council approve and adopt the proposed amendments to the Petaluma Municipal Fire: Code.
Reviewed by , Finance. irector:
e - Attorne :
ate:
A rov" i Manager:
Date:
D ie:
TodaVs Date
Revision# and'Date,,Revised.
File Code:
January 29, 2004
4 N/A
mg/Fireworks ordinance 2004.doc
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- 'CITY OF PETALAJMA CALIFORNIA
FEBRUARY 23, 2004
AGENDA REPORT
FOR
Introduction of Ordinance Incorporating Recommendations Made
'by the Fireworks Taskforce and Amending Petaluma's Fireworks Ordinance.
1. EXECUTIVE SUMMARY
The proposed amendments to the Petaluma Municipal Fire. Code (PMFC) are the result of unfinished
business and direction by-the Council regarding the use of state approved fireworks' sales within the city
limits.
This ordinance is part two of two of the task force recommendations. Part one included approval of a
resolution, authorizing the Fire Department,to continue with the Education and Enforcement Plan (also to
be heard on 2/23/04). This portion involves the task force's recommendations for amendments to the
PMFC as outlined above.
The recommendations of the'task force include the following amendments to the PMFC.
® Banning the retail sales of "Piccolo Pete" or other similar devices
® Amendments to violation and penalty language for fireworks violations
An additional language amendment, unrelated to .fireworks, but necessary to clarify appeal procedures
for fire code interpretations is being piggybacked. on this ordinance amendment..
•
2. BACKGROUND
On August 18, 2003, the Fire Chief requested the Council discuss ,and consider a ban on all fireworks
sales and use in Petaluma. The ,Council voted to continue to :authorize sales of state approved fireworks.
A task force was formed to review and discuss six specific, issues, generated by the wholesalers /retailers
to improve the education and enforcement plan. On January 5, 2004,' the,Fire Chief presented 'a status
report reviewing the findings and recommendation& of thelask force, including the adoption of an
'ordinancemaking amendments to the City's fireworks regulations.
The first two amendments involve "Piccolo . Pete" -type fireworks. Piccolo Pete -type fireworks (and
similar fireworks constructed by other manufacturers) are whistling type fireworks. Unfortunately, the
y pp ed ,code amendment maakinfte g al explosive device.
L
p y this modificat modified
d i to an ille
Last
devices ear the Council a han of 'unsupervised n modified i
g a violation. of the PMFC.
One of the compromises of the August 18, 2003 Council vote to continue the sales of state approved
fireworks was a recommendation' from the wholesalers /distributors to ban the retail sales of Piccolo
Pete -type devices within the city. The specific goal of , the ban is to 'reduce the- opportunities for
modification by unsupervised youth:. The sales ban will be implemented this'coming Fourth of July with
an exception permitting wholesalers to, dell the whistling devices previously packaged in large
assortments left over from the previous year's sales. Assortments sold in 2005 will specifically exclude
the whistling devices.
The third amendment strengtheris penalties for illegal fireworks use. This language resulted from the
City Attorney meeting with 'the task force regarding better ways to improve enforcement, fines and cost
recovery for disposal of confiscated fireworks.
The fourth amendment involves appeals under the PMFC. Currently, Section 1.7.20.080 of the PMFC
provides that an applicant who is refused a permit or believes the. Fire Code has been misinterpreted,
may appeal the decision to a board of building review. Section 17.20.080 has, been revised to continue
allowing general Fire Code ,permits and interpretations to be heard: by a board of building review.
y n g that provides for appeals regarding, fireworks sale permi
Additionally,, anew section has been -added
heard,b, the. City, Mana er-. These latter appeals' will follow;a streamluied procedure used by other
for permitted ;business activities: In. the future, the board of building review will continue • to provide
technical 'expertise; on: technical appeals while the City Manager hears appeal's :involving compliance
with the fireworks permit sales regulations.
3. ALTERNATIVES
The, only alternative is' to take no; action. This would-limit- : fireworks enforcement options of 'the
Police; and. Fire Department ,and still allow piccolo pete or si filar devices to> be sold and discharged
within the city.
4. FLNANCIAL IMPACTS
There-are• no, direct costs associated with the proposed code amendments. Costs .associated with
enforcement will be underwritten by fees collected from wholesalers /retailers °to implement the
Education !and Enforcement Plan. The fireworks Education and Enforcement Plan and ,the `resolution.
authorizing the..collection and.paymeat of the fees will be heard separately under the heading of New
Business on the same night as this! ordinance proposal.
S. CONCLUSION
These tc6de amendments'will reduce the modification of piccolo Pete fireworks or similar
devices as defined in the ordinance. Violations' and, penalty °issues as well as cost recovery 'for
confiscated fireworks disposal will be enforced with .these language changes: Further,: the appeal
procedures previously set forth.in the PMFC have been ,clarified to assure timelyprocess'
i ng of'appe
6. OUTCOMES .OR. PERFORMANCE MEASUREMENTSfTHAT WILL IDFNTiFv qu C' . FSC`nR C'nMPYX..Tlnly-
These code changes will take effect 30 days after asecond - reading of "the-Ordinance; set-to be
before .Council .on March 8, 2004.
7. RECOMMENDATION
The Council, adopt the proposed ordinance with amendments.
.680693
SATireworks,04Tireworks Agenda -Bill amend ing'ordinance.doc
Seconded by
AN ORDINANCE OF THE CITY COUNCIL OF THE CITE' OF PETALUMAANIENDING
SECTIONS 17.20.070 AND 17.20.080 OF THE.PETALUMA MUNICIPAL, CODE RELATING TO
AMENDMENTS TO CALIFORNIA °BUILDING STANDARDS TITLE 24, PART 9, THE 2001
CALIFORNIA FIRE CODE
BE IT ORDAINED BY THE COUNCIL OF THE CITY OF PETALUMA AS-FOLLOWS:
Section 1 . Findings. Pursuant to California Health and Safety .Code section 17958.7, the City Council
makes the factual findings set forth in "Exhibit A" attached hereto and incorporated herein by reference, and
finds that the amendments made in this :ordinance to California Building Standards Title 24, Part 9, the 2001
California Fire Code, are reasonably necessary because of the local climactic, geological or topographical
conditions set forth in said exhibit.
The City Council finds that Piccolo Pete -type fireworks present -an attractive nuisance to children in the
W unity, may be modified for use contrary to their intended use and';therefore pose a serious threat to the
public health, safety and welfare. Thus the City Council has prohibited the sale and use of such fireworks
within the City.
The City Council finds that illegal activities related to fireworks pose a serious threat to the public
Health, safety and welfare. The City Council finds that enforcement actions undertaken by the City to
investigate and prosecute illegal activities and costs related to the destruction of illegal fireworks require the
p gni ty y City ex enditure of significant. Ci resources. Finally, . the Ci Council fin ds that curbing illegal activities related to
fireworks and enforcements :costs related this' effort are a municipal affair. Thus, the City Council has
established penalties for violations pursuant to Article XI, 'section 5(a) of the California Constitution.
The City Council finds that the City has an interest in insuring that the City and persons aggrieved of
decisions made by the Fire Chief, ,or his/her designee, have a due process right to appeal such decisions. The
City Council finds that providing procedures for such appeals which allow for timely reconsideration of these
.decisions by the City Manager of his/her designee provide a stronger protection of the City and the public's due
pess rights than the current appeal procedures.
Section 2 . Amendments. Petaluma Municipal Code section 17.20.070 entitled "Amendments made in
the Uniform Fire Code" is hereby amended as follows:
Amendment 1. Section 205 entitled "Definitions" is amended by adding ta definition of "Piccolo Pete
type fireworks:" .
"Piccolo Pete -type fireworks" shall : mean a state-approved firework item as defined in Health
and Safety Code Section 12529 "and'12562 acid thexelevant sections of Title 19, California Code
of Regulations Subchapter 6 which are hereby incorporated by reference. "Piccolo Pete -type
fireworks" are also known and `sometimes referred, to and/or labeled as and' /..or have substantially
the same appearance and, discharge characteristics as, but not limited to "Piccolo Pete ?? "'Whistle
Pete, Nite Siren; Whistling Phantom," Screaming Willy, Whistling Pete.
Amendment 2. 'Section 7802.3.2.3 is hereby add'ed`to read as follows:
Prohibition Against Sale and Discharge of Piccolo Pete type Fireworks'
A. Notwithstanding the provisions of Section 7802.1.1, no person shall, sell, use, distribute, gi �°
away or discharge, at any time, on any, day, any "Piccolo Pete -type firework" 'or any firew
having substantially the same- appearance and disclarge characteristics as any of these.
Additionally, any retail sale, gift or donation of any "Piccolo Pete - type firework'' (or any
firework. having, substantially the same appearance and discharge characteristics as any of these)
shall be aviolation of this section.
B. Except as otherwise'provided herein, it shall be lawful for any person to possess and /or transport
any "Piccolo Pete -type firework "`within the City of`Petaluma.
C. Except as otherwise provided herein, it shall be lawful in 2004, only -, to sell, any "Piccolo Pete-
type firework" in the City of Petaluma, so long as' said item is contained in an existing fireworks
assortment package containing other types of state- approved fireworks.
D. This section shall not. apply to persons, businesses or entities licensed'by the State Fire Marshall
as wholesaler and/or import/export concern to legally !possess or sell fireworks, including those
prohibited by this section, within the City for the primary purpose of sale and distribution outside
the City.
Amendment 3. Section 103.4.4.1 entitled. "Citation Violation" is hereby amended'to read'as follow.s.
4
Violations and Penalties.
'A. Any violation of the provisions .of this section shall be .a misdemeanor. Notwithstanding the
preceding sentence, a violation of the provisions of this section may be charged and
prosecuted°; as an infraction at the discretion of the City Attorney's office or other enforcing
• authority.
B. Any person convicted of a misdemeanor under the provisions of this section shall be
punishable by a:fine not to exceed one thousand dollars ($1,,000) or by impri sonment in the
county jail for a period. of not more than six (6) months, or by both such fine and
imprisonment.
C. Any person convicted of an infraction under the provisions of this section shall be punishable
by a fine as follows:
1. Upon a first conviction, by a fine not exceeding five hundred dollars ($500..00), or by
court supervised community service, or by both, such fine and community service.
2. Upon a second conviction, by a fine not exceeding one thousand dollars ($1,000.00),
or by court supervised community service, or by both such fine and community
service.
D. Any person convicted under the provisions of this section shall be required to reimburse the
City for costs related to enforcement, including, but not limited to, investigation of
violations, destruction of fireworks, and attorney's fees..
E. Nothing in this section,shall prohibit a court.from.imposing restitution upon any person
convicted of a violation of the provisions of this section.
Section 3 . Amendment. Petaluma Municipal. Code section 17.20:08.0 entitled "Appeals" is hereby
amended as follows:
Section 103.1.4.1 entitled "Appeals" is hereby amended to read as follows:
A. Appeals. Whenever the Chief disapproves an application. or refuses to grant a_permit applied for,
or when it is claimed that the provisions of the code do not apply or that the true intent and
meaning of the code have been misconstrued or wrongly interpreted, the applicant may appeal
from the decision of the Chief to the board of appeals, which is designated to be the board of
building review as heretofore established and. appointed according to Chapter 17.08 of this code,
within thirty days from the date of the decision appealed. The Fire Chief shall act as secretary of
the board when it is hearing. appeals concerned with the Uniform Fire Code. -
B. Fireworks Booth Sales Permits. Notwithstanding section A, the following appeals procedure
shall apply exclusively to permits for Fireworks Booths Sales under this Code. Any person
aggrieved by a decision.of the Fire Chief, or his/her designee, to disapprove an application,
refuse to grant a permit, place conditions on a permit, or revoke a permit shall have a right of
appeal of the decision to the City Manager; or his/hef designee. Such appeal shall be taken by
filing a written notice of appeal with the City Clerk within ten (10) days of the date of the
decision. The appeal shall set:forth the grounds for the appeal and the name and address of the
person requesting the appeal. A failure to file a timely -and complete appeal shall render the •'
decision final and conclusive. The City Manager shall, within ten (10) days of `_the filing of the
appeal set atime and place for a hearing on the appeal. The appeal shall. be set no less than five
(5) days after the filing of the appeal and no more than sixty (60) days after the filing of the
appeal. The City Manag&s, deterrnination.following the hearing shall be in, writing:and shall
contain d.statement of the facts upon which the determination is based. The City Manager's
determination, shall be sent first - class U.S. mail postage prep did `to the person, requesting the
appeal, not later than ten 0b) days I following:the date of such determination. The determination
of the City Manager. shall be final and conclusive.
Section 4 . Repeal. All ordinances or parts of ordinances in conflict herewith are hereby repealed.
Section '5 . Full, Force and'Effect. Except as herein amended, all provisions of,Petaluma 1vlunicipaI
Code sections 17.20:070 and 1720:080 shall remain in full force and effect.
Section 6 . Severability. If any section,. subsection, ;sentence, clause or phrase or word' of this ordin a
is for any'reason.held to be unconstitutional, unlawful or otherwise invalid by a court, competent jurisdiction,
such decision shall not affect,the validity of the remaining portions of this ordinance. The City Council of the
City of Petalumahereby declares that it would have passed and adopted'thi's ordinance and each and all,
provisions thereof irrespective of the: fact that any one or more of said provisions be declared unconstitutional,,
unlawful or otherwise' invalid.
Section 7 . Effective Date. This ordinance shall, become effective thirty,(30) days after the date of its
adoption by the Petaluma City Council.
Section 8 . Posting. The City Clerk is hereby directed to post this ordinance for the .period and in the
manner required by the City Charter.
INTRODUCED and ordered posted/published this _ day February, 2004.
ADOPTED this
day of 2004 by the following vote:
C7
AYES:
NOES';, ...
4 .� ABSENT:
tk
ATTEST:
City Clerk
680577
Mayor
APPROVED AS TO FORM:
City Attorney
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F N�S 0� ACT tiEn T
T - r OR C'- c
/� _ �Gr� OR�IOD OC_ oOlvTITO
L�i� O P;.tii IR,F C0D_ ; 1 99- ��0�, TO R!-
S
CRANWTPS' OR yIOD TC_ I'IO 'S : Pursuant to Section 1 1 7 9 5) 8 o7 the State of California
Health and Safety Code the aovernin c ood-y of the
City of- Petaluma in its ordinance adopting,
and amending the 1997 Edition of the liniior Fire'.Code change
of the State Building Standards Coae as r del o s or modules certamprovisions
`ta-L to the r�Qularion of buildings used for human
habitation. A copy of the text of such chang =s or modifications is attached.
11 Fhy_DT�;GS: Pursuant to Sections 17958.; -g
12
a d = 5`8:. (a) of the State of California
13 Health and Safer Cbde, the go Y e, Ciry of Petaluma has determined and
'IliIl DOQy of'-he ,
1- that all the attached changes or modin °cations ands
ar ne_eded and are reasonably necessary because
15 o "local climatic, geological and tonoo-aphi "c ccnc ions as discussed below. -
10
1 7 LOC_A_L. COly- JI.1ONS: vocal
18 loss �� coed roes a _ gar :ldv - e _ect on the prevention of
or �1) maior
£fires, major _arthQual;e dama ?� and
10 necessar ! — poser—: : or ife and prope�:y loss, m
chanIlPs or mocificatlor m ti e -ors ? -
Fire Code and the Si-,-
e Bu ldin? Standarc_
20 Code fir- oraer to pro�iic a reasoma`eie e
21 City of Petaluma. c - e_ 1 p-o'✓ °rry se, =7, ,, and pre and life sa.=°ty the
22
23 Below are listed adverse local ci --atic eeo ?oL arc topo?rat hic conditions.
2 ' 5 CL a TIC
25
27 Precitiitation. Precipitation ranges from ? p ye ,
28 Approximately nine 'percent 9 1 - �o appro;� nlatel r 25 inches per year.
(� ioi -alts dur�g :he months Of Vo.vernber through Aril, and
?� 10 °ro from Vlay through October. -L 1 -' og� s �t, e _o r
�_ llooding occurred during the months Of
30 January and Nlarch, 1997 and 1998.
Relative Humidity. Humidity generally ranges fr m 50% during daytime 86 at night. It drops to
20% during the Sumner months and occas cnaLiv dro lower during the months of September
through -November. "
36 Temperatures.
37 Temperatures have been recorded as high as 104 degrees Fahrenheit. Average
surnmr hi
eghs are in the 78 -.85' de'm ee ran gt -
38
39 tiV inds. Prevailing winds ,,are from the n.orthwe
40 eve st. However, winds are experienced from virtually
every direction of one time or. another. `ti elocities are generally in the 5_15 mp
42 I h range, gusting to
41 7.430 mph, particularly during the summer months. Extreme wind`s, up to 50 mph, have been
to occur.
43
umm arv. These local climatic condition
arrest the acceleration intensity, and size of fire in the
45 mmunity. Times of little or no rainfall, of low humidity and High temperatures create
I IT ,
� Ord. N `c
pate-1 0 � 3
- v
h azardous conditions, paracularl 2S tLevrelait
to wood. shake a n d s hinglexoof o res
2 and confla2rations, Th winds extz,.Itt
C in this area can have a tremendous i
3 structure fires Mi Proxim�
buildings in close Imp a;.: un 0 n
ItYto one another - W
in ds Can can-V 'sPar',IS' and :'bU.-
4 brands to other structures, thus S'Dr'_adincr then r
t. and .,causing conflagrations. In builciinz_ -- fir-
-S.
5 winds can .li tee Ol for Bt2s back 6 the u ildi n
c InT and create a*blow*torch effect in Addition to
6 preventing "natural'" ventila7abn and cross- vearilarrion efforts,
7
8 GEOL OGIC 'ANM r(-)_P(DGRA.KUC
10 Tile fir t e nv
irournent, of a co is DrilManly a cornbi-ration of l
two factors. the artps
11 - QJ 2 'YsIcai 2eparaphic characteristics and' the '111slonc pattern Of
d evelopment.
factors; l
12 These two ,, alone and combine d. c-.t urban - suburban. d e'
at z a mixtur c-,:' which Ch ullimai-eil",
13 determine the areas DI't needs.
14
15 The basic aeoz. aiDhical boutdan
- s 0 '�'the , C ; IITY i_nlcludt IM to �_-'e o jh d a
in :he c- - 1 3 L ald w am I floor
in:al t- r and Cas- 1 'Pttalurra River h CIS �tht Cit`�' throtC_:"t,
17 c enz a ax t Be e -_ au s e and o f t th north tL - s
of
' 0
18 the fire environment changes irom,on- l oca -� Ojj t
th- mext, Thercifore the c;
19 iry has no'
L
nuraocr.b* t' but a
.L. jr-_ evaronin:emc each o F whi ch ':s in dividual 4 ;7 -, prole. tlon;needs.
has i ind i
20
21 Tht s.-
T area of the CIt; o has a var-J.-t' lo and vtgez
a::ve coy t7. A
22 cOM210ratratiot- 0> bay r)lam'tz,hills and
n Dev- occurre-;
41L the flat 'lands L the cei1=1 and easi-zrm Do Or on
Of ihe Cirv, 1 ove-17 tht year
24 development has mr in the hits and tint smalier valleys and oanvon , s.
25
26z SM-ic Location. i
5!'L.� Ta - -1Y Z 02 Processes that have created the San Francisco
relate YOun-Z L c_
2-17 Bay area are sti
.11 active today. Two acti e Pafth a �
7 faults (San Andreas, and. the Heaidsbur2-
_28 Rodgers Creek) affect the Petalurna area. 4 /0 �, J. ZI land surface i�
pro the ciryls in
29 hj9_b -to- moderate -I rile At2,s s zones,
30
31 Size and Pon The City of Petaluma corers 1,,) squat- mi including an urban POT),ulatibn
32 estimated At 50,000. Within th city axe three fr
33 Fire D e - Dartmen t hancEe , e stations and a total of 533 are personnel. The
s diverse respbnsjbi]ijits i
34 air, rail and M'e emcrsencies. inc
34 land and urban fires, freeway,
38
36 Ton ogra The c#�s service area is a conglom_.tq_ of bay ., p lains ,. hil . Is, vUeyt and ridges,
37 The flatter lafids are found in the central and ea stern portions of the city. Most of the ex
xisun&
38 urban and suburbanized Y
ed-areas are on relatively flatlands (0 - 5% ) Slope.
9
40, Put residential development is .also. proposed for the -hill areas south andwest of the city. The
aj'
41 m aj ority of the hillside a,from 15 i_t these. areas have slopes rangin 30 Correspondingly
42 the ' - - =
ere is much diversi slope percentage�. Sl
Pe 2s an important factor in fire o spread. As a
43 basic rule of thumb
the rate of spread WiLl dcublj-_
as the Slope percentage doubles, all -0ther,
44 factors remaining the same.
45 �'
EXHISMA
Crrd. NCc
•I. ^ .i V �:tl�tl. P 5l l I - ari l C.i7 ^-vi]
ClIPIlate produces ve?��a r sirlL!a- To tC,at
01 mosT of Sonoma Counrv. - r -
4pproxirrlately hal_= of all .the structures it the city have combustible wood- shingle or shake
5 roofs. This very flammable material is susceptible to ignition by embers from a wild lane fire,
o furthering the spread of lire to adjacent buildings.
7 `
8 Sumrrarv. The above local geolocgical and tonogrrabhic conditions enhance the magnitude,
exposure, accessibility problems and fire hazards presented to the City or Petalt=a. ru
. 9
0 followinz ar. earthquake has the potential of causing greater ions. of Life and darnaae than tre
1 i earthquak Itsel .
12
13 The maionty of the City's industral complexes are located in the highest seismic risk zones. T he
14. highest seismic risk zone a1s0 contains the largest concentration of hazardous mate�iaL.
1 Hazardous mater'ialS, oarticular!y toxic .gacec could pose the g'eatcsT t ea; to the lames- nur be-
16 should a si_C7i5canTL Seismic event occur. ' Lt C; s resources Would have to b° prior tr,
17 mitigate the greatest `.hseat. and ma y at' e -� e
-- _ b lr!a �ailab'ie for fir °s s smaller
18
and strucrur es. - -1-
20 Other ambles Taal; :e nd to intensi5i tr;e sittat on:
2
Th,.
7.2 a a T n -
"c. OI CIaT_la t0 L110 tiv3ier SVStem the extent Oi isolat on due to bridge and/or IreeC�a':-
OVe. ass collapse. the extent or ro'adwav g°'andlor aln011Ilt Of C b blocL=2: the r0acnv`.s.
CllrrlatiC cOndltIDI1S (} Ct, dry weather with '�gl', VJi�dS); Time of da= °wil lATtllenCe ttl- apl0l:r1' 0
25 traEic on roadw and could.intensi`�' Ii5li Of llle d n 2 normal OL'S1ne55 11011r5.
26 -
27 Th availabilny of ti:ncly mutual lid o- 2s;istance uozn neiahbori =� deparzneIl.s w'r�ic�l could
28 also have 'emerQencies at the same Urn T. e large portion of dwellings With wood SP1Ilrle r00f
29 coverings could result in conflagrations. "
30
31 CONCLT_SIO Local clitratic, geoioc�lcai and topographic conditions im fire protection
32 efforts, and the aequency, spread, acceleratior i , intensity and size. of fire involving buiidinzs in
33 this community. Further, they Impact pot ential damage to all structures from earthquake and
34 subsequent fire. Therefore it is found, to be reasonably necessary that the uniform Fire Code be
35 chanced or modified to mitigate the effects of the above conditions.
36
37
38 II /I_i98 msonlcelwinword\.ordV7UrCOrd ordI sm 4 /::/0;
XI YT A
Pv 3 c 3 Ord. NCS