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2024 Wildland-Urban Interface Code and local amendments (WUIC) Stakeholder Engagement Summary The following is a summary of stakeholder engagement conducted for review of the 2024 Wildland- Urban Interface Code and local amendments (WUIC). Initial proposed amendments were developed by the Engineering and Plan Review division of the Austin Fire Department Fire Marshal’s Office from 2021 – 2023. A City of Austin internal working group reviewed and further refined proposed amendments during December 2023 – January 2024 including participants from the following: The community stakeholder engagement period was open from May 20, 2024 – June 28, 2024. Austin Fire Department Fire Marshal’s Office, Engineering and Plan Review Fire Marshal’s Office, Inspections Wildfire Division Development Services Department City Arborist Community Tree Preservation Environmental Review Watershed Protection Environmental Policy and Review Community Stakeholder Engagement Engagement Website: Speak Up Austin: https://publicinput.com/2024-technical-codes Webinar Recordings: https://www.austintexas.gov/page/public- meetings#2024MeetingRecordingsampResources Community Engagement Timeline and Summary: May 20, 2024 Public Meeting for I-Codes Zoom Webinar No discussion or questions specific to WUIC Limited discussion May 23, 2024 Home Builders Association (HBA) of Greater Austin PAGE 1 HBA office Limited discussion Following Meeting: Suggestion to reduce requirements for Zone C or allow trade-off of additional structure hardening in lieu of EIZ May 28, 2024 Requested meeting date with HBA and their membership, unable to settle on a date, so additional WUIC specific Zoom webinar offered on June 24, 2024, open to the public. May 30, 2024 Public Meeting for I-Codes City of Austin Planning and Development Center No discussion or questions specific to WUIC June 7, 2024 Revised Draft released Changes addressing recent HOME amendments Public engagement date extended June 24, 2024 Public Meeting for WUIC Zoom Webinar Questions and Answers included in “2024 WUIC Ordinance Public Comment Log” June 26, 2024 Building and Fire Code Board Presentation June 28, 2024 Close of Public Stakeholder Engagement July 11, 2024 Building and Fire Code Board Presentation of changes made in response to stakeholder feedback August 28, 2024 Building and Fire Code Board (SCHEDULED) Presentation of final changes made in response to internal and external stakeholder feedback Request for support Appendices Appendix A – Stakeholder Engagement Communication Summary Appendix B – Public Input Web Platform Statistics Appendix C – Public Comment Log PAGE 2 Appendix A Stakeholder Engagement Communication Summary The Development Services Department hosted the Speak Up Austin webpage and zoom meetings for the 2024 technical codes with a summary below. In addition, the following was distributed by the Austin Fire Department separately: June 14-17, 2024 Austin Fire Department emailed an invitation to participate in the June 24 webinar focused on the 2024 Wildland-Urban Interface Code. The email was sent to 617 target stakeholders and active building permit holders in advance of the June 24, 2024 Building Connections email distributed by the Development Services Department. Development Services Department Summary Second Round: UMC, UPC, IRC, IBC, IPMC, IECC, IFC, and WUIC The second round of engagements for the 2024 Technical Code Changes (UMC, UPC, IRC, IPMC, IECC, IFC, and WUIC) was announced in the April issue of the external e-newsletter, Building Connections. It included promotion of the Public Input webpage and May 20 webinar. The May 30 in-person engagement and the Public Input webpage for the second round of Technical Code Changes engagement was featured in the external newsletter, Building Connections, on May 28, 2024. Each issue of Building Connections was sent to around 5,740 subscribers. On May 14, 2024 an email invitation to participate in the second round of technical code changes engagements including the May 20 webinar and May 30 in-person meeting was sent to 3,156 target stakeholders and active building permit holders (148 specified stakeholders and 3,015 active building permit holders). On June 7, 2024 Austin Water emailed their historic Landscape Transformation stakeholder list (450 emails) as well as all applicants for site plan and building plan permits in 2023 (approx. 4,200 emails). The email notified recipients of Austin Water’s proposed 2024 UPC local amendments for single-family residential development (pressure-reduction devices, irrigation limitation, and laundry to landscape) and pointed them to the 2024 Technical Code Changes Public Input Webpage and comment section. The week of June 24, 2024 Building Connections had an article with updates on the 2024 Technical Code Changes engagements which included a link to the IECC Public Input landing page. The June issue was sent to 5,751 subscribers. That same week an email was sent to 9,618 DSD stakeholders in English and Spanish regarding the comment period for the IBC and IRC, along with updates on other technical codes. The main Technical Code Changes Public Input Webpage was linked; IECC was not referenced. PAGE 3 Appendix B Public Input Web Platform Statistics The Development Services Department hosted the Speak Up Austin webpage and zoom meetings for the 2024 technical codes. The following is a summary from the Public Input website shared by the Development Services Department on August 02, 2024: PAGE 4 2024 WILDLAND-URBAN INTERFACE CODE – Stakeholder Engagement May 20 – June 28, 2024 Question/Comment Sec. 503.2.3 - the heading says FRTW but the text that follows doesn't mention FRTW. This is confusing. You don't actually say if FRTW roofing is allowed or not. Response Wood whether fire-retardant-treated or not shall not be allowed in the Wildland-Urban Interface. The code language is updated to reflect this intent: 503.2.3 Fire-retardant-treated wWood roof coverings. No roof covering in the Wildland-Urban Interface Areas, regardless of the distance from the wildland, shall be allowed to be made from wood shake, wood shingle, or similar combustible material, including fire-retardant-treated wood. Question/Comment Related questions: 1. Sec. 504.3.2 (and the similar paragraphs in 505 & 506) - First, thank you for clarifying the poorly-worded sec(cid:415)ons about soffits, fasciae etc. in the IWUIC! But I s(cid:415)ll find your wording confusing, being one who draws eave details for projects all the (cid:415)me. With regard to fasciae, the term "protected on the exterior" is confusing. Does this mean that I can have a standard 2x6 fascia, for example, but I then need to add some sort of IR trim (like fiber-cement, e.g.) on the outside face of it? Normally, we just skip the 2x and use a 1x Hardie Trim board for the fascia. There are also thicker fiber-cement fascia boards. 2. Sec. 504.3.2 (and similar paragraphs for 505 & 506) - the wording about protec(cid:415)ng the "backside" of a fascia board has always puzzled me. Does this mean that a sub-fascia board of some kind MUST be used? Seems odd that if the fascia board itself is IR then its back face is already IR. And this back face isn't exposed to flame, heat or embers because there is a closed soffit anyway. Response The wording has been updated to reflect that a ¾” solid fiber-cement fascia or ignition- resistant material is acceptable. In addition, all 1-hour rated construction or 2x lumber used as fascia shall have an ignition-resistant exterior material, such as fiber cement, metal, or other. Additional material for the backside is not necessary for option 1, whereas options 2 and 3 may require multiple layers of material. Related sections in 505 and 506 are updated to match. Original proposal: 504.3.2 Fasciae. Fasciae are required and shall be built with solid materials at least ¾ inch thick and protected on the exterior by an ignition-resistant building material. The backside of the fasciae shall be protected by ignition-resistant materials, by materials approved for not less than 1-hour fire-resistance rated construction, or by 2 inch (51 mm) nominal dimension lumber. Updated proposal: PAGE 1 504.3.2 Fasciae. Ignition-resistant fasciae are required and shall be constructed with one of the following: 1. 3/4-inch (19.1 mm) solid igni(cid:415)on-resistant material complying with Sec(cid:415)on 503.2. 2. 1-hour fire-resistance-rated construc(cid:415)on protected on the exterior by an igni(cid:415)on-resistant building material complying with Sec(cid:415)on 503.2. 3. 3. 2-inch (51 mm) nominal dimension lumber protected on the exterior by an igni(cid:415)on- resistant building material complying with Sec(cid:415)on 503.2. Question/Comment Sec. 504.3.3 (and similar paragraphs in 505 & 506) - more confusing wording in my opinion....talking about a gap between a soffit and a roof surface. I understand the intent here, but soffits don't touch roof surfaces. They touch walls and fasciae. Response The wording has been updated to reflect that this section addresses any gaps between eave materials including intersections with the roof assembly, such as between the fasciae and roof deck or surface. Related sections in 505 and 506 are updated to match. 504.3.3 Gaps between materials. Gaps between exterior facing materials within the soffits/eaves or between eave materials and the wall or roof assembly surfaces caused by normal construction techniques or any other unsealed roof opening providing access to the attic space shall be provided with ember protection according to Section 504.10 of this code. Question/Comment Sec. 504.3.4 (and 505.3.4) - Says here that the roof deck must meet ASTM E84 Class A. I assume that this means the 10-minute test and not the extended 30-minute test? Clarification here would be great. Response The intent is the 30-minute test is only required for ignition-resistant building material within Proximity Zone A. A refer to 503.2.4 has been added to clarify the 30-minute ASTM E84 / UL723 / ASTM E2768 test is required with an exception allowing the 10-minute ASTM E 84 test for Proximity Zones B and C. Related section 505.3.4 is updated to match. 504.3.4 Exposed rafter tails. Exposed rafter tails are allowed when built of material classified as heavy timber per the Building Code, provided that the exterior wall be rated for at least one hour and extend from foundation to bottom of roof deck. The roof deck shall be a noncombustible or ASTM E 84 Class A rated material per 503.2.4 and shall extend a distance of not less than 48 inches on both the exterior and interior side of the exterior wall. PAGE 2 Question/Comment Sec. 504.3.5 - Thank you for this clarification on exterior ceilings!! I don't like the IWUIC wording. I take this clarification to mean that such an exterior ceiling only has a roof above it....and not a floor with enclosed space above it? The latter would be an "underfloor area" - - for example, a back patio that is covered by a home's 2nd floor extending out over the patio. Response The exterior ceiling sections apply to ceilings both below a roof and below a floor above. Wording has been updated to better reflect this. Related sections in 505 and 506 are updated to match. 504.3.5 Exterior ceilings. Exterior ceilings below of covered patios roofs, porches, balconies, decks, floors above, and all similar structures shall be built using ignition- resistant building materials that comply with Section 503.2. Rated ceiling assemblies shall have an ignition-resistant building material as the exterior finish. Question/Comment Sec. 504.7.1 - Hooray! Thank you for nixing that 6" opening at the base of the wall, which seemed counterintuitive with regard to keep embers out from under a deck! Response Noted. Question/Comment Sec. 504.6 (and similar in 505/506) - Why no mention of using non-combustible columns and beams such as poured concrete and steel? Response Both concrete and steel would be allowed when 1-hour rated (such as concrete based on thickness) or part of a 1-hour rated assembly. Question/Comment Sec. 506.2.3 - Why are copper sheets allowed on top of combustible decks? Copper conducts heat very well, right? I can't figure this one out...but it doesn't affect my practice much because I don't really have clients wanting copper sheet roofing :-) Response The change to 506.2 is limited to aligning the text with the model code language in sections 504 and 505 and adding exception 4. Exception 3 allowing copper sheets is not amended. This exception is consistent with IBC Section 1505.2 exception 3 for Class A roof assemblies, added in the 2012 edition based on fire test results. PAGE 3 Question/Comment Sec. 603.2.1. - it appears that the EIZ will be required on all WUI projects regardless of Proximity Zone. Are we going to have to show the EIZ on our site plans for permit? Response The Ember Ignition Zone (EIZ) needs to be reflected on both the Site Plan drawing set and the Building Permit construction documents. Question/Comment General Question - Prior to submitting a project for permit, how do we find out if a site is in Proximity Zone B? Currently the online map only shows two zones (light blue/dark blue). Response The WUI map provides approximate locations of the wildland boundary and boundary of each Proximity Zone, due to the complexity of the areas and limitations in mapping programs. The WUI map will continue to show two zone colors. Dark blue for Zone A and B and light blue for Zone C. The WUI map legend will be updated to show this. Distance to the wildland shall be measured from the structure to the actual wildland. Question/Comment – Received at the June 24th public presentation What can we do to turn wildland into not wildland to create a 50' buffer? AFD summary of the June 24th presentation follow-up discussion: (AFD recommends viewing the full presentation recording for the entire discussion) There has to be a way to clear wildland or reduce the burn rating with additional plantings or something to slow down the wildfire. From a land development perspective, where there is an opportunity to invest in fire resistive vegetation or other solutions for an entire neighborhood this could be more cost-effective than updating each home. We need guidance from your team to mitigate the wildland. By enhancing the structure, we are contributing to the housing affordability issue. Response The general approach in COA is to harden the structures using the WUI Code and approved construction methods, rather than clear the wildland. (AFD recommends viewing the full presentation recording for the entire discussion) PAGE 4 Question/Comment – Received at the June 24th public presentation Do the buffer distances change for terrain and/or fuel type? Wooded hills vs. flat pasture land? (AFD recommends viewing the full presentation recording for the entire discussion) Response AFD summary of the June 24th presentation follow-up discussion: (AFD recommends viewing the full presentation recording for the entire discussion. This summary supersedes if discrepancies arise.) Fuel type and terrain changes are incorporated into the Wildfire Risk Map, which was overlaid on the Wildland-Urban Interface (WUI) map. Wildland areas used to determine the Proximity Zones on the WUI map are classified as elevated or high risk. An additional analysis was performed to determine if any 10 acre areas of wildland should be eliminated from consideration, however all wildland areas utilized have an elevated and/or high risk of wildfire. Question/Comment – Received at the June 24th public presentation For the updated code referring to "driveways serving up to max of 3 dwelling units, or provide full width fire lane", will this apply to future platted lots? What about lots that are already platted? Response AFD summary of the June 24th presentation follow-up discussion: (AFD recommends viewing the full presentation recording for the entire discussion. This summary supersedes if discrepancies arise.) This applies to all lots. Flag lots will continue to follow flag lot regulations. The driveway requirements are applied on an individual lot basis only, not for multiple lots sharing a driveway or fire lane. 403.2 Driveways has been updated to clarify this section pertains only to buildings designed to meet the Residential Code. Question/Comment – Received at the June 24th public presentation So in the ember ignition zone, are you expecting us to not put softscape material like shrubs and ground covers in front of our homes? AFD summary of the June 24th presentation follow-up discussion: (AFD recommends viewing the full presentation recording for the entire discussion) Does this include sod? The proposed five-foot EIZ would encroach on front and back yards, negatively impacting aesthetics and livability. Response You can have vegetation in front of the home, it just needs to be at a distance of 5 feet from the structure. This small separation from combustible vegetation reduces the potential for structures to ignite. PAGE 5 AFD summary of the June 24th presentation follow-up discussion: (AFD recommends viewing the full presentation recording for the entire discussion. This summary supersedes if discrepancies arise.) This includes keeping sod out of the 5’ ember ignition zone (EIZ). While vegetation against a home’s foundation is traditionally seen in our area, an appealing landscape may also be achieved while maintaining a noncombustible EIZ. Examples of landscaping with a 5’ noncombustible zone can be found on the CalFire webpage: https://readyforwildfire.org/prepare-for-wildfire/defensible-space/ Question/Comment – Received at the June 24th public presentation "All fences shall be ignition resistant within 10' of structures." --> this eliminates the use of wood privacy fence between homes now. Response This section of code refers to the portion of the fence that connects to the structure and any portion within 10’ of the structure. A wood privacy fence would need to be fire-retardant- treated wood, an ignition-resistant hardwood species, or an ignition-resistant wood-look material. The remainder of the fence further than 10’ from a structure may be any material. Question/Comment – Received at the June 24th public presentation If the EIZ is 5' then why do fences have to be 10'? Response Standard wood fencing materials readily burn and act as a wick tied directly to most structures, as opposed to vegetation which can be sparse and lighter fuels. AFD summary of the June 24th presentation follow-up discussion: (AFD recommends viewing the full presentation recording for the entire discussion. This summary supersedes if discrepancies arise.) Fences are treated similarly to other appendages and structures under 504.7, 505.7, and 506.6 where ignition-resistant materials are required within 10’ of a habitable structure for Proximity Zone C. Although the 10’ distance is increased for non-fence structures within Zones A and B, the requirement for fences will remain as 10’ similar to the 2015 WUIC. Fence wildfire hazard example from the 2022 Balch Springs, TX wildfire: https://youtu.be/DlWKTNDud0g PAGE 6 Question/Comment – Received at the June 24th public presentation Has a cost of housing impact analysis been completed? If so, can you share your findings reflecting the estimated increase for the cost of housing with the new WUI requirements? If it has not been completed, when will a cost of housing impact analysis/statement be available for stakeholders? Response This analysis is currently being conducted and should be completed this week. The findings will be posted on Speak Up Austin under the 2024 WUIC page. Question/Comment – Received at the June 24th public presentation Give an example of new driveway requirements for 3 units on a lot (new HOME initiative) Response AFD summary of the June 24th presentation follow-up discussion: (AFD recommends viewing the full presentation recording for the entire discussion. This summary supersedes if discrepancies arise.) Where you have 3 houses and/or accessory structures with habitable space on a lot, all within 150 feet of the road, no driveway is required. Where you have 3 houses and/or accessory structures with habitable space on a lot and some of those buildings are more than 150 feet from the road one of the following options shall be provided: 1. a fire lane shall be provided 2. A driveway may be provided where an NFPA 13D automa(cid:415)c fire sprinkler system is provided in all buildings with habitable space more than 150 feet from the road 3. The buildings shall be relocated to be within 150 feet from the road 403.2 Driveways has been updated to clarify this section pertains only to buildings designed to meet the Residential Code. Question/Comment – Received at the June 24th public presentation The 5' ember ignition zone may conflict with ecm for vegetation required as well as the requirement from the engineer to mitigate the moisture requirement. AFD summary of the June 24th presentation follow-up discussion: (AFD recommends viewing the full presentation recording for the entire discussion. This summary supersedes if discrepancies arise.) We have multiple requirements including for vegetation and foundation design that need to be considered and integrated effectively on each site. Response The Environmental Criteria Manual requires vegetation to be provided for a certain percentage of the lot where there is more than 1 house, however it does not specify placement against the building foundation. Changes to the ECM are under consideration including, but not limited to, allowing additional aggregate on site within the EIZ. PAGE 7 When dealing with expansive soils, the idea is to maintain a relatively constant level of moisture around your foundation in order to prevent it from becoming too dry or too wet. One method is to introduce moisture near the foundation by placing vegetation that requires constant water use in the absence of rain. In a dry climate, such as ours, it is easier and more water-efficient to maintain a drier moisture content at a natural equilibrium. The 5' noncombustible Ember Ignition Zone (EIZ) can aid in maintaining the natural equilibrium to keep standing water 5' away from the foundation soils, in addition to simple measures like providing gutters and sloping surrounding pavement and soil away from the structure. Question/Comment – Received at the June 24th public presentation When will the proposed/updated WUI map be available? Showing the new Zones (A/B/C) Is that available now? AFD summary of the June 24th presentation follow-up discussion: (AFD recommends viewing the full presentation recording for the entire discussion) With implementation of the 2024 WUIC and map in October, when will the new criteria become effective? Response AFD summary of the June 24th presentation follow-up discussion: (AFD recommends viewing the full presentation recording for the entire discussion. This summary supersedes if discrepancies arise.) The new map will be available with the implementation of the 2024 code. A copy of the map is included in the June 24th presentation document. The map will not be considered final until adopted by City Council. Presentation to the TARP (Technicial Advisory Review Panel) of the criteria manual changes is anticipated in September. The 2024 WUIC amendments are also going forward in September to City Council. The goal is for the criteria manual changes to be implemented at the same time as the 2024 WUIC. Question/Comment – Received at the June 24th public presentation Thanks for this code update. I think this does a good job balancing our whole community's needs in terms of protection from the very real risk of wildfire and grassfires with aesthetic choices by homeowners. Response Comment Noted. PAGE 8 Question/Comment – Received at the June 24th public presentation Is there an appeals board for any of the WUI requirements/interpretations, or opportunities for alternative compliance methods? AFD summary of the June 24th presentation follow-up discussion: (AFD recommends viewing the full presentation recording for the entire discussion.) Can alternative compliance methods be presented for consideration prior to submitting a permit application? Response The most appropriate appeals board would be the Building and Fire Board, but it has not been discussed if they would hear appeals related to the IWUIC. Yes, AFD allows and reviews alternate methods for equivalency. AFD summary of the June 24th presentation follow-up discussion: (AFD recommends viewing the full presentation recording for the entire discussion. This summary supersedes if discrepancies arise.) An alternative method of compliance may be submitted for AFD consideration prior to submitting a development or permit application. A paid preliminary design meeting may be the best option for obtaining a conditional pre-approval. The final Alternative Method of Construction form will not be signed as approved until the application is received and reviewed to ensure no changes have occurred and no new information is presented that would be in conflict. Question/Comment – Received at the June 24th public presentation Related questions received: Q: How often will the WUI proximity areas be re-evaluated as development proceeds? Q: How often will the map be updated? Response AFD summary of the June 24th presentation follow-up discussion: (AFD recommends viewing the full presentation recording for the entire discussion. This summary supersedes if discrepancies arise.) The intent is to update the map annually to reflect new development Further information will be provided within the Fire Protection Criteria Manual. The map will be updated within the Property Profile tool, however it is recommended to use the Wildland-Urban Interface Interactive Map for more information: https://www.austintexas.gov/department/wildland- urban-interface-code PAGE 9 Question/Comment – Received at the June 24th public presentation Have these proposed changes been reviewed by the TARP (Technical Advisory Review Panel)? Response I do not believe TARP reviews technical codes. They will review the Criteria Manual updated rules and interpretations AFD puts forth. This is anticipated to occur at the September TARP meeting. Question/Comment – Received at the June 24th public presentation Will the 5' buffer be exempt from impervious cover calculations by site plan review. Response The 5’ Ember Ignition Zone (EIZ) will not be exempt from impervious cover calculations. Material used within the EIZ may be permeable. Question/Comment – Received at the June 24th public presentation (partial) Related questions received: Q: If a master plan approval was granted with the 2015 WUI regulations do we still have to change to the 2024 code? (Received at the June 24th public presentation) Q: If not too late, am interested in knowing if the new WUI code changes will require a new Volume Builder review for a Volume Builder project that is approved but for which building permits are not yet applied for. Response AFD is coordinating with the Development Services Department (DSD) to maintain consistency within the Volume Builder Program for all upcoming 2024 technical code adoptions. Additional information will be available in mid-July. Question/Comment Would adding an internal fire suppression system, that isn’t otherwise required, preclude residential builders from following any sections of the 2024 WUIC? Response A fire suppression system is not an alternative for structure hardening requirements for the exterior of the building. A residential fire suppression system (NFPA 13D) may be used to mitigate certain deficiencies such as: • • • insufficient fire flow (i.e. water supply at hydrants) hydrants exceeding the minimum required distance from a structure insufficient fire department access PAGE 10 Question/Comment Reduce or eliminate Zone C. The proposed 2024 WUI map covers substantially more area of the city compared to the 2015 map. Since the 2015 map was created, the city has built out further, which should reduce the wildfire risk. From our estimation, roughly 90% of the city is now considered adjacent to wildland. Many of these requirements are expensive or could potentially affect yield in a time where the city should be focused on building more housing more affordably. a. Some builders have proposed crea(cid:415)ng 50’ or 150’ vegeta(cid:415)ve barriers around their project in order to pull units out of Class A and B, which will affect yield. Response The Zone C area has been reduced as shown in WUI Map Option B based on analysis of Wildfire Risk. The City of Austin and Travis County Wildfire Risk map shows that all 10 acre wildland areas are within an elevated or high risk category. Zone C has been altered to be within 0.5 miles of this elevated risk area and includes 1.5 miles within 100 acres of wildland. The fires with the greatest loss in our area were 100 acres of wildland or more. Question/Comment Maintain the current definition of wildland. Changing the definition of wildland substantially changes the WUI map. Reducing the triggering wildland down from 40 acres to 10 acres is too dramatic of a change and will only place additional costly restrictions on construction. Additionally, easements and roads in between structures should be exempted from the definition of wildland. Response The Wildland definition was updated to align with 2015 WUIC interpretation and enforcement. Easements and roadways are considered wildland only if they meet the definition, but will not be considered as a break in wildland continuity with the exception of a 150-foot wide right-of-way. The 2015 WUIC didn't specify a minimum acreage for wildland within the definition. The 40- acre designation was referenced in local amendments in Exhibit A and for Proximity Class A and B eave, wall, glazing, and door code sections. Removing this limit addresses the risk to structures in areas with elevated wildfire risk, as evidenced by recent Texas fires under 40 acres causing significant damage. Including the 2022 Balch Springs fire affecting 26 homes, destroying 9 and the 2023 Parmer Lane fire damaging 14 apartment units and destroying 24 apartment units. For wildland areas less than 100 acres, protection zones are limited to 150' for Proximity Zones A and B, and 0.5 miles for Zone C. This smaller buffer is based on less significant loss occurring in areas less than 100 acres. PAGE 11 Question/Comment Eliminate the Ember Ignition Zones. The 5’ EIZ around the house is impractical, as it prohibits vegetation around the house and limits landscaping options to gravel beds. Pavers and concrete have been proposed, but if you’re building an infill project on a smaller lot (something Council is encouraging builders to do), and you’ve reached your impervious cover allowance, pavers and concrete are not an option. Additionally, the EIZs will result in the removal of nonprotected trees (18” or less). b. At a minimum, exempt Zone C from EIZ requirements. c. Provide addi(cid:415)onal op(cid:415)ons for landscaping, like succulents or other fire resistant vegeta(cid:415)on. Response Based on research from the National Fire Protection Association (NFPA) and Insurance Institute for Business & Home Safety (IBHS), providing a 5 foot noncombustible zone around a structure has the greatest impact in protecting the building from ignition during a wildfire. In addition to protecting against direct flame and radiant heat that are a greater concern in Zones A and B, the zone can protect against wind-blow embers that collect at the base of a wall or structure which is the focus of protections required in Zone C. Vegetation may be provided in front of the house or around it as long as it is 5 feet from the structure. Existing non-protected trees within 5’-0” of a foundation are typically removed during construction. Additional guidance will be provided in the Fire Protection Criteria Manual for existing conditions. Question/Comment Maintain current standards for fence clearances. The proposed standard will add substantial cost to a home in order to maintain privacy between neighbors with a side fence. Iron fences don’t provide privacy and noncombustible cementitious fences are expensive. Both are considered specialty items and there are also concerns about the supply chain keeping up with volume of homes under construction. Response This will be taken under consideration for residential structures within Proximity Zone C. Question/Comment Expand the number of units provided on a single driveway. Limiting the number of units that can be served on a single driveway requires additional curb cuts which are not pedestrian friendly. Additionally, multiple driveways result in more impervious cover and could potentially eliminate units in order to accommodate more driveways on the lot. Response The driveway requirement is applicable to residential properties with up to 3 dwelling units. For properties with more than 3 dwelling units, they will continue to follow Site Plan requirements for a commercial property. Multiple driveway curb cuts will not be required as PAGE 12 the driveway can be upgraded to a Fire Lane where needed as currently required in the Fire Code. 403.2 Driveways has been updated to clarify this section pertains only to buildings designed to meet the Residential Code. Question/Comment Codify current code leniency practices. Codify parts of the code that have not been enforced today. If leniency was granted for practical reasons, perhaps those exceptions should be included in the code. Response The following leniency practices are proposed to be codified: Igni(cid:415)on-resistant (IR) skir(cid:415)ng around the base of decks to allow for non-IR framing Proximity Zones in lieu of analyzing a structure’s Fire Hazard Severity Soffit Vents in Zone C Woven roof valleys in lieu of addi(cid:415)onal cap sheet 10-minute ASTM E 84 allowed for Zones B and C in lieu of 30-minute test Two temporary code leniencies that will end include fences within 5’ of structures and reduced ignition-resistance for covered patios. Fences were granted leniency due to COVD- related supply chain issues in 2021-2022. Patio covers were granted leniency due to conflicting interpretations that led to large orders of incorrect material. Leniency was extended up to the 2024 WUIC adoption as a courtesy and to allow clarifications to be made within the local amendments. Question/Comment Update the map regularly. The initial map was supposed to be updated once every three years but did not receive any updates. Not only should the map be updated, but updates should reduce the amount of land in the WUI zone, reflecting areas that have been developed in the previous three years. Response The current WUI map went into effect January 1, 2021 and a review was conducted within 3 years. Changes deemed necessary are proposed to be brought forth in alignment with the 2024 WUIC and other I-Codes this year. Mapping updates are not limited to reducing the amount of land in the WUI areas, rather they shall be recommended to City Council when necessary to modify boundaries, to un- designate areas, or to add new wildland-urban interface areas per the 2015 WUIC. Going forward the intent is to update the map annually to reflect new development. Further information will be provided within the Fire Protection Criteria Manual. PAGE 13 Question/Comment If more properties are to be included in the WUI zone, ensure that reviews and inspections happen in a timely manner. When the 2015 WUI was implemented, builders and developers quickly experienced delays in reviews and inspections. The proposal substantially increases the amount of land and projects that will be subject to review and inspections. Review and inspection delays are a substantial factor in the overall cost of a home. Response Comment Noted. Should additional staff be required it will be requested to City Council with this code adoption. Question/Comment Maintain current standards for flashing and eaves in Class C. These changes are more restrictive, resulting in higher costs. We are working with our builder members to produce cost estimates. Response Proximity Zones B and C do not have additional flashing requirements. The 2024 IWUIC model code has introduced a new requirement for Proximity Zone A only. Question/Comment The 5 foot ember ignition zone (EIZ) around structures around structures is too restrictive to Austin. Not allowing mulch and vegetation around structures is not sensible for a city that's in zone 2, which is a hot and humid climate. I understand that there's a need to contain fires, but given that the WUI could become something that would affect many more parts of Austin, I think we can't allow this to dictate the look and feel of the landscaping around houses. Response You can have vegetation in front of the home, it just needs to be at a distance of 5 feet from the structure. This small separation from combustible vegetation reduces the potential for structures to ignite. Examples of landscaping with a 5’ noncombustible zone can be found on the CalFire webpage: https://readyforwildfire.org/prepare-for-wildfire/defensible-space/ Question/Comment 1. From my review, these rules appear to prohibit plan(cid:415)ng within 5 feet of homes in 40% of the City of Aus(cid:415)n. Can you clarify that? 2. Certain trees appear protected, but would homeowners be required to rip up their other plan(cid:415)ngs within 5 feet of houses? 3. Do these new rules only apply to newly built single-family housing? 4. Are any kind of plants allowed in this 5-foot space around homes? PAGE 14 5. Finally, have y’all talked to the Watershed Department about the effect on runoff from this proposal? Response 1. New construc(cid:415)on and addi(cid:415)ons located within the Wildland-Urban Interface are required to maintain a 5’ noncombus(cid:415)ble zone free of vegeta(cid:415)on around the perimeter with excep(cid:415)ons listed. 2. This code is not retroac(cid:415)ve and only applies to new construc(cid:415)on and development. Refer to 2024 WUIC 101.5 (amendment). Addi(cid:415)onal guidance will be provided in the Fire Protec(cid:415)on Criteria Manual for exis(cid:415)ng condi(cid:415)ons. 3. These requirements apply to all new construc(cid:415)on and development. They are not limited to single-family housing. 4. No new plan(cid:415)ng is allowed within the EIZ. 5. The noncombus(cid:415)ble material within the EIZ is not required to be impermeable. AFD is coordina(cid:415)ng with the Watershed Department and DSD Environmental Review regarding Environmental Criteria Manual and review process changes where necessary. Question/Comment I worry that the Zone C requirements for rafter tails are unnecessarily strict. As proposed, and with the updated map you've proposed, it would prohibit light wood rafter tails in almost the entire city - even areas that are over a mile from significantly large wildland areas. Many traditional architectural forms built throughout Austin use light wood exposed rafter tails, and prohibiting them adds an undue cost and aesthetic burden with absolutely no real benefit to fire safety. Response Eave protection is increasing for the fascia and soffits in Proximity Zone C. Rafter tails are part of the eave assembly, hence the decision to increase the protection for exposed rafter tails. Heavy timber is viewed as fire-resistant material in the Building Code. The code language will be updated to allow additional ignition-resistant material as an option: 506.4.4 Exposed rafter tails. Exposed rafter tails are allowed when built of ignition-resistant material per 503.2 or material classified as heavy timber per the Building Code. PAGE 15