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SR-416-005 (3) . t(I (p" tJt/~ . B>-A - 1 C/ED:PC:JLA:lwk Council Meeting 7/11/89 TO: Mayor and City Council Santa Monica, California FROM: city staff SUBJECT: Recommendation to Introduce for First Reading Ordinance Requiring Owners of Unreinforced Masonry Buildings to Submit to the City an Engineer's or Architect's Evaluation of those Buildings to the city Concerning their Current Seismic Resistance capability and Associated Recommendations. INTRODUCTION This report transmits staff I s recommendation that the Council introduce for first reading an ordinance requiring owners of unreinforced masonry CORM) buildings to provide an evaluation, prepared by an engineer or architect licensed in the state of California, to the city of their building's current seismic resistance capability. This report also transmits a preliminary discussion on the proposed recommendations for implementation of a Seismic Retrofitting Program for Unreinforced Masonry Buildings, and requests that the City Attorney be directed to prepare an ordinance for subsequent consideration by the Building and Safety Commission and the City Council. In addition, staff recommends an Environmental Impact Report be developed in conjunction with the proposed retrofitting program. This Program is mandated by the State of California's Seismic Safety Commission (approved Senate Bill No. 547) which requires local building departments, by January 1, 1990, to identify potentially hazardous buildings in their jurisdictions and establish a mitigation program under which hazards of URM structures will be - 1 - e-A . . 4 reduced, in interest of public safety. The objective of the ordinance (see Attachment A) requiring an engineer's or architect's evaluation of URMs is to receive reports for sUbmission to the Building and Safety Commission for comprehensive review so that they can make competent recommendations to the Council with respect to a future URM retrofitting program. The engineer's or architect's evaluation shall be submitted to the City within a three month time period from adoption of the ordinance. A notice informing the owners of requirements to have their buildings analyzed and evaluated will be mailed upon adoption. On November 14, 1988, the Building and Safety Commission took public and expert testimony on the technical aspects of Staff's proposed retrofitting program, and met again on December 8, 1988 to discuss the issues. After extensive discussion, the Commission voted to require each unreinforced masonry building owner to obtain an evaluation report from a licensed engineer or architect within nine months of the date of notice [Staff is recommending a three month turnaround time to expedite the evaluation of submittals and to permit the council to take action on this issue prior to the January 1, 1990 deadline imposed by Senate Bill 547 (5.a. 547)J. The report was to include a conclusion by the engineer or architect as to the level of seismic design force the building could withstand. Subsequently however, the City Attorney informed staff that the Commiss ion lacks the authori ty to require such reports. - 2 - . . '" Therefore an ordinance of the City council is necessary to enact this requirement. BACKGROUND In 1986 the state passed Senate Bill 547 (Attachment B), the Unreinforced Masonry (URM) Law, requiring cities and counties to undertake the following steps: 1) inventory certain older potentially hazardous buildings, 2) develop and implement a mitigation program to reduce the hazard, and 3) submit information on potentially hazardous buildings and the hazard mi tigation program adopted by the city to the Seismic Safety Commission by January I, 1990. Building and Safety Departments are the responsible agencies for implementation of the URM law. Santa Monica's Building and Safety Division has already begun to meet some of the law's requirements. It should be noted that the URM law exempts from its provisions (i) any building having five living units or less and (ii) any building whiCh qualifies as a IIhistorical property" under state law. In 1977-78, as directed by City Council, Building and Safety staff performed a complete inventory (Attachment C), of some 250 pre-1933 masonry and concrete buildings in the city. This inventory meets the first step requirement of Senate Bill 547. In June 1978, a "NOTICE OF SUBSTANDARD AND POTENTIALLY HAZARDOUS BUILDING" was recorded on the title records of those properties found not in compliance with minimum 1933 State Seismic Design Standards. - 3 - " . . The new law defines a "potentially hazardous building" as any building with URM walls built prior to the adoption of a local building code requiring earthquake-resistant design. The City Attorney has advised City staff that, by state law, the Santa Monica Building Code began requiring earthquake-resistant design in 1934. Although the Santa Monica Building Code of 1915 and 1921 mentioned reinforcement requirements, such requirements referred to fire and wind factors and not to ground motion. Seismic analysis was not performed prior to 1933 and thus was not incorporated into Santa Monica Building Codes until after the state enacted the Riley Act after the Long Beach earthquake of 1933. The Riley Act was subsequently amended in 1939 to increase seismic design requirements by 50% and was later superseded by the mandatory provisions of seismic design in the Uniform Building Code which went into effect in 1961. The Riley Act set forth the first state-wide set of seismic design standards. It required that all buildings built after its passage be able to withstand horizontal design forces from any direction of not less than 2% of the building's weight, including the weight of its occupants and contents (or, as stated in the Riley Act, "2' of the total vertical design load" of the building). It must be noted that this total vertical design load percentage should not be confused with peak acceleration readings from accelerographs, which measure energy transmitted from an actual earthquake event to the site of the accelerograph. - 4 - . . I. The second step in the URM law requires that the City adopt and monitor a mitigation program for those buildings found to be seismically deficient. The URM law mandated that the state Seismic Safety commission prepare an advisory report for local governments to use as a guide which contains criteria and procedures for meeting the URM law. (See "Guidebooklt as Attachment D.) Several requirements and options are described in the state's Guidebook that may be part of a mitigation program to obtain the goal of safer structures, including: A. Adopting an ordinance to implement the requirements of the URM law. B. Requiring that owners provide a detailed structural evaluation by a licensed engineer for filing with the city. c. Requiring strengthening of structures according to a compliance schedule. D. Requiring strengthening at the time of major remodeling. E. Requiring strengthening at the time of change in use. F. Requiring that notices describing the hazard be posted on buildings. G. Requiring that tenants and lessees be notified of the seismically hazardous condition of the building. H. Requiring owners to reduce occupancy and any hazard to the public. I. Requiring owners to demolish where appropriate. J. Requiring that notices be recorded against the title to the buildings informing future buyers that the building 1s considered potentially hazardous. - 5 - t. . . K. Providing incentives to encourage owners to comply with the program in a timely manner and providing for enforcement of the mitigation program against owners who do not comply in a timely manner. staff anticipates recommending a mitigation program to be adopted by the City which will include the following program obj ecti ves: to reduce the inventory of seismically deficient structures, to reduce the danger to human life, to reduce the danger of loss of housing and increased homelessness as a result of damage to URM structures, to reduce potential property damage, to prevent the loss of the historic and architectural character of the community, to reduce the costs to the City and property owners in the event of a maj or earthquake, and to reduce the demand on city emergency services providers in the event of a major earthquake. To achieve these objectives, staff anticipates proposing that the City adopt an ordinance based upon the "Model state Ordinance" (Attachment E), as the City's required mitigation program. The model ordinance is patterned on the Los Angeles ci ty ordinance, adopted in 1980, and requires retrofitting of only unreinforced masonry bearinq wall buildings, the type of URM building identified by the state as being the most dangerous type of URM building. (In a URH bearinq wall building, the walls support or "bear" the weight of the roof and floors). However, the state Seismic Safety Commission has also identified two other types of URM potentially hazardous buildings, and has stated that it will eventually require cities - 6 - . . to retrofit these types of URM buildings as well. The two other types of URM buildings are: (i) steel frame buildings with walls or partitions of unreinforced masonry (the steel frame supports the weight of the roof and the floors); (ii) non-ductile concrete frame buildings with walls or partitions of unrein forced masonry (the concrete frame supports the weight of roof and floors). The ordinance, as it will be proposed by staff, requires retrofitting of URM bearing wall buildings since the URM law only requires a mitigation program for that type of URM building at this time. Adoption of the ordinance will enable Santa Monica to require owners to bring their seismically deficient URM bearing wall structures into conformance with minimum earthquake safety standards. The safety standards will be set forth as a part of the ordinance. Staff is recommending an Environmental Impact Report (EIR) to be written on the proposed mitigation program to discover if there will be any significant impacts to the environment. Potential impacts analyzed will include program a1 ternatives such as not implementing a retrofitting program; implementing modified programs and other alternatives appropriate to the issues. - 7 - . . DISCUSSION November 14, 1988 Building and Safety Commission Review prior to presenting this report and the anticipated mitigation program report to Council, the City Building and Safety Commission was asked to review the technical aspects of the draft mitigation program staff report and to take testimony at a public hearing from seismic experts, the public and owners of unreinforced structures, and to prepare recommendations for staff and council considerations. The first hearing held by the Commission took place November 14, 1988 and lasted four hours. The testimony from the seismic experts, representatives of organizations and the public are briefly described below, a more detailed report of the testimony can be reviewed as Attachment F (this hearing was video-taped should the Council wish to review the proceedings). List of Speakers in order of appearance: James E. Slasson, Ph.D., State Registered Geologist, Engineering Geologist and Geophysicist, former state Geologist, former member of state Seismic Safety Commission, and past member of Los Angeles Hazardous Buildings Commission. Thomas Heaton, Chief Seismologist, u.S. Geological Survey Robert Kovach, state Registered Geophysicist, Consultant to the Santa Monica Chamber of Commerce. Fredrick Turner, State Registered Structural Engineer, State seismic Safety Commission. - 8 - .. . . Robert Nason, Ph.D. in Earth Sciences, Consultant to the Santa Monica Chamber of Commerce. Karl Deppe, Senior Structural Engineer, Assistant Chief, Earthquake Division, Los Angeles Building and Safety Department, State Registered structural and civil engineer, Member, hazardous Buildings Committee of the Structural Engineers Association of Southern California. william Reqensberqer, Ph.D., Southern California Earthquake Preparedness Project, Governor's Office of Emergency Services. Ed Villaneuva, Chamber of Commerce. Karl Shober, commercial Investment Property Association wilbank Rush, Seismic Association Members of the Public The experts' most compelling message was the likelihood and magni tude of an earthquake this area can expect. Both James Slosson and Tom Heaton noted that the Newport-Inglewood fault is more likely to effect Santa Monica than the San Andreas Fault, and is likely to produce a 6 . 5 to 7.5 magni tude earthquake. They noted the Malibu-Santa Monica fault is capable of producing significant damage to Santa Monica much like the Whittier Narrows fault produced in Whittier. Both scientists discussed ground acceleration and the fact that such measurements of energy released are not an accurate parameter upon which to base a prediction as to a building's ability to withstand ground motion. Slosson noted that ground accelerations experienced at the epicenter of an earthquake remain fairly constant for a distance of 10 kilometers then drop - 9 - ... . . off sharply as they get farther from the epicenter (see the Ground Acceleration Chart as Attachment G). Slosson pointed out that Santa Monica will experience ground accelerations of 40% of gravity when the northern sector of the Newport-Inglewood fault ruptures. Heaton thought the range would be in excess of 33% of gravity and probably it will be closer to 66% of gravity. Robert Kovach discussed his belief that Santa Monica is not at risk from the San Andreas or the Malibu-Santa Monica faults but is from the Newport-Inglewood. He also noted that he disagrees with the State of California Division of Mines and Geology that the Newport-Inglewood is capable of a 7 magnitude earthquake but believes it could produce only a 6 "plus" magnitude. He stated Santa Monica has experienced ground accelerations of 5-13% of gravity and that because Santa Monica buildings have withstood those ground accelerations they are likely to withstand any ground accelerations in the future. He concluded that there is no need for a retrofitting program. Fredrick Turner, explained the state Seismic Safety Commission's goals and objectives as they relate to the URM law and reminded those at the hearing that there is a 60% chance of a maj or earthquake in Southern California within 30 years. Robert Nasson wanted the Commission to move their focus from URM structures which he believes are safe in an earthquake to concrete construction because he bel ieves they have not been sufficiently evaluated. - 10 - . . Karl Deppe spoke to the Commission on the experience of the City of Los Angeles with respect to their seismic retrofitting program and noted a significant difference in retrofitted buildings' behavior during the Whittier quake and those not yet retrofitted, as the retrofitted structures withstood the quake significantly better. Deppe said that "government anchors" alone [Staff notes that government anchors are a type of reinforcement used to anchor walls of a structure to its roof, so the walls do not fall away from the roof as a result of wind pressure on a structure or as a result of fire] were not found to be effective in the Coalinga earthquake in 1983. William Regensberger, told the co~~ission that the State's job to design a disaster plan has uncovered the threat that URMs are "potential deathtraps," and that earthquake injury studies reveal most injuries are caused by falling building elements. The falling and fallen rubble from URMs adds significantly to slow rescue and medical, police, and fire service delivery. Public Testimony Ed Villaneuva represented the Chamber of Commerce opinion and claimed that there is no new evidence that URMs are unsafe since Council adopted Ordinance 1201 in 1981. The Chamber is concerned that retrofitting would put a financial burden on business and displace the elderly. Karl Shober, Commercial Investment representative, requested that no tests or evaluations on URMs be conducted based upon their having withstood previous earthquakes. - 11 - . . Wilbank Rush noted that Santa Monica buildings should be evaluated on its past survival experience and thus no further action is necessary with respect to retrofitting as no building has been damaged in past quakes. Twelve members of the public testified and expressed their concern on a number of issues from the expense of retrofitting, zoning requirements, rent control issues [for a sl1mTllary of Rent Control's position see page 15, last paragraph], and concern for the cultural and historical value of buildings. Adjournment of November 14 Public Hearing After testimony was taken at the Building and Safety Commission hearing (November 14, 1988) the commission closed the public hearing and adjourned until December 8, 1988 when they would discuss the issues. December 8, 1988 Public Hearing At the December meeting the Commissioners discussed a nl~!Ilher of issues and felt strongly that they could not make a competent recommendation to the Council without more detailed survey information of the URMs. The Commission felt that a detailed structural analysis and evaluation of each URM performed by an architect or civil engineer would provide them with the level of information necessary for them to proceed. After two hours of deliberation, the Commission voted to require each URM owner to obtain an evaluation report from a licensed engineer or architect within - 12 - . . nine months of date of notice which would include a conclusion as to the level of seismic design force that the building can withstand in its present condition. Subsequently the City Attorney informed staff that the Commission lacks the authority to require such reports and that an ordinance of the City Council is necessary to enact this requirement. staff Discussion Staff is concerned that the nine months the Building commission required for evaluation may unduly delay the development of a mitigation program and may not make it possible for the Council to meet the January 1, 1990 deadline imposed by the URM law. Although substantial testimony was given by business owners and their representatives in opposition to the seismic retrofitting of buildings, with particUlar concern expressed for potential business disruption, staff believes that it is essential to provide this measure of safety to the community. Since the Building Commission hearings, staff has been made aware of heightened public concern regarding seismic safety as a result of recent earthquakes, such as those in the eastern United states, Soviet Armenia and soviet TadZhikistan, and most recently the series of earthquakes experienced in Santa Monica Bay along the Mal ibu-Santa Monica Fault. Other cities, including Los Angeles and Palo Al to, have adopted programs to retrofit their seismically unsafe structures. In addition, since the adoption of Ordinance 1201, the California Division of Mines and Geology has recently reclassified the Malibu-Santa Monica fault status from "inactive" - 13 - . . to "active". Furthermore, the Whittier Narrows fault is now thought to possibly extend through Los Angeles and closer to the Santa Monica bay area. Also, a segment of the Newport-Inglewood fault (known as the Wilmington spur) has now been found to possibly extend beneath Santa Monica. In addition, a fault known as the Elysian Fault, (source of the June 12, 1989 earthquake) has also been found to possibly extend into the Santa Monica bay area. (See map listed as Attachment H). Santa Monica's proximity to several significant fault zones should be most directly evident from its location in "Los Angeles Basin" at the base of the "Transverse Mountains": two distinct geomorphic provinces. In light of these developments, staff believes that the public health and safety require at a minimum the adoption of the model ordinance, so that a seismic mitigation program may be commenced as soon as possible. In order to move toward developing a mitigation program it is imperative that the URMs are analyzed by an engineer or architect so that the Building and Safety Commission can evaluate the kind of retrofitting program this city may need. Finally, the Building and Safety Commission and the public requested further information from City staff on the following issues. Concern was expressed about what retrofitting may do with respect to zoning issues. In answer to that concern, the Planning Director has advised staff that provided there is no increase in square footage or change in use as a consequence of a structure's retrofitting there should be no zoning problems. - 14 - . e The Building Officer was asked at the December 8 meeting if other cities had codes similar to Santa Monica's 1915 and 1921 codes. He later responded that many cities such as Los Angeles and Long Beach had reinforcement language in their earlier building codes but, like Santa Monica's earlier codes, such requirements pertained to fire and wind stability and not to seismic design. The Rent Control Administrator has advised staff that the URM law neither supersedes nor is in conflict with the Rent Control Ordinance, and the City Attorney concurs in that opinion. According to Building Department records, a total of 15 URM buildings (350 controlled rental units) are now subject to rent control, for a total of 265,000 square feet. Of these 15 buildings: (i) 4 are residential-use-only buildings (215 CRUS) and, (ii) 11 mixed-used buildings (165 CRUS). Actual cost records on file in the Building Department, based on retrofitted City structures, show the cost to renovate residential-use-only buildings has been less than $1.00 per square foot. The cost to renovate mixed-use (commercial and residential) buildings has been from less than $1. 00 per square foot to $3.00 per square foot. In addition, actual experience with rehabilitation of mixed-use structures has indicated that the majority of the cost of retrofitting such structures is attributable to the commercial space. To date, no tenant relocations or displacements have been required to make seismic renovations of residential-use-only - 15 - . . buildings. Only one of the mixed-use buildings renovated so far has required the temporary vacation of the rental units to make the renovations. That building was the Criterion Apartments and the owner put the tenants up at a local hotel for the few days required to make the renovations. So far, no owner of any of the renovated building has requested a rent increase. The Rent Control Administrator has advised that because of the small number of buildings (15) subject to rent control that will be affected by the ordinance and because of the minimal costs involved, any requests by owners for rent increases would be handled by the Rent Control Board on a case by case basis. OWners could petition for rent increases based on the actual costs incurred in the retrofitting. Despite claims to the contrary, actual experience indicates that retrOfitting costs for residential and mixed-use structures are not substantial and do not result in displacement of tenants. The Police Chief has advised staff of his concern that the occurrence of a major earthquake along any of the faults in Southern California would be likely to remove the police from their normal crime fighting role and involve them heavily in emergency response activities. In addition, the Police Chief is concerned that the occurrence of such a natural disaster could create an increased demand for crime fighting services as a result of the confusion and the increased opportunity for looting of businesses and homes. - 16 - . . The Police Chief reminded staff that the Police Department has at least six primary responsibilities in the event of a major disaster: (i) evacuation, (ii) security of the community as a whole, and particularly of damaged and evacuated areas, (iii) handling of the deceased, (iv) traffic control, (v) animal control, and (vi) law enforcement. However, the Police Chief stated that the Police Department, depending on the time of day, may have as few as six or as many as 13 uniformed officers on duty, not counting division commanders, supervisors, detectives and plain-clothes officers. Therefore, any steps the community can take to reduce the demand on the police during such a natural disaster will be extremely helpful. Of course, off-duty police officers as well as off-duty firefighters will be recalled to service, but will probably experience difficulties in returning to the City. By requiring the reinforcement of potentially hazardous structures, the demand on police response will be lessened. Police officers will then be able to turn their attention to other areas of the City needing assistance and protection. The Fire Chief has advised staff of his opinion that the occurrence of a magnitude 6 earthquake or greater along any of the major faults in Southern California will be likely to cause the partial or total collapse of unreinforced masonry structures in Santa Monica. He further believes that if such collapsed structures are in a commercial area, then fire and rescue personnel will have great difficulty in moving emergency - 17 - . . apparatus from certain parts of the city to other parts of the City. The Fire Chief reminded staff that the Fire Department has three responsibilities in the event of a major disaster: (i) fire extinguishing, (ii) light rescue and heavy rescue services (heavy rescue to be performed in conjunction with General Services personnel operating heavy equipment) , and (iii) coordination of emergency medical response. However, the Fire Chief stated that it is important for the community to be aware that the Fire Department only has approximately thirty personnel on duty at any time. In the event of a City-wide natural disaster, thirty people can accomplish only so much. Assistance from other communities through the California state Master Mutual Aid system is not likely to be available because a magnitude 6 earthquake will keep them busy in their own jurisdictions. Therefore, any steps the community can take to reduce the demand on fire department resources during such a natural disaster will be extremely helpful. Of course, off-duty firefighters will be recalled to service, but in the event of a major disaster those firefighters will have difficulty or may even find it impossible to reach the city. In the event that the Fire Department is confronted with more demands on its services than it can perform, the Department must respond to them in the following priority: 1. First, to save lives where they can; - 18 - . . 2. Second, to save the community as a whole from a major conflagration fire; 3. Third, to save private property. By requiring the reinforcement of potentially hazardous structures, firefighters will not have to focus their efforts on freeing people trapped in collapsed structures. Instead, more firefighters will be available to fight a major conflagration fire, if one develops. If such a fire does not develop, then more firefighters will be available to save private and commercial structures. As a result, more firefighters will be available to assist the community as a whole, rather than focusing their efforts on saving people who may be trapped in collapsed URM buildings. Objectives of the Proposed Mitigation Ordinance It is anticipated that the ordinance will assist the Building and Safety Division and the public in performing the seismic rehabilitation requirements of the state URM law. Currently, the local Municipal Code requires rehabilitation at the time a structurels occupancy classification changes pursuant section 502 of the Building Code. Another mechanism that has brought structures into compliance is that when a building is to be sold, the buyer discovers the IINotice of Substandard and potentially Hazardous Conditions" filed with the site records. Both these methods of requiring compliance to seismic safety standards are passive and are not likely to make the City a safer community in the near future. The adoption of an ordinance that - 19 - . . ~ includes the minimum seismic standards and a mitigation program would provide the City with an active approach to making buildings safer and will bring the city into full compliance with the URM law. The mitigation ordinance would allow the City to direct owners of URM bearing wall buildings, one of the three types of buildings found to be potentially hazardous by the state Seismic Safety Commission, to demonstrate that their buildings meet minimum seismic design standards and direct those owners whose structures fail to meet such minimum seismic design standards to bring their buildings into conformance with the Building Code. There is currently no mechanism in this City that gives the Building and Safety Division the authority to require that unreinforced masonry buildings be made safe. Although the proposed mitigation program may constitute a financial burden and responsibility on building owners, staff and the City Attorney continue to hold that a retrofitting program based upon the model ordinance is warranted to protect the health, safety and welfare of all the residents of Santa Monica. By basing the ordinance to have URMs evaluated and the proposed mitigation program and its ordinance on the state URM law and on the model state ordinance, the City of santa Monica can move ahead to reduce the risk of loss of life, loss of housing and increased homelessness, loss of the historic and architectural character of the city and of severe property damage - 20 - ~ . . and will reduce the demand for emergency response staff resources in the event of a major earthquake. Conclusion The evaluation of unreinforced masonry structures will significantly enhance the Building and Safety Commission's ability to make determinations and recommendations with respect to mitigation programs whose primary goal would be the retrofitting of URM's. The evaluations will also complete one of the requirements of the URN law and in turn assist the City in meeting the state reporting deadline of the City's URM inventory and mitigation program set for January 1990. BUDGET/FINANCIAL IMPACT As proposed this ordinance will not have any budgetary or financial impact on the City. There will be financial impact on URM building owners for the analysis by an engineer or an architect. Estimated cost to building owners for evaluation reports is between $1,500 and $4,000 per building, or about $.28 per square foot. RECOMMENDATION In order to implement a comprehensive program to bring seismically deficient structures into current Building Code conformance and into compliance with state law, city staff and the city Attorney respectfully recommend the City Council: 1. Introduce for first reading the attached ordinance requiring property owners of each URM to submit to the - 21 - . . Building Officer an evaluation report by a California licensed engineer or architect to include a professional conclusion on the level of seismic design force each URM building can meet in its present condition. 2. Direct the City Attorney to prepare a draft ordinance for a seismic safety mitigation program along the lines proposed in this report. 3. Direct the Building and Safety Commission to review the building reports once received by the city and to review the draft seismic safety mitigation ordinance and prepare a recommendation to the City Council regarding the advisability of its adoption. 4. Direct the City Manager to enter into a contract with a consultant for the development of an EIR on the proposed seismic safety mitigation program. Prepared by: Peggy Curran, Director, Community and Economic Development Joan Akins, Assistant to the Director, Community and Economic Development Bill Rome, Building Officer Paul Berlant, Planning Director Desi Alvarez, City Engineer Thomas Tolman, Fire Chief James F. Keane, Chief of Police Maryann Yurkonis, Rent Control Administrator Linda A. Mills-Coyne, Deputy City Attorney - 22 - : . . Attachments: A: Ordinance Requiring URMS to be Evaluated B: state URM Law (SB547) c: List of URM Buildings surveyed to Date D: Seismic Safety commission Guidebook and Appendix E: Model state Ordinance F: Expert testimony G: Ground Acceleration Chart H. Map of California Showing Approximate Location of Faults (seismic3) - 23 -