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13.
Iowa
§
100C.2.2
and
I.A.C.
Rule
661-277.1(1)a
prohibit
a
person
from
acting
as
either
an
alarm
system
contractor
or
an
alarm
system
installer
without
first
obtaining
an
alarm
system
contractor's
certificate
from
the
Department.
14.
The
term
"maintenance"
is
not
defined
in
either
Iowa
§
100C.1
or
I.A.C.
Rule
661-277.2.
However,
both
the
2007
edition
of
the
National
Fire
Code
(NFPA
72)
§
3.3.150
and
the
2013
edition
of
the
National
Fire
and
Burglar
Alarm
Code
(NFPA
72A)
§
3.3.100
define
"maintenance"
a
"[w]ork,
including,
but
not
limited
to,
repair,
replacement,
and
service,
performed
to
ensure
that
equipment
operates
properly."
15.
TF
is
aware
of
no
other
statutes
or
rules
of
Iowa
relating
to
licensure,
permitting,
or
certification
that
would
be
pertinent
to
the
facts
describe
above,
but
requests
clarification
regarding
any
other
relevant
statutes
or
rules
that
fall
under
the
jurisdiction
of
the
Department
or
State
Fire
Marshal
that
would
require
licensure,
permitting,
or
certification
by
TF
or
anyone
acting
on
its
behalf.
Analysis
16.
TF
contends
that
neither
it
nor
any
of
its
employees
will
be
required
to
be
certified
by
with
or
obtain
certification
from
the
Board.
17.
TF
will
not
install,
alter,
repair,
inspect,
or
replace
any
alarm
systems
in
the
State
of
Iowa.
Moreover,
neither
TF
nor
anyone
acting
on
TF's
behalf
will
perform
any
work
relating
to
the
layout
or
configuration
of
the
Basic
Product
and
any
Accessories,
the
maintenance
of
the
Product,
or
any
other
aspect
of
the
Product's
performance.
BASED
ON
THE
FOREGOING,
TF
requests
that
the
Department
issue
a
declaratory
statement
that
neither
TF
nor
anyone
acting
on
TF's
behalf
will
be
required
to
obtain
certification
or
any
other
license
or
permit
from
the
Department
or
State
Fire
Marshal
in
connection
with
the
business
endeavor
described
herein.
Respectfully
submitted
this
13
th
day
of
June,
2014,
35015581.1
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