State Farm STATE FARM CLAIMS PO BOX 52260 PHOENIX, AZ 85072-2260

May 23,2014

KERRI F OLIVIER 2125 WICKES RD COLORADO SPRGS, CO 80919-4842

RE: Claim Number: Date of Loss: Type of Policy: Policy Number:

06-08Z4-966 June 26,2012 Homeowners 86-03-6949-4

Dear Ms. Olivier:

Thank you for submitting your claim for your windows on the north side of your home and garage door.

State Farm® had engineer John Peterson MS, PE from Knott Laboratory inspect these items. He conducted his inspection on May 15, 2014, and has provided a report of the findings.

The windows located on the north side of the home were not damaged as a result of the fire. The swelling observed in the garage door panels is consistent with repeated moisture exposure and is not related to fire.

Based on this information provided from Mr. Peterson's inspection and report, there is no ADPL damage to the windows, and the garage door is wear and tear which was address in a letter dated May 6,2014.

Based on the Homeowners Policy FP-7955, it reads as follows:

SECTION I - LOSSES INSURED

COVERAGE A-DWELLING

We insure for accidental direct physical loss to the property described in Coverage A, except as provided in SECTION 1-LOSSES NOT INSURED.

SECTION I - LOSSES NOT INSURED

1. We do not insure for any loss to the property described in Coverage A which consists of, or is directly and immediately caused by, one or more of the perils listed in items a. through n. below, regardless of whether the loss

occurs suddenly or gradually, involves isolated or widespread damage, arises from natural or external forces, or occurs as a result of any combination of these:

g. wear, tear, marring, scratching, deterioration, inherent vice, latent defect or mechanical breakdown;

However, we do insure for any resulting loss from items a. through m. unless the resulting loss is itself a Loss Not Insured by this Section.

Although we are unable to provide coverage for the windows or garage door because of the policy language, we are happy to consider any additional information you would like to provide.

We are still in the process of reviewing and gathering information on the documents you provided from National Smoke and Armstrong lab and will be in contact with you once this is completed.

Thank you for working with me we are happy to consider any additional information you would like to provide. I am looking forward to working with you to bring your claim to conclusion. You may reach me at 970-395-4588.

Sincerely,

a ice Carson I im Representative

9703954588 State Farm Fire and Casualty Company

Enclosure: Knott Laboratory Report

LABORATORY, UC: Forensic: Engineering & Animotion

CARSON.14104-0514 May 23,2014

VIA EMAIL

Janice Carson State Farm Insurance P.O. Box 52260 Phoenix, AZ 85072-2260

Re: Insured: Claim Number: Subject Address:

Dear Mr. Carson:

Kerri Olivier 06-08Z4966 2125 Wickes Road Colorado Springs, CO 80919

At your request, Knott Laboratory, LLC inspected the property noted above for reported damage to the windows and garage door as related to the Waldo Canyon wildfire that occurred during the summer of 2012. This report contains the findings and conclusions reached as a result of that investigation. Persons present at the time of Knott Laboratory's site visit included Mr. John Peterson, MS PE (Knott Laboratory) and Ms. Kerri Olivier (homeowner/insured).

Executive Summary: Knott Laboratory, LLC inspected the property noted above for reported damage to the windows and garage door due to the Waldo Canyon wildfire. Knott Laboratory concluded the windows and garage door were not damaged by the wildfire.

Background: The subject structure is a two-story, wood-framed residence with a single-story attached two car garage. The front of the structure faces north and a photograph of this north face is presented in Figure 1. Records obtained from the EI Paso County Assessor's Office indicate the structure was constructed in 1989 making the age of the home approximately 25 years. The windows throughout the home were reportedly replaced approximately four years prior to the Waldo Canyon fire with Jeld-Wen vinyl windows.

The residence is located near an area of Colorado Springs, Colorado known to have been exposed the Waldo Canyon wildfire that occurred between approximately June 23 and July 10, 2012. Various items were reportedly indicated by State Farm Insurance as requiring replacement due to the fire including the windows located on the south wall of

7185 South Tucson Way· Centennial, CO 80112·3987· p 303.925.1900· f 303.925.1901 www.knottlob.com

Janice Carson CARSON.14104-0514 May 23, 2014 Page 2 of 14

the structure. More recently, Ms. Olivier (homeowner) reported washing the northern windows with a power sprayer and subsequently observed water had intruded at some of the north facing windows, specifically at the vertical interface between the operable and inoperable portions of the window. Ms. Olivier attributed this to damage from the fire.

Ms. Olivier also reportedly expressed concern to State Farm Insurance that the garage door on the north face of the structure was damaged as a result of the fire, more specifically, the power-washing performed by a contractor subsequent to the Waldo Canyon wildfire. Thus, Ms. Olivier contacted State Farm Insurance with her concerns.

Purpose: Per the letter dated May 14, 2014 as provided by State Farm Insurance, the purpose of Knott Laboratory's investigation was to determine and provide our professional opinion relating to the following questions:

1. Are the five windows on the north side of the home damaged? 2. What kind of damage are the windows displaying? 3. What caused the damage to the windows? 4. The insured indicated the windows are leaking is this related to damage from

Waldo wildfire? 5. What is the damage to the garage door and would it be related to fire or smoke

from the Waldo wildfire? 6. What is the repair method for the windows or garage door? 7. Please review any documentation or photos the insured would like for you to

review.

Procedure: Knott Laboratory inspected the structure on May 15, 2014. Available evidence was documented and photographed during the inspection. Knott Laboratory also reviewed photographs of the windows with water intrusion that were taken by and provided by Ms. Olivier.

Findings and Discussion: For clarity, Knott Laboratory has divided this portion of the report into the following sections: Site Investigation, Window Investigation, and Garage Investigation.

Site Investigation The presence of a wildfire in the proximity of a structure does not immediately indicate the structure or its finishes were damaged by the nearby fire. An assessment of the structure is necessary as temperatures from wildfires can vary greatly, but as with all fires, the amount of energy (or heat) given off is highly dependent on the amount and types of fuel present (vegetation, wood, plastiCS, gasoline, etc.) as well as atmospheric convection patterns, topography and distance among other factors. The presence of a nearby wildfire does not necessarily indicate the ambient temperature surrounding a

Janice Carson CARSON.14104-0514 May 23,2014 Page 3 of 14

structure was raised to damaging levels as the heat generated by the 'fire rises naturally due to convection, and damage typically occurs due to radiant heat rather than an overall increase in surrounding ambient temperatures. Radiant heat (outwards) from a fire dissipates into the atmosphere and the intensity of that heat is reduced greatly with increasing distance from the heat source. Similar to a camp fire, the surface of an item facing the fire can feel the effects of the radiant heat while the opposite face does not feel the effects of the radiant heat.

Typical residential structures are constructed of a select set of materials. Many of these materials, such as vinyl and plastic, have a known temperature ranges wherein they will melt or burn and provide the best indicator of actual temperatures to which a structure was exposed. Thus, through inspecting the condition of these materials on the structure, Knott Laboratory can determine, to a reasonable degree of certainty, the temperatures to which the structure was exposed. It should be noted that duration of heat exposure is also a key component in the transfer of heat causing damage, that is, lower temperatures required significantly longer durations of exposure to generate damage whereas higher temperatures require less exposure time.

Based on aerial mapping of the fire conducted by the United States Department of Agriculture Forest Service (USDAFS)1 and the structure's location (Figure 2), Knott Laboratory determined the subject structure is approximately 400 feet from the nearest mapped burn reach of the Waldo Canyon fire which is indicated to the west along Moorfield Avenue. Radiant heat will not typically extend this distance. Ms. Olivier reported the neighbor directly north of the subject residence (across Wickes Road) had the roof catch fire, which was extinguished prior to burning the structure. The nearby structures all remained intact and did not burn down. Thus, the greatest exposure to damaging heat from the fire was from the west, but it is likely minimal due to the distances involved.

Knott Laboratory performed an on-site investigation of the surroundings for evidence of direct fire damage (burn/char) and/or heat damage to flora. Based on studies performed by the United States Department of Agriculture (USDA) and others, most plant tissue begins to die if heated to temperatures between 1220 to 131 0 Fahrenheit2. The extent of damage is also time-temperature dependent wherein mortality of flora can occur at higher temperatures after a short period, while death at lower temperatures requires a longer exposure. Thus the flora on a property is typically a good starting indicator as to the temperatures in which the structure may have been exposed to.

1 USDA Forest Service Fire Data. http://activefiremaps.fsJed.us/googleearth.php 2 Brown, James K.; Smith, Jane Kapler, eds. 2000. Wildland fire in ecosystems: effects ottire on fiora. Gen. Tech. Rep. RMRS-GTR-42-vol. 2. Ogden, UT: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. 257 p.

Janice Carson CARSON.14104-0514 May 23, 2014 Page 4 of 14

As the fire occurred nearly two years ago, the on-site flora has undergone almost two full growth cycles since the fire; however, the immediate surrounding flora (specifically the coniferous trees which do not lose their needles during the winter) did not show evidence of heat damage, particularly on the north side of the property (Figures 3 and 4). Additionally, Ms. Olivier opined that she was surprised to come back to her home shortly after the evacuation was lifted to find her outside flowers remained undamaged. Thus, Knott Laboratory concluded the fire did not generate elevated temperatures capable of damaging the nearby trees (122 0 to 131 0 Fahrenheit).

In addition to the nearby flora, Knott Laboratory also inspected the subject property for heat or fire damage to items that are susceptible to damage from elevated temperatures, specifically plastics. As noted above, plastiCS are a good indicator of temperature exposure due to their low melting point, which are typically between 170 to 320 degrees Fahrenheit, a temperature range less than that typically required to damage most construction materials. Knott Laboratory noted various plastic items surrounding the structure that indicated no evidence of damaging elevated temperatures.

As noted above, the amount of energy (heat) given off by a wildfire is highly contingent on the amount of fuel or combustible material in the fire. Based on the evidence presented above, the extended distance to the nearest fire location coupled with the lack of evident heat damage to the susceptible items (flora, plastics, etc.), Knott Laboratory further determined that the structure was not exposed to widespread, damaging elevated ambient temperatures (conduction heat sources) from the wildfire nor was it exposed to elevated radiant temperatures from a nearby heat source.

Window Investigation The structure's north windows were noted to be picture and side-Sliding style windows with vinyl frames and sashes as manufactured by Jeld-Wen. Ms. Oliver reported having all of the windows in the residence replaced approximately four years prior to the Waldo Canyon wildfire. The replacement of the windows was not permitted through the Pikes Peak Regional Building Department, but the glass stamps indicated a manufacturing date or April 2008.

Based on experience and industry research, Knott Laboratory has determined that "vinyl" window damage caused by excessive heat from a fire most commonly consists of warped or melted window frames which can ultimately lead to failed seals within the insulated glass assembly. Vinyl window frames are made from a polyvinyl chloride (PVC), which typically begin to melt between 1670 and 221 0 Fahrenheit. PVC materials shrink and bend differentially when exposed to heat for prolonged periods. Window damage as a result of heat from a fire is most prominent on the side of the structure that was exposed to the most heat, more specifically the radiant heat from a nearby fire source.

Janice Carson CARSON.14104-0514 May 23.2014 Page 5 of 14

Knott Laboratory inspected exterior and interior of the vinyl frames/sashes of the windows around the house and did not note any perceptible warping or melting of the vinyl or any joint separation at the northern windows (Figures 5 thru 8). All of the operable north windows open and close without binding. Additionally, no evidence of failed seals (fogging or moisture between panes) were reported or observed. Further, Knott Laboratory did not note any localized burning, warping, discoloration or evidence of isolated damage to the window frames from potential flying debris/embers landing on the windows during the fire. Based on the lack of evident damage to the window frames and sashes or glass, Knott Laboratory concluded the subject windows were not damaged as a result of the fire.

Ms. Olivier expressed concern regarding debris on the lower interior horizontal surfaces of the window sashes. Knott Laboratory investigated the windows and noted some of the northern windows contained a small amount of debris/dust, specifically at the interface between the operable and inoperable vertical sashes. Ms. Olivier also reported water was found on the inside lower edge following power-spraying the exterior of the windows as well as at the loft's northern window during a May 21,2014 rainstorm. No moisture intrusion was occurring during Knott Laboratory's investigation, thus Knott Laboratory reviewed photos provided by Ms. Olivier (reportedly taken subsequent to power washing), wherein droplets of water were present at the center sash of various windows (Figure 9). The photographs taken after the May 2014 storm were blurry as to what was present and it remains unclear which photo was of the reported north facing loft window (Figure 10). The presence of corner particulates and water intrusion during driven moisture at the center rail is an indication of potential air infiltration and/or a gap between the operable portion and inoperable portion of the window (the center rail). As noted previously, there was not an elevated thermal exposure related to the fire capable of warping the windows. Thus, the intrusions and particles are likely the result of either a manufacturing or installation defect or general wear of the windows as this is a common observed intrusion location among windows not in an area exposed to wildfire. Additionally, forcefully driven water (such as that from a power sprayer) will also push the limits of lower grade window design, particularly at the central rail joint, and expose small gaps.

Ms. Olivier expressed concern regarding small imperfections in the window sashes including corner bead adhesive material that is exposed (as seen in Figure 9). Ms. Olivier was unsure as to whether these items were present prior to the fire. The corner beads and minor scrapes are consistent with the manufacturing process of the windows (specifically the adhesion of the insulated glass unit to the vinyl sashes). Thus, Knott Laboratory concluded the minor imperfections are the result of the manufacturing process.

Janice Carson CARSON.14104-0514 May 23,2014 Page 6 of 14

In order to alleviate the infiltrations, the window sashes would need to be replaced, at a minimum, but likely the frames as well as fitting new sashes into existing frames may result in similar small gaps.

Garage Investigation The garage door located on the north of the property consisted of a standard, double garage panel door manufactured from fiberboard panels. The garage door had been painted prior to Knott Laboratory's investigation and thus, altered since the fire. Since the door had been altered after the fire and prior to Knott Laboratory's investigation, Knott Laboratory is unable to opine as to the direct physical damage related to the fire; however, as previously noted, the temperatures at the north wall of the structure were not significantly elevated due to the fire which could cause damage to a fiberboard garage door or paint. Thus, it is unlikely that the door was damaged by the fire.

Ms. Olivier rather expressed concern with regards to how the garage door was power-washed subsequent to the fire. Upon investigation of the garage door, Knott Laboratory noted edge and corner cracking present between the individual panels and trim along the lower edges (Figures 11 and 12). Review of photos taken and provided by Ms. Olivier subsequent to the fire and power-washing (but prior to repainting) reveal cracks and paint fading in the finish consistent with long-term wear along with the observed swelling (Figure 13). Knott Laboratory was not provided a photo of the door prior to the power-washing. The swelling observed in both Knott Laboratory's investigations and the photos provided by Ms. Olivier are consistent with moisture damage during moisture events where moisture sat at the lower edge of the panels (on top of the trim) and leeching into the fiberboard material through cracks in the finishes, creating swelling of the fiber board. The long-term wear of the observed cracks in Ms. Olivier's photos indicate the cracks were likely present prior to the fire. Thus, anticipated swelling of the fiberboard material has likely occurred on an ongoing basis, including even recently due to current paint cracks as well (after the painting and fire). Any subsequent power-washing of the door will forcefully expose the fiberboard to additional water at the pre-existing cracks creating additional swelling. Thus, Knott Laboratory concluded the swelling observed in the garage door panels is consistent with repeated moisture exposure from cracks caused by wear and is not related to the fire. The garage door would not be able to be replaced in its current state and would need to be fully replaced to alleviate the swelling.

Conclusion: Based upon Knott Laboratory's inspection, the available evidence, and these engineers' education, training, and experience, the following conclusions have been reached within a reasonable degree of engineering certainty:

• The windows on the north face of the structure were not damaged as a result of the fire.

Janice Carson CARSON.14104-0514 May 23,2014 Page 7 of 14

o The moisture/air intrusion is likely the result of a manufacturing or installation defect or from general wear.

• The swelling observed in the garage door panels is consistent with repeated moisture exposure and is not related to the fire.

o The power washing conducted after the fire was simply another instance of moisture exposure at pre-existing cracks in the finish.

The opinions and findings expressed in this report are based upon the information available to these writers as of the date of this report and are the result of limited non-destructive visual inspections of the exposed building components. As such, Knott Laboratory reserves the right to modify the conclusions contained herein upon receipt or discovery of additional evidence. Due to the limited access and the non-destructive nature of the investigation, Knott Laboratory cannot be held responsible for any hidden defects that may negatively impact the performance of the structure. This report is intended to provide an overview of the existing conditions, and should not be used as an indicator of future performance; no expressed or implied warranties or guarantees of any kind are given.

Respectfully submitted,

KNOTT LABORATORY, LLC

JQnn Peter on, MS, PE Regional Manager, Southern

Stanley Regional Manager, Mountains

Figure 1 - North Face of Subject Structure

Figure 2 - Fire Map and Location of Structure (Courtesy Goog\e Maps and USDA)

CARSON.14104-0514 Claim Number: 06-08Z4-966

Figure 3 - Undamaged Surrounding Flora (looking west/southwest from front)

Figure 4 - Undamaged Surrounding Flora (Looking Northwest Across Wickes Road)

CARSON.141 04-0514 Claim Number: 06-08Z4-966

Figure 5 - Lack of Evidence of Heat Damage to Vinyl Frames

Figure 6 - Lack of Evidence of Heat Damage to Vinyl Frames

CARSON.14104-0514 Claim Number: 06-08Z4-966

Figure 7 - Lack of Evidence of Heat Damage to Vinyl Frames

Figure 8 - Lack of Evidence of Heat Damage or Dimensional Changes to Vinyl Frames

CARSON.141 04·0514 Claim Number: 06-08Z4-966

Figure 9 - Water on Interior of Window (Courtesy of Ms. Olivier)

Figure 10- Reported Water after Rainstorm (Courtesy of Ms. Olivier) - It is Unclear Which Provided Photo is of Which Window

CARSON.14104-0514 Claim Number: 06-08Z4-966

Figure 11 - Garage Panel Swelling

Figure 12 - Garage Panel Swelling

CARSON.141 04-0514 Claim Number: 06-08Z4-966

Figure 13 - Garage Condition After Power-Washing (Courtesy of Ms. Olivier)

CARSON.141 04-0514 Claim Number: 06-0824-966

LABORATORY, t.LC' ForenJit; Engitu!'Cring & An;mcfion