20060720135703.pdfInc. 1Sgv
CITY OF EDMONDS GARY HAAKEIVSON
MAYOR
121 5TH AVENUE NORTH - EDMONDS, WA 98020 - (425) 771-0220 • FAX (425) 771-0221
Website: www d-edmonds.wa.us
DEVELOPMENT SERVICES DEPARTMENT
Planning • Building • Engineering
MICROFILM
July 5, 2006 CITY-- COPY
Mr. Phillip Lehn, Architect
Lehn Desir Collaborative
16202 72' Avenue West
Edmonds, Washington 98026
RE: Bradley Request for Green Roof Alternate Design, Plan Check#05-135
Dear Mr. Lehn:
The City is in receipt of your supplemental letter and documentation (received June 16, 2006) to
the request for alternate design regarding the Bradley green roof. The City received the latest
revised architectural plans on June 26, 2006 which contain specific details of the Carlisle
Coatings green roof assembly.
This letter only addresses the alternate design request for the green roof product Carlisle
Coatings and the statements and/or personal comments made throughout your June 16, 2006
letter. All Building Code plan review responses shall be reviewed separately by the City.
After review of the information submitted, it is my determination as Building Official for the
City of Edmonds that the use of Carlisle Coatings and Waterproofing green roof assembly, as an
alternate method and material under the provisions of International Residential Building Code
(2003 edition), is approved with the following conditions:
• Installation is limited to the product Carlisle Coatings and Waterproofing green roof
assembly on plywood substrate per manufacturer detail GR 500-61)
All work shall be performed in accordance with Carlisle specifications
This letter does not constitute an endorsement of the subject product and shall not to be used in
any manner to promote Carlisle Coatings and Waterproofing products or any portions of the
assembly. As with all alternate design requests the City suggests that property owners consult
with legal advisors and their insurance company regarding liability associated with alternate
designs.,
• Incorporated August 11, 1890 •
Mr. Lehn
Page Two
July 5, 2006
Regarding statements made throughout your June 16, 2006 letter which included the alternate
design information for the Carlisle green roof we have the following comments:
• The March- 17`,h plan submission you made to the City consisted of two sets of plans, one
set was missing the sheets noted in Building Division plan review comments dated
413106. The City's consultant plan set was complete so his review was not affected. The
second set of plans was kept in-house for staff review and that is why the missing sheets
were brought to your attention. We suggest you check your plan sets thoroughly to.
account for all sheets before bringing your plans to the City for submittal.
• Regarding the Lot 2 grading and driveway plan, the City shall review this proposal
separately under separate permit submittal.
• As you have been repeatedly told the City Planning Division determines Critical Areas
and imposes ECDC Chapter 23 requirements. If you have continued questions regarding
status or determination of Critical Areas for the Bradley lot or any lot within the affected
subdivision contact Rob Chave, Planning Manager directly. When critical areas are
determined on a site compliance to applicable provisions of ECDC Chapter 23 are
imposed including permitting requirements of ECDC 19.00.010.
• With regard to peer review of rockeries and retaining walls in Critical Areas, at this time,.
the City Engineer is the lead staff person who determines when peer review is required
for rockeries and retaining walls that are located in a critical area.
• The City accepts Mayes Testing as the Special Inspection firm of record who will be
responsible for inspections noted on the Special Inspection Agreement form.
• Thank you for acknowledging that all foundation plans submitted to date have been
missing foundation spot footing dimensions_
• Thank you for acknowledging your computer glitch on plan omissions.
• Regarding the Bamboo Rain Screen Siding, as discussed at the meeting, include the
structural engineer's details for siding attachment in addition to your architectural details.
This will be reviewed separately.
• Regarding your paragraph on your choice to request alternate designs. You have been
repeatedly advised that you could have shown a prescriptive roofing and siding method
on the plans and submitted alternate design review requests independently. It was your
choice as Architect of Record to submit all plans to date with specific siding and roofing
products and/or assembly systems that are not conventional or expressly permitted or
recognized in the code which are therefore subject to the provisions of IBC 104.11 for
alternate designs/methods. The City concurs you have delayed this project by insisting
that the plans only show roofing and siding products that are not conventional which
requires an alternate design, and also by failing to submit requested documents in a
timely manner.
• Regarding the manufacturer's details for the plywood substrate application, the City first
received the manufacturers' detail GR 500-6D by Carlisle Coatings and Waterproofing
on 6/16/06 and is part of this alternate design approval.
Mr. Lehn
Page Three
July 5, 2006
• Threatening to withdraw the Bradley permit application shall have no bearing on the
decision to approve or deny this or any other alternate design request submitted.
• Regarding 17232 Sealawn Place; alternate design provisions have been included in the
Building Code since at least 1964 and until green roofs are a conventional roofing
assembly recognized in the building code alternate design request approval shall continue
to be required by the City.
• In response to your statement, `rockery and two alternate designs permit, were any of
these permits actually required by statute or policy or did our building officials decide on
their own to impose them ... or are simply an exercise of the building officials authority'.
As you should be aware, IBC 104.11 is the code for alternate designs. A comprehensive
regulatory document such as the building code cannot envision and then address all
future innovations in the building industry. As a result a performance code must be
applicable to and provide a basis for the approval of newly developed products. The
building official is expected to apply sound technical judgment in accepting materials and
is responsible for determining if a requested alternate provides the equivalent level of
protection to public health, safety and welfare as required by the code. Furthermore, IBC
104.11.1 establishes the provisions for supporting data to assist the building official in the
approval of materials and assemblies. It is the supporting data submitted by the. design
professional that should prove code equivalency. To date you have only been asked to
provide copies of information which is readily available from the manufacturer (product
letters, technical data, manufacturer's specifications, etc.). The City has not requested
nor has imposed the testing requirements of IBC 104.11.2. None of the requested
material data was created by your office we have only requested copies of documents
readily available and supplied by the manufacturer so again we strongly disagree that any
delay has been caused or created by the City in this matter.
• Again, by adding personal comments within plan review responses you slow down the
City's review process. If you wish to personally comment on your perception of the City
Building Division it is more appropriate to write separate correspondence to the
Department Director, Mr. Duane Bowman.
• The City shall not respond to your paragraphs 6, 7, and 8 on page six but highlight those
paragraphs as specific examples of personal comments within plan review responses that
are not appropriate and slow down the City's review on the Bradley permit application.
• Thank you for allowing City staff members to browse your presentation boards on green
design.
Lastly, you have not provided enough information on the Hydro -Tech roofing product for
approval at this time. If additional information is provided (similar to the Carlisle product, as
referenced in City letter dated 619106) it will be considered for approval.
Mr. Lehn
Page Four
July 5, 2006
Sincerely,
6�A*�
Jeannine L. Graf
Building Official, C.B.O.
Cc: Robert A. Bradley, Jr.
References associated with this Alternate Design Request
Letters
• March 17, 2006: Request for Alternative Materials, Design and Methods of Construction
from Architect, Phil Lehn (addressed to Hoyt Jeter, City Plan Review Consultant)
• April 3, 2006: Comments regarding Alternate Design request from Ann Bullis, Assistant
Building Official, requesting formal request to Building Official and general additional
information that needs to be submitted for her review
• May 10, 2006: Response letter from Architect .to Jeannine Graf, Building Official
• June 9, 2006: Letter from Building Official to Architect requesting additional
information
• June 16, 2006: Response letter from Architect to Building Official
Product information
• General product brochure for Carlisle Coatings and Waterproofing, received 5110/06.
• Letter dated 5/3/06 from David Barnes, Technical Service for Carlisle Coatings and
Waterproofing, received 5110106
• Manufacturer's detail GR 500.61) (showing plywood substrate), received 6/16/06
• Testing report for CCW -500R, received 6/16/06 -
• CAN/CGSB-37.50-M$9 National Standard of Canada, received 6/16106
• CCW 50OR Technical brochure, received 6/16/06
• CCW 50OR-G Specifications, received 6/16/06
• CCW 500 Reinforcing Fabric Specification Sheet, received 6/16/06
• CCW MiraDRA1N GR9200 Specification Sheet, received 6116/06
• Carlisle's Moisture Mat Specification Sheet, received 6/16106
Carlisle's ROOT BARRIER Specification Sheet, received 6/16/06
• CCW 550 Primer Specification Sheet (as required on manufacturer's detail GR 500-61)),
printed by City Staff from website 6/27/06
• CCW 711-90 Membrane and Flashing (as required on manufacturer's detail GR 500-61)),
printed by City Staff from website 6/27/06