20161121083433.pdfNO
ARCON
TENANT IMPROVEMENT
R
CONTRACTORS
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11 /02/2016
NOV08 2016
(:C)F Eta'
To: Chuck Miller, Plans Examiner
Ds
City of Edmonds
Building Division
From: Dan Lavender (Contractor) for Dr. Etue (Applicant)
RE: Plan Check: BLD2016-1316
8129 Lake Ballinger Way, Suite 101
Complete Dentistry
Dear Mr. Miller,
Please accept these clarifications and revisions regarding the proposed storage room
reconfiguration project for Dr. Ryan Etue.
Note revised plans attached, (changes are indicated as Rev. 1, 10/28/2016). Unchanged sheets
are included as originally submitted.
Regarding your General Review Notes, we will respond in reverse order, as items #2 & #3 help
to clarify the explanation for item #1 (drinking fountain).
3) Clarify the proposed location of the relocated door (Sheet 8, rev. 1).
The door has been reconfigured to provide the required maneuvering clearances
as requested (this sheet also now shows new identity of room 108 as "STORAGE
ROOM").
Sheet 4 (rev. 1), now also correctly shows the space previously identified as space "108-
HYG 2" relabeled to its correct new use as a "STORAGE ROOM".
1) Drinking fountain(s).
We do not believe drinking fountain(s) are required based on our understanding of
the codes referenced in your letter. See reasoning below:
i. Primary Function
1. When an alteration to -a building affects -accessibility to, or contains
an area of primary function, the route to the primary function area
shall be accessible. The accessible route to the primary function
Phone: 425-289-1641 5150 Village Park Drive SE, Suite 107 Bellevue, WA 98006
area shall include... drinking fountains serving the area of primary
function. The code also indicates that the primary function is a
major activity for which the facility is intended. It does not
include supply or storage rooms, mechanical rooms, employee
lounges or lockers rooms, janitorial closets, etc. The item above
refers to the IEBC Section 410.7 which you have identified in your
code correction letter. This is basically saying that if the alteration
is to the primary function of the suite, the route to get there needs
to be accessible.
a. However, in this case, we aren't making any alterations to
any area of primary function. We are altering a storage
room, which is not a primary function per the IEBC
Definition. Therefore, there is no code requirement to
provide an accessible route to this area... which in turn
means no drinking fountain should be required.
ii. Technicaliv Infeasible
1. The IBC states alterations (including adding drinking fountains)
need to comply with the IBC, unless it is technically
infeasible. (See IEBC 410.6.)
a. We think it's technically infeasible to reasonably provide
added drinking fountains given the existing space
constraints (reference drawing sheet 6). Dr. Etue's dental
space is small, and it (drinking fountain) would either have
to go in the Waiting Area, which isn't big to begin with
(much needed seating space would be sacrificed), or in a
hallway, which won't meet code.
iii. Cost of Ini rovcinents
1. The code states the cost of improving the accessible route (aka
adding drinking fountains) is not required to exceed 20% of the
costs of the alterations affecting the area oaf'rira:r�incti>n
a. Again, as stated above, we aren't altering any areas of
primary function with this project. If we were turning a
storage room into an exam room, this may be applicable,
however, we're doing the opposite. Consequently, Dr. Etue
is spending $0 on the primary function of this space,
therefore no additional work should be required.
b. In addition, the current space was built very recently and
we believe it to be fully ADA compliant including site
access and parking areas. And again, no expenditures are
being made on primary function alterations.
Phone: 425-289-1641 5150 Village Park Drive SE, Suite 107 Bellevue, WA 98006