2019-0025 Paradise Heights multi-family residential #3 - Michel Design.pdf
DATE: December 6, 2019
TO: Rob Michel
rwmichel@nwlink.com
FROM: Leif Bjorback, Building Official
RE: Plan Check: BLD2019-0025 – 3rd review
Project Address: 21911 76th Avenue W, Suite 211
Project: Paradise Heights multi-family residential
Scope: Construct 4-dwelling unit structure with private garages – separated
Residential group R-2/Utility group U occupancies – undetermined number of
occupants – VB construction – undetermined sprinkler system – mechanical,
plumbing, fire sprinkler, fire alarm, etc. under separate permits
Please be advised that the building plans for the above referenced project have been disapproved
for the purposes of obtaining a building permit. During a review of the plans by the Building
Division for compliance with the applicable building codes, it was found that the following
information, clarifications, or changes are needed. Reviews by other divisions, such as Planning,
Engineering, or Fire, may result in additional comments that require attention beyond the scope of
this letter.
A complete review cannot be performed until the revised plans/documents, including a
written response in itemized letter format indicating where the ‘clouded’ or otherwise
highlighted changes can be found on the revised plans, have been submitted to a Permit
Coordinator. Only those sheets specifically referenced as follows need to be resubmitted.
Resubmittals must be made at the Development Services Department on the 2nd Floor of City Hall.
Permit Center hours are M, T, Th, & F from 8am-4:30pm and from 8:30am-12pm on Wednesdays.
General plan review note:
· The following comments (1-50) are those resulting from non-structural and structural
reviews performed by a consultant on behalf of the City of Edmonds. Added to the end of
these are those (51-79) resulting from a non-structural review performed by the City of
Edmonds plans examiner of the submitted construction documents. Together, they are
intended to serve as a complete review of the submittal.
City of Edmonds
PLAN REVIEW COMMENTS
BUILDING DIVISION
(425) 771-0220
Page 2 of 8
Subject: Paradise Lane – Building A (Non-structural Review)
Permit: BLD19-0025
Per your request, Beck & Associates has completed a 3rd non-structural review of the drawings and
calculations for conformance with the 2015 International Building Code (IBC), as adopted and
amended by the State of Washington (WSA) and the City of Edmonds (ECC).
Our review of the plans and calculations indicates that corrections are necessary prior to permit
issuance. The applicant should address the following comments in itemized letter format in addition
to making corrections & revisions to the drawings. Corrections and revisions to the drawing should
be clouded so that they are clearly identifiable.
_______________________________________________________________________
Legend:
Faded text = initial comment adequately addressed – no further action required
Plain text = initial comment (these remain where an additional comment is made)
Blue text = 2nd rvw comment (these remain where an additional comment is made)
Red text = additional comment in response to the resubmittal
Building Envelope
1) While the building envelope drawings have now been provided, the drawings remain to address the
following:
a. The building enclosure documents must contain a stamped statement by the person stamping
the building enclosure design documents stating, in substantially the following form: “The
undersigned has provided building enclosure documents that in my profesional judgment are
appropriate to satisfy the requirements of RCW 64.55.005 through 64.55.090."
Note from Leif Bjorback: I see that this item has been addressed in a hard copy submittal
dated 11/12/19; however, an updated electronic copy of this sheet was not provided for
consultant review, which is why it remains on this review list.
b. All multi-unit residential buildings are required to have the building enclosure inspected by a
qualified building enclosure inspector during the course of construction. This inspection is to
be completed by a third party, independent inspector. The requirement for third party
inspection needs to be specified on the plans.
The applicant indicates in his response that building enclosure documents were included in the submitted
documents. However, they were not. This item remains to be addressed.
Pursuant to RCW 64.55, all applications for construction of multi-unit residential buildings must include
building enclosure design documents that identify the building enclosure, including but not limited to,
waterproofing, weather proofing and/or otherwise protected from water or moisture intrusion. The
building enclosure documents must contain a stamped statement by the person stamping the building
enclosure design documents stating, in substantially the following form: “The undersigned has provided
building enclosure documents that in my professional judgment are appropriate to satisfy the
requirements of RCW 64.55.005 through 64.55.090."
Additionally, all multi-unit residential buildings are required to have the building enclosure inspected by a
qualified building enclosure inspector during the course of construction. This inspection is to be
completed by a third party, independent inspector. The City may not issue a Certificate of Occupancy until
the qualified, third party independent inspector prepares a report and submits to the building department
a signed letter certifying that the building enclosure has been inspected during the course of construction
and that the construction is in substantial compliance with the building enclosure design documents. The
requirement for third party inspection needs to be specified on the plans.
Page 3 of 8
Alternatively, a recorded “sale prohibition covenant” is required to be submitted for review. A “sale
prohibition covenant” is a recorded covenant that prohibits the sale or other disposition of individual
dwelling units as or as part of a condominium for five years or more from the date of first occupancy
except as otherwise provided in section 10 of the act, a certified copy of which the developer shall submit
to the appropriate building department; provided such covenant shall not apply to sales or dispositions
listed in RCW 64.34.400(2). The covenant must be recorded in the county in which the building is located
and must be in substantially the following form:
This covenant has been recorded in the real property records of Snohomish County, Washington, in
satisfaction of the requirements of sections 2 through 10 of this act. The undersigned is the owner of the
property described on Exhibit A (the "Property"). Until termination of this covenant, no dwelling unit in or
on the Property may be sold as a condominium unit except for sales listed in RCW 64.34.400(2).
This covenant terminates on the earlier of either: (a) Compliance with the requirements of section 10 of
this act, as certified by the owner of the Property in a recorded supplement hereto; or (b) the fifth
anniversary of the date of first occupancy of a dwelling unit as certified by the Owner in a recorded
supplement hereto.
Accessibility (IBC Chapter 11: ICC A117.1-09)
8) This item remains to be addressed. The applicant indicates that the Site Engineer provided a
response to this item. However, we are unable to locate this. Additionally, plans were not
updated to demonstrate that an accessible route will be provided.
This item remains to be addressed. The applicant indicates that the Site Engineer provided a
response to this item. However, we are unable to locate this. Additionally, plans were not
updated to demonstrate that an accessible route will be provided.
A concrete walkway/ADA ramp is shown along the north side of the three proposed buildings.
We assume this is intended to be the accessible route from the public way (sidewalk) to the
entrance of Building A.
a. Identify slopes and other elements of the accessible route to demonstrate that this will
indeed be an accessible route in accordance with the IBC and ICC A117.1-09. IBC 1104; ICC
A117.1-09, 402
b. The accessible route is required to be independent of and separated from the vehicular path
that enters the site. Currently, it appears that the accessible route utilizes the vehicular path
to travel from the public sidewalk to the concrete walk that serves as the accessible route on
site. At a minimum, a curb should be provided to separate the accessible route from the
vehicular path. 1104
11) All Units in the building that are not Type A Units are required to be Type B Units. 1107.6.2.2.2
Units 201, 301, & 302 are Type B Units.
The MBATH of each of these units has been chosen to comply with 1004.11.3.2
- A clear floor space complying with Section 305.3, positioned for a parallel approach, is
required to be provided at the sink. The approach is required to be centered on the sink. The
plans have yet to demonstrate that this requirement (centered on the sink) will be provided.
1004.3.11.2.1; 1004.11.3.1.1
- The WC is required to comply with 1004.11.3.1.2. Update the plans accordingly.
a) Reference ICC A117.1-09, 1004.12 and Tip Sheet 18 of MyBuildingPermit.com for
requirements for Kitchens in Type B Units. The parallel approach at the sink is required to be
centered on the sink. Otherwise, a front approach is required to be provided. Currently, a
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compliant parallel approach at the sink of Unit 201 & 301 is not provided (laundry appliances
are obstructing the clear floor space). Revise the plans accordingly. ICC A117.1-09, 1004.12
b) Reference Unit 201 & Unit 301. The 48” clear floor space is required to be provided opposite
the control side of the shower. We assume the control side is noted by the triangle (filled in
triangle at the shower). If this is the case, the required clearance is not provided. Revise the
plans accordingly. ICC A117.1-09, 1004.11.3.1.3.3
This item remains to be addressed.
A note is provided on the plans that indicates that the bathroom is required to comply with
1004.11.3 – Option B. The toilet of Units 201 & 301 is currently not provided with the
required 48” clear width. The shower is not permitted to intrude into this space as it is
greater than 24-inches in depth. Revise the plans accordingly. ICC A117.1-09,
1104.11.3.1.2.2.1
12) This item remains to be fully addressed. No new information was provided since the last
submittal. Not all required reinforcement is currently specified. Update the plans to specify all
locations, dimensions, etc. where grab bar reinforcement is required to be provided. Address
both Type A and Type B Units.
This item remains to be fully addressed. Not all required reinforcement is currently specified.
Update the plans accordingly.
Provide dimensions for both Type A & B Units for all required blocking for future grab bars. The
location of all blocking must be clearly specified and detailed. ICC A117.1-09 1003.11.1,
1004.11.1
Interior Environment (Chapter 12)
13) Floor-ceiling assemblies separating dwelling units from each other are required to have an
impact insulation class of not less than 50 when tested in accordance with ASTM E492. New
assemblies provided in the drawings in response to our comments will need to meet this
requirement. 1207.2
Energy (2015 WSEC, Residential)
14) Reference the Prescriptive Energy Code Compliance Form. The following need to be
specified/addressed within the drawing set.
a) In response to this item, Options 1a and 1d are now utilized in lieu of Option 4c. However,
footnote ‘a’ under Energy Credit 1d indicates that projects using Option 1d are not permitted
to also use Options 1a, 1b, or 1c. The applicant needs to choose energy credits that do not
exclude other energy credits chosen. Revise accordingly.
Option 2a is chosen for energy credits. However, the reduced maximum air leakage of 3.0 air
changes is not specified on the plans. Update the plans accordingly.
Option 4c is chosen for energy credits. However, an electric tankless hot water heater is
inconsistent with this credit. The water heating system is required to be gas, propane, or oil.
Alternatively, an electric heat pump water heater with a minimum EF of 2.0 and meeting the
standards of NEEA’s Northern Climate Specifications for Heat Pump Water Heaters is
required. Revise/update the plans accordingly.
Option 5a is chosen for energy credits. However, the requirements of that option are not
specified on the plans. Update the plans to specify the requirements in order to achieve the
Option 5a credits.
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The drawings need to clearly identify the specific requirements of each of the additional
energy credits chosen for this project. WSEC Table R406.2
b) Currently, insulation values noted in the detailing are inconsistent with what is specified and
required on sheet P1. Provide coordination.
c) Detail T/A5 is still erroneously identified on sheet A2. The detail callout needs to be updated
to reference detail T/A6.
Detail T/A6 was provided to address this comment. Sheet A2 reference detail T/A5 (2
locations). The correct reference from A2 is T/A6. Update the plans accordingly.
Provide detailing to demonstrate how the energy envelope will be maintained between the
garage spaces and the conditioned spaces (hallway, elevator area, stairway, exit
passageway). Address slab/foundation insulation. Although noted as “unheated area electric
heat 40 min tem 1 watt per sq ft max”, by definition of “conditioned space” in the
Residential WSEC, the spaces are considered to be conditioned. Ch. 2 Definitions
d) A permanent certificate is required to be completed and posted on a wall in the space where
the furnace is located (or other approved location) and list the following information: R-
values, U-values, Results from duct system air leakage testing, Results from building
envelope air leakage testing (blower door test), Types and efficiencies of heating, cooling,
and service water heating equipment. R401.3
e) Ducts are required to be insulated to a minimum of R-8. R403.3.1
f) Mechanical system piping is required to be insulated to a minimum of R-6. R403.4.
g) The applicant has chosen Option 2a for additional energy credits. Therefore, the maximum
air leakage rate is not permitted to exceed 3 air changes per hour when tested. Update the
notes on sheets A2-A4 accordingly.
The dwelling is required to be tested and verified as having an air leakage rate not exceeding
5 air changes per hour (unless a more stringent requirement is mandated in order to achieve
the additional required credits. R402.4.1.
h) Mechanical ducts are required to be seal tested in accordance with 403.3.2. Testing to
comply with WSU RS-33.
i) In response to this item, the applicant references G/A6 for insulated header detailing.
However, this detail shows insulation on the top of the header as being R-10 insulation. The
wall above the header is required to be R-21. The portion of the header cavity on the interior
side of the header is required to be R-10 (thereby insulating the header). Revise the detail
accordingly, showing the R-10 insulation on the interior side of the header (assuming 4x
headers, the header does not take up the full-width of the 2x6 wall space).
While this is specified in the plans, it also needs to be detailed within the plan set.
Exterior headers are required to be insulated with a minimum of R-10 insulation. This needs
to be specified and detailed within the plan set. WSEC Table R402.1.1, footnote k
j) This item remains to be addressed. The note provided was incomplete and no detailing was
provided. Update the plans accordingly.
Corners of stud walls are required to be fully insulated. This needs to be specified and
detailed within the plan set. WSEC 202, definition of ‘Intermediate Framed Walls’
Drawing Sheets
Sheet P2 – Site Plan
Page 6 of 8
17) This item remains to be addressed. An updated sheet P2 was not included in the submitted
documents.
- Update sheet P2 to show the distance measured from the face of the building, measured at
right angles from the face of the building. Several measurements from the face of the
building are not measured at right angles to the building. Measurements need to be made at
locations where the building is closest to the property line or imaginary line. Revise the plan
accordingly.
- Update the drawings to identify the fire separation at each exterior wall section at each level
along the east face of the building.
Update sheet P2 to show the distance measured from the face of the building, measured at right
angles from the face of the building. Several measurements from the face of the building are not
measured at right angles to the building. Measurements need to be made at locations where the
building is closest to the property line or imaginary line. Revise the plan accordingly.
Identify the distance from the face of the building (measured at right angles from the face of the
exterior wall) to the closest interior lot line, centerline of the adjacent public way, or to an
imaginary line between buildings on the same lot. Ch. 2, Table 602, 7058.3
a) This distance defines the fire separation distance and is required to be identified on all sides
of the building.
b) The percent openings in 1-hour rated walls is limited per Table 705.8. Provide an analysis of
the percent wall opening at each 1-hour rated wall section at each level to demonstrate that
the area of openings is within the limits of Table 705.8. Please be aware that “sprinklered” in
the Table means that the building is equipped throughout with a full NFPA 13 sprinkler
system. Increased opening percentages are not permitted with NFPA 13R systems. Provide
an analysis and update the drawings accordingly.
This item remains to be addressed. Sheet P2 indicates that fire separation distance of 7.6-
feet occurs on the east (right) side of the building. As a result, the exterior walls are required
to be 1-hour rated. Reference the original comment below.
Additionally, all construction supporting the required 1-hour rated exterior wall is required
to be 1-hour rated. Given that there is a cantilever floor at this location, the floor (which is
already noted as being 1-hour rated) and exterior walls supporting that floor (exterior garage
walls along the east face of the building) are required to be 1-hour rated. Provide complete
detailing & specifications for all rated construction. Reference the required rated
construction from the plans.
The fire-resistance rating of exterior walls is based on the fire separation distance as
identified in Table 602. For Type V-B Construction, exterior walls are required to be 1-hour
rated where the fire separation distance is 10’-0” or less. Where this occurs, identify the
listed, tested assembly to be used for construction of the 1-hour rated wall and provide
complete specifications and detailing for construction of the wall. We recommend that an
exact copy of the assembly be provided within the design drawings. This is to help insure
proper construction and inspection.
c) This is indeed the case and remains to be addressed.
Based on the Site Plan and the dimensions provided, it appears that the east exterior walls of
the building will be required to be 1-hour rated (they will have of a fire separation distance
of less than 10’-0”). 705.3
d) Openings in exterior walls that are required to be rated based on fire separation distance are
limited and governed by 705.8. Provide an analysis for the allowed area of openings in
exterior rated walls. Provide opening protection as required by the analysis. Please note that
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a full NFPA 13 sprinkler system is required to utilize increased allowable areas of openings.
An NFPA 13R system does not provide these increased areas. Table 705.8
e) This item remains to be addressed. Plans need to demonstrate compliance with the parapet
requirements or one of the exceptions provided.
This item remains to be addressed.
Where exterior walls are required to be rated, they are required to be provided with rated
parapets or meet one of the exceptions. 705.11
Sheet A6 - Details
34) In response to this item, the applicant identifies the floor-ceiling assembly as UL Design L544.
Unfortunately, we are unable to locate an assembly from the UL website (or other website for
L544) that exactly matches the proposed detailing. Provide an exact copy of the listed, tested
assembly so we are able to review the proposed detailing relative to it. The proposed detailing
and design must match exactly (within the parameters of the listing). Revise the design as
required to match the assembly. The floor-ceiling assembly must also meet STC and IC ratings as
previously indicated.
Complete specifications and detailing for construction of the assembly remain to be provided
within the design drawings. Update the drawings accordingly.
Reference B/A6. It is unclear which assembly in ESR-1153 is proposed to be used. Please clarify.
Provide complete specifications and detailing within the drawings that exactly match the listed,
tested 1-hour assembly. Include fasteners, spacing, etc.
35) This item remains to be addressed. No changes were made to the drawings in comment.
This item remains to be addressed.
Reference K/A6. IBC assembly 22-1.1 is referenced. The assembly proposed and detailed in this
detail does not match assembly 22-1.1 which requires the use of steel joists or trusses. Identify
an assembly in the 2015 IBC (or alternate sources such as the Gypsum Manual) that matches the
proposed construction. Provide complete specifications and detailing.
36) Reference R/A6. The detail provided is for secondary drainage only. However, both secondary
drainage and primary drainage are required to be provided. Update the detail accordingly.
Secondary (emergency) roof drainage is required to be provided in accordance with UPC
1101.12. The secondary roof drains are required to be located no less than 2 inches above the
roof surface. The maximum height of the roof drains shall be a height to prevent the depth of
ponding water from exceeding that for which the roof was designed. Additionally, the secondary
roof drainage system is required to be a separate system and be sized in accordance with Table
1101.12.1 based on the rainfall rate for which the primary system is designed. Update the plans
to provide detailing for the secondary roof drainage and specify the requirements within the
plan set. UPC 1101.12
Reference R/A6. This detail is not applicable to this project as there are no flat roofs. The detail
should be deleted from the plan set.
Please contact me should you have any questions.
Respectfully,
Douglas Beck, PE, SE
Beck & Associates, PLLC
16425 SE 66th Street, Bellevue, WA 98006 ● beckpllc@msn.com ● PH: 206-313-3739
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The following items noted in italics are new notations from the City of Edmonds plan reviewer.
On sheets A3 and A4 – various FLOOR PLANS:
67) This item has not been properly addressed. The fans are still undersized. Change on the plans
the referenced code and section regarding the provisions of whole house ventilation from ‘IRC
1507.3’ to ‘IMC 403.8.6’. The intermittent operation ‘run-time’ as a percentage of each 4-hour
segment of the day must also be specified to determine the proper sizing and wattage of the
proposed exhaust fan. The whole house exhaust fans shown are undersized. Please recalculate the
CFM for the fans in each dwelling unit using IMC Table 403.8.1. Be aware that choosing an
intermittent operation setting requires the CFM to be adjusted proportionally to the percentage of
time of operation in a 24 hour period.
If there are any questions on items 1 through 36, please contact Doug Beck directly. If there is a
question on item 67, please contact Leif Bjorback.