BLD19-0025 Paradise Lane Bldg A - ARCH Corr. Ltr #2 by Beck (7-5-2019).doc
July 5, 2019
Leif Bjorback
Building Official
City of Edmonds
121 5th Avenue North
Edmonds, WA 98020-3145
Subject: Paradise Lane – Building A (Non-structural Review)
Permit: BLD19-0025
Per your request, Beck & Associates has completed a 2nd 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 = additional comment in response to the resubmittal
Building Envelope
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.
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.
General
The drawings state that the address of the site is 548 Paradise Lane. However, the correct address is 546 Paradise Lane. Update the drawings and title block accordingly.
All references to the IRC need to be removed from the drawings. The applicable code is the IBC.
Provide a complete building analysis within the drawing set that identifies the following elements. Please provide this in tabular format, comparing allowable height, stories, & areas
with actuals, for ease of reference.
Occupancy: R-2, S-2
Construction Type: V-B
Allowable Height (NFPA 13R): 60 feet (Table 504.3)
Allowable # Stories (NFPA 13R): 3 stories (Table 504.4). Please be aware that the lowest level is currently identified on the plans as a basement. However, from a code standpoint it
does not meet the definition of a basement and is therefore considered to be a story above grade plane. This needs to be clearly documented in the code analysis.
Allowable Floor Area (NFPA 13R): 7,000 sf (Table 506.2a)
Allowable Building Area (NFPA 13R): 7,000sf x 3 stories = 21,000 sf
The analysis also needs to identify the actual values for comparison with allowable values.
building height
number of stories
floor areas
building area
Provide a roof plan that identifies slopes, drainage, exhaust fans, etc.
Provide an analysis for required roof ventilation and provide detailing that demonstrates that required roof ventilation will be provided. 1203.2
IBC 427.5 (WSA) requires at least one accessible space to be served by vehicle charging infrastructure (208/240 V 40-amp). This needs to be specified.
The plans need to specify and demonstrate that the requirements of Section 427 (WA State Amendments) – Electrical Vehicle Charging Infrastructure will be met. 427
Accessibility (IBC Chapter 11: ICC A117.1-09)
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.
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
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
The plans needs to specify the threshold that is required. It is not sufficient to simply reference the code section for that information. The maximum threshold is ¼”, ½-inch if the
threshold is beveled at a slope not steeper than 1:2. Update the note on sheet A2 accordingly.
Provide specifications and/or detailing to demonstrate that the threshold at the main entrance door to Building A will be accessible. IBC 1104; ICC A117.1-09, 402
The applicant indicates that Unit 202 is the Type A Unit. The plans need to be updated to state that Unit 202 is the required Type A Unit.
It is the applicant’s responsibility to demonstrate that all requirements will be met.
It is apparent that the MBATH of Unit 202 is intended to meet the requirements of 1003.11.2 (as required). Provide complete plans, elevations, specifications, and detailing to demonstrate
compliance. Address the lavatory, mirrors, water closet, bathing fixtures, clearances, grab bars, etc.). ICC A117.1-09, 1003.11.2
The 2nd bathroom (BATH) is required to comply with 1003.11.1. Identify locations for all reinforcement for future grab bars at water closets and bathtubs. ICC A117.1-09, 1003.11.1, 604.5,
607.4
Reference the Laundry room. Based on the clearances specified, front-loading machines are required. This needs to be specified on the plans ICC A117.1-09, 1003.11, 611
Reference the door to MBED. A clearance of 18” is required to be provided on the pull side of the door. Update the plans accordingly. ICC A117.1-09, 1003.5, 404.2.3
Update the plans to demonstrate all Type A Unit Kitchen requirements will be met. This remains to be provided. ICC A117.1-09, 1003.12
Reference 2015 Tip Sheet 17 at MyBuildingPermit.com for Type A Kitchen requirements: https://mybuildingpermit.com/guidelines-and-tip-sheets.
Reference 2012 Tip Sheet 15 at MyBuildingPermit.com for Type A Bathroom requirements: https://mybuildingpermit.com/guidelines-and-tip-sheets.
At least one unit is required to be a Type A Unit on the site since the total number of dwelling units on the site exceeds 10. Identify the location of the Type A unit (Building A, B,
or C). If the Type A unit will be provided in Building A, that unit will need to be identified on the plans as being Type A (it appears that the intent is for Unit 201 to be Type A).
Additionally, provide complete dimension, design, and detailing to demonstrate compliance with Type A Units. Reference ICC A117.1-090 and Tip Sheet 17 of MyBuildingPermit.com for requirements.
All requirements must be addressed within the drawing set. IBC 1107.6.2.2.1 (WA State Amendments); ICC A117.1-09, 1003
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.
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 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
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
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)
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)
Reference the Prescriptive Energy Code Compliance Form. The following need to be specified/addressed within the drawing set.
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.
The drawings need to clearly identify the specific requirements of each of the additional energy credits chosen for this project. WSEC Table R406.2
Currently, insulation values noted in the detailing are inconsistent with what is specified and required on sheet P1. Provide coordination.
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
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
Ducts are required to be insulated to a minimum of R-8. R403.3.1
Mechanical system piping is required to be insulated to a minimum of R-6. R403.4.
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.
Mechanical ducts are required to be seal tested in accordance with 403.3.2. Testing to comply with WSU RS-33.
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
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 P1
Note 18 indicates that the building construction type is V-B. Note 19 indicates that the building construction type is V-A. It appears that the building construction type can be V-B
since a NFPA 13R sprinkler system is being installed throughout the building. Provide coordination.
Note 34 references the 1998 edition of ICC A117.1. The current applicable edition is 2009. Update the note accordingly.
Sheet P2 – Site Plan
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
This distance defines the fire separation distance and is required to be identified on all sides of the building.
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.
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
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 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
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 A2 – Basement Floor Plan
This item remains to be addressed. The plans need to clearly identify each and every rated wall, the required rating, and be provided with a section cut where detailing can be found
for proper construction of the listed, tested assembly.
Every wall that is required to be rated is required to be identified on the plans with the required rating noted and with a reference to the listed, tested assembly that provides specifications
and detailing for construction.
Each private garage (U occupancy) is limited to 1,000 sf in area. 403.6.1
This remains to be addressed. Currently, walls separating garages from each other are not shown to be rated. Update the plans accordingly.
Each private garage is required to be separated from other private garages by 1-hour rated fire barriers (707).
Identify the listed, tested assembly to be used for construction of the 1-hour rated walls 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.
Identify the walls separating the private garages from each other as 1-hour assemblies and reference the 1-hour listed, tested assembly that will be used for construction.
Garage 301 currently exceeds 1,000 sf in area. It will need to be reduced to a maximum of 1,000 sf in area.
Garage 301 is required to be provided with a means of egress. A side-hinged swinging door is required for the means of egress. Elevators and overhead garage doors are not considered
to be means of egress. Revise the plans accordingly. 1010
This item remains to be addressed. Locations of required 2-hour rated wall assemblies and 90-minute rated doors are unclear from the drawings. Neither is a 2-hour rated assembly provided
within the drawings. Identify the listed, tested 2-hour rated wall assembly to be utilized and provide complete specifications and detailing for construction and inspection. Update
the drawings accordingly.
The private garages (U Occupancy) are required to be separated from the common spaces (R2 Occupancy) in accordance with Table 508. 406.3.4
This Table requires these occupancies to be separated with 2-hour rated construction. Please note that a full NFPA 13 sprinkler system is required in order to reduce the rating of the
separation from 2-hours to 1-hour. An NFPA 13R system is not sufficient to reduce the rating to 1-hour. Table 508
Doors in 2-hour rated fire barriers are required to be 90-minute rated. 716.5
Private garages are required to be separated from dwelling units in accordance with 406.3.4.1. It appears that the intent is to provide a 1-hour rated floor-ceiling assembly between
the private garages and dwelling units above. This is sufficient to meet the requirements of 406.3.4.1. The 1-hour floor-ceiling assembly needs to be clearly identified within the drawing
set. The listed, tested assembly needs to be referenced from the plans. 406.3.4.1
This comment remains to be addressed. Washington State Amendments require all Group R-2 occupancies to meet the provisions of 3002.4, regardless of the number of stories. Update the
plans accordingly.
The elevator car is required to be of such size and arrangement to accommodate an ambulance stretcher 24 inches by 84 inches with not less than 5-inch radius corners, in the horizontal,
open position and is required to be identified by the international symbol for emergency medical services (star of life), the symbol being not less than 3 inches in height and being
placed on both sides of the hoistway door frame. Update the plans and provide dimensions and detailing to demonstrate that these requirements will be met. 3002.4
The elevator machine room is required to be provided with natural or mechanical means to keep the equipment space ambient air temperature and humidity in the range specified by the elevator
equipment manufacturer. Coordinate with the elevator manufacturer and indicate on the plans how this will be provided. 3005.2
The elevator machine room is required to be enclosed with a 1-hour rated fire barrier. The door is required to be self-closing and 45-minute rated. Update the plans to demonstrate that
these requirements will be met. 716.5
The door between the interior exit stair and the exit passageway is required to be 60-minute rated. 1023.3.1
Sheet A3 – 1st Floor Plan
This item remains to be addressed. The plans need to clearly identify each and every rated wall, the required rating, and be provided with a section cut where detailing can be found
for proper construction of the listed, tested assembly.
Every wall that is required to be rated is required to be identified on the plans with the required rating noted and with a reference to the listed, tested assembly that provides specifications
and detailing for construction.
A section reference (A/A12) references sheet A12 which does not exist within the drawing set. Provide coordination. Section cuts should be provided to reference all appropriate details.
An exhaust fan needs to be provided in the Master Bath of Unit 202.
Sheet A4 – 2nd Floor Plan
This item remains to be addressed. The plans need to clearly identify each and every rated wall, the required rating, and be provided with a section cut where detailing can be found
for proper construction of the listed, tested assembly.
Every wall that is required to be rated is required to be identified on the plans with the required rating noted and with a reference to the listed, tested assembly that provides specifications
and detailing for construction.
Some section cuts reference details that do not exist. Provide complete coordination.
Numerous section cuts reference drawing sheets that do not exist within the drawing set. Provide coordination. Section cuts should be provided to reference all appropriate details.
An exhaust fan needs to be provided in the Bath of Unit 302.
This item remains to be addressed. No response was provided.
The common path of travel permitted for a single exit is 125 feet. The common path of travel is defined as that portion of the exit access travel distance measured from the most remote
point within a story to that point where the occupants have separate and distinct access to two exits or exit access doorways. It is apparent from a simple scaling of the plans that
the common path of travel for the upper floor exceeds 125 feet. It is possible that the common path of travel is even exceeded for the 1st floor units. Please be aware that the common
path of travel is measured from the most remote point within a story, down the stairs, through the exit passageway, and to the exit discharge door. Travel distance measured down stairs
is measured along nosing of the treads. Revise the design accordingly. Table 1006.3.2(1)
Sheet A6 - Details
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.
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.
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
BLD19-0025
July 5, 2019
Page 10 of 10
16425 SE 66th Street, Bellevue, WA 98006 ● beckpllc@msn.com ● PH: 206-313-3739
Beck & Associates, PLLC
Structural Engineering & Code Consulting
16425 SE 66th Street, Bellevue, WA 98006 ● beckpllc@msn.com ● PH: 206-313-3739