MAG-IBC-Section 104 modifications 21 July 2017.pdfStrotkamp Architects
P.O. Box 501
Burlington WA 98233
IBC Section 104.10 Request for Modifications
To: City of Edmonds From: Strotkamp Architects David Estes
Community Development
Magic Toyota Peter Chung
Attention: Leif Bjorback
Pages:
Building Official
Address: 121 Fifth Ave North
Date: 21 July 2017
Edmonds WA 9020
425.771.0220
Re: BLD 1684 2016 Plan Check Comments
dated 24 April 2017 Response
IBC Section 104. 10 code Modifications
CC: Tom Strotkamp (transmittal)
David Broadus, Magic Toyota
Design Team
❑ Urgent X For Review ❑ Please Comment ❑ Please Reply for Your Information
IBC Section 104.10 Modifications (to paraphrase) allows the Building Official the authority to grant
modifications to provisions of the code upon application by the Owners authorized Agent (Strotkamp
Architects) if the Building Official find that special individual reason makes the strict letter of the code
impractical. Further that such modification does not lessen health, accessibility life safety and fire
safety or structural requirements.
Based on the above referenced plan check comments for the building permit plan check Dated 24
April 2017 requiring a high occupant load for the parking deck on the project we are requesting a
finding under Section 104.10 to reduce the Occupant load of the parking deck based on the criteria set
forth in IBC Section 1004.2.1.
IBC Section 1004.1.2 Areas without Fixed Seating assigns an Occupant load of 1 per 200 sq. ft. of
gross parking deck area without regard to the actual use and Occupant Load of the space. Under the
Exception to Section 1004.1.2 areas without fixed seating, when approved by the building official, the
actual number of occupants shall be permitted to be used in the determination of the design Occupant
Load.
The private parking Deck is designed to hold 66 vehicles and is classified as an S-2 Occupancy —
Open Parking Garage. The use of this area, and the reason for the parking deck is because of lack of
vehicle storage space and the need for some employee parking. The vehicle storage on the parking
deck is for the Toyota Rental Fleet vehicles requiring over half of the spaces and for overflow new
vehicles. The rental fleet vehicles are serviced by two employees who retrieve vehicles as they are
rented. No public assess is allowed on the parking deck. Employee parking on the deck will be the
IBC Section 104 Variance 10 July 2017
second floor staff of 18 people and will arrive and leave during a two hour window in the morning and
afternoon. Based on the actual occupant load for the parking deck the maximum number of occupants
would be a maximum of 20 Occupants. Based on table 1004.2.1 the occupant load would be 116. In
addition two Occupants are required from the mechanical room.
The difference in Occupant load has a major impact on exiting and security of the parking deck. With
116 occupants two exits are required which causes considerable security issues by opening an exist
stair to the public, or a single exit for an Occupant load of 22.
On concern identified in the review of exiting was the separate path of travel on the parking deck as all
Occupants would exit to a single code approved location in the event of a fire on the parking deck.
Several items come to play in this review, first as an open parking deck there is no clearly defined path
of travel from individual parking spaces. As such from any location on the parking deck there are
multiple paths to the exit. While from a code standpoint the parking deck is served by a single exit,
there are in fact additional paths of travel off the parking deck. The vehicle access ramp, while not an
approved exit because of slope and no designated pedestrian lane is available to leave the parking
deck in the event of a fire. Second, door 228.A on Grid 5 provides access into the building for
employees. Employees with access cards can access the building and then to the second floor stair to
exit the building. At all times, authorized personal have access to this door to leave the parking deck.
The only Occupants on the parking deck would be those that have trespassed onto the parking deck.
Magic Toyota acknowledges that the modification to the Occupant Load on the parking deck is based
upon the intended use of the parking area. Should the use of the parking spaces change over time, we
understand that the Occupant load could changes and at that time the required exit quantity may have
to be modified and a second exit added from the parking deck. Should that occur, a new and related
documents modifying the exiting will be required from the City of Edmonds.
For exiting and plan of the stair exit enclosure see Exhibits EX-1 and EX-2 attached.
The change in Occupant Load from the parking deck which reduces the requirement for exits from
two to one does not affect any other provisions of the code as relating to the exiting, accessibility or
life safety issues. An evaluation of the Code sections which have applicability or impact to the
revision to the occupant load, are as follows;
Section Content
406.4.4 Ramps
406.4.6 Mixed Occupancy Separation
406.5 Open parking Garage
Content/Response
Per this section the ramp to the parking deck is
not considered a required exit because of slope.
The S-2 Open parking garage shall be separated
from the S-1 motor Vehicle repair by a 1 hour
separation. (4" concrete slab per table 721.1(3)
item 1-1.1)
The parking deck falls under this section in that
there is parking above grad on the roof of the
facility.
0 Page 2
IBC Section 104 Variance
10 July 2017
406.5.7 Means of Egress When persons other than parking attendants are
permitted open parking garages shall have means
of egress requirements per IBC chapter 10
(allows single exit.)
406.5.8 Standpipe systems An open parking garage shall be equipped with a
as standpipe system per IBC section 905.3 (class
1 Standpipe) this requirement meets the request
of the fire marshal review comments.
1005.1 Stairway width Based on Accessibility requirements the exit
shall comply with 48" between handrails.
1006.2.1 Egress based on Occupant Load There is no common path of travel to the egress
and common path of egress travel location as from each vehicle there is a separate
distance. path of travel.
Table
S Occupancy footnote "f'the
Given the parking deck is a single open space,
1006.2.1
length of a common travel path is
there is not a common path of travel to the single
limited to 100'
exit proposed.
1006.3.2
Egress from stories or occupied
Exception 1 applies to the parking deck allowing
Table
roofs requiring minimum of two
a single exit
1006.3.1
exists.
1009.1
Accessible Means of egress
The Stairway Exit shall be accessible
required.
1009.2
Continuity and Components
All components meet requirements of this section
1009.3
Stairways
Meets requirements of 48" between handrails
however, Exceptions 2 would indicate that a
48"clear distance between handrails. Per
discussion to remain at 48" clear.
1009.6 Area of Refuge
Does not apply per 1009.3 Exception 6
1010.1.2.1 Direction of Swing While for an Occupant Load of less than 50 does
not require doors to swing in the direction of
travel. The exit doors in the egress system do
swing in the direction of travel.
1010.1.6 Landings at Doors
Complies for all doors in the exit star way, both
from the Parking Deck and from the service area.
1011.2 Width and Capacity Exception 1 would apply with the requested
Occupant load, however the stair from the
service to the exit is 44" in width and the stair
0 Page 3
IBC Section 104 Variance 10 July 2017
from the parking deck to the access (ADA
accessible) is 48" clear between handrails.
1011.6 Stairway Landing Complies all landings match the width of the
stairway or 48"
1017.2 Exit Access Travel Distance Per table 1017.2 the maximum travel distance for
Limitations an un-sprinklered S-2 Occupancy (open parking
deck) is 300 ft., the longest diagonal from the
exit door to the corner of the parking deck is 196'
using a travel path in the parking aisles results in
a maximum travel path of 273' complies with a
single exit.
Call if you have questions, either (206-979-8320) or (425)-316-8979
Thanks
David Estes
Strotkamp Architects
Peter Chung
Magic Toyota
0 Page 4