Ombu Salon AM&M.pdfCITY OF EDMONDS
121 51" Avenue North
Edmonds, WA 98020
DEVELOPMENT SERVICES DEPARTMENT
Building • Engineering • Planning
Website: www.edmondswa.gov
January 2, 2018
Heidi Helgeson
H2D Architecture
Re: Alternate Design Request for use of basement for commercial use at
Ombu Salon 121 3rd Ave N
Permit: BLD2018-1021
Dave Earling
Mayor
PHONE: 425.771.0220
Fax: 425.771.0221
As per your request dated December 4, 2018: "We are requesting the use of the basement for office,
laundry, storage and employee break room at the Ombu Salon permit #BLD20181021 per the alternate
Design and Methods section from IBC 2015 104.11. The basement would not be allowed for customer
use. The existing ceiling height of approximately 6"-10" in the basement does not meet the means of
egress code requirement of 7'-6" for ceiling height. Although the ceiling height does not meet the letter
of the code, we would like to propose the use of the basement for the purposed listed above and based
on the below listed code sections and compliance." Please see the entire proposal attached at the end
of this document. Although the substance and intent of the proposal are clear, it should be noted that
not all code references and conclusions made within the proposal are necessarily accurate or agreed
with.
City response: We acknowledge your request and recognize your proposal as utilizing the Work Area
Method of the 2015 International Existing Building Code (IEBC) by which to justify the proposal. Be
aware that this method is the compliance approach to be applied not just to the basement, but to the
entire existing building as required by IEBC 301.1. There are actually two issues in which the existing
building does not conform to the required code standards.
1. The basement ceiling height, as measured by the city building inspector (and as documented on
the energy code forms for lighting), is actually 6'-9" finished, nine inches shy of the 7'-6"
minimum required by IBC 1003.2.
2. The riser heights within the stairs to the basement are 7% inches, exceeding the maximum
height of 7 inches allowed by IBC 1011.5.2.
Ceiling height
It is unlikely that the ceiling height ever complied with code standards for single family residential
construction. However, several factors lend support to allowing the space to be used as proposed. The
building itself appears to be otherwise generally compliant with residential code requirements prior to
the current change of occupancy project, and has been designed to comply with the applicable
requirements for the proposed used as a commercial building. The new use has been evaluated for
compliance within the hazard risk categories for Means of Egress, Heights and Areas and Exposure of
Exterior Walls, as required by the IEBC. The proposal indicates the basement will not be used by the
public, in which case it will be limited to employees, who will likely become accustomed to the short
ceiling height, and not find it to be a hazard or deterrent to normal egress from the space. The small
size of the building, the small occupant load and the short travel distance to the front exit door also
contribute to relative safety of the occupants of the basement. The voluntary upgrade of exterior walls
to one hour construction, although not within the category of means of egress, also improves the overall
safety of the building occupants. Along with these factors, it is also recognized by the building official
that the existing ceiling height does not constitute a distinct hazard to life, thus the basement is hereby
approved for use as proposed.
Stair riser height
IEBC section 1012.4.2 states "When a change of occupancy classification is made to an equal or lesser
hazard category as shown in Table 1012.4, existing elements of means of egress shall comply with the
requirements of section 905 for the new occupancy classification." Section 905 defers to section 805
which states in exception 2 to section 805.4.4.1 "Means of egress conforming to the requirements of
the building code under which the building was constructed shall be considered compliant means of
egress if, in the opinion of the building official, they do not constitute a distinct hazard to life." Since the
stair risers were obviously in compliance with the standards of the International Residential Code prior
to the current change of occupancy project, and exceed the maximum allowed height by only inch, it
is determined that they do not constitute a distinct hazard to life, and are hereby approved for continued
use at the existing height.
Thank you,
r
Leif Bjor ack
Building Official
City of Edmonds
(425) 771-0220
Cc: Beth Sanger
File
December 4, 2018
Attn: Leif Bjorback
City of Edmonds
121 511, Ave N
Edmonds, WA 98020
architecture design
We are requesting the use of the basement for office, laundry, storage and employee break room at the
Ombu Salon permit #BLD20181021 per the Alternate Design and Methods section from IBC 2015
104.11. The basement would not be allowed for customer use. The existing ceiling height of
approximately 6'-10" in the basement does not meet the means of egress code requirement of 7'6" for
ceiling height. Although, the ceiling height does not meet the letter of the code, we would like to propose
the use of the basement for the purposed listed above and based on the below listed code sections and
compliance.
1. The building meets the requirements for height and area for the proposed occupancies of B at
the main floor and B in the basement.
-IBC Table 504.3 Building height — based on this table the building is in conformance for
building height for occupancy of B.
-IBC Table 504.4 Number of stories above the grade plane — based on this table the building is
in conformance for the proposed occupancies of B.
-IBC Table 506.2 Area allowed — based on this table the building is in conformance for the
proposed occupancy of B.
2. The building permit issued for the project has a requirement to install the required 1 hour fire
resistance rating for the existing walls which are between 5'-10' from the property line. The
existing basement would fall into a portion of the building located between 5'40' from the
property line. The exterior walls would not need to be rated based on the equal hazard class
IEBC 1012.62. We will continue forward with the plan to fire rate the walls to offset the lack of
compliance for the riser height on the existing stair (see #6 below).
-IBC Table 602 Fire resistance rating for exterior walls —the issued building permit is proposed
to install the required 1-hour fire resistance rating for the exterior walls for areas between T-10'
from the property line which will meet the requirement for the basement use of B. IEBC
1012.6.2 equal hazard class for existing walls will override the IBC requirement and thus the fire
rated walls would not be required.
3. The existing basement does not meet the means of egress requirement for ceiling height.
-IBC 1003.2 Ceiling height is required to be TV for means of egress. The existing basement
does not meet this requirement.
-IEBC 704.1 Alterations shall be done in a manner to maintain the level of protection provided
for means of egress.
-IEBC 803: No vertical openings other than the stair proposed. Interior wall finish will be '/z"
painted gypsum wall board to comply with the IBC for interior finishes. The stair will be
equipped with handrails at guardrail at the main floor level as proposed in the approved permit.
-IEBC 804: Exits are not serving an occupant load greater than 30 occupants.
-IEBC 805.2.2 Means of egress conforming to the requirements of the building code under
which the building was construction shall be considered compliant means of egress if, in the
opinion of the code official they do not constitute a distinct hazard to life. With the change of
use, the hazard class will be deemed equal between the existing R-3 and B occupancy. The
means of egress is not proposed to be more unsafe than the existing condition. All other
aspects, other than the ceiling height at the basement, meet the current building code and do not
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create a distinct or greater hazard to life. Means of egress lighting and exit signs will be installed
to comply with IEBC 805.7, IEBC 805.8, IEBC 905.2 and IEBC 905.3.
-IEBC 805.3 Exiting requirements are met with the information above.
-IEBC 1005 Shall comply with Section 1012 as noted below in #4.
4. The occupant load and maximum distance to the exits meets the current code requirements if
the basement is converted to a B occupancy. The existing basement for `business areas'
occupancy is 681 sf/100 gross = 6.8 or 7 occupants. The combined occupant load (for main
floor and basement) at front exit door will be 29 occupants, which meets the requirements for
one exit Maximum distance of common path of egress travel distance from furthest point at
lower floor to main floor front exit door is 70' which meets the below listcd requirements.
-IBC Table 1004.1.2 Maximum floor area allowance per occupant for business is 100 gross.
-IBC Table 1006.2.1 Maximum occupant load of space with one exit, B=49. Maximum common
path of egress travel distance without sprinkler system for occupant load over 30 occupants is
B=75'.
-IBC 1006.3.2 (2) Stories with access to one exit: B = 49 occ, 75' travel distance
-IBC Table 1006.3 Path of egress travel to an exit shall not pass through more than one adjacent
story. (Meets this requirement)
-IBC 906.1 Portable fire extinguishers shall be installed.
5. Change of use to convert the existing single family to a B occupancy meets the requirements.
Height and area hazard category for R-3 and B are equal at #4. As noted in #1 above, the
height and areas comply.
-IEBC1012.4.2 Means of egress for change of use to equal hazard category. Existing elements
of means of egress shall comply with the requirements of Section 905 for the new occupancy
classification. See #3 above.
-IEBC Table 1012.5 Heights and Areas hazard category. R 3 and B area equal #4.
-IEBC 1012.5.2 Height and area for change to equal hazard category. The height and area of the
existing building are deemed acceptable.
6. Existing stairway, 39-1/4" in width, is currently not enclosed, but would be in compliance with
width requirements. The existing risers are not in compliance at 7-1/4" tall and the existing
treads are in compliance at 11-1 /47. The ceiling height at the stair meets the required head
height of 80" above the finish nosing and is in compliance. To bring the stair risers into
compliance would be a financial hardship on the Owner. In order to bring the stair riser into
compliance, the following work would need to be performed: structural modification to the
floor system to allow for a long stair run to meet the rise/tun, relocating the hallway wall at the
lower floor to maintain the required 3' clearance, and installing new finishes (drywall, trim,
flooring, lighting, and paint) due to the work of modifying the stair and hallway wall.
-IBC 1019.3.1 Exit access stair that serve only two stories are not required to be enclosed.
-IEBC Table 1012.4 B and R3 are equal means of egress hazard category #4.
-IEBC 2015 1012.4.2 Means of egress for change of use to equal or lower hazard category
indicates that the existing stair would need to be brought up to current compliance for the stair
run.
-Basement to comply with IEBC 905 (Lighting and existing signs) and 805.
7. Ventilation would need to meet IMC 2015 403.3 mechanical ventilation requirements. The
ventilation for the basement would be part of the system serving the other areas of the building.
Each space would be provided ventilation based on the individual requirements.
IMC Table 403.3.1.1: Minimum ventilation rates for various occupancy classifications.
8. Energy code requirements
-WSEC Table C402.1.3: Basement walls to be minimum of R-21. WSEC C503.1.3 Existing
ceiling, wall or floor cavities exposed during construction provided that these cavities are
insulated to full depth with insulation having a min nominal value of R-3.0/inch.
-Heating and cooling system in basement to comply with WSEC C403.
23020 Edmonds Way, -113, Edmonds, WA 98020 1 p. 206.542.3734 1 e. heidCh2darchitects.eom I w. h2darchitects.com
As noted above, the existing low ceiling height at the basement does not meet the letter of the code, but
the intent for the use of the existing space does not create a more hazardous Condit ion. To increase the
safety of the building, the exterior walls will be converted to a I hour fire rating, although this
requirement would not be necessary for the existing building use.
I can be reached at 206-542-3734 or at licidi@h2darchitects.coni with any further questions.
Regards,
Heidi Helgeson
Principal
H2D Architecture + Design
23020 Edmonds WcU, -113, Edmonds, WA 9"0 1 p. Wo.542.3734 1 e. I w. h2ckrd*Ieds.com