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BUILDING REVIEW BOARD
May 27, 1994
Minutes
The Building Review Board was called to order by Chairman Mike
Sutton. Members present: Sutton, Cornell, Cotterman, Goldrich.
Absent: Kruel-Froseth, Hansch.
Staff Present
Staff Liaison:
Council Liaison:
Felix Lee
Ann Chantler
Paul Eckman
Felix Lee
Ann Azari
Guests Present: Tom Sibbald, RLS
Frank Vaught, Architect
Mike Sibbald, Shields Street
Rusty Collins, Neighbor to Neighbor
Tom Sibbald appeared before the Board representing the appellant,
Shields Street Corp. He stated he did not agree with the Building
Official's interpretation of the Uniform Building Code, chapter 31,
Section 3105. As the builder of this project, he felt he was
meeting the code requirement by providing ground floor apartments
with at least one bathroom that was completely accessible. He cited
the Fair Housing Act and HUD codes. Sibbald indicated that to make
both bathroom toilet facilities fully accessible as specified by
City staff, would force him to eliminate the shower in the second
bathroom.
Frank Vaught, architect for the project, stated the wordage in this
section of the code was the problem. He presented to the Board a
copy of the blueprints for the proposed units. He stated the Fair
Housing standards require that only one bathroom in an accessible
unit need be totally accessible, and the proposed plans comply. The
proposed project has units with two bathrooms, one completely
accessible and the other partially accessible. Mr. Vaught reviewed
the requirements for making a bathroom accessible.
Paul Eckman, attorney for the City of Fort Collins, explained the
process and reviewed the charge of the Board.
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Building Review Board
May 27, 1994
Page 2
Felix Lee, Building Official, stated the code was specific when
referring to the type of building regulated. Quoting from Section
3105 (b) 2 he read, "Toilet facilities located within accessible
dwelling units, guest rooms and congregate residences shall comply
with U.B.C. Standard No. 31-1.11. Felix stated he contacted I.C.B.O.
for additional clarification, verifying Felix was interpreting the
code correctly. Mr. Lee stated a person with a disability may have
a choice of where and when to bathe, but may not have that choice
when using the water closet. Lee reiterated his position that the
code states all toilet facilities within accessible dwelling units
are to be accessible.
Rusty Collins, Executive Director of Neighbor to Neighbor,
addressed the Board. He stated he has done research on rentals in
Fort Collins that are accessible and is the Vice President of the
Task Force for Handicapped Citizens. Collins said he has done
extensive research on the ADA and Fair Housing Act, as part of his
post graduate studies. He voiced support for the appellant and
supports this appeal.
Felix stated he sent the packet for this appeal to the staff
liaison for the Commission on Disability, but did not receive any
response from the Commission until the day before the hearing, when
the Chairperson, Shirley Reichenbach said she could not attend the
hearing but would ask someone else to attend.
Board chairman, Mike Sutton, stated he agreed with the Building
Official's interpretation of the code.
A lengthy discussion followed debating bathing facilities vs.
toilet facilities.
Board member Cotterman asked Mr. Vaught if any compromise was
possible by re -doing the shower facilities so that some had showers
and some did not.
Mr. Sibbald stated this project qualified as low-income housing and
they needed to abide by certain standards. He noted that in the
management position for the renting units, having some with and
some without showers would put him in a difficult position and
could even cause legal problems. Sibbald concluded by saying if the
appeal were denied, none of the units with two bathrooms would have
a shower in the second bathroom.
Building Review Board
May 24, 1994
Page 3
Mr. Vaught stated he believed this was an issue for the Board to
consider relief from the code rather than interpretation of the
code.
Board chairman Sutton stated he still agreed with Mr. Lee's
interpretation of the code but would consider "relief from
design", as allowed in Section 204 of the City Building Code.
Board member Cotterman moved that the Building official's
interpretation of Section 3105(b)2 of the Building Code was
correct. Board member Goldrich seconded the motion. Yeas: Sutton,
Cotterman, Goldrich. Abstain: Cornell. The motion passed.
Board member Goldrich moved to approve "design relief" to allow
the second 3/4 bath (toilet stool, shower and lavatory) as proposed
by the appellant in lieu of a half -bath (assessible toilet, stool
and lavatory) and eliminate the requirement for full length grab
bar backing and required full clear floor space at the toilet
stool. Sutton invited further discussion expressing concern that
all other accessible features be in place, including the removable
vanity under the lavatory and backing for a modified grab bar, and
the accessible route is maintained into the second bathroom.
Concluding the discussion, Sutton restated the motion for clarity
to allow design relief for construction of a second bathroom which
does not meet the specific requirements for floor space in front of
the toilet and a full grab bar for backing dimension, but all other
accessibility requirements are to be designed into the project.
Board member Cotterman seconded the motion. Yeas: Sutton, Cornell,
Goldrich, Cotterman. The motion passed.
Doug Audley contractor appealing to the Board for a Class D license
and certificate, was not present.
Board member Goldrich moved to deny license and certificate for
Doug Audley because of lack of job verifications. Board member
Cotterman seconded the motion. Yeas: Sutton, Cornell, Goldrich,
Cotterman. The motion passed.
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Building Review Board
May 27, 1994
Page 4
The meeting was adjourned.
Mike Sutton, Chairman
Felix Lee, Bldg Official
BUILDING REVIEW BOARD
May 26, 1994
Building Code Appeal Hearing
CASE No.
APPELLANT:
Shields Street Corporation
AFFECTED PROPERTY:
Rose Tree Village Apartments (Proposed 120-unit PUD)
The appellant disagrees with the Building Permits and Zoning
Division Director's interpretation of Section 3105(b)2. of the
recently adopted 191 UNIFORM BUILDING CODE. This provision
specifically states, in part, "toilet facilities located within
accessible dwelling units,. . . shall comply with U.B.C. Standard
No. 31-111, with no further qualifier about limiting the provision
to only one toilet facility in any given accessible unit. Staff
conferred with an official at ICBO headquarters and confirmed that
the provision in question does not limit itself to a single toilet
facility in a unit which contains more than one toilet facility.
However, in "other occupancies", the provision does specify that,
"at least one accessible water closet shall be provided."
MITIGATING FACTORS:
The appellant has provided the attached information describing
their rationale for the request, citing the "intent" of the FEDERAL
FAIR HOUSING ACT and the ANSI standards.
brb594.ap1
010940 • •CASE NO.
Va Li dation
Account Number 1014416E
CITY OF FORT COLLINS
REQUEST FOR HEARING BY THE BUILDING REVIEW BOARD
Affected Property Rose Tree Village Apartments
Owner Shields Street Copporation
Address 2301 Research Blvd. Suite 204A
Appellant Vaught Frye Architects
Address 1113 Stoney Hill Dr. Phone 224-1191
Description of Request and Mitigating Factors: —The BUilding_Inspection
Yppartment has interpreted Chapter 31 of the UBC to require that when
2 bathrooms are provided in an apartment, each of them have to be
fully accessible. We disagree with this interpretation and offer the
attached letter to request the Board to intervene.
Applicable Code Sections:_ Chapter 3��fec.j9Z—_____�
— 1 i . --- ------------ — Apr i l 21, 1994
Appellant Si. na i4re Date
AppellLinf may appear in person, in writing, 'or by agent and should be pre-
pared'Ca_ t qii -relevant details, specifications and plans, or ocher
evidrnce' $Lancing of this petition at the hearing time indicated
below.-tarings are scheduled for the Last Thursday of each montn
at 9:15` Council Chambers at 300 Lal'urte Avenue. Applications
accompa 50.00 docket tee should be tiled one week before the
desired date to ensure
considerat10n.
OFFICE USE ONLY
HEARING DATE AND TIME
DISPOSITION AND CONDITIONS
Authorized by Date
Distribution: Original - Appellant, lst copy - File, 2nd copy -Office
VAU9HT * FRYE ARCH*ECTS
TRANSMITTAL LETTER
DATE: ��r, 2 / ,4
PROJ./NO.: Axe Try VI//a9e
TO: C//V o� R7/ C9//1n5
ATTN: Z);m
ENCLOSED PLEASE FIND:
COPIES OF:
B wLdiAn Aevfew &wd 6 /
Forward
Prints
_ Returned
7 Original
_ Specifications
_ Shop Drawings
Computer Disk
REMARKS:
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T am Scsbrnif-fin�
93-32
For Approval —Mail
_ For Your Use
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UAUGHT
FRYE
architects
April 21, 1994
Building Review Board
City of Fort Collins
281 N. College Avenue
Fort Collins, CO 80521
Re: Rose Tree Village Apartments
Gentlemen:
The Building Inspection Department has concluded that if an
apartment offers two bathrooms, both have to meet the requirements
of ANSI 1992, that is to say they each have to be fully accessible.
They base their conclusions on U.B. C. Chapter 31, Section 3105
(2), Toilet facilities which states "Toilet facilities located
within accessible dwelling units, guest rooms and congregate
residences shall comply with U.B.C. Standard No. 31-1.11
The paragraph just above this (b) 1. Bathing facilities, states
"When bathing facilities are provided, at least 2 percent, but not
less than one bathtub or shower, shall be accessible.
There appears to be a distinction between bathing and toilet
facilities that would be a clear conflict in an apartment
configuration. It is our opinion that in an apartment, bathing
facilities refers to a bathroom and toilet facilities refers to
common facilities as found in dormitories, congregate housing etc..
Further research of past and current ANSI Standards previously and
currently enforced by the City indicates the following:
ANSI - 1980
4.34.2 (12) A reasonable number, but always at least one of
full bathrooms shall comply with 4.34.5. A full
bathroom shall include a water closet, a lavatory
and a bathtub or a shower.
ANSI - 1986
4.32.4 Accessible bathrooms shall be on an accessible
route and shall comply with the requirements of
4.32.4.
land planning • architecture
1113 Slonev Hill Drive • Fort Collins, Colorado 80525 • 303-224-1191 • FAX 303-224-1662
Building Review Board
Page 2
ANSI - 1991
4.33.3 Bathrooms. Accessible bathrooms shall comply with
4.33.3
ANSI 1992 only refers to accessible bathrooms needing to comply
with the standards and is unclear on the issue of how many, however
it is obvious from previous ANSI standards and Federal Housing
Design Guidelines that the intent is to provide one full bathroom
that complies with the design standards.
Regulation 7, Usable Kitchens and Bathrooms of the Fair Housing
Design Guidelines, states "At least one bathroom in the dwelling
unit complies with the provisions of paragraph (b) and all other
bathrooms and powder rooms within the dwelling unit must be on an
accessible route with usable entry doors in accordance with the
guidelines for Requirements 3 and 4."
It is unfortunate that Chapter 31 is confusing and unclear and that
our local officials are subject to forming their own
interpretation, however it is clear to me that the intent of the
Fair Housing Act that in an apartment, only one bathroom is
required to be accessible and that if two are provided then the
second need only be on an accessible route with usable entry doors.
Requiring a developer to provide two accessible bathrooms adds
additional square footage to the unit, which only translates in to
additional construction cost and higher rents to the consumer.
I hope you will give careful consideration to our request and
concur that the interpretation concluded by the Building Department
is incorrect and goes beyond what is intended to meet the Design
Standards.
Thank you for your consideration.
S' ly,
Fran Vaught
VAUGHT*FRYE ARCHITECTS
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