BCAB #1911

July 20, 2023

Re: Alternative Solution to Address Spatial Separation Requirements

Project Description:

The project consists of six buildings, five of which are sprinklered, single storey self-storage buildings classified as Group F, Division 2 major occupancy. The five self-storage buildings vary in individual building area from 390 m² to 1161 m² (the combined total building area is 3826 m2) and are of noncombustible construction including noncombustible cladding.

The other building is two storeys and contains an office and dwelling unit. The two storey structure does not form a part of this Appeal.

The appellant has provided an Alternative Solution to address the spatial separation requirements contained in Subsection 3.2.3. regarding the distances between the five self-storage buildings. This Alternative Solution utilizes an approach of combining the building areas of the five buildings in order to consider it as a single building and applying the corresponding construction requirements contained in Subsection 3.2.2. relevant to the resulting building area.

Applicable Code requirements: (BCBC 2018)

3.2.3.1. Limiting Distance and Area of Unprotected Openings
1) Except as permitted by Articles 3.2.3.10. to 3.2.3.12., the area of unprotected openings in an exposing building face for the applicable limiting distance shall be not more than the value determined in accordance with
a) Table 3.2.3.1.-B or 3.2.3.1.-C for an exposing building face conforming to Article 3.2.3.2. of a building or fire compartment which is not sprinklered, or
b) Table 3.2.3.1.-D or 3.2.3.1.-E for an exposing building face conforming to Article 3.2.3.2. of a sprinklered fire compartment that is part of a building which is sprinklered in conformance with Section 3.2.

3.2.3.7. Construction of Exposing Building Face
2) Except as provided in Sentences (3) and (4) and Article 3.2.3.10., the fire-resistance rating, construction and cladding for exposing building faces of buildings or fire compartments of Group E or Group F, Division 1 or 2 occupancy classification shall comply with Table 3.2.3.7.

3.2.3.14.
3) Sentence (1) does not apply to unprotected openings of fire compartments within a building that is sprinklered throughout, but shall apply to
a) unprotected openings of fire compartments on opposite sides of a firewall, and
b) exposure from unprotected openings of a fire compartment that is not protected by an automatic sprinkler system.

Decision being appealed: (local authority’s position)

The local authority has determined that the Alternative Solution mentioned in the project description above has not addressed all applicable acceptable solutions. In addition, it attempts to write new code requirements by referencing other technical documents out of context without applying full consideration to how each requirement may affect another.

Appellant's position:

The appellant considers that the proposed Alternative Solution provided will achieve at least the minimum level of performance required by Division B in the areas defined by the objectives and functional statements attributed to the applicable acceptable solutions regarding Subsections 3.2.2. and 3.2.3.

Appeal Board decision #1911:

It is the determination of the Board that although the Alternative Solution provided has merit, the appellant has not provided enough supporting technical documentation for it’s acceptance in accordance with 1.2.1.1.(1).(b).

Reason for decision:

The Code does not contain a provision which permits the combining of separate buildings to facilitate treating these structures as a single building. The Board recognizes that this may be accomplished through an alternative solution.

The review of an Alternative Solution is based on the materials presented. The provided Alternative Solution did not include sufficient supporting technical documentation.

Doug Vance
Acting Chair, Building Code Appeal Board