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Plan Review Comments
May 13, 2021
Sunfield Education Association
Attn: Ezra Sullivan
111 Sunfield Lane
Port Hadlock, WA 98339
esullivan@sunfieldfarm.org
Re: Building Permit # BLD2021-00164, 111 Sunfield Lane, Port Hadlock
PROJECT DATA:
Architect of record:
(not sealed)
Richard Berg Architects, P.C.
727 Taylor Street
Port Townsend, WA 98368
360-379-8090
rberg@olympus.net
Engineer of Record:
(none identified)
Contractor:
(none identified)
PROJECT DESCRIPTION: (relocated) Modular Building for Classroom/Office Space
OCCUPANCY GROUP: B / E
TYPE OF CONSTRUCTION: V-B
NUMBER OF STORIES: 1
CODE EDITIONS: 2018 International Building Code (WAC 51-50); and
2018 International Mechanical Code (WAC 51-52);
2018 Uniform Plumbing Code (WAC 51-56);
2018 Washington State Energy Code (WAC 51-11R, WAC 51-11C);
Dear Mr. Sullivan,
The building design documents for the permit referenced above have been reviewed for
conformance with the locally adopted codes along with the Washington State amendments. This review
letter contains only those comments related to the Building Department’s review and does not reflect
any additional needs of any other division or City department. Please review the project data above,
and the plan review comments below. It is important that you then follow the instructions for re-submittal
following the plan review comments.
PLAN REVIEW COMMENTS:
1. Additional details are required on the site plan. Is there an accessible route of travel from the
public way to the proposed building? (IBC 1104.1) Are there accessible routes of travel between
buildings on the same site? (IBC 1104.2). Are the accessible parking spaces paved... and are
they provided with an accessible route between the parking and the building(s)? (IBC 1106)
Please clarify satisfaction all required IBC required site components.
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2. On the site plan, (and building floor plans) please identify all exterior exit doors, door landings
and egress paths to the exit discharge.
3. On the site plan, please identify the dimensions between the proposed buildings and any
existing buildings (indicating satisfaction of IBC 705 requirements).
4. Sheet (all). While the building is a manufactured unit, which must be installed in accordance
with the manufacturer's requirements - and it is very helpful to have the original design and
documentation - the installation is a new installation for which the entire project must fully satisfy
all minimum current code requirements. In accordance with the Washington State Building
Code, WA-IEBC Section 1401.2, buildings moved into the jurisdiction (Jefferson County) shall
comply with the provisions of the Washington State Building Code (WAC 51-50) including the
Washington State Existing Buildings Code; the Washington State Mechanical Code (WAC 51-
52); the Washington State Fire Code (WAC 51-54A); the Washington State Plumbing Code
(WAC 51-56); and the Washington State Energy Code (WAC 51-11C) effective at the time of
installation. Again, while the previous plans are helpful, they indicate that the unit will not satisfy
all current code requirements, particularly concerning the foundation system and the Energy
Code requirements. A set of complete plans will be required indicating how the existing
manufactured unit will be installed on a code compliant foundation system; how the unit will
satisfy all current building code and accessibility requirements; how the building will be altered
to fully satisfy all WSEC requirements; how mechanical systems will satisfy both IMC and WSEC
requirements, etc. The review cannot be considered complete until a complete set of
construction plans are provided.
5. The original plans indicate a fairly extensive exterior deck, entry canopy, stairs, ramps, etc., all
of which are noted to be site constructed. Is a similar configuration proposed for the new
installation? If so, please provide complete plans for the proposed (or relocated) components.
6. Sheet 1 of 5. The Women’s restroom stall configuration does not appear to be consistent with
ICC/ANSI A117.1 604.9.3. Please clarify and/or correct.
7. Sheet 5 of 5. The foundation system shall be designed by a licensed professional engineer.
While the foundation system shown may have been calculated and acceptable in 1992, seismic
and building technology has improved dramatically since then, and the design would not satisfy
the current foundation requirements of the 2018 International Building Code (IBC) as adopted
by the State of Washington and Jefferson County. While it might be tempting to try to draw
parallels with installations of manufactured homes, manufactured homes are designed to satisfy
the US-HUD code; this modular commercial building must be installed in full satisfaction of the
current IBC requirements. The new (calculated) foundation design must include a foundation
system founded on native or geotechnically designed and stabilized (compacted fill) soils below
the frost-depth of the area (at least 12 inches), and designed to provide a complete load path
from the unit to the ground as established in IBC Chapters 16, 18 and 19. Please provide a
complete foundation design.
8. Please confirm that the modular unit has been designed to support minimum floor loads as
established in IBC Table 1607.1 for the proposed office and classroom uses, including any
increased loading for corridor areas.
9. The building section provided indicates that the exterior envelope insulation will require
significant alteration in order to satisfy 2018 WSEC envelope requirements. While R-11 wall,
R-11 floor and R-30 attic insulation are shown, WSEC Section C402 requires, at minimum, R-
21 wall insulation, R-30 floor insulation and R-49 roof/attic insulation. Please identify how the
WSEC building envelope requirements will be satisfied.
10. Please provide a completed WSEC – Envelope Compliance form. WSEC forms may be
obtained online at: Washington State Energy Code (waenergycodes.com) .
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11. WSEC Section C406 requires each new building (or newly installed building) to provide
additional energy efficiency packages which will result in providing at least six “credits” in
accordance with WSEC Table C406.1. Please identify how WSEC C406 will be satisfied.
12. Sheet 1 of 5. If a range is to be provided in the meeting room/classroom, as shown, mechanical
exhaust shall be provided in accordance with IMC Section 507.1.2, (potentially including a Type
I commercial hood if any form of commercial cooking is to be performed) and the kitchen must
fully satisfy ICC/ANSI A117.1 Section 804 accessibility requirements, including provisions for
work spaces, forward approach sink, maneuvering clearances, etc. Please clarify what
equipment is truly proposed and provide all necessary documentation to indicate IBC, IMC and
ICC/ANSI A117.1 satisfaction.
13. Sheet 4 of 5. Do the HVAC units satisfy minimum WSEC efficiency requirements? Are they
provided with fresh air intakes that provide the minimum required ventilation air in accordance
with WA-IMC 401.2? Please fully describe how the HVAC system will satisfy current IMC and
WSEC requirements applicable to the occupancy.
14. Please provide a complete WSEC – Mechanical Compliance form. WSEC forms may be
obtained online at: Washington State Energy Code (waenergycodes.com) .
15. Sheet 4 of 5. The “Energy Code Lighting Budget” is antiquated and inconsistent with current
Washington State Energy Code (WSEC) Section C405 requirements. Please provide complete
WSEC – Lighting Compliance forms. WSEC forms may be obtained online at: Washington
State Energy Code (waenergycodes.com) .
16. Sheet 5 of 5. The water supply isometric illustrates a hot water supply system that would require
alteration in order to satisfy the minimum requirements of the 2018 Uniform Plumbing Code
(UPC) and 2018 WSEC. In particular, pipe insulation and either a hot-water re-circulation
system or heat trace system would be required to satisfy the requirements of WSEC Section
C404. Please clarify.
As noted, the plans are ultimately incomplete. Upon resubmittal of a complete plan, the review will be
continued which may result in additional comments, questions, etc. Unfortunately, the construction
plans cannot be recommended for approval for a building permit until all issues are fully resolved.
To re-submit plans:
Please make the required corrections and/or clarifications and submit a revised electronic copy of the
plans (.PDF or .DWF) clearly identifying all revisions.
Submitted electronically, once approved, the electronic set will contain the approval indications and will
be returned to the City electronically for the City record, and a copy will be provided to the
applicant/architect in order to print off an official “Approved Site Copy” of the plans to be maintained on-
site during construction. Electronic plans may be e-mailed to mbarth@codeproswa.com and copied to
dcd@co.jefferson.wa.us or instructions and passwords may be provided for us to download the revised
plans from a FTP site or similar arrangement, or they can simply be mailed on a CD or flash-drive to
the County office or the address below.
To aid in the timely review of the revised plans, please detail all corrections and/or revisions in a cover
letter, numbered the same as the comments above. Revisions should be marked on the sheets and
noted with a cloud surrounding them or some other method to distinguish the changes. Please also be
sure to identify if any other changes are made that are not associated with the plan review comments.
Design documents and calculations prepared by a registered architect or professional engineer must
include the design professional’s original signature, “wet” stamp, registration number and date; as
required under RCW 18.08 & WAC 308-12-081 for architects, or RCW 18.43 & WAC 196-23-020 for
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engineers; or, a “digital signature” as defined by the State of Washington. Additional Information in
regard to the Washington State design professional regulations, please see the “Guidelines for Building
Officials and Design Professionals prepared by Washington State Department of Licensing and
available at: https://www.dol.wa.gov/business/designproguidelines/index.html .
If you have questions or concerns about the review comments, please contact me directly at
mbarth@codeproswa.com .
Sincerely,
Michael J. Barth, M.C.P.
Building Code Consultant
CodePros, LLC
cc:Jefferson County DCD
Richard Berg Architects
Digitally signed by Michael J. Barth, M.C.P.
Date: 2021.05.13 18:06:08 -07'00'
Aug 03 2021