Appeal 16119

2014 OSSC 2903.2

Where substantial alterations are made to existing Group A occupancies with an occupant load in excess of 300, water closets, as specified in Table 2902.1 for new construction, shall be provided.

Fixture totals required per Table 2902.1:
9 men’s water closets
16 women’s water closets

Lents Park’s Walker Stadium is an existing building that has undergone renovation and repair to prepare the facility for use by a local amateur baseball team. These renovations were limited in scope, and did not change the occupant load of the stadium. They did, however, trigger the requirement of 2014 OSSC §2903.2 that water closets be provided according to Table 2902.1.

The existing permanent fixtures at Walker Stadium are fewer than the minimum required by the 2014 OSSC. A set of appeals (#13173 and #14990), allowed the stadium to operate during the 2016 and 2017 seasons with additional temporary fixtures, but called for permanent facilities to be provided at Walker Stadium in the future. In lieu of providing plumbing fixtures according to Table 2902.1, we propose using the Portland Parks & Recreation Department’s method for minimum plumbing fixture estimates as a permanent alternate for Walker Stadium.

The proposed design includes:
5 new permanent all-user (not gender-specific) water closets
5 new permanent all-user lavatories
Equivalent temporary fixtures to be provided until construction of the new facility is completed. The completion date is estimated to be in 2020.

Walker Stadium’s existing plumbing fixture count is as follows:
5.3 men’s water closets (2 urinals at 0.66 of a water closet)
5 women’s water closets
These facilities were considered adequate for the stadium from its construction in 1950 until the adoption of the 2014 OSSC. Recent renovations to the stadium have been limited to replacement of deteriorating elements, miscellaneous repairs, and minor site improvements. Although the renovations meet the technical definition of a “substantial alteration” based on project budget, the essential functions and features of the facility -- including seating capacity, occupancy group, and occupant load -- remain unchanged. Only the plumbing fixture minimums established by code have increased.

Portland Parks & Recreation has allocated funds to build a new restroom facility adjacent to Walker Stadium. This facility will be separate from the existing stadium structure, but will be used by spectators and fans during the Portland Pickles’ amateur baseball games. Outside of game times, the restroom facility will be made available for use by other park visitors.

The A-5 plumbing occupancy in Table 2902.1 is designed to accommodate large-scale athletic events in sports arenas. In contrast, Walker Stadium hosts amateur baseball games at a maximum seated spectator capacity of 1,073, with an average attendance of approximately 1,407 when additional fans watch the game from outside the stadium. These games are shorter than professional athletic events and lack the coordinated break times of other sports such as football, which results in a more evenly distributed demand on the plumbing facilities and less queuing at the restrooms. Providing plumbing fixtures based on Parks & Recreation Department data documenting historical demand is more appropriate for Walker Stadium than basing them on A-5 functions in dissimilar contexts.

Portland Parks & Recreation has developed a consistent and effective strategy for determining plumbing needs at events permitted through the City. They require 1 restroom per 125 persons in estimated daily attendance. Portland Parks & Recreation monitors permitted events for deficiencies in or complaints about plumbing fixture availability. They have found that the 1 to 125 ratio is sufficient for crowds who attend events similar to those hosted by Walker Stadium, such as softball and soccer tournaments, even in cases where attendees may be consuming food and beverage over an extended period of time. See attached statement from Portland Parks & Recreation.

Using Portland Parks & Recreation’s ratio, only 12 total water closets would be required for 1,407 estimated attendees at an amateur baseball game. These toilets could be a combination of men’s restrooms, women’s restrooms, and all-user port-a-potties totaling at least 6 available toilets each for men and women. The existing toilet fixtures in Walker Stadium are 5.3 for men and 5 for women. Adding only two additional fixtures would be adequate for permitting a Portland Pickles event. The proposed design, which adds 5 new all-user water closets to the existing fixtures, provides well over the minimum number of fixtures according to this method.

Portland City Council’s Resolution 37175, passed in 2015, mandates the provision of all-user restrooms in City facilities. By providing all-user facilities, the proposed design allows for gender parity during periods of peak demand. In a traditionally gendered restroom design, women would have access to the existing women’s restroom, and only half of the new fixtures – a maximum of 8 total. The men’s restrooms, meanwhile, might stand empty. With an all-user design, female and male baseball fans will both have access to up to 10 fixtures, as the new facilities adapt to the actual gender ratio of the users. The addition of the proposed all-user restrooms will also increase access to safe and comfortable restrooms for parents with children, individuals relying on personal attendants, and transgender or non-binary persons, among others. This design is consistent with the City of Portland’s stated goals for non-discrimination on the basis of gender identity.

Based on Portland Parks & Recreation’s documented history of success with a 1 to 125 plumbing fixture ratio, an attendance count that reflects actual ticket data greater than tabulated occupant estimates, and the City’s commitment to gender-neutral policies, we believe the proposed design will be more than adequate to serve visitors to Walker Stadium. As an added value, the restroom facility will also contribute to a better overall Lents Park experience for visitors on non-game days.