Appeal 33457

Table 1004.5 maximum floor area allowances per occupant.

This table lists occupant load factors for various building functions.

Table 1004.5 does not list an occupant load for a skateboard park but allows the building official to rule on unlisted functions; we are proposing an occupant load appropriate to the function.

A new canopy structure of approximately 10,000 sf is proposed to shelter skating surfaces from the elements. We propose that an occupant load factor of 200 gross sf per occupant be used to calculate occupant load.

Table 1005.5 does not list a function that resembles the proposed skateboarding activity. A skateboard park features users moving at a high rate of speed in specific patterns over curved, vertical, sloped and flat surfaces. Many of these surfaces cannot be occupied except by a moving skateboard. Based on the design of this particular park and skatepark design best practices, we believe 200 gsf per occupant is an appropriate load. Note that due to the varying topography of the skatepark, it would be very difficult to use this area for any other function. We believe this occupant load is appropriate and will provide equivalent life safety and fire protection to what the code requires.

Section 2902.3.3 location of toilet facilities in occupancies other than malls.

This section requires that required public toilet facilities be located not more than one story above or below the space, and the path of travel to them shall not exceed 500 ft.

We are requesting a path of travel distance greater than 500 ft. Creston Park does not have more than one “story”, but the toilet facilities are located at a higher elevation than the skatepark canopy structure.

The new skatepark canopy structure will be located in the northeast portion of the park, near the existing pool. The existing primary park restrooms are located in the southern portion of the park. The path of travel from the structure to the restrooms is up to 580 ft in distance and 43 ft of elevation gain, depending on the destination restroom. Note that public toilets in the nearby existing pool building are also available on a seasonal basis, aligning with skatepark peak use.

The proposed skatepark was sited to meet several important functional criteria, including efficient use of public funds. Although the skatepark is not sited close to existing primary park restrooms, extended travel distances up to 1,200 ft have been approved in past Parks projects - reference appeal #31337 (reconsideration of 28278).

There are no prescribed maximum walkway distances to restrooms for Park structures in the OSSC or City code. The closest comparable guidelines are in OR-OSHA OAR 437-004-1110 and Directive 097 with respect to portable toilets provided for farm workers or construction workers to be located within a 5-minute walk, not greater than ¼ mile (1,320ft). PP&R provides accessible walkways to the extent practicable to all toilet facilities.

We believe the proposed configuration provides equivalent health accommodation to what the code requires.