Appeal 35073

OFC 507.5.1

FIRE HYDRANTS - ONE- AND TWO-FAMILY DWELLINGS AND ACCESSORY STRUCTURES: Where a portion of a structure is more than 600 feet from a hydrant on a fire apparatus access road, as measured by an approved route around the exterior of the structure(s), on-site fire hydrants and mains shall be provided, or an appeal granted.

Instead of on-site fire hydrants, we propose to provide residential fire sprinkler systems to each structure on site over 600' from the fire hydrant.

A public fire hydrant is located at the northeast corner of SE 58th Avenue and SE Clinton Street and serves all structures within the development except Unit 10. Unit 10 is located approximately 612 feet from this hydrant, exceeding the code threshold by roughly 12 feet. To mitigate this minor exceedance, Unit 10 will be equipped throughout with an NFPA 13D residential fire sprinkler system utilizing 4.9K sprinkler heads. In addition, the building will be constructed with non-combustible roofing and siding materials to further reduce fire risk. The Portland Water Bureau has confirmed that the serving hydrant provides a flow rate of approximately 2,500 GPM, which exceeds typical residential firefighting demand and supports effective fire suppression operations.

Requiring a private on-site hydrant for a single residential unit that exceeds the hydrant distance by a minimal margin would impose a disproportionate financial and long-term maintenance burden on the property owners, particularly given that surrounding properties with comparable access distances are served exclusively by public hydrants. The proposed alternative provides a higher level of life safety and property protection by delivering early, automatic fire suppression directly within the structure, significantly reducing fire growth potential prior to fire department arrival. When combined with non-combustible exterior construction, the proposed design achieves an equivalent—or superior—level of fire safety to that intended by the prescriptive hydrant requirement, while allowing the project to proceed in a reasonable and practical manner.

OFC 503.1.1

Access roads shall be within 150 feet of all portions of the facility and all portions of the exterior walls of the first story of the building as measured by an approved route around the exterior of the building or facility. When the building is equipped throughout with an approved automatic sprinkler system, access roads shall be within 250 feet of all portions of the facility and all portions of the exterior walls of the first story of the building as measured by an approved route around the exterior of the building or facility.

Allow construction of Unit 5 without an automatic fire sprinkler system where portions of the structure exceed the 150-foot fire apparatus access distance, based on enhanced passive fire protection measures and maintained fire department access that provide equivalent fire safety to the prescriptive requirement.

Unit 5 will be constructed with non-combustible roofing and siding materials to reduce ignition potential and limit exterior fire spread. These materials significantly lower the likelihood of exterior fire involvement and contribute to improved firefighter safety during suppression operations.

Fire department access to Unit 5 is provided from the approved fire apparatus access road via a combination of designated fire access easement paths and standard access routes utilizing the on-site driveway and pedestrian walkways, as shown on the site plan. Portions of the hose drag route traverse maintained lawn areas within the access easements. These areas are generally flat in grade, free of obstructions, and will be maintained to remain accessible for emergency operations. Any gates located between properties along these access routes will remain unlocked at all times to ensure uninterrupted fire department access.

Based on the approved access routes, which include a combination of paved walkways and maintained lawn areas, the hose drag distances to Unit 5 range from approximately 160 to 166 feet, as measured along the approved route.

A comprehensive vegetation management and defensible space strategy will be implemented within 30 feet of the structure to further reduce fire risk. All new plantings will consist of fire-resistant native species characterized by low aromatic oil content, high live fuel moisture, deep root systems, low total fuel volume, and minimal ladder fuel characteristics. Vegetation will be maintained in a healthy condition, with dead or diseased material promptly removed and disposed of outside of the vegetation management area. Mature trees within 30 feet of the structure will have lower limbs pruned to remove ladder fuels up to a minimum height of six feet above grade.

Landscaping will be arranged to maintain adequate separation between vegetation and the structure. Low-growing fire-resistant shrubs (average mature height of three feet or less) will be located no closer than six feet from the structure and from adjacent planting groups at maturity. Taller fire-resistant shrubs will be located no closer than ten feet from the structure, with plant size increasing progressively as distance from the structure increases. Fire department access routes, including fire access easements, driveways, pedestrian walkways, and lawn areas used for access, will be maintained clear and unobstructed at all times.

The intent of OFC 503.1.1 is to ensure timely and effective fire department access for initial fire attack operations. This requirement is intended to support apparatus placement, hose deployment, and firefighter mobility rather than to establish a rigid distance threshold absent operational context.

Unit 5 exceeds the 150-foot access requirement by a limited and quantifiable margin, with measured hose drag distances ranging from approximately 160 to 166 feet, representing an overage of approximately 10 to 16 feet (approximately 7 to 11 percent) beyond the prescriptive limit. This incremental increase is less than one standard hose length and does not materially affect apparatus positioning, hose advancement, or firefighter effectiveness.

Fire department operations will originate from the same approved fire apparatus access locations that would be utilized if the structure were within the 150-foot limit, using predictable access routes that are flat in grade and free of obstructions. Although portions of the hose path traverse maintained lawn areas, these areas do not introduce grade changes, pinch points, or operational constraints that would adversely affect firefighter movement or hose deployment.

When considered collectively, the proposed non-combustible exterior construction, permanently maintained defensible space within 30 feet of the structure, and clearly defined access routes provide a level of fire safety and operational effectiveness equivalent to that intended by the prescriptive access distance requirement, while accommodating site constraints that make strict compliance impractical.

OFC 503.1.1

Access roads shall be within 150 feet of all portions of the facility and all portions of the exterior walls of the first story of the building as measured by an approved route around the exterior of the building or facility. When the building is equipped throughout with an approved automatic sprinkler system, access roads shall be within 250 feet of all portions of the facility and all portions of the exterior walls of the first story of the building as measured by an approved route around the exterior of the building or facility.

Allow construction of Unit 6 without an automatic fire sprinkler system where portions of the structure exceed the 150-foot fire apparatus access distance, based on enhanced passive fire protection measures and maintained fire department access that provide equivalent fire safety to the prescriptive requirement.

Unit 6 will be constructed with non-combustible roofing and siding materials to reduce ignition potential and limit exterior fire spread. These materials lower the likelihood of exterior fire involvement and support firefighter safety during suppression operations.

Fire department access to Unit 6 is provided from the approved fire apparatus access road via a clearly defined primary access route utilizing the on-site driveway and pedestrian walkways, supplemented by a designated fire access easement path shown on the site plan. Portions of the hose drag route traverse maintained lawn areas within the access easement. These areas are generally flat in grade, free of obstructions, and will be maintained to remain accessible for emergency operations. Any gates located between properties along these access routes will remain unlocked at all times to ensure uninterrupted fire department access.

All access routes have a minimum clear width of 7 feet. Based on the approved access routes, which include a combination of paved walkways and maintained lawn areas, the maximum hose drag distance to Unit 6 is approximately 160 feet, as measured along the approved route.

The intent of OFC 503.1.1 is to ensure timely and effective fire department access for initial fire attack operations. This requirement is intended to support apparatus placement, hose deployment, and firefighter mobility rather than to establish a rigid distance threshold absent operational context.

Unit 6 exceeds the 150-foot access requirement by a limited margin, with a hose drag distance of approximately 160 feet, representing an overage of approximately 10 feet (approximately 7 percent) beyond the prescriptive limit. This incremental increase is less than one standard hose length and does not materially affect apparatus positioning, hose advancement, or firefighter effectiveness.

Fire department operations will originate from the same approved fire apparatus access location that would be utilized if the structure were within the 150-foot limit, using a predictable access route with flat grades and adequate width. Although portions of the hose path traverse maintained lawn areas, these areas are unobstructed and do not introduce grade changes, pinch points, or other conditions that would impede firefighter movement or hose deployment.

When considered collectively, the proposed non-combustible exterior construction and maintained access routes provide a level of fire safety and operational effectiveness consistent with the intent of the code, while accommodating site constraints that make strict compliance with the prescriptive access distance impractical.

OFC 503.1.1

Access roads shall be within 150 feet of all portions of the facility and all portions of the exterior walls of the first story of the building as measured by an approved route around the exterior of the building or facility. When the building is equipped throughout with an approved automatic sprinkler system, access roads shall be within 250 feet of all portions of the facility and all portions of the exterior walls of the first story of the building as measured by an approved route around the exterior of the building or facility.

Allow construction of Units 9 and 10 where portions of the structures exceed the 250-foot fire apparatus access distance for sprinklered buildings, based on a combination of automatic fire suppression, enhanced passive fire protection measures, and designated fire department access that provide equivalent fire safety to the prescriptive requirement.

Unit 9 will be protected throughout with an NFPA 13D residential fire sprinkler system utilizing 4.9K sprinkler heads to provide early, automatic fire suppression and limit fire growth prior to fire department arrival. The unit will be constructed with non-combustible roofing and siding materials to reduce ignition potential and exterior fire spread.

Fire protection water supply is provided by a public fire hydrant located at the northeast corner of SE 58th Avenue and SE Clinton Street. The Portland Water Bureau has confirmed an available flow of approximately 2,500 GPM, which exceeds typical residential firefighting demand.

Fire department access to Unit 9 is provided from the approved fire apparatus access road via a primary, predictable access route utilizing the on-site driveway and pedestrian walkways, supplemented by designated fire access easement paths shown on the site plan. Portions of the hose drag route traverse maintained lawn areas within the access easements. These areas are generally flat in grade, free of obstructions, and will be maintained to remain accessible for emergency operations. Any gates located between properties along these access routes will remain unlocked at all times to ensure uninterrupted fire department access.

All access routes have a minimum clear width of 5 feet. Based on the approved access routes, which include a combination of paved walkways and maintained lawn areas, the maximum hose drag distance to Unit 9 is approximately 258 feet, as measured along the approved route.

The intent of OFC 503.1.1 is to ensure timely and effective fire department access for initial fire attack operations. For sprinklered residential buildings, automatic fire suppression significantly limits fire growth prior to fire department arrival, allowing flexibility in access distance where operational effectiveness is maintained.

Unit 9 exceeds the 250-foot access requirement by a limited margin, with a hose drag distance of approximately 258 feet, representing an overage of approximately 8 feet (approximately 3 percent) beyond the prescriptive limit. This exceedance is less than one standard hose length and does not materially affect apparatus positioning, hose deployment, or firefighter effectiveness.

Fire department operations will originate from the same approved apparatus access location that would be utilized if the structure were within the 250-foot limit, using a direct and predictable access route. When considered collectively, the proposed sprinkler protection, high-capacity hydrant supply, non-combustible exterior construction, and permanently maintained access routes provide a level of fire safety and operational effectiveness consistent with the intent of the code.

OFC 503.1.1

Access roads shall be within 150 feet of all portions of the facility and all portions of the exterior walls of the first story of the building as measured by an approved route around the exterior of the building or facility. When the building is equipped throughout with an approved automatic sprinkler system, access roads shall be within 250 feet of all portions of the facility and all portions of the exterior walls of the first story of the building as measured by an approved route around the exterior of the building or facility.

Allow construction of Unit 10 where portions of the structure exceed the 250-foot fire apparatus access distance for sprinklered buildings, based on automatic fire suppression, non-combustible exterior construction, and maintained fire department access that provide equivalent fire safety to the prescriptive requirement.

Unit 10 will be protected throughout with an NFPA 13D residential fire sprinkler system utilizing 4.9K sprinkler heads to provide early, automatic fire suppression and limit fire growth prior to fire department arrival. The unit will be constructed with non-combustible roofing and siding materials to reduce ignition potential and exterior fire spread.

Fire protection water supply is provided by a public fire hydrant located at the northeast corner of SE 58th Avenue and SE Clinton Street. The Portland Water Bureau has confirmed an available flow of approximately 2,500 GPM. The distance from this hydrant to the furthest point of Unit 10 is approximately 612 feet when measured along the driveway path, and approximately 550 feet when measured along the designated fire access easement path.

Fire department access to Unit 10 is provided from the approved fire apparatus access road via a clearly defined primary access route utilizing the on-site driveway and pedestrian walkways, supplemented by designated fire access easement paths shown on the site plan. Portions of the hose drag route traverse maintained lawn areas within the access easements. These areas are generally flat in grade, free of obstructions, and will be maintained to remain accessible for emergency operations. Any gates located between properties along these access routes will remain unlocked at all times to ensure continuous emergency access.

All access routes have a minimum clear width of 5 feet. Based on the approved access routes, which include a combination of paved walkways and maintained lawn areas, the maximum hose drag distance to Unit 10 is approximately 284 feet, as measured along the approved route. A widened hardscape area within the central courtyard, located approximately 95 feet from Unit 10, provides an intermediate staging area for hose advancement and firefighter operations.

The intent of OFC 503.1.1 is to ensure timely and effective fire department access for initial fire attack operations. For sprinklered residential buildings, automatic fire suppression significantly reduces fire growth and life safety risk prior to fire department arrival, supporting flexibility in access distance where operational effectiveness is maintained.

The subject site is a deep parcel with existing surrounding development that constrains the ability to extend an approved fire apparatus access road or provide a compliant turnaround closer to Unit 10. Due to these physical constraints, strict compliance with the 250-foot access distance requirement is impractical.

Unit 10 exceeds the 250-foot access requirement with a hose drag distance of approximately 284 feet, representing an overage of approximately 34 feet (approximately 14 percent) beyond the prescriptive limit. Fire department operations will originate from the same approved apparatus access location that would be utilized if the structure were within the 250-foot limit, using a predictable access route with flat grades and adequate width. The availability of a high-capacity hydrant supply, combined with full NFPA 13D sprinkler protection, limits fire development prior to extended hose deployment. The widened courtyard area approximately 95 feet from Unit 10 further supports operational flexibility by providing an intermediate staging location.

When considered collectively, the proposed sprinkler protection, strong water supply, non-combustible exterior construction, permanently maintained access routes, and intermediate staging capability provide a level of fire safety and operational effectiveness consistent with the intent of the code, while accommodating site constraints that make strict compliance infeasible.