AE-7 Addition to PreFIRM Structure
Scott Fraser
The city has a large preFIRM community center. It wants to construct an exterior restroom thats handicap accessible. This restroom will be a free-standing CBS structure that abuts one exterior wall of the main building; the restroom will be new construction.
Access to the restroom will only occur from the outside. There's no passage from within the Community Center to the new restroom.
The architect is claiming the construction of this restroom doesn't amount to a Substantial Improvement of the larger Community Center, therefore the "addition" doesn't have to comply with elevation requirements.
My position was that since this is a free-standing newly constructed building, it's not a question whether its a Substantial Improvement of the other, much larger structure.
However, when I look at the flow chart (attached), when it comes to the question of whether this project amounts to a Substantial Improvement, it's unclear when it comes to the question of Substantial Improvement. Flow chart: ADDITION ONLY (Yes) -> DATE OF BASE BUILDING (PreFIRM) -> SUBSTANTIAL IMPROVEMENT (?).
This makes me wonder whether I'm correct or not.
QUESTION: Can any addition be added to a preFIRM structure and not be elevated so long as the cost of that addition is less than 50% of the original structure?
Who's correct... me or the architect?
Scott
Scott Fraser
FEMA Coordinator/Floodplain Administrator
305-809-3810 o.
305-923-4964 c.
sfr...@keywestcity.com
Rebecca C. Quinn
You are correct. If it is a separate structure then, by definition, it isn’t an addition. The code defines additions “an extension or increase in flood area or height of a building or structure.”
Separate structures must comply with the requirements for new construction. And because it is a separate structure, there is no need to do a substantial improvement determination, which means you don’t go into the flow chart. The flow chart is only for additions.
I expect the next questions will be about a variance to the elevation requirement (FEMA guidance is that accessibility is not an acceptable basis for a variance), or about dry floodproofing, which is an acceptable method of compliance.
Rebecca C. Quinn, CFM
RCQuinn Consulting, Inc.
104 4th St NE #2
Charlottesville VA 22902
434-296-1349 (voice)
443-398-5005 (cell)
320-514-3513 (FAX)
Mike Gambino
Can you provide that flow chart?
M. Gambino, CFM
Floodplain Administrator
City of Miami Gardens
Public Works Dept.
1050 NW 163 Drive
Miami Gardens, Fl. 33169
Tel. 305.622.8039
Email: mgam...@miamigardens-fl.gov
From: fl_flo...@googlegroups.com [mailto:fl_flo...@googlegroups.com] On Behalf Of Scott Fraser
Sent: Wednesday, October 19, 2011 3:35 PM
To: Florida Floodplain Managers Association-List serve
Subject: AE-7 Addition to PreFIRM Structure
I can't recall the rule on additions to preFIRM structures, and the flow chart isn't clear on one point.
Mike Gambino
Can I ask where the definition of “Addition” came from?
M. Gambino, CFM
Floodplain Administrator
City of Miami Gardens
Public Works Dept.
1050 NW 163 Drive
Miami Gardens, Fl. 33169
Tel. 305.622.8039
Email: mgam...@miamigardens-fl.gov
Rebecca C. Quinn
The definition of “addition” is from the building code. The DEM flow chart for additions to buildings in special flood hazard areas is posted at the Florida Floodplain Managers Association’s webpage where DEM has several “Tech Topics.” Go to www.ffma.net and click on the “links and resources” tab (scroll to the bottom to find it).
https://ffma.pbsjteamaccess.com/Pages/Links%20and%20Resources.aspx
Rebecca C. Quinn, CFM
RCQuinn Consulting, Inc.
104 4th St NE #2
Charlottesville VA 22902
434-296-1349 (voice)
443-398-5005 (cell)
320-514-3513 (FAX)
Mike Gambino
Great, thanks Rebecca!
Scott Fraser
Scott
Scott Fraser
FEMA Coordinator/Floodplain Administrator
305-809-3810 o.
305-923-4964 c.
sfr...@keywestcity.com
Scott Fraser
Reviewing FEMA's guidelines, there's a clear concern with additions, that any opening between the two be as minimal as possible, usually not larger than a single doorway. Yet the guidelines appear silent on whether an interior passageway is required.
So... the question now at-hand is: If the new project (exterior restroom) shares a common supporting wall with the base structure & the only access to the new enclose area is from the exterior, does the new project constitute an "addition" as opposed to free-standing "new construction?" I'd say the new area becomes an "addition."
If the "addition" doesn't amount to a Substantial Improvement of the base structure, then elevation/floodproofing, vents etc. wouldn't be required. Concur?
Scott
Scott Fraser
FEMA Coordinator/Floodplain Administrator
305-809-3810 o.
305-923-4964 c.
sfr...@keywestcity.com
Skarvelis, Frank N
Agreed: sharing a supporting wall with the existing structure makes the new construction an “addition” de facto.
Agreed: as an “addition”, the SI consideration is mandated and compliance issues could be based upon the SI determination.
Frank N. Skarvelis, CFM
Brevard County Floodplain Administrator
Legislative Director - Florida Floodplain Managers Association
Under Florida Law, email addresses are Public Records. If you do not want your e-mail address released in response to public record requests, do not send electronic mail to this entity. Instead, contact this office by phone or in writing.
Mike Gambino
I agree with Frank, this would be an addition, regardless of whether there is a door outside, or outside and inside
M. Gambino, CFM
Floodplain Administrator
City of Miami Gardens
Public Works Dept.
1050 NW 163 Drive
Miami Gardens, Fl. 33169
Tel. 305.622.8039
Email: mgam...@miamigardens-fl.gov
From: fl_flo...@googlegroups.com [mailto:fl_flo...@googlegroups.com] On Behalf Of Skarvelis, Frank N
Sent: Friday, October 21, 2011 10:03 AM
To: fl_flo...@googlegroups.com
Scott Fraser
Thank you all.
Scott
Scott Fraser
FEMA Coordinator/Floodplain Administrator
305-809-3810 o.
305-923-4964 c.
sfr...@keywestcity.com
