# IS MIXED-USE COMMERCIAL OR RESIDENTIAL?



## T-Bird (Aug 27, 2019)

I'm starting work on a new project that is located in a flood way. My state does not allow new residential construction in a flood way. My client wants to propose a mixed-use building with commercial use (Group B) on the main floor and residential apartments (Group R-2) above. Should this be considered a "commercial" project or a "residential" project? What would the strongest arguement be for considering it "commercial"?


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## mark handler (Aug 27, 2019)

Both
Mixed Occupancy.


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## T-Bird (Aug 27, 2019)

mark handler said:


> Both
> Mixed Occupancy.


When you apply for the building permit is it a commercial application or a residential application?
You're not going to make two separate applications are you?


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## RLGA (Aug 27, 2019)

It is a mixed-use residential project. 

There are various types of "residential" projects and for multifamily residential uses (more than two units) I would consider them to be _commercial _residential buildings where the IBC would be applicable. Then there would be _noncommercial _residential buildings where the IRC would be applicable. If they prohibit all residential buildings, then you'd be out of luck; however, if the restriction only applies to noncommercial residential buildings (i.e., single-family detached homes, duplexes, and townhouses), then I would say the restriction would not apply.


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## Rick18071 (Aug 27, 2019)

Since this is not in the ICC codes i would not go by a IBC or IRC definitions. It depends on your state definition of residential construction.


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## my250r11 (Aug 27, 2019)

T-Bird said:


> flood way



Or did you mean flood zone?


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## T-Bird (Aug 27, 2019)

my250r11 said:


> Or did you mean flood zone?


flood way is a specific flood zone where flooding is more likely and more severe


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## classicT (Aug 27, 2019)

It is a commercial building with a residential use.

What I believe that you are dealing with is a zoning regulation. Building code definitions are not interchangable with zoning codes.


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## T-Bird (Aug 27, 2019)

Ty J. said:


> It is a commercial building with a residential use.
> 
> What I believe that you are dealing with is a zoning regulation. Building code definitions are not interchangable with zoning codes.


I'll move this discussion to the new Zoning Forum


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## ADAguy (Aug 27, 2019)

"Nice" graphic T-Bird


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## classicT (Aug 27, 2019)

Ty J. said:


> Ok, so looking into the WAC, the definition of residential is given as follows in WAC 173-158-030:
> 
> "Residential structure" means a place in which one lives: Dwelling.
> With that, I would state that one/two family dwellings *and* commercial multi-family dwellings can fall into the category of a residential structure.
> ...


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## T-Bird (Aug 27, 2019)

here is my request to the city on this matter:

We are continuing work on the development project for this location and would like you to consider this project as “commercial” rather than “residential” and feel there are several compelling reasons to consider this:



1.      The Floodway code text reads: “No new construction or reconstruction of *residential structures* shall be permitted within the floodway.”  We are proposing a *commercial structure* that includes a *residential use*.

2.      The proposed project is a vertical mixed-use development where a residential use will be located above a commercial use. The residential use will be located well above the base flood elevation.

3.      The building is used exclusively for commercial purposes. The upper floors will be developed as for rent/lease apartments, and not sold as condominiums.

4.      We are not familiar with the application process for the City of Snoqualmie, but in other jurisdictions permit applications for mixed-use developments are treated as commercial buildings and commercial applications. For example, the City of Kirkland includes Single-Family/Duplex/ADU for residential applications and for non-residential applications Kirkland includes Commercial/Multi-Family/Mixed-Use.

5.      The International Code Council similarly includes only Single Family, Duplex, and Townhouse in the IRC, the code that governs *residential structures*.

6.      The construction loan for this project will be for a commercial property and not a residential property, and insurance for this project will be for a commercial property and not a residential property.


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## e hilton (Aug 27, 2019)

T-Bird said:


> 3.      The building is used exclusively for commercial purposes. .
> .


Thats a distortion of the truth.  There will be residences on every floor but one.  

Also, if it is a floodway where flooding is more frequent and more severe ... why would the city want to allow you to build there?   Thats crazy.  There is the potential to have residents trapped on upper floors of the building for several days at a time, possibly without power or water.  What if there is a medical emergency in one of the units?  Sounds like a greedy developer can only see profit at the risk of human suffering.


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## T-Bird (Aug 27, 2019)

e hilton said:


> Thats a distortion of the truth.  There will be residences on every floor but one.
> 
> Also, if it is a floodway where flooding is more frequent and more severe ... why would the city want to allow you to build there?   Thats crazy.  There is the potential to have residents trapped on upper floors of the building for several days at a time, possibly without power or water.  What if there is a medical emergency in one of the units?  Sounds like a greedy developer can only see profit at the risk of human suffering.



Wow, you sound like a real "glass half empty" sort. This is not a distortion at all, apartments are considered commercial property. And to clarify, this is a state law that limits residential structures but not commercial structures in the floodway. My client is not greedy, they want to develop what is allowed to be developed.


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## T-Bird (Aug 27, 2019)

T-Bird said:


> I'll move this discussion to the new Zoning Forum



really lonely over at the zoning forum


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## T-Bird (Aug 27, 2019)

If the definition of a residential structure is a "dwelling" than I do not see the obfuscation. This is a commercial building, not a dwelling.


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## TheCommish (Aug 28, 2019)

Does the jurisdiction in question have a flood; plane, zone, way, administrator local  expert? if so I would inquire  with them.


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## JCraver (Aug 28, 2019)

As a building official I'd try everything I could to be on your side of this, but the way I read that State statute I'd have to tell you No when I got your submittal.  If it has residential units in it, that statute pretty plainly says you can't build it there.

You're going to have to get whatever State agency is responsible for that bit of statute to sign off on your proposal before you get an approval out of the locals.  Or at least, that's what I'd make you do here.


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## ADAguy (Aug 28, 2019)

Semantics, you are twisting reality; when water rises things get wet, damage occurs; who pays for it? puts first responders at risk?
Blame the cities for failure to enforce or governments to continue to allow construction in flood zones?
Tenants sign awareness of the danger and waive right to sue?
Why would a bank loan on these properties?


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## classicT (Aug 28, 2019)

You cannot use definitions from another source. If the term is from the WAC, use the WAC definition not the IBC's.

Per WAC 173-158-030: "Residential structure" means a place in which one lives: Dwelling.



T-Bird said:


> If the definition of a residential structure is a "dwelling" than I do not see the obfuscation. This is a commercial building, not a dwelling.



It is a commercial building that contains dwellings. You can argue this all you want, but I haven't seen one agreement with your argument yet.


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## e hilton (Aug 28, 2019)

T-Bird said:


> Wow, you sound like a real "glass half empty" sort. .


No actually i am very positive and optimistic.  I just have a problem with developers trying to make a fast buck by finding ways around common sense restrictions.  They build it, then sell to an investor, and move on to the next project.  They only care about short term profits, no regard for long term repercussions.


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## e hilton (Aug 28, 2019)

And i am generally not a fan of zoning departments and their myriad obfuscatory and pollyannish ideas, but when it involves known flood zones i believe they are looking out for the best interests of the citizens.  And emergency responders.


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## cda (Aug 28, 2019)

Yep,

When the citizen knocks on city hall door saying, why did you let me build in a flood area, with pictures of the house underwater.


Just cannot win


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## T-Bird (Aug 28, 2019)

I was thinking about this last night and I want to comment on two claims made here. The first claim is I’ve obfuscated reality. The reality is when this law was codified the code writers chose the term “residential structures.” Not residential dwellings, or dwelling units, or residential uses. It’s clear to me this choice was made to separate structures in the same manner as the ICC has done with the IBC and the IRC. Residential structures are single-family, duplexes, and townhouses. This is not semantics; these are specific words with specific meanings. These are our building and development codes.

The second claim is my client is greedy, and unaffected by human suffering. This person has made that assertion without knowing anything about my client, this site, and the context it exists in. They don’t know that dozens, if not hundreds, of nonconforming residential structures already exist in this area. That the site sits on the edge of the downtown of this city. The site is a mere two blocks from the main highway and the floodway extends all the way to this highway and downtown. Would this person deny a city and their citizens any possibility of future development? Communities all over the world exist in floodways, over seismic faults, in the shadow of volcanoes, and in the path of hurricanes. And yet this person has looked into the soul of my client and proclaimed them to be essentially evil. Shame on you sir.


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## mark handler (Aug 28, 2019)

T-Bird said:


> Wow, you sound like a real "glass half empty" sort. This is not a distortion at all, apartments are considered commercial property. And to clarify, this is a state law that limits residential structures but not commercial structures in the floodway. My client is not greedy, they want to develop what is allowed to be developed.


It is a distortion, totally.
You are building residential in a no residential area. Yes is it 12 feet above the grade but it is plane and simple "residential construction" does not matter if 200 feet in the air.


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## classicT (Aug 28, 2019)

T-Bird said:


> I was thinking about this last night and I want to comment on two claims made here. The first claim is I’ve obfuscated reality. The reality is when this law was codified the code writers chose the term “residential structures.” Not residential dwellings, or dwelling units, or residential uses. It’s clear to me this choice was made to separate structures in the same manner as the ICC has done with the IBC and the IRC. Residential structures are single-family, duplexes, and townhouses. This is not semantics; these are specific words with specific meanings. These are our building and development codes.


They chose the term "residential structures" and were very clear in the intent. They even defined the term.

*Per WAC 173-158-030: "Residential structure" means a place in which one lives: Dwelling.*​Your insistent use of definitions from sources other than the WAC is easily perceived as an intent to obfuscate the truth. Stop using building codes when your dealing with laws.

Please directly answer the following question - Will people live and reside in the proposed building as a dwelling? If yes, it meets the above definition of residential structure and you have the answer to your question.

If you are unwilling to take the answer that does not serve your interests, why ask the question. Seems that your mind has already been made up.


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## Yikes (Aug 28, 2019)

T-Bird, I do appreciate what you are saying about these codes having been written prior to the concept of mixed use structures with the residential use above the floodway.
You might want to check with Kirkland and see how they allowed it in the past.  Is your flood control systems handled at the municipal jurisdictional level, or at a county level?  Is there a variance process available, such as at Clark county?

To clarify:
- The “Floodway” includes the channel of a river or other watercourse and adjacent land areas that must be reserved in order to discharge the base flood without cumulatively increasing the water surface elevation more that one (1) foot.
- The “Floodplain” or “Floodway Fringe” is the land area between the floodway and the limits of the one hundred (100)-year floodplain. The floodplain elevation is also known as the base flood elevation.







I think the goal behind "no residential in a floodway" is that when a big rain occurs, public safety officials can encourage everyone to "stay home today", without getting a bunch of 911 calls saying "help, I'm trapped in my home by flood waters".  So in the case of your particular site, is there a portion of the site located outside the floodway, where all of your upper (residential) levels could have their exit discharge onto land that is not in the floodway during a base flood?  That may help your case a lot.


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## my250r11 (Aug 28, 2019)

T-Bird said:


> flood way is a specific flood zone where flooding is more likely and more severe



Agreed, and the term is consistently used wrong. In general no one lets something be built in the FLOODWAY. Most place do not allow even the one foot.

As Yikes was kind enough to post. 



Yikes said:


> T-Bird, I do appreciate what you are saying about these codes having been written prior to the concept of mixed use structures with the residential use above the floodway.
> You might want to check with Kirkland and see how they allowed it in the past.  Is your flood control systems handled at the municipal jurisdictional level, or at a county level?  Is there a variance process available, such as at Clark county?
> 
> To clarify:
> ...


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## T-Bird (Aug 28, 2019)

my250r11 said:


> Agreed, and the term is consistently used wrong. In general no one lets something be built in the FLOODWAY. Most place do not allow even the one foot.
> 
> As Yikes was kind enough to post.


Not true, this state only restricts "residential structures"


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## classicT (Aug 28, 2019)

my250r11 said:


> In general no one lets something be built in the FLOODWAY.


Mike is right, it would be very atypical to build within a floodway - think structural design for resistance to floods and insurance provisions.



T-Bird said:


> Not true, this state only restricts "residential structures"


I think the point here is that you need to verify if it is in the floodway or the floodplain. These are two very different risks. See the post by Yikes.



Yikes said:


> T-Bird, I do appreciate what you are saying about these codes having been written prior to the concept of mixed use structures with the residential use above the floodway.
> You might want to check with Kirkland and see how they allowed it in the past.  Is your flood control systems handled at the municipal jurisdictional level, or at a county level?  Is there a variance process available, such as at Clark county?
> 
> To clarify:
> ...


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## Tim Mailloux (Aug 28, 2019)

Ty J. said:


> They chose the term "residential structures" and were very clear in the intent. They even defined the term.
> 
> *Per WAC 173-158-030: "Residential structure" means a place in which one lives: Dwelling.*​Your insistent use of definitions from sources other than the WAC is easily perceived as an intent to obfuscate the truth. Stop using building codes when your dealing with laws.




Check & Mate


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## e hilton (Aug 28, 2019)

T-Bird said:


> . They don’t know that dozens, if not hundreds, of nonconforming residential structures already exist in this area.


You keep referring to me as “they” and “this person”.  I have a name, and in fact that’s my real name in the title block.  
Second ... just because dozens or hundreds of residences are already built in the flood way is not enough justification to build more.


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## e hilton (Aug 28, 2019)

Yikes said:


> .



Nice explanation.


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## classicT (Aug 28, 2019)

e hilton said:


> You keep referring to me as “they” and “this person”.  I have a name, and in fact that’s my real name in the title block.
> Second ... just because dozens or hundreds of residences are already built in the flood way is not enough justification to build more.


Hold up, wait a second....

E. Hilton, are you with the AHJ where this project is located? If so this just became priceless. 

And sneaky sneaky....your profile shows you as a PM in Virginia.


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## T-Bird (Aug 28, 2019)

this is exhausting...

I've presented this project as being located in a floodway.
The State of Washington only restricts "Residential Structures" from being built in the floodway.
The development of commercial buildings is allowed in a floodway. Hell, one third of this city is located in a floodway.
And a person who wants to develop their property is not an evil. This is a desirable location in a desirable city.
The bias of some people here is plain to see and becoming a bit hostile, wouldn't you say?


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## classicT (Aug 28, 2019)

T-Bird said:


> this is exhausting...
> 
> I've presented this project as being located in a floodway.
> The State of Washington only restricts "Residential Structures" from being built in the floodway.
> ...


In response to your comments:

You have presented as being in a floodway, we are helping you understand the meaning and requirements.
Residential structures are defined by the WAC; the proposed structure is a residential structure.
1/3 of the city being in the floodway is exceedingly hard to believe, floodways do not typically extend more than a short distance from the waters edge (again, are you confusing floodway with floodplain?)
No comment other than I believe you're the only one to use the word 'evil'.
Bias, no. I believe that we are all frustrated with your indignant opinion that lacks any defense other than the fact you will fill out a commercial building permit application.


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## cda (Aug 28, 2019)

Look at places like Houston and New Orleans, people complaining they are flooded out. 

Why some at or below sea level


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## cda (Aug 28, 2019)

Than there are places that have never flooded, underwater.


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## T-Bird (Aug 28, 2019)

Ty J. said:


> In response to your comments:
> 
> You have presented as being in a floodway, we are helping you understand the meaning and requirements.
> Residential structures are defined by the WAC; the proposed structure is a residential structure.
> ...


yup, you know who you are.


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## cda (Aug 28, 2019)

Sometimes have to ask a lot of questions to give a good answer.

Plus having to figure regional/ city codes.

Codes is a fun contact sport.

Anyway.


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## Yikes (Aug 28, 2019)

T-Bird, I'm suggesting you start with the spirit of the code.  I believe the reason for differentiating between commercial and residential is how they each affect public resources and safety during a base flood:
1.  If a commercial structure floods, the business shuts down and people go home.  There is economic loss, but that's between you and the insurance company.
2.  If a residential structure floods, the people are completely displaced and need to find emergency shelter until the home is repaired.  This is a much greater strain on public resources.  Or worse, the residents are asleep during actual flooding, and they are stuck in a life-threatening situation.
3.  If a residential structure  is at the second story and does not flood, but the _access to / exit from_ the residential structure floods, then people still need to leave their home and find emergency shelter until the base flood subsides.​
Solve for safe access during a base flood as per #3, and you might be able to convince someone to make a variance and further parse the semantic argument of commercial vs residential on the upper floors.

And for what it's worth, I applaud the creative approach, and I think it is important to find new places for housing as long as we are not compromising actual public safety resources.


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## e hilton (Aug 28, 2019)

Ty J. said:


> Hold up, wait a second....
> 
> E. Hilton, are you with the AHJ where this project is located? If so this just became priceless.
> 
> And sneaky sneaky....your profile shows you as a PM in Virginia.


Sorry, no reality tv drama here.  I am in Va, i thought he might have been in ariz or similar, he just said its washington state.  And i am a construction pm for a very large national property management firm.


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## my250r11 (Aug 29, 2019)

e hilton said:


> just because dozens or hundreds of residences are already built in the flood way is not enough justification to build more.


  Exactly! the point is to change this trend to protect life and property, which is also the basis of all the codes.

If the State of Washington & the local AHJ will allow it then that's on them. I do not believe NFIP & FEMA will be as forgiving. Also to build in a flood area the commercial building will have to be WATERPROOFED to 1 foot above the BFE. this is even in the IBC 107.2.5.1, & section 1612.


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## Yikes (Aug 29, 2019)

my250r11 said:


> Exactly! the point is to change this trend to protect life and property, which is also the basis of all the codes.



I'm going to disagree - -  or at least look at it the code issue without impugning motivations on the part of the developer.
The point may not be to undermine protection of life and property.  It is possible that the point may be to develop where it is reasonable to do so in an infill situation, rather than simply sprawling further out of the city into undeveloped or agricultural land.  I live in the LA area, where we are both dramatically under-housed and running our of available land We have homeless encampments right in the riverbeds, both within the urban areas and in the mountain canyons, and you can't tell me that is safer than putting someone inside housing that is above the base flood level.  

We've all seen developments over the years that include any one of the following over a waterway:  housing built on piers; housing on fill in a harbor; a site that was graded to relocate the flow of stormwater.
You may not think that putting residential above a base floodway is a good solution, but the original poster said it was being done in other nearby communities, and all he was doing was spitballing about the mechanism and rationale that might make it approvable.  I see no need to draw conclusions about the motivations of the designer or developer, especially when the OP said that the code was written prior to the popularity of vertical mixed use.
Instead, it would be more productive to consider the underlying safety issues of WHY the code allows commercial but not residential, and then address that head-on.  That is what I attempted to do in my earlier posts.


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## ADAguy (Aug 30, 2019)

The same is true in the SFV Yikes where historic air photos show that before development the SFV was crisscrossed with channels, gullies and streams that have been built over and are subject to liquifaction. Proximity to water was usually the first location for most development without consideration to flood hazard or weather. 
That was then and this is now. Don't "we" know better and yet are laws and codes have not kept pace with the obvious until a disaster happens.
We continue to allow home construction in mountain fire districts using combustable materials, don't we? And what of tornado and hurricane areas?


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## classicT (Aug 30, 2019)

ADAguy said:


> The same is true in the SFV Yikes where historic air photos show that before development the SFV was crisscrossed with channels, gullies and streams that have been built over and are subject to liquifaction. Proximity to water was usually the first location for most development without consideration to flood hazard or weather.
> That was then and this is now. Don't "we" know better and yet are laws and codes have not kept pace with the obvious until a disaster happens.
> We continue to allow home construction in mountain fire districts using combustable materials, don't we? And what of tornado and hurricane areas?


This isn't a liquefaction issue. The focus is building within an active floodway; an area subject to frequent waterflow during the base flood event (think yearly not every 100yrs).

The *LAW *(this is a Washington Administrative Code - WAC), is intended to protect peoples homes, allow shelter in place protection, minimize rescue needs, and most importantly, prevent the impedance of flood waters which in turn makes it worse conditions for all.


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## Rick18071 (Aug 30, 2019)

Build it on a barge. No worry about flooding or codes.


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## Yikes (Aug 30, 2019)

Ty J and Rick 18071, you both make good comments.  The prescriptive provisions of the law exists for public safety, yet other technologies can provide alternate means of achieving a similar level of safety.  I saw one of those British homebuilding shows on Netflix where a guy built his house on a barge in a river floodway.
My point is, if the OP can understand the underlying safety issues behind the original prescriptive provisions of the law, there may be an alternative performance-based solution that provides for equivalent safety.  

Ty J, if impedence of floodwaters was the "most important" issue behind the original prescriptive requirement, then why does the WAC allow commercial construction in a floodway?


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## classicT (Aug 30, 2019)

Yikes said:


> Ty J and Rick 18071, you both make good comments.  The prescriptive provisions of the law exists for public safety, yet other technologies can provide alternate means of achieving a similar level of safety.  I saw one of those British homebuilding shows on Netflix where a guy built his house on a barge in a river floodway.
> My point is, if the OP can understand the underlying safety issues behind the original prescriptive provisions of the law, there may be an alternative performance-based solution that provides for equivalent safety.
> 
> Ty J, if impedence of floodwaters was the "most important" issue behind the original prescriptive requirement, then why does the WAC allow commercial construction in a floodway?


Since when are there prescriptive and performance based laws?

This is not building code that we are discussing, it is a State Administrative Code. Totally different aspect than building codes.


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## ADAguy (Aug 30, 2019)

Semantics again, unless your house will "float" it is moot to build in a floodway.
Even then, if it breaks loose and floats downstream, who then pays for the damage it does to bridges?


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## Yikes (Aug 30, 2019)

Ty J. said:


> Since when are there prescriptive and performance based laws?
> 
> This is not building code that we are discussing, it is a State Administrative Code. Totally different aspect than building codes.



I agree, but every prescriptive law is originally crafted with a performance-based goal in mind.  In context with my other posts, all I'm saying (again) is: find out WHY residential is not allowed, but commercial is allowed; then find out how neighboring municipalities addressed this successfully when they allowed vertical mixed use in a floodway; then see if that concept can transfer to this site prescriptively without affecting the safety performance intended in the WAC.

No one (including ADAguy in post #50) seems to be addressing why or how commercial construction is allowed in the floodway.


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## ADAguy (Aug 30, 2019)

Because they have insurance and/or the financial ability to rebuild, residents (whether owners or renters) often lack the ability to rebuild, wait till too late and have to be rescued (even when told to evacuate - remember Katrina).


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## Yikes (Aug 30, 2019)

ADAguy said:


> Because they have insurance and/or the financial ability to rebuild, residents (whether owners or renters) often lack the ability to rebuild, wait till too late and have to be rescued (even when told to evacuate - remember Katrina).


OK, so we have established that commercial vs. residential in a flood way it does not have to do with impeding the flow of water.
We speculate as per post #52 that the "no residential" has underlying performance goals that address (1) the likelihood of unrecoverable damage to residences, and (2) the ability to evacuate.

So, let's picture a vertical mixed use building has residential units that are (1) on the second floor, well above the floodway so they are undamaged in event of base flood, and (2) have an exit path of travel that stays completely out of the floodway (for example, a "U" shaped building where the stairwells/elevators at both ends of the U are outside of the floodway zone).  The commercial ground level is concrete construction, designed not to be undermined in event of flood.  (Perhaps it is simply a commercial parking garage.  This has addressed all the residential-specific safety issues identified in post #52, has it not?


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## Paul Sweet (Aug 31, 2019)

This is probably a zoning issue, not a building code issue.  

The National Flood Insurance Program and FEMA regulations are probably behind zoning code restrictions on construction in the floodway, because any structure in a floodway can restrict the flow of floodwater and cause greater flooding upstream.  The buildings in the floodway probably predate this program, which I believe started in the late 1960s.

These regulations might make it impossible to get flood insurance on the building.  If I remember correctly, NFIP will not allow flood insurance coverage in localities that don't enforce their regulations through zoning.  

FEMA distinguishes between commercial and residential buildings when it comes to floodproofing methods.  Residential buildings have to be raised above base floor elevation, while commercial buildings can have water barriers to seal off levels below base flood elevation.  I don't know how FEMA would treat a mixed use building.


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## my250r11 (Sep 3, 2019)

Paul Sweet said:


> This is probably a zoning issue, not a building code issue.
> 
> The National Flood Insurance Program and FEMA regulations are probably behind zoning code restrictions on construction in the floodway, because any structure in a floodway can restrict the flow of floodwater and cause greater flooding upstream.  The buildings in the floodway probably predate this program, which I believe started in the late 1960s.
> 
> ...



Exactly my point, Paul Said it better.


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## ADAguy (Sep 3, 2019)

Yikes said:


> OK, so we have established that commercial vs. residential in a flood way it does not have to do with impeding the flow of water.
> We speculate as per post #52 that the "no residential" has underlying performance goals that address (1) the likelihood of unrecoverable damage to residences, and (2) the ability to evacuate.
> 
> So, let's picture a vertical mixed use building has residential units that are (1) on the second floor, well above the floodway so they are undamaged in event of base flood, and (2) have an exit path of travel that stays completely out of the floodway (for example, a "U" shaped building where the stairwells/elevators at both ends of the U are outside of the floodway zone).  The commercial ground level is concrete construction, designed not to be undermined in event of flood.  (Perhaps it is simply a commercial parking garage.  This has addressed all the residential-specific safety issues identified in post #52, has it not?


No, what of all the flooded vehicles and their environmental contents?
What of the threat to and cost of first responders who attempt to rescue them?


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## Yikes (Sep 3, 2019)

ADAguy said:


> No, what of all the flooded vehicles and their environmental contents?
> What of the threat to and cost of first responders who attempt to rescue them?


Vehicles / environmental contents: Again, we go back to the OP's statement that the WAC already allows commercial uses; therefore the parking and environmental contents related to commercial uses has already been considered in the code.
First responders:  for residents, in my design scenario that you quoted, they already "have an exit path of travel that stays completely out of the floodway."  Therefore it should be no problem for first responders.


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