Building Height, High-Rise Classification, and a Requested Phased Occupancy
A developer submits plans for a five-story, 120-unit R-2 apartment building. The plans list building height as 74 feet 8 inches above grade plane, and the applicant states the building is not a high-rise. The site includes a sunken parking level, and the fire department's approved access road runs along a lower plaza whose surface sits 78 feet 6 inches below the highest occupied floor. The building is Type III-A and fully sprinklered.
The applicant also requests phased occupancy so floors 1 through 3 can be leased while the voice evacuation system and the stair pressurization fans are still being commissioned. No temporary measures are proposed.
1. Is this a high-rise? Show how you determine it and explain why the applicant's 74-foot-8 figure does not control.
Read the worked answer
Yes. The high-rise definition turns on a different measurement than building height. A high-rise is a building with an occupied floor more than 75 feet above the lowest level of fire department vehicle access.
- The applicant computed height above grade plane: 74 ft 8 in. That figure governs allowable height and area and other height-based thresholds. It is not the high-rise test.
- The controlling measurement is from the lowest level of fire department vehicle access - the lower plaza where the approved access road runs - to the highest occupied floor. That is 78 ft 6 in, which exceeds 75 feet.
The building is a high-rise. Note also that the measurement goes to the occupied floor, not the roof, so you must verify the elevation of the fifth-floor walking surface rather than relying on a roof line on the drawings.
Write the finding as a plan review comment with the definition, the two elevations used, and the resulting classification. The applicant may disagree, but the disagreement has to be with the measurement, not with the definition, and the appeal route should be stated.
2. What changes in the review now that the building is a high-rise, and how do you handle the permit administratively?
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The classification pulls in the high-rise provisions of Chapter 4, which add requirements beyond what a mid-rise R-2 would need: an approved voice/alarm communication system, a fire command center, standby power, protection of the elevator hoistway and recall provisions, standpipe and water supply features, and - depending on configuration - luminous egress path markings and additional egress reliability measures. Structural fire-resistance, shaft protection, and smoke control assumptions all need to be re-examined against the new basis.
Administratively:
- Issue written comments that the review basis has changed and that the plans must be revised and resubmitted showing compliance with the high-rise provisions.
- Confirm with the applicant's engineer which systems on the drawings were designed assuming no high-rise classification, since staged and mechanical submittals may need to be reworked.
- Additional plan review effort and any corresponding fee adjustment should be handled under the jurisdiction's adopted fee schedule, applied consistently, not negotiated.
- Document the classification decision, the elevations relied on, and the date. If the applicant appeals, the file should already contain the measurement and the definition.
Do not approve the sheets piecemeal while the basis is unresolved; a partial approval is a trap for the field inspector.
3. Can you grant the phased occupancy as requested? State your decision and the conditions you would attach.
Read the worked answer
Not as requested. A temporary or partial certificate of occupancy is available only where the portion to be occupied is safe for its intended use, and here the portion proposed for lease depends on systems that are not yet functional. In a high-rise residential building, the alarm and notification system and the stair pressurization serve the leased floors directly; leasing ahead of them means occupants are relying on systems that have never been proven to operate.
What the official can consider: a limited occupancy for specific floors, conditioned on all life-safety systems serving those floors being tested and accepted, including the alarm and notification coverage, sprinkler protection and final flushing, standpipe availability, stair pressurization for the egress paths serving those floors, emergency power, and egress illumination.
Conditions to attach if any relief is granted:
- Occupancy limited to identified floors, with no occupancy above the highest fully protected floor and signage and locked access controlling the boundary.
- A written fire watch with documented rounds and a named responsible person, expressly as an interim measure with a stated end date - not a substitute for the systems.
- Daily inspection reports submitted to the department, and immediate notification of any system impairment.
- A firm completion date, with the temporary occupancy automatically void if it passes.
- Explanation to the applicant of why: the temporary occupancy is discretionary relief, and the file record of the conditions is what supports it.