2015 st. seattle wa robin murphy jackson|main architecture

13
Date: July 7 th 2015 DPD Pre construction meeting notes for project # 6478526 Project Address: 1008 N 109 th St. Seattle WA Project Description: 4 story building with 93 SEDU’s and 7 Live/Work units on the ground floor. Levels 2-4 will be built of pre-fabricated Modular units. Attendance: Robin Murphy Jackson|Main Architecture John Morefield Jackson|Main Architecture Cornell Burt DPD Senior Structural Plans Engineer. Roussi Roussev DPD Senior Structural Plans Engineer. James K. Clancy Seattle Fire Dept. Ray Jacobson Senior Mechanical Plans Engineer. Ray Jacobsen re: Energy Code Per C402.4.7 project will require a vestibule located at the main entrance. o It was noted that the vestibule is still required although there are patio doors in similar lobby locations at the 2 nd 3 rd and 4 th floors. The vestibule is required due to the door facilitating the entry and exit of the building. Project will require an Air Barrier. Project will follow prescriptive path for energy code per C402.2 Domestic metering for hot water will be required for Live/Work Units. James K. Clancy re: Fire Protection. Project is NFPA13 not NFPA13r Steel stand pipe in each Stairwell req. Dry Pipe sprinklers may be required under Solar Array on roof depending on arrangement of panels. If panels constitute a canopy or concealed space, sprinkler protection beneath the panels would be required. SFD- JKC 8/31/15. Each modular “box” will require sign off from L&I Sprinkler system to be designed and submitted under separate permit. SFD requires one sprinkler contractor to take responsibility for the project, even if another contractor, or the modular manufacturer install the various components at the factory. SFD-JKC 8/31/15. Cornell Burt Re: Phasing Project to be permitted in phases with site work and level 1 construction being the first phase to expedited construction time and prepare to receive the modular boxes. Fill out phased permit request form.

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Page 1: 2015 St. Seattle WA Robin Murphy Jackson|Main Architecture

Date: July 7th 2015 DPD Pre construction meeting notes for project # 6478526 Project Address: 1008 N 109th St. Seattle WA Project Description: 4 story building with 93 SEDU’s and 7 Live/Work units on the ground floor. Levels 2-4 will be built of pre-fabricated Modular units. Attendance: Robin Murphy Jackson|Main Architecture John Morefield Jackson|Main Architecture Cornell Burt DPD Senior Structural Plans Engineer. Roussi Roussev DPD Senior Structural Plans Engineer. James K. Clancy Seattle Fire Dept. Ray Jacobson Senior Mechanical Plans Engineer. Ray Jacobsen re: Energy Code

Per C402.4.7 project will require a vestibule located at the main entrance. o It was noted that the vestibule is still required although there are patio doors in

similar lobby locations at the 2nd 3rd and 4th floors. The vestibule is required due to the door facilitating the entry and exit of the building.

Project will require an Air Barrier. Project will follow prescriptive path for energy code per C402.2 Domestic metering for hot water will be required for Live/Work Units.

James K. Clancy re: Fire Protection.

Project is NFPA13 not NFPA13r Steel stand pipe in each Stairwell req. Dry Pipe sprinklers may be required under Solar Array on roof depending on

arrangement of panels. If panels constitute a canopy or concealed space, sprinkler protection beneath the panels would be required. SFD- JKC 8/31/15.

Each modular “box” will require sign off from L&I Sprinkler system to be designed and submitted under separate permit. SFD requires

one sprinkler contractor to take responsibility for the project, even if another contractor, or the modular manufacturer install the various components at the factory. SFD-JKC 8/31/15.

Cornell Burt Re: Phasing Project to be permitted in phases with site work and level 1 construction being the first phase to expedited construction time and prepare to receive the modular boxes.

Fill out phased permit request form.

Page 2: 2015 St. Seattle WA Robin Murphy Jackson|Main Architecture

6478526 Mtg. Notes 07-02-15 Page 2

Utilize Phased Permit Checklist.

Roussi Roussev re: SEDU compliance of units.

It appears the current configuration of the typical Type B SEDU as designed does not meet the Building Officials interpretation of Directors Rule 25-2014

o Entry way is not wide enough to be considered part of main space. o “connector” Space to be defined to also comply with main space criteria. o Min 55 cubic feet of storage required. o Main room area to be min. 150 sf.

Based on this feedback Drawings of typical unit designs were issued to Cornell Burt for compliance review on 07-08-15 See Exhibit A. See Exhibit B. Upon Further review this statement was issued by Cornell Burt on 07-09-15 John, Our Code Interpretation committee met yesterday, and it is apparent that the floor plans as proposed do not comply; the entry areas are too deep and not wide enough to be counted toward the minimum area of the room. Regarding shortening the countertop length as a means of gaining more area in the room toward the minimum, you may refer to the guideline and note that such an area would be considered a “bump-out.” I realize that this will result in some fairly major revision to your design, but these documents reflect the Building Official’s interpretation of the minimum room area for these small efficiency dwelling units. Please carefully review the documents and feel free to ask any further questions. Please note that I included DR 25-2014 and cc’d Craig Sedlacek at LNI, so that he can be aware of the rules and interpretations pertinent to this review. Sincerely, Cornell E. Burt, P.E.

Page 3: 2015 St. Seattle WA Robin Murphy Jackson|Main Architecture

6478526 Mtg. Notes 07-02-15 Page 3

Senior Structural Plans Engineer City of Seattle Department of Planning and Development Direct: (206) 684-7844 BURTCE COMMENT: Confirmed. Exhibit A does not comply. 9-11-15 Further designs were submitted on 07-09-15 See Exhibit C This statement was issued on 07-10-15 John, I have consulted with the Building Official, and the unit layout as you have proposed it is deemed acceptable as meeting the interpretation of the Director’s Rule and other documents provided since our meeting. I hope you are able to make the modules work with this information. Please feel free to send the meeting minutes in MS Word (or other text format) for distribution and review, and have a great day. Sincerely, Cornell E. Burt, P.E. Senior Structural Plans Engineer City of Seattle Department of Planning and Development Direct: (206) 684-7844 BURTCE COMMENT: Confirmed. Exhibit C does comply with both the DRAFT guideline of Exhibit B as well as Director’s Rule 25-2014. Please note that this approval is granted for this building only, as the DRAFT is still not finalized into an ordinance, while it is the most current document DPD has for consideration. Please refer to Exhibits as included in this email. Note that Exhibits A, B, and C are attached For Reference Only. 9-11-15

Page 4: 2015 St. Seattle WA Robin Murphy Jackson|Main Architecture

18 19

A

B

C

D

231 SF

UNIT

217

13

' - 3

7/8

"

8' - 3 1/4"

4' - 8 7/8"

4' -

3 7

/8"

5' - 2 7/8"

8' -

3 7

/8"

PRIMARY ROOM153 SF

11.01

12.02

06.03

06.04

06.02

01.03

5 6

A

B

C

D

1' -

1"

5' -

7 1

/2"

3' -

0"

0' -

5 1

/2"1' -

1"

10

' - 9

1/2

"2

' - 0

"

24

' - 0

1/2

"

1' -

0"

0' - 11" 1' - 4 3/8" 4' - 0 7/8" 1' - 5 3/4" 1' - 0" 2' - 1 1/8"

10' - 11"

2' - 9 3/8" 3' - 0 5/8" 5' - 1 1/8"

3' - 5" 2' - 2 7/8"

2' - 0 1/2" 3' - 7 7/8"

1' - 5" 1' - 4 3/8" 1' - 2 3/4"

227 SF

UNIT

228

2' - 3 1/4" 8' - 7 3/4"

48X56

1' - 7 3/8"

2' - 10"

1' -

9"

2' -

0"

2' - 0"

06.02

01.03

06.04

06.03

12.02

11.01PRIMARY ROOM

152 SF

19 20

F

G

H

260 SF

UNIT

215A

2' - 8" 6' - 0 1/8" 1' - 10" 1' - 7 1/2"

8' - 8 1/8" 3' - 5 3/8" 1' - 0 3/4"

2' -

0"

10

' - 7

"1

' - 1

1/2

"0' -

7 1

/2"

1' -

0 3

/8"

2' -

2 3

/4"

5' -

1 7

/8"

1' -

3 1

/2"

3' -

0 5

/8"

13

' - 8

1/2

"0

' - 7

1/2

"9

' - 8

1/2

"

24

' - 0

1/2

"

5' - 1 1/2" 3' - 4 5/8" 2' - 3 3/8" 2' - 4 3/4"

1' - 4 5/8"

13' - 2 1/4"

4' - 1 1/2" 3' - 5 1/8"

2' - 0" 1' - 2 3/4" 1' - 3 3/4" 3' - 6 1/8"

2' - 10"

0' -

10

1/2

"

3' -

5"

PRIMARY ROOM164 SF

01.03

06.02

06.04

06.03

12.02

11.01

PROJECT NO.:

PROJECT MGR.:

DRAWN BY:

CHECKED BY:

JACKSON | MAIN ARCHITECTURE P.S. © 2015

311 FIRST AVENUE SOUTH

SEATTLE, WA 98104

t 206.324.4800

WWW.JACKSONMAIN.COM

JACKSON | MAINA R C H I T E C T U R E

7/6

/20

15

3:1

0:5

6 P

M

A5.0

ENLARGED UNITPLANS

Author

Designer

14049

GRADINGUSE

PERMIT

CU

BIX

AU

RO

RA

AP

AR

TM

EN

TS

1008 N

109T

H S

T.

Checker

PA

RK

ST

ON

E P

RO

PE

RT

IES

DP

D #

6481751

DA

TE

N0.

DIS

CR

IPT

ION

1/2" = 1'-0"2

ENLARGED PLAN TYPICAL ON FLOORS 2,3,4 1/2" = 1'-0"

4ENLARGED TYPICAL UNIT WITH TYPE B BATH

1/2" = 1'-0"1

ENLARGED TYPICAL ACCESSIBLE UNIT WITH TYPE A BATH

KEYNOTES

01.03 7'X7' CLEAR FLOOR AREA

06.02 55 CUBIC FEET OF STORAGE LOCATED IN UPPER AND LOWER CABINETS

06.03 24"X24" (4 SF) OF CLEAR COUNTER SPACE TYP.

06.04 DESK @ 30" A.F.F. TYP

11.01 10 CUBIC FOOT REFRIDGE

12.02 18"X18" SINK - 2 BURNER ELECTRIC RANGE - HOOD MICROWAVE ABOVE(TYP. FOR ALL UNITS)

john.morefield
Text Box
EXHIBIT A
burtce
Text Box
EXHIBIT A REPRESENTS CONFIGURATIONS WHICH DO NOT COMPLY WITH THE CURRENT DRAFT GUIDELINE AND DIRECTOR'S RULE GOVERNING SMALL EFFICIENCY DWELLING UNITS. BURTCE 9-11-15
Page 5: 2015 St. Seattle WA Robin Murphy Jackson|Main Architecture

1 2

F

G

H

237 SF

UNIT

201

9' - 5 1/4"

13

' - 1

3/4

"

4' - 8 1/8"

8' -

3 7

/8" 4

' - 3

7/8

"

5' - 2 7/8"

19 20

A

B

C

D

227 SF

UNIT

216

8' - 3 5/8"

13

' - 3

7/8

"

4' - 8 7/8"

4' -

3 7

/8"

5' - 2 7/8"

8' -

3 7

/8"

1 2

A

B

C

D

296 SF

UNIT

231A

13

' - 1

3/4

"

12' - 9 1/2"

4' - 7 3/8"

9' -

4"

5' -

0 7

/8"

7' - 6"

PROJECT NO.:

PROJECT MGR.:

DRAWN BY:

CHECKED BY:

JACKSON | MAIN ARCHITECTURE P.S. © 2015

311 FIRST AVENUE SOUTH

SEATTLE, WA 98104

t 206.324.4800

WWW.JACKSONMAIN.COM

JACKSON | MAINA R C H I T E C T U R E

7/6

/20

15

3:1

0:5

6 P

M

A5.1

ENLARGED UNITPLANS

Author

Designer

14049

GRADINGUSE

PERMIT

CU

BIX

AU

RO

RA

AP

AR

TM

EN

TS

1008 N

109T

H S

T.

Checker

PA

RK

ST

ON

E P

RO

PE

RT

IES

DP

D #

6481751

DA

TE

N0.

DIS

CR

IPT

ION

1/2" = 1'-0"2

ENLARGED PLAN - LEVEL 2 1/2" = 1'-0"

3TYP. TYPE B UNIT

1/2" = 1'-0"1

ENLARGED PLAN TYPICAL ON FLOORS 2,4

burtce
Text Box
EXHIBIT A REPRESENTS CONFIGURATIONS WHICH DO NOT COMPLY WITH THE CURRENT DRAFT GUIDELINE AND DIRECTOR'S RULE GOVERNING SMALL EFFICIENCY DWELLING UNITS. BURTCE 9-11-15
john.morefield
Text Box
EXHIBIT A
Page 6: 2015 St. Seattle WA Robin Murphy Jackson|Main Architecture

19 20

A

B

C

D

239 SF

UNIT

316

9' - 5 3/4"

13

' - 1

3/4

"

4' - 6 1/4"

9' -

4"

5' - 2 7/8"

5' -

3"

1 2

A

B

C

D

272 SF

UNIT

331A

13

' - 1

3/4

"

10' - 7 1/2"

6' -

1 3

/4"

7' - 6"

4' - 7 3/8"

9' -

4"

19 20

F

G

H

239 SF

UNIT

315

4' - 8 7/8"

9' -

4"

13

' - 1

3/4

"

9' - 5 3/4"

5' - 2 7/8"

4' -

3 7

/8"

PROJECT NO.:

PROJECT MGR.:

DRAWN BY:

CHECKED BY:

JACKSON | MAIN ARCHITECTURE P.S. © 2015

311 FIRST AVENUE SOUTH

SEATTLE, WA 98104

t 206.324.4800

WWW.JACKSONMAIN.COM

JACKSON | MAINA R C H I T E C T U R E

7/6

/20

15

3:1

0:5

7 P

M

A5.2

ENLARGED UNITPLANS

Author

Designer

14049

GRADINGUSE

PERMIT

CU

BIX

AU

RO

RA

AP

AR

TM

EN

TS

1008 N

109T

H S

T.

Checker

PA

RK

ST

ON

E P

RO

PE

RT

IES

DP

D #

6481751

DA

TE

N0.

DIS

CR

IPT

ION

1/2" = 1'-0"2

TYPE B UNIT 2 1/2" = 1'-0"

3TYP. TYPE A UNIT

1/2" = 1'-0"1

TYPE B UNIT 3

john.morefield
Text Box
EXHIBIT A
burtce
Text Box
EXHIBIT A REPRESENTS CONFIGURATIONS WHICH DO NOT COMPLY WITH THE CURRENT DRAFT GUIDELINE AND DIRECTOR'S RULE GOVERNING SMALL EFFICIENCY DWELLING UNITS. BURTCE 9-11-15
Page 7: 2015 St. Seattle WA Robin Murphy Jackson|Main Architecture

19 20

F

G

H

246 SF

UNIT

415

10' - 7 1/2"

9' -

4"

11

' - 1

3/4

"2

' - 0

"

4' - 8 7/8" 5' - 2 7/8"

5' -

3"

19 20

A

B

C

D

247 SF

UNIT

416A

8' - 3 1/4"

9' -

1 7

/8"

13

' - 3

7/8

"

4' - 9"

5' -

0 7

/8"

7' - 6"

1 2

FG

H

249 SF

UNIT

401

9' -

4"

13

' - 1

3/4

"

4' - 8 5/8"

10' - 6 1/8"

5' - 2 7/8"

4' -

3 7

/8"

PROJECT NO.:

PROJECT MGR.:

DRAWN BY:

CHECKED BY:

JACKSON | MAIN ARCHITECTURE P.S. © 2015

311 FIRST AVENUE SOUTH

SEATTLE, WA 98104

t 206.324.4800

WWW.JACKSONMAIN.COM

JACKSON | MAINA R C H I T E C T U R E

7/6

/20

15

3:1

0:5

7 P

M

A5.3

ENLARGED UNITPLANS

Author

Designer

14049

GRADINGUSE

PERMIT

CU

BIX

AU

RO

RA

AP

AR

TM

EN

TS

1008 N

109T

H S

T.

Checker

PA

RK

ST

ON

E P

RO

PE

RT

IES

DP

D #

6481751

DA

TE

N0.

DIS

CR

IPT

ION

1/2" = 1'-0"1

TYP B UNIT 5 1/2" = 1'-0"

2TYP A UNIT 3

1/2" = 1'-0"3

TYP B UNIT 4

burtce
Text Box
EXHIBIT A REPRESENTS CONFIGURATIONS WHICH DO NOT COMPLY WITH THE CURRENT DRAFT GUIDELINE AND DIRECTOR'S RULE GOVERNING SMALL EFFICIENCY DWELLING UNITS. BURTCE 9-11-15
john.morefield
Text Box
EXHIBIT A
Page 8: 2015 St. Seattle WA Robin Murphy Jackson|Main Architecture

GUIDELINE FOR SMALL EFFICIENCY DWELLING UNIT FLOOR AREA

06/12/2015 (Draft)

CODE REQUIREMENTS:

• Efficiency dwelling units must have a “living room” of 220 sq ft (SBC 1208.4).

o (Interpretation): An efficiency dwelling unit is a dwelling unit with one habitable room.

• Habitable space is defined as space used for living/eating/sleeping/cooking, specifically excludes

halls, closets/storage, bathrooms/toilet rooms, and utility spaces (SBC Ch 2).

• DR 25-2014 requires/allows “a room” of at least 150 sq ft in a Small Efficiency Dwelling Unit

(SEDU). Bathrooms, cabinets, appliances, structural features and closets are specifically

excluded.

QUESTIONS:

• When is the entry area part of the “room” in a SEDU?

• When does a narrower area become a “hall” for the purposes of determining habitable space in

a SEDU?

GUIDELINES:

Main area requirements:

• Area used for living/eating/sleeping/cooking (per “habitable room” definition)

• Min. 100 sq ft floor area

• Meets “7-foot square for the 70 sq ft” standard

o 7’ square can be translated to/into all areas counted toward 70 sq ft min. room size

o Sides of square to be parallel/perpendicular to principal walls or principal axes of room

• Bump-outs < 7’ dimension can be included as part of 100 sq ft area (but not the 70 sq ft

requirement) if not deeper than wide (max 1:1 ratio). Does not include bay windows (not floor

area), cabinets, appliances, other enclosed spaces (closets, bathrooms, etc.)

• Circulation space around furnishings and in kitchen (min. 3’ working space in front of appliances

per SBC 1208.1) can be included. Circulation paths from the main room to the unit entry or the

bathroom are subject to the entry area and “connector” guidelines below.

• The main area, plus the entry area or portion thereof, plus a “connector” between the entry and

the main area can be considered as one room, subject to the guidelines below.

o The main room and any entry or connector area used to comply with the 150 sq ft

requirement must be contiguous.

Entry floor area or portion of entry can be considered part of the main area if:

• The length cannot exceed the width [Max. 1:1 ratio (length:width)]

o Length measured in direction of travel from main area

• Min. 5’ dimension (perpendicular and parallel to walls)

• Common wall/wall line has unobstructed width/area:

o Min. 50% width

o Min 25 sq ft area

• Min 7’6” ceiling height. No exception for sloping ceilings, beams, etc.

• Connector OK if complies with below

• Entry area plus connector area < 50 sq ft

A “connector” is part of the main area (not a hallway) if:

• Part of circulation path between main area and entry or bathroom

• Max. 4’ long

john.morefield
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EXHIBIT B
Page 9: 2015 St. Seattle WA Robin Murphy Jackson|Main Architecture

• Common wall/wall line at main area and additional area is unobstructed

o Min 25 sq ft area

• Min 7’6” ceiling height. No exception for sloping ceilings, beams, etc.

FACTORS TO CONSIDER:

• Look and feel. Does the entry area and connector look and feel like part of the main room?

Avoid look and feel of long hallways.

• Use of space. Areas clearly used for living/eating/sleeping/cooking are part of main room.

Circulation-only must meet entry & connector guidelines.

• Size of entry and connector relative to main area. Although part of one room, can’t be too big in

proportion. Note that the entry or connector can be larger (subject to the other maximums),

but the area won’t count toward the 150 sq ft.

• Openness to main area. Part of look and feel.

• Proportion of connector. Longer length:width looks more like a hallway. If wider than 4’, starts

looking more like part of the main area when compared to max. 4’ length.

OTHER NOTES:

• Min. 25 sq ft opening and min. 7’6” ceiling height translates to 3’4” wide connector. 8’ ceiling

height => 3’1½” wide connector. Practical limit is 3’ to move furniture, appliances.

• Unobstructed opening size requirements are consistent with natural light requirements (SBC

1205.2.1)

• Min. ceiling height is consistent with habitable room requirement (1208.2).

• See “SEDU Examples – Acceptable Floor Area”

john.morefield
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EXHIBIT B
Page 10: 2015 St. Seattle WA Robin Murphy Jackson|Main Architecture

DPD

Director’s Rule 25-2014 Applicant:

City of Seattle

Department of Planning and Development

Page

1 of 2

Supersedes:

6-2004

Publication:

12/22/2014

Effective:

2/2/2015

Subject:

Small Efficiency Dwelling Units

Code and Section Reference:

Seattle Building Code

Type of Rule:

Code Interpretation

Ordinance Authority:

SMC 3.06.040

Index:

Seattle Building Code

Approved Date ___________________________ Diane M. Sugimura, Director, DPD

BACKGROUND: This Rule sets forth minimum room size and other technical requirements for small efficiency dwelling units. The Seattle Building Code (SBC), Section 1208.3 regulates minimum room sizes for dwelling units, and Section 1208.4 regulates efficiency dwelling units. Section 1208.4 requires an efficiency dwelling unit to have a living room of not less than 220 square feet of floor area. In addition, Section 1208.4 requires there to be a separate closet and bathroom, as well as a kitchen area with a kitchen sink, a cooking appliance, and refrigeration facilities. This Rule allows for efficiency units smaller than required by Section 1208.4, when other specified amenities are also provided.

City of Seattle Department of Planning and Development Diane M. Sugimura, Director 700 Fifth Avenue, Suite 2000, PO Box 34019, Seattle, WA 98124-4019

Page 11: 2015 St. Seattle WA Robin Murphy Jackson|Main Architecture

Director’s Rule 25-2014 Page 2 of 2

RULE: Buildings containing small efficiency dwelling units shall comply with the Seattle Building Code, except when modified by this Rule. Small efficiency dwelling units are single, independent, residential units that consist of one habitable room (excluding kitchen, bath, and storage rooms). Floor area: A small efficiency dwelling unit shall have a room of at least 150 net square feet of floor area on one level. The floor area occupied by bathrooms, cabinets, appliances, structural features, and any closets shall not be included in calculating the net floor area. Food preparation area: Each small efficiency dwelling unit shall contain a food preparation area. The food preparation area shall include:

• cooking appliance; • refrigerator; • sink with hot and cold water; • food and utensil storage space; and • contiguous countertop work area of not less than 4 square feet.

For the purposes of this Rule only, a microwave oven is permitted to serve as the cooking appliance. The food preparation area shall be provided with two 20 amp small appliance branch circuits. Each circuit shall serve at least one duplex receptacle. Built-in cooking appliances shall be on an additional circuit. Closets and Storage: A built-in closet shall be provided within each unit. The portion of a closet used to store a built-in bed or other built-in equipment shall not be counted in the unit’s required square footage, and it also shall not be counted as a required closet. In addition, there shall be 55 cubic feet of storage space provided for each unit. This can be located anywhere within the building, and several may be grouped together in a common storage area. Natural Light: The habitable room in the unit shall be provided with natural light, complying with Section 1205.2.

Page 12: 2015 St. Seattle WA Robin Murphy Jackson|Main Architecture
siu
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siu
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siu
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siu
Rectangle
siu
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siu
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siu
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siu
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siu
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siu
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siu
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Main area
siu
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Entry area
siu
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Connector
siu
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130 sq ft
siu
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142 sq ft
siu
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110 sq ft
siu
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burtce
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THIS SHEET REPRESENTS SAMPLE CONFIGURATIONS WHICH COMPLY WITH THE CURRENT DRAFT GUIDELINE AND DIRECTOR'S RULE GOVERNING SMALL EFFICIENCY DWELLING UNITS. BURTCE 9-11-15
Page 13: 2015 St. Seattle WA Robin Murphy Jackson|Main Architecture

48X56

30X48

30X

48

2' - 9" 2' - 7 7/8" 5' - 0"

10' - 11"

1' - 8"

5' -

0"

4' -

0"

13' -

5 3

/4"

7' - 9 1/2"

60x60

ENTRY

25 SF

84x84

105 SF

60x48

CONNECTOR

45 SF

3' -

0"

john.morefield
Text Box
EXHIBIT C
burtce
Text Box
THIS SHEET REPRESENTS CONFIGURATIONS WHICH COMPLY WITH THE CURRENT DRAFT GUIDELINE AND DIRECTOR'S RULE GOVERNING SMALL EFFICIENCY DWELLING UNITS. BURTCE 9-11-15