HomeMy WebLinkAboutB23-1186 006-670-013 AMMR Request REQUEST FOR MODIFICATIONS OR ALTERNATE MATERIALS
AND METHODS REVIEW
Fire Code Sections 104.9—Modifications and 104.10—Alternate Materials and Methods
SECTION 1 —APPLICANT
INSTRUCTION: Applicant(s) or Project Owner(s) or Owner(s) designee (with written
authorization from Project Ownership accompanying this form). Please complete SECTION 1
and submit this form and all supporting documents (building plans, calculations, specifications,
test reports, etc.)to the Fire Marshal Office for review of this document.A non-refundable
Alternate Materials and Methods Review fee is required upon submittal and prior to the review.
Permit Number: B23-1186 APN: 006-670-013 Date: 11/15/2023
Project Address: 4475 Nord Highway,Chico
Owner: Liane Christensen Owners Address: momof4kydz@gmail.com
Applicant: Bre Moebius, Hefner Law Applicants Email: bmoebius@hsmlaw.com
Counsel/Agent for Applicant and Owner
Applicant's Phone Number:(916)639-8277
❑x Modification [] Alternate Materials ❑x Alternate Methods of Construction or Protection
Project Description:
Modification Request - Explain the practical difficulties involved in carrying out the provisions of
the Code and proposed application. —OR—Alternate Request- Explain the materials, designs, or
methods of construction not specifically prescribed in the Code and proposed application.
(Attach additional documents as necessary):
Refer to Overview and Project Sections in supplementary AMMR Support letter
Applicable Code References: (List all applicable Code Sections)
Refer to Applicable Code References Section in supplementary AMMR Support letter
Justification: Demonstrate conformity and equivalence with that prescribed in the Code.
(Attach additional documents as necessary):
Refer to Justification section in supplementary AMMR Support letter
SECTION 2 - FIRE MARSHAL OFFICE USE ONLY- FINAL DETERMINATION: This request is:
❑ APPROVED (Provide Conditions of Approval, if Any) Approved By:
❑ NOT APPROVED (Provide comments, if any) Not Approved By:
Comments:
0 ENGINEERED FIRE SYSTEMS, INC.
FIRE PROTECTION SPECIALISTS
November 15, 2023
Butte County Fire Department
Fire Prevention Bureau
7 County Center Drive
Oroville, CA 95965
Re: Christensen Barn
Modification and Alternate Method of Protection Analysis
Overview
This document provides the analysis in support of a Modification under Fire Code Section 104.9 and,
alternatively, an Alternative Method of Protection under Fire Code Section 104.10 for the Christensen
Barn Special Events Facility, hereafter referred to as "The Barn." The Barn is classified as a group A-2
occupancy of type V-B construction with a fire area of 5,971 square feet and an occupancy limit of 225
per use permit 22-0004.The acronym"CFC"shall refer to 2022 edition of the California Fire Code in this
document.
Fire Code Section 104.9 provides: "Where there are practical difficulties involved in carrying out the
provisions of this code,the fire code official shall have the authority to grant modifications for individual
cases,provided that the fire code official shall first find that special individual reason makes the strict letter
of this code impractical and the modification is in compliance with the intent and purpose of this code and
that modification does not lessen health, life and fire safety requirements. The details of action granting
modifications shall be recorded and entered in the files of the department of fire prevention."
Fire Code Section 104.10 provides:"The provisions of this code are not intended to prevent the installation
of any material or to prohibit the design or method of construction not specifically prescribed by this code,
provided that any such alternative has been approved. An alternative material, design or method of
construction shall be approved where the fire code official finds that the proposed design is satisfactory
and complies with the intent of the provisions of this code, and that the material, method or work offered
is, for the purposes intended, not less than equivalent of that prescribed in this code in quality, strength,
effectiveness, fire resistance, durability and safety. Where the alternative materials, design or method of
construction is not approved, the fire code official shall respond in writing, stating the reasons why the
alternative was not approved."
The Barn is in a rural area and has its water supplied by an existing onsite well. The Barn does not have
access to available water supply to meet the fire flow requirements (CFC Appendix B) or fire sprinkler
system water demand requirements (CFC 903) of the CFC. However, the CFC has contemplated this
scenario and provides an allowance such that NFPA 1142"Standard on Water Supplies for Suburban and
Rural Firefighting"can be utilized when adequate and reliable water supplies are not available.
11832 Tammy Way dprice@efsl.com (530) 274-9400
Grass Valley, CA 95949 www.efsl.com Fax (530) 274-9488
This letter makes use of NFPA 1142 to propose a modification and alternative method to achieve code
compliance that maintains equivalent life-safety,property protection, and firefighting goals.
Project
Based on the fire area, construction type, occupancy load, and occupancy group, the CFC requires the
following for the Barn:
• A fire flow of 2,000 gallons per minute
• An automatic fire sprinkler system installed in accordance with section 903.3.1.1 (NFPA 13
commercial system)
As an alternative to the two above requirements,this Alternative Methods of Protection analysis proposes
the following:
• An onsite water supply of at least 30,375 gallons installed in accordance with NFPA 1142.
o There are two options contemplated for the water supply.The water supply would be either
a dedicated onsite water tank of at least 30,375 gallons, or an existing 40,000-gallon pool
located 150 feet away from The Barn.
• A draft (suction)hydrant near The Barn, through which the fire department can access the water
supply.
• An automatic Fire Sprinkler System installed in accordance with section 903.3.1.2 (NFPA 13R
Residential System) and enhanced with steel piping as well as a monitored with a flow switch,
tamper switch,and fire alarm panel.
Applicable Code References
The following codes and standards are utilized for this Modification and Alternative Method of Protection
analysis:
• 2022 edition of California Fire Code
• 2022 edition of NFPA 13
• 2022 edition of NFPA 13R
• 2022 edition of NFPA 1142
The code-basis for this Modification and Alternative Method of Protection is below.
Section B 103 of the CFC allows for a modification to fire flow requirement when an adequate and
reliable water supply is not available.
2022 Edition of California Fire Code
B103.3 Areas Without Water Supply Systems
For information regarding water supplies for fire-fighting purposes in rural and suburban
areas in which adequate and reliable water supply systems do not exist, the fire code
official is authorized to utilize NFPA 1142.
NFPA 1142 provides information on sizing and maintaining an onsite water supply that can be
treated as equivalent to fire flow.Additionally,NFPA 1142 contemplates that properties which do
not have access to a sufficient water supply may be comprised in their ability to fully meet the
requirements of an automatic sprinkler system.
2022 Edition of NFPA 1142
4.4*Structures with Automatic Sprinkler Protection.
4.4.1
The AHJ shall be permitted to reduce the water supply required by this standard for
manual firefighting purposes when a structure is protected by an automatic sprinkler
system that fully meets the requirements of NFPA 13, NFPA 13D, or NFPA 13R. (See
Annex F.)
4.4.2
If a sprinkler system protecting a building does not fully meet the requirements of NFPA
13, NFPA 13D, or NFPA 13R, a water supply shall be provided in accordance with this
standard.
This Modification and Alternative Method of Protection proposes to provide a water supply in
accordance with NFPA 1142 and then utilize section &4.4.2 to install a monitored, automatic fire
sprinkler system based off of NFPA 13R (residential) in the place of an NFPA 13 (commercial
system). In the subsequent `Justification' section, this analysis will take the position that the
monitored NFPA 13R system, complemented with the NFPA 1142 water supply as well as other
fire and life-safety precautions, is a code-compliant alternative for The Barn that achieves
equivalent fire protection and life safety goals for the space.
Justification
This Modification and Alternative Method of Protection justification is formulated upon three parts. First
an NFPA 1142 calculation is provided to illustrate that the proposed onsite water supply will meet or
exceed 1142 requirements. Second a discussion is provided of the capabilities and limitations of an NFPA
13R sprinkler system relative to an NFPA 13 system and take the position that an NFPA 13R system,
augmented with sprinkler monitoring and the 1142 water supply,can meet the fire protection goals of this
structure. Third, taking a holistic view of the fire protection and life safety factors of the structure, the
analysis will identify areas in which The Barn exceeds code-mandated fire protection requirements.
NFPA 1142 Calculation
The following formula is provided in NFPA 1142 to determine the minimum water supply for structures
that do not have exposure hazards. (An exposure hazard is defined as "a structure within 50 ft of another
building and 100 ft2 or larger in area."The Barn does not have any exposure hazards).
WSmin = Vs`°`OHC (CC) Equation 1
-
where:
WSmin=minimum water supply in gal
VSrot=total volume of structure in ft
3
OHC =occupancy hazard classification number
CC =construction classification number
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Figure 1: South Elevation view of The Barn
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Figure 2:West Elevation view of The Barn
• The total volume of The Barn, VStot,is approximately 81,000 ft.
• The occupancy hazard classification number, OHC, is determined by a set of tables in Chapter 5
of NFPA 1142. The lower the OHC,the greater the water supply requirement. Chapter 5 provides
a list of example structures and their corresponding OHC value.In terms of intended use,The Barn
is probably most like the structures with an OHC value of 5, which include Amusement
Occupancies and Restaurants. However, to be more conservative in this analysis, we will utilize
an OHC value of 4 which includes Commercial Barns and Stables.
• The Construction Classification number, CC, is provided in a table within Chapter 6 of NFPA
1142.Wooden structures of Type V construction have a CC value of 1.5.
Entering the above values into the NFPA 1142 equation yields a minimum water supply requirement,
WSmin,of 30,375 gallons.
L . a
In this Modification and Alternative Method of Protection analysis,the required water supply is proposed
to be one of two possible sources. The water supply will be accessible to the fire department through a
draft hydrant.
• One proposed water supply is a dedicated water storage tank of at least 30,375 gallons.
• The other proposed water supply is an existing, approximately 40,000-gallon pool, 150 feet from
The Barn.The pool is under the same ownership as The Barn.
Whether the tank or the pool is utilized,the water supply will be kept full year-round and will be maintained
in accordance with Chapter 7 of NFPA 1142. Piping will be installed connecting the water supply to the
draft hydrant. The draft hydrant will be installed,tested, and maintained in accordance with Chapter 8 of
NFPA 1142 and will be capable of supplying a minimum of 1,000 gallons per minute.
NFPA 13R Discussion
Due to the presence of an onsite water supply that meets the minimum requirements of the above NFPA
1142 calculation,NFPA 1142 allows for a sprinkler system "that does not fully meet the requirements of
NFPA 13, NFPA 13D, or NFPA 13R".
This Modification and Alternate Method of Protection analysis proposes to use an enhanced NFPA 13R
(Residential)system in the place of an NFPA 13 (Commercial)system.
The justification for this proposal is as follows:
• The Barn is to be used as an event center for gatherings and meals. The fuel load within the Barn
is very similar to a fuel load in a residential setting: tables, chairs, tablecloths, etc. There is no
commercial kitchen in The Barn that could pose the opportunity for an oil-based fire,there is only
a Food Prep area with standard residential kitchen fixtures.
• The NFPA 13R system will be designed with sufficient water supply to be able to operate 4 fire
sprinklers simultaneously.According to the 2021 research report from the NFPA aggregating data
from 61,100 fires between 2015 and 2019 where fire sprinklers were deployed, it was found that
in 77%of cases,the fire was controlled with the deployment of a single sprinkler. In 97%of fires,
the fire was controlled with 5 or fewer sprinklers.
• A traditional NFPA 13R system does not require the fire sprinkler system to be monitored by a fire
alarm panel. This Modification and Alternative Method of Protection analysis proposes and
enhanced NFPA 13R system that includes tamper switch monitoring and water flow switch
monitoring in the fire sprinkler system.This will notify the fire department immediately if the fire
sprinkler system is ever deployed,reducing the potential incident response time.
Additional Fire Protection Measures at The Barn,
Complementing what has been discussed above, The Barn already possesses, or proposes to implement,
measures to exceed code requirements with respect to fire protection in life safety.
• The Barn has a calculated occupant capacity of 513 persons. However, per its Minor Use Permit,
The Barn will limit occupancy to no more than 225. The implication of this lower occupancy is
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that in the event of an emergency, occupants will be able to easily and quickly evacuate as there
will not be dense seating with ill-defined aisles.
• The Barn has 6 exits which is double the 3 exits that would be required based on 513 occupants
that could be allowed based on square footage (the occupancy load is much less at 225 based on
the Minor Use Permit).In addition to the six exits that meet Building Code requirements as"exits,"
the Barn has two additional large barn doors.
• The Barn has eight fire extinguishers which is four times the two required.
• The Barn has multiple safe dispersal areas with designated dispersal areas to the east and west,and
a gravel parking lot is immediately to the north.
• The Barn proposes to implement a limitation on the use of open flames indoors, with flames only
being allowed in designated candle holders.
• The Barn proposes to implement a limitation on wall hangings and tapestries, with only fire-
retardant hangings to be allowed.
This Modification and Alternative Method of Protection analysis is based on the information provided to
me regarding the existing condition of The Barn and surrounding property as well as proposed renovations.
If there are any questions regarding aspects of this analysis,please feel welcome to contact me.
Sincerely,
Dca ru eAi Price'
Daniel Price
Fire Protection Engineer, PE
Engineered Fire Systems
dnrice@efs l.com
(530)274-9400 ext 208
ref. 33292
b'� J
•
0 ENGINEERED FIRE SYSTEMS, INC.
t FIRE PROTECTION SPECIALISTS
DANIEL PRICE
Fire Protection Engineer
BIO
Daniel is a licensed Fire Protection Engineer and a Principal at Engineered Fire Systems, Inc. (EFS)where
he oversees the companies fire protection engineering practice.Prior to joining EFS,Daniel founded,grew,
and operated a 30-person engineering consulting company focused on the research, development, and
implementation of new technological systems. In that role Daniel taught fire protection seminars at
national conferences and gave a TEDx talk on new technologies. Daniel attended Oxford University on a
Rhodes scholarship where he earned an MBA and an engineering master's degree. For undergraduate
Daniel attended UC Berkeley where he graduated summa cum laude with two engineering degrees and a
physics minor.
EXPERIENCE
Apr 2019—Present
Principal, Fire Protection Engineer, ENGINEERED FIRE SYSTEMS
Provide consulting,engineering,and design services for residential and commercial fire protection
systems.
Nov 2019-Present
Co-Founder, IOTERRA
Co-Founded and manage a platform of Internet of Things(loT)-related technologies and services.
Sep 2015—Mar 2020,
Co-Founder & CEO, BREADWARE
Co-founded and oversaw all parts of the business of a premier product development and 30-
person engineering consulting firm specializing in Internet of Things.Acquired in 2020.
May 2014—Aug 2015
Head of Electrical Engineering, MotoCrane
Managed the architecture,engineering,and manufacturing of the MotoCrane electronics system.
11832 Tammy Way dprice@efs1 .com (530) 274-9400
Grass Valley, CA 95949 www.efsl.com Fax (530) 274-9488
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EDUCATION
2014-2016
MBA, UNIVERSITY OF OXFORD
M.S. Biomedical Engineering, UNIVERSITY OF OXFORD
Rhodes Scholarship: selected as 1 of 32 students in the US to receive a 2-year scholarship to
Oxford University, during which completed 2 Master's degrees
Received Sir Michael Brady Prize: awarded to the single top graduating student from the
Biomedical Engineering Master's degree Program
2009-2013
B.S. Electrical Engineering and Computer Science, UC BERKELEY
B.S. Bioengineering, UC BERKELEY
(Minor) Physics, UC BERKELEY
Completed 2 engineering degrees as well as a physics minor in 4-year period
Received Departmental Citation: awarded to the single top graduating student from the
Bioengineering Bachelor's degree program
SELECTED SPEAKING HISTORY, KEYNOTES, AND SEMINARS TAUGHT
August 25, 2021
IOT Recon—with Hardware Massive and loterra
"How CAN lOT EFFECTIVELY COMBAT WILDFIRES"
Session Moderator
OCTOBER 18,2019
Potter Signal Conference 2019
"DEFINING THE FUTURE OF LIFE SAFETY(IOT/CLOUD SERVICES ROUNDTABLE)"
Seminar Leader
January 27. 2018
TEDx University of Nevada
"How DO WE BUILD TRUST INTO THE INTERNET OF THINGS?"
TEDx Speaker
7t.wwwwww- — 1.4* -wow
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CAL -1 Butte County Fire Department
FIRE i S` lit
.: Fire Prevention Bureau
176 Nelson Avenue Oroville, CA 95965 �..a.
Office(530)538-7888
www.buttecou ntv.netlfire •CA L I F O N N I A•
Tuesday, December 12, 2023
Breann Moebuis
2150 River Plaza Drive, Suite 450
Sacramento CA, 95833
Re: Christensen Barn Alternate Means and Methods Application
Dear Mrs. Moebuis,
Butte County Fire Department has completed the review of your Alternate Materials and
Methods application for the Christensen Barn Special Events Facility, at 4475 Nord Highway in
Chico. As stated in the application, "The Barn" is classified as a group A-2 occupancy of type V-
B construction with a fire area of 5,971 square feet and an occupancy limit of 225 per use permit
22-0004. Based on the fire area, construction type, occupancy load, and occupancy group, the
2022 California Fire Code(CFC) requires an automatic fire sprinkler system installed in
accordance with section 903.3.1.1.
California Fire Code section 903.3 further details that system design and installation should be
per National Fire Protection Association Handbook 13 (NFPA). NFPA 13R system design and
installation are addressed in CFC 903.3.1.2 and notably, are only permitted in R occupancy
groups. Sprinkler systems designed following NFPA 13R are intended to prevent flashover(total
involvement) in the room of fire origin and to improve the chance for occupants to escape or be
evacuated. The 2021 IFC Code and Commentary further state that"NFPA 13 systems provide
the level of protection associated with adequate fire suppression for all occupancies. NFPA 13R
and NFPA 13D systems are intended more to provide adequate time for egress but not
necessarily for complete suppression of the fire."
NFPA 13R Section 1.1 expresses this limitation, as does the IBC 903.3.1.2. The 2019 NFPA 13R
Handbook Commentary suggests, "NFPA 13R provides a high, but not absolute, level of life
safety and a somewhat lesser degree of property protection. A higher degree of property
protection will be achieved with the installation of an NFPA 13 sprinkler system, which allows
fewer unsprinklered areas and requires a more robust design and installation basis. Where
property protection is the primary objective of the owner or system designer, installation of an
NFPA 13-compliant system should p e build owner or developer is not
ing
companies are requiring their
limited to using an NFPA 13Rsystem. More and more
clients to provide NFPA 13 systems for buildings that could be protected with an NFPA 13R
system."
Exceptions for the use of NFPA 13R and 13D systems are addressed throughout the code when
exceptions based on the use of sprinklers are provided. More specifically, if the use of these
other standards is appropriate, it will be noted within the exception. For a building to be
considered"equipped throughout" with an NFPA 13 sprinkler system, complete protection must
be provided in accordance with the referenced standard, subject to the exempt locations indicated
in Section 903.3.1.1.1.
Within your code-basis and NFPA 13R Discussion, it is stated that NFPA 1142, Chapter 4,
Section 4.4 allows for a sprinkler system "that does not fully meet the requirements of NFPA 13,
NFPA 13D, or NFPA 13R". The Butte County Fire Department interprets this section
differently. Similar to Annex B and BB in the California Fire Code,NFPA 1142, Section 4.4.1
permits reductions in required fire flow when structures are sprinkled in accordance with NFPA
13/13R/13D. Section 4.4.2 does not intend to permit a lesser level of sprinkler protection, but to
require the complete fire flow when a partial or limited area system is installed.
It is also worth mentioning that absent from your submittal were any test data, reports from a
recognized institution, or examples of previous installations. While the sections contained within
the California Fire Code and NFPA 13 cannot address every conceivable arrangement of
equipment that is acceptable, they do describe what is not allowed. Based on the review of the
submitted information, the Butte County Fire Department finds that your AMIVIR does not
comply with the intent of the applicable code and does not provide an equivalent level of fire and
life safety. Please let me know if you require any further assistance.
Sincerely,
/4444),idoel 827/
Garrett Sjolund Chris Boyd
Fire Chief Deputy Fire Marshal