HomeMy WebLinkAboutPC Agenda Packet 2022-12-28
AGENDA
PLANNING COMMISSION
Hybrid Meeting – In-Person and Virtual
City Council Chambers: 321 East 5th Street, Port Angeles, WA 98362
Attend Virtual Meeting Here: https://www.cityofpa.us/984/Live-Virtual-Meetings
December 28, 2022
6:00 p.m.
I. CALL TO ORDER
II. ROLL CALL
III. PUBLIC COMMENT
IV. APPROVAL OF MINUTES
Minutes of the December 14, 2022 Regular Meeting
V. DISCUSSION
1. Pursuing Housing for All – Title 17 Code Amendment Process
Continuation of the Port Angeles Municipal Code (PAMC) update process. Review
and discussion of the December 28, 2022, Staff Memorandum prioritizing
recommended changes to the PAMC based on Planning Commission feedback.
VI. STAFF UPDATES
VII. REPORTS OF COMMISSION MEMBERS
VIII. ADJOURNMENT
December 28, 2022 Planning Commission Agenda Packet Page 1 of 23
Minutes from Previous
Meeting
December 14, 2022 Planning Commission Agenda Packet Page 2 of 18
December 28, 2022 Planning Commission Agenda Packet Page 2 of 23
MINUTES
PLANNING COMMISSION
Hybrid Meeting – In Person and Virtual
City Council Chambers: 321 E 5th Street, Port Angeles, Washington 98362
December 14, 2022 6:00 p.m.
REGULAR MEETING
CALL TO ORDER
Chair Stanley opened the regular meeting at 6:04 P.M.
ROLL CALL
Commissioners Present: Benjamin Stanley (Chair)
Andrew Schwab (Vice Chair)
Tammy Dziadek
Marolee Smith
James Taylor
Commissioners Absent: Richie Ahuja, Colin Young - excused
City Staff Present: Ben Braudrick (Senior Planner)
Holden Fleming (Housing Coordinator)
Norman Gollub (Interim Director of Community and Economic
Development)
Zach Trevino (Assistant Planner)
Public Present: Brian M.
PUBLIC COMMENT
Chair Stanley opened the meeting to public comment.
Brian M. provided comment praising City Councilmember Mike French for his service
and encouraging Chair Stanley and Commissioner Young to apply for the open position on
the City Council.
Chair Stanley closed the meeting to public comment.
APPROVAL OF MINUTES
Vice Chair Schwab moved to approve the minutes from the October 26, 2022 regular
meeting of the Planning Commission. The motion was seconded and passed by unanimous
consent (5-0).
DISCUSSION ITEM
1. Housing for All Code Amendment Process
December 28, 2022 Planning Commission Agenda Packet Page 3 of 23
Planning Commission Minutes
December 14, 2022
Page 2
Planner Braudrick introduced the discussion item, providing an overview of the staff
memorandum included in the agenda packet. He noted that several commissioners
provided comments in response to the memorandum, which was distributed for their review
and input prior to the meeting. Each commissioner had been asked to identify five
suggestions from the list in the memorandum that they feel should be prioritized.
Planner Braudrick explained each of the six criteria that were established to serve as the
foundation of the Housing for All code amendment process, which will result in
amendments to the Port Angeles Municipal Code (PAMC) that reduce barriers to housing
production. He concluded his introduction by explaining that the purpose of this Planning
Commission meeting is to narrow down the suggestions in the memorandum to a
prioritized list that can be presented to the public at a workshop on January 25th.
The Commission’s discussion of the memorandum began with an overview of the written
comments that had been provided in advance of the meeting. Commissioners Smith and
Dziadek each explained the comments they had submitted. Commissioner Young’s
comments were acknowledged.
Following the presentation of individual comments submitted by Commissioners, the
Commission conducted a review of the list of suggestions contained in the memorandum.
This involved a discussion of each bulleted item contained in the suggested “Staff Code
Changes” list. The Commission’s discussion followed the order of the bulleted list in the
memorandum. The full discussion of each item is available in the recording of the Planning
Commission meeting.
Chair Stanley clarified that staff would proceed to take a more detailed look at the items
the Commission identifies as priority PAMC changes following this discussion.
Following the Commission’s discussion of each of the 25 bulleted items in the
memorandum, staff requested that the Commissioners identify which items are most
important in their perspective. This will allow staff to provide a prioritized list of suggested
PAMC amendments, based on the Commission’s feedback, for consideration at the next
regular Planning Commission meeting.
Chair Stanley identified the following items as priority changes:
1. Build residential capacity in commercial zones and structures to the greatest
extent possible by allowing accessory dwelling units in commercial zones.
2. Allow for commercial to residential conversion on the ground floor of structures
in the Central Business District (CBD).
3. Allow a detached accessory dwelling unit (ADU) to be constructed accessory
to a duplex on one lot in all residential zones where duplexes are allowed by
right.
4. Creation of a new section of Title 17 PAMC that facilitates the establishment
of temporary housing, including through occupancy of recreational vehicles.
5. Enable a City-led development authority and land bank through which the City
could act as a developer and then sell developed housing to the private sector.
Vice Chair Schwab identified the following items as priority changes:
December 28, 2022 Planning Commission Agenda Packet Page 4 of 23
Planning Commission Minutes
December 14, 2022
Page 3
1. Fix errors and clarify terminology in the PAMC to ensure consistency and
uniformity of regulations. These changes were referred to as “housekeeping”
items.
2. Disincentive single-household dwelling construction by providing a fee
discount or other incentive for a developer to construct multi-family housing
instead.
3. Allow the establishment of ADUs in more locations through an easier approval
process.
4. Eliminate maximum bedroom requirements for ADUs.
5. Creation of a new section of Title 17 PAMC that facilitates the establishment
of temporary housing, including through occupancy of recreational vehicles.
Commissioner Smith identified the following items as priority changes:
1. Creation of a new section of Title 17 PAMC that facilitates the establishment
of temporary housing, including through occupancy of recreational vehicles.
2. Allow a detached accessory dwelling unit (ADU) to be constructed accessory
to a duplex on one lot in all residential zones where duplexes are allowed by
right.
3. Eliminate maximum bedroom requirements for ADUs.
4. Codify pre-application requests with a firm timeline and deliverable date.
5. Define “apartment” and add as a permitted use in all commercial zones.
6. Exempt apartments located above businesses from residential density
requirements.
Commissioner Dziadek explained that she needs more time to choose the items she
believes are priorities.
Following the identification of priority items by each Commissioner, Chair Stanley closed
the discussion and confirmed that the Commission will be continuing the PAMC
amendment process at subsequent meetings.
STAFF UPDATES
City staff provided several updates to the Commission, as follows:
• Planner Braudrick noted that Commissioner Taylor is new to the Planning
Commission. He expressed appreciation for Commissioner Taylor’s willingness to
participate and contribute to the Commission’s work.
• The City was able to secure additional funding and will soon enter into a contract with
a contractor for completion of Phase I of the Race Street Improvement Project.
Construction is anticipated to begin in February.
• The City has been selected by the Washington Department of Commerce as one of
three communities in the State to participate in the Department’s Climate Pilot
Program. The program will aid the City in integrating climate action planning and the
Climate Resiliency Plan into the Comprehensive Plan during the next update in June
December 28, 2022 Planning Commission Agenda Packet Page 5 of 23
Planning Commission Minutes
December 14, 2022
Page 4
of 2023. On December 15th, the City will begin the process to conduct a limited sea
level rise vulnerability assessment. A workshop will occur with the Planning
Commission in February as part of this process.
• Planner Fleming has been participating in Housing Solution Committee meetings,
which the Commissioners are encouraged to attend.
• Staff has begun developing promotional materials for the Housing for All code
amendment process discussed at this Commission meeting. These will be an important
part of a larger public engagement effort that will involve the Commission.
REPORTS OF COMMISSION MEMBERS
• Vice Chair Schwab announced that the scaffolding has been removed from the Lee
Plaza building in the Central Business District. He also noted that he is currently
reading a book titled The Color of Law by Richard Rothstein.
ADJOURNMENT
Vice Chair Schwab moved to adjourn the meeting. The motion was seconded and
passed unanimously (5-0).
The meeting adjourned at 8:46 p.m.
Zach Trevino, Secretary Ben Stanley, Chair
MINUTES PREPARED BY: Zach Trevino, Secretary
December 28, 2022 Planning Commission Agenda Packet Page 6 of 23
Discussion Items
December 14, 2022 Planning Commission Agenda Packet Page 7 of 18
December 28, 2022 Planning Commission Agenda Packet Page 7 of 23
`
MEMORANDUM
DATE: December 28, 2022
TO: Port Angeles Planning Commission
FROM: Planning Division Staff
RE: Pursuing Housing for All Code Update: Priority List of Title 17 Code Changes
On December 14, 2022 Planning Staff provided a list of proposed code changes for the Planning Commission
to discuss and prioritize. The following memo is a revision of that list incorporating those priorities and what
staff has deemed can be feasibly accomplished by the March 31, 2023 deadline. This deadline has been
imposed by the Building Residential Capacity legislation of the Growth Management Act (RCW 36.70A.600).
Staff has also prepared draft code for Accessory Dwelling Units (ADU’s) and an excerpt of a Planning
Advisory Service (PAS) report from the American Planning Association on first floor residential uses in
commercial structures. During the December 14th Planning Commission meeting, general consensus was
given that reducing the barriers to ADU development is a top priority. There was less consensus on
residential uses on the first floor of commercial structures, so staff wanted to present what zoning
standards might be used to ensure compatibility with the zone.
Staff has placed all the suggested code Title 17 code amendments into four priority categories for code
change considerations:
Priority, Significant: Planning Commission priorities that will require major changes to code that may include
new code sections, increased complexity, design standards, or require evaluation of the changes to ensure
there is no cascading “domino” effect, or conflict/connection across multiple sections, chapters, or even
titles of the municipal code.
Priority, Minor: Planning Commission priorities that provide support for multiple evaluation criteria but may
not result in municipal code changes staff considers difficult to insert, edit, or draft. These changes likely
have minimal “domino” effects.
House Keeping: Changes identified by staff that have made code interpretation difficult or created
confusion for the public. These changes are generally minor in nature and have little “domino” effect. Their
priority may be less high on the Planning Commission’s scope, but they are related to pursuing housing for
all.
Priority, Out of Scope: Changes related to pursuing housing for all that were seen as important for the City
to review and institute in the future, but were out of scope of this code amendment exercise.
The proposed changes are provided individually within six categories. These categories define either how
December 28, 2022 Planning Commission Agenda Packet Page 8 of 23
P a g e 2
the existing code is a barrier to housing development, an opportunity to provide greater development
flexibility, increase housing density, decrease unnecessary financial burden of existing and developed
housing, or ensure housing for all community members.
Code as a Barrier to Affordable Housing Development
A major focus of this code revision exercise is to identify where the City’s zoning and building code continues
to act as a barrier to the development of affordable and attainable housing. Changes identified under this
criterion have been identified as barriers. The goal is to remove these barriers from code while ensuring
consistency in regulations remains across individual Titles and Sections.
Increasing Flexibility in Zoning Code Provisions
Since 2017 the City of Port Angeles has continued to provide more flexibility in residential uses allowed in
residentially focused zones and commercially mixed-use focused zones. This flexibility includes the use itself
(whether now allowed outright or by condition) and how the use performs on the site through design
standards of setback, height, and bulk standards (how development interacts with adjacent property and
the street). Examples of this include allowing duplexes by right and accessory dwelling units as an accessory
use in every residentially focused zone and reducing lot size requirements in certain zones.
Increasing Housing Density Availability
Housing density has historically been the most significant control segregating districts of residential
development. Increasing housing density allows for more affordable and equity housing availability across
the community. Zoning is a tool to ensure incompatible uses do not create undue nuisance, burdens, or
health impacts to surrounding property owners. Best available science and practice has recently shown that
this frame of thought has created a pattern of development across the United States inhibiting affordable
residential development, especially “missing-middle” housing that has the ability to easily integrate into
historically low-density residential development. The BRC is particularly framed to provide a means to
develop missing middle housing and integrate housing density as infill development into existing low
density residential zones
Reducing the Potential Cost of Development
Development cost not only includes the cost of labor and materials. Cost can also be attributed to the
amount of time the development process takes to navigate from property acquisition to an occupiable
structure; the required infrastructural improvements required to ensure adequate services and safe
occupancy; and restrictive design standards imposed by municipal codes. Municipal codes should not
impose a barrier that drives housing costs up in order to cover the cost of development. Streamlining
permitting, imposing infrastructural alternatives, and strategically relaxing some design standards are all
some ways that municipal codes can assist in reducing housing costs.
Ensuring Housing Equity and Availability
Housing is a human right. In order to appropriately ensure housing for all members of the community,
municipal code should adequately address the needs of everyone. Best available science and practice has
December 28, 2022 Planning Commission Agenda Packet Page 9 of 23
P a g e 3
recognized the faults in requiring strict segregation of certain housing types that can otherwise be
reasonably located adjacent to each other. All community members deserve to have access to housing that
meets their specific needs at any and all stages in their life. Successfully employed municipal code should
act as the framework providing diverse housing construction to support and encourage the realization of
this right for everyone.
Enabling Local Property Development Through Self Reliance
By amending Title 17 to be more easily read and understood, local property owners will more readily
understand development requirements and make choices to maximize the use of their property.
Prioritize List of Draft Code Changes
Priority, Significant:
1. Creation of temporary housing section of Title 17 with design standards and timelines that also
addresses RV’s
The City Council tasked staff and the Planning Commission to develop code to provide City residents
the means to create safe temporary housing for all. This includes a permitting process and any
standards and requirements to address life/safety issues. The Planning Commission additionally
expressed interest in revisiting the proposal to allow a codified permitting process for recreational
vehicles on axels to be considered as temporary housing on private property.
2. Allow for alley/street lot subdivision in areas on property with appropriate existing or updated street
standards.
Many properties in Port Angeles were developed prior to modern setback standards that restrict
the location of the residence towards the center of a building site. Many of these properties are
also within the City’s original townsite plat where access to a street and alley are both available.
Permitting of an interior lot with street and alley access to subdivide perpendicular to those
accesses will allow another means for property owners with historic residences in the far front or
rear of the lot to subdivide and develop a new primary residence. Setback standards and frontage
definitions will also be evaluated to ensure any subdivision proposal is not disruptive to surrounding
neighbors
3. Allow for commercial to residential conversion with design considerations – specific to CBD to allow
for residential on ground floor.
Ground floor residential development is currently only available in the rear of a structure within the
CBD zone. Vacant storefronts might be used as or converted into housing units as the market
allows–either in the interim or permanently–with appropriate design considerations to ensure
future inhabitants have adequate privacy and the adjacent streetscape is not disrupted.
4. Create disincentive fee for large single-household dwellings and use that fee for multi-family market
subsidy.
A recent article by The New York Times highlighted the national decline of the “starter home”
December 28, 2022 Planning Commission Agenda Packet Page 10 of 23
P a g e 4
(homes typically at or below 1400 sq.ft.). Simultaneously, while homes have on average became
larger, household sizes became smaller. A disincentive fee targeted at single household dwellings
significantly above the average size of Port Angeles homes could help slow this trend while directly
supporting the creation of multi-family units. Multi-family units will play an increasingly important
role in providing affordable and equitable access to housing in our community as the cost of
development and redevelopment rises. The disincentive fee as proposed would function similarly
to what other jurisdictions call an Affordable Housing Mitigation Fee.
5. Enable a City-led development authority/land bank (Transfer of Development Rights)
Municipal land banks are typically tasked with addressing issues related to vacant, abandoned and
tax-delinquent real property. This includes, but is not limited to, the purchase, rehabilitation,
improvement, or sale of properties for the purpose of eliminating blight and returning those
properties to productive use. The creation of a municipal land bank would allow for a more direct
method of addressing these issues than what is currently feasible as well as aid the City in facilitating
future targeted economic development. Similarly, Port Angeles may form a Public Development
Authority (PDA) focused on real estate development and management. While these PDAs are
typically focused on a singular public development, a broader scope of focus could be possible.
Priority, Minor:
1. Reevaluate and revise each residential zone’s purpose statement to reflect the changes provided in
the BRC process.
The changes that are being proposed run counter to the R7 zone’s current stated purpose. The
zone’s purpose will change to reflect the availability of a number of mixed middle housing types
that will now be available through several amendments in the code section.
2. Allow a detached ADU to be constructed accessory to a duplex on one lot in all residential zones
where duplexes are allowed by right.
ADUs are an attainable way for a property owner to create affordable housing options in Port
Angeles. With soon-to-be developed permit ready ADU plans being made available by the City of
Port Angeles, allowing them accessory to all primary housing types will reduce the barrier to their
construction and increase affordable housing options.
3. Eliminate bedroom requirements for ADUs
Size restriction is enough of a design consideration and control for ADUs to remain subordinate to
its primary residence. An increase in the number of bedrooms allows for potentially larger
households to occupy an ADU residence.
4. Allow 1 unit per 1,750 sf in the R7 zone.
This change will allow 4 separate primary units on a standard 7000 sf lot, a change that opens the
opportunity for a property owner to acquire a multifamily tax exemption. Standards will ensure
harmony for surrounding neighboring properties and within a block.
December 28, 2022 Planning Commission Agenda Packet Page 11 of 23
P a g e 5
5. Remove maximum per unit requirements for cottage housing developments.
Per unit requirements for cottage housing can be seen as a barrier to housing unit development.
Removing this barrier will allow a developer to determine the residential density of their proposal
based upon the design standards for cottage housing development. The change allows for creative
design within the means of the existing standards. This change does not affect minimum unit per
lot development requirements
6. Allowed dwelling types – if building meets IBC standards per WA state, allow it on any property if the
design meets infill development standards.
Manufactured homes are an affordable residence type regulated by Washington State Labor and
Industries. Double-wide manufactured homes measuring 24X36 sf are the only manufacture
housing type allowed in any zone not RTP, Residential Trailer Park zone. There is a social stigma
against “single-wide” trailers, and this type of housing is only found as an allowed use in the RTP,
Residential Trailer Park zone. The hesitance to allow smaller manufactured housing has to do with
its historic design: the height and roofline of the structure, the finished siding materials, the
orientation of the door to the street, and the overall number of windows and transparency. But,
staff has found that there are manufactured home builders that are producing affordable housing
units that do not abide by the stigmas mentioned above. This code change will require the correct
licensing from the state that ensures the structure meets all life/safety requirements of the
International Building Code and International Residential Code, and it could require some infill
residential design standards to ensure correct building and front door orientation, transparency,
and screening from adjacent properties.
House Keeping:
The following proposal are directly related to consistency and clarification of the zoning code:
1. Replace “single-family with “single-household” to provide inclusivity and equity in Title 17
2. Reestablish consistency among all zone titles (“RS-7” replaced with “R7”)
3. The lower residential zones removed the “S” in 20XX. This housekeeping item will ensure this change
is reflected throughout the entire title.
4. Add definitions in multiple places to ensure people find term they are looking for. E.g. SEE ______
5. Identify inconsistency between PAMC titles
6. Refine use charts to avoid conflicts
7. Define “public” in Title 17 so use of terms such as “public buildings” in Section 17.22.110 are clear
and consistently applied.
The following proposals are directly related to situations where code has created a barrier to developing
housing units:
8. Allow for conversion of accessory structures to housing units in all residential zones regardless of
conformity to zoning standards.
9. Exempt apartments above businesses from residential density requirements
10. Allow preexisting single-household dwelling as allowed use in all zones.
December 28, 2022 Planning Commission Agenda Packet Page 12 of 23
P a g e 6
11. Define “apartment” and add as permitted use in all commercial zones.
The following proposals are in direct response to practical use and intent of the form-based code changes
of Chapter 17.22:
12. Reevaluate landscaped block frontage standards to required minimum frontage distances.
13. Parking standards – sequential spaces and landscaping. Location of parking.
14. Allowance of deviations from design standards for existing historically significant structures.
Priority, Out of Scope:
1. Codify pre-application requests with a firm timeline and deliverable date.
Preapplication Meeting Requests do not currently have a codified process that provides
predictability and guidance to applicants looking to submit an application. This process has been
identified as a potential future change due to the consolidated development permit process chapter
existing in Title 18 and a cost of services analysis currently taking place that will not be completed
until after this amendment is proposed to be adopted.
2. Create Maximum lot sizes in R11 and R9 zones to prevent large lot subdivisions or require a
restriction on the plat requiring future subdivision to be at a minimum density.
This code change would prevent single residential units on large lots from being carved out, leaving
the large lot open to potential development without future subdivision being possible. This can be
due to the frontage available, siting of a future residence, or lack of proper access and utility
easements. Large lots are increasingly scarce in Port Angeles, but this process should include a more
robust review with the inclusion of a change in subdivision standards in Title 16.
3. Define and allow “corner shop mixed-use structure” on strategic residential intersections.
This code change will require analysis that identifies appropriate intersections for this type of
development. The Planning Commission also found that the City should make its focus
neighborhood centers and corridors and the downtown for commercial development before
expanding the availability of commercial development to traditionally residential-focused zones.
Attachments:
1. Draft Updated ADU Design Standard Code
2. Excerpt of PAS Report 472: Converting Storefronts to Housing
December 28, 2022 Planning Commission Agenda Packet Page 13 of 23
17.21.020 - Accessory dwelling unit (ADU).
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A. Purpose. The purpose of an accessory dwelling unit is to:
1. Add affordable units to existing housing and make housing units available to people who might
otherwise have difficulty finding homes within the City.
2. Promote the development of additional housing options in residential neighborhoods that are
appropriate for people at a variety of stages of their lives.
3. Provide homeowners with a means of obtaining, through tenants in either the accessory dwelling unit
or the principal residence, rental income, companionship, or security.
4.Protect neighborhood stability, property values, and the character of the neighborhood.
B. Standards. An ADU, in any zone, must comply with the following development standards:
1. Configuration. An ADU may be located either within, attached to, or detached from a primary
structure housing a primary single-household dwelling or duplex.
2. Density. Only one ADU may be created in conjunction with each single-household dwelling or duplex.
The ADU must be located on the same zoning lot as the primary structure. Accessory housing which
conforms to the standards in this chapter shall not be considered to exceed the allowable density for the
lot upon which it is located and shall be considered a residential use which is consistent with the
comprehensive plan and zoning designation for the lot.
3. Minimum lot size. An ADU must not be established on any parcel smaller than 3,500 square feet.
4. Maximum unit size. The ADU must not exceed 50 percent of the average gross floor area of all other
dwelling units on the lot, not including a detached garage and/or a detached accessory building, or 600
square feet, whichever is larger.
5. Setbacks, height, and site coverage. ADUs must comply with all dimensional standards including the
site coverage, height, and setback requirements of the zone.
6. Scale and visual subordination. The ADU must be visually subordinate to the primary unit. If the ADU
is located within an existing residence, there can only be one main entrance located on the primary
street-facing facade of the single-family residential structure, unless the residence contained additional
entrances before the ADU was proposed. Detached ADU's and entrances that do not have access from
the ground, such as an entrance from a balcony or deck, are exempt from this standard.
7. Parking. The off-street parking requirements set forth in Chapter 14.40 must be provided and
maintained for the primary dwelling. No additional parking is required for an ADU.
8. Addressing. A separate address must be created for the ADU:
December 28, 2022 Planning Commission Agenda Packet Page 14 of 23
Attachment 1
17.21.XXX – Commercial caretaker unit in commercial and industrial zones (CCU).
A. Purpose. The purpose of a commercial caretaker unit is to:
1. Promote the development of limited housing options in commercial and industrial areas that are
otherwise prohibitive of residential development.
2. Provide housing for an owner/proprietor, employee, or other on-site security or operations personnel
of a commercial/industrial property where no residential dwelling units exist.
B. Standards. A CCU must comply with the following development standards:
1. Configuration. An CCU may be located either within, attached to, or detached from a primary
structure housing a commercial or industrial use. To ensure CCUs do not constitute an encroachment
into commercial areas or otherwise compete with commercial or industrial developments for limited
commercial or industrially zoned land, CCUs shall only be located above the first floor or to the rear of
commercial or industrial buildings.
2. Density. Only one CCU may be created in conjunction with each commercial or industrial enterprise. A
CCU which conforms to the standards in this chapter shall not be required to meet minimum residential
density standards for the lot upon which it is located and shall be considered an accessory use which is
consistent with the comprehensive plan and zoning designation for the lot.
3. Maximum unit size. The CCU must not exceed 1,250 square feet unless approved through an
administrative conditional use permit process.
4. Setbacks, height, and site coverage. CCUs must comply with all dimensional standards including the
site coverage, height, and setback requirements of the zone.
5. Parking. The off-street parking requirements set forth in Chapter 14.40 must be provided and
maintained for the primary use of the parcel. No additional parking is required for an CCU.
6. Addressing. A separate address must be created for the CCU.
7. Occupancy. CCUs shall be reserved for individuals employed on site at the commercial/industrial use
the CCU is subordinate to.
8. Applicability. CCUs shall be permitted on all lots within commercial and industrial zones where an
approved commercial or industrial use is operating. In all other circumstances, CCUs may be
administratively approved as a conditional use permit.
December 28, 2022 Planning Commission Agenda Packet Page 15 of 23
December 28, 2022 Planning Commission Agenda Packet Page 16 of 23
Attachment 2
sEP - B pe7
0 r
Converting
Storefronts
to Housing
An lllustrated Cuide
This project was supported in part by a grant from the
National Endowment for the Arts, a federal agency.
Cooer imnges: Douglas Farr €¡ Associates (lørge photo); Milce
løckson (let't inset); Møry Fishmøn (right inset).
This report is printed on recycled pøper.
The Planning Advisory Service is a subscription service offered by the Research Department of the American Planning
Association. Eight reports are produced each year. Subscribers also receive the PAS Memo each month and have use of the
Inquiry Answering Service. Frank S. So, Executive Director; Sylvia Lewis, Publications Director; William Klein, Director of
Research.
Planning Advisory Service Reports are produced in the Research Department of APA. fames Hecimovich, Editor; Marya
Morris, Assistant Editor; Lisa Barton, Design Associate.
@Jr;Jy 1997by the American Planning Association and the City of Chicago. APA's publications office is at1.22 S. Michigan
Ave., Suite 1600, Chicago ,IL 60603. E-mail: pasreports@planning.org. APA headquarters office is a|7776 Massachusetts Ave.,
N.W., Washington, DC 20036.
December 28, 2022 Planning Commission Agenda Packet Page 17 of 23
Recommended
A storefront building's most defining feature is the large amount
of glass at the ground floor, punctuated by vertical cof umns and
horizontal transom and sill lines.
The light and open appearance of the glass, combined with
the slenderness of the storefront's structural members, is meant
to contrast with the heavy masonry or solid wood walls of the
floors above.
Not Recommended
When you replace the storefront glass with a solid wall
of masonry or aluminum siding, you lose not only the gravity-
defying effect, but the vertical and horizontal divisions that help
the proportions of the top relate to those of the bottom.
c
E
à
%5
:1-,î-"- !,f,
æ,r,
How should the bottom r€late
to the top of tüe bui|d,ing?
Passive solar heating
South or southwest facing stofe-
fronts can take advantage of their
large expanses of glass for passive
solar heating in the winter. In a
passive system/ heat gain from the
windows is stored during the day
and released to the interior rooms
ât night. The heat is stored either
in an enclosed space behind the
storefront glass, or in thick, ma-
sonry "trombe" walls or other heat
collectors behind the glass. These
well-documented systems can be
installed with minimal effect on the
exterior âppearance of the store-
front. Some of them, such as wateÍ-
fflled tanks, can be custom-designed
to be decorative as well
as energy-saving.
Shielding
from sunlight
Traditional methods
In hot weather the problem in
converted storefronts becomes heat
gain rather than heat loss. Blinds,
shades, and awnings provide tradi-
tional solutions that can be adjusted
to the time of day and the season.
Deciduous trees/ strategically
placed, wil1b1ock out the sun
in the summer and allow it to fflter
through in the winter, when it
is desired.
Glass coatings and tints
On existing storefront windows,
a coated polyester "glazrngfrln:'"
can be applied to the interior glass
surface to provide solar insulation.
Working in much the same way
as sunglasses, these low cost
fflms come in a variety of colors,
and generally have a 10- to Zo-year
life span.
If you are replacing the storefront
windows, one option would be
to install tinted glass to reduce heat
gain. Tinted (or heat-absorbing) glass
absorbs a portion of the sun's energy
and then dissipates the heat to both
the interior and the exterior. The
exterior face also reflects a certain
CONVERTING STOREFRONTS TO HOUSING
amount of the eneïgy be{ore it isabsorbed by the slr;;. Àto;;;,,h
a reduction in heat, h"*;;?, ;h;',To.y.rr of light allowed in _" ú"significantly reduced ,, *"ii.'*, "'
Because the tints are integral tothe glass, they are peïmanent.
Factory_coated window fi lms,known as ,,low 8,,, are ¡"ao_i""more cornmon than tinted glrr, "
for reducing heat gain, especjallvin residenti"l rr".þpi";ll;ä'l
ored (pinl<, yelJow, or'blue), tt,ïrnf,sometimes clear, the fflm is "p_
."
plied between layers of insulaiins
gta.ss. As the insútate¿ *i"ä"#ïãrtfaiJs (,it,s usuaJly gone in about I5yearsl these coatings wilJ wear out.
Th^e. most signifi cant drawbacl<ot frlms and tints is that, as thedegree of solar protection in_creases, the amount of daylight letin decreases. Also, ,h" d;;;?;;r;"shading, the more mirror_úke thãglass becomes from ,¡" ""irìãà.'iryou choose to tint your windows.
w-e recommend moderate degreeso{ shadrng, in combina;i;;irh "
blinds, drapes,
"rrA r*riffi.",*"
lVleeting
"light and Vent"
Codes
Keeping as much of the frontglass area as possible m ,iárïrrorrtconversions is desirable not orrlvrn terms of aesthetics, it is alsooften necessary to meet coderequirements for natural iight inresidences. To better rrr¿"rãt"rrJcurrent light and ventilationregulations, a JittJe Irirtárywill help.
The light and ventilation codes weaord_e by today were ffrst enacted Ãthe late nineteenth centuryrn response to miserable híingconditions in tenement housif;S.
^,::1" codes required natural lilhtand lresh air in residences butnot in businesses because many
CHAPTER 2: KEY ISsUES
Cânvas æuafuç:
AtSwe*hou,p¡rú sohrfu
December 28, 2022 Planning Commission Agenda Packet Page 18 of 23
tsgı
()
Design the living space
without partitions.
The "open plan" scheme differentiates
spaces by low walls or furniture,
changes in flooring material or floor
height, drops in the ceillng, etc.,
rather than by floor-to-ceiling parti-
tions. Natural light and ventilation
circulate freely within the
undivided space.
Many storefronts have no side yards
and, thus, are limited to the front and
back facades for window and door
openings. So, meeting the additional
level of natural lighting and ventila-
tion required when storefronts are
converted to residential use may
present a problem. We recommend
five basic approaches to this problem.
Locate habitable rooms on
outside walls with windows.
Habitable rooms include bedrooms,
living and dining rooms, and kitchens
larger than 125 square feet. This is
the traditional, ideal solution for
residences, but often is not possible
with long or land-locked storefronts.
Allow interior rooms
to borrow from fooms
with direct sunlight and
natural ventilation.
Some cities permit "shared" light and
ventilation in buildings converted to
residential use.
Carve out new courtyards.
Adviseable for multilot, one-story
buildings only, where larger
floorplates permit the loss of some
interior space. To keep costs down,
the courÇard locations should be
coordinated with the existing
structural grid.
Use operable skylights
for "interio/'rooms.
This solution works best for one-story
buildings, where adding new skylights
is relatively easy. Skylights are a good
idea for storefronts in multistory
buildings only if they can be located
in existing lightwells. Otherwise,
cutting out new lightwells through
many floors is expensive and takes
space away from the upper floors.
,iJ
borrow light and vent from a room
*i,h , direct source) is an optlon -
;;i;"s as Your local building
áLo"r,',11"tt, recognizes thi s con cept'
ïir-i..¿ numbèr of cities' have
rìåii.it"t ror shared light and vent
in their building code'
Problem buildings
Onlv in verY long, multistory
Ïä'åm'it''il diägs (about 1,og i""'
or longer) with no light avatLaoLe
from sidewalls or skYlights/.ano
int"tiot spâces that are too tar lrom
ät;;;;;";;' of light' does Provid-
inn "tto"sh
naturaI light become
äiig..,li.î"me building codes.
i"ïãü "t,incial
light to substitute
ior rr"tot"l light in living spaces âs
îJïãt i" kiichens and baths''
irti"rt *å"id be necess ary in longer
storefront conversions' Most
ä;;;;;;' are less than 1oo {eet
long, ho*"ver/ so the lighting
,".[it"-"ttts are easier to meet'
people-homemakers' children' the
ãi¿Ërtv-tPent most or all of their
ã"ï"í it"*e, whereas emPloYees
orárorn"t tY sPent onlY.a limited
ããão", of time at work'
Despite the universal availability
ãi"i*iti" lighting and the wide-
;;t*d;t" oI air-conditioning in
today's homes, manY residential
codes have not been updated' tn
ðïi"u*o, for examPle' co-des for
""*À".i.lul buildings allow. me-
ãf'tr"i."f sources of ventilation as
;h;;l;*PPIY, but' for residences'
ïit*il".";ói tn' tit "n"n
and
bathroom are recluired to have
;;;;;lri" windows' (rhough most
;;;;l;;""1d Prefer to have win-
äowt itt everY room' there ",t:,to*"
cases where excePtions could De
rtä",';;;h as foi dinins rogms"an$
ä"î.1,'*hi"h are used sporadically' )
So. storefronts that meet the
ffiü;;"de as commercial spaces
är""" å?¿ additional natural I igh t-
i"g'^"¿ ventilation when con-
ï"it"¿. This Presents a Problem'
but in most cases' the solutions
ur" oo, di{frcult (see "Light ano
î"-rrã^tio" Pointers" at right)'
Natural light
Natural ventilation
Sirr"" -o"h of the storefront glass
ä;ä;itionallY fi'xed' Providing
irr"ãã"". of natural ventilation
;il;á lrv code is more trickY'
ıi nittoti" storefronts that âre
i"i;;;;;;""ltY the onlY window
that oPens will be the transom
Ïüäìã',n. storefront door' This is
;;;b;Ñ not enough ventilatins
ãt.",o meet "ode
requirements'
lo*"""t' For instance' the current
ä;;"r* code for residential uses
.tvt ifi", half of the window area
;å;o"d for natural light must be
operable.
lnstalling oPerable wíndows
It i, r"r. fo-r the orisinal transoms
;";-.h" disPlaY "å to be oPerable'
But it's easy to rePlace a fixed
;;;.*m with one that oPens' The
windows can be different tYPe:-
u*ning, hoPPer, even sliding glass-
;;triï fiiin with the architec-
i"åi "tt"tu"ter
of the building
iJ." ilf"tttution page 34)' These
.
window tYP"' *o'it because their
;;;p";;ú; are horizontal' as is
the transom area'
For average-length storefronts
i"rr"* åó:so feãt long), Providing
lrrotgh tight is not an issue' due
;;,h; larle amounts o{ glass 11 1\"
iroot f"."d", and the light avattaote
from the rear windows or srdewair
.ro"t'tl"*t' Openings at the rear can
rrã i""tË"t.d in size (or openings'
;;;î; added to exPosed sidewalls)'
iä"åJ;;, wrthout damaging the
character of the building'
Shared light (and vent)
ão-"ti-"tfit's not Possible for
;;;;;;;'* to have a window on
;;ir*á; *all' if the storefront-is
ät" ";" ;,orY, it's eâsy. to install.
;;lrbi; skYtights for these interior
,åo*r' It's even Possible to carve
out interior courtyards' In multi- -
Iä.ïï"ii¿ings, "shared" light and
'rr.níit",ioo (where an interior room
ù1, *ittdo*s or oPenings that
I CONVERTING STOREFRONTS TO HOUSING
CHAPTER 2: KEY ISSUES
tight and Venti'lation Pointers
December 28, 2022 Planning Commission Agenda Packet Page 19 of 23
ICase 1997 Consttucti on Cost Estimate :CAISESTlrDy
First-floor interiots
Demolition and hauling
Carpentry
t and back f a cades, and site imqrovements
$ 7,725
14,956
$ 1,854
845
9,270
2,987
27,654
1,7 42
7,4r5
onLy, fron
Framing and trim
Drywall
CabinetrY and toPs
Doors and hardware
A midblock, multilot, two-story building
(40'wide by G0' long)
Windows and doors
Storefront {new wooden-windows and
frames, ä'ì;;;;"t* bulkhead) $ I
Second-floor' front windows
'(new Chicago stYIe windowsl
Rear (remove brick at former window
op""itgÏ,Ttïi"ti í""t windows and doors)
Painting
AFTER CONVERSION
t i'åï:iî'*iî'"*d",i::,
flexibility in dividing up the ffrst
floor space), this building has a
solid bearing wall cutting the
storefront space decisively in half.
Built in 1910, the structuïe wâs
designed for two storefronts,
separated by a slightly off-center
stairway leading to the two
apartments upstairs.
Mike fackson, the architect who
converted the storefront for his
family in 1987, found that fhe
storefront Íacade was largely
intact. The wooden bulkheads,
doors, and winclow frames were in
good repair. One storefront had an
Terra Cotta
Remove gunnite, remove sign'clean. Does not include terra cottâ repalr
6,O25
2,472
$ 2,884
8,24O
2,884
4,120
g 9,270
1,700
s 9,476
1,442
$ 10,631
5,600
18,128
10,970
12,560
r0,918
l06,5l I
$ 116,942
$ lo,25o
$ 8,086
Design Strategy
Architect Mike Jackson's
idea was to adapt this
storefront into living space
for his own family with a
minimal amount of
change, preserving the
building's notable archi-
tectural features both
inside and out. He elected
to take over the entire
ground floor while
retaining two separate
residential units upstairs.
The bearing wall divìder
between the former
storefronts works to the
family's advantage,
creating two zones: one
mainly for the parents
(living room side), and
one for their teenage son
(family room side).
Finishes
Carpeting
Ceramic tile
Painting
Appliances
Plumbing
Rough
Fixtures
HVAC
Gas forced-air furnace with
Electrical
Rough
Fixtures
Subtotal
10% contingencY
Total
$39 per squâle foot (3,000 square feet total)
Storefront Alternate I
Metal stock frame, obscure and clear glass
Storefront Alternate 2
Translucent panels, stucco and clear glass
unit for air conditioning
co
=
condensing
$ 9,650
CONVERTING STOREFRONTS TO HOUSING
original, recessed center entryl
and the other, an original off-
center entry with an enclosed
display case.
A sidewaik overhang was â ïem-
nant from an earlier second-story
porch. This upper floor was
ffnished in rock face concrete
block, a popular building material
of the early twentieth century.
Inside, a noteworthy feature was
the decorative tin ceiling, which
fortunately was in good repair.
Though midblock, this storefront
building is actually freestanding.
It sits on a mixed-usê, rnoderately
busy street in Springfield, Iliinois.
6 CHAPTER 3: CASE STUDIES
TEEI
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tE-l
r:=r--1
tt I
December 28, 2022 Planning Commission Agenda Packet Page 20 of 23
I I
1
Il
I
I
Floor plan
The storefront unit is enteredfrom the.living room slde oniy.Double doors carved into the'dividing wall aliow passage intothe teen zone. The originãl, centeïshopfront door on this side isretained, however, even though itls not normally used.
The decorative sheet metal ceilinghighlights the open pfr",p*".'îli"
most noteworthy ìnterior feature isa Large bullt_in refrigerator with anoâK ïront-converted by the archi_tect into a walk_in closet.
lg"t facade and site plan
Lil<e Case Study Z, becausË thisstoretront was located in a mixed_
use residential setting, the store-front owners never f;"J;;;;;,
sary-to brick-in the rear Íacadewindows (as is likely to happenrn commercial districts thaiare
deserted at night). rh" orig,nlì"r"r,wlndows and doors remained, and.like those of the ,tor"rrãnf i;";;:'
are well-suited to residential use.'At the rear of the lot is a smallyard, andJ:eyond that, païking
space for four cars.
FACADE
Éo
o
=
Front facade
Due to the high clualitY of the
original storefronts, and the pres-
ence of operating trânsoms/ a
simple scraping, rePainting, and
caulking job was all that was
necessaïy to make the facade
work-a tremendous cost savings
for the conversion Project.
Ventilation from the over-door
transoms is supPlemented bY
natural air {rom side and rear
windows. At the liriing room, the
enclosed display window below the
trânsom helps create an insulating
space against noise and extreme
temperatures outside. Blinds add a
ievel of privacy, and, along with the
sidewalk overhang, helP shield the
window from too much sun'
t---
I
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Irul
Bedroom
Êl¡
rtt I
Il-l
t¡¡ I*¡¡Elr-l.^l
b
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I
Family Room Porch
a
Dining
Bedroom
o
o
E
Living Room
Kitchen
Co
!l
=
View toward living room from dining room FIRST.FTOOR PIAN
oo
LIL
CONVERTING STOREFRONTS TO HOUSING CHAPTER 3: CASE STUDIES
Ã
December 28, 2022 Planning Commission Agenda Packet Page 21 of 23
--
lS-Minute
Design Solutions
2'\Þþ* I
FÊoÑT
SECTION AND PLAN
Four townhouse units, carved-out atrium,
rear bay retained for garages with hruo additional
units above
6,L ¡l*¿"
At/
REAR
eusr)-l f ..Ü lw ÔZ
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stoEwAt-K
ILOOK P¿-AÑ
)T
All building codes require ventila_tion for almost any use to whicha structure can be put. Some codeshave,lighting r"quir"_"r.,,r, roã.
-"
For all uses excepr residential.ventilation and Iighting r,rnãrr¿,
;an b¡ rnet by me.hr',[al ;;;;;
¡r..e., fans, air conditioners, andelectric lighting). Only for ."riA"n_rrat uses do codes require specificâmounts oÍ natural light andventilation.,,Naturall light means
:l']ich:.:hrough clear sfãrt "r; ;;;'.'..naturaL,, ventilation _"rn, fi,"flow of outside air unassisted bymechanical devices. Natural lightand ventilation may enter a resi_dence through wìnáows, doo^r'
{rn .so-rne bui lding codes),
and skylights. Tñe folloiing
sections describe how the cãde, of{ive cities treat rhe issues "lú;h;^and ventilation.
Chicago Building GodeIn the Chicago Building Code,rhere are two criteria for deteimin_ing the natural lighting rrr¿ rr"rtiù_tron requirements for residences.They are: l ) the use to which eachïoom or space is to_be put, and,2)the size (nurnber of sqùare feet)
.?l^"r:f room or rpr... Regarding
lrl,. C.h].r8o requires thaiall
nâDrtable rooms receive naturallight and ventilation.,,Habitable
rooms', are defined as rooms ,,used
or intended to be used for living.sleeping, eating, or cooking.,iiîi,
ts lnterpreted to mean liviÀg
roo.ms/ dining ïooms, bedroãms,
and kitchens over 125 square feåt.Bathrooms, laundry ïooms, foyers.corndors, closets, and storage
spâces do not require naturallight and vent.
Once the use of each room
has been determined, the sizeof,each habitabie room must becalculated. The Chicag, B;lì;;gCode requires the size"of ,fr",à"?".of natural light and u"rrtitrtlon"-"'
lusuatJy a window) to be a mini_mum percentâge of the floor
area of each habitable room orspace. The standard percentages
are 10 percent (natural hshtlãnd Spercent lnatural ventilati"on l.
Ior-example, a bedroorn l0 feetDy t5 feet has an area oÍ I 50 squarefeet.-The natural Jight requir;å;;;would be t0 percenl of tso, ";Jl^"square feet. This arnount would besarisfied b,y a rypical*i"¿o* tl_,rããreer wrde by tive feet high. Thenatural ventilatjon requirement
would be 5 percent of j S0, oli.-Ssquare feet, which would t" ,"_counted for when the bottom halfof a three-foot by five_foot ¿or-rUå_nung window was opened.
Due to a )arge number of industrialloft conversions, the Chicago codenas specral provisions for residen_tial open floor plans withoutpartitions and spaces deeper thanl.ó,teet. For these typ". oi residen_tral spaces, the percentages ofrequired natural light and ventila_rron tncrease to l2 percent and 6percent. This means that, in theabsence of intervening partitions. aspace may receive all of jts nrturrllight and ventilation frrrn """"i,îfì,regardless of the distance away
tight and ventilation building codesand storefront conversions
1.04
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APPENDIX
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CONVERTING STOREFRONTS TO HOUSING APPENDIX BDecember 28, 2022 Planning Commission Agenda Packet Page 22 of 23
from that wall. The exact distinc-
tion between an open floor plan- and
one where rooms are considered
sepârate is unclear, however'
nurtding DePartment ofiicials
ã"ttà",iv must decide on â case-by-
ãàr" u"tit whether Plans with
nartial height pârtitions or rooms-
i"itt in-"-tóom (such as an eight-
i"ã,-ftigft bathroom volume within
" ii i"ã. nigh sPace) can be consid-
ered as loft spaces for the purposes
Àt tgtt, and ventiiation calculations'
The Chicago Code also has a
nrovision for residential conver-
ãio,., *h"tt all of the habitable
tão*t cânnot be arranged to have
ã direct source of natural light or
vent. This Provision allows for
;;;;t receìving direct light and .
r""i," "share'iwith those that do
not, in buildings built before 1957'
ihá p"t""t tages of required open-
ittgt ìo floor area increase substan-^,ì-uiy to-pared to what is recluired
iot tâo-t ihat receive direct light
and vent. Pages 79-82 of this
^ooendix
illustrate the calculation
oi'shared light and ventilation per
the Chicago Code'
Milwaukee Building Code
Other codes deal differentlY with
,to "on""p,
of light 4nd ventilation
io. r"tid"tttial conversions' Mil-
*"11L"", which uses the Wisconsin
State Building Code, also requir-es
""i"t¿ light ãnd vent for all habit-
"üi" toorn"t, but restricts the deiini-
tion of these rooms to "bedrooms
and one room designed for lìving
purPoses." The Percentage of floor
area required for openings is only 8
olt.."ifot light and 4 Percent for
ient. Doors maY be counted as
op"r.ingt, while in Chicago, theY
.ro no1. Chicago, on the other
n"í¿, allows shared light and ve.nt
i" "ii t"tia.ntial uses, while Mil-
waukee onlY allows it in transient
o"".tprt"l"s such as hotels and
motels.
MinneaPolis Building C,ode
MinneaPólis uses the 1994 UBC
{Ut¡fottrr Building Code), which is
"t"à frv manY other municiPalities
as well. It is imPortant to note/
howevet, that even though cities
mav adoPt national building stan-
ãrrât t.råh as the UBC or BOCA
[Building Officials Code Adminis-
trâtorsl codes, the interpretatlon
of the same code book maY varY
widelY from Place to Place'
iUinnåaPolis has a Provision {or
,h"r"d light and ventilation' recluir-
ing a minimum oPening of 50
n"i."rr, in the common wall
lr.,*..n the lending and borrowing
fooms.
Gincinnati Building Code
Cincinnati, which uses the BOCA
;;e;; """-Pts all kitchens (regard-
less of sizef and bathrooms from
,rlu ,lntrr^l tight and ventilation
rec1.tir"m"nts. Alt other rooms
must have their own direct sources
of light and vent.
Gleveland Building Code
Cleveland also uses BOCA' but it
i*rpr",, residential light and vent
tãq"it"to""ts diif erently' Natur¿l
iigiìir"¿ ventilation is recluired in
sl-eeping rooms only' Other spâces
may substitute mechanical sources
{or natural ones'
Features in light
and ventilation
codes that would
facilitate storefront
conversions
1 Provide explanations and inter_
pretations of "difficult,, sections
of the code
2. Define habitable rooms (i.e.,
those requiring natural light and
ventilarion) to include only bed-
rooms and living rooms/ 04
3. Allow the use of mechanical
ventilation and artificial light
in some habitable rooms, such
as kitchens and dining ïooms
4. Allow the use of glazed doors
and operable windows on interior
openings required between Íooms
sharing light and ventilation, rather
than requiring the openings to be
permanently open
5. Include the glazed areas of doors
in the calculation of natural light
provided and include door opening
areas in the calculation of natural
ventilation
6. For the purposes of loft or open
plan conversions, add a statement
in the code that specifically defines
ân open floor plan; that is, what is
the maximum percentage of wall
area or the maximum partition
height allowed between two spâces
before they must be considereã as
two separâte rooms?
Shared tight and
Ventilation lllustrated
Using Chicago
Building Code
Standards as an
Example
Rules
]. Th" arca oÍ spâces borrowing
light and ventilation must be
30 percent or less of the area of the
entire unit.
2. The area of outside wall
openings providing natural light
and ventilation must be l5 pércent
and 7 .5 percent/ respectively, of the
sum of the areas of rooms or spâces
borròwing plus rooms or spaces
lending light and ventilation.
3. The area of openings between
the borrowing and lending ïooms
must be 30 percenr (for light) and
15 percent (for ventilation) of the
iloor area of the borrowing rooln.
The worksheet on the following
p-age takes you step-by-step through
the calculation of shared light and
ventilation requirements, based on
the Chicago Building Code (1994
version). The example illustrates
Unit B alternate from Case Study 3.
Note that the worksheet verifies
oniy that the rooms sharing light
and vent meet code requirements;
the requirements for other rooms
receiving direct light and vent
should be calculated in the
usual way.
CONVERTING STOREFRONTS TO HOUSING APPENDIX BDecember 28, 2022 Planning Commission Agenda Packet Page 23 of 23