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• Gene Bolante ` From: William E. Endelman <bill@endelman.com> Lam+' Sent: Thursday,June 23,201110:41 AM To: Gene Bolante;scoff@marathoncs.com Cc: bart@endelman.com Subject: Oregon Unit Kitchen Counter Heights Importance: High Hi Gene and Scott, I just got off the phone with Steve Judson at the State, having discussed the issue that in effect, the County is requiring all kitchen counters to be 34" high by adhering to the 24" maximum depth. This is not a requirement in the kitchen section under OSSC 1110.5. Per OSSC 1109.2.3.6, side reach range it states that 24" maximum depth of the obstruction is also required to be 34" high. In addition, this will require all kitchens in covered dwelling units to have custom cabinets and some of the standard appliances will not fit in these non-typical depths. Mr. Judson suggested that you seek an "Alternate method' exception with the jurisdiction based upon the premise that the State is in the process of updating the Code to be effective March 2012, and that Code will be in alignment with: 2009 IBC and referenced ANSI Al 17.1 — 2003 and the new 2010 ADA Standards. It will have Type A fully accessible units and Code Type B (FHA compliant) units, the latter being what the current OSSC code is really intended to meet. (ANSI Section 1004.12 at Type B units has NO requirement krfor 34" height, nor maximum 24" counter depth. Section 1004.9 on operable parts requires accessible outlets and controls meet reach ranges. Type A units will require a 34" kitchen countertop only at the sink and a 30" lowered section of countertop.) As a point of context, the current OSSC units are intended to be Fair Housing Act compliant units, not true accessible units, which Oregon has never had. Yet, the 34" countertop height implied is more stringent than IBC /ANSI Type B units - Type A Units—or Accessible Units, 2010 ADA Standards for accessible units, UFAS units for Section 504 project accessible units, CA units (more stringent units), the more stringent Chicago Building Code units, or any other code I am aware of—all this in a unit that is not close to being an accessible unit which would have door maneuvering space, knee space under sinks and lavatory, 60" diameter turning space in all rooms, etc. It is plainly inconsistent with ANY accessibility standard. Finally, I will bet that 98% of all required covered units built in the last 20 years in Oregon will not have been built to meet a 34" countertop height. Mr. Judson indicated he would put into an email he owes Gene Bolante the recommendation to seek "alternate means" exception with Merion County. Feel free to contact me if you have any further questions. Regards, Bill William E.Endelman,AIA,Principal Endelman &Associates PLLC Accessibility Consulting/ADA-FHA Compliance 1