HomeMy WebLinkAboutCorrespondence MICHAEL I ANDREOLI
ATTORNEY AT LAW
1393 West Oak Street
Zionsville, Indiana 46077-1839
(317) 873-6266
Fax (317) 873-6384
mandreoli(c�datlaw.com
November 15, 2019
Carmel Board of Zoning Appeals
One Civic Square
Carmel, IN 46032
Attn: Angie Conn
Planning Administrator
Attn: Joe Shestak
Administrative Assistant
Re: Willow Haven Senior Home
Docket No. 19090019 UV, 19090020 V
19090021 V, 19090022 V
Dear Board Members:
Please be advised that I have been retained and am representing the Glen Oaks
Property Owners Association, individual residents and others in remonstrance to the
above docket items.
As such, I am delivering my Response in Opposition to Willow Haven Senior Home with
exhibits, including Petitions in Opposition from area residents.
As best we can, we are going to try to filter all letters or other submissions, including
additional petitions, through my office so that I can forward them over nd make your
respective jobs a little easier in terms of paper management. Th ou for your
cooperation.
Very t y yo ,
/ Mi el J. Andreoli
MJA/ba
Enclosure
RVEYORS'OFF
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7Centon C. Ward, L, FF./Y[
Surveyor of NamilIIton County
'hone (317) 776-8495
Fax (317) 776-y628
Cash Wagner and Associates
402 East 13"' Street, Suite 101
Jasper, IN 47546
RE: Willow Haven Senior Homes
Suite r88
One ,Hamilton County Square
JYoblesidle, Indiana 46o6o-2230
We have reviewed
the primary plat and development plan
submitted to
the Hamilton County
Surveyor's Office
on November 14, 2019, for this project
and have the
following comments:
1. The proposed project falls in the incorporated area and MS4 jurisdiction of the City of
Carmel.
2. The proposed project DOES NOT fall in a Carmel Wellhead Protection Zone.
3. The proposed project falls in a Boone County Watershed.
4. The proposed project must comply with applicable parts of the Hamilton County Stormwater
Management Technical Standards Manual.
5. Please submit an outlet permit request with payment if you plan on outletting to a
surrounding subdivision drain.
6. Please provide drainage calculations when they become available. If you plan to outlet to a
surrounding subdivision, these drainage calculations will be needed as well.
Should you have any questions, I can be reached at Samuel.Clark@hamiltoncounty.in.gov
Sincerely,
Sam Clark
Plan Reviewer
Ellison, Christopher M
From: Ellison, Christopher M
Sent: Thursday, November 07, 2019 7:49 AM
To: Ellison, Christopher M
Subject: FW: CFD information for 11/06/19 Meeting
Indiana Building Commissioner Craig Burgess comments to Michael Riley's letter for Willow Homes Senior Homes
Memory Care.
From: Burgess, Craig [mai Ito: CBurgess@dhs.IN.gov]
Sent: Thursday, October 31, 2019 10:42 AM
To: Ellison, Christopher M
Cc: Blunk, Alan; Ray, Lucas M; Rohr, Christopher M; Burgess, Craig
Subject: RE: CFD information for 11/06/19 Meeting
**** This is an EXTERNAL email. Please exercise caution and Do Not open attachments or click links
from unknown senders or unexpected email. ****
Chris:
Here are my thoughts on the points raised in the designer's letter. We can discuss this in more detail when we meet
next week. The Plan Review personnel I invited may have other ideas, and we can hash them all out.
1. Contrary to the designer's contention, an 1-2 classification is not inconsistent with the IBC (more on that below,
in my discussion of the type of care provided). Whether it is inconsistent with NFPA 101 is immaterial, since 101
is not an adopted code in Indiana, save for one instance of adoption by reference on the sole issue of smoke -
protected assembly seating areas. Nothing else in 101 is in effect as a building code in our state.
2. The manner in which the Indiana State Department of Health classifies or regulates facilities such as this is also
immaterial to our agency. The term "residential tare facility" doesn't even appear in the IBC, and we do not
utilize or enforce any regulations outside of those adopted by the Indiana Fire Protection and Building Safety
Commission.
3. By placing their facility under NPFA 101's "Limited Care Facility" category, the designer admits that the
residents of the facility are incapable of self-preservation. The IBC has no R occupancy groups that include such
incapacitated occupants. Their suggestion that the facility be considered an R-4 directly contradicts the text of
IBC 310.6, which states R-4 is for persons capable of self-preservation.
4. It's true that the text of 308.4 references medical care in 1-2 occupancies, and the designers say medical care is
not being provided here, but that text does not limit 1-2 uses to medical care; it simply says 1-2 includes such
medical care facilities.
In short, here are what I think are the important factors:
• The text of 308.4 states that 1-2 merely includes facilities that provide medical care for incapacitated occupants.
It does not say it is limited to such medical care facilities.
• The text of 310.6 states that R-4 is only for occupants who are capable of self-preservation.
Neither NFPA 101, nor any ruling, classification or license from the ISDH, has any bearing on the situation, since
they are not our adopted rules.
Since there are no IBC occupancy groups that combine non -medical or custodial care with persons incapable of self-
preservation (except for detention facilities), we're faced with a choice between what is clearly prohibited in the code
(R-4) or one (1-2) that includes, but is not limited to, a degree of care beyond that which the facility is providing. While I
admit the argument that the type of care provided in an 1-2 is not limited to the medical variety can seem a bit tenuous,
in protecting the safety of the occupants, we have no choice but to default to 1-2 as the safer option, since the letter of
the code specifically prohibits classification as R-4.
It appears to me, at this point, that the designer has three choices: 1) design and construct the facility in accordance
with the requirements for an 1-2 occupancy (which other memory care facilities in Indiana have done), 2) provide
convincing documentation that the occupants are actually capable of self-preservation thereby qualifying for R-4 status,
or 3) seek a variance from the Commission.
Craig E. Burgess AIA CPE CBI LEEDAP
Indiana State Building Commissioner
Indiana Department of Homeland Security
Office of the State Fire Marshal
302 W Washington St., Room E241
Indianapolis, IN 46204-2739
317.232.2222
Shestak, Joe
From:Conn, Angelina V
Sent:Thursday, October 31, 2019 8:54 AM
To:Shestak, Joe
Subject:FW: Water Tap Location for Willow Haven Senior Home 13145 West Road
Attachments:C-103 Utility.pdf
Follow Up Flag:Follow up
Flag Status:Flagged
FYI - correspondence for willow haven use variance.
From: Adrien Dannemiller \[adrien@millstonemgmt.com\]
Sent: Wednesday, October 30, 2019 6:22 PM
To: Cook, Steve L
Cc: Doug Mitchell; James Miles; Nathan Waggner; Conn, Angelina V
Subject: Water Tap Location for Willow Haven Senior Home 13145 West Road
**** This is an EXTERNAL email. Please exercise caution and Do Not open attachments or click links
from unknown senders or unexpected email. ****
Hi Steve,
We are wondering if you can take a look at the attached utility plan for the proposed Willow Haven Senior
Home at 13145 West Road to let us know if you are OK with our proposed tap location. The fire department
told us they want our hydrant and FDC on the North side of the property, so that is why we would like to
connect to the Carmel Water main on the North side of our property as well. This will save us many feet of
underground water piping.
To be clear, we are not talking about connecting to the private line on the North side of our property. We are
talking about crossing the road to make our connection on the West side of West road like we discussed earlier
today, just a bit to the North of where your TAC comment suggested.
We have to submit these revised plans tomorrow, so if possible, your prompt response on this would be
appreciated!
Thanks again!
Adrien Dannemiller
Millstone Management LLC
Construction and Development Services
317-525-9464
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NOTE: a
ALL DIMENSIONS TO FACE OF CURB (FC), EDGE/PAV'T I I
AND/OR FACE OF BUILDING UNLESS OTHERWISE NOTED.
BUILDING DIMENSIONS SHALL BE VERIFIED WITH
ARCHITECTURAL PLANS. '
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UTILITY NOTES
The Contractor is cautioned that the location and/or elevation of existing utilities as shown on
these plans is based on records of the respective utility companies, and measurements taken
in the field. This information is not to be relied upon as being exact or complete. The
Contractor shall notify all utility companies & the State's underground locate service at least 2
(business) days before commencing excavation to request the utilities be located in the field.
If any existing structures/utilities to remain are damaged during construction, it shall be the
Contractors responsibility to repair and/or replace the damaged structure/utility as necessary
to return it to existing conditions or better.
The Contractor shall be responsible for notifying all property owners that will experience an
interruption to their utilities caused by this project.
Construction shall comply & be in conformance with all applicable governing codes and be
constructed to same. Material specifications shall be in conformance with the State
Department of Transportation's (DOT) standard specifications, latest edition.
Contractor shall provide & maintain traffic control in accordance with the Manual on Uniform
Traffic Control Devices, latest edition.
All materials, installation, construction & testing of the water and sewer utilities shall be in
conformance with Local Water & Sewer Depts. Standards and Specifications, latest edition.
Contractor shall coordinate the installation of building sewers / service laterals with the local
water & sewer depts., building inspector, plumber, and plumbing plans. Installation and
materials shall be in conformance with applicable codes, standards, and regulations.
Contractor shall coordinate actual location of proposed utility services with architectural plans.
The Contractor shall install all water and sewer service lines to 5' outside the building for tie-in
by the plumber.
Water lines shall bear NSF seal of approval and meet:
3" thru 8" mains and service lines - C-900 PVC, Class 200 per AWWA C-900.
Smaller than 3" - Type 'L' Copper per ANSI 816.22 or PVC, Class 200 per ASTM D1784 and
D2241.
Sanitary sewer pipe shall be as follows:
8" & larger mains - SDR 35 PVC (min.) in accordance with ASTM D-3033 & 3034 or PVC Truss
Pipe in accordance w/ ASTM D-2680.
6" services (laterals) - Schedule 40 PVC or SDR 26 PVC and as required by local jurisdiction.
Water mains shall be saddle tapped and bedded with sand a minimum of 6" below and 12"
over the pipe.
All fill material shall be in place and compacted before installation of proposed utilities.
All utilities shall be installed, inspected, and approved before backfilling.
All proposed road crossings must be fully backfilled with a granular material.
Contractor shall maintain a minimum of 54" cover on all waterlines and 36" cover on all
sanitary sewer lines.
Detectable line marking tape and No. 12 insulated copper tracing wire shall be installed with all
water lines and sanitary sewer laterals. All tape shall be placed 24" (min.) above lines.
Tracing wire shall be taped to the top of the water line and be pulled into valve boxes and
meter pits (to the surface) for locating purposes. If ductile iron pipe is used, the main must be
poly wrapped and marking tape installed 2-feet above the water main.
All water joints and bends are to be mechanical joints with thrust blocking.
All storm pipe entering structures shall be grouted to assure a watertight connection.
All storm structures shall have a smooth uniform poured mortar invert from invert in to invert
out. The inside of all structures where storm pipes connect shall be grouted smooth.
Storm pipe lengths provided are measured to center of structure and/or end of Flared -End
Section.
Water lines shall be installed with 10-feet of horizontal and 18-inches of vertical separation
from sanitary and storm sewers.
Provide 8 feet (min.) of horizontal separation between the water main and all storm and
sanitary structures.
Where water lines and sewers cross and the water line cannot be placed above or below the
sewer with a minimum of 18 inches vertical clearance, the sewer must be constructed of water
works grade ductile iron pipe with mechanical joints or plastic (S.D.R. 26) sewer pipe with
gasketed, compression - type joints within ten feet of the water line.
Where water lines and sewers run parallel and a minimum seperation distance of ten feet
cannot be maintained, the sewer must be constructed of water works grade ductile iron pipe
with mechanical joints or plastic (S.D.R. 26) sewer pipe with gasketed, compression -type
joints.
Clean -outs shall be installed on sewer services within 5'
of the building, at 100' intervals (max.), and at every
horizontal & vertical change in direction greater than 450
Clean -outs shall be of the same size as the service line
and be extended to grade.
Sanitary sewers shall be installed in accordance with the
Indiana State Board of Health Specifications (330 IAC 3.1).
Permits shall be obtained prior to commencing work.
This drawing and/or specifications is provided as an instrument of service
provided by Cash Waggner & Associates, PC and is intended for use on this
402 EAST 1 3TH STREET
N ❑ .
DATE
B Y
DESCRIPTION
WILLOW HAVEN SENIOR HOMES
DATE:
project only. All drawings, specifications, designs, models, ideas, calculations,
and arrangements appearing herein constitutes the original and unpublished
Work of and remains the property of Cash Waggner & Associates, PC. Any
`A` G A`
SUITE 1 O 1
JASPER, IN 47546
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PROJECT No.: 19-3957
PROJECT'
MEMORY CARE HOMES
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INI
Description
reproduction, use or disclosure of the proprietary information contained herein
without the prior written consent of the Cash Waggner & Associates, PC is
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W A G G N E R P 8 1 2. 6 3 4. 5 0 1 5
❑
DESIGNED BY:
I N RW
ADDRESS:
1 3 1 4 S WEST ROAD
DRAWN BY:
I DJ M
DRAWING N❑.
strictly prohibited.
Written dimensions shown hereon shall take precedence over scaled dimensions.
pCASH
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FAX: 131 2.6 3 4. 5 0 1 7
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C A R M E L, I N D I A N A 4 6 0 7 4
Contractors shall calculate and measure required dimensions. Notify Cash1.3964_
Waggner & Associates, PC with any variations in dimensions or conditions from
those indicated these drawings. This drawing based
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information. Commencement of Work constitutes verification and acceptance of
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C A S H WA G G N E R. C❑ M
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Application of a material or equipment to Work installed by others constitutes
acceptance of that Work and assumption of responsibility for satisfactory
S I CG N AT U R E DATE
CASH WAG
PLAN
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installation.
W W W . G N E R . C O M
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❑ F:
Empact
rchitects
RE: Response to CFD TAC review comments
Willow Haven Senior Homes, Indianapolis, IN
Memory Care Home, 13145 West Rd
Dear Chris Ellison,
No. AR11000188
STATE OF
!*nIAgp
As a licensed architect in the State of Indiana, Michael Riley, dba Impact Architects, providing
consulting to Willow Haven Senior Homes for the project to build a memory care home at 13145
West Rd, I have reviewed CFD's TAC Review comments and provide the following response:
The purpose of this letter is to respond to the CFD TAC Review comments and to request that CFD
interpret its classification of Willow Haven Senior Homes Memory Care Home as R-4. An I-2
classification is inconsistent with the IBC and NFPA.
Willow Haven Senior Homes is building a Memory Care home which will house 12 residents. This
home will be licensed by Indiana State Department of Health (ISDH) as a Residential Care Facility
(RCF) and will provide Alzheimer's and Dementia care to its residents. According Miriam
Buffington, Enforcement and Provider Services Manager, Long Term Care, Indiana State Department
of Health: "Indiana does not have a separate license for memory care." This is confirmed in 410 IAC
16.2-3.1-13 that describes the requirements for a memory care director and staff training
requirements.
Classification of memory care assisted living as I-2 is not consistent with the IBC or NFPA 101.
According to the Indiana State Department of Health the proposed Willow Haven Senior Homes
Memory Care home will be licensed as a Residential Care facility. Even though it will provide
Memory care this home can only provide residential care and is prohibited from providing medical
care. CFD's TAC review comments equating memory care homes as an equivalent occupancy type
to nursing homes incorrectly equates people who need nursing and medical care for their dementia
and those who merely need personal care.
NFPA 101 recognizes that people with dementia, depending on the stage of their disease, may seek
care in a nursing home, limited care facility, or board and care facility. "For such persons, it is the
level of care provided, not the medical diagnosis, that matters for the purposes of determining
whether the.facility should meet the requirements.for limited care." The explanation of limited care
facility is specific in saying that "where personal care is provided but medical or custodial care is not,
the limited care definition does not typically apply."
Willow Haven Senior Homes remain committed to the safety and security of all of our residents in
memory care. The measures we are taking in the home provides excellent protection from fire and
other hazards. These measures include:
• Providing a NFPA 13R sprinkler system throughout.
• Providing a fire alarm system throughout.
Impact Architects 314-422-9615 michaelriley@charter.net
• Provide all code compliant structural element fire ratings.
• Written policies and special training for staff on how to handle emergencies.
• Fire drills for residents.
• Selection of residents with appropriate level of acuity.
• Providing egress doors with access control that is connected to the fire alarm to provide egress
during emergencies or power outages as per NFPA 101.
Willow Haven proposes to build a R-4 occupancy facility where all residents meet the R-4 Condition
2 criteria stated in the IBC
NFPA 101, which recognizes that non -medical facilities should be classified as residential board and
care occupancies, rather than institutional occupancies.
The NFPA 101 (2015) defines Limited Care Facility as:
3.3.90.2* Limited Care Facility. A building or portion of a building used on a 24-hour basis for the
housing of four or more persons who are incapable of self-preservation because of age; physical
limitations due to accident or illness; or limitations such as mental retardation/developmental
disability, mental illness, or chemical dependency.
The Annex explains this use in greater detail:
A.3.3.90.2 Limited Care Facility. Limited care facilities and residential board and care occupancies
both provide care to people with physical and mental limitations. However, the goals and programs
of the two types of occupancies differ greatly. The requirements in this Code for limited care
facilities are based on the assumption „that these are medical facilities, that they provide medical
care and treatment, and that the patients are not trained to respond to the fire alarm; that is, the
patients do not participate in fire drills but, rather, await rescue. (See Section 18.7)
The requirements for residential board and care occupancies are based on the assumption that the
residents are provided with personal care and activities that foster continued independence, that the
residents are encouraged and taught to overcome their limitations, and that most residents, including
all residents in prompt and slow homes, are trained to respond to fire drills to the extent they are able.
Residents are required to participate in fire drills. (See Section 32.7)
Persons with Alzheimer's and related illnesses might be located in a nursing home, limited care
facility, or board and care facility. For such persons, it is the level of care provided, not the medical
dia iosis, that matters for the purposes of determining whether the facility should meet the
requirements for limited care. Where personal care is provided but medical or custodial care is not,
the limited care definition does not ty
Pic!ql1v apply. It is the intent of this definition that it not apply
to persons not receiving medical or custodial care, provided that are able to assist in their own
evacuation, regardless of their medical diagnosis. (emphasis added)
The NFPA defines residential board and care occupancies and personal care as follows:
Impact Architects 314-422-9615 michaelriley@charter.net
3.3.190.12* Residential Board and Care Occupancy. An occupancy used for lodging and boarding
of four or more residents, not related by blood or marriage to the owners or operators, for the purpose
of providing personal care services.
3.3.208* Personal Care. The care of residents who do not require chronic or convalescent medical or
nursing care.
In this case, Willow Haven Senior Homes can only provide personal care. As a Residential Care
Facility, it is prohibited from providing medical or nursing care. The regulation delineates what must,
may, and cannot be offered.
The following is our response to the specific comments submitted by CFD.
1. The Carmel Fire Department supports the proposed building being provided with a fully
compliant NFPA 13 fire sprinkler system.
NFPA 101 32.2.3.5.3.1 In buildings four or fewer stories in height and not exceeding 60 ft in
height above grade plan, systems in accordance with NFPA 13R shall be permitted. All
habitable areas, closets, roofed porches, roofed decks and roofed balconies shall be
sprinklered.
903.2.8.3 Group R-4 Condition 2. An automatic sprinkler system installed in accordance
with Section 903.3.1.2 shall be permitted in Group R-4 Condition 2 occupancies. Attics shall
be protected in accordance with Section 903.2.8.3.1 or 903.2.8.3.2
903.2.8.3.2 Attics not used for living purposes, storage or fuel -fired equipment
Attics not used for living purposes, storage or fuel -fired equipment shall be protected in
accordance with one of the following:
1. Attics protected throughout by a heat detector system arranged to activate the building
fire alarm system in accordance with Section 907.2.10
2. Attics constructed of noncombustible materials.
3. Attics constructed of fire -retardant -treated wood framing complying with Section
2303.2
4. The automatic sprinkler system shall be extended to provide protection throughout the
attic space.
2. Per section 308 of the 2014 Indiana Building Code, a facility that provides care for persons
who are incapable of self-preservation shall be designated as a I-2 occupancy classification
and shall be designed and constructed as such.
308.4 Institutional Group I-2. This occupancy shall include buildings and structures used for
medical care on a 24-hour basis for more than five persons who are incapable of self-
preservation...." (emphasis added)
Per NFPA 101, as stated above, Persons with Alzheimer's and related illnesses might be
located in a nursing home, limited care facility, or board and care facility. For such persons, it
is the level of care provided, not the medical diagnosis, that matters for the purposes of
Impact Architects 314-422-9615 michaelriley@charter.net
detennining whether the facility should meet the requirements for limited care. Where
Personal care is Provided Gut medical or custodial care is not, the limited care definition
does not twically apply. It is the intent of this definition that it not apply to persons not
receiving medical or custodial care, provided that are able to assist in their own evacuation,
regardless of their medical diagnosis. (emphasis added)
Willow Haven Senior Homes can only provide personal care. As a Residential Care Facility, it
is prohibited from providing medical or nursing care. The regulation delineates what must,
may, and cannot be offered.
Therefore Willow Haven Senior Homes' Memory Care home should be allowed to be
designated as R-4.
3. Per section 1008.1.9.6 of the Indiana Fire Code, Special egress control devises installed to
prevent a resident from walking out of the building, as described in our meeting on 1019119,
shall only be permitted in I-2 occupancies. To install this type of egress locking system in
your proposed facility the building shall be designed and constructed to comply with the
requirements of an I-2 Occupancy.
PER IFC 1010.1.9.9 Delayed Egress
Delayed egress locking systems shall be permitted to be installed on doors serving the
following occupancies in buildings that are equipped through with an automatic sprinkler
system in accordance with Section 903.3.1.1 or an approved automatic smoke or heat
detection system installed in accordance with Section 907
1. Group B, F, I, M, R, S and U occupancies
2. Group E classrooms with an occupant load of less than 50
ALSO PER NFPA 101:
32.2.2.5.5.1 Delayed -egress electrical locking systems complying with 7.2.1.6.1 shall be
permitted on exterior doors only
32.2.2.5.5.3 Door -locking arrangements shall be permitted where the clinical needs of
residents require specialized security measures or where residents pose a security threat,
provide all the following conditions are met:
1. Staff can readily unlock doors at all times in accordance with 32.2.2.5.5.4
2. The building is protected by an approved automatic sprinkler system in accordance with
32.2.3.5
3. The provision of 32.2.3.5.2 (13D) for conversions is not be permitted to be used
32.2.2.5.5.4 Doors located in the means of egress and permitted to be locked in accordance
with 32.2.2.5.5.3 shall comply with all of the following:
1. Provisions shall be made for the rapid removal of occupants by means of one of the
following:
a. Remote control of locks from within the locked building
b. Keying of all locks to keys carried by staff at all times
c. Other such reliable means available to staff at all times
2. Only one locking device shall be permitted on each door.
Impact Architects 314-422-9615 michaelriley@charter.net
4. Provide an auto turn emergency vehicle circulation plan demonstrating that fire apparatus
can navigate through the facilities drive areas. Drive areas that cannot accommodate fire
apparatus shall be corrected and changed to be able to accommodate the largest piece offire
apparatus available to the Carmel Fire Dept.
Cash Waggner and Associates will modify the drive areas on the plans and the drive areas will
be constructed per Carmel Fire's direction on this
Provide a Fire Hydrant within 100 ft. of the FDC location. The Fire Hydrant and FDC
locations discussed in the meeting are approved.
Cash Waggner will modify the plans to show the fire hydrant and FDC in the locations
advised by Carmel Fire, and the fire hydrant and FDC will be constructed in accordance with
the plans/Carmel Fire's direction.
6. Prior to vertical construction approved asphalt fire apparatus access shall be provided to the
construction site.
Can you please describe the objective that is trying to be accomplished here? It is out -of -
sequence to perform paving before vertical construction because the several months of heavy
trucking and construction activity that will occur during the construction process will do
significant damage to a paved surface. It is likely that paving so early will 1) delay our
construction schedule and lengthen the timeline for the construction of this project and 2)
result in significant extra cost because the asphalt will have to be repaired or taken out and
replaced after 6 or 7 months of construction is performed over top of it. We would prefer not
to incur these delays and extra costs by installing paving at a time that is typical to a normal
construction sequence.
In closing, we'd like to thank you again for your interest in and commitment to making our proposed
project safe and secure. We are happy to continue this discussion with you should you have follow up
questions or should you like to discuss in more detail any of the points put forth in this
communication. Feel free to reach out to the members of our team, including myself at any time.
5inerely,
r%r
1Michael R
1
Impact Architects 314-422-9615 michaelriley@charter.net