As the representative of the U.S. General Services Administration (GSA) Public Buildings Service at the Building Codes and Historic Rehabilitation Conference (April 26-27, 2004) and as chair for the closing conference session, I was invited to offer a public-sector perspective with conference highlights as a segue to the concluding remarks of Marilyn E. Kaplan, AIA, about future directions in the application of codes to historic buildings.

One thing the conference in San Francisco made clear: The line dividing public and private sectors grows thinner every day. Attorney Frank Baltz’s session on GSA’s lease redevelopment of Washington D.C.'s 1840s-era General Post Office by the Kimpton Hotel Group enumerated the benefits and complexities of America's continuing trend toward public-private partnerships, mirrored in other countries. In this case, a third-party expert in hotel occupancy was retained to serve as the Authority Having Jurisdiction, allowing the federal government to maintain its sovereign authority while ensuring safety in a new use not within the agency’s expertise to oversee. Among the conference’s principal connecting threads was another take on public-private partnerships, one that redefines the project team as a larger collaboration between code enforcers, preservationists, owners, and designers employed to translate program to plan.

Smart-Code Alternatives Encourage Reuse, Rehabilitation, Reinvestment

The introductory remarks of Natalie Bull, president of conference sponsor Preservation Technology International (APT),  recounted the organization’s history of leadership in promoting alternative compliance approaches for historic buildings, as founding APT members in Canadian and American national government preservation programs have joined private practitioners and institutional members to play an active part in this effort. The keynote address by Sharon C. Park, FAIA, reviewed code compliance issues and solutions, illustrating approaches that worked well in Tax Act projects overseen by the National Park Service. Common factors in these success stories were flexibility and the benefit of getting everyone to the table from the onset for collaborative dialogue. Kaplan’s overview of historic building code alternatives provided the context for succeeding sessions with a history of regulation in response to disasters caused by unsafe conditions, the development of alternative codes and compliance approaches, and emerging issues.

States and municipalities are exploring "smart code" alternatives to traditional building codes principally written for new construction, applying new requirements in proportion to project scopes to make reuse affordable. Codes official Margaret Mahoney described a program through which Portland, Ore., allows phased compliance and developer-municipality compliance agreements as another alternative to put safety improvements within the financial grasp of owners reliant on revenue that doesn’t come in all at once. These common-sense approaches to managing risk within financial constraints have, to some extent, been de facto public-sector practice for years as GSA and other agencies prioritized costly safety interventions based on building-by-building risk analysis to ensure public safety in the nation’s vast inventory of federal facilities.

Architects Tom Winters and Alan Dreyfuss, AIA, of the California State Historical Building Safety Board offered case studies illustrating the goal of California’s Historic Building Code to facilitate the preservation and continued use of historic buildings while providing reasonable safety, exemplified in the determination that a former brick kiln converting to institutional use could take the heat, so to speak, and that reasonable safety could be achieved by installing sprinklers in high-hazard areas such as kitchens. Encouraging trends include the growing prominence of modeling in conjunction with expanded research on the fire resistance of archaic materials for evaluating the efficacy of alternative compliance solutions under different fire scenarios. In the Oakland Rotunda case study, advances in modeling supported replicating original, noncompliant railings and maintaining open access from all floors to the building’s grand atrium.

David Hattis of Building Technology Inc., an author of the U.S. Department of Housing and Urban Development's Guideline on Fire Ratings of Archaic Materials and Assemblies and Maryland’s Rehabilitation Code, discussed how the principle of proportionality—focusing compliance on delineated work areas—is improving the predictability of rehabilitation costs to encourage reinvestment in historic buildings. Other smart-code principles include triggering compliance requirements through change in the hazard ranking of the occupancy, not change of occupancy alone. For jurisdictions exploring rehabilitation code options, Hattis cautioned that adopting a code is not enough to effect change. Maryland was successful because it followed the code’s adoption with extensive training and a building officials hotline.

In a permitting process, as San Francisco Chief Building Inspector Lawrence Kornfield reminded conference attendees, the analysis begins with critical threshold questions such as “Is the building qualified (designated)?” and “What is the equivalency?” Kornfield elaborated on the growing importance of new technologies that help to achieve equivalency with less intervention, such as intumescent coatings and rated glass for smoke and fire separation.

Code officials Dennis Richardson, Mike Broomfield, and Mahoney stressed the importance of ensuring that the design team does its homework before seeking approval for alternative solutions. This begins with identifying affected code provisions and conditions and being prepared to offer a plan for achieving a reasonable level of safety with specific solutions because code officials do not have the time to perform the analysis or develop the solutions. Richardson’s program in California has developed a helpful matrix aligning corresponding provisions of each code, available online. In Oregon’s program, compliance agreements are recorded in the property deed to give applicants assurance that an approved solution is durable. The state has also begun documenting equivalency determinations for future reference, with the intent of improving code interpretation consistency and eliminating redundant effort.

Documentation plays an important part in liability risk management for design professionals as well. Attorney Frank Baltz reviewed liability issues for project architects and owners, recommending that architects document agreed-upon, reasonable design solutions; manage liability through risk-sharing contract provisions; and insist upon a project budget contingency for claims. Historic building redevelopment projects depend upon predictability so that owners and developers can create a reliable project pro forma to secure financing.

Case Studies Show How to Meet Code Challenges Successfully

Conference technical sessions explored in greater detail the complexities associated with alternative code compliance approaches and how challenges have been successfully resolved. Fire Safety Engineer Melvin Green reiterated the importance of thinking through the specific building occupancy to identify conditions and hazards and documenting how each is resolved. Alice Carey, AIA, presented the case study of the Columbo Building, for which new construction accommodated accessible restrooms, provided horizontal egress, and buttressed a historic commercial building to meet seismic requirements.

Several projects demonstrated how modeling, though somewhat costly, can net substantial project savings and preserve historic character. Engineer Cheryl Domnitch pointed to the value that an $8,000-to-$80,000 modeling study offers when it saves a five-story building’s open ceremonial stair or eliminates the need for mechanical smoke evacuation. Green’s review of the Balboa Theater project, where modeling cut seismic upgrade costs from $2.5 million to $1 million, reinforced this truth. In the Ahwanee Hotel case study presented by Naomi Miroglio, AIA, modeling confirmed the efficacy of proposed egress improvements and the benefit of incorporating operational solutions, such as staff training, into the compliance program.

Developing an alternative compliance program requires the project team to look beyond individual spaces and assemblies to take larger building performance, operations, and stewardship concerns into account. Domnitch urged conferees to consider the importance of continuity of operations in choosing among smoke or heat alarm and fire suppression options, for example, by asking how long functions housed in a building can afford to be down. In that regard, costlier detection technologies sometimes offer net savings in combination with other systems. In Domnitch’s San Jose, Calif., example, projected-beam smoke detection eliminated the need to replace sprinklers below the code-mandated distance from the ceiling. Similarly, fire safety engineer Nick Artim’s review of detection and suppression technologies showed how costlier mist suppression offered savings where existing water delivery was insufficient for conventional water suppression. Exceeding minimum code requirements can also offer net savings and preservation gains, as Miroglio illustrated by a Stanford University project where adding detection not required by code kept the wings of Toyon Hall open.

Many projects achieve equivalency using a combination of high- and low-tech solutions to meet the intent of the code while preserving original features. The case studies of Milford Wayne Donaldson, FAIA, used intumescent coatings to achieve ¾-hour rating equivalents for fire escape windows, recessed accordion fire separation doors to preserve historic lobbies, reversibly installed rated walls to preserve glazed historic doors that do not need to remain operable, and historic exit signs modified with modern illumination to meet current egress requirements. Miroglio’s Calvert Presbyterian Church project illustrated how far the application of codes to historic buildings has advanced in sophistication since the 1970s—rethinking a compliant, if inefficient, solution for fire separation between adjoining buildings to gain usable space by examining the complex holistically and eliminating an unnecessary stair addition.

The Future: "Unique Solutions for Unique Buildings"

So where does this leave us? Kaplan had opened the conference with a history of codes and recent developments, striving to find a reasonable balance between safety, economy, aesthetics, and integrity. At the close of the conference, she offered these reflections on future directions for continued discussion:

"The mix of attendees reinforced the necessity of code officials, fire protection engineers, and architects to work together to address the problems faced when making historic buildings fire-safe in a manner that does not damage historic character. Whereas some codes, such as the California State Historic Building Code and NFPA 914 Code for Historic Structures explicitly recommend a team approach, the need to convene numerous sources of expertise is implicit in other codes. Throughout the conference, presenters and conferees identified the team as the source of all successful solutions.

"With the move toward a single national code framework (if not a single national code) continuing to gain footing, regional differences that go beyond technical differences become increasingly clear. States and municipalities vary greatly in the amount of discretion given to the code enforcement officer, their approach to the acceptance of alternate solutions not prescribed by the codes, and their reliance on the team approach as the key to a successful outcome.

"Although recent decades have brought many more tools for developing successful code solutions for historic buildings, the challenge facing historic buildings will continue as the public’s expectation of acceptable levels of safety increases. There is no single, fits-all solution, and sprinklers are not the only answer. The latter is particularly evident when viewed in the context of severe budget restrictions of some private nonprofit organizations or through a critical preservation lens seeking a minimal level of intervention.

"Because the national move to proportional codes for existing buildings is still in its childhood, the next decade will determine whether these approaches are widely endorsed and the extent to which modifications can be made while maintaining the basic, underlying philosophy. The next decade also promises to make performance-based codes and computer modeling techniques accessible and affordable to more projects, permitting unique solutions to be developed for unique buildings."

Caroline Alderson is program manager of the Center for Historic Buildings, Public Buildings Service, U.S. General Services Administration

Marilyn Kaplan, AIA, is principal of Preservation Architecture, Albany, N.Y.