The week before last I caught a ride to our state capitol Salem, OR with Kol Peterson of the Portland ADU Tours and Caravan - The Tiny House Hotel. We went to the Oregon Residential & Manufactured Structures Board to testify regarding the provisions drafted by BCD regarding HB 2737 - the small housing bill in Oregon.
“Author’s Note: The Board was reviewing a draft set of provisions for small homes because the Building Codes Division (BCD) received a mandate via House Bill 2737 to develop a set of standards to accommodate small homes under 600 square feet. Unfortunately, the draft they created shifted the size from 400-1500 SF, renamed it “workforce housing” and included many provisions that had nothing to do with the mandate. (Some of which would set back energy-efficiency requirements to the standards we had 20 years ago!) So those of us who believe in affordable housing, energy-efficient housing, and tiny housing filled the room to speak up for small homes. Anne Holmgreen, Pam Westra, Michelle Boyle, Lori Slaughter, and many more were there. With us in spirit were Andrew and Gabriella Morrison who were out of the country and out of pocket during this session. They have worked doggedly on this endeavor, including championing Appendix Q, the tiny house appendix which was approved by the International Code Council last year and is now available for adoption by municipalities. (If you want to learn more about it, check out our pals Christian and Alexis’ films: Living Tiny Legally (Parts 1 & 2 are now available)). I’m so glad we got to testify a couple weeks ago and pleased to see so many other people also asking the Board to support small homes! I can’t make it tomorrow so instead I sent the following letter today: ”
Dear Oregon Residential and Manufactured Structures Board c/o Richard Baumann, Rules Coordinator:
I testified on 11/30 regarding concerns about the BCD draft provisions for HB 2737. I am unable to attend the meeting tomorrow due to a work meeting conflict, so I am writing today to share my requests with the Board. I am a tiny house designer, dweller, educator, and advocate. I've had the opportunity to live in five homes under 600 square feet while studying for my Masters of Urban and Regional Planning, working for sustainable development companies doing adaptive reuse projects, and starting my own small company to help fellow Oregonians find (or create) affordable housing. Over the past several years I've compiled a set of ADU Case Studies on accessorydwellings.org, worked on dozens of small space design projects, taught tiny house classes at Yestermorrow Design-Build School and through Portland Community College, and spoken at Tiny House Jamboree, Tiny House Conference, Tiny House Fest Vermont, Tiny House Fair, and a plethora of smaller events. In these ventures I've met tens of thousands of people from around the world - including thousands of Oregonians - who are using small homes to meet their needs for safe, comfortable, stable, energy-efficient, community-oriented, affordable housing.
My recommendations are as follows:
- Adopt Appendix Q in its entirety as the base for this code. Appendix Q was carefully researched and written to accommodate the specific design and building constraints of space-efficient housing and it has been approved by the ICC for adoption by cities and states. A few municipalities have adopted it already: https://tinyhousebuild.com/code/.
- Eliminate R329.1.1, R329.4.5, and R329.9 limitations regarding lofts. There was no rationale provided for limiting a small home to just one loft or to limiting the maximum size of a loft, nor are there any reasons to do so. Similarly, the concern about kitchens under or near lofts are addressed by other provisions, such as guardrails. Therefore, these limitations regarding lofts should be removed.
- Require fire sprinklers (Section R329.5) and/or Class A finishes (R329.4.4.1) only when they are required of other residential structures and/or with evidence that small homes have a greater need for them. We absolutely want small homes to be safe, but we are concerned about the requirement of cost-prohibitive fire safety components when these precautions are not required for other residential structures. As noted by Andrew Heben of SquareOne Villages, providing the option to select either R329.5. (fire sprinkler) or R329.5.1 (interior finishes), "balances the interests of innovation and cost-effectiveness along with safety concerns."
- Eliminate the requirement for Alternating Tread Devices and Ships Ladders to meet Section R311. Appendix Q addresses vertical circulation standards.
Please ensure that the set of standards you approve in response to the mandate from HB 2737 helps to meet the tremendous need for small housing options in our state! I welcome any questions and appreciate your consideration of my concerns and requests.