Both ASCE 24 and 44 CFR Parts 59 and 60 have long prohibited sub-grade parking under residential in flood zones.
But both allow sub-grade parking under non-residential in flood zones.
ASCE 24 allows sub-grade parking under mixed-use in flood zones.
The allowance for mixed-use is problematic. A tiny amount of non-residential added to an otherwise residential building allows sub-grade parking.
44 CFR Parts 59 and 60 avoid the loophole with the introduction of "other residential". The current draft revision of ASCE 24 still suffers from the loophole.
A related issue: does the mere addition of sub-grade parking to an otherwise residential building make it mixed-use?
The definition of mixed-use would improve if sub-grade parts of a building were excluded from counting as a non-residential use.
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Steven Johnson Aff.M.ASCE
Santa Barbara CA
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