BCAB 1981 - Spatial separation requirements for an RV shelter

Spatial separation requirements for an RV shelter

Project Description

The project is the design and construction of a post-and-beam, roofed, structure without walls to shelter a recreational vehicle (“RV”).  A roofed deck, without walls, is attached to one side of the shelter.  The building will be located on a rural property that has seasonal RV sites.  The RV in the shelter will be used intermittently during three seasons and stored in the shelter for the remainder of the time.

The new RV shelter and deck are proposed to be located parallel to, partially offset but still overlapping, and 3.7 m away from an existing RV shelter.  A line identified as an “RV pad separation line – not a legal property line” runs between the buildings; the exact location of the line is unknown.

The configuration is generally as illustrated below.

Applicable Code requirements (BCBC 2024)

Sentence 1.4.1.2., Division A, Defined Terms

Exposing building face means that part of the exterior wall of a building that faces one direction and is located between ground level and the ceiling of its top storey or, where a building is divided into fire compartments, the exterior wall of a fire compartment that faces one direction.

Limiting distance means the distance from an exposing building face to a property line, the centre line of a street, lane or public thoroughfare, or to an imaginary line between 2 buildings or fire compartments on the same property, measured at right angles to the exposing building face.

Sentence 9.10.14.2.(1), Division B, Area and Location of Exposing Building Face (excerpt)

(1) Except as permitted by Sentence (4), the area of an exposing building face shall be

(a) taken as the exterior wall area facing in one direction on any side of a building, and

(b) calculated as

(i) the total area measured from the finished ground level to the uppermost ceiling . . .

Sentence 9.10.14.4.(1), Division B, Openings in Exposing Building Face (excerpt)

(1) Except as provided in Sentences (6) to (10), the maximum aggregate area of unprotected openings in an exposing building face shall

(a) conform to Table 9.10.14.4.-A . . .

Sentences 9.10.14.5.(1 and 6), Division B, Construction of Exposing Building Face and Wall above Exposing Building Face

(1) Except as permitted in Sentences (3) to (14), each exposing building face and any exterior wall located above an exposing building face that encloses an attic or roof space shall be constructed in conformance with Table 9.10.14.5.-A. (See Note A-9.10.14.5.(1).)  (See also Subsection 9.10.8.)

(6) Except as provided in Sentence (7), combustible projections on the exterior of a wall that are more than 1 m above ground level and that could expose an adjacent building to fire spread shall not be permitted within

(a) 1.2 m of a property line or the centre line of a public way, or

(b) 2.4 m of a combustible projection on another building on the same property.

Decision being appealed (Local Authority’s position)

The RV shelter is a principal use building, not an accessory building, and the side of the new building facing the existing RV shelter is an exposing building face.  The limiting distance is less than 1.2 m; the permitted percentage of unprotected openings is zero.

Based on the top row in Table 9.10.14.5.-A, the exposing building face requires a 1 h fire-resistance rating, noncombustible construction, and noncombustible cladding.

Appellant's position

The Code definition of an exposing building face references an exterior wall.  This post-and-beam structure has no exterior walls as it is open on all four sides.

The RV within the shelter will see only intermittent use.  Building a wall with a fire-resistance rating defeats the purpose and enjoyment of the RV resort.  Without a shelter there are few options to protect property and persons from the elements.

Appeal Board Decision #1981

The Board varies the decision of the local authority.

It is the determination of the Board that the side of the new building (i.e. the outside edge of the RV shelter posts) facing the existing RV shelter is an exposing building face and that the spatial separation requirements outlined in Subsection 9.10.14., Division B, apply.  In this case, the roof over the deck is considered to be a combustible projection located more than 1 m above the ground.

When the new building is placed in a Code-compliant location, the limiting distance will be more than 1.2 m.

Reason for decision

The new RV shelter building is considered to contain a low hazard industrial major occupancy (i.e., Group F, Division 3) as its principal use is to shelter a vehicle.  The attached deck is considered to be a subsidiary use to that major occupancy.

It is generally established that spatial separation requirements apply to buildings containing roofs without exterior walls.  Reference Board Decisions #1302, #1430 and #1649, as well as BCIC 12-0075 prepared by the Building Code Interpretation Committee.

It is possible that the “RV pad separation line” has been used by the property owners and the building owners as the “imaginary line” for the purpose of spatial separation Code compliance in the construction of buildings on the property.  In that case the Code’s imaginary line is the same as the RV separation line.

If that has not been the case, then the location of the “imaginary line” (as stipulated in the definition of “’limiting distance”) between these two buildings on the same property can only be determined through an analysis of the features of the existing building.  The occupancy of the existing building and multiple features of its exposing building face including its area, the percentage of unprotected openings, the fire-resistance rating, the type of construction, and the type of cladding must all be analyzed to determine how much limiting distance is required for the existing building.  The location of existing combustible projections may also need to be considered.  In other words, it must be determined how much of the property the existing building ‘uses up’.

Only after the location of the imaginary line is determined can the placement of the new building be selected and its limiting distance established.  The imaginary line may located at the “RV pad separation line” or it may be located on one side or the other of the “RV pad separation line”.  Depending on the location of the imaginary line and the resultant proposed placement of the new building, the limiting distance will be more than 1.2 m based on the Code requirement for the location of the new combustible projection (i.e. the roof over the deck) and the dimension of the deck and its roof.

The Board notes that the Code’s spatial separation requirements do not apply to facilities (e.g., recreational vehicles, park model trailers, etc.) that are not buildings.  Reference Board Decision #1914.

Don Pedde
Chair, Building Code Appeal Board

Dated:  September 4, 2025