City staff, fire chief ask council to abandon allowing RVs as full-time homes on Bainbridge

The Bainbridge city council is considering a change in its development rules that would allow recreational vehicles, or RVs, to be used as permanent, year-round homes.

But while the move is meant to help alleviate the affordable housing crunch on the island, other public officials are raising safety concerns about the proposal, and warn it won’t be a quick fix to the lack of lower-cost housing on the island.

City councilmembers are expected to review proposed changes to building rules at their meeting Sept. 10.

In addition to looking at RVs being allowed as permanent homes, the council will also review rules for “tiny homes” — small homes, usually less than 400 square feet, with some built on wheels — and zoning districts for communities of tiny homes.

While the council reached consensus at its July 23 meeting to allow RVs to be used as a primary residence on some Bainbridge properties, councilmembers will continue their talk about that idea when they take up a proposed ordinance that would allow RVs as permanent housing. Types of RVs include motorhomes, camper trailers and fifth-wheel trailers, campervans and truck campers, and typically contain a sleeping area, a kitchen or basic cooking facilities, and a bathroom.

The notion to allow RVs as full-time homes on the island has prompted planning officials and others to raise concerns about the idea.

In a letter to the city, Bainbridge Island Fire Chief Hank Teran said RVs lack the minimum safety features that are required for residential homes. Those features include emergency egress (fire code-built homes require both a primary and secondary means of escape in case of fire or other emergency), permanent electrical wiring, and fire resistance and fire protection. RV housing would also need to meet regulations for other single-family homes, such as fire flow and fire department access.

Teran also noted that fire and life-safety detection devices — smoke alarms, propane detectors, carbon monoxide alarms — would also need to be installed.

“The use of RVs as an approved form of a permanent dwelling is unconventional and a challenge regarding compliance with fire and life safety minimum standards,” Teran wrote. “I addition to fire and life safety challenges, older RVs may not be able to comply with minimum recognized RV standards without significant cost and expense.”

“The fire district recognizes the importance of addressing the homeless issue but recommends addressing this issue by a more conventional method that provides the minimum recognized fire and life safety standards,” he added.

City staff are now asking the council to reject the idea of allowing RVs to be used as permanent homes.

Bainbridge Building Official Todd Cunningham, in a memo to Interim Planning Director Heather Wright, listed eight reasons why the proposal should be rejected:

• RVs are currently regulated as “vehicles” and construction is regulated by the Department of Labor & Industries. As such, jurisdictions at the local level such as the city of Bainbridge Island can’t dictate how they are built under the city’s building code. The city can only regulate where they can be parked.

• Fire protection life safety concerns, as shared by Bainbridge’s fire chief.

• Raw sewage is stored in holding tanks within RVs; handling sewage is challenging and can lead to further health risks, as well as environmental problems caused by spills.

• RV plumbing systems “are of a much lower quality and are not designed for continual or prolonged use.” Such systems are not insulated and subject to damage by freezing.

• Mechanical systems — such as heating, refrigeration and air conditioning — are not designed for full-time use and permanent living, and not regulated by state energy codes.

• The growth of mildew and mold is an issue due to poor air quality creates a greater health risk in RVs “which can expose the occupants to respiratory and other health risks.”

• RVs are not energy efficient, with thinner walls, lower quality windows and lower values of thermal insulation, “all of which waste energy and create moisture problems.”

• RVs are built using materials that create higher levels of volatile organic compounds such as formaldehyde, which exposes occupants to long-term health risks.

Jennifer Sutton, a senior planner in the planning department, noted in a recent memo to the council that the Kitsap Public Health District regulates drinking water and the disposal of sewage, and will require that RVs meet the same requirements that conventional accessory dwelling unit must meet.

Sewage tanks from RVs would not be allowed to empty into traditional septic systems, and RV residents would need to reach agreements with the city to discharge at legal, off-site pump-out facilities.

If the RV is placed on land with a well, wells can only serve up to two residences (if the well is designed that way) and adding a third unit of any kind would require converting the private well to a Group B public water system, a difficult task that also includes additional costs due to monitoring and reporting requirements.

“RVs are not a ‘quick fix’ for creating affordable housing because of potable water and sanitation requirements,” Sutton wrote in the memo.

City staff noted that just one place in Washington allows RVs as a primary residence: Ocean Shores.

Ocean Shores, a seaside town of roughly 5,500 in Grays Harbor County, has allowed RVs as a primary residence in one zoning district since 2008.

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