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Parking Garage Occupancy Category

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My firm is part of a design-build team for a parking structure.  The RFP states that the structure is in Occupancy Category III under the 2003 IBC, which results in a seismic importance factor of 1.25.  We feel strongly that this is based on an incorrect interpretation of the clause "buildings and other structures where more than 300 people congregate in one area."  Indeed, this clause has been changed in the 2006 IBC to more accurately reflect the intent of the provision.

We have assembled documentation showing the provision's intent, including John Henry's article in the November issue of Structural Engineer (, but we are hoping to find some resource that states "Parking garages are not required to be Occupancy Category III."  Any help in finding this would be greatly appreciated.

Daniel Popp