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"Change Of Use": original permit vs. latest code - change of "USE"

We have an existing 1970's hotel that is being converted into studio apartments (R-1 to R-2). The addition of the kitchenette requires an upgrade to the electrical service for the building, arc fault and GFI upgrades along with a fire suppression and smoke detection throughout the building. That is just the major requirements. There will be a number of other code requirements as we work through the review process.
I agree about upgrading the electrical service, but that’s an alteration.
The interesting thing here is that, like many hotels, these existing hotel rooms already have refrigerators, microwaves and coffee makers sufficient to prepare food, items which meet the CBC 202 definition of kitchen. Yet I haven’t heard anyone say that any hotel rooms with microwaves and refrigerators are now dwelling units instead.
The only think we are proposing to add is a kitchen sink, and maybe an induction burner.

The main trigger to code change appears to be length of stay - - and I would think that long term residents are a safer, being more familiar With building features and exit routes.
 
I don't think the microwave actually constitutes cooking....
1677884838903.png
I would have assumed that under a code definition, using a microwave to heat food was considered "cooking"... (I'm not one to ask about haute cuisine)...

But to your point, the link below in to an interpretation from the NIH division of the fire marshal stating that all of the following can be used as appliances for "cooking" without triggering designation as a kitchen for purposes of fire safety:
Microwave ovens​
Toaster ovens​
Toasters​
Air fryers​
Slow cookers​
Popcorn poppers​
Hot plates with enclosed heat elements.​
They say "limited quantities of butter, cooking spray or oil can be used".​
https://ors.od.nih.gov/ser/dfm/Documents/Interp 17-8 Portable Cooking Appliances.pdf

Wow, under this scenario, a kitchenette with a toaster oven, microwave oven and enclosed burner is not a kitchen - - so in my proposed design, under this interpretation "kitchenettes" aren't really "kitchenettes" at all. so my original point stands, regarding there being no practical increase in life-safety hazard in hotel vs. apartment as an allowed use.
 
View attachment 10254
I would have assumed that under a code definition, using a microwave to heat food was considered "cooking"... (I'm not one to ask about haute cuisine)...

But to your point, the link below in to an interpretation from the NIH division of the fire marshal stating that all of the following can be used as appliances for "cooking" without triggering designation as a kitchen for purposes of fire safety:
Microwave ovens​
Toaster ovens​
Toasters​
Air fryers​
Slow cookers​
Popcorn poppers​
Hot plates with enclosed heat elements.​
They say "limited quantities of butter, cooking spray or oil can be used".​
https://ors.od.nih.gov/ser/dfm/Documents/Interp 17-8 Portable Cooking Appliances.pdf

Wow, under this scenario, a kitchenette with a toaster oven, microwave oven and enclosed burner is not a kitchen - - so in my proposed design, under this interpretation "kitchenettes" aren't really "kitchenettes" at all. so my original point stands, regarding there being no practical increase in life-safety hazard in hotel vs. apartment as an allowed use.
I see your point BUT converting "Sleeping Unit into Dwelling would include, not only number of dedicated circuits like the general lighting and plug loads for the 3VA / SF , but also the min. 2 kitchen (which include the counter) the bathroom, and Laundry (probably) all with a separate and accessible panel that only serves those circuits and also the appliances and HVAC for that unit.
I suspect that 2 or more "Rooms" are to be consolidated to enlarge the space and the idea of finding and reconnecting the original wiring seems like it would be false economy. So a complete electrical system seems like a prudent approach.

With the amount of level 1 alteration, wall changes All new wiring seems to be the most cost effective approach since trying to estimate what might be saved would be a real crap shoot

Can't really know without looking at the plans.

I, like you, like to save what can be saved and not just rip it out. So I know where you are coming from
 
Just stumbled over a reference in a 2017 NEC "Handbook" that suggested a microwave sitting on the counter would Not Trigger the idea of Cooking BUT a permanently Installed Microwave WOULD.
I just think we are all just trying our best to discern the INTENT of the Code
 
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