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A longtime Buffalo Bills season-ticket holder -- an engineer armed with a tape measure -- has filed a formal complaint with the county, claiming his new sideline lower-bowl seats in Ralph Wilson Stadium violate state building codes.

Mike Dickman, a former code-enforcement officer with the city, claims the distance between the front of his seat and the back of the seat in front of him measures only 8 1/4 inches, well short of the 10-inch minimum required under the building code.

Dickman was quick to point out that he wasn't allowed to bring a level into the stadium 10 days ago, so he couldn't be as precise as he wanted. But he insisted the distance was well short of the required minimum.

"The 10 inches is not there," Dickman said Tuesday. "The seats don't comply with the code. It's a violation that has to be redressed."

No Bills or Erie County officials reached for comment Tuesday disputed Dickman's measurements, but it was unclear how seriously his complaint will be taken and how it will be handled.

While Dickman measured only the four adjacent seats held by him and his good friend in Row 26 of Section 115, his claim suggests that many of the 30,000 new sideline seats in the lower bowl could be in violation of the state code.

Those new seats, all equipped with armrests and cup holders, have sparked complaints about cramped legroom. The rows are so tight it's all but impossible for anyone to enter or leave a row without everyone else in the row standing up. And the new cup holders eat into the available knee space.

The Bills have replied that they've tried to answer each individual complaint, relocating some fans to other seats and removing some of the offending cup holders.

The team continues to be as proactive as possible in dealing with the complaints, said Bill Munson, vice president for operations.

"We're already looking at solutions," he said Tuesday. Neither he nor Scott Berchtold, the team's vice president for communications, would comment further.

No one knows what's likely to happen with Dickman's complaint. In most code violations, the municipality goes after a private citizen. Here, it's the opposite.

"We've never dealt with a complaint like this in the past," Erie County Attorney Kenneth A. Schoetz said Tuesday. The way the stadium lease was written, the county is not legally responsible for the new seats, he added.

Under the state's Fire Prevention and Uniform Building Code, Schoetz said, taking the complaint directly to State Supreme Court would be one option for an individual trying to force compliance with the building code.

No matter what happens to the complaint, Dickman brings some credibility to the situation.

"Mike Dickman is certainly credible," said Frank DiJames, Buffalo's Housing Court representative. "He knows the ins and outs of the state code. I think that because of Mike's credibility, somebody should listen."

Dickman, all 6 feet 6 inches of him, has been a season-ticket holder for 15 years, a loyal fan who attended all four of the Bills appearances in the Super Bowl.

He got quite a shock when he sat down in his new seat for the Sept. 4 preseason game against the Pittsburgh Steelers.

"The cup holders were digging into my shins, and that was the best scenario I could get," he said. He was so uncomfortable he left the game early in the second quarter.

Two days later, Dickman called Bills ticket officials, who tried hard to help him, he said. But he didn't have enough seniority to be relocated, especially with the Bills so close to selling out several home games.

"They had complaints from people with more seniority, and I understand that," he said.

Dickman subsequently called the Town of Orchard Park, Erie County's project manager for the stadium renovations and several Bills officials.

The Bills did agree to take out all four cup holders for Dickman's group of season-ticket holders, but the team wouldn't let him into the stadium to measure the seat in the days before the home opener against the New York Jets.

At that game, Dickman came with his tape measure, to see whether the seats comply with the building code.

Dickman said the state's Uniform Building Code is very fuzzy on some points, but crystal-clear on the distance between seats.

For outdoor assemblies, the code says, the space between the front of one seat and the back of the seat immediately in front of it must be at least 10 inches.

A footnote tells how that must be measured:

"Measured between the edge of the seat in its lowered position and the horizontal projection of any part of the back of the chair in the row ahead," the code states.

In other words, a level would be needed to measure the horizontal distance between the front edge of a person's seat and the closest part of the chair in front.

"I couldn't get my level in the stadium," Dickman said. "It's one of the banned items."

Using his years of experience as an engineer and code-enforcement officer, Dickman did his best to measure the distance without the level and came up with 8 1/4 inches.

Dickman also claimed the seat width is only 18 inches, short of the 19-inch minimum width required under the code. He emphasized, though, that the code is less clear about how that distance should be measured.

Removing the cup holders helped Dickman, but he still has to infringe on his wife's legroom and seat to sit there.

"I will not have season tickets there next year if they don't make some changes to those seats," he said, eyeing a possible move to the upper deck instead.

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