# CBC 11B for townhomes



## Yikes (Mar 7, 2017)

Peer reviewing a non-elevator building with five for-sale, low-income, multistory (townhome) units. CDBG and HOME funds were used to acquire the land, so I'm pretty sure it is considered "publicly funded" and subject to CBC 11B.

CBC 11B-233.3.1.2.4 requires that 10% (at least one) multistory unit have the following:
1.  A primary entry on an accessible route.
2.  At least one bathroom or powder room on the primary entry level.  
3.  All rooms on the ground level shall comply with 11A, Div. IV "Dwelling Unit Features".​
*Question for item #1: does this mean the primary entry door clearances comply with 11B-404, or 1126A?
Question for item #2: does this mean the powder room clearances comply with 11B-604, or 1134A?*


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## ADAguy (Mar 7, 2017)

Nope, unless it has common spaces open to the public, it is an 11A (smiling)
Is an FHA/HUD project.


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## Yikes (Mar 7, 2017)

ADAguy said:


> Nope, unless it has common spaces open to the public, it is an 11A (smiling)
> Is an FHA/HUD project.


Two years ago the LA city attorney published a determination that any housing project that uses HOME or CDBG funds is subject to ADA (even within the dwelling unit themselves per ADAS 233), 504/UFAS, and FHA.  That is de facto "publicly funded".  

For the purposes of this thread, humor me and assume that CBC 11B applies, and let me know how you would respond.  Thanks!


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## ADAguy (Mar 8, 2017)

Can you post that letter? Does this mean the LA bc has been revised?


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## Yikes (Mar 9, 2017)

ADAguy, I'm not sure if we are on the same page in this discussion.  This has nothing to do with amending the building code.

1.  The city of LA, _wearing the hat of an investor in affordable housing projects (NOT the building official)_, has internally determined (presumably through its in-house legal counsel) that when a housing project utilizes HOME/CDBG funds administered though the city, the project ought to be subject to UFAS/504, ADA, and FHA.  (Sorry, I cannot give you a letter from the city; this was part of a previous RFP a couple of years ago).
2.  The 2010 ADA standards include standards for inside some of the dwelling units, not just for public/common use areas.
3.  Since I have to comply with 2010 ADA I am using CBC 11B to design the units, because I know 11B has been reviewed for compliance with ADA for dwelling units, whereas CBC 11A has not.
4.  11B makes some reference back to 11A, and here is where I restate my original question in hopes of a direct response:

***
CBC 11B-233.3.1.2.4 requires that 10% (at least one) multistory unit have the following:
1. A primary entry on an accessible route.
2. At least one bathroom or powder room on the primary entry level.
3. All rooms on the ground level shall comply with 11A, Div. IV "Dwelling Unit Features".

*Question for item #1: does this mean the primary entry door clearances comply with 11B-404, or 1126A?
Question for item #2: does this mean the powder room clearances comply with 11B-604, or 1134A?*​


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## ADAguy (Mar 10, 2017)

I had a similar situation with the LAHousing Authority holding us to HUD/FHA, no problem for units.
Common areas were required to meet 11B.
Do as they direct but UFAS can be substituted with 2010 Standards at a minimum.


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