# 60 unit project in CA with no accessible/adaptable units?



## nealderidder (Feb 10, 2020)

I'm looking at a CA project with multiple buildings, most of which are made up of carriage units. The carriage units do meet the CBC definition of such. The CBC gives carriage units a pass regarding accessibility (1102A.3.1 Exception). 

So the bulk of those 60 units are carriage units and have no accessibility requirements (and no adaptable elements are proposed). Several of the buildings are mixed-use commercial on the ground floor with multi-story units above. 

Two of the mixed-use buildings are connected by a second story bridge (egress balcony basically) that is served by an elevator. One of the mixed-use buildings does not have an elevator. All of the mixed-use dwelling units start on the second floor and are multi-story.

My questions are about the multi-story units over the commercial uses. These plans show a single powder room on the entry level that's not accessible/adaptable (see attached).

So I've got a Building "A" with an elevator that serves multi-story units.

And a Building "B" without an elevator that contains multi-story units (starting at 2FL).

Is there any way building A or B could have only the attached powder room at the entry level?

I say no for Building "A" because 1102A3.2 says I need a powder room and a kitchen that complies with Division IV. Would you agree?

I'm not sure about Building "B" (no elevator) because 1102A.3 applies to units on the ground floor (these are on the 2FL). Do units that are not on the ground floor and not served by an elevator get a pass like the Carriage units?

Thanks for any insight!


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## Yikes (Feb 10, 2020)

CBC 11A starts with Note 1, which incorporates the HUD/DOJ statement by reference, and therefore should be plan-checked on that basis:



That statement can be found here:  https://www.treasurer.ca.gov/ctcac/2013/hud_doj.pdf 

The statement addresses the Fair Housing Act, and it includes a series of Questions and Answers.

Q&As #22-24 address the building with the elevator.  Basically, because an elevator exists somewhere within building A, all the townhomes in building A need to have to be on an accessible route and be adaptable per 1102A.3.2.  And if building A is physically connected with a bridge to building B, then HUD/DOJ (and therefore the CBC) considers it to be one single building, and that triggers the same 1103A.2 requirements for building B, as per Q&A #17 which says:

Building Separations 
17. _[Q:] _Does the use of breezeways to separate dwelling units that would otherwise be covered by the Act’s design and construction requirements make those units exempt from the Act’s requirements? _[A:] _*No.* In situations where four or more dwelling units are connected by one or more covered walkways (breezeways), stairs, or other elements that are structurally tied to the main body of a building, the dwelling units are considered to be in a *single* building. If the building does not contain an elevator, the ground floor units are subject to the Act’s design and construction requirements. See Design Manual at 10. If the building contains an elevator, all units are subject to the Act’s design and construction requirements.​


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## Rick18071 (Feb 11, 2020)

I thought they were only carriage-units when there is a private garage (U) on the first floor not commercial businesses.

check this out: 
https://www.thebuildingcodeforum.com/forum/threads/carriage-units.11228/


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## ADAguy (Feb 11, 2020)

Is this in Sac.? Hang um high! Experienced developer? Public or private funding?


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## nealderidder (Feb 11, 2020)

Rick18071 said:


> I thought they were only carriage-units when there is a private garage (U) on the first floor not commercial businesses.
> 
> check this out:
> https://www.thebuildingcodeforum.com/forum/threads/carriage-units.11228/



There are about 10 separate buildings. Three of them are mixed use with commercial on the ground floor, the remainder are true "carriage" units with garages only on the ground floor as you mentioned.


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## nealderidder (Feb 11, 2020)

ADAguy said:


> Is this in Sac.? Hang um high! Experienced developer? Public or private funding?



Certainly not an inexperienced developer. They're applying for HUD mortgage guarantees (221 D).


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## nealderidder (Feb 11, 2020)

Yikes said:


> CBC 11A starts with Note 1, which incorporates the HUD/DOJ statement by reference, and therefore should be plan-checked on that basis:
> View attachment 6463
> 
> 
> ...



It certainly seems like some re-design is called for. At least an accessible powder room and kitchen on the entry level.


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## ADAguy (Feb 12, 2020)

certainly does.


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