Existing (not in scope) conditions not in compliance

[jl3]

Hi All,

We have an interior office project in CA (Palo Alto), using CBC 2022 and the question has to do with existing, not in scope, conditions that are non-compliant.

We originally did an interior renovation design earlier this year, got the construction permit approved and were on hold while the client discussed the budget. Unfortunately, they decided to drastically cut the budget and we're now renovating only the lobby finishes of level 1; the rest of the floor will now be out of scope. The intention is to amend the current permit with our revised scope, however I'm a bit nervous given how strict the AHJ is. In reviewing the existing permit drawings from 2018, the AOR at the time seemingly fudged their plumbing counts by calculating the entire 3 story building in total as opposed to calculating each individual floor; this wasn't an issue previously because we were adding sufficient plumbing fixtures. Based on a similar nearby project we did last year, the expectation is that the AHJ would require existing conditions to be shown, including egress and plumbing counts, in which case we would be depicting level 1 as being non compliant in regards to plumbing counts.

I'm essentially looking to see if there's any exception we can use to get around having to update things that are non compliant when all we're doing now is updating finishes in a lobby. We asked the AHJ if could use CEBC 2022 1009.1 as an exception and apparently chapter 10 has not been adopted by the city. Any input is appreciated.

 

[Joe.B]

We asked the AHJ if could use CEBC 2022 1009.1 as an exception and apparently chapter 10 has not been adopted by the city. Any input is appreciated.

If your permit application was before July 1 2024, they are correct. CA added a whole bunch of blue pages into the CEBC mid-cycle amendment. Permit applications are only required to comply with the code in effect at the time of application. Before July 1 most of the CEBC was "Not adopted by the State of California." Many jurisdictions miss the mid-cycle amendments. But if you're trying to use an existing application then that is a moot point.

Based on the very brief description I would suggest you re-apply under a new application. If you paid a deposit, kindly request that they forward that deposit onto this application.

 

[steveray]

Maybe a California thing but I’ve never seen the requirement to calculate by floor…

 

[Yankee Chronicler]

Maybe a California thing but I’ve never seen the requirement to calculate by floor…

Agreed. In fact, under the basic IBC and IPC there isn't even a requirement that each floor have toilet facilities. Toilet rooms can be up to 500 feet and one story vertically remote from the area they serve.

Please be more specific about the nature of the proposed work. If all you are doing is replacing finishes, and not moving, adding, or removing any walls or doors, then under the IEBC the work would not be considered an "alteration" as defined in the code (unless California revised the definitions).

 

[ICE]

we're now renovating only the lobby finishes of level 1

Are you sure that a permit is required?

 

[arwat23]

Agreed. In fact, under the basic IBC and IPC there isn't even a requirement that each floor have toilet facilities. Toilet rooms can be up to 500 feet and one story vertically remote from the area they serve.

CA uses the UPC, but the paint stands. Restrooms can be on an adjacent floor if needed. You just need an accessible restroom per CBC 11B-202.4 that serves the area of work (on an accessible route from the area of work). Other than that, the remainder could be on a separate floor.

 

[JPohling]

If it is indeed just finishes then no permit would be required. What would be inspected?

 

[Yankee Chronicler]

CA uses the UPC, but the paint stands. Restrooms can be on an adjacent floor if needed. You just need an accessible restroom per CBC 11B-202.4 that serves the area of work (on an accessible route from the area of work). Other than that, the remainder could be on a separate floor.

And if there is an elevator, does that mean that the accessible toilet rooms can be on an adjacent floor?

 

[arwat23]

And if there is an elevator, does that mean that the accessible toilet rooms can be on an adjacent floor?

Yes. If an accessible elevator is provided, the accessible toilet room can be on an adjacent floor.

If an accessible route between stories isn't required (11B-206.2.3, exception 1), then the accessible toilet room needs to be on a story connected by an accessible route to an accessible entrance (11B-213.1).

 

[Yikes]

If it’s only lobby finish renovations, then:
1. Remove all cosmetic work from consideration of scope (11B-202.4 exc. #7) and related valuation
2. Remove work that doesn’t require a permit from project valuation
3. Remaining valuation forms basis for 20% rule (11B-202.4 exc. #8) for adjusted construction cost.
Does that get you below the threshold?