Plumbing fixture count

[Yankee Chronicler]

Our firm does many California multifamily rehab/refresh projects, including public housing where we need to reconfigure 5% of thr kitchens for mobility accessibility, The approach that most building departments take (and I agree with it) is:

In the (non-mobility) units where we are removing all the old cabinets and countertops and appliances because they are worn out, and we are replacing them in-kind, like-for-like, in the same configuration, no new electrical loads: typically there is no code upgrade, particularly on the electrical work. We leave the old switch and outlet locations as they were. We will typically swap out the countertop outlets with GFI outlets, but that/s about it. Replacement lighting needs to meet current energy codes.

California Building Code:

[A] 105.2 Work Exempt From Permit

Exemptions from permit requirements of this code shall not be deemed to grant authorization for any work to be done in any manner in violation of the provisions of this code or any other laws or ordinances of this jurisdiction. Permits shall not be required for the following:
Building:

1. One-story detached accessory structures used as tool and storage sheds, playhouses and similar uses, provided that the floor area does not exceed 120 square feet (11.15 m2). It is permissible that these structures still be regulated by Section 710A, despite exemption from permit.

2. Fences not over 7 feet (2134 mm) high.

3. Oil derricks.

4. Retaining walls that are not over 4 feet (1219 mm) in height measured from the bottom of the footing to the top of the wall, unless supporting a surcharge or impounding Class I, II or IIIA liquids.

5. Water tanks supported directly on grade if the capacity is not greater than 5,000 gallons (18 925 L) and the ratio of height to diameter or width is not greater than 2:1.

6. Sidewalks and driveways not more than 30 inches (762 mm) above adjacent grade, and not over any basement or story below and are not part of an accessible route.

7. Painting, papering, tiling, carpeting, cabinets, counter tops and similar finish work.

 

[Yikes]

California Building Code:

I find exception #7 interesting as it relates to public housing. CBC 11B / ADA and the DOJ commentary defines a “substantial alteration” to a kitchen or bathroom to include “replacement of cabinetry”. Per 11B-233.3.4.2 that Substantial Alteration then triggers reconfiguration of 5% of the units to meet the mobility requirements of CBC 11B. And yet, per exception #7 no plan check is required to confirm compliance with 11B.