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Public Housing Congregate Residence - how much accessibility for accessible route?

Yikes

SAWHORSE
Joined
Nov 2, 2009
Messages
4,120
Location
Southern California
Client: a not-for profit that is expanding an existing house into an R-2 congregate residence for people at risk of homelessness. The finished residence will have 20 bedrooms, and each bedroom has its own en suite bathroom. The residents share common living rooms and a common kitchen.
Public funds, including HOME funds, are being used and so the project meets the definition of "public housing", per 2010 ADAS and Calif. Bldg Code 11B.

QUESTION: How much of the house needs to be accessible?
  • If these were 20 apartments instead of 20 bedrooms, then only 5% (one unit) would need to be mobility accessible.
  • But if the code considers the entire building to be a single residence, then ADAS / 11B 809.2.1 says the accessible route shall connect ALL SPACES which are a part of the residential dwelling unit. That means for example that all 20 bathrooms need an accessible route (T-turnaround, 11B door clearances, etc.)!
 

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Look at the contract for the money. (Grant)
Many times the lender/grantor may have required it be fully accessible.
 
Look at the contract for the money. (Grant)
Many times the lender/grantor may have required it be fully accessible.
Grantor did not specify. But they used HOME funds, and DSA says that triggers 504 compliance:
1726676733871.png

So does that mean all 20 bathrooms need a T-turnaround, and all bedroom closets need clothes rods within reach range?
If "yes", then it seems odd that if I then add a kitchen into each bedroom, turning the bedroom into a dwelling unit, then only 5% of the bedrooms would need to be mobility accessible.
 
Wouldn't this be more similar to a dormitory than to a single dwelling unit?

You probably have to make all doors have a 32" clear width, and closet shelves & rods need to be able to be lowered to an accessible height.
 
Wouldn't this be more similar to a dormitory than to a single dwelling unit?

You probably have to make all doors have a 32" clear width, and closet shelves & rods need to be able to be lowered to an accessible height.
To be honest, the more I look at it the more confused I get, and I think I'm dealing with a unicorn just trying to classify it per CBC Chapter 3.
  1. The average length of stay is 6 months, so our client considers it "transitional". But in CBC 202, "transient lodging" is a stay of 30 days or less. So it's not
  2. There is only one kitchen in the building, for common use by all residents. Per CBC 202 definition of "sleeping unit", the bedrooms with en suite bathrooms are not considered sleeping units, because they are part of one dwelling unit.
  3. One dwelling unit = R-3 congregate residence, right? Wrong: CBC 310.4 says its only R-3 when a congregate residence has 16 or fewer occupants. We havve at least 20 occupants.
  4. OK, so now it sounds like R-2, "congregate residences (nontransient), right? Wrong again. CBC 310.3 says it must contain sleeping units (see #2, it doesn't), or must have more than two dwelling units, and it doesn't.
I may make a separate post about this.
 
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