• Welcome to the new and improved Building Code Forum. We appreciate you being here and hope that you are getting the information that you need concerning all codes of the building trades. This is a free forum to the public due to the generosity of the Sawhorses, Corporate Supporters and Supporters who have upgraded their accounts. If you would like to have improved access to the forum please upgrade to Sawhorse by first logging in then clicking here: Upgrades

When bedrooms don't require windows

N

nealderidder

Sawhorse
Joined
Dec 7, 2010
Messages
394
Location
Sacramento, CA
I have a developer trying to reuse an office building with a very deep footprint as an apartment building. Probably happening a lot right now. The depth of the building, the window layout, and their unwillingness to open up the core of the building, results in very narrow and deep unit layouts. Their idea is to put the living space at the windows and then bedrooms in a row behind it toward an interior corridor (think mobile home in plan). With this layout, none of the bedrooms will have a window. That idea is antithetical to how I usually start an apartment layout, by putting bedrooms on an exterior wall. Sure you can make a deep "studio" and have a "niche" where the bed is going to go and it won't have any windows but an enclosed bedroom usually finds its way to an exterior wall and a window.

My first instinct is to rebel against the idea but then I thought - if it's marketable and allowed by code, is there a reason to say no?

Assume a 4-story building of type III-A construction

A few reasons why one might think a window is "required" in CA:

1. Ventilation: CBC 1202.1 requires natural ventilation or mechanical ventilation. So no absolute requirements for a window.
2. Light: CBC 1204.1 requires natural light or artificial light. So no absolute requirements for a window.
3. Emergency Escape and Rescue: CBC 1031.2 Exception #1 says a sprinkled apartment building (R2) of construction type III-A doesn't require escape windows.

Is there anything else stopping one form designing every bedroom in this building without a window?
 
I don't believe that there is. I think you have covered your bases and determined that it can be done.

Code is a minimum, not best practice. Hopefully the owner has determined that the market will be interested in the proposed units. They will need to carefully consider the coloring, finish textures and materials, lighting, etc. to provide an environment that will feel comfortable. Too sterile or too industrial, and it will feel like a hospital or an industrial factory.
 
The underlying code concerns for bedrooms are (1) ventilation, and (2) egress & escape.

IBC 1031.2 has been amended by my state. We don't have the exception you quoted, so I can't comment on it.
 
nealderidder said:
I have a developer trying to reuse an office building with a very deep footprint as an apartment building. Probably happening a lot right now. The depth of the building, the window layout, and their unwillingness to open up the core of the building, results in very narrow and deep unit layouts. Their idea is to put the living space at the windows and then bedrooms in a row behind it toward an interior corridor (think mobile home in plan). With this layout, none of the bedrooms will have a window. That idea is antithetical to how I usually start an apartment layout, by putting bedrooms on an exterior wall. Sure you can make a deep "studio" and have a "niche" where the bed is going to go and it won't have any windows but an enclosed bedroom usually finds its way to an exterior wall and a window.

My first instinct is to rebel against the idea but then I thought - if it's marketable and allowed by code, is there a reason to say no?

Assume a 4-story building of type III-A construction

A few reasons why one might think a window is "required" in CA:

1. Ventilation: CBC 1202.1 requires natural ventilation or mechanical ventilation. So no absolute requirements for a window.
2. Light: CBC 1204.1 requires natural light or artificial light. So no absolute requirements for a window.
3. Emergency Escape and Rescue: CBC 1031.2 Exception #1 says a sprinkled apartment building (R2) of construction type III-A doesn't require escape windows.

Is there anything else stopping one form designing every bedroom in this building without a window?
Click to expand...
The way I read the CBC 1031.2, the Exceptions are relating to basements, not the above stories.
 
1031.2 Where Required

In addition to the means of egress required by this chapter, emergency escape and rescue openings shall be provided in Group R occupancies.

Basements and sleeping rooms below the fourth story above grade plane shall have not fewer than one emergency escape and rescue opening in accordance with this section. Where basements contain one or more sleeping rooms, an emergency escape and rescue opening shall be required in each sleeping room, but shall not be required in adjoining areas of the basement. Such openings shall open directly into a public way or to a yard or court that opens to a public way.

Exceptions:
...

I see two statements, and I don't see that the exceptions were only to the second statement?
 
Joe.B said:
1031.2 Where Required

In addition to the means of egress required by this chapter, emergency escape and rescue openings shall be provided in Group R occupancies.

Basements and sleeping rooms below the fourth story above grade plane shall have not fewer than one emergency escape and rescue opening in accordance with this section. Where basements contain one or more sleeping rooms, an emergency escape and rescue opening shall be required in each sleeping room, but shall not be required in adjoining areas of the basement. Such openings shall open directly into a public way or to a yard or court that opens to a public way.

Exceptions:
...

I see two statements, and I don't see that the exceptions were only to the second statement?
Click to expand...
Basements and sleeping rooms below the fourth story....
NOT including the fourth story......
 
The last 3 posts above seem to be focusing on what story the sleeping rooms are located on. That is irrelevant to the original post, which asked us to assume a Type III-A building, which eliminates the need for an escape window in California Building Code 1031.2. Therefore the OP is correct, there is nothing in the CBC to prevent bedrooms with no windows in the building described in the post.

That said, the developer may want to read up on the history of the scrapped windowless dorm room plans at UC Santa Barbara: https://www.archpaper.com/2023/08/university-california-abandons-windowless-dorm-munger-hall/

1698778720795.png

1698778789029.png

***

1031.2 Where Required​

In addition to the means of egress required by this chapter, emergency escape and rescue openings shall be provided in Group R occupancies.
Basements and sleeping rooms below the fourth story above grade plane shall have not fewer than one emergency escape and rescue opening in accordance with this section. Where basements contain one or more sleeping rooms, an emergency escape and rescue opening shall be required in each sleeping room, but shall not be required in adjoining areas of the basement. Such openings shall open directly into a public way or to a yard or court that opens to a public way.
Exceptions:
  1. In Groups R-1 and R-2 occupancies constructed of Type I, Type IIA, Type IIIA or Type IV construction equipped throughout with an approved automatic sprinkler system in accordance with Section 903.3.1.1.
 
Last edited:
It is amazing how many fire related requirements are relaxed if a building is sprinklered. Too many?
 
mark handler said:
Regardless to the quality of life, CA is looking for cheap housing.....
Click to expand...
Email from a local broker:

In the wake of distressed office markets, the White House recently provided guidance aimed at finding solutions to increase affordable housing. The White House proposes incentivizing office owners and investors to pursue environmental friendly adaptive reuse / conversions as a possible solution to affordable housing and to solve the problem of empty office spaces and expensive investment capital. This short article from Bisnow discusses the White House plan and includes the 54-page White House Resource Guide. I am always interested in discussing adaptive reuse/conversions for housing. If you are interested,
please give me a call!​

White House Launches Effort To Spur Office-To-Residential Conversions​

​
b372f373-ce7a-4c92-aff9-a5c6c57ab30c.png
The Biden administration is getting in on the office-to-residential conversion push, releasing a guidebook Friday morning on how the federal government can help facilitate conversions.

The 54-page guidebook lays out existing and new opportunities from the federal government to create affordable housing through conversion projects. One of the most notable is the land disposition deals the government is putting forward to help reduce development costs.

The Department of Transportation has cleared the way for local transit agencies to make land available at no cost to local governments and non-profit and for-profit developers seeking to develop affordable housing. Some of the land potentially has existing commercial space ripe for conversion, according to the guidebook.

The General Services Administration, in partnership with the Office of Management and Budget, has begun to identify federal properties it could sell, and the guidebook said it will create a public list of these opportunities.

The guidebook also lists federal loans, grants, tax credits and technical assistance programs across seven federal agencies that can help with these residential conversion projects.

One of these programs is the Department of Housing and Urban Development's Community Development Block Grant program, which has seen $10B in funds allocated since President Joe Biden took office. HUD published an updated notice Friday that expands guidance for the CDB program to include financing acquisitions and conversions of office buildings to housing.

“Addressing the affordable housing crisis requires an all-of-the-above approach,” HUD Secretary Marcia L. Fudge said in a release. “The White House guidebook on commercial-to-residential conversions and the updated CDBG notice are just a few of the steps that HUD is taking to help our state and local partners to ***** supply.”

The guidebook also has a handful of opportunities for zero-emission buildings, including tax incentives for energy-efficiency improvements, tax credits to use and create clean energy in buildings, and affordable financing to support these projects.

Roughly 15% of the office space in the 105 largest cities in the country is eligible for conversion, according to a National Bureau of Economic Research report. Cities like New York, D.C., San Francisco and Boston have started focusing on revitalizing their business districts through these conversions.

Last week, Boston officially launched its office-to-residential incentives program, which will provide an average tax reduction of 75% to office landlords that pursue a conversion project. In February, D.C. officials announced a new tax abatement program aimed at office landlords interested in converting part of their buildings into housing.

In response to the White House's Friday announcement, Mortgage Bankers Association CEO Bob Broeksmit released a statement saying the association supports the initiative.

“Housing providers are grappling with higher interest rates and rising labor and construction costs at a time when our nation’s housing supply remains inadequate,” Broeksmit said. “The initiatives announced today should help facilitate more commercial-to-residential projects. We encourage state and local governments to ensure zoning laws, tax credits, and subsidies are aligned to take full advantage of these programs.”​
 
Eight million, and counting, new arrivals need a place to call home.
 
Last edited:
You must log in or register to reply here.
Top