Understanding the Differences Between CBC Chapter 11A and 11B: A Guide for Public and Private Housing

The fundamental difference between California Building Code (CBC) Chapter 11A and Chapter 11B lies in funding source and occupancy type. Chapter 11A applies to privately funded multifamily housing, while Chapter 11B applies to publicly funded housing, public accommodations, and commercial buildings.

Chapter 11A: Private Housing Accessibility

Chapter 11A applies to privately funded multifamily dwellings and focuses on adaptable design features.

Scope and Applicability

Chapter 11A covers the following privately funded housing types:

• Apartment buildings with 3 or more dwelling units

• Condominiums with 4 or more dwelling units

• Townhouses with 3 or more efficiency units

• Timeshare dwellings with 3 or more units (not considered public accommodation)

• Dormitories with 3 or more guest rooms

• Other Group R occupancies in covered multifamily dwellings

Key Requirements Under Chapter 11A

Adaptable Features: Chapter 11A requires adaptable features rather than fully accessible units. Adaptable units can be easily modified in the future to accommodate persons with disabilities.

Ground Floor Requirements: All ground floor dwelling units in non-elevator buildings must be adaptable and on an accessible route.

Elevator Buildings: All units on floors served by an elevator must be adaptable.

Multistory Units: In non-elevator buildings with multistory dwelling units, at least 10% of the units must comply with accessibility requirements, with the primary entry and at least one bathroom on the primary entry level.

Parking: Accessible parking spaces must be provided at a minimum rate of 2% of the dwelling units or 2% of assigned parking spaces, whichever is larger.

Chapter 11B: Public Housing and Public Accommodations

Chapter 11B applies to publicly funded housing, public accommodations, commercial buildings, and facilities owned or operated by public entities.

Scope and Applicability

Chapter 11B covers:

• Housing facilities owned, operated, or constructed by public entities

• Housing projects receiving public funding or subsidies

• Buildings or complexes with 3 or more residential dwelling units (when publicly funded)

• Homeless shelters, group homes, halfway houses

• Transient lodging (hotels, motels, hostels)

• Housing at places of education (public schools, colleges, universities)

Key Requirements Under Chapter 11B

Mobility Features: A minimum of 5% of residential dwelling units must provide mobility features complying with full accessibility standards.

Communication Features: A minimum of 2% of residential dwelling units must provide communication features for persons with hearing or vision impairments.

Adaptable Features: All ground floor dwelling units must have adaptable features, and all units in elevator buildings must have adaptable features.

Dispersion: Required accessible units must be dispersed among various types of dwelling units and located on accessible routes.

Critical Distinctions in Practice

Funding Determines Chapter Applicability

The key determining factor is public funding or public entity involvement. Even partial public funding can trigger Chapter 11B requirements for the entire project.

Examples of public funding that triggers Chapter 11B:

• California Tax Credit Allocation Committee (TCAC) funding

• Community Development Block Grants

• Low Income Housing Tax Credits

• California Multifamily Housing Program

• Local housing bonds or loan agreements

Technical Standards Differences

Chapter 11A: Focuses on adaptable design that can be modified later. Requirements are less stringent and designed for future accessibility modifications.

Chapter 11B: Requires fully accessible design meeting 2010 ADA Standards. Units must be immediately usable by persons with disabilities.

Scoping Requirements Summary

Requirement	Chapter 11A	Chapter 11B
Ground Floor Units	All adaptable	All adaptable
Elevator Building Units	All adaptable	All adaptable
Mobility Features	Not specifically required	Minimum 5%
Communication Features	Not required	Minimum 2%
Parking	2% of units/spaces	Per ADA Standards

Real-World Examples

Chapter 11A Projects

• Private Apartment Complex: 100-unit privately funded apartment building requires all ground floor units to be adaptable

• Private Condominiums: 20-unit condominium project with private financing follows Chapter 11A adaptability requirements

• Senior Housing: Privately funded senior housing with 50 units requires adaptable features per Chapter 11A

Chapter 11B Projects

• Affordable Housing: Tax credit project requires 5% mobility units and 2% communication units

• Mixed-Income Development: 200-unit project with 50% market rate and 50% subsidized units - entire project follows Chapter 11B because of public subsidy

• University Dormitory: Public university housing requires Chapter 11B compliance

Enforcement and Compliance

Chapter 11A: Enforced by local building officials through the Department of Housing and Community Development (HCD).

Chapter 11B: Enforced by the Division of the State Architect - Access Compliance (DSA-AC).

Recent Changes

As of July 1, 2021, adaptable dwelling unit requirements for public housing moved from Chapter 11A to Chapter 11B. This change consolidated public housing accessibility requirements under a single chapter.

DISCLAIMER: The information provided in this post is for informational purposes only and does not constitute legal advice. Please consult a qualified attorney or consultant for advice tailored to your situation.