Public housing is set to lose five 11B accessibility exceptions

On a publicly funded 60-unit building, the laundry room has an easy out today: install a bank of washers and dryers, make the required two of each accessible, and you're done. A proposed California rule would end that. Every common-use washer and dryer would have to be front loading and within reach.

Here's the thing: that laundry rule is one of five exceptions a proposed Division of the State Architect rulemaking — DSA-AC 01/25 — would take away from public housing. It does it by filling a slot that has sat empty in the building code for years.

The empty slot gets filled

Open the 2025 California Building Code to Chapter 11B and you'll find this: "11B-233.2 Reserved." A placeholder. The proposal replaces it with a new "11B-233.2 Public housing facilities" and loads it with the extra requirements from HUD's 2014 Deeming Notice (Docket No. FR-5784-N-01) — the federal instruction that tells Section 504 recipients which parts of the 2010 ADA Standards don't reach far enough.

Verified against the live code text: the 2025 CBC Chapter 11B still reads "11B-233.2 Reserved." The replacement language comes from the DSA-AC 01/25 Final Express Terms sent to the Building Standards Commission.

The new section applies to public housing with five or more residential dwelling units. An exception exempts facilities with four or fewer units — a change DSA made after Disability Rights California and others pointed out that the Deeming Notice itself only reaches projects of five or more.

The five exceptions on the way out

For a 5+ unit publicly funded project, each of these everyday carve-outs would disappear:

1. Site accessible routes. The new 11B-233.2.1 bars the "vehicular way" exceptions at 11B-206.2.1 Exception 2 and 11B-206.2.2 — you can't skip an accessible route from site arrival points, or between buildings on a site, just because the only connection is a drive aisle.
2. Employee work areas. The circulation-path exceptions at 11B-206.2.8 Exceptions 2 and 3 are gone, and the 11B-403.5 clearance exception is rewritten to apply only "in facilities that are not public housing."
3. Fire alarms. The 11B-215.1 exception — the one that lets existing facilities skip visible alarms unless the system is upgraded or replaced — is no longer available (new 11B-233.2.3).
4. Laundry. The 11B-214 counts (one of three, two of more than three) give way: every common-use washer and dryer must be front loading and comply with 11B-611 (new 11B-233.2.4).
5. Additions. Additions to public housing now follow a dedicated path (new 11B-233.2.5): on top of the dwelling-unit requirements under 11B-233.3.3, an addition has to provide an accessible entrance, an accessible route, and accessible toilet and bathing facilities, and at least one of each type of element, space, or common-use area in the existing building must be made accessible.

What doesn't change

The headline unit counts hold. The 5% mobility and 2% communication minimums stay exactly where they are — they just move into 11B-233.3, which the proposal renames from "Public housing facilities" to "Facilities with residential dwelling units," so it now covers all 11B residential facilities, not only public housing. (The companion rewrite of 11B-202.4 Exception 1 simply points residential facilities to 11B-233 — we covered the 20% path-of-travel rule separately.)

It's proposed — not adopted

This is the part to hold onto. These are Final Express Terms that went to the Building Standards Commission at its August 25–27, 2026 meeting as a contested item. As of this writing, no recorded Commission adoption action is confirmed. If it is adopted, it would land in the July 1, 2027 supplement to the 2025 code — the thin intervening cycle we wrote about here.

And it is genuinely contested. CALBO and an industry coalition represented by the California Building Industry Association urged disapproval, arguing DSA can't adopt substantive changes mid-cycle under AB 130 and asking that the item wait for the 2027 triennial cycle. DSA's answer: AB 130 amended Health & Safety Code §18942(2)(F) to permit updates that align with minimum federal accessibility law, and the Deeming Notice requirements — DSA argues — already bind Section 504 recipients whether or not they appear in the building code. Disability Rights California supported the proposal as amended.

What to check now

If you have a five-or-more-unit project backed by a public-entity housing program — think LIHTC, the California Multifamily Housing Program, CDBG, or housing bonds — don't wait for the vote to sketch the worst case. Check the site plan (routes from arrival points), the laundry room (front-loading machines, reach ranges), the fire-alarm scope (visible alarms in common areas), and any staff work areas against this list before CDs are locked. And confirm the final adopted text with your local jurisdiction before you rely on it — this is proposed law, not settled law.

What CrossBeam does with it

CrossBeam reads a plan set against the code that's actually in force today and flags where a pending change like this one would move the line — so a 5+ unit affordable project gets its accessible-route, laundry, alarm, and staff-area questions surfaced while the design is still on paper. When the Commission acts, the new 11B-233.2 is ready to apply the moment your jurisdiction adopts it.