What are the Key changes in Chapter 11B Accessibility to Public Buildings & Public Housing of CBC 2025?

Chapter 11B gets a lot of surgical changes rather than giant new concepts. Main themes:

1. Clearer separation between transient lodging vs. housing at places of education
2. Sharper scoping for public housing units with mobility/adaptable features
3. Clarified EV charging station scoping
4. Improved clarity on blended transitions (detectable warnings), bathrooms, personal lift spaces, vanity counters, doors, and clear floor spaces at dining surfaces

Essentially, the 2025 code is cleaning up edge cases that were confusing designers and plan reviewers in the 2022 text.

2.1. Scoping & General Provisions

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2.2. EV Charging Stations & Public Housing

EVCS & Public Housing Scoping

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2.3. Guest Rooms, Bathing Rooms, and Lodging-Specific Requirements

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2.4. Dwelling Units with Mobility/Adaptable Features (Public Housing Context)

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2.5. Blended Transitions & Detectable Warnings

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2.6. Dining Surfaces & Clear Floor Spaces

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Expert Commentary — Why These Accessibility Changes Matter

1. Public Housing & 11B

With 11A stepping back from public housing, public housing is now squarely a Chapter 11B world:

• Tighter alignment with federal ADA
• More scrutiny from enforcement agencies
• Less ambiguity for designers juggling dual requirements

2. Lodging vs. Education Housing

By separating transient lodging from housing at places of education, the code acknowledges that:

• A dorm is not a hotel
• Some items (e.g., personal lift device floor clearances) make sense in hotels, but not in dorms
• Others (vanity counter space) should apply to both

3. EV Charging Stations (EVCS)

Clarified EVCS rules are increasingly important:

• EVCS scoping is a frequent point of confusion
• These clarifications are exactly the type of “micro-interpretation” that junior staff often miss, and reviewers catch
  
  

4. Showers, Bathrooms & Adaptable Units

The changes around 11B-809.x are the bread-and-butter of accessibility conflicts:

• Shower size and clearance
• Doors in adaptable units
• Bathroom layout semantics

5. Detectable Warnings & Dining Routes

Two super practical, often-misinterpreted topics got clearer:

• Blended transitions (ramps to crosswalks, shared plaza edges)
• Dining surface clear space vs. route

These are exactly the kinds of issues that show up in punchlists and late-stage field conflicts.

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FAQs

1. What are the biggest accessibility changes in CBC 2025 Chapter 11B?

CBC 2025 refines and clarifies scoping for public housing, transient lodging, housing at places of education, EV charging stations, bathrooms, showers, door clearances, blended transitions, and clear floor spaces. Most changes resolve long-standing ambiguities rather than introduce new concepts.

2. Why did the CBC separate transient lodging from housing at places of education?

Because hotels and student housing serve fundamentally different use patterns.
The 2025 update removes “dormitories” from transient lodging provisions and directs student housing to the correct subsections, preventing misapplication of hotel-specific requirements (e.g., personal lift clearances).

3. How did CBC 2025 update EV charging station (EVCS) scoping?

Section 11B-228.3.2 clarifies exceptions for EVCS counts and distribution.
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The wording is rewritten for easier enforcement, reducing misinterpretation about:

• Minimum number of accessible EVCS
  
• Required types (standard/van-accessible)
  
• Distribution across parking facilities
  
  

4. What changed for public housing accessibility?

Multiple sections direct designers toward §11B-809 for mobility and adaptable features.
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Highlights include:

• Corrected references for site impracticality
  
• Clarified scoping for adaptable units
  
• Revised door, bathroom, and shower requirements
  

These changes better align public housing with ADA and avoid conflicting interpretations.

5. What is the significance of the updates in §11B-809 for adaptable and mobility units?

These are some of the most impactful revisions in the chapter.
CBC 2025 clarifies:

• Interior door requirements
  
• Bathroom definitions and layout
  
• Shower size, configuration, and clearances
  
• Terminology (e.g., removing “multifamily unit”)
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These changes create more predictable layouts for public housing and reduce plan-check disputes.

6. How do the new rules affect bathrooms and bathing facilities?

Several subtle but important updates:

• Exception language reorganized (e.g., §11B-603.6)
  
• “Bathroom” clarified as a defined term
  
• Shower requirements spelled out directly for adaptable units
  

These revisions eliminate conflicting cross-references and make bathroom design easier to document and inspect.

7. Did shower requirements change in CBC 2025?

Yes.

In §11B-809.10.6.1 and §11B-809.10.6.3:

• Shower size requirements are now explicit
  
• Clear floor space is increased
  
• A new figure clarifies the required location relative to the control wall
  

This gives architects more certainty when laying out small residential units.

8. What changed for interior door clearances in residential units with adaptable features?

CBC 2025 revises the requirements and relocates previous exceptions into a new §11B-809.8.3.1, making the rules more organized.
This is especially important for small units where every inch of swing, clearance, and maneuvering space matters.

9. How does CBC 2025 handle blended transitions and detectable warnings?

§11B-705.1.2.5 clarifies:

• When detectable warnings are needed
  
• How width and depth vary depending on pedestrian travel direction
  

This reduces disputes during plan check and field inspection for curb ramps, plazas, and mixed-use streetscapes.

10. What is the new rule about clear floor space at dining surfaces?

CBC 2025 explicitly prohibits overlapping clear floor space at dining surfaces with the accessible route (§11B-902.2).
This means circulation aisles cannot double as the knee/toe clearance zone for accessible seating.

11. How do these changes affect student housing projects?

CBC 2025 clarifies which 11B sections apply to:

• Transient lodging
  
• Housing at places of education
  

This prevents hotels-style requirements (e.g., lift device maneuvering spaces) from being incorrectly imposed on dormitories.

12. What should designers know about “site impracticality” updates?

Several corrected references and clarifications in 11B-233.3.1.2.6.x tighten when site impracticality can be claimed.

This affects:

• Accessible routes across steep sites
  
• Distribution of accessible dwelling units
  
• Public housing projects with challenging grades
  
  

13. Does CBC 2025 make public housing more aligned with ADA?

Yes. The revisions emphasize mobility features, adaptable features, and correct scoping—creating clearer alignment with federal ADA requirements and reducing legal exposure for jurisdictions and owners.

14. Are vanity and countertop requirements different under CBC 2025?

Yes.
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§11B-806.2.4.1 now makes explicit that vanity counters apply to:

• Transient lodging bathrooms
  
• Housing at places of education bathrooms
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This removes ambiguity that previously caused inconsistent plan-check interpretations.

15. What should architects review first when applying Chapter 11B updates?

Start with:

1. Transient lodging vs. education housing distinctions
   
2. EVCS scoping and exceptions
   
3. 11B-809 revised bathroom/shower and door requirements
   
4. Detectable warning rules at blended transitions
   
5. Clear floor space rules for dining surfaces
   
   

These areas drive the most plan-check comments and field conflicts.

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References

1. ‍2022 California Building Code, Title 24, Part 2 (Volumes 1 & 2) with July 2024 Supplement updated

2. 2025 California Building Code Volumes 1 and 2, Title 24, Part 2

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