The Division of the State Architect (DSA) has revised the previously issued Interpretation of Regulations (IR) EB-4 (04/09/2021) and reissued IR EB-4: Rehabilitation Required by Cost: 2019 CAC. After publishing the previous IR, we received feedback with concerns about adopting the replacement values used by the Office of Public School Construction (OPSC) and for the community college projects utilizing their own FUSION cost evaluation program. In addition, our implementation of the IR did not take into consideration sufficient advance notice to implement a change in procedure commensurate with the length of time school districts plan an addition or modernization project, thus significantly impacting project scope and submittal to DSA and ultimately delaying completion.

The revisions to IR EB-4 now reflects options for a district to demonstrate building replacement value, including a return to previous procedure in establishing the building replacement value cost comparison.  

The revisions in IR EB-4 are provisional until DSA can establish a per square foot cost for school construction that is in-line with today’s construction market. DSA plans to issue a Request for Proposal to cost estimating entities to provide the requisite value of construction this summer. Once we have this figure established, we will re-issue IR EB-4 using a new per square cost value for the cost comparison, and likely eliminating the options as indicated in IR EB-4.

DSA acknowledges that regulatory reform in determining building replacement value is overdue. In advance of the 2022 Intervening Code Cycle, DSA plans to convene a task force comprised of stakeholders to evaluate and propose changes to the California Administrative Code (CAC) regulations regarding the 50 percent building replacement value which, if adopted, will be effective Fall 2023.

For questions regarding this message, or to express your interest in participating in the task force to explore the CAC regarding the 50 percent building replacement value regulations, please reach out to your local DSA Regional Manager

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