REPORT TO THE BUILDING STANDARDS APPEALS BOARD
October 20, 2026
FROM: ASHLEY ATKINSON, AICP, Assistant Director
Planning and Development Department
BY: VERONICA CORTEZ, Management Analyst II
Planning and Development Department
SUBJECT
Title
Appeal of Certified Building Official's Determination - Alternate Means and Methods for Waters Edge Apartments
Body
RECOMMENDATION
Staff recommends upholding the Certified Building Official’s denial of the proposed Request for Alternate Materials, Design or Methods of Construction for Waters Edge Apartments at 330 S Clovis Ave.
EXECUTIVE SUMMARY
On August 3, 2026, the applicant submitted an Alternate Means and Methods Request seeking approval to downsize an 8-inch sanitary sewer line to 6 inches as part of the project’s revised design. The Certified Building Official denied the request on September 16, 2026.
BACKGROUND
The applicant proposes revising the sewer design to use two separate 6-inch sanitary sewer lines at a 1% slope. The proposal includes installation of two separate 6-inch sanitary sewer pipes at a 1% slope receiving 557 and 612 drainage fixture units (DFU), respectively, from the associated buildings on the project site. The change in pipe sizing requires approval under the Alternate Means and Methods Request. The proposal includes installation of two separate 6-inch sanitary sewer pipes at a 1% slope receiving 557 and 612 drainage fixture units (DFU), respectively.
ANALYSIS
Obstruction and Flow Reduction
Staff determined that reducing the pipe size from 8 inches to 6 inches creates an obstruction that may significantly reduce flow capacity and increase the likelihood of debris accumulation, blockages, and sanitary sewer overflows.
Code and Standard Noncompliance
The proposed alternate design conflicts with multiple governing codes and standards, including:
1. California Plumbing Code / Uniform Plumbing Code:
Prohibits fittings or installations that obstruct or retard flow beyond normal friction resistance.
2. International Plumbing Code:
Prohibits reduction of drainage piping size in the direction of flow.
3. City of Fresno Standard Specification 17-8.4:
Requires maintaining the larger diameter where pipes enter and leave manholes and mandates smooth directional flow transitions.
DFU Capacity Exceeded
Under CPC Table 703.2 (footnote 5), the maximum allowable DFU load for a 6-inch pipe at 1% slope is 576 DFU.
• Pipe 1: 557 DFU (within limit but leaves no operational margin)
• Pipe 2: 612 DFU (exceeds maximum allowable load)
Hydraulic Performance Deficiency
Using CPC §702.3 and IPC §709.3 conversion methods, the design loads convert to 278.5 GPM and 306 GPM. Manning’s Formula (n = 0.013; slope = 1%) shows that a 6-inch pipe reaches full capacity at approximately 251 GPM, below both projected flows.
Conclusion
Based on review of code requirements and the above analysis, staff finds and the Building Official Concurs that:
1. The proposed downsizing creates operational and safety risks due to obstruction and inadequate flow.
2. The request is inconsistent with State, national, and municipal plumbing regulations.
3. The proposed system exceeds the maximum permitted DFU and hydraulic capacity requirements.
4. The alternate method does not provide equivalent performance, safety, or life-health protection as required by the adopted codes.
RECOMMENDATION
Staff recommends that the board review the available evidence, hold the hearing, and uphold the Certified Building Official’s denial of the proposed Request for Alternate Materials, Design or Methods of Construction for Waters Edge Apartments at 330 S Clovis Ave., as the proposed design does not meet the minimum standards of performance, code compliance, and public health protection required for approval.
ENVIRONMENTAL FINDINGS
This is not a project for the purposes of the California Environmental Quality Act.
LOCAL PREFERENCE
N/A
FISCAL IMPACT
N/A
ATTACHMENTS
Exhibit A - Building Appeal Form
Exhibit B - Request for Alternative Materials, Design and Methods of Construction
Exhibit C - California Plumbing Code 2025 - Chapter 3 General Regulations
Exhibit D - California Plumbing Code 2025 - Chapter 7 Sanitary Drainage