# Constraints Register

This register separates hard constraints from assumptions. Constraints are externally imposed boundaries that the architecture operates within. They cannot be changed by the project; they are designed around.

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| ID | Constraint | Category | Source | Impact on Design | Mitigation |
|:---|:-----------|:---------|:-------|:-----------------|:-----------|
| C-01 | Exclusionary Rule for Specialized Facilities | Federal | 42 CFR §435.1010; Medicaid statute | Facilities with > 16 beds providing clinical treatment cannot bill Medicaid | Tower design classifies as residential supportive housing, not clinical facility; services delivered via external managed care contracts |
| C-02 | Medicaid Room-and-Board Exclusion | Federal | Social Security Act §1905(a); Medicaid statute | Federal matching funds cannot pay for physical rent or real estate ("room and board") | Philanthropic/venture capital (the $36.9M CapEx) must fund the physical asset while CalAIM exclusively funds clinical and ECM services |
| C-03 | AB 2011 by-right authorization requires prevailing wage | State | California AB 2011, amended by AB 2243 | All construction workers receive prevailing wage; healthcare benefits required for ≥ 50 units | Construction budget includes prevailing wage premium; apprenticeship program participation required. NOTE: AB 2011 (Gov. Code §§65912.100–140) contains two distinct pathways: Article 2 (§65912.110 et seq., general commercial) and Article 3 (§65912.120 et seq., corridor-specific). Which pathway, if either, applies to full high-rise office-tower adaptive reuse is a working assumption pending outside legal review, not yet confirmed against the bill text by counsel. SB 6 (Middle Class Housing Act of 2022) is a separate, unevaluated alternative pathway (see RK-15). |
| C-04 | LPS Act (WIC §5150/§5350) governs involuntary hold authority | State | California Welfare and Institutions Code | Compelled care requires documented grave disability or imminent danger; 72-hour hold limit (§5150); conservatorship requires court petition (§5350) | Four-condition conjunctive threshold; independent neuropsychiatric evaluation; mandatory 3 voluntary offer cycles |
| C-05 | ADA compliance for all residential units | Federal | Americans with Disabilities Act | All units meet accessibility standards; reasonable accommodations required | STC 65 acoustic parameter positioned as ADA reasonable accommodation for PTSD sensory processing |
| C-06 | California seismic code for commercial conversion | State | California Building Code | Structural retrofit required for residential occupancy classification | Seismic assessment included in site feasibility; retrofit cost factored into conversion budget |
| C-07 | Fire suppression and egress requirements | State/Local | California Fire Code | Residential occupancy requires upgraded fire suppression, emergency lighting, and egress paths | Fire suppression upgrade included in conversion scope; ground floor commons designed for dual egress |
| C-08 | CEQA environmental review (unless exempt) | State | California Environmental Quality Act | Discretionary projects require environmental impact review | AB 2011 provides statutory CEQA exemption for qualifying by-right projects |
| C-09 | Local zoning for commercial-to-residential conversion | Local | Municipal zoning code | Conversion requires site zoned for office, retail, or parking as principally permitted use | Site selection limited to qualifying zones; AB 2011 overrides local discretionary review. NOTE: AB 2011 (Gov. Code §§65912.100–140) contains two distinct pathways: Article 2 (§65912.110 et seq., general commercial) and Article 3 (§65912.120 et seq., corridor-specific). Which pathway, if either, applies to full high-rise office-tower adaptive reuse is a working assumption pending outside legal review, not yet confirmed against the bill text by counsel. SB 6 (Middle Class Housing Act of 2022) is a separate, unevaluated alternative pathway (see RK-15). |
| C-10 | Federal waiver renewal cycle (Section 1115) | Federal | CMS waiver schedule | CalAIM waiver scheduled for renewal December 2026; continuity of fiscal model depends on renewal | Monitor renewal process; develop contingency fiscal model for post-waiver scenario |
| C-11 | Fair Housing Act compliance | Federal | 42 U.S.C. §§3601–3619 | Cannot discriminate in resident selection on protected characteristics | Intake criteria based exclusively on clinical acuity and sequential priority; documented compliance protocol |
| C-12 | Dunbar Pod community ceiling of 150 individuals (staff + residents combined) | Biological | Dunbar (1992); neocortex social processing capability | Maximum 116 residents per pod after 34 FTE staff allocation; exceeding 150 total collapses community into institution | Non-negotiable; no mitigation; ceiling is a biological constant |
| C-13 | Minimum physical plant of 85,000 gross square feet per single Dunbar Pod | Engineering | WP6 spatial derivation; program space + back-of-house infrastructure | Building footprint cannot shrink below 85,000 sq ft without eliminating pipeline-critical infrastructure (kitchen, laundry, mechanical, clinical) | No mitigation; constraint defines the structural floor of the specification |
| C-14 | Maximum three Dunbar Pods per independent vertical pipeline | Architectural | WP6 multi-pod scaling analysis | Beyond three pods, preventing resident cross-contamination in shared circulation infrastructure (elevators, airlocks) becomes impossible; mega-towers require architectural segregation into independent three-pod sectors | Mega-tower deployments sever superstructure into independent sectors with separate airlocks, elevator banks, and street entrances |
| C-15 | HIPAA Privacy Rule | Federal | 45 CFR Part 160 and Part 164 | Clinical identity and medical status cannot be indiscriminately broadcast or linked to raw physical occupancy data without consent | Zero-Knowledge Billing Firewall cryptographically isolates clinical identity from physical telemetry; bifurcated consent doctrine protects opt-outs |
| C-16 | AB 2011 categorical siting exclusion buffers | State | Government Code §65912.123(g) and adjacent subsections | No AB 2011 residential unit may be sited within 500 feet of a freeway or within 3,200 feet of an active oil- or gas-extraction facility | For a single-footprint tower conversion, this buffer applies to the entire building rather than a portion of it, since a vertical envelope cannot horizontally reposition units to escape a buffer radius the way a spread low-rise site can; any named candidate site, including One California Plaza, must be confirmed clear of both buffers as a precondition of site selection, not assumed clear |