The head count comes before the layout
A senior living site plan settles one number before it draws a building: how many residents will receive care. That number sets the building code occupancy. Under the International Building Code, a facility where more than 16 residents receive custodial care is Group I-1, Condition 1 or 2; one with 6 to 16 such residents is Group R-4; and one with 5 or fewer is Group R-3 [1, 2]. The jump to the institutional group comes at the 17th resident [1, 2]. Washington amends the model code so that licensed assisted living is I-1 Condition 2 regardless of size [3].
Height is the second number. Once the roof is more than 30 ft above grade, the site plan must provide an aerial apparatus road at least 26 ft wide, located 15 to 30 ft from the building, where IFC Appendix D is adopted [4]. On a multi-story assisted living building, that lane is drawn before the drop-off and the parking field.
The preliminary site plan carries this in its site data table: residents and units by care level (independent living, assisted living, memory care), the occupancy group and stories of each building, parking required against provided, open space, and the fire apparatus access drawn to scale. Engineering stays with the client's engineer of record.
Numeric standards that shape the layout
| Standard | Value | Code or record |
|---|---|---|
| Group R-3 | 5 or fewer residents receiving custodial care | IBC 308.2, as summarized [1, 2] |
| Group R-4 | 6 to 16 residents receiving custodial care | IBC 308.2.3 [1] |
| Group I-1, Condition 1 or 2 | More than 16 residents receiving custodial care | IBC 308.2 [1, 2] |
| Washington amendment | Licensed assisted living is I-1 Condition 2 regardless of size | WAC 51-50-0308, Section 308.2.6 [3] |
| Minnesota building rule (2014 version) | More than 16 residents is I-1; 6 to 16 is R-4 | Minn. R. 1305.0308 [7] |
| Aerial fire apparatus road | Required where the highest roof is more than 30 ft above grade plane | IFC D105.1, where adopted [4] |
| Aerial road width | 26 ft minimum, exclusive of shoulders | IFC D105.2 [4] |
| Aerial road position | 15 ft minimum to 30 ft maximum from the building, parallel to one entire side, as approved by the fire code official | IFC D105.3 [4, 8] |
| Overhead lines | No utility lines over the aerial road or between it and the building | IFC D105.4 [4] |
| Base fire access road | 20 ft unobstructed width, 13 ft 6 in vertical clearance | IFC 503.2.1 [9] |
| Fire road at a hydrant | 26 ft minimum width, where Appendix D is locally adopted | IFC D103.1 [10] |
| Parking, Washington | Cities and counties may not require minimum parking for senior housing | ESSB 5184 (2025) [11, 12] |
The aerial road takes one full long face of a multi-story building, and overhead service lines stay off that side [4]. The drop-off, the parking aisles and the courtyards go where the lane leaves room.
Local fire codes amend the model text. San Antonio's 2021 fire code exempts Group R-only buildings of 4 stories or fewer from the aerial road where conditions are met, including roof access by stair and 25 ft lanes throughout [13]; the relief is written for Group R-only buildings, so a building classed I-1 is outside its terms [13]. Seattle's 2018 fire code requires two separate approved access roads for residential projects over 30 dwelling units, a threshold a larger independent living building can cross [14].
Washington's parking law changes the parking field. ESSB 5184 (2025) bars minimum parking for senior housing, residences under 1,200 SF, commercial spaces under 3,000 SF, affordable housing, child care, ground-level commercial in mixed-use buildings and changes of use, and caps what cities may require at 0.5 spaces per multifamily unit [11, 12]. On a Washington senior housing site the parking count is a program decision, not a code minimum [11]. See Washington site plans.
Podium buildings
A senior building over a parking or retail podium follows IBC 510.2 (2024). The section treats the podium and the building above as separate buildings for area, stories and construction type when the horizontal assembly is 3-hour rated, the building below is Type IA, shaft and stair enclosures through it are rated 2 hours, and the building above contains Group A, B, M, R or S occupancies [15]. Group I is not on that list [15], so an assisted living floor classed I-1 above a podium is settled with the architect of record before the massing is fixed. NFPA 13 sprinklers are required below the assembly, and height is measured from grade plane [16], so the podium does not take the building out of the aerial road requirement [15, 16]. The mixed-use rules for the ground floor are on mixed-use site plans.
Assisted living licensing by state
Assisted living is licensed by a state agency, and in several states the license tier follows the resident or bed count. The table shows the states whose agency and primary citation the National Center for Assisted Living (NCAL) summaries confirm. Rows from NCAL's 2023 edition carry that year.
| State | Licensing agency | Primary citation | License | Size tiers | NCAL edition |
|---|---|---|---|---|---|
| Alabama | Dept. of Public Health, Bureau of Health Provider Standards | Ala. Admin. Code ch. 420-5-4; 420-5-20 (specialty care) | Assisted Living Facility; Specialty Care ALF | Family 2 to 3 (legacy only), Group 3 to 16, Congregate 17+; life-safety rules differ by tier (420-5-4-12) | NCAL 2023 [17] |
| Alaska | Dept. of Health, Assisted Living Office | AS 47.33; AS 47.32; 7 AAC 75 | Assisted Living Home | License at 3+ unrelated adults; 6+ residents need a biennial fire inspection | NCAL 2023 [17] |
| Arizona | Dept. of Health Services, Bureau of Residential Facilities Licensing | A.A.C. Title 9, Ch. 10, Art. 8; A.R.S. 36-411 | Assisted Living Facility | Building rules vary by size | NCAL 2023 [17] |
| Arkansas | Dept. of Human Services, Office of Long Term Care | A.C.A. 20-10-1703 | ALF Level I and Level II | License above 3 residents | NCAL 2023 [17] |
| California | Dept. of Social Services, Community Care Licensing | Health and Safety Code Div. 2, Ch. 3.2; 22 CCR 87101 et seq. | RCFE | Added staffing rules at 16+ residents | NCAL 2023 [17] |
| Colorado | Dept. of Public Health and Environment | 6 CCR 1011-1 Ch. 7 | Assisted Living Residence | License at 3+; homes in single-family neighborhoods exempt from some FGI design rules | NCAL 2023 [17] |
| Connecticut | Dept. of Public Health | Regs. Conn. State Agencies 19-13-D105 | Assisted Living Services Agency; Managed Residential Community | The housing component registers but is not licensed | NCAL 2023 [17] |
| Delaware | DHSS, Division of Health Care Quality | 16 Del. Admin. Code 3225 | Assisted Living Facility | Staffing tiers at 4 or fewer, 5 to 24, and 25+ beds | NCAL 2023 [17] |
| Florida | Agency for Health Care Administration | F.S. Ch. 429 Part I; Ch. 408 Part II; F.A.C. 59A-36 | ALF with LNS, ECC and LMH specialty licenses | Not stated | NCAL 2025 [18] |
| Texas | Health and Human Services Commission | Health and Safety Code Ch. 247; 26 TAC Ch. 553 | ALF Type A and Type B | License at 4+ | NCAL 2025 [19] |
NCAL updates selected states quarterly. As of June 2026 it lists updates for AL, AZ, AR, CA, CO, DC, GA, HI, IN, IA, KS, KY, LA, ME, MD, MA, MI, MN, MS, MO, MT and NC, so rows taken from its 2023 edition may be stale for Alabama, Arizona, Arkansas, California and Colorado [20]. In calendar 2025, 18 states plus DC updated their assisted living rules [21]. In Maryland, new regulations take effect July 2026, and 82% of the state's 1,625 licensed programs have 15 or fewer beds, as reported by Property Manager Insider (secondary) [22]. Other states license assisted living under their own statutes and rules; the state agency confirms the tier for a given program before the plan is fixed.
The Alabama tiers show how a license and the building code meet on the site: Group licenses run 3 to 16 residents and Congregate licenses 17 or more, and life-safety rules differ by tier [17], the same 16 and 17 resident line at which the IBC moves from R-4 to I-1 [1, 2].
Memory care, assisted living and independent living
Memory care is usually a specialty license or certification layered on assisted living. Texas licenses assisted living facilities as Type A or Type B, and its Alzheimer's certification requires a Type B license [19]. Florida's assisted living license carries LNS, ECC and LMH specialty licenses, issued by the Agency for Health Care Administration [18]. The site data table lists units by care level so the licensing agency and the building official read the same counts.
Independent living sits outside these care licenses. Whether a senior use counts as residential or institutional for zoning is decided locally, so the zoning district's use table is read before the site is drawn. For the residential side of a senior campus, see multifamily site plans.
Approval path patterns
A senior project runs two tracks at once: the state license and the local land use approval. The local track is where the preliminary plan works hardest.
Murfreesboro, Tennessee is a documented example of a city that asks for a concept plan first. Its due diligence meeting "is required for Master Plans, Preliminary Plats, Site Plans, Annexation and Rezoning requests that are beyond the conceptual stage and where a more formal design is moving forward," and "A dimensioned conceptual site plan is required depicting all proposed and existing structures, vehicle and pedestrian access, parking, landscaping, potential drainage area(s) and a site data table" [23]. A due diligence meeting must be held before a pre-application meeting can be requested, and at the pre-application meeting plans should be "90-95% complete" [23].
Tennessee's board rule for architects and engineers requires working or partially completed plans, and any drawings that are not construction documents, to carry a designation such as preliminary, not for construction, for review only or draft (Rule 0120-02-.08(9)); the registrant's seal goes on all original sheets of any set of working drawings or plans (Rule 0120-02-.08(2)(a)) [24]. The land surveyors' rule lets working drawings and preliminary documents go without seal and signature when they carry a statement to that effect in large bold letters (Rule 0820-04-.08(2)) [25].
| Stage | What the city asks for (Murfreesboro example) | Seal | Source |
|---|---|---|---|
| Due diligence meeting | A dimensioned conceptual site plan with structures, access, parking, landscaping, potential drainage areas and a site data table | None for drawings designated preliminary under Tennessee board rules | [23, 24] |
| Pre-application meeting | Plans 90-95% complete | Not stated | [23] |
| Site plan approval | Drainage retention or detention areas with engineered stamped calculations | Engineer | [26] |
| Building permit | Construction documents | Registrant's seal on all original sheets of working drawings or plans | [24] |
The unsealed preliminary plan belongs at the concept meeting, in the lender package and in the capital raise. The engineer and architect of record take it as the program and layout brief and draw the sealed set under their own responsible charge. For the general picture, see preliminary vs final site plans, do I need an architect for a site plan and where unsealed site plans are accepted. The state layer for Tennessee is on Tennessee site plans, and Murfreesboro sits in the Nashville metro.
What the preliminary plan carries, and what the engineer of record adds
| Item | Preliminary site plan | Engineer or architect of record |
|---|---|---|
| Residents by care level and the occupancy group | Stated in the site data table against the IBC thresholds [1, 2] | Architect confirms occupancy and construction type |
| Aerial fire apparatus road | Drawn along one full side, 15 to 30 ft off the building [4] | Fire access plan approved by the fire code official [8] |
| Podium separation | Massing and parking count | 3-hour horizontal assembly over a Type IA base under IBC 510.2 [15] |
| Drainage | Area reserved on the plan | Engineered stamped calculations at site plan [26] |
| Building plans | No | Sealed on all original sheets [24] |
The general split is in who prepares a site plan.
Supply and demand, 2026
NIC MAP put senior housing occupancy at 89.5% in Q1 2026 [5]. Year-over-year inventory growth hit a record low that quarter: 0.4% for assisted living and 0.3% for independent living across the 31 NIC MAP Primary Markets [27]. Units under construction fell under 24,000 in 2Q 2026, the lowest since mid-2012 [6]. NIC MAP's 2026 Senior Housing Market Outlook revised its forecast of the units needed to "approximately 576,000 units by 2030 and... more than 1 million by 2035"; these are projections, not measured figures [28].
Related pages
For the views boards ask to see on a multi-story residential building, see apartment rendering. The studio's article four acres and a license covers the deal side, and hotel site plans show the same aerial fire lane logic on a 4-story building.
Frequently asked questions
When does assisted living become institutional under the building code?
Who licenses assisted living in Texas?
The Health and Human Services Commission, under Health and Safety Code Ch. 247 and 26 TAC Ch. 553. Facilities are licensed as ALF Type A or Type B, a license is required at 4 or more residents, and Alzheimer's certification requires a Type B license [19].
Who licenses assisted living in Florida?
The Agency for Health Care Administration, under F.S. Ch. 429 Part I, Ch. 408 Part II and F.A.C. 59A-36. The ALF license carries LNS, ECC and LMH specialty licenses [18].
Does senior housing need parking in Washington?
How wide is the fire lane and where does it go?
Can I take an unsealed concept plan to the city?
At the concept stage, often yes. Murfreesboro, Tennessee asks for a "dimensioned conceptual site plan" with a site data table at its due diligence meeting [23], and Tennessee's board rule requires drawings that are not construction documents to be designated preliminary, not for construction, for review only or draft [24]. At site plan, Murfreesboro wants drainage areas with "engineered stamped calculations" [26].
Is new senior housing being built?
Little. Under 24,000 units were under construction in 2Q 2026, the lowest since mid-2012 [6]. In Q1 2026, inventory grew 0.4% for assisted living and 0.3% for independent living year over year, a record low [27]. NIC MAP's 2026 outlook forecasts a need for approximately 576,000 units by 2030, a projection rather than a measured figure [28].
Sources
- 1)IBC Section 308.2, Institutional Group I-1 (International Code Council text via UpCodes), UpCodes. Accessed 2026-10-10.
- 2)Occupancy Classification: Chapter 3 of the IBC, Brief Explanation, Blount County, Tennessee. Accessed 2026-10-10.
- 3)WAC 51-50-0308, Section 308, Institutional Group I, Washington State Legislature. Accessed 2026-10-10.
- 4)Site Design Requirements for Fire Department Apparatus (IFC Appendix D as adopted), City of Bismarck, ND. Accessed 2026-10-10.
- 5)Senior Living Occupancy Grows Amid Construction Slowdown, Limiting Options for Older Adults, NIC. Accessed 2026-10-10.
- 6)Senior Housing Construction Trends Fall to a 2012 Low, NIC MAP. Accessed 2026-10-10.
- 7)Minn. R. 1305.0308 (2014 version), Minnesota Office of the Revisor of Statutes. Accessed 2026-10-10.
- 8)Aerial Fire Apparatus Access Roads Proximity to Building (practitioner forum, secondary), The Building Code Forum. Accessed 2026-10-10.
- 9)The Ins and Outs of Fire Department Access, TERPconsulting. Accessed 2026-10-10.
- 10)2003 International Fire Code, Appendix D, Fire Apparatus Access Roads, International Code Council. Accessed 2026-10-10.
- 11)Washington State Growth Management Program, June 2025: New TOD and parking laws (Washington Department of Commerce), Puget Sound Regional Council. Accessed 2026-10-10.
- 12)ESSB 5184, as passed by the Legislature (5184-S.PL), Washington State Legislature. Accessed 2026-10-10.
- 13)San Antonio Fire Code 2021, Appendix D, Fire Apparatus Access Roads (City of San Antonio, via UpCodes), UpCodes. Accessed 2026-10-10.
- 14)Seattle Fire Code 2018, Appendix D, City of Seattle, Department of Construction and Inspections. Accessed 2026-10-10.
- 15)2024 International Building Code, Section 510.2, Horizontal building separation allowance, International Code Council. Accessed 2026-10-10.
- 16)Podium Construction and Fire Protection (August 30, 2023), National Fire Sprinkler Association. Accessed 2026-10-10.
- 17)2023 Assisted Living State Regulatory Review, National Center for Assisted Living (AHCA/NCAL). Accessed 2026-10-10.
- 18)Florida: State Assisted Living Regulation Summary, National Center for Assisted Living (AHCA/NCAL). Accessed 2026-10-10.
- 19)Texas: State Assisted Living Regulation Summary, National Center for Assisted Living (AHCA/NCAL). Accessed 2026-10-10.
- 20)State Regulatory Resources, National Center for Assisted Living (AHCA/NCAL). Accessed 2026-10-10.
- 21)NCAL Report: States Continue Modifying Assisted Living Regulations, American Health Care Association and National Center for Assisted Living. Accessed 2026-10-10.
- 22)New Regulations Are Impacting Assisted Living Facilities Nationwide (secondary), Property Manager Insider. Accessed 2026-10-10.
- 23)Current Planning, City of Murfreesboro Planning Department. Accessed 2026-10-09.
- 24)Tenn. Comp. R. & Regs. 0120-02-.08, Seals (Tennessee Board of Architectural and Engineering Examiners rule, via Cornell LII), Cornell Legal Information Institute. Accessed 2026-10-10.
- 25)Tenn. Comp. R. & Regs. 0820-04-.08, Seals (Tennessee Board of Examiners for Land Surveyors rule, via Cornell LII), Cornell Legal Information Institute. Accessed 2026-10-10.
- 26)Planning Commission Site Plan Review Checklist, Appendix A:44 (updated February 12, 2026), City of Murfreesboro. Accessed 2026-10-09.
- 27)Senior Housing Occupancy Climbs to 89.5% as Record Demand Meets Record-Low New Supply in First Quarter 2026, NIC. Accessed 2026-10-10.
- 28)2026 Senior Housing Market Outlook (press release), NIC MAP. Accessed 2026-10-10.