Ask your local building official.   Were the SFD's subdivided or are
they still townhouses that are now rented out?   Seems to me that if you
haven't changed the use and occupancy, then it doesn't matter whether
the tenants own the dwelling or not.

Steve Leyton
Protection Design & Consulting
San Diego, CA




-----Original Message-----
From: [email protected]
[mailto:[email protected]] On Behalf Of Mike
Cabral
Sent: Wednesday, November 04, 2009 3:52 PM
To: [email protected]
Subject: Townhouse or Apartment Building

Hypothetical Question. . .  A builder constructs what was intended to be
3 story townhouses. 13D is applied under  2010 13D Section  3.3.10. The
units don't sell and are rented out. If you rent a townhouse complex is
it an apartment building? Would 13R system be required?

Mike Cabral
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