Change of use (kind-of) - not occupancy

Current use of existing building: "B" medical office.
Large waiting room - 965 sq. ft.
Church wants to move in and use waiting room as chapel.
By initial calculation, the occupant load could lend itself to almost 200 people.
Through careful configuration of fixed seating and aisleways, we can get the occupant load down to 48 maintaining the building classification as a "B". The rest of the building is offices.
Question: Would it be unreasonable to require a licensed design professional to provide plans justifying the occupant load using CBC 107.1 "....Where special conditions exist, the building official is authorized to require additional construction documents to be prepared by a registered design professional"? Might this be considered in line with CBC 107.2.3 Means of egress.
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Plans Required to be Designed by an Architect or Engineer
Plans prepared for the following work, except as specifically noted above, shall be deemed as affecting the safety of a building or its occupants and shall be stamped and signed by a registered engineer or architect:
• New buildings, additions to existing buildings
• Projects with interior or exterior structural alterations
• Interior alteration with an occupancy change
• Interior alteration with walls and partitions over 5'9" in height or ceiling work which cover a floor area greater than 3,000 square feet in B, F-1, F-2, S-1, S-2 and M occupancies
• Storage racks over 8' in height
• Remodeling projects with changes to rated corridors, fire rated occupancy separations, or fire walls
• Alteration with changes to exiting requirements
• Hazardous occupancies H-1, H-2, H-3, H-4, and H-5
• Assembly occupancies: A-1, A-2, A-2, A-3, A-4, and A-5
• Tanks and vessels
• Machinery and equipment requiring design per the 2010 California Building Code
• Roof mounted mechanical equipment
• School and day care occupancies E
• Hospital occupancies I-1, I-2, I-2, I-3, and I-4
• Projects with S-1, S-2, S-3, or F-2 occupancies
• Hotel, motel, and apartment occupancies R-1 or R-2
• Projects with mixed occupancies
• Remodeling projects in a high-rise building
• Lateral force resisting systems utilizing poles embedded in the ground
• Cripple walls exceeding 4' in height or adjacent to garage door openings
• Any project deemed by the Chief Building Official to require professional design by a California Registered Engineer or Architect

Plans that Can be Prepared by an Unlicensed Person
Section 5537 and 5538 of the California Business & Professions Code allows unlicensed person to prepare plans, drawings, and specifications for the following types of structures in accordance with the conventional framing requirements of the 2010 California Building Code and tables of limitation for wood frame construction.

• Single family dwelling not more than two stories and basement in height.
• Multiple dwellings containing no more than four dwelling units and not more than two stories and basement in height. Also, maximum of four dwelling units on any lot.
• Garages or other structures appurtenant to single family dwelling or multiple dwellings not more than two stories and basement in height.
• Agricultural and ranch buildings unless the building official deems that an undue risk to the public health, safety, or welfare is involved.
• Nonstructural store fronts, interior alterations or additions, fixtures, cabinet work, furniture, or other appliances or equipment.
Unlicensed persons may not design any building or structure component that changes or affects the safety of any building, including but not limited to, structural or seismic components.

Design Limitations for Professional
The following limitations for professionals are based on the California Health and Safety Code (HSC) and the Business and Professional Code (BPC).
May design any building of any type expect the structural portion of a hospital.
(HSC section 15048 and BPC sections 5500.1 and 6737)
Civil Engineers
May design any building expect hospitals and schools.
(HSC section 39148, BPC sections 5537.5, 6731, 6735, and Education Code section 39148)
Structural Engineers
No limitations. May design any building of any type.
(BPC sections 6637.1, 6731, and 6736)

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