18.3 Construction Changes: Change Orders (CO), CCDs, ASIs & DSA Category A/B CCDs

California Supplemental Examination CSE

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1 Chapter 1: California Architects Practice Act & Professional Practice

1.1 Licensing, Board Authority, and Unlicensed Practice Exceptions 1.2 Mandatory Written Contracts & Required Provisions 1.3 Architect's Stamp, Signature, and Professional Liability

2 Chapter 2: Professional Conduct, Ethics & Business Entities

2.1 Rules of Professional Conduct & Disciplinary Grounds 2.2 Permissible Business Entities, Firm Names, and Filing Requirements 2.3 Copyright, Instruments of Service & Ownership of Architectural Documents

3 Chapter 3: Contractual Roles, Scope & Consultant Agreements

3.1 Standard Owner-Architect Agreements (AIA B101 / B102) & California Practice Realities 3.2 Consultant Selection, Prime-Consultant Agreements & Liability Flow-Down (AIA C401) 3.3 Project Delivery Methods & Impact of Project Funding Sources

4 Chapter 4: Risk Management, Dispute Resolution & Project Planning

4.1 Professional Standard of Care & Managing Contractual Risk and Liability 4.2 Dispute Resolution in California Practice: Mediation, Arbitration, and Litigation 4.3 Project Scheduling, Budgeting Assumptions, and Milestone Approvals

5 Chapter 5: Site Feasibility, Schematic Design & Discretionary Approvals

5.1 Site Feasibility Studies, Existing-Conditions Due Diligence & Project Impacts 5.2 Programming, Schematic Design Development & Stakeholder Engagement 5.3 Local Land-Use Control: General Plans, Zoning, Specific Plans & Local Ordinances 5.4 The Discretionary Approval Process: Use Permits, Variances, Design Review & Hearings 5.5 Entitlement Exhibits, Conditions of Approval & Leading the Approval Team

6 Chapter 6: Environmental Review & CEQA Compliance

6.1 CEQA Regulatory Framework: Lead, Responsible, and Trustee Agencies 6.2 CEQA Process: Statutory & Categorical Exemptions, Initial Studies, and (Mitigated) Negative Declarations 6.3 Environmental Impact Reports (EIR) & Official Filings (NOP, NOC, NOD, NOE)

7 Chapter 7: California Coastal Act & Specialized Regional Regulations

7.1 California Coastal Commission & Coastal Development Permits (CDP) 7.2 Local Coastal Programs (LCP), Coastal Zone Boundaries, and Appeals 7.3 Clean Air Act (CARB/AQMDs) & Clean Water Regulations (Porter-Cologne, RWQCB & SWPPP)

8 Chapter 8: State Agency Jurisdictions: DSA, HCAI & Essential Services

8.1 Division of the State Architect (DSA): Field Act & Public K-12/Community College Oversight 8.2 Department of Health Care Access and Information (HCAI): Alfred E. Alquist Act & Healthcare Facility Classification 8.3 Essential Services Buildings Seismic Safety Act (ESBSSA) & California Historical Building Code (CHBC)

9 Chapter 9: California Building Code (CBC Title 24 Part 2) Core Architecture Provisions

9.1 Occupancy Classifications, Building Heights, and Allowable Floor Areas (CBC Chapters 3 & 5) 9.2 Fire and Smoke Protection Features, Fire Barriers, and Fire-Resistance Ratings (CBC Chapter 7) 9.3 Means of Egress, Occupant Load Calculations, and Exit Separation (CBC Chapter 10) 9.4 California Health and Safety Code: Building Standards Law, State Housing Law & Health Mandates

10 Chapter 10: Accessibility Requirements: Title 24 Chapter 11B & ADA

10.1 California Accessibility Framework: CBC Chapter 11B vs Federal ADA Standards 10.2 Accessible Routes, Entrances, Parking, and Site Arrival Points 10.3 Accessible Restrooms, Signage, Scoping, and Path of Travel Alteration Thresholds

11 Chapter 11: California Site Conditions & Natural Hazards

11.1 Seismic Hazard Mapping: Alquist-Priolo Earthquake Fault Zoning Act & Liquefaction 11.2 Wildland-Urban Interface (WUI) & Fire Hazard Severity Zones (CBC Chapter 7A & CFC Part 9) 11.3 Flood Hazard Zones (FEMA/DWR) & California Wind Exposure Categories

12 Chapter 12: Energy Efficiency: California Energy Code (Title 24 Part 6)

12.1 Energy Code Compliance Approaches: Prescriptive vs Performance & Time Dependent Valuation (TDV) 12.2 Mandatory Energy Measures: Envelope, HVAC, Lighting, Solar PV & Energy Storage Systems

13 Chapter 13: Sustainability (CALGreen) & Systems Integration

13.1 CALGreen (Title 24 Part 11) Mandatory Nonresidential & Residential Green Building Measures 13.2 Life-Cycle Cost Analysis (LCCA) & Value Engineering in California Practice 13.3 Building Systems Integration: MEP Coordination, Materials Evaluation & Acoustic Control

14 Chapter 14: Construction Document Requirements & Regulatory Coordination

14.1 CD Content, Detailing & Inter-Disciplinary Coordination for Agency Approval and Bidding 14.2 Authority Having Jurisdiction (AHJ) Hierarchy, Local Amendments & Local Finding Requirements 14.3 Reconciling Conflicting Codes, Standards, and Regulatory Mandates

15 Chapter 15: Plan Check & Permitting Processes

15.1 Permitting Procedures, Plan Check Review, Agency Comment Inquiries & Approval Pathways 15.2 Phased Permitting, Deferred Approvals, Encroachment Permits & Public Right-of-Way Coordination

16 Chapter 16: California Public Contract Code & Bidding Procedures

16.1 Public Works Bidding, Competitive Bidding Thresholds & Responsive vs Responsible Bidders 16.2 Subletting and Subcontracting Fair Practices Act & Subcontractor Listing Rules (PCC §§ 4100–4114) 16.3 California Prevailing Wage Requirements, DIR Registration & Certified Payroll Records

17 Chapter 17: California Mechanics Lien Law & Payment Remedies

17.1 20-Day Preliminary Notice Requirements & Timing (Civil Code § 8200) 17.2 Mechanics Liens, Recording Deadlines & Impact of Notice of Completion (Civil Code §§ 8400–8494) 17.3 Stop Payment Notices, Payment Bonds & Design Professional Liens (Civil Code §§ 8300–8319, 9350–9566)

18 Chapter 18: Construction Administration: Pre-Construction, Submittals, Changes & Field Observation

18.1 Pre-Construction & Pre-Installation Meetings and the Construction Manager's Impact on Services 18.2 Shop Drawings, Submittals & Architect's Deferred Submittal Review and Stamp 18.3 Construction Changes: Change Orders (CO), CCDs, ASIs & DSA Category A/B CCDs 18.4 Periodic Site Observations, Field Reports & the Means-and-Methods Boundary

19 Chapter 19: Inspection, Close-Out & Post-Construction Services

19.1 Special Inspections, Testing (CBC Chapter 17) & DSA/HCAI Continuous Field Inspection 19.2 Project Close-Out, Payment Applications (G702/G703), Retainage & California Warranty/Defect Limitations (CCP §§ 337.1 & 337.15) 19.3 Post-Construction Services, Record Documents & the Warranty Period 19.4 Construction Industry Standards, Detailing & Referenced Standards

18.3 Construction Changes: Change Orders (CO), CCDs, ASIs & DSA Category A/B CCDs

Key Takeaways Explain This Topic AI

AIA Document A201 Article 7 establishes three primary contractual mechanisms for construction changes: Architect's Supplemental Instructions (ASI / G710) for minor changes without cost/time impact; Change Orders (CO / G701) as bilateral agreements adjusting work, cost, and time; and Construction Change Directives (CCD / G714) as unilateral orders directing work when cost/time is not yet agreed.

A Change Order (AIA G701) requires tripartite agreement and signatures of the Owner, Architect, and Contractor, formalizing agreed adjustments to the Contract Sum and Contract Time.

A Construction Change Directive (AIA G714) is signed by the Owner and Architect only, commanding the contractor to proceed immediately with urgent work; costs are determined by unit prices, lump sum, or actual documented time and material expenses plus overhead and profit under A201 § 7.3.7.

Under California Code of Regulations (CCR) Title 24 Part 1 Chapter 4 and DSA IR A-6, changes on public K-12 and community college projects require a Construction Change Document (Form DSA 140) categorized as either Category A or Category B.

Category A CCDs affect Structural Safety (SS), Fire and Life Safety (FLS), or Accessibility (Access) and MUST receive formal DSA plan check approval BEFORE work commences in the field; Category B CCDs do not affect SS, FLS, or Access and do not require DSA pre-approval prior to construction.

Last updated: September 2026

Construction Changes: Change Orders (CO), CCDs, ASIs & DSA Category A/B CCDs

During the construction phase of an architectural project, unforeseen site conditions, regulatory interpretations, owner-requested modifications, design clarifications, or material supply chain disruptions inevitably necessitate changes to the work. In architectural practice, managing these changes demands rigorous adherence to contractual protocols and state regulatory mandates. Under AIA Document A201-2017 Article 7 , construction changes are executed through three distinct contractual instruments: Architect's Supplemental Instructions (ASI) , Change Orders (CO) , and Construction Change Directives (CCD) . In California public school and community college construction under the jurisdiction of the Division of the State Architect (DSA) , changes are governed by statutory procedures under the Field Act (CCR Title 24, Part 1, Chapter 4 and DSA Interpretation of Regulations IR A-6) requiring specialized Construction Change Documents (Form DSA 140) classified into Category A and Category B . Candidates preparing for the California Supplemental Examination (CSE) must understand the precise procedural differences, required signatures, cost determination rules, and regulatory pre-approval mandates for each change mechanism.

The Three AIA Contractual Change Instruments (AIA A201 Article 7)

AIA Document A201-2017 Article 7 governs changes in the work. It establishes that changes may be accomplished after execution of the contract, and without invalidating the contract, by Change Order, Construction Change Directive, or order for a minor change in the work.

1. Architect's Supplemental Instructions (ASI / AIA Document G710)

Under AIA A201 Section 7.4, the architect possesses sole authority to order minor changes in the work that:

Are consistent with the intent of the Contract Documents; and
Do not involve an adjustment in the Contract Sum; and

Do not involve an extension of the Contract Time.

Such changes are issued using AIA Document G710 (Architect's Supplemental Instructions) . The ASI is an administrative order signed solely by the architect and is binding on both the owner and contractor. The contractor must execute the work promptly.

Contractor Notice Rule: If the contractor believes that the instructions issued in an ASI will cause an increase in the Contract Sum or Contract Time, the contractor must not proceed with the work and must promptly give written notice to the architect within the timeframe specified in the contract (typically 14 to 21 days pursuant to A201 Article 15) before executing the work. If the contractor performs the work without giving timely written notice, the contractor waives any right to claim additional compensation or time.

2. Change Order (CO / AIA Document G701)

Under AIA A201 Section 7.2, a Change Order is a written instrument prepared by the architect and signed by the Owner, Contractor, and Architect stating their mutual agreement upon all of the following:

The change in the Work;
The amount of the adjustment, if any, in the Contract Sum; and

The extent of the adjustment, if any, in the Contract Time.

A Change Order is a bilateral (or tripartite) amendment to the prime contract. Because all three parties have agreed on the scope, cost, and schedule adjustments, the Change Order becomes immediately binding upon execution. The contractor may bill for completed Change Order work on subsequent progress payment applications (AIA G702/G703).

3. Construction Change Directive (CCD / AIA Document G714)

Under AIA A201 Section 7.3, a Construction Change Directive is a written order prepared and signed by the Architect and Owner , directing a change in the Work prior to agreement on adjustment, if any, in the Contract Sum or Contract Time, or both.

Why Use a CCD?

A CCD is a unilateral contractual tool utilized when:

The owner and contractor cannot agree on the proposed price or time extension for an essential scope change;

Time is of the essence, and waiting for formal change order price negotiations would cause catastrophic jobsite delay; or

An emergency or immediate life-safety condition requires immediate field execution.

Signatures and Mandatory Compliance

A CCD requires only the signatures of the Owner and Architect . It does not require the contractor's signature to be effective. Upon receipt of a valid CCD, the contractor must promptly proceed with the change in the Work .

Cost Determination Under AIA A201 § 7.3.3 & § 7.3.7

If the CCD provides for an adjustment to the Contract Sum, the adjustment is calculated using one of four methods:

Mutual acceptance of a lump sum properly itemized and supported by sufficient substantiating data;
Unit prices stated in the Contract Documents or subsequently agreed upon;

Cost to be determined in a manner agreed upon by the parties and a mutually acceptable fixed or percentage fee; or

If the contractor does not respond promptly or disagrees with the method of adjustment, the method is determined under Section 7.3.7 (Time and Material / Force Account) .

Under Section 7.3.7, the architect determines the cost based on reasonable expenditures and savings of those performing the work, including:

Actual costs of labor (payroll taxes, fringe benefits, workers' comp);
Costs of materials, supplies, and equipment (including transportation);
Rental costs of machinery and equipment;
Costs of premiums for bonds and insurance, permit fees, and sales taxes; and

A reasonable allowance for contractor overhead and profit as defined in the contract.

Conversion of CCD to Change Order (A201 § 7.3.6)

If the contractor agrees with the architect's determination of the cost and time adjustment, the contractor signs the CCD. The CCD then immediately becomes effective as a Change Order .

Division of the State Architect (DSA) Construction Change Documents (CCDs)

In California public school (K-12) and community college construction projects governed by the Field Act , changes to the state-approved plans and specifications are strictly regulated under California Code of Regulations (CCR) Title 24, Part 1, Chapter 4, Group 1, Section 4-338 and DSA Interpretation of Regulations (IR) A-6 . In DSA parlance, construction changes are documented using Form DSA 140: Construction Change Document (CCD) .

DSA categorizes all design and construction changes into two distinct legal classifications based on their impact on public safety: ┌───────────────────────────────┐

│ DSA Construction Change │
│ Document (Form DSA 140) │
└───────────────┬───────────────┘
│

Does the change affect any of the following?

1. Structural Safety (SS)
2. Fire and Life Safety (FLS)
3. Accessibility (Access)
│
┌────────────────────────┴────────────────────────┐
▼ ▼
YES NO
┌─────────────────────────────┐ ┌─────────────────────────────┐
│ CATEGORY A CCD │ │ CATEGORY B CCD │
├─────────────────────────────┤ ├─────────────────────────────┤
│ • Affects SS, FLS, or Access│ │ • Does NOT affect SS, FLS, │
│ • DSA Plan Check & Written │ │ or Accessibility │
│ Approval MANDATORY BEFORE │ │ • Does NOT require DSA │
│ work begins in the field │ │ pre-approval to construct │
│ • Unapproved work subject to│ │ • Signed by AOR; logged by │
│ Stop Work / Non-Cert │ │ IOR; filed at closeout │
└─────────────────────────────┘ └─────────────────────────────┘
Category A CCDs (Mandatory DSA Pre-Approval Required)

A Category A CCD encompasses any change that affects one or more of the three pillars of DSA jurisdiction:

Structural Safety (SS): Modifications to foundations, structural framing members, load-bearing walls, shear walls, diaphragm nailing, structural connections, or seismic force-resisting systems;

Fire and Life Safety (FLS): Alterations to exit corridors, exit doors, occupant loads, travel distances, fire-resistance-rated assemblies, fire alarm systems, fire sprinkler layouts, or emergency lighting;

Accessibility (Access): Modifications to accessible paths of travel, ramp slopes, curb ramps, door opening widths, door hardware, accessible restroom layouts, clearance dimensions, or disabled parking stalls.

Strict DSA Field Rule: A Category A CCD MUST be submitted to DSA and receive formal plan check review and written approval BEFORE the work is performed in the field! If a contractor proceeds with Category A work prior to receiving DSA written approval, the DSA field engineer or Project Inspector will issue a Notice of Non-Compliance (Form DSA 154) or a Stop Work Order. Work executed without DSA approval cannot be certified and may have to be demolished.

Category B CCDs (No Pre-Approval Required)

A Category B CCD encompasses changes that do not affect Structural Safety, Fire and Life Safety, or Accessibility. These are minor architectural, mechanical, or electrical revisions that comply fully with code and do not touch regulated life-safety elements:

Interior paint color changes or finish substitutions (non-rated);

Minor millwork, casework, or shelving modifications not located in accessible paths or required clearance zones;

Non-structural ceiling tile changes;

Minor landscaping revisions outside the accessible route of travel.

Category B CCDs do not require DSA plan check approval prior to construction. The Architect of Record prepares and signs the Form DSA 140 (Category B), transmits it to the general contractor, provides a copy to the DSA Project Inspector (IOR) on site, and submits the document to DSA for informational logging and verification during project closeout.

Comparison Table: Construction Change Instruments & DSA CCD Rules

Instrument Governing Standard Signatures Required Timing of Execution Cost / Time Impact Regulatory Pre-Approval

Architect's Supplemental Instructions (ASI) AIA A201 § 7.4 / AIA G710 Architect Only Before work proceeds Zero cost change; zero time change (minor changes only) None (Internal design team instruction)

Change Order (CO) AIA A201 § 7.2 / AIA G701 Owner, Architect, Contractor (Tripartite) Prior to contractor billing for changed work Agreed lump sum, unit prices, or time & materials; agreed schedule adjustment Local AHJ approval required only if altering permitted plans

Construction Change Directive (CCD) AIA A201 § 7.3 / AIA G714 Owner and Architect (Unilateral) Immediate; contractor must proceed immediately Cost determined under § 7.3.7 (Time & Materials) if not agreed Local AHJ approval required if scope alters permitted life-safety/structure

DSA Category A CCD CCR Title 24 Part 1 § 4-338 / Form DSA 140 Architect of Record, Structural Engineer (if SS), DSA Plan Reviewer MANDATORY DSA Approval BEFORE work begins in field Contractual cost handled via CO/CCD; DSA regulates code compliance DSA Plan Check Approval MANDATORY prior to field construction

DSA Category B CCD CCR Title 24 Part 1 § 4-338 / Form DSA 140 Architect of Record, DSA Project Inspector (IOR logged) Prior to field construction; no DSA pre-approval needed Contractual cost handled via CO/CCD No DSA pre-approval; reviewed by DSA during final project closeout

CSE Exam Traps & Practical Takeaways

Trap 1: Confusing CCD Signatures in Standard AIA Contracts: Candidates often mistakenly believe a Construction Change Directive requires the contractor's signature. It does not. A CCD is specifically designed as a unilateral mechanism requiring only the Owner and Architect signatures so that work cannot be stalled by a contractor's refusal to agree on price.

Trap 2: Issuing an ASI That Costs Money: An architect can never use an ASI to resolve a field problem that increases the contractor's cost or schedule, even by one dollar or one day. If cost or time is affected, a Change Order or CCD must be used.

Trap 3: Commencing DSA Category A Work Without Pre-Approval: In public school projects, contractors often pressure architects to let them proceed with Category A framing or door changes "while DSA plan check is pending." Permitting this violates Title 24. Category A work executed without DSA written approval jeopardizes the school's certification and the architect's professional license.

Trap 4: Forgetting the DSA Project Inspector's Role: Under Title 24, the DSA Project Inspector (IOR) cannot inspect or sign off on any work that deviates from the original DSA-approved plans unless the inspector has an approved Category A CCD (stamped by DSA) or an issued Category B CCD (signed by the AOR) in hand.