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Board of Health adopts revised bedroom definitions in Chapter 2.23 after public comment
Summary
The Nantucket Board of Health voted to approve updated definitions in Board of Health Regulations Chapter 2.23 that clarify how bedrooms are counted for septic sizing. The revision drew detailed public comment from local engineers about how cabanas, large open rooms and room-count methods interact with Title 5 rules.
The Nantucket Board of Health on a vote approved updated language in Board of Health Regulations, Chapter 2.23 that clarifies how the board will count bedrooms for septic-system sizing.
The update, presented as a final draft after review with town counsel and shared with the Select Board, defines when a room is to be counted as a bedroom and spells out exceptions and mechanical rules used by staff when they review building plans and septic permits. The board voted to adopt the revisions after concluding a public hearing and hearing comments from local designers and engineers.
The change matters because the number of bedrooms determines septic design and wastewater flow calculations used under both local rules and the state Title 5 program. Under the revised text, rooms that include full bathrooms, rooms exceeding specified minimum areas, and other features will be more explicitly identified as bedrooms during plan review, reducing uncertainty about septic sizing.
Don Bracken of Bracken Engineering told the board the new wording will help in some cases but raised persistent concerns about how literal application of the rules affects structures such as cabanas. Bracken said some cabanas that are roughly 70 square feet with a window have in prior practice been treated as bedrooms even though their configuration makes conversion to sleeping use unlikely. He also described recurring issues with rooms used as exercise rooms, wine cellars or other non-sleeping spaces that nevertheless read as bedrooms under a strict reading of area- and feature-based tests.
Bracken also questioned a local rule that treats one open room over 400 square feet (or one room constituting 50% of a single level's floor area) as equivalent to two bedrooms, saying many large recreation rooms or entertainment areas are not realistically used as two separate bedrooms. He noted that the local practice for room-count conversions has at times diverged from Title 5 approaches, and urged the board to expect ongoing questions from homeowners and architects.
John (Health Department staff) responded to many of Bracken’s points: the 400-square-foot rule is applied only when the space is both over 400 square feet and represents 50% of the single level’s finished floor area; the department will continue to consider the total floor-area context in basement and other configurations. John said the island has historically used a conservative approach to bedroom counting because of its sole-source aquifer and septic-related drinking-water protection goals.
Board members noted the draft clarifies many situations but acknowledged it cannot anticipate every building design. Rocky (board member) said the definitions aim to capture the most common scenarios and that plan-by-plan review will still resolve edge cases. After a brief final board discussion, a motion to approve the updated definitions for Chapter 2.23 passed; the chair recorded the vote by saying “aye.”
The adopted language is now the board’s formal guidance for counting bedrooms on septic and building plan reviews; staff said the building department will continue to submit floor plans for review so health staff can confirm bedroom counts when issuing septic-related approvals.
The board closed the hearing after the vote and moved to the next agenda item.
