Tenant Improvements and Finish-Outs in El Paso

A gray shell is usually the bare suite, with slab, walls, roof and stubbed utilities, and a white box, also called a vanilla shell, usually adds basics such as demising walls, a ceiling, restrooms and base building systems. The lease defines both, because El Paso's building code defines only a shell building: exterior walls, foundation, site work, landscaping, zoning and parking requirements, property line firewalls and roof structure, with mechanical, plumbing and electrical limited to rough-in designs for future use and utilities stubbed into the service entrance for connection at the time of the tenant improvement (El Paso Municipal Code 18.08.040, amending IBC section 202).

So a gray shell sits close to the code's shell, while what a white box includes changes from lease to lease, which makes the work letter or lease exhibit the document that counts. A second-generation suite, one another tenant already built out, starts with demolition of whatever the new layout does not keep.

The City's rule for a finished shell is that nobody occupies it: it earns a certificate of completion, and the certificate of occupancy waits for the tenant work (EPMC 18.08.040, 18.02.111.7). That is why the starting condition moves scope and schedule more than any finish selection: it decides what the tenant improvement has to build, which trades are involved and what the drawings have to show. Sage reads the work letter against the actual suite at the Feasibility Audit, before the scope is fixed.

A change of occupancy or use into an assembly, business, educational, factory, hazardous, institutional or mercantile occupancy needs drawings sealed by a Texas architect or engineer whatever its size (El Paso Municipal Code 18.02.105.9(1)). For other tenant improvements and alterations, the seal is required in assembly, educational, factory, hazardous and institutional occupancies once the affected area exceeds 1,000 square feet, and in business and mercantile occupancies once it exceeds 3,000 square feet, a figure the code ties to a single-exit space of no more than 29 occupants. In any of those occupancies, work that involves or affects structural elements, fire-resistive elements or fire exits needs sealed drawings whatever the size, and so does work in any building three stories or taller (18.02.105.9(2)).

Those letters are the International Building Code's occupancy groups, which El Paso adopted with its own amendments (EPMC 18.08.020). Offices, outpatient clinics, medical and dental offices and banks are Group B. Stores are Group M. A restaurant or other gathering space is Group A once its occupant load reaches 50, and below 50 it is classified as Group B (IBC 2021 sections 303.1, 303.1.1, 304.1 and 309.1). So whether a suite changes use matters as much as its size, and which group a restaurant falls in depends on its occupant load.

Where a seal is not required, the submittal carries the applicant's certification of the state law exception that lets someone other than a registered architect or engineer prepare it (EPMC 18.02.105.9), and the building official can require a registered design professional wherever special conditions exist (18.02.105.7). Either way, construction documents go in digitally, and the title sheet carries the designer's code review: building size, construction type, occupancy, area and height, fire sprinklers and any deferred items (18.02.105.7, 18.02.105.8(B)).

Sage does not seal drawings. On a tenant improvement that needs them, the architect or engineer of record draws and seals the set, Sage builds to it, and field questions go back to that designer before anything is built differently. The same designer submits accessibility plans to the State when a project meets its threshold, which the concrete and code compliance page explains.

El Paso's code requires that order for new construction, and a finish-out follows it for the same reason: the building permit fixes the scope that every trade permit attaches to. For new construction, the master permit is issued before any separate electrical, mechanical, plumbing or fire protection permit (El Paso Municipal Code 18.02.105.3). Sage sequences a finish-out the same way, settling the building scope and drawings first so each trade permit is drawn against a layout that will not move. Why one project carries several permits at all is covered in the El Paso permits guide.

The order keeps working after the permit is issued. A revision that changes the electrical, plumbing or mechanical systems, the fire alarm or suppression, the fire separations, accessibility or exits, the structure, or the occupancy goes back for another plan review with its own fee (EPMC 18.02.106.11). Plans that need more than three reviews before issue also carry a submission fee, and an application with no permit secured within 180 days expires (same section).

That is the reason Sage fixes the layout at Scope Lock before the drawings are submitted, and why any change after that point comes to you in writing for approval before it is built. A wall moved on paper costs a revision. A wall moved after the permit costs a revision and a review cycle.

For a tenant improvement in a shell-only building, the City values the permit at 20 percent of the International Code Council rate for the building type and occupancy on the date of application (El Paso Municipal Code 18.02.106.8). A new shell is valued at 80 percent of that rate and a new commercial building at the full rate (18.02.106.6, 18.02.106.7), which is why finishing a suite is not valued like building one.

The ICC rate comes from the Code Council's Building Valuation Data, a square-foot table by construction type and occupancy that jurisdictions use as a benchmark for permit fees and that the Code Council updates twice a year. The fee amounts themselves live in the City's fee schedule, and this page does not print them.

For other alterations, the City reviews the valuation stated on the application. If the building official finds it understated, the permit is denied unless a certified professional appraisal supports it, one that counts the earthwork inside the building area, the electrical, gas, mechanical and plumbing work, labor, materials and permanent equipment (EPMC 18.02.106.5).

Each runs under its own City permit, on a schedule Sage coordinates as your one point of contact (El Paso Municipal Code 18.02.105.4).

Two systems carry extra state requirements in commercial suites: fire sprinklers, fire alarms and detection, and fixed and portable extinguisher systems, which answer to the Texas Department of Insurance, State Fire Marshal's Office, and medical gas piping in a medical or dental suite (El Paso Municipal Code 18.02.104.6(6) - (8)).

El Paso adds two sprinkler rules of its own. When a shell building has a sprinkler system, every tenant improvement inside it includes a sprinkler system modification that meets the current NFPA 13 standard (EPMC 9.52.080.2, adding section 901.4.3.1 to the fire code). And in an existing building, where a work area has to be sprinklered, the system includes a riser and stub-out so future work areas above and below can connect to it (EPMC 18.28.170, amending the 2021 International Existing Building Code). Both are part of the fire protection design. Sage frames the ceilings and soffits around them and holds the finishes until each system's inspection is released.

A baby diaper changing station, and often an accessible family or assisted-use toilet room, two items El Paso wrote into its own building code. Every new establishment or use provides at least one diaper changing station on each floor level with restrooms, accessible to women and to men or one station for both, with signs to it, and a shopping center with a central directory shows where the stations are. In new construction, and wherever the designer's code path for the suite applies it, assembly and mercantile occupancies also need an accessible family or assisted-use toilet room (El Paso Municipal Code 18.08.055).

The fixtures in those rooms are plumbing work under its own permit. The room itself, its walls, door, blocking for grab bars and finishes, is part of the build, scheduled around the plumbing inspection.

Two other El Paso amendments shape a change of use. A storage tenant (Group S) is separated from other tenants by 1-hour fire partitions unless each non-rated area stays within 3,000 square feet or the building is sprinklered (EPMC 18.08.060). And a building 40 years or older that changes occupancy in a way that raises its energy demand does not have to meet the energy conservation code for that change (EPMC 18.28.130). Existing buildings undergoing alteration or a change of occupancy may also follow the El Paso Existing Building Code in place of the new construction code (EPMC 18.08.020), and choosing that path is the designer's call.

Yes, with an after-hours construction permit. Permitted work runs Monday through Saturday, 6:00 a.m. to 10:00 p.m., and anything outside those hours, on Sundays or on legal holidays needs the after-hours permit, filed seven days before the work starts (El Paso Municipal Code 18.02.105.20.1 - 18.02.105.20.2). The permits guide covers how that permit is granted.

Two details matter most for a suite that stays open. The after-hours permit runs for the period stated on the application, up to one year, with one renewal (18.02.105.20.4), so a finish-out phased around business hours can be permitted once rather than night by night. And inspections outside the department's business hours need the building official's prior approval and carry a two-hour minimum charge paid before the inspection is scheduled (18.02.107.10), so night work is planned to put inspections in daytime wherever the sequence allows.

When something cannot wait, such as an imminent public safety concern or an opening that leaves the work site unprotected, the owner or the owner's agent may act outside permitted hours to address it, then notify the permit official and obtain the after-hours permit as soon as reasonably practicable (18.02.105.20.3).

Inside the suite, protection moves with the work: furniture, casework, equipment and workstations covered where they stand, and each room protected before work reaches it.

When the City issues the certificate of occupancy. A new building, and any change in the occupancy, nature or use of a building or part of one, waits for the certificate, which issues only after every required inspection has passed and the building official releases the space (El Paso Municipal Code 18.02.111.1). A permit will not issue at all for work that would violate the zoning ordinance (18.02.105.14(B)), so a new use is checked against the zoning of the address before the lease is signed, not after the drawings are done.

When the suite is ready but a detail is not, a temporary certificate of occupancy can open the doors. For a commercial space it follows the engineering, electrical, fire, mechanical, plumbing and building finals, runs for 30 days, and can be extended for another 30 days on a written request (18.02.111.5). A conditional certificate of occupancy covers a different case: it lets an existing space be used for an occupancy other than the one it was built for, once every life safety requirement of the new occupancy is met, for up to one year (18.02.111.6.1).

Two things do not open a suite. A certificate of completion confirms finished permit work but does not authorize occupancy of an incomplete shell (18.02.111.7), and permanent utility service is not connected to regulated systems until the building official releases them and a certificate of occupancy or completion issues (18.02.111.8). Sage builds the schedule backward from the opening date, with the finals and the certificate as its last milestones.