Development Length in Seismic Regions

[ENGJP22]

Hi guys, hope you are okay, I have this Situation, the ACI 318 indicates a equation in chapter 25 to calculate development Length (ld). There's a factor that's used to account the effects of casting position when there's more than 12in of concrete below the bars, this factor is 1.3. This equation is for ld in tension, if I splice the top bars in the Center of the beam span theres only compression so I dont have to use the equation that involves the casting position. This criteria can be applied in a special moment frame?

 

[struct_eeyore]

The increased development length for a condition w/ more than 12" of concrete below is a result of the bleed water pooling to the top of the beam - in turn increasing the w/c ratio within that region.
Unless you're 100% certain that that region of the beam will never see tension, I would consider it bad practice to not follow ACI in this case.