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Does an Alteration trigger the need for path to street?

nealderidder

Sawhorse
Joined
Dec 7, 2010
Messages
394
Location
Sacramento, CA
I'm working on a TI in an existing building. It's a big TI, includes the entire two floors of the building. This is in California.

CBC 11B-206.2.1 calls for an accessible route from the building to the street. It notes "at least one".

CBC 11B-202.4 tells me that in an alteration I'm only required to provide a path of travel to altered elements from the primary entrance to the building. It would appear that my TI wouldn't trigger the need for an accessible route to the street. Am I right?
 
If not, then how is one to approach and enter the building if not by an accessible POT? especially if the building is not presently served by one?
(there I go being logical?)
 
That POT from the public sidewalk is often not achievable in an existing building that was constructed prior to this requirement. Is this a change in use? You will need to provide a compliant POT from the accessible parking area serving your suite.
 
11B-202.4 Path of travel requirements in alterations, additions and structural repairs
When alterations or additions are made to existing buildings or facilities, an accessible path of travel to the specific area of alteration or addition shall be provided.
The primary accessible path of travel shall include:
  1. A primary entrance to the building or facility,
  2. Toilet and bathing facilities serving the area,
  3. Drinking fountains serving the area,
  4. Public telephones serving the area, and
  5. Signs.

Chapter 2 Definitions
PATH OF TRAVEL. An identifiable accessible route within an existing site, building or facility by means of which a particular area may be approached, entered and exited, and which connects a particular area with an exterior approach (including sidewalks, streets and parking areas), an entrance to the facility, and other parts of the facility. When alterations, structural repairs or additions are made to existing buildings or facilities, the term “path of travel” also includes the toilet and bathing facilities, telephones, drinking fountains and signs serving the area of work.
 
That POT from the public sidewalk is often not achievable in an existing building that was constructed prior to this requirement. Is this a change in use? You will need to provide a compliant POT from the accessible parking area serving your suite.
Technically infeasible. In alterations, where the enforcing authority determines compliance with applicable requirements is technically infeasible, the alteration shall provide equivalent facilitation or comply with the requirements to the maximum extent feasible. The details of the finding that full compliance with the requirements is technically infeasible shall be recorded and entered into the files of the enforcing agency.
 
Technically infeasible. In alterations, where the enforcing authority determines compliance with applicable requirements is technically infeasible, the alteration shall provide equivalent facilitation or comply with the requirements to the maximum extent feasible. The details of the finding that full compliance with the requirements is technically infeasible shall be recorded and entered into the files of the enforcing agency.

In California I have also used 11B-206.2.1 exception 2. "An accessible route shall not be required between site arrival points and the building or facility entrance if the only means of access between them is a vehicular way not providing pedestrian access."
 
In California I have also used 11B-206.2.1 exception 2. "An accessible route shall not be required between site arrival points and the building or facility entrance if the only means of access between them is a vehicular way not providing pedestrian access."
But if there is any pedestrian access, Accessible or not, you can not use this.
 
11B-202.4 Path of travel requirements in alterations, additions and structural repairs
When alterations or additions are made to existing buildings or facilities, an accessible path of travel to the specific area of alteration or addition shall be provided.
The primary accessible path of travel shall include:
  1. A primary entrance to the building or facility,
  2. Toilet and bathing facilities serving the area,
  3. Drinking fountains serving the area,
  4. Public telephones serving the area, and
  5. Signs.

Chapter 2 Definitions
PATH OF TRAVEL. An identifiable accessible route within an existing site, building or facility by means of which a particular area may be approached, entered and exited, and which connects a particular area with an exterior approach (including sidewalks, streets and parking areas), an entrance to the facility, and other parts of the facility. When alterations, structural repairs or additions are made to existing buildings or facilities, the term “path of travel” also includes the toilet and bathing facilities, telephones, drinking fountains and signs serving the area of work.

I have a related question. I am doing a T.I for a religious organization in California on a project that has its own parking garage. It was approved by the AHJ 10 years ago with two accessible stalls, but only the van stall has a POT that does not go behind another vehicle; the other accessible stall goes behind the van stall.

Q: Since I can comply with POT for all things except access stall #2, should just the one van stall be sufficient for satisfying 11B-202.4?
 
(I reference that it is a religious organization to note their exemption from ADA lawsuits; this is purely a CBC -11B compliance issue for the remodel, on a parking lot already approved by the AHJ several years ago.)
 
# ~ #
" Q: Since I can comply with POT for all things except access stall #2, should
just the one van stall be sufficient for satisfying 11B-202.4 ? "
IMO, ...Yes, you have satisfied the Accessibility POT.......In your jurisdiction, is there a
precedent for having an Accessible POT for "all" Accessible Parking Spaces, or is it a
"Gray Area" to be determined by the AHJ ?


# ~ #
 
Careful MH, CASps can only opinion unless they are an AHJ. Theirs is a "voluntary" certification, overseen by the state.
 
IMHO, No. But that is up to the AHJ and the CASp.

I agree, Mark. But when it comes to being a sounding boards on accessibility questions on this forum, you are analogous to "Mikey" in the old Life Cereal commercials: if I can get you to 'like' something, chances are good that most everyone else (incl. AHJ and CASp) will eventually 'like' it too.
(And I seriously mean this as a major compliment to you!)
 
That POT from the public sidewalk is often not achievable in an existing building that was constructed prior to this requirement. Is this a change in use? You will need to provide a compliant POT from the accessible parking area serving your suite.
Nope, not a change of use.
 
Nope, not a change of use.
Be very careful in your use of change of occupancy. Per the Ch. 2 definition, it is:

[A] CHANGE OF OCCUPANCY. A change in the use of a building or a portion a building which results in one of the following:
  1. A change of occupancy classification.
  2. A change from one group to another group within an occupancy classification.
  3. Any change in use within a group for which there is a change in application of the requirements of this code.
#3 can trip you up. Some occupancy types have requirements that are specific to a use, not just the occupancy classification.
 
, but only the van stall has a POT that does not go behind another vehicle; the other accessible stall goes behind the van stall.
Where in the IBC or ADA does it state a person can not be required to go behind another vehicle? I agree it is not a good idea but is it prohibited by the IBC or ADA? I am not interested in California regulations.
 
Where in the IBC or ADA does it state a person can not be required to go behind another vehicle? I agree it is not a good idea but is it prohibited by the IBC or ADA? I am not interested in California regulations.
It is allowed; however, per the Advisory, it is discouraged.

A117.1 - 502.3 Access Aisle
Access aisles serving parking spaces shall comply with 502.3. Access aisles shall adjoin an accessible route. Two parking spaces shall be permitted to share a common access aisle.
Advisory 502.3 Access Aisle. Accessible routes must connect parking spaces to accessible entrances. In parking facilities where the accessible route must cross vehicular traffic lanes, marked crossings enhance pedestrian safety, particularly for people using wheelchairs and other mobility aids. Where possible, it is preferable that the accessible route not pass behind parked vehicles.
 
This most often occurs on gas station sites where service bays are converted to mini-marts, sites are tight and only drive aisles exist.
 
Big box stores where there is a fire lane in front of the store. All of the HC parking spaces you have to travel in the driving aisle to get to the HC parking space of which there could be 6 or more of them
 
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