Accessibility Advisory 208.2 - Parking Facility vs Parking Lot - Explained

[jar546]

Advisory 208.2 Minimum Number. The term “parking facility” is used Section 208.2 instead of the term “parking lot” so that it is clear that both parking lots and parking structures are required to comply with this section. The number of parking spaces required to be accessible is to be calculated separately for each parking facility; the required number is not to be based on the total number of parking spaces provided in all of the parking facilities provided on the site.

The ADA does not define the difference between "parking facility" and "parking lot" but does define the word "facility."

Facility: All or any portion of buildings, structures, site improvements, elements, and pedestrian routes or vehicular ways located on a site.

Explanation:

• Terminology:
  • The term "parking facility" is used instead of "parking lot." This is to ensure that both open parking lots and enclosed parking structures (like parking garages) are covered under this requirement.
• Calculation of Accessible Spaces:
  • Each parking facility must be considered individually when determining the number of required accessible parking spaces.
  • You do not calculate the number of accessible parking spaces based on the total number of parking spaces across multiple parking facilities on a single site. Instead, each parking lot or structure is evaluated separately.

Example:

• Suppose a site has two separate parking facilities: one with 100 spaces and another with 200 spaces.
• According to the ADA standards, the required number of accessible spaces must be determined separately for each facility.
  • For the 100-space facility, you might need 4 accessible spaces (based on the ADA table for determining accessible parking requirements).
  • For the 200-space facility, you might need 6 accessible spaces.
• You cannot combine these facilities and then calculate the requirement as if there were a single 300-space facility.

 

[Paul Sweet]

You can't combine them to calculate the number of required accessible spaces, but you can put most or all of the 10 accessible spaces in the parking lot closest to the accessible entrance(s) and the remainder (if any) in the farthest parking lot.

 

[Jean Tessmer-HI]

In addition, if there are separate employee parking areas, or designated parking such as visitor, PV charging station, time limited parking, patient, specific designated named store customer parking, emergency room, parking areas all will need their own ADA compliant parking with at least one van accessible stall. This is not an exhaustive list, but these have all appeared on complaints by the DOJ. The parking has to be dispersed for equity, if the parking lot serves more than one big box store or a bunch of small retailers.

 

[CASpAccess]

P Sweet: You can't combine them to calculate the number of required accessible spaces, but you can put most or all of the 10 accessible spaces in the parking lot closest to the accessible entrance(s) and the remainder (if any) in the farthest parking lot.

It is required to locate all of the accessible parking spaces in the parking lot closest to the accessible entrance(s) but also locate them to be on the shortest accessible route to the entrances the accessible parking spaces serve'

ADAS 208.3.1 General.​

Parking spaces complying with ADAS 502 that serve a particular building or facility shall be located on the shortest accessible route from parking to an entrance complying with 206.4 Where parking serves more than one accessible entrance, parking spaces complying with 502 shall be dispersed and located on the shortest accessible route to the accessible entrances. In parking facilities that do not serve a particular building or facility, parking spaces complying with 502 shall be located on the shortest accessible route to an accessible pedestrian entrance of the parking facility.

EXCEPTIONS: 1. All van parking spaces shall be permitted to be grouped on one level within a multi-story parking facility.

2. Parking spaces shall be permitted to be located in different parking facilities if substantially equivalent or greater accessibility is provided in terms of distance from an accessible entrance or entrances, parking fee, and user convenience.

US DOJ Advisory 208.3.1 General Exception 2. Factors that could affect “user convenience” include, but are not limited to, protection from the weather, security, lighting, and comparative maintenance of the alternative parking site.

 

[Yankee Chronicler]

You can't combine them to calculate the number of required accessible spaces, but you can put most or all of the 10 accessible spaces in the parking lot closest to the accessible entrance(s) and the remainder (if any) in the farthest parking lot.

But if the 100-space lot is on the north side of the building and the 200-space lot is on the south side, absent some special conditions I would view that as requiring that each lot be treated independently, and that both the north and south building entrances be accessible.

 

[Paul Sweet]

I should have made "parking lot" plural. My point was that a parking lot doesn't have to have accessible spaces as long as there are adequate accessible spaces in other parking lot(s) or facilities which are closer to the entrance(s).