Modification letter
Here is what I ended up with for the modification request. Feedback is appreciated. Applicant information has been omitted.
October 20, 2010
To: (****)
Re: Modification request dated October 11th, 2010
Permit # TPN (****)
I have received your request to modify some of the accessibility requirements as they pertain to the “Zip Line Tour” constructed under the permit listed above.
Discussion:
This permit was issued under the 2006 International Building Code and the tour was classified as an “A5” occupancy, the designation given to amusement rides. Your submitted letter confirms this project is indeed an amusement ride, based on definitions found in the WAC.
The accessibility requirements are scoped in Chapter 11 of the 2006 IBC, specifically:
1103.1 Where required. Sites, buildings, structures, facilities,
elements and spaces, temporary or permanent, shall be accessible
to persons with physical disabilities.
1104.2 Within a site. At least one accessible route shall connect
accessible buildings, accessible facilities, accessible elements
and accessible spaces that are on the same site.
These sections have listed exceptions to the accessibility requirements; however, none of the listed exemptions could be reasonably applied to this project.
Using the United States Access Board (
www.access-board.gov), a federal agency whose function is to provide technical guidance on accessible design and enforcement of accessibility standards, we find a section on amusement rides.
The USAB offers the following guidelines for accessibility:
Exceptions
There are four types of rides that are not covered by the guidelines. However, other ADA requirements still apply. The four types are: (1 thru 3 omitted)
• #4 Rides that do not have seats must only provide an accessible route to the load and unload areas and a turning space in the load and unload area.
Conclusion:
The loading and unloading for each segment of the ride is considered an “accessible element”, and as required by IBC 1104.2, shall be provided with an accessible route.
Using the IBC and the USAB guidelines for amusement rides, an accessible route to the load and unload areas and a turning space in the load and unload areas shall be provided. Your request for modification is hereby denied.
The proposed “Zip Line Tour” will require the following items for compliance:
1) Complete and submit a revised site plan showing what is actually being built (per inspector request dated 8-16-10)
2) Provide details (on revised drawings) showing accessible routes to be provided between load and unload areas of the ride. If a zip line terminates in a location that requires walking, hiking, or otherwise traversing the site, an accessible route will be required between the unloading (termination of one segment) and the loading (start of the next segment).
3) The towers, ramps, ladders, and other elements necessary for the zip line will require an accessible route to them as well as the turning space as noted in the USAB guidelines.
4) Technical specifications and provisions for “accessible route”, “turning space”, “accessible parking”, and all other accessible elements of this project shall be constructed in accordance with the ANSI A117.1-2003 Standard for Accessibility.
5) Previously noted accessible elements, including but not limited to accessible parking and accessible restroom facilities, shall continue to be required.
6) Upon completion of all elements of the permit, contact (****) County for an inspection to verify compliance. All work will be subject to inspection, approval and possible correction.
7) Prior to inspection, a copy of the operation manual for the facility shall be provided to (****) County for review.
Sincerely,
John (****)
Deputy Building Official, (****) County
(****)