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Accessible Parking Upgrades Required for Alteration?

N

nealderidder

Sawhorse
Joined
Dec 7, 2010
Messages
394
Location
Sacramento, CA
Hello all,

I wanted to get some opinions on the accessibility requirements for an alteration (using 2019 CBC). My understanding has always been that anything being "altered" or built "new" for a project would have to meet all of the accessibility requirements of Division 2. And anything that's not being altered would not have to be upgraded to meet accessibility with some exceptions.

The exceptions being things that either get you to an altered/new space or things that serve an altered/new space. Specifically what is listed in 11B-202.4. Primary entry, bathrooms, drinking fountains, public phones, and Signage. Any existing, unaltered space that isn't on that list is not required to be upgraded is what I'm thinking.

My question is specifically about parking. Imagine this project, a interior remodel, with no changes proposed to the parking lot (which has existing accessible parking). If the existing parking is not up to snuff, is it required by code that the parking be upgraded? If so, how do you arrive at that conclusion?

To put it more simply - Am I wrong that since it's not on the 11B-202.4 list, it's not required?

Thanks for your thoughts. And just so you know, we are going to upgrade the parking, it's not a big expense.

Neal
 
Part of the decision would be based on what is not quite up to snuff about the parking area. As far as I know the 20% requirement would still come into play and making changes to the parking lot could be an easy place to spend some money to get to 20%.
 
nealderidder said:
Hello all,

I wanted to get some opinions on the accessibility requirements for an alteration (using 2019 CBC). My understanding has always been that anything being "altered" or built "new" for a project would have to meet all of the accessibility requirements of Division 2. And anything that's not being altered would not have to be upgraded to meet accessibility with some exceptions.

The exceptions being things that either get you to an altered/new space or things that serve an altered/new space. Specifically what is listed in 11B-202.4. Primary entry, bathrooms, drinking fountains, public phones, and Signage. Any existing, unaltered space that isn't on that list is not required to be upgraded is what I'm thinking.

My question is specifically about parking. Imagine this project, a interior remodel, with no changes proposed to the parking lot (which has existing accessible parking). If the existing parking is not up to snuff, is it required by code that the parking be upgraded? If so, how do you arrive at that conclusion?

To put it more simply - Am I wrong that since it's not on the 11B-202.4 list, it's not required?

Thanks for your thoughts. And just so you know, we are going to upgrade the parking, it's not a big expense.

Neal
Click to expand...
Is everything on the list upgraded?
Exceptions:
"...Alterations of existing parking lots by resurfacing and/or restriping shall be limited to the actual scope of work of the project and shall not be required to comply with Section 11B-202.4. ..."
This MAYNOT alleviate the risk of a lawsuit for non-accessibility.
 
mark handler said:
Is everything on the list upgraded?
Exceptions:
"...Alterations of existing parking lots by resurfacing and/or restriping shall be limited to the actual scope of work of the project and shall not be required to comply with Section 11B-202.4. ..."
This MAYNOT alleviate the risk of a lawsuit for non-accessibility.
Click to expand...
Mark - I believe that section is saying that if you are only doing a parking lot refresh (resurfacing/restriping) than the improvements listed in 11B-202.4 are not triggered. That's not my question. I'm talking about an interior remodel which absolutely does trigger 11B-202.4. I'm wondering what requires me to make improvements that are not listed in 11B-202.4.
 
Msradell said:
Part of the decision would be based on what is not quite up to snuff about the parking area. As far as I know the 20% requirement would still come into play and making changes to the parking lot could be an easy place to spend some money to get to 20%.
Click to expand...
This is in CA so the 20% rule doesn't really come into play. I can't remember that last time I had a project whose costs fell under the valuation threshold... So sky's the limit, spend until it's up to code. I've still got the same question. What pushes me to make improvements beyond that list of five items in 11B-202.4? Is A Primary Entrance to the Building being interpreted as meaning everything from the public way to the building including site arrival points and parking? Seems like a stretch...
 
Be wary if property is not compliant with ADA as to existing barriers vs CBC, it is required to be maintained in a compliant condition as to existing elements. Depending on use it may be a potential "target" in CA.
 
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