Accessible Routes Next To Parking Lot

[arwat23]

Got a comment I've never seen before and wanted to get more opinions on it. Commercial TI in California using 2022 CBC / 2021 IBC.

The comment states that we need to have a 48" wide accessible route from the parking to the entry of a building (CBC 11B-403.5.1, exception 3). Sure, makes total sense, I have no complaints so far.

The second part of the comment says that if the accessible route is separated from a vehicular way by a curb ramp or blended transition (we have a blended transition that looks like a parallel curb ramp - it's kind of odd), we can't use the detectable warning as part of the accessible route (CBC 11B-250.1, exception 4). This means we effectively need roughly 84" clear from the beginning of the detectable warning (36" for the separation plus 48" for the accessible route).

I personally don't read this section that way. Or, at least, it doesn't seem very explicit. What do you all think?

 

[Joe.B]

Yeah, this came up in a CASp training I recently attended (virtually) and it's relatively new. I think it was added in the 2019 mid-cycle amendments, so July 2021? I think the reviewer might be mixing things up a little bit though. 11B-250.1 is specific to circulation paths. Here's the CBC definition of "circulation paths" and the full text of 250.1 for the sake of conversation.

Before going to deep in this, first check and see if the element in question fits the definition. If it does, then I'd look at the other exceptions for an out. Check out accesstoolkit.com, it requires an annual fee, but it's the best resource I've found, especially for CA. He compiles tons of resources into one place and adds a lot of his own diagrams, it's searchable too. I searched "circulation path" and he shows what was allowed prior to this requirement, and how it looks different now. Big $$$$$$$$$$$ difference for the project.

[BE] CIRCULATION PATH. An exterior or interior way of
passage from one place to another for pedestrians. [DSA-AC]
An exterior or interior way of passage provided for pedestrian
travel, including but not limited to, walks, sidewalks, hallways,
courtyards, elevators, platform lifts, ramps, stairways
and landings.
11B-250 Circulation paths
11B-250.1 General. Circulation paths contiguous to vehicular
traffic shall be physically separated from vehicular traffic.
Vehicular traffic includes travel through parking
facilities. into and out of parking spaces, into and out of electric
vehicle charging spaces, and along roadways, driveways
and drive aisles. Physical separation shall be provided with
circulation paths raised 4 inches (102 mm) minimum above
the area where vehicular traffic occurs.
Exceptions:
1. Curb ramps and blended transitions 1vith detectable
warnings complying with Section 11B-247 may be
used to connect raised circulation paths and pedestrian
crossings within areas of vehicular traffic.
Blended transitions and cut-through medians with
detectable warnings complying with Section 11B-
247 may be used to connect circulation paths and
pedestrian crossings at similar elevations within
areas of vehicular traffic.
2. At locations where sidewalks and walks in the public
right-of-way cross driveways without yield or stop
traffic control, compliance with this section shall not
be required.
3. At locations where circulation paths cross driveways
or drive aisles, circulation paths shall not be
required to comply with this section and detectable
warnings shall not be permitted. Beyond the crossing
where continuation of the circulation path
within a parking facility leads immediately to and
does not continue beyond only parking spaces complying
with Section 11B-502, passenger drop-off
and loading zones complying with Section 11B-503
and electric vehicle charging stations complying
with Section 11B-812, the circulation path shall not
be required to be raised.
4. In alterations to existing parking facilities, including
alterations required by Section 11B-202.4, physical
separation may be provided with detectable warnings
complying with Sections 11B-247 and 11B-
705.1 in lieu of raised circulation paths.
5. Access aisles serving any electric vehicle charging
station vehicle spaces complying with Section 11B-
812, parking spaces complying with Section 11B-
502, or passenger drop-off and loading zones complying
with Section 11B-503 shall not be required to
comply with this section.
6. At each electric vehicle charging station complying
with Section 11B-812 where the charger and its controls
are oriented toward the vehicle space it serves
and the charger's clear floor spaces for operable
parts and point-of-sale devices are at the same elevation
as the vehicle space, the accessible route
complying with Section 11B-812.5.2 shall not be
required to comply with this section.

 

[arwat23]

Thanks Joe.B! Lets say for the sake of argument that is is considered a circulation path. Would the detectable warning not be included in the required accessible route width? That's really the sticking point - if this separation requirement for circulation paths removes the detectable warning space from the accessible route width.

Here's an as-built plan showing the existing conditions of the space:

 

[JPohling]

Arwat, couple thoughts. Like you mentioned what you have is not a traditional parallel curb ramp. It would be possible to place 36" of detectable's across the entire width of the bottom of your accessible ramp and eliminate them from the zero curb condition across the parking spaces. If you view it as a parallel curb ramp and you are limited in the width that you can provide to 5'-6" then you can reduce the detectable's to 24" in depth and get 3'-6" of a smooth walkway per 11B 705.1.2.2.2.1. Current code only requires 36" smooth and 36" detectable's for a parallel curb ramp path of travel, not 48". I do not believe you need 48" of smooth concrete in this situation.

 

[Joe.B]

 

[Joe.B]

Would the detectable warning not be included in the required accessible route width? That's really the sticking point - if this separation requirement for circulation paths removes the detectable warning space from the accessible route width.

Hard to say for sure, I am not a designer. I think @JPohling has a good idea there. I do think you need 36" for your accessible route and that DW's cannot be in that space, if that's what you're asking.

 

[arwat23]

The existing conditions were permitted under the 2013 CBC.

2022 CBC 11B-705.1.2.2.2.1, exception 2 seems to allow less than 36" since that wasn't a requirement in the 2013 CBC.

But still, ignoring all of that, there's 11B-250.1. Even if we can use the exception above, I don't see that changing the accessible route clear width requirement.

Current code only requires 36" smooth and 36" detectable's for a parallel curb ramp path of travel, not 48". I do not believe you need 48" of smooth concrete in this situation.

CBC 11B-403.5.1, exception 3 is what's being used to require a 48" accessible route. The city seems to be considering this space a "walk".

 

[JPohling]

Where in the code does it restrict the use of detectables on an accessible path if they comply with 303 changes in level? Floor and ground surfaces comply with 302. Accessible paths are constantly crossing them. How does the plan reviewer reconcile the parallel curb ramp code requirements with his interpretation? Or place 36" of detectable's at the end of your ramp and call it good

 

[arwat23]

Where in the code does it restrict the use of detectables on an accessible path if they comply with 303 changes in level? Floor and ground surfaces comply with 302. Accessible paths are constantly crossing them. How does the plan reviewer reconcile the parallel curb ramp code requirements with his interpretation? Or place 36" of detectable's at the end of your ramp and call it good

Their interpretation is that the barrier required by 11B-250.1 cannot be used as part of an accessible route or circulation path. Their thought is, if you allow the accessible route to use the detectable warning (used as a barrier by 11B-250.1 exceptions), then you don't have an adequate barrier. You are, in their mind, negating the barrier and putting people in danger.

 

[JPohling]

Well it is not a barrier, it is a warning device that you need to experience by walking on the surface or with cane detection. What people do they believe are in danger in your situation? Place the detectable's at the base of your ramp 36" deep and you are done. I would prefer less detectable's anyway, they cause more disabilities than anything

 

[arwat23]

Well it is not a barrier, it is a warning device that you need to experience by walking on the surface or with cane detection. What people do they believe are in danger in your situation? Place the detectable's at the base of your ramp 36" deep and you are done. I would prefer less detectable's anyway, they cause more disabilities than anything

Sorry, I meant it's a separation component. The way I think of it, the plans examiner is basically considering it a wall. Not visually obviously, but more so that you can't have a circulation path or accessible route through a solid wall. The "wall" physically separates the vehicle space from the circulation path, and you can't have an accessible route unless the clear space is 48" measured from the "wall".

There's nothing I see in code that explicitly says the detectable warning can't be used as an accessible route, which is what's making this so frustrating for me to understand. This is just how the plans examiner is interpreting 11B-250.1

11B-250.1, exception 4: In alterations to existing parking facilities, including alterations required by Section 11B-202.4, physical separation may be provided with detectable warnings complying with Sections 11B-247 and 11B-705.1 in lieu of raised circulation paths.

 

[JPohling]

Yeah I would go higher up the chain. Detectable warnings are typically used across walks. they are not walls or physical barriers. they are a warning device specifically made to be crossed and detected as you circulate down the walkway. The previous code for parallel ramps had the entire surface covered in detectable's that you used to have to navigate. Detectable warnings are not excluded from being a surface of an accessible route if they comply with 302/303

 

[Yikes]

Detectable warnings are permitted as part of an accessible route, unless they are on a portion the accessible route where either (a) they are explicitly prohibited, or (b) changes in elevation are not allowed.

Regarding (b): a detectable dome is 0.2" high. Where CBC 11B allows changes in level on an accessible route, the dome complies with the max. 1/4" height in 11B-303.2.
Domes and other changes in level are prohibited at landings (doors, ramps, stairs), at accessible parking spaces and access aisles, turning spaces per 11B-304.2, and clear floor spaces in 11B-305.2. There's probably a few more places I can't think of at the moment.

 

[arwat23]

So what I'm hearing is everyone's in agreement that 11B-250.1 doesn't remove the detectable warning from the accessible route. Great! Now comes the hard part.

 

[Yikes]

There's nothing I see in code that explicitly says the detectable warning can't be used as an accessible route, which is what's making this so frustrating for me to understand. This is just how the plans examiner is interpreting 11B-250.1
11B-250.1, exception 4: In alterations to existing parking facilities, including alterations required by Section 11B-202.4, physical separation may be provided with detectable warnings complying with Sections 11B-247 and 11B-705.1 in lieu of raised circulation paths.

I think the wording of exception #4 is unfortunate. It should have said " In alterations to existing parking facilities, including alterations required by Section 11B-202.4, detectable warnings complying with Sections 11B-247 and 11B-705.1 may be provided in lieu of raised circulation paths.

So what I'm hearing is everyone's in agreement that 11B-250.1 doesn't remove the detectable warning from the accessible route. Great! Now comes the hard part.

My suggestion is to contact DSA and ask this question:
Regarding 11B-250.1 exception #4: Should the phrases "physical separation" and "in lieu of raised circulation paths" be construed to mean that detectable warning cannot be considered as part of, or allowed within, the minimum required width of a walkway that is part of an accessible route?

 

[Paul Sweet]

Detectable Warnings are warnings, not a good walkway surface. I have read that they are annoying, if not difficult, to roll over in a wheelchair for any distance. They would also be annoying to people who shuffle along when they walk.

 

[arwat23]

Detectable Warnings are warnings, not a good walkway surface. I have read that they are annoying, if not difficult, to roll over in a wheelchair for any distance. They would also be annoying to people who shuffle along when they walk.

I completely agree, but this is an existing condition that the building owner doesn't want to modify unless required to by code. If this were new construction, there's no way we'd design this.

 

[Yikes]

Detectable Warnings are warnings, not a good walkway surface. I have read that they are annoying, if not difficult, to roll over in a wheelchair for any distance. They would also be annoying to people who shuffle along when they walk.

The requirement in the code uses the word "contiguous":
11B-250.1 General. Circulation paths contiguous to vehicular traffic shall be physically separated from vehicular traffic.
So if the circulation path can be made non-contiguous by other means, then 11B-250.1 becomes non-applicable to the project.
The methods I've seen in lieu of detectable warnings to make it non-contiguous are:
1. A narrow planter
2. Cobble in lieu of plants
A Curb (can be a trip hazard
3. A handrail , guardrail or low wall with something at <27" AFF.

All of these 4 items take up much less space than the 36" width of truncated domes along the length of the walkway.