Alteration to existing hotel

[Camilo Vasquez]

I am working on a project where the hotel is undergoing substantial alterations; the common areas and many of the guest rooms are being redesigned and altered.

One of the guest rooms, which was not previously an ADA-M (guest room with mobility features) guest room is now being converted to an ADA-M guest room. This room provides a balcony with a 5 inch level change. The main concern with providing an accessible level change into the balcony is that they'd have to go deep into the guest room to provide the accessible level change.

I've been looking at the alteration requirements under the Tittle III ADA Regulations. 28 CFR Subpart 36.402 (Alterations) states that any alteration to a place of public accommodation, after January 26, 1992, shall be made so as to ensure that, to the maximum extent feasible, the altered portions of the facility are readily accessible.

That said, I believe it is fair game - they'll have to figure out a way to make the balcony threshold accessible. Unless they can provide that it is not "feasible". I am unsure how they can claim that it is unfeasible or if they have any grounds to defend their decision in not making the balcony level change accessible.

Happy to hear any thoughts!

 

[bill1952]

I was at a ADA hearing - for totally different subject - when this was discussed. 15 to 20 years ago I suspect. Those seemed to be curbs or the balcony was a step down in coastal areas subject to hurricanes. Buildings seemed to often be cmu walls and hollow core prestressed floors, and issue was wind blown rain. Just curious if this is close. There was no good answer as adequate door-sill gasketing did not seem possible and clearly the curb or step discriminated.

 

[Paul Sweet]

It might be possible to build a new deck at the inside floor level. You could probably use treated wood (possible also fire-retardant treated) and leave 1/8" - 1/4" gaps between planks for drainage without exceeding the load limits. The railings would have to be raised to 42" above the new deck level.

The door threshold height would probably be harder to overcome.

 

[ADAguy]

Is it to be presumed that the balcony is deep enough to allow for a WC to enter and exit if the elevation issue was resolved?

 

[Yikes]

Both Paul and ADAguy bring up good points:

I believe if the balcony is less than 3' it is not intended to be "occupied" and is considered decorative (aka a "juliette balcony"), and therefore no access is required. i don't have a code citation, but out here in California that's how HCID - LA's neutral accessibility consultant has interpreted it. I think it has to do with the balcony being considered too small for a 48" long wheelchair to fully enter and thus (like a shallow bedroom closet, or kitchen cabinets) the back of the wheelchair is still touching (and is therefore "on") the "accessible path of travel" that is inside the room.

If you do need to make the balcony accessible, I've seen people set either pedestal pavers, or P.T. sleepers with a Trex deck on top, depending on what the existing structure can support as a dead load. Both systems allow stormwater to pass through (max. 1/4" gap between the pavers or Trex boards), and raise the walking / rolling surface to the same height as the unit interior.

Note that if you raise the deck level on an elevated balcony, you may also have to raise the balcony guardrail height for life-safety reasons.

 

[bill1952]

Can you confirm the main room is 5" above to the balcony? The examples I saw was a curb under slider but both floors at same elevation. All hollow core planks on block edge to edge.

 

[steveray]

All good advice but maybe Camilo disappeared?