CBC 1109A accessible parking - no stall height specified?

[Yikes]

I know the subject was briefly touched upon elsewhere a few years ago, but I just want to make sure. I have a developer client that wants to put storage cabinets and even a portion of the over the front of the accessible parking stalls in a common-use subterranean parking garage serving private housing. He says there is nothing in CBC 11A that requires the accessible stalls to have the usual 8'-2" headroom.

As I read it, neither CBC 1109A (for private housing) nor FHA have any requirements for minimum (non-van) accessible parking stall height, nor for the loading/unloading access aisle. CBC 1109A.8.1 has 8'-2" vertical clearance requirements for the "entrances, exits, vehicular passageways to and from required accessible spaces", but it is totally silent on height at the stalls and loading/unloading aisle.

FHA is mostly silent on the subject of standard accessible stall heights, but offers conflicting advice on accessible van stall heights:

• The 1998 FHA Design Manual page 2.25 says: "Neither the Guidelines nor ANSI give specifications for vertical clearance in parking garages or other sheltered parking to accommodate vans".
• On the other hand, FHADM page 2.20 says "Accessible parking spaces must meet the requirements for parking in ANSI 4.6...". I don't know what ANSI 4.6 said when the FHADM was published in 1998, but the version that I can find online says: "At parking spaces complying with 4.1.2(5)(b), provide minimum vertical clearance of 98 in (2490 mm) at the parking space and along at least one vehicle access route to such spaces from site entrance(s) and exit(s)." Current ANSI 4.1.2(5)(b) specifically references van stalls: "One in every eight accessible spaces, but not less than one, shall be served by an access aisle 96 in (2440 mm) wide minimum and shall be designated "van accessible" as required by 4.6.4. The vertical clearance at such spaces shall comply with 4.6.5."

Is there anything in either CBC 11A or in FHA that definitively compels either private housing van accessible stalls or non-van accessible stalls to have more headroom than the minimum 7'-6" found in CBC 1207.2?

 

[e hilton]

2010 ADA 502.5 says “parking spaces for vans and access aisles and vehicular routes serving them shall provide a vertical clearance of 98 inches”.

502.2 says “car parking spaces … shall have an adjacent access aisle”.

That seems pretty clear, if it applies to your location.

 

[ADAguy]

2010 ADA 502.5 says “parking spaces for vans and access aisles and vehicular routes serving them shall provide a vertical clearance of 98 inches”.

502.2 says “car parking spaces … shall have an adjacent access aisle”.

That seems pretty clear, if it applies to your location.

Is a vehicular Route inclusive of the accessible space?

 

[Yikes]

2010 ADA 502.5 says “parking spaces for vans and access aisles and vehicular routes serving them shall provide a vertical clearance of 98 inches”.

502.2 says “car parking spaces … shall have an adjacent access aisle”.

That seems pretty clear, if it applies to your location.

I agree that ADA says this, and ADA would apply to public housing and/or public parking.
But this project is private, market rate apartments, and the parking is only for residents, so only CBC 1109A and FHA apply, not ADA.

Is a vehicular Route inclusive of the accessible space?

ADAguy, I like your thinking on this, in that the vehicle most move into the space in order to park in it, so the space itself might be considered at part of a "route". But the 2 issues I have with this approach are:

• If the authors of the code really intended this, why didn't they explicitly include the words "accessible parking" in 1109A.8.1? Otherwise I'm like Michel Foucault, trying to discern what the author is saying based on what the author is NOT saying.
• That still allows the loading/unloading aisle to be less than 8'-2" clear, since this aisle is explicitly marked "no parking" and is thus not a vehicular route.

 

[ADAguy]

Watch how folks approach and park, they often "drift" when doing so. Best practice to maintain the height but technically not called for. 80" min, for projections.

 

[Jean Tessmer-HI]

I know the subject was briefly touched upon elsewhere a few years ago, but I just want to make sure. I have a developer client that wants to put storage cabinets and even a portion of the over the front of the accessible parking stalls in a common-use subterranean parking garage serving private housing. He says there is nothing in CBC 11A that requires the accessible stalls to have the usual 8'-2" headroom.

As I read it, neither CBC 1109A (for private housing) nor FHA have any requirements for minimum (non-van) accessible parking stall height, nor for the loading/unloading access aisle. CBC 1109A.8.1 has 8'-2" vertical clearance requirements for the "entrances, exits, vehicular passageways to and from required accessible spaces", but it is totally silent on height at the stalls and loading/unloading aisle.

FHA is mostly silent on the subject of standard accessible stall heights, but offers conflicting advice on accessible van stall heights:

• The 1998 FHA Design Manual page 2.25 says: "Neither the Guidelines nor ANSI give specifications for vertical clearance in parking garages or other sheltered parking to accommodate vans".
• On the other hand, FHADM page 2.20 says "Accessible parking spaces must meet the requirements for parking in ANSI 4.6...". I don't know what ANSI 4.6 said when the FHADM was published in 1998, but the version that I can find online says: "At parking spaces complying with 4.1.2(5)(b), provide minimum vertical clearance of 98 in (2490 mm) at the parking space and along at least one vehicle access route to such spaces from site entrance(s) and exit(s)." Current ANSI 4.1.2(5)(b) specifically references van stalls: "One in every eight accessible spaces, but not less than one, shall be served by an access aisle 96 in (2440 mm) wide minimum and shall be designated "van accessible" as required by 4.6.4. The vertical clearance at such spaces shall comply with 4.6.5."

Is there anything in either CBC 11A or in FHA that definitively compels either private housing van accessible stalls or non-van accessible stalls to have more headroom than the minimum 7'-6" found in CBC 1207.2?

Yikes, originally Congress gave HUD the 1986 ANSI A117.1 standard to use with the 1991 FHAG and the 1994 supplement to the FHA - These regulations coupled together are one of the safe harbors HUD allows you to choose to produce FHA compliant adaptable housing.
The following is a part the the appendix to the 1986 ANSI A117.1. It alerts you to needing higher clearances for vans.
A4.6 Parking Spaces and Passenger Loading Zones
A4.6.2 Parking Spaces. High-top vans, which physically handicapped people or transportation services often use, require higher clearances in
parking garages than automobiles. If parking spaces are provided for vans, a wider access aisle may be needed for the side lift. A side lift that loads perpendicular to the van may require an aisle that is 96 in (2440 mm) wide.
Signs designating parking places for physically handicapped people can be seen from a driver's seat if the signs are mounted high enough above the ground and located at the front of a parking space.
The following is from the 1986 ANSI on Parking with references looking to the appendix for more information.
4.6 Parking Spaces and Passenger Loading Zones
4.6.1 General. Accessible parking spaces shall comply with 4.6.2. Accessible passenger loading zones shall comply with 4.6.3.
Parking spaces designated for physically handicapped people and accessible passenger loading zones that serve a particular building shall be located on the shortest possible accessible circulation route to an accessible entrance of the building. In separate parking structures or lots that do not serve a particular building, parking spaces for physically handicapped people shall be located on the shortest possible circulation route to an accessible pedestrian entrance of the parking facility.
4.6.2* Parking Spaces. Parking spaces for physically handicapped people shall be at least 96 in (2440 mm) wide and shall have an adjacent access. *See Appendix for additional information.

HUD allows the designer and contractor to choose the any safe harbor to use but HUD and the DOJ are the enforcers.

 

[ADAguy]

Now if the same were true for the ADA we would be good too.

 

[Yikes]

Yikes, originally Congress gave HUD the 1986 ANSI A117.1 standard to use with the 1991 FHAG and the 1994 supplement to the FHA - These regulations coupled together are one of the safe harbors HUD allows you to choose to produce FHA compliant adaptable housing.
The following is a part the the appendix to the 1986 ANSI A117.1. It alerts you to needing higher clearances for vans.
A4.6 Parking Spaces and Passenger Loading Zones
A4.6.2 Parking Spaces. High-top vans, which physically handicapped people or transportation services often use, require higher clearances in
parking garages than automobiles. If parking spaces are provided for vans, a wider access aisle may be needed for the side lift. A side lift that loads perpendicular to the van may require an aisle that is 96 in (2440 mm) wide.
Signs designating parking places for physically handicapped people can be seen from a driver's seat if the signs are mounted high enough above the ground and located at the front of a parking space.
The following is from the 1986 ANSI on Parking with references looking to the appendix for more information.
4.6 Parking Spaces and Passenger Loading Zones
4.6.1 General. Accessible parking spaces shall comply with 4.6.2. Accessible passenger loading zones shall comply with 4.6.3.
Parking spaces designated for physically handicapped people and accessible passenger loading zones that serve a particular building shall be located on the shortest possible accessible circulation route to an accessible entrance of the building. In separate parking structures or lots that do not serve a particular building, parking spaces for physically handicapped people shall be located on the shortest possible circulation route to an accessible pedestrian entrance of the parking facility.
4.6.2* Parking Spaces. Parking spaces for physically handicapped people shall be at least 96 in (2440 mm) wide and shall have an adjacent access. *See Appendix for additional information.

HUD allows the designer and contractor to choose the any safe harbor to use but HUD and the DOJ are the enforcers.

Jean, I don't see anything in the sections you cited above that prescriptively state a minimum headroom for vans. It says "higher clearances...than automobiles", but it doesn't say how much higher. Do you know if the ANSI appendix states a minimum height?

 

[Jean Tessmer-HI]

Yikes you are correct the 1986 does not state the height. The letter "A" before the 4.6 refers to the appendix. As you can see the Appendix just say higher but not how high.

The CABO/ANSI A117.1 - 1992 does contain van stall height.
All ANSI A117.1 Standards starting with the 1986 were considered safe harbors by HUD as long as you used them with the 1991 FHAG and the 1994 Supplement to the FHA. However if you decide to use the 1992 ANSI A117.1 you will need to stick with it throughout your project.
I believe the 1992 ANSI standard was the first version that contained the van vertical height.
Here is the citation:

4.6.4* Van Parking Space. Accessible parking spaces for vans used by persons with disabilities shall have a height of 98 in (2490 mm) minimum at
the space and along the vehicular route thereto and shall have an access aisle 96 in (2440 mm) wide minimum.

You can look up HUD's FHAG safe harbors to see the list. To me all the different safe harbor standards (I think we are up to 16 now) just makes figuring out how to comply with FHAG, more confusing. Essentially HUD says you have the choice to stick with the 1986 ANSI A117.1, 1991 FHAG, and 1994 Supplement as handed down to HUD from Congress, makes figuring out adaptable housing much less confusing. They say you also have the choice to depart in some instances if you can prove it is from a know established recognized accessibility standard.

HUD will not penalize you for using the 1992 height. You can say you augmented the 1986 with the 1992 clarification of van stall clear heights and can prove that you choice came from a source HUD recognizes.