Do facade improvments trigger accessibility upgrades?

[Yikes]

A California town is proposing facade improvements to existing buildings in a redevelopment area (gotta spend that money before Jerry Brown takes it away!). I was asked whether facade improvements would trigger accessibility upgrades to the buildings per title 24, CBC 1134B. Here's my initial opinion, and I welcome your critique:

1. In general, facade improvements are not within the occupied portion of the building; they are exterior features, viewed from a distance (e.g. new rooflines, decorative parapets, columns, overhangs, signage, equipment screens, exterior lighting, etc.). So there is NO path-of-travel to the "specific area of alteration", so there is no Title 24 trigger for any accessibility improvements, except as noted in #2-4 below.

2. If the facade improvements include any substantive (i.e., more than painting) changes to any entry or exit doors on the facade, those entry/exits should be made accessible per 1134B.2.1. However, making those doors accessible will not cause/trigger other accessibility upgrades (CBC 1134B.2.1 exc. #3). The extent of "accessibile entry" would stop after creating an accessible landing on each side of the entry; it would not continue further into the tenant space past the 4' or 5' landing area.

3. If these facade improvements include any work to a parking lot or path-of-travel (repaving the lot, putting in decorative walkway paving), then those improvements should be made accessible. I assume that restriping a lot would trigger accessible parking striping and signage, and repaving may trigger re-grading for accessible parking.

4. ADA is a completely separate issue, and needs to be addressed by each building owner and tenant regardless of the facade improvement program.

 

[rshuey]

Typically, if the improvements are cosmetic, signage, etc it would not trigger any accessibility improvements. However, if they get into structural, means of egress, etc kind of work, the IEBC calls for 20% of the cost to go towards achieving ADA compliance.

 

[mark handler]

Does the value exceed the present code threshold of (+/-) $160,000? If not then 20% up to that amount.

Does the upgrade exceed (+/-) $160,000? If so, 100% compliance.

 

[Yikes]

mark, I appreciate the input. Let's take it for a test drive:

Pretend for the moment that I decided to take the existing stucco facade and overlay the existing roof cornice with gold leaf panels at a cost of $1 million. I've done no work inside the building, and the area of alteration is not accessible to humans, just birds.

CBC 1134B.2, "Accessibility For Exisiting buildings - General" says "these requirements shall apply only to the area of specific alteration..."

So, how does this trigger ANY accessibility upgrades at all, even if there's lot of money floating around?

 

[mark handler]

You might want to read the DSA INTERPRETATION's

Interpretation Number: 1-07 DSA/AC

http://www.documents.dgs.ca.gov/dsa/pubs/AccessCodeAppeals_rev01-01-11.pdf

 

[mark handler]

Projects consisting exclusively of the following work shall not trigger

accessibility requirements in existing buildings and facilities

provided the work does not affect accessibility or usability of

building or facility:

Heating

Ventilation

Air conditioning

Reroofing (non-structural)

Electrical work not involving placement of switches or outlets

Cosmetic work not affecting items regulated by the California

Building Code (e.g., painting, office equipment)

CBC 1134B.2.1(4)

 

[Yikes]

Mark, that is a really useful link! I knew you would have something on this. I appreciate your generally conservative approach to these issues.

The interpretation says: "The ordinary dictionary meaning of cosmetic is decorative rather than functional, ornamental, beautifying, done for the sake of appearance, and serving an aesthetic rather than a useful purpose."

That sounds like the exact definition of "facade renovation", EXCEPT where such exteriorrenovations touch a "useful" part (doorway, walkway) of the building.

On the other hand (and in support of your argument), the list above includes "reroofing (non-structural)". They make a distinction that when you touch the structure of the roof, you've crossed the line and accessibility issues apply, even though there will be no "path to the specific area of alteration". So the key point is its percieved usefulness to make the building work as a building, e.g., the shell (wall strucutre and roof), the core (basic stuff required for occupancy as defined in the CBC). Drywall, tape and mud that is used to create a rated wall or any wall that would be plan-checked would trigger T-24 accessibility upgrades. Putting wallpaper on that wall would not.

Facade renovations may be finish material only (non-structural), but if my gold-leaf cornice panels provided additional structure or enclosure, they would trigger T-24. Do you agree with that statement.

 

[mark handler]

The text "...(permits) Consisting exclusively of..."

and the text "...Cosmetic work not affecting items regulated by the California Building Code..."

Would exclude "most" if not all "facade" improvements.

As a licensed Architect, I always recommend accessibility improvements to all my clients.

 

[Gene Boecker]

Exactamundo!

If its cosmetic, put on the Beatles and start singing "Let it be, let it be, let it be, oh, let it be. . . . "

(whispered words of wisdom)