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Do I need an elevator?

How about a platform lift instead of an elevator?

A platform lift is permissible under FBC-Accessibility Section 206.7.

206.7 Platform Lifts

Platform lifts shall comply with 410. Platform lifts shall be permitted as a component of an accessible route in new construction in accordance with 206.7. Platform lifts shall be permitted as a component of an accessible route in an existing building or facility.
 
A note for the OP (@Scott F) - You have so far asked about ADA compliance. I'd note that as a church, you may find exemption under ADA. However, FL has its own Accessibility Code. I have been pulling references from the building, existing building, and accessibility codes. Even if exempt from ADA, these will apply.

ADA and Accessibility Codes are parallel, but often the State's accessibility code should meet or exceed ADA.
 
A note for the OP (@Scott F) - You have so far asked about ADA compliance. I'd note that as a church, you may find exemption under ADA. However, FL has its own Accessibility Code. I have been pulling references from the building, existing building, and accessibility codes. Even if exempt from ADA, these will apply.

ADA and Accessibility Codes are parallel, but often the State's accessibility code should meet or exceed ADA.
Newbie here, what does OP represent?

I truly appreciate everyone's input and the time you've invested to help out. We are preparing for a call with our local building official and will report back on their determination.
 
Newbie here, what does OP represent?

I truly appreciate everyone's input and the time you've invested to help out. We are preparing for a call with our local building official and will report back on their determination.
Original Poster
 
As others have noted, ADA Title III does not apply to churches. However, the International codes incorporate almost all of the ADA provisions and apply them to all buildings.
 
And I still believe that the 1000 sf floor is exempt from the accessible route requirement.

It may be. But the starting point in the code is that all new spaces shall be accessible. So to determine that it's not required to be accessible, you have to find a specific provision in the code that makes it exempt.

An important consideration is whether it's a mezzanine or a story. I still haven't seen anything to convince me that it in any way qualifies as a mezzanine, so I think it's a story. And we still haven't been told how many stories the building has. In short -- we don't have enough information to answer the question.
 
And I still believe that the 1000 sf floor is exempt from the accessible route requirement.
And I believe the word "aggregate" is in there.....

The area we would be working on is 3,088 square feet. While there are existing elevators in the building, they wouldn't be able to service this new space.
 
And I believe the word "aggregate" is in there.....
The new floor level that we are creating in this space is unique and does not align with any other floors in the building, served by the existing elevators.

Do you aggregate two floor plates not near each other in plan nor section as the same story?

In buildings with assembly seating and used for presentations, floor plates in different parts of the building frequently don't align. A stair or elevator in one part of the building may serve floors 1, 3, and 5, whereas in another part 1, 2, 4, and 6. And who knows what story a seating bank is on that spans between floors 2 and 5.

It was a big problem with early accessibility requirements that assumed floors stacked up on atop another.

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Do you aggregate two floor plates not near each other in plan nor section as the same story?

In buildings with assembly seating and used for presentations, floor plates in different parts of the building frequently don't align. A stair or elevator in one part of the building may serve floors 1, 3, and 5, whereas in another part 1, 2, 4, and 6. And who knows what story a seating bank is on that spans between floors 2 and 5.

It was a big problem with early accessibility requirements that assumed floors stacked up on atop another.

View attachment 12771
Seems pretty clear to me if it is a mezz(s)...

1103.2.16 Mezzanines


Mezzanines having fewer than 3,000 square feet (278.7 m2) of gross floor area, either singly or in the aggregate for multiple mezzanines on any floor,

I don't design the buildings...I just tell those who do what they are doing wrong.....
 
The proposed upper level would have to be a second story instead of a mezzanine because it the existing floor is subdivided into several smaller spaces. It would be limited to 1/3 of the area of the space it opens into.

Since ADA Title III does not apply to churches, they could request a code modification of 1104.4 to allow this a small portion of the second floor that is separated from the rest of the accessible second floor to not have an accessible route to it.

Another possibility is1104.4 exception 4, as long as it's a 2 story building and the floor is no more than 750 SF (5 occupants at 150 SF).

In any case, they have to make reasonable accommodations for disabled people. A disabled employee would have to be given an office on an accessible level, and somebody working in the new upper level would have to come down to the conference room to meet with a disabled person.
 
Yes. Any story or mezzanine not on the level of accessible access is included in calculating the aggregate area.
Well, I thought the exception applied to the aggregate of the inaccessible areas. And it does according to the ICC staff person I work with often.

"Aggregate is the mezzanines and stories that don’t have an accessible route to them. You do not count any levels that do have a route to them."

Maybe I misunderstood you classicT or maybe I misunderstood the OP, but I thought he proposed a 1000 SF floor - a story - be inaccessible but the rest of the building, including at least a second story was accessible. So it would comply.

So did I misunderstand or were you aggregating all of the floors and mezzanines to say this small floor did not fit in the exception?

In any case, they have to make reasonable accommodations for disabled people. A disabled employee would have to be given an office on an accessible level, and somebody working in the new upper level would have to come down to the conference room to meet with a disabled person.
I agree this is needed to not discriminate.
 
Seems pretty clear to me if it is a mezz(s)...

1103.2.16 Mezzanines


Mezzanines having fewer than 3,000 square feet (278.7 m2) of gross floor area, either singly or in the aggregate for multiple mezzanines on any floor,

I don't design the buildings...I just tell those who do what they are doing wrong.....
Just to address this, even thought it seems certain the op is not talking about a mezzanine, the interp I get is:

"If you have two mezzanines, both 2,000 sq.ft., you have to provide an accessible route to only 1. Once you get a route to one mezzanine, the total in the building is less than 3,000 sq.ft."

I believe the "aggregate" includes only the inaccessible mezzanines, not all mezzanines, accessible or not.
 
Just to address this, even thought it seems certain the op is not talking about a mezzanine, the interp I get is:

"If you have two mezzanines, both 2,000 sq.ft., you have to provide an accessible route to only 1. Once you get a route to one mezzanine, the total in the building is less than 3,000 sq.ft."

I believe the "aggregate" includes only the inaccessible mezzanines, not all mezzanines, accessible or not.
Did you get a formal interpretation, or verbal?
 
Verbal (an email) from an ICC staff person I know through Access Board hearings and ICC A117.1 meetings since late 1990s.

I'm going to follow up with the access board and some others. I'm a little shocked that anyone would include accessible areas in the aggregate, especially from people who are as erudite and conscientious as this group. Clearly, whichever the intent is, it needs to be more clearly written. On my list for end of 2026 to submit a change proposal for the 2030 IBC - if I'm still around. :) Not promising to make it to 80 (but trying).
 
It is our professional opinion that vertical accessibility should always be provided. At the same time, it is our responsibility to present the owner with various options and potential exceptions, should they exist. I also plan to seek advice from our local building official for their input.
Our local building department has communicated that the only exception they will acknowledge is the third exception under the Vertical Accessibility section (201.1.1) of the 2023 Florida Building Code/Accessibility.

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