Do you count accessible units in 20% valuation? CBC 202.4

[Yikes]

When doing improvements on a public housing project, I see at least 2 "triggers" of mandatory accessibility improvements:

1. INSIDE THE DWELLING UNITS: This is purely scope-based, not money-based. You can spend $2k or $200k on dwelling unit alterations and neither triggers accessibility upgrades (other than the alteration itself being accessible per 202.3). However, the moment you substantially alter a kitchen or bath and at least one other space, then dwelling unit full accessibility gets triggered. See 202.4 exception #1.

2. OUTSIDE THE DWELLING UNITS: This is money-based, not scope based. You must provide a full path-of travel to the area of alteration, and spend at least 20% of the adjusted construction cost to do so. See 202.4 exception #8.

QUESTION: When you have alterations both inside AND outside the units, is the adjusted construction in 202.4 exception #8 excluding not only the cost of accessibility improvements outside of the units, but also all the costs of all altrations inside the dwelling units (because they are already scoped under exception #1)?

 

[Yankee Chronicler]

What type(s) of exterior alterations are subject to accessibility upgrades?

 

[mark handler]

What type(s) of exterior alterations are subject to accessibility upgrades?

Path of travel.
Parking
Exterior amenities....POT and Access.

 

[mark handler]

IMPO the alteration, the alterations to the path of travel during the preceding three-year period shall be considered in determining the cost....

 

[Yikes]

IMPO the alteration, the alterations to the path of travel during the preceding three-year period shall be considered in determining the cost....

I agree, but my question is, since 202.4 treats dwelling units (exc. #1) separately, does that mean any work inside the dwelling units should be excluded from the “adjusted construction cost” valuation?