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Does 208.2 word "facility" imply an accessible for every unique parking label?

Yikes

SAWHORSE
Joined
Nov 2, 2009
Messages
3,485
Location
Southern California
Parking lot at a public housing development has gated parking reserved for each dwelling unit. In addition to resident parking, outside the gates there are 25 parking stalls labeled as follows:
  • Guest Parking Only
  • Reserved for Future Residents [aka leasing office business parking]
  • Reserved - Staff
  • Reserved - Maintenance
There are some stalls that have no "reserved / only" markings, meaning they can also be used by residents. Of these unmarked stalls, one is and ADA van stall, and the other is an ADA standard stall.

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QUESTION: Since each of the "reserved / only" means that only specific types of users can park there, is each of the categories above considered a unique type of "facility" in 208.2?... IOW, does each type also need its own (van) accessible parking space? Do I also need a van space for guests, another van space for leasing office business, a van space for management staff, and a van space for maintenance staff?

If I don't provide these, but only provide non-reserved ADA spaces for use by everyone, am I discriminating against (for example) a leasing office employee who drives an accessible van because they now have to fight for parking with all other user types, whereas the able-bodied employee gets to use spaces reserved for employees?
 
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