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Does an Alteration trigger the need for path to street?

Discussion in 'Accessibility' started by nealderidder, Oct 8, 2019.

  1. nealderidder

    nealderidder Bronze Member

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    I'm working on a TI in an existing building. It's a big TI, includes the entire two floors of the building. This is in California.

    CBC 11B-206.2.1 calls for an accessible route from the building to the street. It notes "at least one".

    CBC 11B-202.4 tells me that in an alteration I'm only required to provide a path of travel to altered elements from the primary entrance to the building. It would appear that my TI wouldn't trigger the need for an accessible route to the street. Am I right?
     
  2. ADAguy

    ADAguy Sawhorse

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    If not, then how is one to approach and enter the building if not by an accessible POT? especially if the building is not presently served by one?
    (there I go being logical?)
     
  3. JPohling

    JPohling Sawhorse

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    That POT from the public sidewalk is often not achievable in an existing building that was constructed prior to this requirement. Is this a change in use? You will need to provide a compliant POT from the accessible parking area serving your suite.
     
  4. mark handler

    mark handler Sawhorse

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    11B-202.4 Path of travel requirements in alterations, additions and structural repairs
    When alterations or additions are made to existing buildings or facilities, an accessible path of travel to the specific area of alteration or addition shall be provided.
    The primary accessible path of travel shall include:
    1. A primary entrance to the building or facility,
    2. Toilet and bathing facilities serving the area,
    3. Drinking fountains serving the area,
    4. Public telephones serving the area, and
    5. Signs.

    Chapter 2 Definitions
    PATH OF TRAVEL. An identifiable accessible route within an existing site, building or facility by means of which a particular area may be approached, entered and exited, and which connects a particular area with an exterior approach (including sidewalks, streets and parking areas), an entrance to the facility, and other parts of the facility. When alterations, structural repairs or additions are made to existing buildings or facilities, the term “path of travel” also includes the toilet and bathing facilities, telephones, drinking fountains and signs serving the area of work.
     
  5. mark handler

    mark handler Sawhorse

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    Technically infeasible. In alterations, where the enforcing authority determines compliance with applicable requirements is technically infeasible, the alteration shall provide equivalent facilitation or comply with the requirements to the maximum extent feasible. The details of the finding that full compliance with the requirements is technically infeasible shall be recorded and entered into the files of the enforcing agency.
     
  6. JPohling

    JPohling Sawhorse

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    In California I have also used 11B-206.2.1 exception 2. "An accessible route shall not be required between site arrival points and the building or facility entrance if the only means of access between them is a vehicular way not providing pedestrian access."
     
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  7. mark handler

    mark handler Sawhorse

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    But if there is any pedestrian access, Accessible or not, you can not use this.
     
  8. Yikes

    Yikes Gold Member

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    I have a related question. I am doing a T.I for a religious organization in California on a project that has its own parking garage. It was approved by the AHJ 10 years ago with two accessible stalls, but only the van stall has a POT that does not go behind another vehicle; the other accessible stall goes behind the van stall.

    Q: Since I can comply with POT for all things except access stall #2, should just the one van stall be sufficient for satisfying 11B-202.4?
     
  9. ADAguy

    ADAguy Sawhorse

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  10. Yikes

    Yikes Gold Member

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    (I reference that it is a religious organization to note their exemption from ADA lawsuits; this is purely a CBC -11B compliance issue for the remodel, on a parking lot already approved by the AHJ several years ago.)
     
  11. north star

    north star Sawhorse

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    # ~ #
    IMO, ...Yes, you have satisfied the Accessibility POT.......In your jurisdiction, is there a
    precedent for having an Accessible POT for "all" Accessible Parking Spaces, or is it a
    "Gray Area" to be determined by the AHJ ?


    # ~ #
     
  12. JPohling

    JPohling Sawhorse

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    Agreed!
     
  13. mark handler

    mark handler Sawhorse

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    IMHO, No. But that is up to the AHJ and the CASp.
     
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  14. ADAguy

    ADAguy Sawhorse

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    Careful MH, CASps can only opinion unless they are an AHJ. Theirs is a "voluntary" certification, overseen by the state.
     
  15. mark handler

    mark handler Sawhorse

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    Certification, Which is recognize by the courts.
     
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  16. ADAguy

    ADAguy Sawhorse

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    Accepted by state but up to feds to accept or reject.
     
  17. Yikes

    Yikes Gold Member

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    I agree, Mark. But when it comes to being a sounding boards on accessibility questions on this forum, you are analogous to "Mikey" in the old Life Cereal commercials: if I can get you to 'like' something, chances are good that most everyone else (incl. AHJ and CASp) will eventually 'like' it too.
    (And I seriously mean this as a major compliment to you!)
     

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