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Exterior renovations & IEBC 705.2 Alterations affecting an area containing a primary function

The primary function cannot be performed if the environmental envelope is not intact which it wouldn't be given the scope of reconstruction proposed. Stop trying to "dodge" the intent of the ADA! Nothing is achieved by allowing a non-compliant use to continue.
Not sure if you were directing your comment to me or others, but I don’t think the intent is to dodge the ADA, but rather to put the barrier removal where it actually belongs. I don’t think it needs to be tied to the project that Tim is either working on or reviewing. Compliance with the ADA is separate from building code compliance, although there are aspects of accessibility tied to building codes, I don’t believe the project as presented warrants accessibility upgrades to the extent implied by the interpretation made—thus, barrier removal should not be a condition of the permit.

That said, it does not relieve the owner from complying with the ADA, which does require barrier removal, and people have had almost 30 years to do it. If the building is not compliant with the ADA and the owner has completed several construction projects without any projects for barrier removal since January 1992, the DOJ will look upon that negatively should a complaint be filed.
 
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