Steps on Grade in Exit Discharge

[RLGA]

I have an interesting dilemma. Regarding one of the building's exits, the occupants must egress through a path (essentially an egress court that is less than 10 feet wide) between the building and an adjacent property to reach the public way--no problem (1-hour wall protection is provided at the building and at the lot line). However, there is a significant grade change that cannot be handled via a gentle slope (1:20 or less) of the walkway, so a set of steps or a ramp is necessary.

However, in the section on exit discharge, it states in 1027.3 (2009 IBC) for exit discharge locations that "exterior balconies, stairways and ramps, shall be located at least 10 feet (3048 mm) from adjacent lot lines..."

The section does not use the term exterior exit ramps or exterior exit stairways that are used in Section 1026, but Section 1026.5 states that exterior exit ramps and stairways shall meet the location requirements of Section 1027.3. This leads me to believe that Section 1027.3 is only referring to exterior exit ramps and stairways and not steps that are a part of the exit discharge.

It seems silly to create an "exit enclosure" just for these stairs or ramps just so it can be adjacent to a lot line.

How do others interpret this section? Do you require that all steps that are part of an exit discharge be 10 feet away from the lot line?

 

[RLGA]

Just for kicks, I looked at my copy of the 2012 IBC (I should have looked there before posting) and found that the location requirements in Section 1027 was deleted and were incorporated into Section 1026.5, which makes it more definitive that steps that are a part of the exit discharge are not subject to the same location limitations.

But, my question still stands regarding earlier editions of the IBC. Have you seen jurisdictions use the conservative interpretation of that requirement by applying it to any stairs, even if they are part of the exit discharge?