When do facade alterations trigger POT improvements (CBC 11B-202)

[Yikes]

Existing office building has built-in planters, canopies and stone veneer on its facade. Owner is renovating the facade to remove the planters (replacing with river rock), alter the canopies to a more modern look, and replace stove veneer with smooth plaster.

CBC 11B-202.4 requires path of travel improvements "when alterations... are made to existing buildings or facilities".
But are the kinds of alterations described above exempt from path-of travel requirements?

Logic: the "altered area is an exterior aesthetic improvements, out of reach of the public elevated planters, exterior wall finishes, decorative canopies". The is no path of travel to the area of alteration. It is "cosmetic work that does not affect items regulated by this code". Likewise there is nothing in 11B that requires decorative planters, canopies or plaster to be accessible.

 

[steveray]

Exterior finishes shouldn't really be in the route/ primary function or affect it....But it does get muddy

 

[Yankee Chronicler]

I'm not in California so I won't claim to know what California has done to the IEBC but, in general, there are two things we keep in mind: First, "alteration" is defined in the IEBC:

ALTERATION. Any construction or renovation to an
existing structure other than a repair or addition

The description doesn't appear to affect the "structure."

Next up, the provisions in the IEBC calling for accessibility upgrades, as noted by steveray, only apply when altering an area containing a primary function. When delving into the Work Area method of IEBC compliance, we find that "alteration" only applies when moving, removing, or adding walls, doors, and/or windows. Removing and replacing finishes doesn't constitute and alteration and doesn't trigger accessibility upgrades.

The proposed work isn't even inside the building. If there is NO path of travel in the affected area, I don't see how even California could construe that the require accessibility upgrades.

 

[Joe.B]

Considering the section you quoted is in 11B-202.4 Exception 7, I'd say not required.

"...cosmetic work that does not affect items regulated by this code..."

What's the valuation of the proposed improvements? Many local jurisdictions have capital improvement thresholds, so they could potentially require improvements to the public ROW based on that.

 

[ICE]

require improvements to the public ROW based on that

I required a chain coffee shop replace twenty feet of busted sidewalk. They were not happy about it however, they complied. Some time later I found out the city public works director was upset. He complained to the city manager. The city manager thanked me.

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[Yankee Chronicler]

I required a chain coffee shop replace twenty feet of busted sidewalk. They were not happy about it however, they complied. Some time later I found out the city public works director was upset. He complained to the city manager. The city manager thanked me.

"That's union work!"

 

[arwat23]

Exterior finishes shouldn't really be in the route/ primary function or affect it....But it does get muddy

Route to primary function is not really a thing in CA. I know it is for other states, but in CA, if an alteration or addition is being done, regardless of location, as defined (with some exceptions), path of travel improvements are required.

 

[steveray]

Route to primary function is not really a thing in CA. I know it is for other states, but in CA, if an alteration or addition is being done, regardless of location, as defined (with some exceptions), path of travel improvements are required.

So it sounds like you take something like this quite literally and nothing is infeasible:

306.7 Alterations​

A facility that is altered shall comply with the applicable provisions in Chapter 11 of the International Building Code,ICC A117.1 and the provisions of Sections 306.7.1 through 306.7.16, unless technically infeasible.

 

[arwat23]

So it sounds like you take something like this quite literally and nothing is infeasible:

306.7 Alterations​

A facility that is altered shall comply with the applicable provisions in Chapter 11 of the International Building Code,ICC A117.1 and the provisions of Sections 306.7.1 through 306.7.16, unless technically infeasible.

That section is not adopted by DSA-AC and is not applicable to California. CA used the 2010 ADAS as the reference code, not ICC A117.1, and amends ADAS to eliminate the "primary function" language when determining path of travel improvements.

Technical infeasibility still exists, as does a 20% adjusted cost of construction valuation threshold (CBC 11B-202.4, exception 8). All I was saying is that the state of California (what this post is referencing) doesn't determine path of travel improvement requirements the same way most other states do. Primary function has no impact on if improvements are required or not in California. If an improvement is being done, regardless of the improvement type or location (with some exceptions), path of travel improvements must be undertaken. The project originally mentioned in this post seems to apply for one of the exceptions imo.

Edit: Yes, we like to make things complicated in CA. IBEC basically has no impact in the state when it comes to ADA accessibility. Why? Don't ask me lol. I also now realize that I worded my previous comment VERY poorly. My apologies for that.

 

[JPohling]

I agree with Arwat23 regarding California

 

[steveray]

That section is not adopted by DSA-AC and is not applicable to California. CA used the 2010 ADAS as the reference code, not ICC A117.1, and amends ADAS to eliminate the "primary function" language when determining path of travel improvements.

Technical infeasibility still exists, as does a 20% adjusted cost of construction valuation threshold (CBC 11B-202.4, exception 8). All I was saying is that the state of California (what this post is referencing) doesn't determine path of travel improvement requirements the same way most other states do. Primary function has no impact on if improvements are required or not in California. If an improvement is being done, regardless of the improvement type or location (with some exceptions), path of travel improvements must be undertaken. The project originally mentioned in this post seems to apply for one of the exceptions imo.

Edit: Yes, we like to make things complicated in CA. IBEC basically has no impact in the state when it comes to ADA accessibility. Why? Don't ask me lol. I also now realize that I worded my previous comment VERY poorly. My apologies for that.

No worries....I am not likely to ever work in Cali, but I do like to understand how things got to where they are....I did not mean YOU personally in post 8, I meant you in the "royal" California sense....