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Where does 5% mobilty accessible apply on a mixed public+private project?

Y

Yikes

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Southern California
A private developer builds 200 unit housing project.
100 units designated lower-income and are provided with project-based rental vouchers from a local Housing Authority and are considered "public housing".​
The other 100 units are market-rate and are privately funded.​
CBC 11B / ADAS 233.3.1 requires a minimum of 5% of the units to be mobility accessible.
  • How many units need to be 11B/ ADA mobility accessible: 5 units, or 10?
  • Or to put it another way, on a mixed public+private development, does the 5% rule apply only to the # of units with project-based vouchers, or does it apply to all the units on the site?
(This question is not about 11A or FHA, which is a separate subject - -it's purely about ADA.)
 
Is this one site with lower-income units dispersed among market rate units, with all sharing the common spaces? Is there any other public assistance vouchers?
 
Jay Smith said:
Is this one site with lower-income units dispersed among market rate units, with all sharing the common spaces? Is there any other public assistance vouchers?
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I should’ve proofread one more time. Is there any other public assistance besides the vouchers?
 
I'm dealing with a "Homekey" project where they are converting a hotel to apartments. The specifics of the homekey program require a higher number of fully accessible units, and vision/hearing impaired units. The program requires 15% Mobility Units, and 10% Hearing an Vision Units.

As far as your original question I think that's a tough one. Basically is it publicly funded or privately funded? Sounds like both. I have a book I reference once in awhile when looking for interpretations, so I grabbed it now. (CalDAG 2020) This says "If the project involves funding provided in whole or in part by any of the above entities, [(a) any state or local government; (b) any department, agency, special purpose district, or other instrumentality of a state or states or local government; and (c) the national railroad passenger corporation, and any commuter authority (as defined...)] then it must comply with title II of ADA." Then a bit later it references government code commencing with section 4450.

Obviously you want to dig deeper than that, but based on what I just read I would say because a portion of your project is publicly funded, all of it needs to meet the higher standard.
 
This is one site with 200 units. The 100 lower-income units with project-based vouchers are dispersed among the other 100 market-rate units.

To be really specific, the 200 units were originally developed as private market-rate condos, subject to FHA and CBC 11A.
The developer went bust right as the project construction finished, and another not-for-profit swooped in and bought the finished-but-unoccupied development with the idea of operating it all as mixed-income rental housing project (no condo sales). They've secured Section 8 vouchers for 100 of the units. I am certain the 100 project-based vouchers triggers a determination of "public housing" and ADA compliance.
There is no other public assistance besides the vouchers.

My main question is that since ADA requires 5% of the units to be accessible, is it
(a) 5% of just the 100 public housing units, or
(b) 5% of all 200 units, including the market-rate units?
 
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It sure seems like the rule means all residential dwelling units, not just the units that generated the public assistance.
 
Joe.B said:
New construction?
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Yes, it was built about 10 years ago and meets FHA and CBC 11A for condos.
The not-for-profit developer operated it for years as market-based rentals until they were able to secure the project-based vouchers.
It's just the post-construction PBV's that trigger UFAS/ADA compliance.

The problem is that 100% of the units are multistory townhomes and ADA 809.2.1 requires an accessible route throughout the unit. They may be able to get away with saying that an accessible route inside the unit is not "readily achievable barrier removal" for a 100% townhome development, but at some point in the next 10 years the units will eventually need renovation, and that's when "substantial alteration" in both ADA and CBC 11B will probably trigger a requirement to make some accessible ground-level flats.
 
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Yup, that's a jar of pickles... Keep us posted on what you learn, I am very interested. Thanks for sharing!
 
Joe.B said:
I'm dealing with a "Homekey" project where they are converting a hotel to apartments. The specifics of the homekey program require a higher number of fully accessible units, and vision/hearing impaired units. The program requires 15% Mobility Units, and 10% Hearing an Vision Units.

As far as your original question I think that's a tough one. Basically is it publicly funded or privately funded? Sounds like both. I have a book I reference once in awhile when looking for interpretations, so I grabbed it now. (CalDAG 2020) This says "If the project involves funding provided in whole or in part by any of the above entities, [(a) any state or local government; (b) any department, agency, special purpose district, or other instrumentality of a state or states or local government; and (c) the national railroad passenger corporation, and any commuter authority (as defined...)] then it must comply with title II of ADA." Then a bit later it references government code commencing with section 4450.

Obviously you want to dig deeper than that, but based on what I just read I would say because a portion of your project is publicly funded, all of it needs to meet the higher standard.
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FOR ONCE cALDAG GOT IT RIGHT,
 
I believe that as long as the privately funded units do not make use of any federal funds, they are not subject to UFAS or Fair Housing Standards. UFAS & Fair Housing both have accessibility requirements that do not completely align with ADA.
 
Chirstine is correct. Generally speaking, as long as there is no federal, state, or county funding (tax incentives included) there is no requirement for 5% of the residences to be accessible to the federal Uniform Federal Accessibility Standard (UFAS) and Section 504. However there may be more stringent local requirement in place, that you would need to apply if they are more stringent than the Fair House Act Guidelines (FHAG). Also be wary of the fact that UFAS is more stringent than ADA. Applying just the ADA to the 5% of a multi family residential project does not mean your off the hook from being investigated and sued by the DOJ under the FHAG. Its a bit complicated but this is a straight a shot, to answer your question. I hope this helps. Here is a good link that explains more about Section 504 and UFAS and ADAS. https://www.map-strategies.com/blog...504-compliance-using-2010-ada-instead-of-ufas
Here is a short excerpt from the link:
The Department of Housing and Urban Development (HUD) regulations for Section 504 can be found in the Code of Federal Regulations under Title 24, Part 8, Subpart C Program Accessibility § 8.32 Accessibility Standards (24 CFR Part 8). It is in this code that UFAS is listed as an acceptable design standard for Section 504 compliance.

In 2014, HUD issued a “deeming notice”, a rule change that allowed for an alternative accessibility code for Section 504. This notice was published in the Federal Register, which is the official journal of the federal government containing new rules, changes to existing rules and public notices. HUD’s notice can be found in Federal Register Volume 79, No. 100, Friday, May 23, 2014, under Docket No. FR-5784-N-01.

This notice permits recipients of federal assistance to use the 2010 ADA Standards as an accessibility standard for compliance with Section 504 and the regulations of 24 CFR Part 8. The notice does not remove the option for using UFAS, it can continue to be used if chosen. However, if it is decided to use UFAS, the project must comply with the 2010 ADAS and UFAS, depending on which code section from either code is stricter in its requirement.
 
Fyi-to me it is easier to just stick with the 1991 FHAG statutes, coupled with the 1994 supplement Q&A, and the required application of the ANSI A117.1 1986 as mandated by congress. I find it dizzying to try to figure out all the safe harbors that I am not allowed to pick and choose from without getting into trouble with DOJ and HUD. These three documents are the core congressionally approved FHAG objective criteria docs. The DM helps but has a lot of errors.
 
Yikes said:
A private developer builds 200 unit housing project.
100 units designated lower-income and are provided with project-based rental vouchers from a local Housing Authority and are considered "public housing".​
The other 100 units are market-rate and are privately funded.​
CBC 11B / ADAS 233.3.1 requires a minimum of 5% of the units to be mobility accessible.
  • How many units need to be 11B/ ADA mobility accessible: 5 units, or 10?
  • Or to put it another way, on a mixed public+private development, does the 5% rule apply only to the # of units with project-based vouchers, or does it apply to all the units on the site?
(This question is not about 11A or FHA, which is a separate subject - -it's purely about ADA.)
Click to expand...
Answer to this specific question:

Where does 5% mobilty accessible apply on a mixed public+private project?​

What do you mean by mixed private and public projects?
Do you mean that that is private and governmental public funding on the same project?

If there is any public funding at all, even one dollar (I was told by the DOJ), all needs to comply with FHAG (ground floor non-elevator dwellings or all for elevator connected dwellings). Beyond that you need to include the Uniform Federal Accessibility Standard (UFAS only for 5% of the housing with 2% for hearing and visual impaired which mean you need visual and audible alarms in those if alarms are being installed according to UFAS). My understanding is all outside areas for publicly funded projects are still controlled by the ANSI A117.1 1986.
 
Jean Tessmer-HI said:
Answer to this specific question:

Where does 5% mobilty accessible apply on a mixed public+private project?​

What do you mean by mixed private and public projects?
Do you mean that that is private and governmental public funding on the same project?

If there is any public funding at all, even one dollar (I was told by the DOJ), all needs to comply with FHAG (ground floor non-elevator dwellings or all for elevator connected dwellings). Beyond that you need to include the Uniform Federal Accessibility Standard (UFAS only for 5% of the housing with 2% for hearing and visual impaired which mean you need visual and audible alarms in those if alarms are being installed according to UFAS). My understanding is all outside areas for publicly funded projects are still controlled by the ANSI A117.1 1986.
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Thanks, Jean. Yes, I am aware of FHA requirements for private housing, which are expanded on here in California via CBC 11A.

But my question was specific to the more stringent requirements of CBC 11B, ADA, and for that matter we can throw in UFAS too.
The specific question is, if only 100 out of the 200 units were touched by public funds, does 5% mobility accessible mean 5 units out of 100? or 10 units out of 200?

I recently had another rehab project where the 1- and 2-bed units were UFAS, but the market rate studio lofts were privately funded. The ADA deeming notice requires dispersion among the various types of units in the development. Imagine the reaction of the tenant when you remodel their kitchen by removing base cabinets, lowering upper cabinets so their coffee maker won't fit anymore (to achieve 50% accessible storage), making their sink shallower, enlarging their bathrooms for a turnaround space which then shrinks their living area, etc. They are not thrilled to be 'helped' by the government.
 
Yikes said:
Thanks, Jean. Yes, I am aware of FHA requirements for private housing, which are expanded on here in California via CBC 11A.

But my question was specific to the more stringent requirements of CBC 11B, ADA, and for that matter we can throw in UFAS too.
The specific question is, if only 100 out of the 200 units were touched by public funds, does 5% mobility accessible mean 5 units out of 100? or 10 units out of 200?

I recently had another rehab project where the 1- and 2-bed units were UFAS, but the market rate studio lofts were privately funded. The ADA deeming notice requires dispersion among the various types of units in the development. Imagine the reaction of the tenant when you remodel their kitchen by removing base cabinets, lowering upper cabinets so their coffee maker won't fit anymore (to achieve 50% accessible storage), making their sink shallower, enlarging their bathrooms for a turnaround space which then shrinks their living area, etc. They are not thrilled to be 'helped' by the government.
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First to answer your question about the 5% yes if you have 100 you need 5 units mobility compliant under the UFAS. Yes if you have 200 units you need 10 mobility compliant units. I was told by DOJ that even if it is just one dollar going to the project all of it has to comply with 504 thus UFAS.

I could not find the word dispersion in the UFAS. I don't think it is required until you go to the ADA, for that to happen your project would need to be vacation rentals that happen to be covered by HUD FHA and happen to be covered under the federal government funding.

Please see the 1991 FHAG page 9477 last column and nearly the last paragraph, here is the excerpt.
For example, a multifamily dwelling may be subject both to the Fair Housing Amendments Act and to section 504 of the Rehabilitation Act of
1973. Section 504 requires that 5% of units in a covered multifamily dwelling be fully accessible—thus imposing a stricter accessibility standard for those
units than would be imposed by the Fair Housing Act. However, compliance only with the section 504 requirements would not satisfy the requirements of the Fair Housing Act. The remaining units in the covered multifamily dwelling would be required to meet the specific accessibility requirements of the Fair Housing Act.

In UFAS here is the statement about adaptable dwelling units 4.34:
4.34.3 Adaptability. The specifications for 4.34.5 and 4.34.6 include the concept of adaptability. Accessible dwelling units may be designed for either permanent accessibility or adaptability. UFAS 4.34.5 covers everything in bathrooms, UFAS 4.34.6 covers everything in kitchens.

You can make it adaptable later.

on page 51 of UFAS at 3.34.2 (5) it states:
In addition, the parties who will be responsible for making adaptations shall be provided with the following information:

I am in the process of finding out Who the parties are who will be responsible for making adaptations.

As far at the UFAS 2% requirement for hearing and visually impaired it is only if a visual emergency alarm system is being installed. Under ANSI you can convert the system to visual and audible alarms later.

Hope this helps?
 
Jean Tessmer-HI said:
I could not find the word dispersion in the UFAS. I don't think it is required until you go to the ADA, for that to happen your project would need to be vacation rentals that happen to be covered by HUD FHA and happen to be covered under the federal government funding.
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2010 ADAS 233 applies to any housing development that's been "tainted" by any public funds, be it Federal, state or local funds.
For example, an affordable apartment development that is awarded state tax credits is subject to ADA.
And ADAS 233.3.5 requires dispersion.

https://www.ada.gov/regs2010/2010ADAStandards/2010ADAstandards.htm#sec233

Advisory 233.1 General. Section 233 outlines the requirements for residential facilities subject to the Americans with Disabilities Act of 1990. The facilities covered by Section 233, as well as other facilities not covered by this section, may still be subject to other Federal laws such as the Fair Housing Act and Section 504 of the Rehabilitation Act of 1973, as amended. For example, the Fair Housing Act requires that certain residential structures having four or more multi-family dwelling units, regardless of whether they are privately owned or federally assisted, include certain features of accessible and adaptable design according to guidelines established by the U.S. Department of Housing and Urban Development (HUD). These laws and the appropriate regulations should be consulted before proceeding with the design and construction of residential facilities.
Residential facilities containing residential dwelling units provided by entities subject to HUD's Section 504 regulations and residential dwelling units covered by Section 233.3 must comply with the technical and scoping requirements in Chapters 1 through 10 included this document. Section233 is not a stand-alone section; this section only addresses the minimum number of residential dwelling units within a facility required to comply with Chapter 8. However, residential facilities must also comply with the requirements of this document. For example: Section 206.5.4 requires all doors and doorways providing user passage in residential dwelling units providing mobility features to comply with Section 404; Section 206.7.6 permits platform lifts to be used to connect levels within residential dwelling units providing mobility features; Section 208 provides general scoping for accessible parking and Section 208.2.3.1 specifies the required number of accessible parking spaces for each residential dwelling unit providing mobility features; Section 228.2 requires mail boxes to be within reach ranges when they serve residential dwelling units providing mobility features; play areas are addressed in Section 240; and swimming pools are addressed in Section 242. There are special provisions applicable to facilities containing residential dwelling units at: Exception 3 to 202.3; Exception to 202.4; 203.8; and Exception 4 to 206.2.3.
233.2 Residential Dwelling Units Provided by Entities Subject to HUD Section 504 Regulations. Where facilities with residential dwelling units are provided by entities subject to regulations issued by the Department of Housing and Urban Development (HUD) under Section 504 of the Rehabilitation Act of 1973, as amended, such entities shall provide residential dwelling units with mobility features complying with 809.2 through 809.4 in a number required by the applicable HUD regulations. Residential dwelling units required to provide mobility features complying with 809.2 through 809.4 shall be on an accessible route as required by 206. In addition, such entities shall provide residential dwelling units with communication features complying with 809.5 in a number required by the applicable HUD regulations. Entities subject to 233.2 shall not be required to comply with 233.3.

Advisory 233.2 Residential Dwelling Units Provided by Entities Subject to HUD Section 504 Regulations. Section 233.2 requires that entities subject to HUD's regulations implementing Section 504 of the Rehabilitation Act of 1973, as amended, provide residential dwelling units containing mobility features and residential dwelling units containing communication features complying with these regulations in a number specified in HUD's Section 504 regulations. Further, the residential dwelling units provided must be dispersed according to HUD's Section 504 criteria. In addition, Section 233.2 defers to HUD the specification of criteria by which the technical requirements of this document will apply to alterations of existing facilities subject to HUD's Section 504 regulations.

233.3.5 Dispersion. Residential dwelling units required to provide mobility features complying with 809.2 through 809.4 and residential dwelling units required to provide communication features complying with 809.5 shall be dispersed among the various types of residential dwelling units in the facility and shall provide choices of residential dwelling units comparable to, and integrated with, those available to other residents.
 
Yikes said:
2010 ADAS 233 applies to any housing development that's been "tainted" by any public funds, be it Federal, state or local funds.
For example, an affordable apartment development that is awarded state tax credits is subject to ADA.
And ADAS 233.3.5 requires dispersion.

https://www.ada.gov/regs2010/2010ADAStandards/2010ADAstandards.htm#sec233

Advisory 233.1 General. Section 233 outlines the requirements for residential facilities subject to the Americans with Disabilities Act of 1990. The facilities covered by Section 233, as well as other facilities not covered by this section, may still be subject to other Federal laws such as the Fair Housing Act and Section 504 of the Rehabilitation Act of 1973, as amended. For example, the Fair Housing Act requires that certain residential structures having four or more multi-family dwelling units, regardless of whether they are privately owned or federally assisted, include certain features of accessible and adaptable design according to guidelines established by the U.S. Department of Housing and Urban Development (HUD). These laws and the appropriate regulations should be consulted before proceeding with the design and construction of residential facilities.
Residential facilities containing residential dwelling units provided by entities subject to HUD's Section 504 regulations and residential dwelling units covered by Section 233.3 must comply with the technical and scoping requirements in Chapters 1 through 10 included this document. Section233 is not a stand-alone section; this section only addresses the minimum number of residential dwelling units within a facility required to comply with Chapter 8. However, residential facilities must also comply with the requirements of this document. For example: Section 206.5.4 requires all doors and doorways providing user passage in residential dwelling units providing mobility features to comply with Section 404; Section 206.7.6 permits platform lifts to be used to connect levels within residential dwelling units providing mobility features; Section 208 provides general scoping for accessible parking and Section 208.2.3.1 specifies the required number of accessible parking spaces for each residential dwelling unit providing mobility features; Section 228.2 requires mail boxes to be within reach ranges when they serve residential dwelling units providing mobility features; play areas are addressed in Section 240; and swimming pools are addressed in Section 242. There are special provisions applicable to facilities containing residential dwelling units at: Exception 3 to 202.3; Exception to 202.4; 203.8; and Exception 4 to 206.2.3.
233.2 Residential Dwelling Units Provided by Entities Subject to HUD Section 504 Regulations. Where facilities with residential dwelling units are provided by entities subject to regulations issued by the Department of Housing and Urban Development (HUD) under Section 504 of the Rehabilitation Act of 1973, as amended, such entities shall provide residential dwelling units with mobility features complying with 809.2 through 809.4 in a number required by the applicable HUD regulations. Residential dwelling units required to provide mobility features complying with 809.2 through 809.4 shall be on an accessible route as required by 206. In addition, such entities shall provide residential dwelling units with communication features complying with 809.5 in a number required by the applicable HUD regulations. Entities subject to 233.2 shall not be required to comply with 233.3.

Advisory 233.2 Residential Dwelling Units Provided by Entities Subject to HUD Section 504 Regulations. Section 233.2 requires that entities subject to HUD's regulations implementing Section 504 of the Rehabilitation Act of 1973, as amended, provide residential dwelling units containing mobility features and residential dwelling units containing communication features complying with these regulations in a number specified in HUD's Section 504 regulations. Further, the residential dwelling units provided must be dispersed according to HUD's Section 504 criteria. In addition, Section 233.2 defers to HUD the specification of criteria by which the technical requirements of this document will apply to alterations of existing facilities subject to HUD's Section 504 regulations.

233.3.5 Dispersion. Residential dwelling units required to provide mobility features complying with 809.2 through 809.4 and residential dwelling units required to provide communication features complying with 809.5 shall be dispersed among the various types of residential dwelling units in the facility and shall provide choices of residential dwelling units comparable to, and integrated with, those available to other residents.
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Yikes: Excellent questions.
Here is what I got from the DOJ ADA TA phone line conversation with Latrice TA. If the residential facility is receiving public funding it does not need to comply with the ADA including the Dispersion part. Since Title II private residences are not considered transient or dormatory or homeless type shelters (which are covered by the ADA) the government funded housing only needs to comply with UFAS (5% mobility and 2% alarms visual and audible) and FHAG all ground floor units covered by FHA and exterior common areas covered under the ANSI A117.1 1986. No dispersion necessary. FYI dispersion can be based on equity of number of bedrooms per unit type and they can all be on the ground floor.
From: ADA Title II Regulation manual. Yes, you have to word search this document too to figure out what the design standards mean.
Section 35.151 -- Title II Regulation - The 2010 Standards contain scoping and technical standards for residential dwelling units. However, section 233.3.2 of the 2010 Standards specifically defers to the Department and to HUD, the standard-setting agency under the ABA, to decide the appropriate scoping for those residential dwelling units built by or on behalf of public entities with the intent that the finished units will be sold to individual owners. These programs
include, for example, HUD’s public housing and HOME programs as well as State-funded programs to construct units for sale to individuals. In the NPRM, the Department did not make a specific proposal for this scoping. Instead, the Department stated that after consultation and coordination with HUD,
the Department would make a determination in the final rule. The Department also sought public comment on this issue stating that “[t]he Department would welcome recommendations from individuals with disabilities, public housing authorities, and other interested parties that have experience with these programs. Please comment on the appropriate scoping for residential dwelling units built by or on behalf of public entities with the intent that the finished
units will be sold to individual owners.”73 FR 34466, 34492 (June 17, 2008).
Section 35.151 (j)
Residential housing for sale to individual owners Although public entities that operate residential housing programs are subject to title II of the ADA, and therefore must provide accessible residential housing, the 1991 Standards did not contain scoping or technical standards that specifically applied to residential housing units. As a result, under the Department’s title II regulation, these agencies had the choice of complying with UFAS, which contains specific scoping and technical standards for residential housing units, or applying the ADAAG transient lodging standards to their housing. Neither UFAS nor the 1991 Standards distinguish between residential housing provided for rent and those provided for sale to individual owners. Thus, under the 1991 title II regulation, public entities that construct residential housing units to be sold to individual owners must ensure that some of those units are accessible. This requirement is in addition to any accessibility requirements imposed on housing programs operated by public entities that receive Federal financial assistance from Federal agencies such as HUD. All of the public comments received by the Department in response to this question were supportive of the Department’s ensuring
that the residential standards apply to housing built on behalf of public entities with theGuidance on 2010 Standards: Title II - page 29
 
Yikes, I cannot comment on the California Code I do know if that local government law is more stringent that FHAG? If it is and you know enough about the medical science behind disability ergonomics, to be able to see if you are really making what you are doing superior to the FHAG then you are supposed to use the most stringent parts. Problem is I don't know if the California residential accessibility code with local amendments, would be deemed as a safe harbor under FHA HUD. Only HUD and DOJ can enforce Fair Housing regulations.
 
Jean, your commentary has been really helpful, thank you. where my specific example gets more complicated and confusing is that the 100 market rate units were originally approved as condos, complete with the condo map and everything. They were all going to be built as Phase 2, after the Phase 1 (100 affordable rental units) were completed.
Phase 2 was partway through construction when the developer went belly-up, and a local housing authority purchased all the condos in Phase 2, with the intent to finish the project rent out all of the condos rather than have a half-built blight.

Now the HA is trying to do a re-fi of the 100 affordable units and the lenders want assurance they won’t be on the hook for access compliance design issues for the other 100 market rate units, which were plan-checked as condos but were completed as rentals.

So as much as ADA defers to HUD for condo scoping, what we really have is former for-sale project operating as rental housing.
 
Your welcome. I hope you don't mind me asking, can you tell me what the configuration is for the now rental units? Are they town house like pods with four or more rental units per pod? Are they just one stand alone residence? Does the HA say they are residences? Will they be rented to single families (generally)? FYI HUD does not care if they are rentals or condos or apartments, if they act like a residence and fall into their Four or more category, HUD accessibility takes precedence.

If I understand correctly each unit has its own parcel, residence, water meter, electrical meter, parking area, everything that would be given to an individual buyer of a lots with a house on it with easement rights to use the road or walkways to get to their home?
If this is the case only 5% of each phase needs to be mobility and 2% hear and vision fitted. All roads, walkways, parking areas, entry ways, for the 5% units, and common elements on the the site will need to be in UFAS or ADA compliance. No FHA would be required.

DOJ told me unless the residences are the federal state or locally funded, or they are hotels, dormitories, crisis shelters etc... they do not get involved.

I am assuming that none of the phase one residences included the 5% mobility design? Because the housing projects are being funded by the state you will need 5% either ADA or UFAS mobility fitted and 2% hearing and vision fitted: even if they are each one a single family stand alone residence, because of the funding the project is under Section 504 civil rights law.

I think it will be ok to cluster them in the second phase but all accessible routes connecting both phases of the site will need to be in UFAS or ADA compliance: including common elements (USPSCBU, pool, club house, tennis courts etc..), parking areas, etc.., with accessible entries required to the 5%. As far as dispersion goes I have been told you can use the how many bedroom category and make sure some of each is available in the 5% offering. I would also recommend the following IF none of the first phase has the 5% mobility units or that the cluster of the 5 or 10 percent accessible units be place in are as close the mid line defining phase one and phase two scope of work. I sincerely hopes this helps.
 
The market rate units are all multistory townhomes with shared walls. Every building has more than 4 units. The plans comply with both FHA and CBC 11A for adaptability.
The major issues that make an 5% ADA unit much more difficult than an FHA unit are:
- ADA requires an accessible route throughout the unit. You can't do that in a multistory unit without installing an elevator in the unit.
- Bathrooms require a full turnaround space.
- ADA has larger clearances at door landings, and this causes a lot of problems with hallway widths.
AD requires 50% of kitchen storage to be accessible, requires a forward approach to kitchen sinks, and has accessibility requirements for all appliances. Microwave + range hood combinations on existing units don't work.
 
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