# Alteration & Path of Travel



## mp25 (May 23, 2018)

I'm trying to get my head around the ADA requirements for a renovation project - renovation of guest rooms in a hotel (only about 1/2 of them, with the work being staged - and the remaining half will be renovated a few years from now - depending on the financial health of the establishment).
The scope of the project started with just the interior updating of the rooms - i.e. finishes/plumbing equipment. The proper number of rooms will have a more extensive remodeling to provide accessible toilet rooms/36" doors, communication features etc.

There will also be a renovation of the lobby - to refresh the image. 

When calculating the 20% requirement for barrier removal - it says that the 20% cost is based off the cost of renovating of primary function area. It is my understanding that in this scenario, only the cost of the renovation of the lobby would be considered the cost of alteration - and the cost of the rooms would not. Am I understanding this right?

The other question concerns where the 20% gets spent. 
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(i) An accessible entrance;

(ii) An accessible route to the altered area;

(iii) At least one accessible restroom for each sex or a single unisex restroom;

(iv) Accessible telephones;

(v) Accessible drinking fountains; and

(vi) When possible, additional accessible elements such as parking, storage, and alarms. 
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The site is a corner lot - and a public sidewalk is provided only along one of the sides, and there currently is no pedestrian sidewalk to connect the main entry and the public sidewalk. There is a parking lot and there is a path of travel provided between the accessible space and the main entry. The main entrance is already accessible, so the first place the 20% should get spent on is to create a sidewalk to connect the entry to the public walk? The cost of providing this will likely exceed the 20% of the cost of the lobby alteration, so how does this play out if the owner does not want to spend more $$$ to fully complete the sidewalk (there is some distance and grade changes that have to be overcome). What would the code compliant thing to do here - pour a sidewalk as far as the 20% will allow - or spend the money on upgrading the public bathrooms (in the lobby area) to make them fully accessible and not do any of the sidewalk work?

In my opinion, upgrading the bathroom will be more beneficial, rather than providing a sidewalk to nowhere


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## steveray (May 23, 2018)

In a hotel, the hotel rooms are the primary function.....One could maybe argue that it would apply to the "non-accessible" rooms....They can spend the 20% any way they want, regardless of what makes sense...


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## mtlogcabin (May 23, 2018)

I would not spend money on the sidewalk 
Our state rules require the 20% be spent on the accessible route starting from the parking lot and into the building. If that is exisrtng and compliant then it is up to the owner/designer to determine where to spend the required amount

I agree the primary function of a hotel would be the lobby, eating areas, pool area and the rooms

 PRIMARY FUNCTION. A primary function is a major activity for which the facility is intended. Areas that contain a primary function include, but are not limited to, the customer service lobby of a bank, the dining area of a cafeteria, the meeting rooms in a conference center, as well as offices and other work areas in which the activities of the public accommodation or other private entity using the facility are carried out. Mechanical rooms, boiler rooms, supply storage rooms, employee lounges or locker rooms, janitorial closets, entrances, corridors and restrooms are not areas containing a primary function.


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## mark handler (May 23, 2018)

The rooms *are *considered to be a “primary function area” under the ADA.
Hallways and restrooms usually are not primary function areas.

_Priority in upgrades should be given to those elements that will provide the greatest access, in this order:_

An accessible entrance
An accessible route to the altered area
Upgrades to the “path of travel" to all areas
At least one accessible restroom for each sex or a single unisex restroom
Accessible telephones
Accessible drinking fountains
additional accessible elements such as parking, storage, and alarms
Sidewalks first not Parking.


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## mtlogcabin (May 23, 2018)

mark handler said:


> Sidewalks first not Parking


I think that should be based on the location of the project and the surrounding amenities provided
Once you are outside of a city in my state there are very few public sidewalks so requiring the parking space and route into the building first is logical in Montana. In the case of a hotel, private vehicles is how 99.9% of their customers arrive onsite. If there are no other facilities (shopping, theater, dining) within a short walking distance to your hotel then a sidewalk to a public way will not be used as an accessible route.


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## Rick18071 (May 23, 2018)

Put up a solid gold: accessible door hardware, handrails, threshold, operable parts or anything else listed in Chapter 4 "Accessible Routes" in ICC/ANSI A117.1 that should could you 20% of the cost.
I don't think you can count the cost of upgrading the restrooms for the 20%, only like the code says "the accessible route to the the prime function area" and  the accessible route to the restrooms and drinking fountains.


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## mp25 (May 23, 2018)

Thank you all for your responses. Unfortunately sometimes codes are written in a way which do not necessarily make the most sense for a particular situation. 

The project location is in a loosely populated suburban area, outside of the city  - this is a budget type of a hotel. I see money being spent on sidewalk as really a waste when compared to other areas that could be upgraded. I still have to do a more thorough reading of the state accessibility code to see what that triggers.

I recently bought a book that is supposed to clarify ADA issues, but it doesn't focus on scoping as much as I expected. Does anyone have any references that they could point me towards? (i already went thru the guidance to 2010 ada on ada's website)


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## Yikes (May 24, 2018)

Also, in my own opinion, the 20% valuation is based on the value of items that fall under code jurisdiciton.  for example, if the renovation was $500k, but $100k of that was being spent on normal cosmetic maintenance (repainting and new wallpaper), then the valuation for ADA improvements would be 20% of the remaining $400k.


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## steveray (May 24, 2018)

Yep....because granite countertops are way more important than handicap accessibility...


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## steveray (May 24, 2018)

503.1 Scope. Level 1 alterations include the removal and
replacement or the covering of existing materials, elements,
equipment, or fixtures using new materials, elements, equipment,
or fixtures that serve the same purpose.


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## steveray (May 24, 2018)

705.1 General. A facility that is altered shall comply with the
applicable provisions in Sections 705.1.1 through 705.1.14,
and Chapter 11 of the International Building Code unless it is
technically infeasible. Where compliance with this section is
technically infeasible, the alteration shall provide access to
the maximum extent that is technically feasible.
A facility that is constructed or altered to be accessible
shall be maintained accessible during occupancy.


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