# Accessible parking for existing buildings



## Rick18071 (Jun 1, 2017)

For an existing building or part of a building that is having alterations or a chance of occupancy with an existing parking lot when is an accessible parking space required. Chapter 34 or the IEBC doesn't seem to be clear on this. The parking section in IBC chapter 11 is not in the accessible route section so it is not part of an accessible route.

1104.1 Site arrival points.
Accessible routes within the site shall be provided from public transportation stops; accessible parking; accessible passenger loading zones; and public streets or sidewalks to the accessible building entrance served.

Notice it says from accessible parking. I can't find anywhere that the accessible parking space as part of the accessible route that is required for existing buildings or spaces.


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## mtlogcabin (Jun 1, 2017)

The key is if parking is required, this is usually found within the local zoning ordinances not the building code

3411.4.2 Complete change of occupancy.
Where an entire building undergoes a change of occupancy, it shall comply with Section 3411.4.1 and shall have all of the following accessible features:

1.    At least one accessible building entrance.

2.    At least one accessible route from an accessible building entrance to primary function areas.

3.    Signage complying with Section 1110.

4.    Accessible parking, where parking is being provided.

5.    At least one accessible passenger loading zone, when loading zones are provided.

6.    At least one accessible route connecting accessible parking and accessible passenger loading zones to an accessible entrance.

Where it is technically infeasible to comply with the new construction standards for any of these requirements for a change of group or occupancy, the above items shall conform to the requirements to the maximum extent technically feasible.

3411.6 Alterations.
A facility that is altered shall comply with the applicable provisions in Chapter 11 of this code, unless technically infeasible. Where compliance with this section is technically infeasible, the alteration shall provide access to the maximum extent technically feasible.

Exceptions:

1.    The altered element or space is not required to be on an accessible route, unless required by Section 3411.7.

2.    Accessible means of egress required by Chapter 10 are not required to be provided in existing facilities.

3.    The alteration to Type A individually owned dwelling units within a Group R-2 occupancy shall be permitted to meet the provision for a Type B dwelling unit.

4.    Type B dwelling or sleeping units required by Section 1107 of this code are not required to be provided in existing buildings and facilities undergoing a change of occupancy in conjunction with alterations where the work area is 50 percent or less of the aggregate area of the building.

1106.1 Required.
Where parking is provided, accessible parking spaces shall be provided in compliance with Table 1106.1, except as required by Sections 1106.2 through 1106.4.


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## Rick18071 (Jun 2, 2017)

Thanks for the help.
This is a 3 story existing building. Only the first floor is to be changed to a coffee bar from an office with less than 50 occupants. So it was B and will remain B. The other floors are B. So it is not a change of occupancy but only a change of use. This is in a urban setting. There is a existing parking lot with no accessible parking space and no accessible route from the building or front sidewalk to the parking lot.  There is no plans to alter the parking lot. So it looks like I can only use 3411.7 which does require an accessible route but nothing about parking spaces. The only exterior changes will be a new front door so they will have an accessible route to the sidewalk but not to the parking lot.

Do I need to require an accessible parking space? I will need a code section.

Also the parking lot has been repaved a couple of years ago. It may have had an accessible parking space before but I have no way to find out.


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## mark handler (Jun 2, 2017)

How many parking stalls are there?
You may need to add them....


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## BillS (Jun 5, 2017)

Rick, the change of use from an office to a coffee bar is considered a change of occupancy, as well as a change of use. The commentary in IEBC 3411.4.1 Partial Change in Occupancy (2009) mentions this..."_*When a building undergoes a partial change in occupancy, such as where there is a tenant change*_ or a change in function of a specific area, then the level of accessibility must be maintained or improved at the same level as if that space was undergoing an alteration."


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## mtlogcabin (Jun 5, 2017)

IEBC Definition
CHANGE OF OCCUPANCY. A change in the purpose or level of activity within a building that involves a change in application of the requirements of this code.

An office to a coffee shop is a definite change in the purpose and level of activity


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## ADAguy (Jun 5, 2017)

I Like where this is going, talk about opening a bag of often overlooked worms?
On the same note if existing parking is less than a certain number and to add an accessible space would further reduce parking, is an accessible space still required if parking is provided?


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## Rick18071 (Jun 5, 2017)

The parking lot is behind this building and the one next door. The parking lot is on two separate properties. Not sure to count all spaces or just the spaces on the property that is making changes.


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## ADAguy (Jun 5, 2017)

Separate lots, separate addresses or tied together?


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## Rick18071 (Jun 5, 2017)

separate properties and owners but it looks like one parking lot.


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## steveray (Jun 6, 2017)

3411.9.1 Site arrival points. At least one accessible route
from a site arrival point to an accessible entrance shall be
provided.
Full compliance would require an accessible route
from all site arrival points. If this requirement would
adversely affect the historical significance of the
building, the alternative available is to provide an
accessible route from one site arrival point to an
accessible entrance.


Is the parking "on site"....? No parking, no accessible parking....You can't make someone do off site improvements...


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## mtlogcabin (Jun 6, 2017)

We recently went through this with a professional office complex of 8 buildings individually owned and all the sidewalks and parking lot under a condo type ownership of the building owners. It took a couple of phone calls and one letter explaining the requirements of providing an accessible route and it is now being installed 6 months later. It had to be agreed upon by the association and approved through their budget. One building compliant 7 more to go when they remodel


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## ADAguy (Jun 6, 2017)

Have a similar property in Orange County, 5 buildings on a topographically challenged site with no WC access from adjacent sidewalk.
Given common interest how is accessible parking to be distributed? To each building or based on parking count for entire site?, in which case not all buildings would have direct access to accessible parking, 
Treat each building individually and site would have more than the minimum accessible spaces.

As to initial? It sounds as if the parking, though on 2 lots is contiguous; due to property line, each building has a separate lot. Is there an alley between the buildings and the parking, or not?


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## Rick18071 (Jun 6, 2017)

Yes there is a driveway for bank window between buildings. There also is an enclosed bridge connection of the two buildings on the 2nd floor above the driveway.


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## ADAguy (Jun 6, 2017)

Does the building have a rear entrance or must you use the sidewalk to traverse from the Parking lot to the building entrance?
Building has an ongoing barrier removal responsibility that if parking for the building is provided then an accessible space must be provided.


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## Yikes (Jun 6, 2017)

1.  If parking is provided, then accessible parking stalls must be provided.
2.  Even if you weren't doing a remodel, the property owner and/or tenant could be subject to an ADA lawsuit if parking is provided but is not accessible.  So they better get to work on it!
3.  Many cities and states have provisions to allow a reduction in existing parking stall count if it is necessary to create new accessible parking stalls/aisles.  Check with your local municipality.


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## ADAguy (Jun 6, 2017)

Rick, awaiting for your responses to continue.


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## JBI (Jun 7, 2017)

mtlogcabin said:


> IEBC Definition
> CHANGE OF OCCUPANCY. A change in the purpose or level of activity within a building that involves a change in application of the requirements of this code.
> 
> An office to a coffee shop is a definite change in the purpose and level of activity



The 'level of activity' language is the key for this query, and is included in the definition specifically for this type of change.


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## Rick18071 (Jun 13, 2017)

Sorry I was busy for a change. There are several doors around the building that are not accessible. They are planning a new accessible door at the front on the sidewalk. And now I got them to put in a new sidewalk from the parking lot to the new door. The existing accessible parking space is in the middle of the lot. I told them this space needs to be moved to the closest space to the new entrance. Not sure why they are resisting moving the space. It's only paint.


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## ADAguy (Jun 13, 2017)

Cheap is cheap (smiling)


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