# No site arrival points



## Rick18071 (Dec 19, 2018)

A golf club is making a club house from an old existing barn in the middle of the golf course. From the exit/entrance door the circulation route crosses a patio then to a ramp down to a private driveway. There is no site arrival points, no parking, public transportation stop, loading zone, public street or sidewalk. 

1.Does this ramp need to meet the code to be accessible or can the accessible route to the entrance start at the patio?

2. There also will be a stairway that goes down a hill behind the building from the patio to a grassy area where golf carts can be parked. Do they need an accessible route also?

I would think no for both. There is no reason for the ramp or starway to be accessible since they do not go to anything accessible and there are no site arrival points that comply with 2009 1104.1.


----------



## RLGA (Dec 19, 2018)

If there are no "site arrival points," how does _anyone _get there? If access to the building is by golf cart (which I assume is obtained via from an actual site arrival point) or walking, then where the golf carts park is the site arrival point and should have an accessible route to the building.


----------



## mark handler (Dec 19, 2018)

Rick18071 said:


> A golf club is making a club house from an old existing barn in the middle of the golf course. From the exit/entrance door the circulation route crosses a patio then to a ramp down to a private driveway. There is no site arrival points, no parking, public transportation stop, loading zone, public street or sidewalk.
> 
> 1.Does this ramp need to meet the code to be accessible or can the accessible route to the entrance start at the patio?
> 
> ...


Rick what code is it under?

2010 ADASAD
Advisory 1006.2 Accessible Routes.
...an accessible route connecting an accessible parking space to the entrance of a golf course clubhouse is not covered by this provision.
https://www.ada.gov/regs2010/2010ADAStandards/2010ADAstandards.htm


----------



## Rick18071 (Dec 19, 2018)

When I first did the plan review I asked for an accessible drop off area and they added to the plan. The driveway is on a hill next to the building so it would have required digging right next to the building lower than the old barn footing to have a level area.

I'm not not allowed to decide if anything is technically infeasible in this state when it comes to accessibility.

I don't see anything in Chapter 11 that requires Site Arrival Points, only that a accessible route is required from them.

Later the AHJ told me they don't need a drop off area. So there is no site arrival point. So I'll go by this:

Section 1104.2 Exception: An accessible route is not required between accessible buildings, accessible facilities, accessible elements and accessible spaces that are on the same site. ( but none of these are accessible anyway)

IEBC for a complete change of occupancy only requires an accessible route to parking if provided, an accessible passenger loading zone when loading zones are provided.

For Alterations affecting an area containing a primary function 20% rule the existing building (barn) didn't have a floor, swinging doors or restrooms before so I am sure they made the 20%.


----------



## Rick18071 (Dec 19, 2018)

mark handler said:


> Rick what code is it under?
> 
> 2010 ADASAD
> Advisory 1006.2 Accessible Routes.
> ...



We don't inforce ADASAD. Only 2015 IBC and ICC/ANSI 117.1 2006.


----------



## Rick18071 (Dec 19, 2018)

First time I looked at the ADASD. Interesting that in alterations affecting an area containing a primary area the ADASD includes accessible entrances but the IEBC only includes to toilet facilities or drinking fountains which this building has.


----------



## steveray (Dec 20, 2018)

The IEBC gets you full accessibility in any alteration unless technically infeasible....

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.

If you didn't have a site arrival point, the entrance would be the start of the accessible route and therefore covered by the IEBC....

705.2 Alterations affecting an area containing a primary
function. Where an alteration affects the accessibility to a, or
contains an area of, primary function, the route to the primary
function area shall be accessible. The accessible route to the
primary function area shall include toilet facilities and drinking
fountains serving the area of primary function.


----------



## ADAguy (Jan 4, 2019)

typically a code may be greater than but no less than the ADA, as you note, the code requires access.
Also golf carts may be parked by employees and those employees are entitled to access.


----------



## Rick18071 (Jan 7, 2019)

Don't think I can use the IEBC because it was just a barn and never had a C O.



Rick18071 said:


> I'm not not allowed to decide if anything is technically infeasible in this state when it comes to accessibility.
> 
> I don't see anything in Chapter 11 that requires Site Arrival Points, only that a accessible route is required from them.


----------



## JBI (Jan 7, 2019)

An 'existing' building is one that was lawfully in existence prior to adoption of the IEBC.
The barn would be an existing building regardless of a CofO or lack thereof.


----------



## RLGA (Jan 7, 2019)

JBI said:


> An 'existing' building is one that was lawfully in existence prior to adoption of the IEBC.
> The barn would be an existing building regardless of a CofO or lack thereof.


If it required a CofO at the time it was constructed and did not receive one at that time or any time after, then it would not be considered "lawfully in existence."


----------



## JBI (Jan 8, 2019)

RLGA said:


> If it required a CofO at the time it was constructed and did not receive one at that time or any time after, then it would not be considered "lawfully in existence."



Ron, Very few places issue permits of CofO's for barns.


----------



## mtlogcabin (Jan 8, 2019)

CABO never required a CofO for residential one and two family dwellings and there accessory structures so if the "barn" was accessory to a residence at the time it was built a CofO would not have been issued.
It all depends on what the local AHJ did at the time it was built


----------



## RLGA (Jan 8, 2019)

JBI said:


> Ron, Very few places issue permits of CofO's for barns.


I'm sure that's true, which, if that had been the case, would have made it a legal structure--what I was pointing out is that if a CofO _was _required and one _was not_ obtained, then it is not a legal structure even though it is existing; thus, the IEBC would not be applicable and full compliance with the IBC is required.


----------



## Rick18071 (Jan 8, 2019)

If I was going by the IEBC I could not require a lot of things that barns don't have like a floor.


----------



## Yikes (Jan 16, 2019)

1.  To clarify, an "accessible route is a route for pedestrians or wheelchair users.
2.  According to the OP, the users are either (A) walking/hiking through planted (turf) areas of the golf course to get to the barn, or (B) they are arriving by vehicle down the private driveway, or (C) they are arriving via golf cart to a nearby parking lot.  There is currently no sidewalk (or similar feature) from the public right-of-way to the old barn.

3.  Now, here's ADAS 206.2.1 exception #2:
"2. An accessible route shall not be required between site arrival points and the building or facility entrance if the only means of access between them is a vehicular way not providing pedestrian access."​Therefore, neither A nor B above require an accessible path.

Regarding item C, once you acknowledge the existence of golf cart parking, it is a type of parking lot.  Therefore ADAS 206.2.1 applies:
*"206.2.1 Site Arrival Points.* At least one accessible route shall be provided within the site from accessible parking spaces and accessible passenger loading zones"​Therefore, since you have golf cart "parking", I think you need accessible golf cart parking stall(s) and an accessible path-of-travel from those stalls to the accessible entrance on your old barn.

Some advice, from an ADA liability standpoint: if the owner thinks a golf cart can get up that ramp and drive onto the patio, then I would suggest that owner provide a portion of that that patio as a type of accessible passenger loading zone.


----------



## Rick18071 (Jan 17, 2019)

I'm glad I only need to enforce the IBC. Never read ADA. How does the ADA  require accessible golf cart parking space to be designed? There is only grass on the area where the stairway in the back will go to and if there wasn't any golf carts there you wouldn't know that it's a golf cart parking area. 

I already finaled the building and the AHJ COed it but the stairway in the back is on a different permit and is not started yet. I stopped by today and noticed they just pained some blue lines with the symbol in the driveway near the building just large enough for golf carts. I don't think you can call it a larking area just because the painted some stripes in a driveway. it's more like street parking.There isn't enough room to put in normal parking spaces there, and it's a hill, other old barn across the driveway and other close by out buildings makes it a narrow driveway.


----------



## ADAguy (Jan 17, 2019)

Oh the webs we weave, many golfers have disabilities.


----------



## Yikes (Jan 17, 2019)

Rick, in this case it doesn't matter that the vehicle is the size of a golf cart vs. the size of a van.  If the facility owner starts describing something as a parking for vehicles, and it is parking that serves that barn, then in our local code parking facilities need an accessible parking stall. Actually a van stall, 9'x18' with a 8' aisle.
For what it's worth our local building code (the CBC) has been formatted to match ADAS.  

From a code compliance standpoint, if they don't provide an accessible stall then IMO they'd be better off not labeling anything as parking at all.


----------



## steveray (Jan 18, 2019)

As full egress would seem to be in play for this project, how are they handling the access to the public way?

*1027.5 Access to a public way.* The exit discharge shall provide a direct and unobstructed access to a public way.


----------



## ADAguy (Jan 18, 2019)

1. You do have a parking lot at the main entrance to the facility? If so, it must be connected to the clubhouse.
2. The clubhouse is accessible?
3. Every hole is linked by a cart path, no?
4. Carts (not cars) maybe parked at designated areas, those areas must have an accessible surface.
5. If you provide a remote facility (barn) connected by cart path then access from the cart parking to the facility must be provided.
6. As to code vs ADA, each state us mandated to provide a code that is equal to but no less than the ADASAD minimums. A117.1 still differs in some areas, applicants for permits must be made aware of that. It is also the duty of the design professional to address those differences. We are coming up on 30 years of not yet achieving an acknowledged "safe harbor" with most of our codes.


----------



## Rick18071 (Jan 18, 2019)

It's about a mile on the driveway to get to the public street. On the other side of the property which is a different jurisdiction there is parking just off a street for the golf course but no connecting driveway. To get from that drive to the this clubhouse you would drive about 3 miles on public roads to get to the driveway that goes to this clubhouse. 

They never labeled any parking on the plan or told me there was going to be any parking. They just told me their was no parking and the public was not to use the driveway, the only way to get there is by golf cart. I told the they needed a accessible drop off for golf carts but the AHJ nixed that and it would probably be impossible to build one as required by code because of the hill and it would have taken up most of the narrow driveway. The made the lines on the driveway after the building was COed.

Don't get me wrong, I am for an accessible way to get into the building but don't see how it can be achieved.

Now the stairs in the rear of the building that lead down to the golf course (on a different permit that wasn't stared yet) would need to be an accessible route if there was something accessible down there but there isn't..


----------



## mtlogcabin (Jan 18, 2019)

The building official should handle like this

[A] 104.10 Modifications.
Wherever there are practical difficulties involved in carrying out the provisions of this code, the building official shall have the authority to grant modifications for individual cases, upon application of the owner or owner’s representative, provided the building official shall first find that special individual reason makes the strict letter of this code impractical and the modification is in compliance with the intent and purpose of this code and that such modification does not lessen health, accessibility, life and fire safety, or structural requirements. The details of action granting modifications shall be recorded and entered in the files of the department of building safety.

No appeals board needed to make a determination just a building official you is not afraid to make a decision.
We have areas in our state where the public way is miles away from an exit. Just get them a safe distance away which the code recognizes as 50 feet

1027.5 Access to a public way.
The exit discharge shall provide a direct and unobstructed access to a public way.

Exception: Where access to a public way cannot be provided, a safe dispersal area shall be provided where all of the following are met:

1.    The area shall be of a size to accommodate at least 5 square feet (0.46 m2) for each person.

2.    The area shall be located on the same lot at least 50 feet (15 240 mm) away from the building requiring egress.

3.    The area shall be permanently maintained and identified as a safe dispersal area.

4.    The area shall be provided with a safe and unobstructed path of travel from the building.


----------



## Rick18071 (Jan 18, 2019)

PA State law requires an appeal and must be decided by the state Accessibility Board for anything like this. The inspector or AHJ can't make a decision to let anything at all to not comply with code. But I am not letting anything go.

1104.1 Site arrival points. At least one accessible route
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.

The code does not say one of these site arrival points are required only that an accessible route shall be provided from a site arrival point. There are no existing site arrival points

.
1104.2 Within a site. At least one accessible route shall connect
accessible buildings, accessible facilities, accessible elements
and accessible spaces that are on the same site.
*Exceptions:
1. An accessible route is not required between accessible
buildings, accessible facilities, accessible elements
and accessible spaces that have, as the only
means of access between them, a vehicular way not
providing for pedestrian access.*
2. An accessible route to recreational facilities shall
only be required to the extent specified in Section
1110.


----------



## ADAguy (Jan 18, 2019)

This isn't a course it is a "bushwack". The carts provide acessible routes via the cart paths. You can therefore approach the entances to the facilities, no. Are you implying that you park off site and then "slog" to hole 1? How are deliveries made and the fire department to arrive?


----------



## Rick18071 (Jan 21, 2019)

ADAguy said:


> This isn't a course it is a "bushwack". The carts provide acessible routes via the cart paths. You can therefore approach the entances to the facilities, no. Are you implying that you park off site and then "slog" to hole 1? How are deliveries made and the fire department to arrive?



I never saw any lay out of the course, never explored the other side. I guess the deliveries and emergency vehicles would use the non public driveway.

What little I saw of the golf course it is kind of run down and the paths for the golf carts are not really defined and connected except one spot where golf carts can ford the small creek.. The golf course is divided in two by a small creek and wetlands, the west side and east side. No bridge any where on the site. Cars must drive a few miles on public roads to get to the other side. The parking is on the west side in a different jurisdiction where I have no say and I don't know if there are any accessible parking there and the new club house is on the east side in converted barn with many old outbuilding surrounding it. I think the creek is the line between the two jurisdictions. The property is also a horse farm.

There is an existing clubhouse on the west side by the parking lot. There are plans to turn the whole west side into a townhouse 
development some time which includes demolishing the old clubhouse and then it would just be a 9 hole golf course on the east side. 
Eventually i guess they will need a new parking lot on the east side maybe near the new clubhouse.The problem with that is that they don't need a building permit for a parking lot so I still won't be able to make them put in an accessible path from the new parking lot.


----------



## ADAguy (Jan 22, 2019)

So, is this a members only facility or is the public allowed in?
What exemption are they claiming for no access?


----------



## Rick18071 (Jan 22, 2019)

ADAguy said:


> So, is this a members only facility or is the public allowed in?
> Don't know don't care. What difference does it make?
> What exemption are they claiming for no access?


There is no site arrival points, no parking, public transportation stop, loading zone, public street or sidewalk to have an accessible route from.


----------



## ADAguy (Jan 22, 2019)

Initially You say it is a "club" "meaning members only? No guests allowed. 
So how do members access the site and what if they are disabled?


----------



## Rick18071 (Jan 23, 2019)

I don't know if it is members only. How would that effect accessibility?

They access the club by walking in, biking in, ride a horse in, parking in the parking lot by the old club house that I mentioned before on the other side of the golf course  a in a town that is in a different jurisdiction where I don't do inspections. Then they walk or ride a golf cart through the golf course, over grass, through a creek to get the the new club house that I am talking about


----------



## ADAguy (Jan 23, 2019)

You seem to indicate that it is privately owned (or not?). If open to the public, it must comply with the ADA and your local code.
No grandfathering. They have been obligated to remove barriers to access since the 90's (not your issue),
it is only a matter of time before a complaint is filed with DOJ.


----------

