ADA Shop Talk Episode 041 – Is An Elevator Required For New Hotel Rooms? Is An Accessible Route Required To A Church Mezzanine Addition?

ADA Shop Talk Episode 041 – Is An Elevator Required For New Hotel Rooms? Is An Accessible Route Required To A Church Mezzanine Addition?

Internet Radio Talk Show With Paul Klein

January 4, 2018

Questions answered this episode:

Roger – An Existing Hotel in California, built before 1992 is planning an addition adding a second floor with 6 new guest rooms. The preliminary design shows new exterior stairs to each of the new guest rooms. Reviewing CBC 11B-224 there does not seem to be a requirement to have all guest rooms on an accessible route. CBC 11B-202 does require an accessible path of travel to the specific area of alteration. And CBC 11B-224 requires that accessible rooms be dispersed which would imply that the new enhanced ocean view from the second floor should have at least one room with mobility feature. Will an elevator be required to provide access to the new second floor rooms?

Dave – The owner of an existing 4 unit apartment building in California with the first occupancy prior to March 13, 1991, is planning on adding four units to the building. One unit shall be on the ground floor, three on the second floor. Only the new ground floor unit is required to be accessible. However, due to extremely tight site constraints, no feasible path from the accessible parking location to the new unit and floodplain issues, it is not possible to provide an accessible path to this unit from the accessible parking space. The original building is configured such that providing an accessible path to the existing ground floor units is feasible and interior modifications could be achieved in these units to meet accessibility requirements. Have you ever come across a situation where it has been accepted to substitute constructing new accessible units with upgrading existing non-covered units? In effect, this would net one additional accessible unit over what is required, effectively doubling the required accessibility, which the city should support. I just can’t find any precedent case that can be used as a backup to support this proposal. What say you?

Keith – Hi there, i have a proposed tenant improvement to an existing church built in 1988. They are proposing to enlarge the existing stage/platform (less than 30 inches above the finished floor) and proposing replacing existing choir platform detail with new layout at the rear of the stage. They are proposing to relocate and replace the existing 5'-0”x 8'-0”baptismal to the right side of the stage. In the existing mezzanine at the rear of the stage, they are proposing an office space and a dressing room. The proposed plans have no vertical access proposed the remodeled stage and relocated baptismal and mezzanine office space. I think they should provide access to the area of alteration at a minimum to the stage and baptismal.

Dave – Here is a question that has come up a few times for me. Occasionally, I have been hired to assist local design teams to get their projects through the building department. When a project is a tenant improvement and not an owner-involved project, there have been times where the city has required significant access improvements outside of the scope of work, most notably with regard to elevator upgrades. On more than one occasion, the city has initially wanted to have the elevator cab enlarged or updated to meet code. This could mean encroaching into an existing tenant space unrelated to the TI project. I have also had times where significant site work is demanded by the city. Where do you come down in determining responsibility for access upgrades outside of the primary tenant improvement space? I realize that there can be a lot of grey area in figuring this out, but thanks for any input and suggestions/opinions.