36 CFR Parts 1190 and 1191 ADA and ABA Accessibility Guidelines - Preamble (Discussion of Comments and Changes)
502 Parking Spaces
Section 502 addresses car parking spaces and van parking spaces. Substantive changes pertain to the:
In the final rule, the Board has clarified how parking spaces and access aisles are to be measured.
Where parking spaces are marked with lines, the width of parking spaces and access aisles is to be measured from the centerline of the markings (502.1). However, at spaces or access aisles not adjacent to another parking space or access aisle, width measurements are permitted to include the full width of the line defining the parking space or access aisle (502.1, Exception).
Comment. The proposed rule specified that car and van spaces be at least 8 feet wide and that access aisles be at least 5 feet wide for car spaces and at least 8 feet wide for van spaces. These specifications are consistent with the original ADAAG. However, that document also recognized an alternative "universal" design under which all spaces are designed to be accessible for vans or cars by incorporating additional space in the parking space instead of the access aisle. Under this design,parking spaces are at least 11 feet wide and access aisles at least 5 feet wide. Commenters requested that this design be recognized in final rule, at least for the portion of spaces required to be van accessible. Comments pointed out certain benefits of the alternative design, such as access aisles that are less likely to be mistaken for another parking space.
Response. The final rule includes specifications for alternative van parking spaces based on the "universal" design specifications (502.2). Van spaces are required to be at least 11 feet wide and to have an access aisle at least 5 feet wide. An exception allows van spaces to be 8 feet wide where the access aisle is at least 8 feet wide, which is consistent with the specifications of the proposed rule and the original ADAAG.
Comment. Requirements for access aisles in section 502.3 address width, length, marking, and location. Two spaces are permitted to share an access aisle. The proposed rule, consistent with the original ADAAG, allowed access aisles to be provided on either side of the parking space. Many commenters urged the Board to revisit this issue, particularly with respect to van parking. The lift provided on vans is typically located on the passenger side. It is important, especially where front-in only parking is provided, that the access aisle be located on the passenger side of van spaces.
Response. The Board has included a requirement that where angled spaces are provided, the access aisle must be located on the passenger side of van spaces (502.3.4). Otherwise, this provision permits access aisles to be located on either side of the space since drivers can pull in or back into spaces as needed.
To harmonize the guidelines with the ANSI A117.1‒2003 standard, the Board has added clarification that access aisles are not permitted to overlap vehicular ways (502.3.4).
Comment. The proposed rule removed a requirement that the access designation for van parking include the term "van accessible" to clarify that both car and van drivers can use such spaces, as was the original intent of ADAAG. Many commenters strongly opposed this change. While some may have misinterpreted it as removal of the requirement for van accessible spaces, others considered this designation important in encouraging car drivers to use other accessible spaces over those designed to accommodate vans.
Response. The Board has restored the requirement that the designation of van spaces include the term "van accessible" (502.6). This designation is not intended to restrict the use of spaces to vans only, but instead to identify those spaces better suited for vans. An advisory note to this effect is included in the final rule.
Comment. The proposed rule removed language in the original ADAAG that vehicles parked in accessible spaces not reduce the clear width of connecting accessible routes. The Board had considered this requirement redundant in view of specifications for accessible routes in section 402. Many commenters disagreed and urged that such a requirement be restored in the final rule. Some comments pointed out that the ANSI A1171.1 standard, like the original ADAAG, specifies that "parked vehicle overhangs shall not reduce the clear width of an accessible route."
Response. The Board has added a requirement that spaces and access aisles be designed so that parked vehicles "cannot obstruct the required clear width of adjacent accessible routes" (502.7). A typical design solution where accessible routes run in front of spaces is the provision of wheel stops that help prevent encroachment into the accessible route.
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