DSA IR 11B-10: SCOPING AND PATH OF TRAVEL UPGRADE REQUIREMENTS FOR FACILITY ALTERATION, ADDITION AND STRUCTURAL REPAIR PROJECTS (with revisions issued through April 2017)

1. SCOPING CONSIDERATIONS FOR ALTERATION PROJECTS: A project at an existing facility is an alteration of that facility. This applies when either 1) existing elements are altered or 2) new elements, up to and including new buildings, are added.

1.1 Maintenance and Repair Projects: Projects limited to maintenance or repair are not alterations and do not trigger accessibility requirements. Definitions related to alteration projects are included in Attachment 1 of this IR.

1.2 Compliance with New Construction Requirements: The basic work of any project, whether new construction, an addition to an existing building or facility or an alteration of an existing building or facility, must comply with the following requirements for new construction:

• "11B-201.1 Scope. All areas of newly designed and newly constructed buildings and facilities and altered portions of existing buildings and facilities shall comply with these requirements."¹

¹ "These requirements" means the accessibility provisions of Chapter 11B and related sections within the California Building Code, current edition.

• "11B-202.3 Alterations. Where existing elements or spaces are altered, each altered element or space shall comply with the applicable requirements of Division 2, including Section 11B-202.4."

1.3 General Exceptions: The code then provides general exceptions to the requirements in 11B-203.² Many of these exceptions are applicable to public school, community college and higher education projects; a copy of Section 11B-203 is provided as Attachment 2 to this IR.

² "11B-203.1 General. Sites, buildings, facilities and elements are exempt from these requirements to the extent specified by Section 11B-203."

1.4 Accessible Route Requirements: For additions, the new construction provisions require an accessible route from the area of the addition to other accessible areas of the building, site or facility:

• "11B-206.2.2 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."

1.5 Accessible Route Requirements for Campus Settings: For campus-style school facilities with multiple buildings and functional areas, the accessible route/path of travel situation can become more complex. The following factors may apply to projects on existing campus facilities:

• New construction on an existing site must be connected, as part of the basic project scope, with an accessible route to existing on-site circulation paths and accessible routes.

• When multiple paths of travel to a specific area of alteration, addition or structural repair are present but not code compliant, Section 11B-202.4 requires the upgrade of only a single primary path of travel to the project area. Upgrades of secondary paths of travel shall not be required.

• Path of travel (POT) upgrades only apply to existing construction; any new POT elements or accessible routes being provided as part of the basic project scope are not considered path of travel upgrades.

• The cost of new POT elements or a new accessible route is part of the project’s adjusted construction cost and cannot be used to satisfy the 20-percent disproportionate cost limitation for path of travel upgrades on projects with an adjusted construction cost below the valuation threshold. See Section 3.1 of this IR.

1.6 Vehicular Way Exception: Again, there are exceptions to these general requirements. For example, if the only means of access between accessible buildings, accessible facilities, accessible elements and accessible spaces on a site is a vehicular way not providing pedestrian access, an accessible route connecting them is not required.^{3, 4} The Section 11B-203 exceptions also apply to the extent specified.

³ 11B-206.2.1 Site arrival points Exception 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.

⁴ 11B-206.2.2 Within a site Exception. An accessible route shall not be required between accessible buildings, accessible facilities, accessible elements and accessible spaces on a site if the only means of access between them is a vehicular way not providing pedestrian access.