DSA IR 11B-9: Accessibility Requirements for Solar Photovoltaic Systems at School Sites

6. PV Systems at Parking Facilities

PV systems are frequently installed over existing parking facilities. Shaded or covered parking is considered an amenity or user convenience¹⁵, the provision of which could allow accessible parking to be located in different parts of a parking facility or in different parking facilities on a single site. ¹⁶ After installation of a PV system, even if not all the parking spaces are shaded or covered, the parking lot will be considered a single parking facility. ¹⁷

The access compliance requirements for these projects will be determined by the following considerations:

• Whether or not the existing parking meets the accessibility requirements.

• Whether or not a reasonable portion of accessible parking will be shaded or covered by the PV system elevated components.

• Whether or not new accessible parking provided under the PV system elevated components will be located on the shortest accessible route to a facility entrance.

There are different options for meeting the accessibility requirements triggered by the addition of a PV system over existing and new parking facilities, based upon the extent of coverage of the parking by the PV system (full or partial) and the level of accessibility of the existing parking facility (accessible or not accessible). 

6.1 Required Elements for Accessible Parking

Parking at school facilities shall be considered accessible when the following elements are provided in compliance with the CBC edition in effect at the time of the installation of a solar PV project:

1. Accessible parking in compliance with the CBC; 

2. An accessible route from the accessible parking to the building served by the parking facility.

3. An accessible primary entrance into the building being served by the parking facility.

4. If the parking facility does not serve a specific building or facility, the accessible parking should be on the shortest accessible route to an accessible pedestrian entrance to the parking facility.

Path of travel upgrades other than those required for exterior site elements mentioned above shall not be triggered by PV projects at parking facilities

6.2 PV Systems at Existing Parking Facilities

6.2A – Parking Fully Covered - The PV system covers all of the standard parking, accessible parking, or code compliant location for accessible parking.

1. Existing facility has accessible parking - No additional access compliance work required.

2. Existing facility does not have accessible parking – If the elements listed in 6.1 above are not fully accessible, the scope of the project must include upgrades to bring them into compliance with the current standards.

6.2B – Standard Parking Covered, Accessible Parking Not Covered - The proposed PV system covers all existing standard parking spaces, however existing accessible parking or the code compliant location for accessible parking is not shaded or covered by the PV system. The following approaches for providing access compliance are acceptable:

1. Existing facility has accessible parking - Construct a shade structure over all existing accessible parking.

2. Existing facility does not have accessible parking – Provide accessible parking in accordance with the CBC and construct a shade structure over the new accessible parking spaces.

3. Option - Applicants have the option to construct the required number of covered accessible parking spaces beneath the PV system elevated components. These parking spaces shall comply with the shortest route requirements of 11B-208.3.1. If the existing uncovered accessible parking is closer to the facilty [sic] entrance than the new covered accessible parking, it should remain in service to provide users a choice between proximity to an entrance and shade.

6.2C – Standard Parking Partially Covered, Accessible Parking Fully Covered - The proposed PV system covers a portion of the total parking. The covered portion includes the existing accessible parking or a code compliant location for accessible parking.

1. Existing facility has accessible parking – PV system covers the existing accessible spaces. As the accessible parking is provided with the additional amenity of weather protection (shade or cover) no new accessible spaces are required in the uncovered portion of the parking facility.

2. Existing facility does not have accessible parking – Provide the required number of accessible parking spaces beneath the PV system elevated components, based on the total number of both covered and uncovered parking spaces. Similar to a. above, no new accessible spaces are required in the uncovered portion of the parking facility.  

6.3 PV Sytems [sic] at Newly Constructed Parking Facilities

6.3D – New Construction, Standard / Accessible Parking Fully Covered - Provide accessible parking in accordance with the CBC.

6.3E – New Construction, Standard / Accessible Parking Partially Covered - Provide accessible parking, covered by the solar PV array, in accordance with the CBC. If the code compliant location for accessible parking is not covered by the PV system, the project can either:

1. Provide a shade cover over a pro-rata share of the accessible parking or;

2. Provide a pro-rata share of the accessible parking covered under the PV system elevated components. Shaded or covered accessible parking spaces should be located on the shortest accessible route to the accessible pedestrian entrance of the shaded portion of the parking facility.

Attachment A - Tables 1 and 2 summarize possible configurations of PV systems at both existing parking facilities and as part of new construction.