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

7. Path of Travel Requirements and Adjusted Construction Cost

Specific exceptions within the CBC provide that PV system projects are not alterations for purposes of accessibility. These include exceptions for machinery spaces¹⁸, exceptions for electrical projects¹⁹, and exceptions for changes to mechanical or electrical systems²⁰. Additionally, alterations solely for the purpose of compliance with certain accessibility requirements of the code are limited to the scope of work of the project and shall not be required to comply with the alteration provisions.²¹ For projects qualifying for these exeptions [sic], there shall be no further path of travel upgrades beyond those specifically required by this IR.

When minor elective alterations incidental to the primary scope of installing a PV system are included as part of the project, the adjusted construction cost for purposes of complying with the 2013 California Building Code §11B-202.4 Path of travel requirements in alterations, additions and structural repairs. Exception 8 shall be limited to the cost of those minor alterations; the costs directly associated with the solar PV system shall not be included.

For the addition of a new parking lot in cojunction [sic] with the installation of a PV system at an existing facilitiy [sic], the adjusted construction cost for purposes of complying with the 2013 California Building Code §11B-202.4 Path of travel requirements in alterations, additions and structural repairs. Exception 8 shall be limited to the cost of the non-solar system improvements; the costs directly associated with the PV system shall not be included.

When a PV system is include [sic] as part of the construction of a new facility, there will be no path of travel requirements, as all aspects of the new facility must comply with the accessibility requriements [sic] of the current edition of the CBC.