Guide to the ADA Standards

Scoping Requirements

Must the minimum number of spaces be determined separately for each parking facility on a site or can it be based on the collective total of spaces provided on a site?

The minimum number of accessible parking spaces, including van accessible spaces, must be calculated separately for each parking facility on a site. Spaces required for one parking facility can be provided in another where doing so results in equal or greater access and convenience for users, but the required number must still be calculated separately for each parking facility.

Is accessible parking required on sites where no parking is intended?

No, the ADA Standards require accessible spaces only where parking is provided. They do not require accessible spaces where parking is not provided at all. Most local and state codes and regulations address the amount of parking required for a site.

Are accessible spaces required in employee parking lots?

Yes, the requirements for accessible parking spaces apply equally to employee parking facilities and are not limited to visitor parking. Where a parking facility contains parking spaces for visitors and spaces reserved for employees only, it is important that sufficient access is provided to both types of spaces. In this case, it is advisable to calculate the minimum number separately for each type of space as though they were separate parking facilities, but this is not required if they are both located in the same parking lot or garage. Both accessible visitor and employee spaces must be on the shortest accessible route to an accessible entrance.

Are accessible spaces required in temporary parking lots and in unpaved lots, such as gravel or grass lots?

Yes, the ADA Standards apply to both permanent and temporary facilities, including parking facilities (§201.3). In all parking facilities, including gravel or grass lots, parking spaces and access aisles must be marked and have firm, stable, and slip resistant surfaces as specified for accessible ground and floor surfaces (§302).

Is resurfacing of a lot considered an alteration?

According to the definition of "alteration," normal maintenance is not considered an alteration unless it affects a facility’s usability. For example, if a lot is to be resurfaced or its plan reconfigured, accessible spaces must be provided. However, work that is primarily maintenance, such as surface patching, does not trigger a requirement for accessible spaces. When the work is not considered an alteration, providing accessible spaces is advisable where sufficient accessible parking is lacking and may be necessary in meeting obligations for program access by government entities and barrier removal by public accommodations as required by DOJ’s regulations.

Are accessible spaces required for tractor trailers at rest stops and other facilities?

No, the Standards exempt those spaces used exclusively for trucks, as well as buses, other delivery vehicles, law enforcement vehicles, or vehicular impound.

Is compliance required for parking spaces designed specifically for recreational vehicles such as motor homes and camping or boating trailers?

Spaces designed for recreational vehicles (RVs) and trailers are not exempt from coverage, but the Standards do not include technical provisions specific to these spaces. If RV or trailer spaces are located in parking facilities with car and van parking spaces, scoping should be applied separately to both types which will permit accessible RV or trailer spaces to be located among other RV or trailer spaces so long as they are on the shortest accessible route to facility entrances among such spaces. Access aisles serving accessible spaces must be as long as the vehicle space they serve.

The ABA Standards, which apply to federally funded sites, provide requirements for outdoor developed areas on federal lands such as camping and picnic facilities that include provisions for RV parking and pull-up spaces.  They can be consulted as a reference in addressing access to RV parking on non-federal sites, including those subject to the ADA.  The ABA Standards address access to RV and other parking spaces at camping and picnic units and pull-up spaces at dump stations and cover space width (minimum 20’, or 16’ in the case of a second adjoining space) and utility and sewage hook-ups (§1011 and §1012).

Are accessible parking spaces required on a site where valet service is provided but vehicles are parked off site, such as in a public parking garage or on public streets?

Parking facilities with valet parking must provide accessible parking spaces to allow self-parking by people with disabilities (and must also provide an accessible passenger loading zone (§209.4)). This applies where parking spaces are provided on the same site as the valet parking service. However, if valet parking service is provided on a site without any parking spaces, accessible parking spaces are not required on the site (but policies and practices to accommodate people with disabilities must be in place under the Department of Justice’s ADA regulations). Public garages and other parking facilities subject to the Standards must comply and provide accessible parking spaces in any case. If a parking garage does not provide valet parking, or if valet parking service is provided off site by a different entity that parks vehicles in the garage, an accessible passenger loading zone is not required at the garage.