Title III Technical Assistance Manual (with 1994 supplement)

III-7.4000 Sites and exterior facilities

III−7.4100 General. This section addresses exterior features such as parking, portable toilets, and exterior signage in new construction.

III−7.4200 Accessible route (ADAAG §4.1.2(1)). An accessible route must connect accessible public transportation stops, parking spaces, passenger loading zones, and public streets or sidewalks to an accessible building entrance.

The ADA, however, does not require the provision of an accessible route in cases where there is no pedestrian route for the general public.

ILLUSTRATION 1: A developer would not be required to provide an accessible route between an accessible entrance to a retail store and a major highway bordering the site, if customers only have access to the store by driving to the parking lot (i.e. , where no pedestrian route exists from the highway to the store). An accessible route would have to be provided, however, for pedestrians to travel from the parking lot to the facility's entrance.

ILLUSTRATION 2: Where multiple accessible facilities are built on the same site, an accessible route between the facilities will be required only where a pedestrian route for the general public exists between the multiple facilities or where pedestrians typically walk between the facilities.

Whether a route for the general public exists within a site depends upon the unique characteristics of the site, including its geography and proximity to public transportation stops. Factors such as the presence of sidewalks, crosswalks, or significant pedestrian flow along a particular route should also be considered in determining whether a route for the general public exists. Creation of special accessible routes along paths not available to the general public is not required.

Note, however, that private entities often do not have control over streets and sidewalks. In such a case, the private entity is not responsible for compliance. However, it is encouraged to request public entities to modify sidewalks and install curb cuts.

III−7.4300 Parking (ADAAG §4.1.2(5)(b)). If self-parking is provided for employees or guests of a public accommodation, accessible parking spaces must be provided in compliance with the ADA. ADAAG provides a table with the number of accessible parking spaces required dependent on the size of the lot. For example, only four percent of the spaces in a 100-space lot must be accessible. Certain facilities, however, are subject to higher requirements.

Outpatient units are subject to a higher requirement if they are part of medical care facilities where persons may need assistance in responding to an emergency and where the period of stay may exceed twenty-four hours. For such facilities, ten percent of the total parking attributable to the outpatient unit or facility must be accessible.

In addition, any unit or facility providing medical care or other services, including occupational or physical therapy, or vocational rehabilitation, is subject to a higher accessible parking requirement, if it specializes in treatment or services for persons with mobility impairments. Twenty percent of the total number of parking spaces serving each such unit or facility must be accessible.

In addition to the general requirements for accessible automobile spaces, ADAAG requires that at least one of every eight accessible parking spaces have adequate adjacent space for a van lift to be deployed. Each such space must have a sign indicating that it is van-accessible, but it is not to be reserved exclusively for vans. Alternatively, "universal parking," in which all spaces can accommodate van widths, is permitted.

Accessible parking spaces must be located on the shortest accessible route of travel to the facility's entrance. Accessible parking spaces and the required accessible route should be located where individuals with disabilities do not have to cross vehicular lanes or pass behind parked vehicles to have access to the entrance. If it is necessary to cross a vehicular lane because, for example, local fire engine access requirements prohibit parking immediately adjacent to a building, then a marked crossing should be used as part of the accessible route to the entrance.

If valet parking is provided, there must be an accessible passenger loading zone.

If a lot is limited to the exclusive use of employees, and none of the employees are individuals with disabilities requiring accessible parking, accessible spaces may be assigned to employees without disabilities.

III- 7.4400 Signage (ADAAG §4.1.2(7)). Requirements for exterior signs are essentially the same as those for interior signs (see §4.1.3(b) below). The international symbol of accessibility must be used to indicate accessible parking spaces; accessible passenger loading zones; and accessible entrances and toilet facilities, if all are not accessible.