ADAAG-R: Access from Site Arrival Points & Between Buildings

This post is part of a series of articles on the new ADAAG-R guidelines.  I will be exploring some of the more notable changes from the current version of the ADA Accessibility Guidelines for Buildings & Facilities (ADAAG).  You can find a complete copy of the new ADA/ABA Accessibility Guidelines (ADAAG-R) on the Access Board’s website.

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Access from Site Arrival Points & Between Buildings on a Site

The requirement that an accessible route be provided from public streets and transportation stops to an accessible building entrance is one that has caused much frustration over the years.  Likewise for the similar requirement that all buildings on a site be connected by an accessible route.  The language of ADAAG and TAS currently states:

4.1.2 (1) At least one accessible route complying with 4.3 shall be provided within the boundary of the site from public transportation stops, accessible parking spaces, passenger loading zones if provided, and public streets or sidewalks, to an accessible building entrance.

(2) At least one accessible route complying with 4.3 shall connect accessible buildings, accessible facilities, accessible elements, and accessible spaces that are on the same site.

It is not difficult to ensure compliance with this accessible route requirement from parking and passenger loading zones: they are often in proximity to an accessible entrance.  It is not even too difficult to ensure compliance from more distant locations like public streets, sidewalks and transportation stops, especially when pedestrian routes are provided from these locations in the first place.

The problem with this requirement is that there is no exception for those instances when no pedestrian route is provided whatsoever from public transportation, sidewalks or streets.  Imagine a single building located a quarter mile from the public street.  The only thing connecting the public street to the parking area in front of the building is a quarter mile-long driveway with no adjacent pedestrian walkway.  According to the current guidelines, notwithstanding the absence of any pedestrian route, an accessible route for persons with disabilities would need to be provided.

Similarly, when no pedestrian route is provided between buildings on a site, the guidelines still require an accessible route between each building on a site.  This can be especially ominous when vehicular ways between some buildings can be exceptionally dangerous to any pedestrian, and more so to those with mobility impairments and other physical limitations.

The new ADA/ABA Accessibility Guidelines (ADAAG-R) restate the current requirement (using the term “Site Arrival Points”) and then provide the necessary exceptions:

206.2.1 Site Arrival Points.  At least one accessible route shall be provided within the site from accessible parking spaces and accessible passenger loading zones; public streets and sidewalks; and public transportation stops to the accessible building or facility entrance they serve.

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.

Similarly, in the case of access between buildings on the same site, an exception is made for those instances where pedestrian routes are not provided in the first place:

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.

EXCEPTION:  An accessible route shall not be required between accessible buildings, accessible facilities, accessible elements, and accessible spaces if the only means of access between them is a vehicular way not providing pedestrian access.

There are several other key qualifications to these new requirements and their exceptions (for those instances where there are multiple bus stops serving a site, or multiple accessible entrances, or when the route provided to pedestrians is through a parking lot), so take the time to go to section 206 in the new ADAAG-R and read up on all the particulars.

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