ADA Accessible Vehicle Parking Facilities Scoping Requirements
ADA Compliant Vehicle Parking Space
This article will discuss the scoping requirements for accessible vehicle parking facilities required by the Americans with Disabilities Act (ADA). The graphic on the right is representative of ADA parking spaces for vehicles. The sections of the 2010 ADA Standards that cover accessible vehicle parking facilities and spaces the most include:
§ 35.151, New construction and alterations
§ 36.403. Alterations: Path of travel
Standard 208, Parking Spaces (Scoping)
Standard 216, Signs
Standard 502, Parking Spaces (Technical)
The technical requirements for accessible parking spaces will be discussed in another article. All together the term “parking spaces” is used approximately 123 times in the 2010 ADA Standards. So there is a lot to this.
Vehicle parking is not required to be provided at any facility by the ADA but, if vehicle parking is provided accessible vehicle parking is required, including temporary facilities. The scoping requirement in 2010 ADA Standard 208.1, [Parking Spaces] General, states, “Where parking spaces are provided, parking spaces shall be provided in accordance with [Standard] 208.” Exceptions to this Standard exclude accessible parking at commercial vehicle storage used exclusively for buses, trucks, or other delivery vehicles; law enforcement vehicles; or vehicle impound parking.
Number of Accessible Parking Spaces
Table 208.2, Parking Spaces
The number of ADA compliant parking spaces required depends on the parking facilities in use. 2010 ADA Standard 208.2, [Parking Spaces] Minimum Number, states, “Parking spaces complying with [Standard] 502 shall be provided in accordance with Table 208.2 except as required by [Standards] 208.2.1, 208.2.2, and 208.2.3. Where more than one parking facility is provided on a site, the number of accessible spaces provided on the site shall be calculated according to the number of spaces required for each parking facility.” Table 208.2 is shown above.
Parking Garage
The term “parking facility” is used in Standard 208.2 instead of the term “parking lot” so that it is clear that both parking lots and parking structures are required to comply with this section. The number of parking spaces required to be accessible is to be calculated separately for each parking facility; the required number is not to be based on the total number of parking spaces provided in all of the parking facilities on the site. A “parking facility” can be a single parking space, a parking lot, a parking floor within a building, or a stand-alone parking structure. The graphic above is representative of a stand-alone parking structure (garage).
When calculating the required number of accessible parking spaces in a parking facility, it is important to include the requirements for “van accessible” parking spaces. 2010 ADA Standard 208.2.4, [Parking Spaces] Van Parking Spaces, states, “For every six or fraction of six parking spaces required by [Standard] 208.2 to comply with [Standard] 502, at least one shall be a van parking space complying with [Standard] 502.”
Parking facilities are to be treated separately for scoping purposes if they are either:
structurally different (e.g., surface lot versus parking garage or deck);
dedicated to, and separately serve, different facilities on a site;
segmented and separated by guard rails, fencing, or barriers, particularly where they serve different users; or
separated by streets or roadways (as opposed to drive aisles on a site).
Surface lots that are contiguous or that are segmented by landscaping or drive aisles (i.e., vehicular passageways located within parking areas), but not streets or roadways, typically can be treated as a single parking facility. A good example is a large mall with other buildings on the site. See the graphic below.
Mall Parking
In the mall parking graphic above, the parking lot serving the shopping mall (center) and store (lower right) can be treated as one parking facility because the parking area is not divided or separated. The lot in the lower/left corner of the graphic is treated as a separate parking facility because it is divided from the surrounding lot by a raised sidewalk and is dedicated to a specific building.
Again in the mall graphic above, parking areas that are labeled (e.g., “Lot A”) to help users locate their vehicles but that are part of the same lot (i.e., not separated) do not have to be treated as separate parking facilities.
Scoping Example
So now lets look at an example of how to compute the required number of accessible parking spaces at a site. Look at the graphic below.
Site Plan - Parking Lot Scoping Example
In the example above the site plan shows 5 buildings with 6 associated parking lots with the following spaces totals: 20, 30, 10, 8, 5, and 30. This adds up to 103 spaces total for the site. If you went into Table 208.2 with the number 103, you would come up with 4 standard ADA parking spaces and 1 van accessible parking space, for a total of 5 ADA accessible parking spaces. And that would be the wrong answer. Note in the graphic above that all of the parking facilities are separate. So each one has to be looked at individually for required ADA parking spaces. See the graphic below for a representation.
Accessible Parking Per Parking Facility
The site plan shows scoping applied lot by lot among 6 parking lots with the the following numbers of total spaces and accessible spaces:
20 (1 van accessible)
30 (1 standard accessible, 1 van accessible)
10 (1 van accessible)
8 (1 van accessible)
5 (1 van accessible)
30 (1 standard accessible, 1 van accessible)
Using this calculation for the 103 spaces you need 8 accessible spaces for the site, 6 of which must be van accessible. So the total spaces needed is 8, not 5, and the total van accessible parking space needed is 6, not 1. Again, if there is a road or a physical installation that separates the lots, then the ADA parking spaces for the lots are computed separately.
Now understand that, under the disbursement rules, these 8 ADA accessible parking spaces do not have to be in each of the six parking facilities. The location of the accessible spaces can be wherever they need to be to satisfy rules for proximity to the accessible entrances and disbursement.
There are some specific exceptions to the requirements for ADA accessible parking for recreational vehicles (RV) and trailers, at Hospital Outpatient Facilities, Rehabilitation and and Outpatient Physical Therapy Facilities, and Residential Facilities. Each will be discussed below.
Recreational Vehicles (RV) and Trailers
Spaces designed for RV 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.
Hospital Outpatient Facilities
2010 ADA Standard 208.2.1, Hospital Outpatient Facilities, states, “Ten percent of patient and visitor parking spaces provided to serve hospital outpatient facilities shall comply with [Standard] 502.“ So for these facilities the number of ADA accessible parking spaces will be higher than the number from Table 208.2. The graphic below is representative of a hospital outpatient facility.
Hospital Outpatient Facility Parking
The term “outpatient facility” is not defined in the Standard but is intended to cover facilities or units that are located in hospitals and that provide regular and continuing medical treatment without an overnight stay. Doctors' offices, independent clinics, or other facilities not located in hospitals are not considered hospital outpatient facilities for purposes of the ADA Standards. These facilities would need to comply with Table 208.2 for ADA accessible parking.
Rehabilitation Facilities and Outpatient Physical Therapy Facilities
2010 ADA Standard 208.2.2, [Parking Spaces] Rehabilitation Facilities and Outpatient Physical Therapy Facilities, states, “Twenty percent of patient and visitor parking spaces provided to serve rehabilitation facilities specializing in treating conditions that affect mobility and outpatient physical therapy facilities shall comply with [Standard] 502.”
Again, for these facilities the number of ADA accessible parking spaces will be higher than the number from Table 208.2. These facilities include those not located at hospitals and rehabilitation facilities that specialize in treating conditions that affect mobility. Conditions affecting mobility include:
those involving the use of mobility aids and devices such as braces, canes, crutches, prosthetic devices, wheelchairs, or powered mobility aids;
arthritic, neurological, or orthopedic conditions that severely limit one's ability to walk;
respiratory diseases and other conditions which may require the use of portable oxygen; or
cardiac and any other conditions that impose substantial limitations on one’s mobility.
Rehabilitation facilities that provide, but that do not specialize in, services or treatment for persons with mobility impairments, such as general rehabilitative therapy centers, are not subject to the 20% requirement. In mixed-use facilities, the 20% may be applied only to the portion of spaces that are determined to serve the types of rehabilitation or outpatient therapy facilities covered by this provision.
Residential Facilities
2010 ADA Standard 208.2.3, [Parking Spaces] Residential Facilities, states, “Parking spaces provided to serve residential facilities shall comply with [Standard] 208.2.3.” This Standard is referring to one-to-one parking for residents, where more than one-to-one parking for residents is provided, and parking for guests, employees, and other non-residents. The graphic below is representative of a residential facility.
Parking at Residential Facility
2010 ADA Standard 208.2.3.1, [Parking Spaces, Residential Facilities] Parking for Residents, states, “Where at least one parking space is provided for each residential dwelling unit, at least one parking space complying with [Standard] 502 shall be provided for each residential dwelling unit required to provide mobility features complying with [Standards] 809.2 through 809.4.” This is the rule where a facility has one-to-one parking for all residents.
2010 ADA Standard 208.2.3.2, [Parking Spaces, Residential Facilities] Additional Parking Spaces for Residents, states, “ Where the total number of parking spaces provided for each residential dwelling unit exceeds one parking space per residential dwelling unit, 2 percent, but no fewer than one space, of all the parking spaces not covered by [Standard] 208.2.3.1 shall comply with [Standard] 502.”
So if the residential facility has 100 dwelling units, of which 10 dwelling units are for disabled individuals, and 10 accessible parking spaces for these accessible dwelling units, then 2% of the remaining 90 residential parking spaces would need to be ADA accessible. This 2% (1.8) requirement would be rounded up to 2 more parking spaces. This rule is for resident parking only. Non-resident parking still must comply with Table 208.2. See the Standard below.
2010 ADA Standard 208.2.3.3, [Parking Spaces, Residential Facilities] Parking for Guests, Employees, and Other Non-Residents, states, “Where parking spaces are provided for persons other than residents, parking shall be provided in accordance with Table 208.2.” Again, these are the non-resident parking spaces.
Accessible Parking Location and Dispersion
2010 ADA Standard 208.3.1, [Parking Spaces, Location] General, states, “Parking spaces complying with [Standard] 502 that serve a particular building or facility shall be located on the shortest accessible route from parking to an entrance complying with [Standard] 206.4. Where parking serves more than one accessible entrance, parking spaces complying with [Standard] 502 shall be dispersed and located on the shortest accessible route to the accessible entrances. In parking facilities that do not serve a particular building or facility, parking spaces complying with [Standard] 502 shall be located on the shortest accessible route to an accessible pedestrian entrance of the parking facility.”
In other words, accessible spaces must be dispersed among accessible pedestrian entrances and be located on the shortest accessible route to the pedestrian entrance they serve. Understand that the shortest accessible route may not be the closest to the facility pedestrian entry door. The graphic below is representative where the accessible parking is located near the start of the ramp, not the steps to the facility entry.
Accessible Parking Located Near Ramp Entry
As is common, there are exceptions to this Standard.
All van parking spaces shall be permitted to be grouped on one level within a multi-story parking facility.
Parking spaces shall be permitted to be located in different parking facilities if substantially equivalent or greater accessibility is provided in terms of distance from an accessible entrance or entrances, parking fee, and user convenience.
Accessible spaces must be dispersed and located at different facilities and accessible entrances served by the parking lot. However, accessible spaces required for one parking facility can be located in another if doing so results in substantially equal or better access in terms of travel distance to an accessible entrance, parking fee, or user conveniences such as protection from weather, better security and lighting. The minimum number must still be determined separately for each parking facility.
Employee Parking
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.
Parking Garages
The ADA Standards apply to parking garages, including those provided below grade. At sites that also include surface lots, a garage is treated as a separate parking facility for scoping purposes. At multi-level parking garages with direct connections to a facility, each direct connection to the facility must include an accessible entrance (§206.4.2). The graphic below is representative of foot bridges connecting the levels of the parking to the levels of the facility.
Footbridges Connecting Parking Levels to Facility Levels
In multi-level parking garages not serving a particular facility, accessible spaces, including van spaces, must be located so that they provide the same level of protection and security as other spaces in the garage. The graphic below is representative. Locating accessible spaces required for a garage on the exterior is not usually acceptable.
Parking Garage Not Serving a Particular Facility
In all multi-level parking facilities, all van parking spaces are permitted to be grouped on one level.
Mechanical Access Parking Garages
Mechanical Parking Facility
Accessible parking spaces are not required in mechanical access parking garages where lifts are used to stack vehicles. The graphic on the right is representative. However, such facilities must provide at least one accessible passenger loading zone at vehicle drop-off and pick-up areas so that people with disabilities can transfer from vehicles (2010 ADA Standard 209.5).
Residential Facilities Accessible Parking Location
Accessible parking location in residential facilities is slightly different. 2010 ADA Standard 208.3.2, [Parking Spaces, Location] Residential Facilities, states, “In residential facilities containing residential dwelling units required to provide mobility features complying with [Standards] 809.2 through 809.4, parking spaces provided in accordance with [Standard] 208.2.3.1 shall be located on the shortest accessible route to the residential dwelling unit entrance they serve. Spaces provided in accordance with [Standard] 208.2.3.2 shall be dispersed throughout all types of parking provided for the residential dwelling units.”
So the shortest route in a residential facility is to the accessible dwelling unit(s) entrance, not necessarily the facility entrance. And, if there is a difference in parking spaces, such as some with a carport and some without a carport, then dispersion is required. Those assigned to specific units are not required to be identified by signs (ADA Standard 216.5, Ex. 2). If the total number of resident spaces is less than the total number of units, accessible parking is based on scoping Table 208.2, but providing one accessible space for each mobility accessible unit is advisable.
The exception for residential parking locations is that parking spaces provided in accordance with [Standard] 208.2.3.2 shall not be required to be dispersed throughout all types of parking if substantially equivalent or greater accessibility is provided in terms of distance from an accessible entrance, parking fee, and user convenience.
Parking Facilities Pay Stations and Other Elements
Parking Facility Accessible Pay Station
Pay stations, air pressure machines, recycling bins, and other elements that serve accessible parking facilities and spaces must comply with requirements for accessible elements and operable parts and be served by an accessible route. Requirements for operable parts cover clear floor space, operating characteristics, and location within accessible reach ranges. The graphic on the right represents a parking facility pay station. Operable parts that are used from inside vehicles, such as garage ticket dispensers at vehicle entry, are not required to comply with the Standards. However, under DOJ’s ADA regulations, policies or practices must be in place to accommodate persons with disabilities who are unable to use such devices.
Electric Vehicle Charging Stations
The Standards do not include specific provisions for electric vehicle (EV) charging stations. However, it is advisable to address access to EV charging stations so that they are usable by people with disabilities. If provided, accessible spaces at EV charging stations cannot count toward the minimum number of accessible car and van parking spaces required in a parking facility.
US Access Board recommendations for EV charging stations include providing access to a reasonable number of spaces serving EV charging stations or, use scoping Table 208.2 to determine an appropriate number. The number of accessible spaces serving EV charging stations must be determined separately from the required number of car and van parking spaces. Also, provide an accessible route on both sides of the vehicle space that connects to the charging station for easier access. The graphic below is representative.
Accessible Parking at EV Charging Station
In the EV parking space shown above, a vehicle space at least 10 – 13 feet wide is advisable. A 10-foot width offers an extra 2 feet that effectively provides a 5-foot aisle on one side when paired with the accessible route; a 13-foot wide space will allow an 8-foot aisle. This flexibility is helpful since the parking direction is determined by the location of the charging station and the vehicle connection. Use the International Symbol of Accessibility only where spaces are reserved exclusively for people with disabilities.
Alterations to a Parking Facility
When an existing parking facility is altered, scoping requirements are based on the following:
the planned scope of work
technical infeasibility
primary function areas/path of travel says if you alter an area of primary function you have to alter the path of travel, including parking.
Parking Lot Re-Striping Machine
If the planned scope of work involves resurfacing and/or re-configuring the parking spaces, then the project should include compliance modifications for ADA compliance. If the planned scope of work involves only repainting existing lines, that would be considered normal periodic maintenance, which would not require full compliance with ADA Standards. The graphic on the right is representative of a machine to repaint the parking space lines. The photo below is a crew resurfacing a parking lot.
Parking Lot Re-Surfacing
Technical infeasibility with respect to an alteration of a building or a facility, is defined in the ADA Standards as “something that has little likelihood of being accomplished because existing structural conditions would require removing or altering a load-bearing member that is an essential part of the structural frame; or because other existing physical or site constraints prohibit modification or addition of elements, spaces, or features that are in full and strict compliance with the minimum requirements.”
If the project scope does involve resurfacing and/or re-configuring the parking spaces, but making the parking spaces fully ADA compliant is determined to be technically infeasible, such as resurfacing may require making the slope compliant, then the re-grading for ADA compliance may not have to be included in the project. But, there may still have to be changes made as much as possible. Also, technical infeasibility is difficult to argue for elements such as parking lot surfaces.
In the Standards, when primary function areas are altered there is a requirement to alter the path of travel, including parking, to comply with the ADA.
It would be reasonable to expect compliance with these scoping requirements for a primary function area to be challenged by the cost of compliance. The cost of compliance with these rules is addressed in § 35.151, New construction and alterations, and § 36.403. Alterations: Path of travel, of the 2010 ADA Standards. In general, alterations made to provide an accessible path of travel to the altered area will be deemed disproportionate to the overall alteration when the cost exceeds 20% of the cost of the alteration to the primary function area.
Summary
Parking facilities can include single parking spaces, parking lots, and parking garages. Issues that must satisfy ADA requirements for accessible parking facilities include number of parking spaces, location, and dispersion. Where more than one parking facility is provided on a site, the number of accessible spaces provided on the site shall be calculated according to the number of spaces required for each parking facility. Elements within a parking facility that serve the public must also be ADA accessible. These issues must be considered for new construction and altered parking facilities.
For another article about the technical criterial for parking facilities please see ADA Accessible Vehicle Parking Facilities - Technical.
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