Non-ADA Compliant Passenger Loading Zone at Renovated Hotel
Hotel Passenger Loading Zone with Valet Parking
Recently on a road trip I stayed at a hotel that had undergone significant renovations, except for the passenger loading zone (PLZ). See the photo on the right. Note that this hotel PLZ is provided where there is valet parking service. The valet parking service uses a parking facility across the street to park cars. Passenger Loading Zones must be compliant with the Americans with Disabilities Act (ADA). The sections of the 2010 ADA Standards that covers PLZs the most include 209 and 503.
Where passenger loading zones are provided, at least one accessible passenger loading zone is required in every continuous 100 linear feet of loading zone or fraction thereof. Compliance is required only where areas are specifically designed or designated for passenger loading, such as those at airports, many hotels, convention centers, and some parking garages.
2010 ADA Standard 209.2.1, Passenger Loading Zones, states, “Passenger loading zones, except those required to comply with [Standards] 209.2.2 and 209.2.3, shall provide at least one passenger loading zone complying with [Standard] 503 in every continuous 100 linear feet (30 m) of loading zone space, or fraction thereof.” So if you have 150 feet of PLZ, 1.5, rounded up to 2, accessible PLZs are required.
There are three types of facilities that always require a PLZ. These include medical care and long-term care facilities, facilities using valet parking, and mechanical access parking garages.
Parking Facility Logo
2010 ADA Standard 209.4, [Passenger Loading Zones] Valet Parking, states, “Parking facilities that provide valet parking services shall provide at least one passenger loading zone complying with [Standard] 503.” So this Standard only applies to parking facilities with valet parking. Not all other places such as restaurants, unless the restaurant uses a parking facility to park the vehicles. If a restaurant, or some other entity, offers valet parking but not from a designated loading zone, then an accessible PLZ is not required.
Valet parking facilities or entities that use a designated loading zone also must have a policy and procedure for self-parking so that disabled individuals who have a vehicle that can only be operated by the disabled individual can use the parking facility.
2010 ADA Standard 503.2, Vehicle Pull-Up Space, states, “Passenger loading zones shall provide a vehicular pull-up space 96 inches (2440 mm) wide minimum and 20 feet (6100 mm) long minimum.”
2010 ADA Standard 503.3, Access Aisle, states, “Passenger loading zones shall provide access aisles complying with [Standard] 503 adjacent to the vehicle pull-up space. Access aisles shall adjoin an accessible route and shall not overlap the vehicular way.” The access aisle must be at least 60 inches wide, extend the full length of the vehicle pull-up space, adjoin an accessible route, and cannot overlap vehicular ways.
2010 ADA Standard 503.3.1, Width, states, “Access aisles serving vehicle pull-up spaces shall be 60 inches (1525 mm) wide minimum.”
2010 ADA Standard 503.3.2, Length, states, “Access aisles shall extend the full length of the vehicle pull-up spaces they serve.”
2010 ADA Standard 503.3.3, Marking, states, ”Access aisles shall be marked so as to discourage parking in them.” The marking method and color is not specified in the ADA Standards.
2010 ADA Standard 503.4, Floor and Ground Surfaces, states, “Vehicle pull-up spaces and access aisles serving them shall comply with [Standard] 302. Access aisles shall be at the same level as the vehicle pull-up space they serve. Changes in level are not permitted. EXCEPTION: Slopes not steeper than 1:48 [2.08%] shall be permitted.” In other words, the access aisle and vehicle pull-up space must be at the same level and the slope of these surfaces cannot exceed 2.08%. These surfaces must also be stable, firm and slip resistant and cannot hold water or debris that would make the surfaces slippery.
Passenger loading zones are designed to include a level vehicle pull-up space, a level marked accessible aisle between the vehicle pull-up space and the curb or walkway, and a curb ramp, if applicable. The graphic below is representative.
Passenger Loading Zone Schematic
The graphic below is representative of an accessible PLZ.
Accessible Passenger Loading Zone
The photo below shows the small cutout of the walkway at this hotel PLZ where a marked access aisle should be located. Not even close to the 60 inches minimum required.
Small PLZ Access Aisle
The photo below shows this PLZ from the opposite side. Note the out-of-date curb ramp installed completely across the walkway and away from the PLZ itself. A parallel curb cut would be a better installation here.
Old Curb Cut Across Walkway and Away from the PLZ
2010 ADA Standard 503.5, Vertical, states, “Vehicle pull-up spaces, access aisles serving them, and a vehicular route from an entrance to the passenger loading zone, and from the passenger loading zone to a vehicular exit shall provide a vertical clearance of 114 inches (2895 mm) minimum.” The graphic below is representative. This height is greater than the 98 inches required for van accessible parking spaces because it is intended to accommodate larger vehicles and buses. Note that this height requirement includes the vehicular route from the entry to the PLZ and out to the exit.
Note that PLZs apply to designated areas, not to random drop-off/pickup points used by a cab, Uber, or Lyft service. Furthermore, according to the US Access Board, “Only those areas that are specifically designed or designated for passenger loading are considered “passenger loading zones” under the Standards. This includes those passenger drop-off or pick-up areas commonly found at airports, convention centers, schools, and many hotel entrances that have design features, signs, or markings indicating passenger loading zones. At other locations, compliance is not required even if passenger loading may occasionally occur, but is not specifically intended or reflected in the design.” Accessible passenger loading zones are not required to be identified by the International Symbol of Accessibility.
Summary
Where passenger loading zones are provided, at least one accessible passenger loading zone is required in every continuous 100 linear feet of loading zone or fraction thereof. When facilities are renovated, PLZs at the facility should be included in the renovation for ADA compliance.
When alterations to Title III facilities are designed, § 36.403(g)(2) Alterations: Path of travel, states, In choosing which accessible elements to provide, priority should be given to those elements that will provide the greatest access, in the following order:
(i) An accessible entrance;
(ii) An accessible route to the altered area;
(iii) At least one accessible restroom for each sex or a single unisex restroom;
(iv) Accessible telephones;
(v) Accessible drinking fountains; and
(vi) When possible, additional accessible elements such as parking, storage, and alarms.
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