Comment NumberOL-100654
OrganizationADA Build it Right, Inc.
Received05/31/2005 09:43:22 PM
Commenter
First NameLast NameState/Province
WayneYarnallOR
AgencyU. S. Department of Justice
Docket IDCRT Docket No. 2004-DRS01
RuleNondiscrimination on the Basis of Disability in State and Local Government Services; Nondiscrimination on the Basis of Disability by Public Accommodations and in Commercial Facilities
Attachments
AttachmentPlug-in
OL-100654.pdf Adobe Acrobat Reader

CommentsAnswers to Specific Questions


9-Reference Van Accessible parking paragraphs of the new ADAAG Sections 106, 208 and F208. I suggest the following changes in Chapter 2 Section 208 and F208 to make absolutely clear the recuirements for Van Accessible parking scoping. My experience observing van accessible parking and driving side lift van for 12 years is that the error rate on van accessible parking complience is over 50%. Since many professionals using the accessibility specifications don't know what a side-lift van is the van accessible parking spots are overlooked or done incorrectly. Section 106 Definitions has no definition for van accessible parking, Ameican Heritage dictionay has no definion to fall back on. Please add a definition for van accessible parking to the definition section: "van accessible parking - an accessible parking spot providing 8 ft. side clearance on the passenger side of the vehicle so there is room for the side wheel chair platform lift to be lowered to the pavement with sufficient additional space for the wheel chair to drive off the platform and turn onto the accessible route." Or see USDOJ Technical Assistance Update number 1, August 1996 pages 13-19. The new document section 208 obscures van accessible parking spot scoping with poor organization. (Same comments apply to Chapter F208 - ABA Scoping). Move Paragraph "208.2.4 Van Parking Spaces" scoping so that it is part of 208.2-B or directly under Table 208.2 Parking spaces. (It is easy to read past located on the next page and below 208.2.1 Hospital Outpatient Facilities and 208.2.3 Residential Facilities) 208.2.4 Van Parking Spaces. For every six or fraction of six parking spaces required by 208.2 to comply with 502, at least one shall be a van parking space complying with 502. IBC 2000 has 1106.4 the van scoping paragraph BEFORE Table 1106.1, Accessible parking spaces. See Below. Old ADAAG has the van accessible scoping directly under the scoping table. In Section F208, Paragraph F208.2.4 is indented incorrectly under F208.3 further obfuscating it. ---------------------------------- From the 1994 ADAAG: ---------------------- 4.1.2 Accessible Sites and Exterior Facilities: New Construction. An accessible site shall meet the following minimum requirements: ........ (5) (a) If parking spaces are provided ..... Total Parking in Lot Required Minimum Number of Accessible Spaces 1 to 25 1 26 to 50 2 ...... 1001 and over 20 plus 1 for each 100 over 1000 Except as provided in (b), access aisles adjacent to accessible spaces shall be 60 in (1525 mm) wide minimum. (b) One in every eight accessible spaces, but not less than one, shall be served by an access aisle 96 in (2440 mm) wide minimum and shall be designated "van accessible" as required by 4.6.4. The vertical clearance at such spaces shall comply with 4.6.5. All such spaces may be grouped on one level of a parking structure. --------------------------------------------- From Icode 2000: (Copyright property of ICC). --------------------------------------------- 1106.4 Van spaces. For every eight or fraction of eight accessible parking spaces, at least one shall be a van-accessible parking space. TABLE 1106.1 ACCESSIBLE PARKING SPACES TOTAL PARKING REQUIRED MINIMUM NUMBER OF SPACES PROVIDED ACCESSIBLE SPACES 1 to 25 1 26 to 50 2 1106.5 Location. Accessible parking spaces shall be located on ...... ---------------------------------------
General Comments