Analysis Of The Proposed Standarts (Appendix A) - Summary Of The Major Substantive Changes Proposed For The Scoping And Technical Requirements Page 15

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threatening in situations where the power failure is associated with a fire or other
emergency. The use of a platform lift is generally only one of the options available to
covered entities. Covered entities that are concerned about the costs associated with
maintaining standby power for a lift may wish to explore design options that would
permit the use of a ramp.
208 and 502 Parking Spaces
General. Where parking spaces are provided, the proposed standards at sections 4.1.2
(5)(a) and (7) and 7(a), and the proposed changes at section 208.1 and Exception require
a specified number of the parking spaces to be accessible. The proposed changes add a
new exception that exempts parking spaces used exclusively for buses, trucks, delivery
vehicles, law enforcement vehicles, or for purposes of vehicular impound from the
scoping requirement for parking spaces. If a lot containing parking spaces for these
vehicles is used by the public, the lot is required to have an accessible passenger loading
zone.
The proposed standards require accessible parking spaces to be identified by signs that
display the International Symbol of Accessibility. At section 216.5 and Exceptions 1 and
2 new changes will add two new exceptions that exempt accessible parking spaces from
the signage requirement. The first exception exempts sites that have four or fewer
parking spaces from the signage requirement. The second exception exempts residential
facilities where parking spaces are assigned to specific dwelling units from the signage
requirement.
Commenters stated that the first exception, by allowing a parking lot with four or fewer
spaces not to post a sign at its one accessible space, is problematic because it could allow
all drivers to park in accessible parking spaces. The Department believes that this
exception provides necessary relief for small business entities that may otherwise face the
prospect of having between twenty-five percent (25%) and one hundred percent (100%)
of their limited parking area unavailable to their customers because it is reserved for the
exclusive use of persons with accessible tags or parking placards. The proposed standards
still require these businesses to ensure that at least one of their available spaces is
designed to be accessible.
A commenter stated that accessible parking spaces must be clearly marked. The
Department notes that section 502.6, Identification, provides that parking spaces must be
identified by signs that include the International Symbol of Accessibility. Additional
signs are required to identify van accessible spaces. Also, section 502.3.3, Marking,
requires that access aisles are to be marked so as to discourage parking in them.
Access Aisle. The advisory note accompanying section 502.3 provides that it is
preferable that the accessible route connecting parking spaces to accessible entrances not
pass behind parked vehicles.
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