Architects/Engineers and Designers

Services

CASp evaluations and consultation
Full review services including Fire-Life Safety, CASp level accessibility, Structural, Plumbing, Mechanical and Electrical, Green Building and Energy
Work closely with your building and site development teams to help with code related issues
Pre-Permit Submittal Plan Review. This helps to insure when submitting for a building permit, the plans get through the plan check phase with minimal corrections and resubmittals
Accessibility design and field inspections during design and construction
Work closely as your personal Code Expert
Act as your personal liaison to the Building, Planning and Fire Departments to work out Code related issues.

A word to Architects, Engineers and Designers …

As hard as it is to be expert at the services you provide, being expert in all of the code requirements on top of that is an overwhelming task.

Steve has been performing plan check since 2002. He has been an ICC Certified Plans Examiner since 2007 and a Certified Access Specialist, CASp #393, since 2012. He has spent those years applying the code to real world projects, working alongside city planners, fire departments, contractors and design professionals as the code expert on the job. That has proven over and over to be an invaluable asset to the design community, helping design professionals produce plans that move through the building permit process faster and with fewer corrections.

Where design teams get caught: the federal and California path of travel rules do not work the same way. Both the ADA and the California Building Code require that when you alter an area containing a primary function, the path of travel to that area is made accessible. Most design professionals know that. What catches teams is that the two codes handle the cost limit differently, and the California rule can reverse the answer.

Federal: 20 percent is a ceiling. Under 28 CFR 36.403, an alteration affecting the usability of or access to an area containing a primary function requires the path of travel to that area — plus the restrooms, telephones and drinking fountains serving it — to be made accessible to the maximum extent feasible. That path of travel includes walks and sidewalks, curb ramps and other pedestrian ramps, parking access aisles, elevators and lifts, and the route through the building.

The obligation is capped. Path of travel work is deemed disproportionate when its cost exceeds 20 percent of the cost of the alteration to the primary function area. Above that, the obligation stops.

California: 20 percent can become a floor. Under CBC Section 11B-202.4, Exception 8, the answer depends on whether the adjusted construction cost lands above or below the valuation threshold.

Below or equal to the threshold, the cost of compliance is limited to 20 percent of the adjusted construction cost. Where full compliance would exceed 20 percent, you comply to the greatest extent possible without exceeding it. This behaves like the federal rule.

Above the threshold, full compliance is required. Relief is available only if the enforcing agency determines that the cost of compliance is an unreasonable hardship — and even then, the code states that in no case shall the cost of compliance be less than 20 percent of the adjusted construction cost. The finding must be recorded and entered into the enforcing agency's files.

So on a project above the valuation threshold, 20 percent is no longer the point where the obligation ends. It is the point below which it cannot fall.

The valuation threshold is not a fixed number. It is adjusted annually from a 1981 baseline using the ENR construction cost index, so the figure that applied to your last project may not be the figure that applies to this one.

What counts toward adjusted construction cost, and what does not. The code defines adjusted construction cost as all costs directly related to construction — labor, material, equipment, services, utilities, contractor financing, contractor overhead and profit, and construction management.

It expressly excludes project management fees and expenses, architectural and engineering fees, testing and inspection fees, and utility connection or service district fees. It also excludes the cost of the path of travel alterations themselves.

Those exclusions move projects across the threshold. They are worth calculating before the scope is set, not after.

Work that does not trigger a path of travel obligation at all. Section 11B-202.4 limits a number of project types to their actual scope of work:

Altering one building entrance, one existing toilet facility, existing elevators, existing steps, or existing handrails.

Alterations undertaken solely for barrier removal under the ADA at 28 CFR 36.304 — installing ramps, making curb cuts, widening doors, installing accessible door hardware, creating designated accessible parking spaces, and the rest of that list.

Resurfacing or restriping an existing parking lot.

Adding or replacing signs and identification devices.

Projects consisting only of HVAC, reroofing, electrical work not involving placement of switches and receptacles, cosmetic work not affecting regulated items, and equipment not considered part of the architecture — unless they affect the usability of the building.

Two provisions that catch phased projects. Where path of travel elements were built to the immediately preceding edition of the California Building Code, they need not be retrofitted to reflect incremental changes solely because an area they serve is altered. The code notes that this reaches back one edition only and is not cumulative to prior editions.

And if an area is altered without providing an accessible path of travel, and further alterations to that area — or to a different area on the same path of travel — are undertaken within three years, the total cost of all those alterations over the preceding three-year period is considered in determining whether the path of travel cost is disproportionate. Splitting a project into phases does not reset the calculation.

These are the determinations we make on projects every week: which standard governs, where the valuation threshold falls, what counts toward adjusted construction cost, and which parts of the scope trigger a path of travel obligation. Getting them settled during design is considerably cheaper than discovering them in plan check.

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