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Conoboy-CS171101 omcuecompany OL.. /fit ler P.O. Box 116747 • Carrollton,TX 75011-6747 • Voice:(214)755-2525 01 NOV2017 Mr. Michael Adams Firmitas Design 2735 Villa Creek Drive -#275 Dallas, TX 75234 Project Name: - PENCE OFFICE Address - 717 South Coppell Road &446 Houston Street City, State -Coppell, TX 75019 REVIEW—COMPLETED The application of the Texas Accessibility Standards(TAS) and scope of this review is limited to those accessible elements constructed, renovated, modified, or altered within the scope of this project. These pedestrian elements are subject to compliance with TAS Chapter 2 through TAQS Chapter 9 except as modified by the Texas Department of Licensing and Regulation (TDLR) Administrative Rule 68.102. Thank you for providing the footprint for the proposed project. The question posed was does the proposed accessible parking space and hash marked access aisle meet the technical and scopinq requirements of the 2012 Texas Accessibility Standards. Yes, the parking space and access aisle are provided in accordance with 208 scope and 502 parking spaces technical elements. The Standards require that 60% of public entrances be accessible. As there are only two doors,this appears to be satisfied. Additionally, a question was posed about requirements for accessible parking on Houston Street which also has an accessible entrance. The sidewalks and parking spaces on public property are the responsibility of the City. The angled parking spaces on Houston Street serving this location as well and other buildings towards Burnet Street belong to the City of Coppell, and are part of the public right of way. The City of Coppell is required to provide accessible parking spaces based on the 208.2 Scoping—Parking Spaces—Minimum Number. While the site plan was not entirely complete to determine exactly how many total car or van accessible spaces there are,the existing accessible parking spaces identified appear to be provided for two accessible cars, not a van, based on the width of the access aisle. So the may be some exposure by the City for not having enough van or car parking spaces, population to be served, availability to the user, location relative to distance and time, location relative to isolation and separation,function of the building or facility and equal treatment and opportunity In all parking locations, at least one must be van accessible with the appropriate space for unloading, either 8'x8' or 11'x5'. And in angled parking the access aisle for van accessible parking must always be on the right side of the vehicle. While we know it is nearly impossible to provide an accessible parking space in front of every business, an accessible route that is reasonable in distance should be considered to allow mobility individuals an opportunity to access the same businesses as abled body person without an undue burden. While you have satisfied the requirements for parking and access to your facility,the City of Coppell may be opening themselves up for potential Civil Rights legal action by individuals and"drive by"attorneys for not providing any additional accessible parking. In conclusion: The parking spaces along Houston Street are the responsibility of the City of Coppell. The City of Coppell maybe in compliance and may be confident they do not have to add another accessible parking location, as we do not have a full pictu'e of all of their parking along this street. But, as I noted above, I did not see a space for"van"accessible parking. The relative distance to travel from the only identified accessible parking (with no van parking) is a good distance from your proposed facility other public entrance or end of the block. As I shared with you on the phone, the ADA Design Guide has warned that if a business, State or local government agency, or other covered entity restripes a parking lot(space), it must provide accessible parking spaces as required by the current ADA/TAS Standards for Accessible Design. Failure to do so would violate the ADA/TAS. A large number of"drive by"attorneys have filed numerous claims in Federal Court on behalf of their'clients"for just this reason. I recommend that two accessible parking spaces on Houston Street in front of your building or that end of the block be constructed, with curb ramp of course, and one the space on the left side be the van space with the appropriate with access aisle. The other for accessible car. Spaces should be marked with signage matching the usage of the space. Sincerely, Michael Quimbey—RAS#0102 EMCUE Company, Inc. PO Box 116747 Carrollton,TX 75011 214-755-2525(cell) GENERAL NOTE: According to typical details and general notes provided in Texas Department of Transportation (TxDOT) Pedestrian Facilities PED-'2, the following pedestrian facilities constructed, modified, or altered within the scope of this project will comply with TAS Chapter 2 through TAS Chapter 9 and Rule 68.102. GENERAL NOTE: In accordance with Rule 68.102, in Public Right-of-Way areas where the adjacent roadway has running slopes of 5% or greater, the pedestrian access route shall not exceed the grade established for the adjacent roadway. This running slope deviation from the requirements of TAS 403.3 shall also be applicable to any newly constructed, renovated, modified, or altered exterior circulation path that is improved for use by pedestrians, including but not limited to, sidewalks,driveways, crosswalks, and curb ramps. The cross slope, however, is subject to compliance with the following: 403.3 Slope. Nowhere shall the cross slope of an accessible route exceed 1:48. 201 APPLICATION. 201.1 SCOPE. All areas of newly designed and newly constructed buildings and facilities and altered portions of existing buildings and facilities shall comply with these requirements. These standards apply to fixed or built-in elements of buildings, structures, site improvements, and pedestrian routes or vehicular ways located on a site. Unless specifically stated otherwise, advisory notes and figures explain or illustrate the requirements of the standards; they do not establish enforceable requirements. The standards for determining the appropriate or minimum numbers contained in this document are considered minimal and the Executive Director shall have the authority to make adjustments when it is determined that the standards would cause the numbers or locations to be insufficient to adequately meet the needs of people with disabilities based on the nature, use, and other circumstances of any particular building or facility. In determining the appropriate number and location of a particular element, space, or fixture, the following factors shall be among those considered: (i) population to be served (ii)availability to the user; (iii) location relative to distance and time; (iv) location relative to isolation and separation; (v)function of the building or facility; and (vi) equal treatment and opportunity 206 ACCESSIBLE ROUTES. 206.1 General.Accessible routes shall be provided in accordance with 206 and shall comply with Chapter 4. COMMENTS: 1. Public sidewalks and curb ramps are indicated outside of the established property boundaries of this site. For the purposes of this review, property under separate ownership cannot be reviewed for compliance with these Standards. See General Disclaimer below. For more information regarding the Texas Accessibility Standards or the Rules of the Texas Department of Licensing and Regulation, please visit the TDLR website by typing: TDLR access, once the page opens up, click on "Elimination of Barriers". GENERAL DISCLAIMER: This worksheet and report does NOT cover any elements, spaces or features which have been located OUTSIDE of the established property lines of this site, or in any adjacent easements or right-of-ways, which may include public streets, sidewalks, access drives, ramps, curb ramps, and public transportation stops. The public entity having ownership of those areas must obtain separate approva' for that work where required under the Texas Architectural Barriers Act(TABA). BUILDING AND FACILITY OWNERS: It should be noted that EMCUE Company, Inc. has NOT verified compliance for the Project with the standards referenced in Section 105.2 of the 2012 Texas Accessibility Standards(TAS), including, but not limited to, the International Building Code (IBC) (collectively, the"Referenced Standards"), consistent with the Texas Department of Licensing and Regulation's Registered Accessibility Specialist Bulletin 2012-01 issued April 16, 2012. EMCUE Company, Inc. has not agreed to review the Project for compliance with the Referenced Standards, nor has EMCUE Company, Inc. actually performed a review of the Project for compliance with the Referenced Standards, and EMCUE Company, Inc. expresses no opinion whatsoever regarding the Referenced Standards. The review of documents, contract documents and field inspections for this project by this registered accessibility specialist(RAS) for the Texas Department of Licensing and Regulation (TDLR) Standards, is based on best efforts endeavor following the completion of training, certification and licensing by the TDLR. The Registration, Plan Review and Site Inspection shall in no way imply or warrant complete compliance with the Texas Accessibility Standards. Information is based upon the plan and specifications submitted to the RAS and/or the site inspection, on the date noted on the documents. The business, professionals, engineers, their employees, and clients for whom the review or inspection is made, agrees to hold harmless and indemnify this RAS by all parties from and against liability arising from the performance of the work. The determination does not address applicability of the Americans with Disabilities Act(ADA),(P.L. 101-336), or any other state, local, or federal requirement. For information on the ADA, call the ADA Hotline, (800)949-4232 or the United States Department of Justice at (202) 514-0301. Sincerely, Michael Quimbey— RAS0102 The information herein and related documents are provided by a Registered Accessibility Specialist(RAS)for The Texas Department of Licensing and Regulation, upon completion of training and certification by TDLR. It is based upon the plans and specifications submitted and information available at the time of review. This shall not imply nor warrant complete compliance of the referenced project to the Texas Accessibility Standards. The RAS aid the Texas Department of Licensing and regulation shall be indemnified and held harmless by all parties from and against liability arising from the performance of the work.