1.2.3 Accessibility Scope and Path of Travel (POT)

Planning Rationale

This section is provided to outline Americans with Disabilities Act (ADA) and Illinois Accessibility Code (IAC) requirements that apply to construction projects and, more particularly, to alterations and renovations in elementary and high schools. CPS has completed many construction projects throughout the district to remove physical barriers and provide options for disabled students to enable them to attend schools with particular programs, gifted schools and schools in their own neighborhoods. CPS has reviewed the success of various changes and modified standards or stipulated specific elements that are required to address particular groups of students, including various ages of children. These Design Guidelines have been developed to clarify standards for alterations or additions to respond to the needs identified in the schools, which may not be clearly addressed in Local, State and Federal Accessibility Standards.

This serves as a useful tool for alteration projects as it provides interpretations of applicable standards and identifies the appropriate level of access for students. The guidelines also address appropriate variations for particular age groups, and ways in which the standards are employed to meet unusual student needs that may not be clearly defined in other standards. A Student Accommodation Project (SAC) addresses specific scope requirements at a particular school for accommodations for identified students to provide barrier-free access. Additionally, these guidelines offer practical solutions for common problems inherent in older school buildings by providing examples that achieve a high degree of access. The CPS Design Guidelines and related Accessibility Standard Detail drawings have been reviewed and approved by the Mayor’s Office for People with Disabilities (MOPD).

Information about applicable regulations is indicated below along with the CPS criteria. This information is provided to assist the AOR/EOR, to evaluate schools and make appropriate decisions about accessibility modifications. However, the AOR and design team is responsible for identifying and interpreting the latest version of each applicable regulation, code or standard and applying them to design elements and spaces using the most stringent requirements.

The terms renovation and alterations are used interchangeably in the guidelines and the both terms apply to changes made to an existing structure. The applicable standards, Chicago Building Code (CBC), Illinois Accessibility Code (IAC), American National Standards Institute (ANSI), Americans with Disabilities Act Accessibility Guidelines (ADAAG), and 2010 ADA Standards for Accessible Design, refer to such changes as alterations. It is understood that these terms refer to the same conditions and the alteration standards apply to renovation projects

Primary Function Areas (PFA)

Primary Function Areas are defined as all spaces where activities take place for which the building was specifically designed. Examples include: Classrooms (all types), Offices (Administrative and Counseling), Shops/ Labs/Makerspaces, Libraries/Media Centers, Cafeterias/Serverys, Aquatic Centers, Gymnasiums/Auditoriums, Performing Arts Spaces, Strength Training and Fitness, Locker Rooms, Athletics Fields (Turf), Sports Fields/ Courts, Play Fields, and Playgrounds. Spaces that are not considered Primary Function include but are not limited to: Corridors and Entrances, Toilet Rooms, Parking Lots, Kitchen, Storage, Boiler and Mechanical Equipment Rooms.

Campus Accessibility Levels

All CPS sites are assigned one of three levels of accessibility based on information gathered by the district’s Facility Assessment Team. Campuses that comprise multiple sites are assigned an accessibility level based on Program Accessibility of all of the associated facilities.

When the accessibility level is Usable, at least one building on the campus contains, or can reasonably contain without major renovation, all of the program requirements of the associated buildings of a campus. At a minimum, the following elements meet or are in substantial compliance with the ADA requirements for Program Accessibility:

A public site arrival point with a route to the building
An entrance into the building
Main Office
One (1) set of public Toilet Rooms (Student multi-stall) or, two (2) single occupancy All Gender Toilet Rooms
At least one of each type of student and public Special Function Room (where exists) as follows:

Auditorium
Cafeteria
Library
Gymnasium/Gymnatorium
Student Locker Rooms
Horizontal and vertical interior routes as necessary to reach the Special Function Rooms listed above

When the accessibility level is First Floor Usable, there is, at least, a route to the main floor (usually the First Floor) of the facility on the campus which provides the most complete selection of programs offered on the campus. At a minimum, the following elements meet or are in substantial compliance with the ADA requirements for Program Accessibility:

A public site arrival point with a route to the building
An entrance to the building
An interior route from the entrance to the main interior floor (usually First Floor)
A Main Office
One (1) set of public Toilet Rooms (student multi-stall) or two (2) single occupancy All Gender Toilet Rooms

Parking Accessibility Levels

Accessibility Level for the Building does not include Parking as a criteria. Parking is evaluated separately in order to distinguish between potential uses (i.e student’s use of the building who arrives via bus versus a visitor who drives to the site). All CPS sites are assigned one of three levels of parking accessibility based on information gathered by the district’s Facility Assessment Team.

Parking

Accessible parking spaces shall be placed nearest the designated main accessible entrance.
The accessible route from the accessible parking spaces to the designated main accessible entrance shall be outside of vehicular traffic path.
Provide wheel stops or a raised curb at all parking spots adjacent to an accessible travel path.
Provide concrete filled sign post protection at all post mounted signs. See ADA Sheet ADA.01 Detail 6.

Entrance & Exits (openings where students and visitors enter and exit)

When altering only one entry, that entry shall be made accessible.
Alterations to multiple entries require a minimum of 60% of the building entries to be made accessible.
Doors and stairs serving exits shall have accessible handrails, accessible exit doors, and stairs.
If exterior entrance stair renovations occur, provide at each location an accessible route to each entrance from grade level to doorway.

Stairs, Ramps, Sloped Walkways

Detectable warnings and stair edge conditions
CPS requires an additional length of horizontal handrail extended at the bottom of stairs. CPS standard handrail extensions exceed the Federal requirements. See ADA Sheet ADA. 07 Detail 1A and 1B.
For slope requirements reference Ramps, Level Changes in Volume 3, 2.2, page 82. Any requested deviations due to physical site constraints shall be approved by CPS.

Doors
Windows
Toilet Rooms

The Illinois State Plumbing Code requires all single user toilet rooms to be deemed All Gender. CPS requires that at a minimum, two (2) accessible All Gender Toilet Room be provided when a set of multistall toilet rooms are being renovated.

Drinking Fountains
Lockers
Auditoriums Seating, Flooring and Stage
Flooring
Signs
Exterior Spaces

Path of Travel Improvements triggered by Alterations to Primary Function Areas

A “path of travel” includes a continuous, unobstructed way of pedestrian passage by means of which the altered area may be approached, entered, and exited, and which connects the altered area with an exterior approach. For the purposes of this section, the term “path of travel” also includes the restrooms and drinking fountains serving the altered area.

Alteration work to Primary Function Areas might trigger additional work outside the spaces.

Up to 20% of the cost of an alteration of a space containing a Primary Function Area shall be allocated towards improvements outside the space for Path Of Travel improvements (if they are not already in place). See below for Path of Travel (POT) improvement triggers associated with work in Primary Function Areas (PFA).

Path of Travel Improvements include the following:
Providing accessible parking spaces.
Providing an accessible path to the Primary Function Area space being altered.
Providing accessible entries to reach the Primary Function Area space being altered.
Providing Toilet Rooms Accessibility upgrades and/or add an All Gender Toilet Room on the way to the Primary Function Area space being altered.
Providing accessible drinking fountains on the way to the Primary Function Area space being altered.

Note: Areas which are not essential to school programs such as, Parking Lots, Building Entrances, Corridors, Toilet Rooms, Storage Rooms, Boiler Rooms, etc. are NOT considered Primary Function Areas and do not trigger the 20% alteration cost.

Door alterations/replacement located in a Primary Function Area when the work is undertaken for purposes other than to meet the program accessibility requirements of associated space (see exemption below).
Incidental flooring repairs/replacement related to damages caused by a breach in the building envelope and when the quantity of replaced flooring is in excess of 20% of the flooring area located in a Primary Function Area.
Flooring repairs or patching related to replacement of floor mounted equipment or casework and when the quantity of the flooring is in excess of 20% of the flooring area located in a Primary Function Area.
The floor area in a Primary Function Area is increased. For example, when a storage room in an art room is demolished and the storage room area is incorporated into the classroom SF.
Complete renovation of a Primary Function Area.

When the facility already includes a fully accessible Path of Travel to all Primary Function Areas.
When the facility is already deemed Usable or First Floor Usable.
When alterations in a Primary Function Area are undertaken solely for the purpose to meet the program accessibility requirements.
Where it can be demonstrated that it is structurally infeasible to meet the requirements. Full compliance will be considered structurally impracticable only in those rare circumstances when the unique characteristics of terrain prevent the incorporation of accessibility features. Documentation will be required for the Mayor’s Office for People with Disabilities (MOPD).
When the cost of alterations necessary to make the Path of Travel to the altered area fully accessible is disproportionate to the cost of the overall alteration, the Path of Travel shall be made accessible to the extent that it can be made accessible without incurring disproportionate costs.
When the cost of providing the accessible route is not required to exceed 20% of the material costs of the alterations affecting the area of primary function.
When alterations are limited solely to windows, hardware, operating controls, electrical outlets and signs.
When alterations are limited solely to mechanical systems, electrical systems, installation or alteration of fireprotection systems and abatement of hazardous materials.
When alterations are limited solely to cosmetic work such as painting and minor plaster repairs.
When Path of Travel improvements are triggered, one accessible All Gender Toilet room may be provided in lieu of accessible Multiple Stall Toilet Rooms for each sex, if the total area of the accessible Primary Function Area is less than 5,000 net square feet.
When Path of Travel improvements are triggered and it can be demonstrated that it is structurally not feasible to convert the Multiple Stall Toilet Rooms to meet all accessibility requirements and at the same time maintain code required fixture counts, a single fully accessible All Gender Toilet located elsewhere along an accessible path may be provided instead.

New and renovated Toilet Rooms shall be designed in compliance with all applicable codes, standards, and the CPS Standard ADA Accessibility Details.

Clearances: Space must be provided within the Toilet Room to accommodate all required clearances: entrance door(s) and/or alcove, turning space within the room and required clearance at fixtures and dispensers.
Pre-K-8 Schools: 1st floor Toilet Rooms to meet elementary standards. Pre-K/K requirements to be addressed based on single user or Multi-stall Toilet Room conditions for applicable age group standards.
All Gender Toilet Room: Where required by Code, All Gender toilet rooms in each school shall be designed to meet adult standards for accessibility requirements and the CPS Accessibility Standard Details.
Pre-K/K Toilet Facilities: Addressed in an associated Toilet Room accessed directly from the classroom. When not feasible due to space or budget, a Pre-K/K accessible stall can be located within the multi-stall toilet rooms at the 1st floor (one each for boys and girls). Facilities with multiple Pre-K/K classrooms and multi-stall Toilet Rooms shall provide appropriate accessible toilet stalls and additional age appropriate height toilets in additional stalls sufficient to accommodate the expected population.