POLICY REPORT
URBAN STRUCTURE

TO:

Standing Committee on Planning and Environment

FROM:

General Manager of Engineering Services, in consultation with the Director of Current Planning, the Director of City Plans, the Chief Building Official, and the Director of Legal Services

SUBJECT:

Disability Parking Space Requirements

 

RECOMMENDATIONS

As an alternative to A, the following is put forward for CONSIDERATION:

GENERAL MANAGER'S COMMENTS

COUNCIL POLICY

Relevant Council policy includes:

· Parking By-law
· Building By-law

PURPOSE

This report brings forward proposals to amend the Parking By-law and Building By-law in regard to improved accommodation of persons with physical disabilities who require parking. The proposed amendments would increase the number and size of disability spaces, and introduce different standards for uses with greater and lesser needs city-wide. Also, provision for improved access to ticketing machines is proposed. Finally, steps to improve accessibility for existing parking facilities, whether under City ownership or not, are brought forward.

SUMMARY

After detailed study, staff recommend changes to the Parking By-law and Building By-law with respect to the quantity and design of disability parking spaces. Proposed changes are:

· For multiple dwelling, retail, and medical facility uses (except veterinary), as well as hotels and churches, chapels, funeral homes, places of worship, or similar places of assembly, there should be one disability space once 10 total parking spaces are provided, two once 40 spaces are provided, three once 75 spaces are provided, and one additional disability space for each additional 50 parking spaces provided.

· For seniors care facilities and housing, the first two spaces provided should be disability spaces, with one additional disability space for every 15 parking spaces provided after the first 15 total spaces.

· For all other uses, which includes offices, theatres, arenas, and similar places of public occupancy, among others, there should be one disability space once 25 total parking spaces are provided, two disability spaces once 75 total parking spaces are provided, three disability spaces once 150 total spaces are provided, and one additional disability space for each additional 100 parking spaces.

· Where parking is relaxed for cultural and recreational uses, as well as churches, chapels, places of worship, or similar places of assembly, disability parking spaces should be provided per the full, unrelaxed parking requirement.

· Each required disability space that is provided should be counted as two spaces for the purpose of satisfying the minimum requirement for parking spaces.

· A disability space should have its minimum width increased from 3.7 metres to 4.0 metres, and its minimum vertical clearance increased from 2.0 metres to 2.3 metres (Recommendation A refers). Should the increased vertical clearance not be supported for small developments, Council should consider allowing when only one disability space is required, that it be required to have the current minimum 2.0 metres of vertical clearance (Consideration C refers).

· The Building By-law should be amended to ensure that ticketing and pay station equipment, as well as entry and security devices, within parking facilities are designed in such a way that permits use by all.

In addition, staff will pursue the upgrading of existing parking facilities to meet the new standards via reviewing the lay-outs at City-owned parking sites and publicizing changes in standards to the private sector.

The changes proposed, together with adequate levels of inspection and enforcement, will ensure a high level of service to persons with physical disabilities in the use of motor vehicles in Vancouver.

BACKGROUND

Staff continually review parking requirements, but parking for persons with physical disabilities had not been reviewed for many years. Citizens have brought forward concerns that in several locations across the city the disability parking spaces provided have not been adequate. With some 37,000 disability placards issued to residents of the Lower Mainland, including roughly 10,000 within Vancouver specifically, by the Social Planning and Research Council (SPARC) of British Columbia, close to 2 percent of the population, constituting about 3.5% of those licensed to drive passenger vehicles, may be considered in need of disability parking spaces. Developments in Vancouver are now required to provide one percent of parking in this format, and none when 50 or fewer total parking spaces are required.

With the "age creep" of the population, the need for disability parking is expected to increase. To ensure the number of spaces meet the need, and address existing shortcomings in disability parking, staff conducted a comprehensive study of disability parking in the summer of last year. The initiative resulted in the document entitled Disability Parking Study, available through the office of the General Manager of Engineering Services or the City Clerk's Office.

DISCUSSION

The study by staff found that the City's Parking By-law standards need to be revised. The study examined both the quantity of spaces needed and the size of an individual space. In response to public feedback and local experiences, staff considered five significant types of uses for distinct standards: multiple dwelling, seniors care facilities and housing (including nursing homes and congregate housing), retail, medical facilities, and general (or other) development. Information gathered included site observations, interviews with managers, and standards employed in other jurisdictions. Observations took into account both legitimate usage and abuse of the disability spaces as well as overall lot occupancy. Interviews with managerial staff gathered comments on complaints from visitors, abuse, adequacy of the site's disability spaces, and what number of these spaces the site ideally should have.

Information from other municipalities across Canada, plus Seattle and Phoenix, found that Vancouver lies in the middle of the pack in terms of its requirements. When compared with those jurisdictions which have reviewed their standards of late, however, Vancouver is low. Those with more up-to-date standards feature lower thresholds upon which disability parking becomes required and differentiate between uses generating greater versus lesser demand for disability spaces.

Site investigations indicated that where a building provided only the minimum, a disability space was available only about one-third of the time.

Multiple Dwellings

Relatively few problems were encountered amongst the sites studied. This was due to frequent excess provision of disability spaces beyond the minimum requirement. Also, though some 3.5% of the driving public requires disability parking, those with physical disability will tend to seek out dwellings that can accommodate them, and are more concentrated within housing for seniors.

An increased minimum requirement is appropriate to improve availability for current needs and prepare for greater needs in future. Evidence suggests at least 2% of parking provided should be designated for this purpose. As well, a reduced threshold is recommended. Therefore, it is recommended that the first disability space should be required upon a total parking provision of 15 spaces, the second space when 40 are provided, the third at 75 spaces, and an additional disability space for each additional 50 total spaces. (see Table 1 and Figure 1, Appendix B). This will generally more than double the number of required disability spaces.

Seniors Care Facilities and Housing

Staff found that though more than the minimum requirement was being provided, disability spaces typically were only available 50 to 74% of the time. Other cities with standards similar to Vancouver's reported problems for residents and their visitors. The evidence suggests that a ratio of one disability space per 15 total parking spaces would satisfy demand most if not all of the time. The minimum requirement recommended for special needs residential facilities, community care (Class B), as well as seniors congregate or similar housing is based on this ratio. In order to ensure a supply of spaces accessible to residents, visitors, or volunteers with limited mobility, however, in any new facility the first two parking spaces provided should be disability spaces (see Table 1 and Figure 2, Appendix B), with the third disability space provided at 30 total spaces provided, fourth at 45, etc.

Retail

Staff found that large commercial centres typically have inadequate disability parking. During peak demand periods, when the parking would be fully used it is estimated that twice as many disability spaces spaces would be required to meet the observed needs. Also Vancouver's standard for this use category is near the low end of the spectrum compared with other cities. As abuse was found to be light, staff conclude that legitimate demand was present to warrant a higher standard.

The standard proposed for multiple dwelling is similar to the demand for retail use. Thus, it is recommended that the same standard apply (see Table 1 and Figure 1, Appendix B). This will generally more than double the number of required spaces.

Medical Facilities

Though the health care offices studied were providing more than the required number of disability spaces, average adequacy was found to be only 25 to 49%, which clearly is not satisfactory. Visitors to these facilities count disproportionately high numbers of persons with disability compared with most other uses. Other cities have recognized this by establishing higher standards of parking. Once again, the standard proposed for multiple dwelling (and retail) use is most appropriate (see Table 1 and Figure 1, Appendix B). This standard should be applied to all medical facilities (including hospitals, health care offices or clinics, and health enhancement centres), except for veterinary offices or clinics.

General Use including Office

The remaining uses, which include offices, generally can be well-served with the existing standard of the Parking By-law. This is confirmed by the information gathered from other cities. The only change recommended is to lower the thresholds at which the initial two disability spaces are required. Thus, it is recommended that the first space be required when a total of 25 parking spaces are provided, the second when 75 total parking spaces are provided, the third at 150 spaces, and an additional disability space be required for each additional 100 total parking spaces (see Table 1 and Figure 3, Appendix B). This will generally result in one additional space.

TABLE 1
DISABILITY PARKING SPACE REQUIREMENTS

 

Existing

 

Proposed

  
 

All Uses

Multi-dwelling, Retail, Medical Facility, Hotel, & Church Uses

Seniors Care Facilities and Seniors Housing

Other Uses including Office & Theatre Uses

Total spaces

Total Number of Disability Spaces Required

0 to 50

0

0 to 2

2 to 4

0 to 1

51 to 149

1

2 to 4

4 to 10

1 to 2

150 to 249

2

4 to 6

3

250 to 349

3

6 to 8

4

350 to 449

4

8 to 10

  

5

450 to 549

5

10 to12

  

6

1 per 100spaces above 50

1 per 50 spaces above 75

1 per 15 spaces above 15 (2 min.)

1 per 100spaces above 150

Consistency

Finally, the wording in the Parking By-law differs from the wording in the Building By-law governing the number of disability spaces required (see Appendix A). This can lead to a different calculation of the number of required disability spaces. For hotel use, the Building By-law requires that one in forty rooms be accessible, and that there be an equal number of disability parking spaces. Similarly, for certain assembly occupancies, such as theatres and auditoria, the Building By-law triggers disability parking requirements based on the number of viewing positions specified, though users may have arrived by taxi or handidart rather than their own vehicle. Again, this results in different calculations from that of the Parking By-law.

The amendments proposed in this report eliminate these inconsistencies. For hotel use, it is excessive to provide disability spaces on a one-for-one basis with accessible suites. Since parking requirements are either 0.3 space (downtown) or 0.5 space (elsewhere) per hotel suite, given that many guests arrive by taxi or other means apart from a private vehicle, a reduction is appropriate. Including hotels with the standard proposed for multiple residential, retail and medical uses would generate disability spaces-to-accessible suites in a ratio generally comparable with or higher than the parking-to-suite ratios of hotels both within and outside the Downtown. To minimize the number of separate standards, it is recommended that hotels be assessed the same as multiple residential, retail, etc. uses. Similarly, it is recommended that for assembly occupancy uses with viewing position requirements, the standards proposed within the Parking By-law for theatres, arenas, and similar places of public occupancy (i.e. "other uses") should govern.

OTHER ISSUES

Design Issues

Design-related concerns deal with the size, location, and signage of disability parking spaces. Furthermore, the inaccessibility of ticketing equipment and the inconvenience of pay stations also have caused concern.

Dimensions - The width and height (vertical clearance) of disability spaces have been found to be inadequate. The Parking By-law requires that disability spaces have a minimum width of 3.7 metres (12 feet), which is 1.2 metres (4 feet) wider than a standard parking space. There is no additional vertical clearance required, so disability spaces bear the same 2.0 metre height requirement as applies to standard parking spaces. A customized mini-van with a side-lift needs an additional width of 1.5 metres (5 feet), and often has its roof heightened by up to 0.4 metre (16 inches). Given that stock mini-vans typically are 1.7 to 1.9 metres in height, it is recommended that the vertical clearance required for disability spaces be increased to a minimum of 2.3 metres.

While Vancouver's 3.7 metre standard is near the average of cities surveyed, Seattle's requirement for a 5-foot aisle supplementing the basic 8-foot parking stall, for a total width of 13 feet, or 4.0 metres (rounded to the nearest one-tenth of a metre), is more suitable for accommodating a broader spectrum of persons with physical disability. The 13 feet standard is also what the widely-used Americans with Disabilities Act Accessibility Guidelines specify. The equivalent 4.0 metre width is recommended for Vancouver. Though the AADAG calls for one in eight, but at least one, disability space to be "van accessible", with a minimum height clearance of 96 inches (2.49 metres), this is not proposed for Vancouver, as the design and cost implications for relatively small marginal benefit would be disproportionate, what with the trend toward mini-van conversions as opposed to full-sized van conversions.

Location and Signage - Location and signage of disability spaces are regulated by the Parking By-law and Building By-law (see Appendix A). Parking By-law requirements for satisfactory location and labeling allow for flexibility, while the Building By-law calls for spaces to be close to a conforming entrance, "accessible", and clearly identified for their intended use. The requirement for disability spaces to be close to an entrance is important in parking structures. In large surface lots, their location near the building entrance, especially on large retail sites, makes disability spaces vulnerable to abuse. While those with walking aids require front-door convenience, those in wheelchairs can travel longer distances with less difficulty. Where spaces are not located at the front entrance (in surface lots) or near accessible exits (in structures), directional signage to these spaces should be clearly provided. Development review staff and inspectors shall make every effort to ensure location and signage of disability spaces meets users' expectations.

Ticketing and Pay Stations - Finally, the designs of ticketing equipment and pay stations, as well as security and entry devices, require consideration. These may be at inconvenient heights or out of reach due to the presence of curbs. Amendment of the Building By-law, with adequate inspection and enforcement, is proposed as the way to ensure that equipment is installed in a manner that ensures inclusiveness of all potential users.

Existing Parking Facilities

Should the changes proposed in this report be approved, parking facilities across the city will be found non-compliant with the new standards. Staff will take it upon themselves to publicize the changes to building owners, developers, parking operators, and design professionals, and encourage them voluntarily to bring existing facilities up to the new standards. In particular, staff should focus on bringing City-owned parking facilities up to standard (Recommendation B relates). To assist in offsetting increased costs relating to the expanded size and number of disability spaces, for existing and new facilities alike, staff recommend that each required disability space be counted as two parking spaces toward satisfying the total parking requirement.

PUBLIC INPUT

In March and April, a draft of this report was circulated to approximately three dozen organizations representing persons with disabilities, the development industry, design professionals, property owners, parking operators, community groups, City departments, and other regional municipalities.

Comments Received

· There was widespread support for the initiatives, especially the increased number of spaces and dimensions.

· The greatest concern, received from six respondents, related to the requirement for increased vertical clearance. While the chief concern was the cost implication, there was also concern that this could hamper compliance with building height restrictions. Furthermore, it is noted that the increased height would place Vancouver apart from the clearance stipulated in the BC Building Code.

· One respondent objected to the implications on parking efficiency relating to fitting within the standard structural bay rhythm, and questioned whether the larger space size was necessary. Meanwhile, another respondent from the development industry commented, "...we believe that the recommended 4.0 metre width could be accommodated by most developers at a reasonable extra cost..."

· Three respondents raised concerns over treatment of buildings becoming non-conforming, chiefly as to whether upgrading would be mandatory or how an upgrade would be triggered.

· One respondent questioned why the threshold for multiple residences or retail use would be set at 10 parking spaces, feeling this would impose too great a cost for small projects where underground parking had to be provided, especially with the increased height requirement. He also suggested a height increase of 0.15 rather than 0.3 metres would be more reasonable.

· Another respondent called for a specific time frame to upgrade City parking facilities, greater education of the general public and disabled parking permit holders, and improved enforcement. The respondent also questioned how the City would deal with lots with no disability spaces and whether the City could help offset costs to parking lot and building owners.

· Finally, a telephone respondent commented that better signage to elevators was needed, that SPARC should consider offering different types of decals, depending on the degree of mobility (i.e. closest spaces to the building entrance would be reserved those with the greatest impairment), and that there needed to be more spaces on the street restricted for the use of persons with a physical disability.

Staff Response

· To investigate the additional cost associated with increased vertical clearance, the City's Facilities Development Department analyzed the implications of adding 0.3 metre within the initial portion of the upper parking level of a two-level parkade serving a proposed high-rise multiple residence. The area with increased height could accommodate 2 disability spaces and another 4 or so overheight vehicles. It was estimated that the additional cost of this construction would be $20,500. Another $15,000 would be required for contingency, soft costs, and design and project management, though these cost factors would impinge on whatever design were used. While these costs should not be insurmountable for larger projects, they could pose problems for the viability of some smaller projects. In some cases problems of vertical clearance may be averted through careful planning of sprinklers, which commonly governs ultimate clearance. While staff support having all disability parking given added height, should Council wish to grant relief for smaller projects, it should consider not requiring added height for disability parking when only one such space is required in a parking structure.

· Staff believe that the increased width proposed for disability spaces does not pose a problem with respect to structural bay design. This is because the Parking By-law will continue allowing reduction of the total width of side-by-side disability spaces in that they may share the intervening access aisle.

· While staff intend to encourage building owners to upgrade their disability spaces to meet any new standards, this would not be mandated. The important objective is to achieve disability spaces which meet the latest standards in effect to the greatest extent where it is achievable cost-effectively. A directed awareness program is the means to advance this aim. To assist implementation of changes staff propose that, up to the minimum number of disability spaces required per the new standards, each disability space will count as two parking spaces. Increased height would not be required where technically infeasible within an existing structure.

· The threshold for retail and multiple residential uses is deliberately set low since these are among the most widespread uses, serving the entire population; therefore, it is essential to make them highly accessible. Should increased vertical clearance not be required for the first disability space, then impacts on small-scale developments would be relatively small, of the order of $10,000 to $15,000 for the additionalhorizontal area of an enlarged underground space; however, this would be offset by the forgiving of a required parking space from the total, as now proposed with the disability space counting doubly. Finally, if the height were only increased by 0.15 metre, this would still leave many adapted minivans unserved.

· As a result of comments received on churches and similar places of assembly, additional standard changes are supported which would put the uses of Section 4.2.3.4 of the Parking By-law (church, chapel, funeral home, place of worship, or similar place of assembly) in with multiple residential, retail, and medical office use concerning disability parking requirements. As well, where parking is relaxed for churches or similar uses, or in any cultural or recreational use, it is recommended that disability spaces be provided per the full, unrelaxed parking requirement.

· The City's parking operator, EasyPark, has stated support for upgrading to meet any new disability parking standards. Staff will work with EasyPark to implement these changes at the earliest time achievable. An education program for the public and disabled parking permit holders would be welcome; however, staff intend to direct publicity efforts on the new standards to building owners, developers, and design professionals. Staff would provide information on this to groups such as SPARC and the BC Coalition of People with Disabilities for use in their public information programs. While the City can seek greater enforcement by EasyPark, it will be left to private parking owners and operators to manage their enforcement programs as they see fit.

· Finally, better signage to elevators can be sought under existing requirements in the Parking By-law (section 4.12.4). Having different categories of disability placards and increasing the number of on-street disability spaces would have to be addressed separately from this report.

CONCLUSION

After extensive study, the City's existing requirements for off-street disability parking spaces have been found inadequate for the needs of today and the future. With Council's approval, the recommendations contained within this report, which have been modified following public consultation, would remedy the existing regulatory shortcomings and position Vancouver among the leaders in serving the needs of persons with disability.

APPENDIX A - TEXT AMENDMENTS

Existing wording in the Parking By-law Section 4.7.4 Disability Spaces is:

Existing wording in the Building By-law Section 3.8.3.4. Parking includes:

The Parking By-law amendments to be prepared for enactment would delete the text within Section 4.7.4, and any other necessary sections, and replace it with new wording to implement the following new standards (and add a table to describe them, if necessary):

1. For multiple dwellings, retail, and hospitals, health care offices, and health enhancement centres, as well as hotels and churches, chapels, funeral homes, places of worship, or similar places of assembly, there should be one disability space once 10 or more total parking spaces are provided, two disability spaces once 40 or more total parking spaces are provided, three disability spaces once 75 or more total parking spaces are provided, and one additional disability space for each additional 50 parking spaces.

2. For SNRF Community Care - Class B and congregate housing for seniors the first two parking spaces provided should be disability spaces and, from 15 total parking spaces upward, there should be one additional disability space for every additional 15 parking spaces.

3. For all other uses, there should be one disability space once 25 or more total parking spaces are provided, two disability spaces once 75 or more total parking spaces are provided, three disability spaces once 150 or more total parking spaces are provided, and one additional disability space for each additional 100 parking spaces.

4. Where parking is relaxed for cultural and recreational uses, as well as churches, chapels, places of worship, or similar places of assembly, disability parking spaces should be provided per the full, unrelaxed parking requirement.

5. Each disability space provided to satisfy the minimum required number of such spaces should count as two parking spaces for the purposes of satisfying the minimum requirement of the latter.

6. A disability space should have its minimum width increased from 3.7 metres to 4.0 metres, and its minimum vertical clearance increased from 2.0 metres to 2.3 metres (Recommendation A refers); furthermore, each disability space shall be labeled and located to the satisfaction of the Director of Planning who, in consultation with the City Engineer, may permit a lesser or greater width where he is satisfied as to the sufficiency of access to the space.

The Building By-law amendments to be prepared for enactment would amend Section 3.8.3.4.(1) to be consistent with the text being amended in the Parking By-law dealing with requirements for hotels and assembly occupancies with viewing position requirements and the dimensions of a disability space, and replace or delete the text within Section 3.8.3.4.(2) to be consistent with the text being amended in the Parking By-law. Finally, provisions should be incorporated into the Building By-law to ensure that ticketing and pay station equipment, as well as entry and security devices, within off-street parking facilities are designed in such a way that they can be operated by all authorized persons, with or without a physical disability.

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