is a delivery truck dock entrance for the driver, an accessible entrance per 206.4.1

I have been challenged on plan check and want to make sure I am not being too conservative in my interpretation of 11B-206.4., and would appreciate knowing what others think.

 

Entrances and exterior ground floor exits.
All entrances and exterior ground-floor exits to buildings
and facilities shall comply with Section 11B-404.

The picture indicates the situation at issue. The trucker's entrance at the truck dock is via steps. I think it is an entrance subject to 11B-206.4

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