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

My analysis so far leaves an intent question (see last line) that I will have to ask of DSA.


General Exemptions don’t help:We have our general exemptions that do not apply. I can forget about those although here are the ones that are close just for reference in case I am missing something:

11B-203.1 General. Sites, buildings, facilities, and elements are exempt from these requirements to the extent specified by 11B-203. 

11B-203.5 Machinery spaces. Spaces frequented only by service personnel for maintenance, repair or occasional monitoring of equipment shall not be required to comply with these requirements or to be on an accessible route. Machinery spaces include, but are not limited to, elevator pits or elevator penthouses; mechanical, electrical or communications equipment rooms; piping or equipment catwalks; water or sewage treatment pump rooms and stations; electric substations and transformer vaults; and highway and tunnel utility facilities 

11B-203.6 Single occupant structures. Single occupant structures accessed only by passageways below grade or elevated above standard curb height, including but not limited to, toll booths that are accessed only by underground tunnels, shall not be required to comply with these requirements or to be on an accessible route. 

The general requirement for entrances:If an area containing the entrance is not subject to general exemptions then every entrance is covered by 206.4:

 11B-206.4 Entrances. Entrances shall be provided in accordance with Section 11B-206.4. Entrance doors, doorways, and gates shall comply with Section 11B-404 and shall be on an accessible route complying with Section 11B-402.

 Restricted entrance provision:Public entrance, restricted entrance and service entrance are all defined so the fact that 206.4 does not distinguish between them means it may apply to all these types of entrances. Strangely, there is section 206.4.7 that follows 206.4, feels like an exception, but is not placed as an exception to it. It seems to suggest a partial exclusion for restricted entrances because it requires the door to be accessible (404) but not that it be on an accessible route (402). 

11B-206.4.7 Restricted entrances. Where restricted entrances are provided to a building or facility, all restricted entrances to the building or facility shall comply with Section 11B-404.

 This is a restricted entrance, not a service entrance:The definition of restricted entrance excludes entrances that are primarily service entrances, and that is ok because this is not an entrance primarily for the delivery of goods or services, only occasionally when the package is small; usually goods are coming through the roll-up door, not the man-door entrance: 

RESTRICTED ENTRANCE. An entrance that is made available for common use on a controlled basis, but not public use, and that is not a service entrance.

SERVICE ENTRANCE. An entrance intended primarily for delivery of goods or services.

 Conclusion:If 11B-206.4.7 is meant to be an exception of sorts for the full requirement of 206.4, then a restricted entrance may comply with 404 and not 402, and this appears to be a restricted entrance. I am still left with doubts as to whether 206.4.7 is intended to trump 206.4 in this regard.

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