TPS offers great guidance for meeting ADA and the Standards: Preservation Brief 32: Making Historic Properties Accessible Planning Successful Rehabilitation Projects, Codes-Technical Preservation Services, National Park Service https://www.nps.gov/tps/standards/applying-rehabilitation/its-bulletins/ITS53-Additions-Accessibility.pdf For tax credit projects, I try to steer developers in the direction of the reasonable access provision under ADA, which usually depends on the proposed use of the building. This provision does not mean that no access is provided to upper floors; it means that you must have material on the first floor, such as video or interpretive materials, that allow the visitor to experience the entire property, even those areas that aren't accessible. For some properties, this just isn't possible due to other circumstances, such as cultural affiliation. For example, the Muskogee (Creek) Nation Council House (an NHL) in Okmulgee, Oklahoma is undergoing a historic rehabilitation for tax credits. Because the tribe considers the second floor spaces its primary spaces, accessibility must be allowed for tribal elders. As a result, a wheelchair lift is being inserted discreetly into a corner. This is also necessary because the Council House is the center of the downtown square in Okmulgee; thus, an elevator tower really is not an option. Otherwise, we prefer developers provide accessibility by inserting elevators into more secondary spaces, such as the back of an historic downtown commercial building that is being rehabilitated for mixed use with residential on the second and third floors. If there is an alley, then an elevator tower could be incorporated in a way that meets the Standards. This is especially important for those developers coupling the historic tax credits with other incentives such as LIHTC and New Markets.ADA compliance is another good reason why each tax credit project must be considered on a case-by-case basis. In the end, if it's private money, then the Standards don't have to be met. Thus, you can put an elevator or wheelchair lift where ever you want to put it. We always steer folks in the direction of the guidance provided by TPS hoping that they'll make a decision that is compatible with their building.I hope this helps.
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