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ADA and remodeling of an historic house

  • 1.  ADA and remodeling of an historic house

    Posted 11-05-2019 16:56
    ​Hello Fellow Forum Members,

    The Manhattan Beach (Calif.) Historical Society curates a number of historical artifacts as well as an historic house.  The City Council has set aside $200,000 for renovations to create a safe and secure environment for all of the records, pictures, furniture, etc. in the house.  Of course, as soon as renovation was mentioned, ADA was the next thing mentioned.   City staff said to bring the house up to ADA standards would require way more than $200,000 the project pretty much stopped dead in its tracks.  This says nothing of preserving the house's original architecture, amenities and charm.

    I find it hard to believe ADA didn't carve out some exceptions historical buildings.  In fact, I've discovered there are California Historical Properties Building codes.  I'm lead to believe these codes mitigate or make concessions pertaining to various rules when new construction in necessary.

    I'm hoping experts on this matter might weigh in on the Forum and provide advice or tell me where I might find good information on the applicable rules.

    Thank you in advance for any information you might be able to provide.

    Phillip Cook
    Manhattan Beach Historical Society
    Manhattan Beach CA

  • 2.  RE: ADA and remodeling of an historic house

    Posted 11-06-2019 07:57
    Hi Philip,

    I'm not an expert in ADA for historic houses, but I have had to work within its parameters on several projects here in Florida. If they want to bring it up to full ADA accessibility, then yes, it would be more than $200k, especially if it is a multistory home. However, in projects I have worked where 100% accessibility was not feasible, we have been able to use alternative solutions. At a minimum you would likely need a ramp at one of the entry point. For areas where ADA accessibility is not manageable, we have been allowed to have video or images of the area shown in an accessible area. For example, if someone cannot make it up the steps, we have a monitor showing rolling footage of the exhibit. Perhaps this could help you also.

    I don't think it should be a show stopper if you cannot come to full accessibility. Most of the historic homes I have visited have not been heavily modified to do so. This past summer I visited the Belmont Paul House in Washington, DC and had to navigate stairs to get to the upper levels. There was a ramp to get to the main floor, but that was all.

    All the best,

    Jennifer Mayo
    Kennedy Space Center Visitor Complex
    Kennedy Space Center FL

  • 3.  RE: ADA and remodeling of an historic house

    Posted 11-07-2019 11:45

    Our experience has been that working with local municipal plan reviewers and building inspectors is for best bet. They are the persons that interpret code and ADA based upon your building. We have always received permission (after walking the property with the inspector) to have the ADA entry point be on the side or rear of the building to avoid compromising the historic edifice. It helps if the building is locally designated. Your local HPRES office staff may be able to assist and intervene with plan reviewers and inspectors.

    The important topic is Change of Use. If you are not changing the building use, based on your municipality, you may not be required to bring the building up to full code compliance.

    The second important topic is occupancy. If the building occupancy is low enough, small measures may be all that is necessary.

    Costly elevators and long ramps are not automatically mandated. Consider lighter tough and more cost effective options such as porch lift or stair lift (attaches to the sidewall of a stair).

    Good luck!


  • 4.  RE: ADA and remodeling of an historic house

    National Trust Advisor
    Posted 11-06-2019 11:41
    ​Hello Phillip

    I agree with Jennifer's assessment on this situation.  ADA vs preservation has been a factor on numerous sites throughout the country.  I think there are some properties that cannot accommodate full accessibility due to the nature of the structure, size or configuration.  One project that is a good example our historic lighthouses.  We can accommodate accessibility to the ground floor of the lighthouse but no way can someone with physical challenges go up the narrow spiral stairs to the upper levels.  The intent is to make the experience of the space as equitable to everyone to the fullest extent that is reasonable.  Showing images of the upper levels for persons who cannot climb the stair atop the lighthouse is a way to meeting that intent.  One more example that was recently implemented in the newly renovated NPS St. Louis Arch.  The pods that take you to the top are not accessible so NPS installed a mock up exhibit of what it feels like at the observatory deck with images of the city and river views from that point.
    Good luck with your project and I hope you can find a compromise that is acceptable so you can move forward!
    Edward Torrez, Architect & NTHP Advisor

    Edward Torrez AIA
    Preservation Architect
    Bauer Latoza Studio
    Chicago IL
    [312-567-1000, X126]
    PrincipalPrincipalPrincipalPrincipalPrincipalPrincipalPrincipalPrincipal(312)567-1000 (26)

  • 5.  RE: ADA and remodeling of an historic house

    Posted 11-07-2019 17:59
    Chapter 12 of the International Existing Building code provides specific exceptions for historic buildings.

    Typically it is a matter of meeting with the code official to discuss your options under the code and what they will accept. You will also want to ask a state or local historical authority to write you a letter stating that certain changes would be detrimental to the historic structure and they support variances.

    The result is "program compliance" rather than strict compliance with the code, meaning that you are providing programmatic alternatives in areas where you can't strictly comply with accessibility standards. For example, if you can't put a ramp on the front, you can put one in the back. Section 1204.1.4 states that you are only required to provide a single unisex accessible restroom. Sometimes we are even allowed to put those and other public restrooms in a compatible out building. Section 1204.1.2 states that in a multilevel building "An accessible route from an accessible entrance to public spaces on the level of the accessible entrance shall be provided."

    The IEBC can also help you with egress and other safety provisions.

    Jay Firsching, Sr Associate
    Historic Preservation Specialist
    Dallas, TX

  • 6.  RE: ADA and remodeling of an historic house

    Posted 11-11-2019 15:44
    Hi Phillip. Museums operated by state or local governments are covered by ADA title II. If it receives federal funding, it may also be covered by Section 504 of the Rehabilitation Act. As as has been stated above, title II requires that state or local government programs be accessible, which does not mean that every building housing a state or local program must be completely accessible.

    As far as an existing structure that is being turned into a house museum without major renovation, title II would require require that architectural barriers be removed to the greatest extent possible. Meaning their complete removal unless it could be convincingly demonstrated that the cost would be unreasonable. Basically, title II would require:

    1. There must be an accessible entrance. This should be the main entrance. If the main entrance cannot be made accessible, it is permissible for another entrance to function as an accessible entrance if signage and other conditions are met. Many house museums will install a chair lift at a rear or side entrance in the belief that construction of a ramp will damage the historical integrity of the exterior.

    I disagree with this strategy primarily because chair lifts that are installed outdoors experience a lot of mechanical and electrical problems that result in them often being out of service for long periods.

    I object to people with disabilities being forced to use a side or rear entrance, instead of the main entrance.

    I disagree with the presumption that a ramp at the main entrance will diminish the historical value of the building. Ramps can be constructed so they are compatible with the building design. They will still be visible, but they will participate in the ongoing evolution of the building by making the statement that it can now accommodate people with disabilities in a way that it could not during its preceding history.

    Another, equally valid, design approach would be to make the ramp at the main entrance clearly visible as a new, separate add-on to the building. In this case, observers will clearly differentiate the new structure from the old, without any negative effect on their appreciation of the structure's historical style.

    2. There must be an accessible route from the accessible entrance through the entry level. Most historic homes have wide hallways and doorways on the main level, so this requirement usually means adjusting the position of movable items.

    3. For areas that are not accessible, and cannot be made accessible for reasons of unreasonable cost or damage to the building's historical or structural integrity, other means of experiencing the museum can be provided. This, however, should be more than just providing a brochure with pictures.  Thought must be given to providing for the needs of persons who are blind, or with reduced vision, or if recordings are provided, how to accommodate persons who are deaf or with reduced hearing.

    Even with these considerations, $200,000 seems high. For more information you could go where there is a wealth of information, including the ADA Standards for Accessible Design, and a section called Business Connection where you will find a PDF relating to museum accessibility.

    Jim Sparks
    Sparks Architecture
    Glasgow, KY

  • 7.  RE: ADA and remodeling of an historic house

    Posted 11-11-2019 13:08
    All of the previous respondents are correct in starting with a building official; it's the first step to getting an objective pair of eyes on the project. In San Francisco, the rules are "if it's new, it must be accessible", meaning new construction, renovation and spatial alterations within the historic building. Then one must provide an accessible path to the area and make sure that the new items are accessible.

    In this case, is the primary effort is for weatherization(?) or a secure climate controlled area/room (?) that visitors will NOT be accessing, then the question becomes one for employees access--then equivalent facilitation becomes the strategy. Usually weatherization, security upgrades and new building systems installation alone don't trigger improvements to accessible routes or facilities unless they are over a construction cost threshold limit.

    California has a stated construction cost threshold limit that then triggers an ordered list of improvments to remove barriers. The trigger is currently $166,157.00 in San Francisco. If you are at or below the threshold, you must spend up to 20% of the construction cost to upgrade the accessible path to the area of renovation. Above that limit, there is a list of other items that must be made compliant.

    After that, there are methods and calculations to prove hardship--to limit the work--these are letters written by an architect or engineer with the additional construction costs for review by a building official. 

    Keep in mind that ADA is civil rights legislation. While building officials are delegated to enforce accessibility measures as stated within the building code, this does not imply the building is "cleared". The ADA is enforced in the courts by individual citizens.

    Susan McComb
    San Francisco CA

  • 8.  RE: ADA and remodeling of an historic house

    Posted 11-15-2019 17:47
    As others have said, there is a component of proportionality. You absolutely should make an effort, but I think the 20% of project costs towards approving accessibility is a standard approach.

    My city uses this worksheet to address proportionality of the work. After an accessible entrance and an accessible bathroom, the goal is to cost out something that can be done with the funding limitations.

    Tim Askin
    City of Milwaukee Historic Preservation Commission
    Milwaukee WI

  • 9.  RE: ADA and remodeling of an historic house

    Posted 11-16-2019 11:00
    Edited by Carolynn Segers 11-16-2019 12:49

    This information is very helpful!