DSA IR 11B-10: SCOPING AND PATH OF TRAVEL UPGRADE REQUIREMENTS FOR FACILITY ALTERATION, ADDITION AND STRUCTURAL REPAIR PROJECTS (with revisions issued through April 2017)

6.3 Operational Considerations: In situations where a fully compliant path of travel cannot be required, from a civil rights perspective the public agency operating the facility still has an obligation to make its programs and services accessible. The fact that the building code did not require full compliance does not remove this program delivery obligation. However, this is an operational consideration outside of the building code and shall not be used as a condition of approval for projects under DSA’s jurisdiction.