IR-11B-10 SCOPING AND PATH OF TRAVEL IMPROVEMENT REQUIREMENTS FOR FACILITY ALTERATION, ADDITION AND STRUCTURAL REPAIR PROJECTS (Revised 10/14/25)

PURPOSE

This Interpretation of Regulations (IR) provides guidance for projects submitted to the DSA on the required improvements to path of travel elements when an alteration, addition or structural repair project is undertaken.

SCOPE

This IR is applicable to projects under DSA jurisdiction.

BACKGROUND

A project at an existing site is an alteration of that facility and subject to the requirements of California Building Code (CBC) Section 11B-202.4. A facility alteration includes a modernization, rehabilitation, reconstruction, change in use, addition, or structural repair of an existing building or element on an existing site. Construction of a new building or new elements on an existing site is also an alteration to an existing facility. Facility alterations require existing path of travel elements serving the area of alteration to be improved to the current edition of the CBC.

DEFINED TERMS

• ACCESSIBLE ROUTE
• ALTERATION
• ADDITION
• ADJUSTED CONSTRUCTION COST
• ENTRANCE
• FACILITY
• PATH OF TRAVEL
• TECHNICALLY INFEASIBLE
• UNREASONABLE HARDSHIP
• VALUATION THRESHOLD

1. SCOPING CONSIDERATIONS FOR ALTERATION PROJECTS

1.1 Compliance with Scoping Requirements

Facility alterations must comply with CBC Section 11B-201.1 Scope, 11B-202.2 Additions, and 11B-202.3 Alterations.

1.2 Path of Travel Improvements Required

Facility alteration and addition projects require compliance with CBC Section 11B-202.4.

1.3 Maintenance Projects

Projects limited to maintenance are not alterations and do not trigger additional accessibility requirements. Refer to IR A-22: Construction Projects and Items Exempt from DSA Review

2. ACCESSIBLE ROUTE REQUIREMENTS WITHIN A SITE

2.1 General

CBC Section 11B-206.2.2 requires at least one accessible route to connect accessible buildings, accessible facilities, accessible elements and accessible spaces that are on the same site.

2.2 Accessible Routes in Campus Settings

For campus school facilities with multiple buildings and functional areas, the following factors may assist in determining the accessible route requirement:

• New construction on an existing site must include, as part of the basic project scope, an accessible route connecting to an existing on-site accessible route.
• When multiple accessible routes to a specific area of alteration or addition are present but not code compliant, CBC Section 11B-202.4 requires improvements to only a single primary accessible route to the project area. Improvements to secondary routes serving the same area shall not be required. Signs indicating the direction of the accessible route to a facility entrance may be required, per CBC Section 11B-216.6.
• If an accessible route which connects the addition to other elements of the facility is newly constructed, it shall be part of the project scope included in the adjusted construction cost for the project. If the accessible route is existing and not compliant, it must be brought into compliance as part of path of travel improvements.

3. PATH OF TRAVEL IMPROVEMENTS REQUIRED BY CBC SECTION 11B-202.4

3.1 Path of Travel Elements

Facility alteration projects trigger requirements for accessibility improvements to elements outside the project area of work. per the requirements of CBC Section 11B-202.4.

3.2 Path of Travel Exterior Elements

The CBC definition of PATH OF TRAVEL in Chapter 2 lists existing components required to be improved for a facility to be accessible and maintained as accessible, which are site-specific and must be evaluated for each project. Path of travel elements include an accessible route within the site by which the altered area or addition may be approached, entered and exited, and which connects the altered area to the facility entrance; toilet facilities, drinking fountains and signs serving the area of work; and other parts of the facility including site arrival points such as the public sidewalk and accessible parking.

4. ADJUSTED CONSTRUCTION COST AND VALUATION THRESHOLD

4.1 Valuation Threshold

The extent of path of travel improvements is based on the adjusted construction cost and the valuation threshold. The CBC definition of VALUATION THRESHOLD in Chapter 2 is a dollar-amount figure used to determine the extent of the required path of travel improvements. The valuation threshold is published on the DSA website and updated annually.

4.2 Included in Adjusted Construction Cost

The CBC definition of ADJUSTED CONSTRUCTION COST in Chapter 2 shall include all costs directly related to the construction of a project, including labor, material, equipment, services, utilities, contractor financing, contractor overhead and profit, and construction management cost. The costs shall not be reduced by the value of components not directly associated with accessibility or usability.

4.3 Not Included in Adjusted Construction Cost

The adjusted construction cost shall not include project management fees and expenses, architectural and engineering fees, testing and inspection fees, and utility connection or service district fees.

5. LIMITATIONS ON APPLICATION OF CBC SECTION 202.4, EXCEPTION 8

5.1 Projects with Adjusted Construction Cost at or Below the Valuation Threshold

CBC Section 11B-202.4, Exception 8, limits the cost of path of travel improvements to 20 percent of the adjusted construction cost for projects less than or equal to the valuation threshold. A project with an adjusted construction cost below the valuation threshold and which cannot achieve full compliance of the path of travel elements without exceeding 20 percent shall provide compliance to the greatest extent possible utilizing the priority list in Exception 8.

5.2 Projects with Adjusted Construction Cost Above the Valuation Threshold

Projects with an adjusted construction cost above the valuation threshold must provide full compliance of the path of travel elements with current accessibility requirements. CBC Section 11B-202.4, Exception 8 addresses projects where the cost of full compliance of path of travel improvements is disproportionate to the adjusted construction cost and may be an unreasonable hardship. See DSA PR 24-04 for additional information.

5.3 When Full Compliance Cannot Be Achieved

To request an unreasonable hardship under CBC 11B-202.4, Exception 8, see PR 24-04 Request for Finding of Unreasonable Hardship per CBC 11B-202.4, Exception 8 and Form DSA 1-RUH.

If compliance with the applicable requirements are determined by DSA, as the enforcing authority, to be TECHNICALLY INFEASIBLE as defined in Chapter 2, submit the Form DSA 1- RTI. When an improvement to a path of travel element is technically infeasible, CBC Section 11B-202.3, Exception 2 requires equivalent facilitation or compliance to the maximum extent feasible.

6. COMPLIANCE WITH IMMEDIATELY PRECEDING EDITION OF THE CBC

6.1 Compliant Facilities

Where all the path of travel elements serving the area of alteration are in compliance with the current or immediately preceding edition of the CBC, such path of travel elements shall not be required to be retrofit per CBC Section 11B-202.4, Exception 2.

6.2 Immediately Preceding Edition

The preceding edition of the code includes the following published documents related to the applicable triennial edition:

• Initially adopted and published triennial edition of the California Building Code.
• Intervening code cycle amendments adopted and issued as supplements.
• Emergency amendments, if any, adopted and issued as supplements.
• Errata

REFERENCES

California Code of Regulations (CCR) Title 24

               Part 2: California Building Code (CBC), Chapter 2, Section 202

               Part 2: California Building Code (CBC), Chapter 11B, Section 11B-202.4

This IR is intended for use by DSA staff and by design professionals to promote statewide consistency for review and approval of plans and specifications as well as construction oversight of projects within the jurisdiction of DSA, which includes State of California public schools (K-12), community colleges and state-owned or state-leased essential services buildings. This IR indicates an acceptable method for achieving compliance with applicable codes and regulations, although other methods proposed by design professionals may be considered by DSA.

This IR is subject to revision at any time. Please check DSA’s website for currently effective IRs. Only IRs listed on the webpage at www.dgs.ca.gov/dsa/publications at the time of the project application submittal to DSA are considered applicable.