Understanding ADA 206.2.1: Site Arrival Points and When Accessible Routes Are Required

What is ADA 206.2.1?

ADA 206.2.1 Site Arrival Points requires at least one accessible route within a site from site arrival points to accessible building entrances.

Site arrival points include:

• Accessible parking spaces and passenger loading zones

• Public streets and sidewalks

• Public transportation stops

Think of it as creating a continuous, accessible path that people with disabilities can use to get from where they arrive at your property to your building entrance.

The Two Exceptions Explained

Exception 1: Historic Buildings

This exception applies only to alterations of qualified historic buildings and limits the requirement to just one accessible route instead of multiple routes.

Exception 2: Vehicular Way Without Pedestrian Access

This is the exception that causes the most confusion.

It states: "An accessible route shall not be required between site arrival points and the building or facility entrance if the only means of access between them is a vehicular way not providing pedestrian access".

When Exception 2 Actually Applies (It's Rare!)

The official guidance makes clear this exception applies only in "relatively rare situations".

✅ EXEMPT Examples:

• Office complex on isolated site with private access road - Where pedestrians are never expected and the road is purely for vehicles

• Self-storage facility where all users drive to storage units - No pedestrian access is designed or anticipated

• Industrial facilities with vehicle-only access roads - Where the route genuinely dictates vehicular access only

❌ NOT EXEMPT Examples:

• Shopping center or mall parking lots - Even though it's a "vehicular way," pedestrians use it

• Any driveway where pedestrians might walk - If pedestrian use can be "reasonably anticipated," the exception doesn't apply

• Gas station drive aisles with pedestrian access to convenience stores

• Any site where people park and walk to buildings

The Key Test: Can Pedestrian Use Be "Reasonably Anticipated"?

The critical question is: Will the route between the site arrival point and building be used by pedestrians, regardless of whether a pedestrian route is currently provided?

If the answer is YES, Exception 2 does not apply, and you must provide an accessible route.

Common Misconceptions

❌ Wrong: "We have asphalt drive aisles with no sidewalks, so we're exempt"

✅Correct: If pedestrians will use those drive aisles to reach the building, an accessible route is required

❌ Wrong: "The property was originally built without pedestrian connections, so we're exempt"

✅ Correct: Original design doesn't matter - if pedestrian use is anticipated, accessible routes are required

The Official Guidance Language: California Building Code and 2010 ADAS

From the 2019 California Building Code Advisory (and the federal guidance it quotes):

"Advisory 11B-206.2.1 Site arrival points. Exception 2. If it can be reasonably anticipated that the route between the site arrival point and the accessible facilities will be used by pedestrians, regardless of whether a pedestrian route is provided, then this exception will not apply. It will apply only in the relatively rare situations where the route between the site arrival point and the accessible facility dictates vehicular access – for example, an office complex on an isolated site that has a private access road, or a self-services storage facility where all users are expected to drive to their storage units. (Excerpt from the Guidance on the 2010 Standards: Titles II and III.)"

From the DOJ Commentary on the 2010 ADA Standards:

"If it can be reasonably anticipated that the route between the site arrival point and the accessible facilities will be used by pedestrians, regardless of whether a pedestrian route is provided, then this exception will not apply."

Key Points from the Official Guidance:

1. "Reasonably anticipated" is the test - not whether pedestrian access is currently provided, but whether it can be anticipated

2. "Regardless of whether a pedestrian route is provided" - meaning even if you don't build sidewalks, if people will walk there, the exception doesn't apply

3. The exception applies only in "relatively rare situations"

4. It requires that the route "dictates vehicular access" - meaning vehicle use is truly the only logical way to travel between points

From the Access Board's Technical Guide:

"Where a vehicular way does provide pedestrian access, such as a shopping center parking lot, an accessible route is required."

Bottom Line on Site Arrival Points

Exception 2 is extremely narrow and applies only when a site is genuinely designed for vehicle-only access with no pedestrian use anticipated. In almost all commercial situations - especially restaurants with outdoor seating - accessible routes are required from site arrival points to all accessible areas, including outdoor service counters.

DISCLAIMER: The information provided in this post is for informational purposes only and does not constitute legal advice. Please consult a qualified attorney or consultant for advice tailored to your situation.