An opinion piece by Howard Moutrie, Accessible Building Solutions
The Standard for accessible car parking, AS 2890.6 was updated in 2022. As yet, it hasn’t been referenced in the BCA so is not mandatory, but it can be used to provide information for performance solutions. Although, the revised Standard has improved in some areas, there are other areas which will create problems for us. Before I discuss the issues, I want to recall a previous article in which I described how I believe AS 2890.6 should be used, and that is in combination with Part 1. See below.
- Refer to table 1.1 of AS 2890.1 and determine class of parking. Accessible parking is Class 4. The table refers to AS 2890.6 for the size (My underlining for emphasis)
- Refer to Figure 2.2 of AS 2890.1 which provides the size for the various classifications and different angled parking configurations. For Class 4, Parking for people With A Disability, this again refers to AS 2890.6 for the size requirement and the requirement for the shared areas. Figure 2.2 also says in Note 5 that aisle width are the same as noted in the table for the other parking classes.
- If we then revert back to Part 1, the requirements for general parking areas, such as wheel stops, barriers etc are provided.
- Then, again within Part 1, there are requirements for ramps and aisles, line marking etc
- Finally, in Section 5 are the other considerations, which include how structural elements (including columns) relate to the parking space. This section applies to all carparks, so it can be assumed it applies to accessible parking particularly as it makes specific reference to Part 6 in relation to headroom.
To me, this is a logical approach to designing a carpark. By treating Part 6 for what it really is, an expanded description of a Class 4 parking space, the confusion regarding the location of columns is removed. Part 6 provides no greater scope than which was previously provided in the 1993 version of Part 1 regarding the actual parking space size and then the specific requirements such as gradient, clear headroom etc which were in Clause 2.4.5.
So, let’s get back to the new version and look at the good things. Firstly, the Standard now recognises that the increased headroom over the parking space and shared area is not required over the whole area, which allows some flexibility for the reticulation of services. Secondly, it has been recognised that columns can perform the same function as a bollard in the shared zone. So that’s the good news. Now I will look at the problematic issues that I have identified in the remainder of the Standard, some of which are a hangover from previous versions.
Standards Australia were approached to grant approval to copy figures from the Standard. The approval wasn’t given so I have provided my interpretation of the figures to help you understand the text.
Clause 2.3.2. Side Shared Area
It was always unclear in the 2009 version whether the shared area at the side could be in an aisle; the wording in the definition indicated it could. The draft of the 2022 version clarified that it could, but the final version now states that it cannot. I assume this is based on safety concerns, but why doesn’t the same concern apply to the rear shared area, which is located in an aisle? Based on information provided by the major vehicle modification companies in Australia, the 85% of vehicles are modified rear access, so safety for the rear shared area would seem to be more critical. I also note that the Standard AS 2890.5, for on road parking – where the speed of passing cars will be much greater – indicates that a 3.2m wide space is to be provided, with the vehicle parked against the kerb to provide space for a driver side exit adjacent to the passing traffic. Perhaps a compromise would be that accessible parking spaces 3.2m wide could be provided in lieu of a shared area in an aisle at the side. To ensure this doesn’t become the default situation, this could be limited to 20% of all accessible spaces – that is, you would need four other spaces before being able to do this once.
I do note that for Part 6, parallel parking spaces require a shared area, so this negates this argument to some extent. But read on, there is more on this later!
Clause 2.4 Bollard
For this commentary, I am using the term bollard, but it equally means column or post.
The Standard requires a 300mm retro reflective band that is a minimum of 900mm above the floor. I am not sure of the purpose of this band, but I would assume it is to assist in visibility for drivers who may attempt to park in the shared area, because retro reflective bands are design to reflect light straight back. However, the clause then says it is to have a 30% luminance contrast with pavement, measured in accordance with AS 1428.1. This would seem to indicate it is to assist people with vision impairment, but this poses a number of issues. Is the colour of the band, ignoring the reflectivity, to be tested, or is it to include the reflectivity? This is critical because the results from a spectrophotometer or a colorimeter are likely to give different results. A further complication is the pavement surface. This will likely be concrete or bitumen with yellow banding, in varying proportions depending on the direction you view it; so how do you determine the pavement reflectance?
Most commercially available bollards are 1000mm to 1200mm high. The requirements for the retro reflective band means that the bollard must have a minimum height of 1200mm, but the Standard requires the bollard to have a minimum height of 1300mm. While there are currently commercially available bollards of this height, and they do have a retro reflective band applied, the band is not 300mm wide.
The positioning of the bollard is curious; if the shared area is between two accessible parking spaces, then a 1m clear space is required on each side of the bollard. However, if the shared area serves a single accessible space, the 1m is only required on one side of the bollard. Why is this? I would have thought that a 1m clear space on one side would be sufficient in either situation. I can only assume that the clear space on each side of the bollard is to accommodate people exiting or accessing both vehicles at the same time. However, shouldn’t this be a minor issue with the congestion at that time? Perhaps it is just a typo?
The note to Fig 2.2 says “Minimum accessible path… on at least one side.” Whereas for Fig 2.3 to 2.6 it doesn’t say “on at least one side”.
This means that columns, in a shared zone serving two parking spaces, essentially have to be centrally located. Does this preclude having columns located in the shared zone, serving two accessible spaces, but adjacent to the parking space? A bollard would still be required, but unless the shared zone was wider, the 1m could not be achieved on both sides. I note that Part 1 clearly permits columns adjacent to a parking space, provided they are outside the door zone. I do not see how a correctly located column, next to the parking space, would negatively impact on the use of the shared area, if one centrally located does not.
Clause 2.5.2 Shared Area for Parallel Parking
This clause requires a shared area of 1600mm wide on the non-traffic side of the parallel parking space (in addition to the 3.2m wide parking space). The shared area can be at a different level i.e. higher on a footpath. This seems to be in conflict with the AS2890.5 (the on-road parking Standard), but as Part 6 is more recent, I accept that it reflects current thinking. However, if it is the driver side which requires the access, the shared area would be unusable. The vehicle would need to park on the non-trafficked side of the parking space, leaving only a nominal 800mm of space to the aisle. See my version of Fig 2.12 below. I note that alighting from the drivers side would not involve the use of a ramp, the person would be ambulant or use a roof mounted hoist or similar, so the 2400mm wide shared area on the drivers side would not be required.
So, I return to my earlier thought, that an accessible space 3.2m wide adjacent to an aisle may be a suitable solution.
Figs 2.8 and 2.9 Angle Parking
This figure provides an example of 45 degree angle parking. Interestingly, the shared area is significantly truncated at each end, and together with the indicated column, at least one space has had the manoeuvring space significantly reduced. If this is acceptable, then surely the wall end of a shared area with 90 deg parking could be used? For example, for a fire hose reel or a storage cupboard. Further evidence that the whole shared area is not required is in Clause 2.8, which says a kerb ramp may extend into the shared area by up to 1.2m. More on this later.
This is the available side shared area
Clause 2.7 Headroom
On the positive side, the Standard has limited the zone of the increased headroom it has removed the area of lower headroom over the bonnet. I suspect that this is due to the increased number of vans being used. These have a reduced bonnet area and may be impacted by the reduction of the headroom to 1800mm. However, this reduced headroom only extended 500mm into the parking space, and I doubt that anyone would park so close to the end of the space for this to be an issue. I am mainly referring to where this is against a wall. This space was particularly useful for the reticulation of ventilation ductwork which is required in enclosed carparks. The result of this may be that the accessible parking spaces are not located against a wall to avoid raising the building height, at a considerable cost. I am not sure that removing this concession has much benefit.
Clause 2.8 Kerb Ramp conflict with Fig 2.12
There are times when the parking area is at a different level to the access way of the building, and this is separated by a kerb. A kerb ramp is used to access the upper level and throughout the Standard, kerb ramps are shown to provide access from the shared area. But there is a conflict. Clause 2.8 says that the kerb ramp can extend into the shared area up to 1200mm, yet Fig 2.12 indicates the maximum encroachment is 760mm. See my interpretation of that Fig to the below.
Perhaps this is a difference for encroachment in a shared area for parallel parking as opposed to angle parking, but this is not explained. Further, unless a requirement in a Figure is described in the text, it is not a mandatory requirement, so the 1200mm would take precedence.
If we also go back to the Figures indicating 45 degree angle parking, they show a kerb ramp outside the shared area, but according to Clause 2.8, this could extend up to 1200mm into the shared area. This would further limit the already truncated available manoeuvring area. See below in red.
Clause 3.2 Space Delineation
AS 2890.1 requires that parking spaces be identified by a white or yellow line. Part 6 has always required the line to be yellow. Why? The only reason I can think of is to help identify an accessible space before you see the symbol, but this only works if the other spaces are marked with white. Perhaps it could be to provide luminance contrast for people with vision impairment, but why would this be necessary? Further, white would probably provide a better luminance contrast on most pavement surfaces. This is obviously a carry over from previous versions, but if it provides no benefit, it should not be in the Standard.
The requirement to identify and mark walkways within a shared area will provide a confusing array of lines which are unlikely to assist anyone.
Appendix A3.3 shared area in aisle
The appendix is informative, which means it does not provide mandatory requirements, but in this case it causes confusion as it conflicts with the body of the Standard. Clause A3.3 says, with respect to the shared area for a parallel parking space, that it “can be shared with the roadway…”. This is clearly in conflict with clauses 2.3.2 and 2.5.2. Obviously, the clauses take precedence, but these inconsistencies create confusion.
Summary
These examples show that the Standard has a number of issues which need to be resolved before it is adopted. Hopefully, these may be addressed and the Standard revised before it is referenced in the BCA.