Building Alterations in California: Don't Forget the Path of Travel

When designing alterations or additions to an existing building, many teams focus solely on the area being modified. But ADA compliance extends well beyond the project footprint.

Under both the ADA Standards and CBC Chapter 11B, any time a primary function area is altered, an accessible path of travel must be provided to and through that area. This includes:

- An accessible route from the site arrival point and parking

- Restrooms, drinking fountains, and telephones serving the area

- Any other elements required to make the altered area usable by persons with disabilities

This is not limited to major renovations. A modest tenant improvement that crosses a valuation threshold triggers the same obligation.

What Is Often Overlooked

Owners and contractors frequently assume accessibility upgrades are limited to the new work. They are not.

If you are not assessing the path of travel as part of every alteration project, you could be exposing yourself to non-compliance at plan check — and civil liability after occupancy. A plaintiff's attorney does not care that the work was limited to one suite. They care whether the path from the parking lot to that suite is accessible.

The Disproportionality Cap and What It Means

CBC 11B-202.4 sets specific obligations for path of travel upgrades, and while there is a 20% disproportionality cap — meaning you are not required to spend more than 20% of the primary work cost on path-of-travel upgrades — the responsibility to improve still applies, even for small projects.

When path-of-travel costs would exceed 20%, the requirement does not disappear. It means you must prioritize improvements by impact, document the disproportionality finding with a qualified professional, and address the remaining items in a phased plan.

How to Approach It

As a CASp and licensed architect, I advise clients on every alteration project to:

- Budget for accessibility upgrades early — before the scope is set and the contractor is priced

- Evaluate existing conditions holistically — not just the area being remodeled

- Document any technical infeasibility with a qualified professional so the record is clear

Accessibility is not an afterthought. It is integral to equity in the built environment — and in California, it is a legal obligation on every permitted alteration project.

Have a question about path of travel on your next project? Let's connect before the drawings are finished.

‍