The route
A plan tracing the route from parking and the public sidewalk to the altered area, through the entrance.
Plan check correction · Accessibility
Plan check correction: accessible path of travel in alterations
Tenant improvements often get this comment even when the work never touches the entrance. Accessibility rules reach beyond the altered space to the route that serves it.
The comment asks you to show the accessible route from the site arrival points to the altered area, including the entrance and the restrooms, drinking fountains, and public phones that serve it, and to say which elements are being upgraded. Clear it with a path-of-travel plan, a survey of existing conditions, and, where improvements are limited by cost, the valuation and the upgrades chosen.
Read the comment
What the plans examiner is asking for
Elements serving the area
Restrooms, drinking fountains, and public phones serving the altered area, identified and evaluated.
Existing conditions
Which route elements already comply and which do not, with dimensions or notes.
Cost limit and priorities
Where the jurisdiction’s rule caps spending, commonly at 20 percent of the cost of the alteration to the primary function area under the federal rule in 28 CFR 36.403, the valuation and the priority order of upgrades.
Published correction lists
How city lists word this correction
Published lists ask for a path-of-travel plan, existing-condition surveys, or the construction valuation behind any cost limit. Paraphrased from each department’s own published list; the lists do not rank items by how often they are issued.
| City | What the published list asks for | Code cited | Where it appears |
|---|---|---|---|
| Los Angeles | Altered elements must fully comply, and alterations or additions need an accessible path of travel to the work area, covering the primary entrance, restrooms, drinking fountains, phones and signs. | 11B-202.3; 11B-202.4 | Counter Plan Check Correction Sheet (2026 Code Ref.), Part III, H. Accessibility, items 1-2 |
| Los Angeles | When adjusted construction cost is at or below the valuation threshold, path-of-travel cost may be limited to 20 percent, with an unreasonable hardship request. The sheet lists $203,611; the state updates the threshold each January. | 11B-202.4, Exception | Counter Plan Check Correction Sheet (2026 Code Ref.), Part III, H. Accessibility, items 3-4 |
| San Francisco | Commercial tenant improvements must reproduce the signed D.A. checklist on plans; above the valuation threshold provide a fully accessible path of travel, otherwise apply the 20% rule. | CBC 11B-202.4, Exception 8 | Information Sheet DA-02 package - D.A. Checklist p.1 and Form C |
| San Diego | Inside the building, floor plans must trace the accessible route to all rooms and to path-of-travel elements such as toilet rooms, drinking fountains and public telephones. | CBC Chapter 11A and/or 11B | Project Submittal Manual Section 2, checklist Accessibility Plans, Path of Travel item (numbered 4.2.5 in the source) |
| San Jose | For work in existing buildings, include the City's Accessibility Compliance Form, plus an Unreasonable Hardship request where one applies. | — | BDN 01 Information Required on the Drawings, Required Information list |
| San Jose | Commercial remodels must provide accessible parking near accessible entrances, directional signs at inaccessible entrances, a path of travel to the remodeled area, and accessible toilets, phones and drinking fountains. | — | Bulletin #226 Disability Access Requirements (03/26/2023), p. 2, General Accessibility Requirements chart – Commercial Remodels |
| San Jose | For tenant improvements, a key plan should locate the work within the building and show the path of travel to exits and the accessible main entrance. | — | Tenant Improvements – Plan Checklist (Handout No. 2-10), Sec. II, A-3 Key Plan |
| Seattle | SDCI reviews against SBC Chapter 11 and ICC A117.1, and the Seattle Existing Building Code covers accessibility in alterations. ADA and Fair Housing compliance stay with the applicant. | SBC Chapter 11; ICC A117.1; Seattle Existing Building Code | Tip 119, Accessibility Laws We Enforce |
| Portland | A commercial permit application should include a barrier-removal summary -- an itemized list of accessible improvements and their cost as a ratio of the overall project cost -- along with an analysis of which existing-building alteration compliance method was used (Prescriptive, or Alteration Level 1/2/3), with the prescriptive path assumed if none is stated. | — | Commercial Permit Application Requirements page, Accessibility section |
| Phoenix | For existing buildings, plan review checks a change of occupancy, alterations generally, and the path of travel required when an alteration affects an area of primary function (following the federal order-of-priority rule), plus toilet-room and historic-building provisions. | IEBC 306.5, 306.7, 306.7.1, 306.7.12, 306.7.18; 28 CFR Part 36 Subpart D 36.403(g)(2) | Accessibility Plan Review Checklist – Guideline, item 9 Existing Buildings |
| Boston | Where full compliance with the state's accessibility regulations is impracticable, an applicant may seek a variance from the Architectural Access Board, processed through the City's Disabilities Commission rather than through ISD plan review itself. | 521 CMR 4.1 | Disabilities Commission - Submitting an Architectural Access Board Variance page |
| Austin | In an existing building undergoing alterations, IBC-required Type B accessible dwelling units are not required when the altered work area is 50 percent or less of the building's aggregate area. | IEBC 306.7.4 | Residential Technical Review Checklist, Accessibility and Visitability section, Type B Unit Requirement Exceptions |
| Chicago | Alterations affecting an area with a primary function trigger a path-of-travel obligation capped at 20% of the cost of alterations to that area; the MOPD form has the architect calculate that 20% figure and certify compliance directly on the form. | Chapter 14B-11; Section 14R-3-305 | MOPD Project Data Form, Schedule (B), Total Cost of Alterations Affecting an Area Containing a Primary Function calculation |
Sources reviewed September 12, 2026. Code sections are as cited on each list and follow that city’s adopted code. Confirm the current list and edition with the department.
Revise the set
What changes on the drawings, and what else to re-check
Path of travel adds sheets that reach outside the tenant space.
| Change | Sheets to revise | Also re-check |
|---|---|---|
| Path-of-travel plan added | Site plan; path-of-travel plan | Parking layout, curb ramps, entrance door hardware |
| Restroom upgrades added | Enlarged restroom plans; interior elevations | Plumbing plans, shared building restrooms outside the lease line |
| Entrance upgraded | Entrance plan and details | Door threshold, landing slope, exterior lighting and signage |
| Valuation documented | Cover sheet notes; cost statement | Scope of work description, permit application valuation |
Close the comment
A response the reviewer can verify
An illustrative example written for this guide, not a real project or a city’s wording. Name the sheet, the detail, and the change, so the recheck does not start with a search.
Comment
Show the accessible path of travel to the area of alteration, including parking, entrance, and restrooms serving the area. Provide a disproportionality statement if applicable.
Response
Revised as requested. Path-of-travel plan A1.02 traces the route from accessible parking to Suite 210, with existing conditions noted at each element. The primary entrance hardware and restroom grab bars are upgraded; details on A7.03. The construction valuation and the upgrades selected, in the order the code requires, are listed on G0.02.
Before you submit
Catch it before the plans examiner does
Walk the route
Survey the route from parking and the sidewalk to the space before design starts, and photograph it.
List the elements
Identify the entrance, restrooms, fountains, and phones that serve the altered area.
State the scope
Put the path-of-travel scope and any cost-limit basis on the cover sheet so the reviewer does not have to ask.
Groundbook compares the drawings, schedules, and specifications with the adopted code and local amendments, and links each potential issue to the sheets and sections behind it. We read the amendments governments publish online and use licensed model codes only where a license allows it. Your team verifies each finding; the jurisdiction makes every approval decision. See the pre-permit review and drawing-to-code review.
Questions, answered
Path of travel in alterations: questions
What is the 20 percent rule?
Under the federal ADA rule in 28 CFR 36.403, when an alteration affects a primary function area, the path of travel must be made accessible unless the cost exceeds 20 percent of the cost of the alteration to the primary function area. Upgrades up to that amount are still required, in priority order.
Does California use the same rule?
California’s CBC Section 11B-202.4 has its own path-of-travel requirements, including a valuation threshold that is adjusted over time and a 20 percent provision. Check the current threshold with the department.
Is the path of travel required for every alteration?
Not always. Some work, such as certain repairs and alterations that do not affect a primary function area, is excluded. The plans should state why the rule applies or does not.
Keep going
Related corrections and city guides
Accessible toilet rooms
Enlarged toilet room plans and elevations dimensioning turning space, fixture clearances, grab bars, and mounting heights.
Read this correctionCode analysis
Occupancy, construction type, allowable area, occupant load, and sprinkler basis stated on the cover sheet and consistent with the plans.
Read this correctionSheet coordination
Detail references that resolve, and plans, sections, schedules, and consultant sheets that describe the same condition the same way.
Read this correctionLos Angeles plan check
How LADBS reviews a permit set and what its published lists ask for.
Open the city guideSan Francisco plan check
How DBI reviews a permit set and what its published lists ask for.
Open the city guideSan Diego plan check
How DSD reviews a permit set and what its published lists ask for.
Open the city guideRespond to plan check comments
Response letter format, six response types, and a free response log.
Read the guideFind the corrections before the plans examiner does
Upload the drawing set. We read the local amendments that governments publish online, and link each potential issue to its sources for your team to verify.