City of Lebanon, PA
Lebanon County
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Table of Contents
Table of Contents
[Ord. No. 1-2020, 21, passed 6-22-2020]
(a) 
Overall requirements and applicability.
(1) 
Number of spaces. In the CBD Zoning District, off-street parking is not required to be provided, except: a) if three or more new dwelling units are being developed in a new building, or b) a hotel or rooming house is being developed. In all other districts, each use that is newly developed, enlarged, significantly changed in type of use, or increased in number of establishments shall provide and maintain off-street parking spaces in accordance with the table below and the regulations of this Article 1311.
(2) 
Uses not listed. Uses that are not specifically listed in the table below shall comply with the requirements for the most similar use listed in the table below, unless the applicant provides suitable evidence acceptable to the Zoning Officer, based upon actual counts of peak demand at similar facilities, that an alternative standard should be used for that use.
(3) 
Multiple uses. Where a proposed lot contains or includes more than one type of use, the number of parking spaces required shall be the sum of the parking requirements for each separate use, except as provided in § 1311.03(f).
Table 1311.01, Off-Street Parking Requirements
Use
Number of Off-Street Parking Spaces Required
Plus 1 Off-Street Parking Space for Each of the Following
A. RESIDENTIAL USES:
1.
Dwelling unit, other than types listed separately in this table
2 per dwelling unit, except: 1.5 for a 2-bedroom multifamily dwelling unit and 1 per dwelling unit for a 1-bedroom or efficiency multifamily dwelling unit
As part of a new subdivision, if a vehicle must be moved from 1 space in order to access the second space, then an additional parking space shall be available for each dwelling unit, such as on-street parking spaces on the same side of the street adjacent to the homes or an overflow parking lot
2.
Home occupation
See § 1306.03
3.
Housing permanently restricted to persons 55 years and older and/or the physically handicapped
1 per dwelling/rental unit, except 0.5 per dwelling/rental unit if the age limit is 62 and older
1.2 nonresident employee
4.
Boardinghouse or fraternity or sorority house
1 per 2 adult residents
1.2 nonresident employee
5.
Group home
1 per 2 adult residents, unless the applicant proves the home will be limited to persons who will not be allowed to drive a vehicle from the property
Employee
B. INSTITUTIONAL USES:
1.
Assisted living facility, personal care home, hospice, or similar retirement community
1 per 6 beds that are not within dwelling units, plus 0.5 for each dwelling unit
1.2 employees
2.
College or university
1 per 1.5 students not living on campus who attend class at peak times, plus 1 space for every 3 persons living in on-campus housing (other than students forbidden from having a car in the City)
1.2 employees
3.
Day-care center
1 per 12 children, with spaces designed for safe and convenient dropoff and pickup; the City may, at its discretion, approve one or more short-term on-street parking spaces to meet this requirement
1.2 employees
4.
Hospital
1 per 4 in-patient or out-patient beds
1.2 employees
5.
Library, community center or cultural center or museum
1 per 5 seats (or 1 per 300 square feet of floor area accessible to patrons and/or users if seats are not typically provided)
1.2 employees
6.
Nursing home
1 per 6 beds
1.2 employees
7.
Place of worship (includes church)
1 per 5 seats in room of largest capacity; for pews that are not individual seats, each 50 inches shall count as one seat; an accessory day-care center is not required to provide additional parking
1.2 employees
8.
School, primary or secondary
1 per 4 students aged 16 or older
1.2 employees
9.
Swimming pool, nonhousehold
1 per 50 square feet of water surface, other than wading pools
1.2 employees
10.
Temporary shelter
1 per 10 adult residents
1.2 employees
11.
Treatment center
1 per 3 residents aged 16 years or older plus 1 per 2 nonresidents intended to be treated on-site at peak times
Nonresident employee
12.
Utility facility
1 per vehicle routinely needed to service facility
C. COMMERCIAL USES:
All commercial uses, as applicable, shall provide additional parking or storage needed for maximum number of vehicles stored, displayed or based at the lot at any point in time. These additional spaces are not required to meet the stall size and parking aisle width requirements of this title.
1.
Adult use
1 per 50 square feet of building floor area
1.2 employees
2.
Auto service/gas station or repair garage
5 per repair/service bay and 1/4 per fuel nozzle with such spaces separated from accessways to pumps
Employee; plus any parking needed for retail sales
3.
Auto, boat, recreational vehicle or manufactured home sales
1 per 30 vehicles, boats, RVs or homes displayed
1.2 employees
4.
Bed-and-breakfast use
1 per rental unit plus 2 for the operator's dwelling unit
1.2 nonresident employee
5.
Bowling alley or pool hall
2 per lane plus 2 per pool table
1.2 employees
6.
Car wash
1 space per lane for drying and/or vacuuming areas.
1.2 employees
7.
Exercise club
1 per 300 square feet of floor area accessible to customers
8.
Financial institution (includes bank)
1 per 300 square feet of floor area accessible to customers, plus office parking for any administrative offices
9.
Funeral home
1 per 5 seats in rooms intended to be in use at 1 time for visitors, counting both permanent and temporary seating
1.2 employees
10.
Gaming establishment
1 per 200 square feet of floor area accessible to customers
1.2 employees
11.
Golf, miniature
1/2 per hole
1.2 employees
12.
Haircutting/hairstyling
1 per customer seat used for haircutting, hair styling, hair washing, manicuring or similar work
1.2 employees
13.
Hotel or motel
1 per rental unit plus 1 per 5 seats in largest meeting room (plus as required for any restaurant)
1.2 employees
14.
Laundromat
1 per 4 washing machines
On-site employee
15.
Nightclub or after-hours club
1 per 4 persons of allowed building capacity under the fire code
1.2 employees
16.
Offices, primarily medical or dental
1 per 300 square feet of total floor area, other than shared lobby, elevator and stairway space
17.
Offices, other than above
1 per 400 square feet of total floor area, other than shared lobby, elevator and stairway space
18.
Personal service use, other than haircutting/hairstyling (minimum of 2 per establishment) or business service use
1 per 400 square feet of floor area accessible to customers
1.2 employees
19.
Indoor recreation (other than bowling alley), membership club or exercise club
1 per 5 persons of maximum capacity of all facilities
1.2 employees
20.
Outdoor recreation (other than uses specifically listed in this table)
1 per 5 persons of capacity (50% may be on grass overflow areas with major driveways in gravel)
1.2 employees
21.
Restaurant or tavern
1 per 5 seats, or 1 space per 50 square feet of floor area accessible for customers for a use without customer seats
1.2 employees
22.
Retail sales (other than types separately listed and other than a shopping center)
1 per 300 square feet of floor area of rooms accessible to customers
23.
Retail sales of only furniture, lumber carpeting, bedding, floor coverings or similar home improvements
1 per 1,000 square feet of floor area of rooms accessible to customers
24.
Shopping center which includes multiple retail establishments on a lot, and which may also include restaurants
1 per 300 square feet of total floor area, other than nonleasable space such as shared lobbies
25.
Stadium, arena or commercial auditorium
1 per 5 seats, provided that spaces shared with other business uses that are not typically used on weekends or after 5:00 p.m. on weekdays may also be counted for these uses
1.2 employees
26.
Theater
1 per 5 seats, provided that spaces shared with other business uses that are not typically used on weekends or after 5:00 p.m. on weekdays may be also counted for these uses
1.2 employees
27.
Trade/hobby school
1 per 2 students on-site during peak use
1.2 employees
28.
Veterinarian office
4 per veterinarian
1.2 employees
E. INDUSTRIAL USES:
In addition to parking or storage needed for maximum number of vehicles stored, displayed or based at the lot at any point in time, which spaces are not required to meet the stall size and aisle width requirements of this title
All industrial uses (including warehousing, distribution and manufacturing)
1 per 1.2 employee, based upon the maximum number of employees on-site at peak period of times
Self-storage development
2, plus room in aisles for temporary parking that allows a second vehicle to pass a parked vehicle
1.2 employee
(b) 
Reduced-need populations.
(1) 
The above table includes reductions in parking for housing limited to persons over certain ages.
(2) 
In addition, as a special exception use, the Zoning Hearing Board may approve a reduction of up to 50% in the required number of off-street parking spaces for an institutional or residential use based upon written evidence that is provided that the typical residents or clients will not be physically able or allowed to operate a vehicle from the site because of their disabilities or similar conditions.
[Ord. No. 1-2020, 21, passed 6-22-2020]
(a) 
General. Parking spaces and accessways shall be laid out to result in safe and orderly use, and to fully take into account all of the following: vehicular access onto and off the site, vehicular movement within the site, loading areas, pedestrian patterns and any drive-through facilities. No parking area shall cause a safety hazard, or an impediment to traffic off the lot.
(b) 
Existing parking.
(1) 
Any parking spaces serving such preexisting structures or uses at the time of adoption of this title shall not in the future be reduced in number below the number required by this title.
(2) 
If a new principal nonresidential building is constructed on a lot, then any existing parking on such lot that serves such building shall be reconfigured to comply with this title, including but not limited to, requirements for channelization of traffic from adjacent streets, channelization of traffic within the lot, minimum aisle widths, paving and landscaping.
(c) 
Change in use or expansion. A structure or use in existence at the effective date of this title that expands or changes in use of an existing principal building shall be required to provide all of the required parking for the entire size and type of the resulting use, except as follows:
(1) 
If a nonresidential use expands by an aggregate total maximum of 5% in the applicable measurement (such as building floor area) beyond what existed at the time of adoption of this title, then no additional parking is required. For example, if an existing building included 3,000 square feet, and a single minor addition of 150 square feet was proposed, then additional parking would not be required. This addition without providing new parking shall only be allowed one time per lot.
(2) 
An existing nonconforming deficit in the numbers of parking spaces can be grandfathered. For example, if an existing business would be required to provide six spaces and only three spaces are provided, and the use changes to needing eight total spaces, then only five total spaces need to be provided (three existing spaces plus two spaces for the change in use).
(d) 
Continuing obligation of parking and loading spaces. All required numbers of parking spaces and off-street loading spaces shall be available as long as the use or building which the spaces serve still exist, and such spaces shall not be reduced in number below the minimum required by this title. No required parking area or off-street loading spaces shall be used for any other use (such as storage or display of materials) that interferes with the area's availability for parking.
(e) 
Location of parking.
(1) 
Required off-street parking spaces shall be on the same lot or abutting lot with the principal use served, unless the applicant proves to the satisfaction of the Zoning Officer that a method of providing the spaces is guaranteed to be available during all of the years the use is in operation within 300 feet walking distance from the entrance of the principal use being served. The 300-foot distance may be increased to 600 feet for parking serving employees or company vehicles. A longer distance may be approved for employee parking if there is a commitment by the employer to provide a regular shuttle service. A written and signed lease shall be provided, if applicable. A sign shall direct persons to the parking spaces.
A. 
The Zoning Officer may require evidence at any time that shows that the parking continues to be available for the use. If such parking is not available in the future, the zoning permit shall be considered to have been revoked, unless the applicant proves that other parking is provided that meets the requirement.
B. 
This requirement may be met by a legally binding commitment by the applicant to lease a specific number of parking spaces in an accessible public parking lot or deck. The City may require a deed restriction for off-site parking that is intended to be available over the long-term.
[Ord. No. 1-2020, 21, passed 6-22-2020]
(a) 
General requirements.
(1) 
Backing onto a street. No parking area of four or more parking spaces shall be designed to require or encourage parked vehicles to back into a public street in order to leave a parking space, except for a driveway that enters onto a local street or a parking court. Parking spaces may back onto an alley.
(2) 
Except for spaces serving one household, every required parking space shall be designed so that each motor vehicle may proceed to and from the parking space provided for it without requiring the moving of any other vehicle.
(3) 
Parking areas shall not extend into a required buffer yard. New parking spaces shall only be allowed within a street right-of-way where they are specifically approved by the City.
(4) 
Separation from street. Except for parking spaces immediately in front of individual dwellings, all areas for off-street parking, off-street loading and unloading and the storage or movement of motor vehicles shall be physically separated from the street by a continuous grass or landscaped planting strip, except for necessary and approved vehicle entrances and exits to the lot. See landscaping provisions in § 1313.04.
(5) 
Stacking and obstructions. Each lot shall provide adequate area upon the lot to prevent back-up of vehicles on a public street while awaiting entry to the lot, or while waiting for service at a drive-through facility.
(6) 
Provisions allowing flexibility or reduction of parking requirements.
A. 
Purposes. To minimize impervious surfaces, while ensuring adequate parking, and to recognize unique circumstances that may justify a reduction in required parking.
B. 
Reduction. The Zoning Hearing Board may permit a reduction, through the special exception process, of the number of parking spaces that would otherwise be required if the applicant proves to the satisfaction of the Board that less parking spaces are needed.
1. 
Proof. To prove that fewer parking spaces are needed, in the written application, the applicant shall provide existing and projected employment, customer, resident or other relevant data. Such data may include a study of parking at similar developments during peak periods of use.
2. 
Shared parking. Under this section, an applicant may seek to prove that parking permanently shared with another use or another lot with shared internal access or another lot within 500 feet will reduce the total amount of parking needed because the uses have different peak times of parking need or overlapping customers.
(A) 
For example, an applicant may prove that a use with peak parking needs during late evenings or weekends (such as a theater, bowling alley or place of worship) can reasonably share parking with a use with peak parking needs during daytime weekdays (such as a bank or office).
(B) 
Reduced parking requirements for joint parking shall only continue in effect as long as such uses or their closely similar successor uses remain in operation, and shall be guaranteed by a legally binding agreement. If such agreement becomes legally ineffective, then all parking shall be provided as would otherwise be required by this article.
3. 
Reservation of future parking areas. If a reduction is permitted under this section, the Board may require as a condition of the special exception that the lot include the reservation, permanently or for a specified number of years, of areas sufficient to otherwise meet the required number of spaces, if needed in the future.
(A) 
Such reservation shall be provided in a legal form acceptable to the Zoning Hearing Board such as a legally binding deed restriction and be officially filed with the Zoning Officer.
(B) 
In such case, the applicant shall be required to submit site plans to the Zoning Officer showing where and how the additional parking could be accomplished. Such future parking areas shall not be covered by buildings and shall be attractively landscaped unless needed for parking.
(C) 
Such additional parking shall be required to be provided within one year after the Zoning Officer may determine it to be necessary to meet actual demand. Such determination may be made based upon field analysis by the Zoning Officer.
4. 
As a special exception, the Zoning Hearing Board shall have the authority to modify off-street parking requirements, considering the total impact of the new uses of the lot versus the previous uses, and considering whether a percentage of customers are likely to arrive by public transit and/or walking. The Board may also approve a reduction in the required parking if the applicant proves that there is an excess of on-street parking spaces during hours when the business will have its peak demand.
(b) 
Size and marking of parking spaces.
(1) 
Each parking space shall be a rectangle with a minimum width of nine feet and a minimum length of 18 feet, except the minimum sized rectangle shall be eight feet by 22 feet for parallel parking, except as provided for parking for persons with disabilities in Subsection (g) below. Larger parking spaces are required for persons with disabilities, as provided below. A maximum of 10% of required parking spaces may be nine feet by 16 feet if they are clearly marked as "compact cars only" and provided they are not the most conveniently located spaces.
(2) 
All spaces shall be marked to indicate their location, except those of a one- or two-family dwelling, and except where stone parking may be allowed.
(3) 
Motorcycle parking spaces may be provided with a minimum size of nine feet by nine feet. Each two motorcycle parking spaces may count as one required regular parking space, comprising up to 5% of the total required number of spaces.
(4) 
Bicycle parking. If a lot will include more than 10,000 square feet of new commercial building space or 10 or more dwelling units, a bike rack or similar feature shall be provided to allow locking of bicycles without obstructing sidewalks. For dwellings, a suitable indoor area may be provided, instead of a public bike rack.
(c) 
Parking aisles.
(1) 
The aisle width of required parking shall comply with the following table:
Parking Angle
(degrees)
Minimum Aisle Width
(feet)
Parallel to 25
12 (except 20 feet for 2-way traffic)
25 to 47
13 (1-way traffic only)
48 to 52
14 (1-way traffic only)
53 to 58
15 (1-way traffic only)
59 to 62
16 (1-way traffic only)
63 to 68
17 (1-way traffic only)
69 to 72
18 (1-way traffic only)
73 to 85
20 (1-way traffic only)
86 to 90
20 (except 24 feet for 2-way traffic)
(2) 
For parking at an angle of 45° or greater, the minimum aisle width may be reduced one foot where the adjacent parking spaces have a width of 10 feet or greater.
(3) 
Within an underground parking structure or an aboveground parking structure, the minimum aisle width may be reduced by one foot.
(d) 
Driveways. See also the Lebanon County Access Management Ordinance.
(1) 
Width of driveway at entrance onto a public street, at the edge of the cartway.
One-Way Use*
(feet)
Two-Way Use*
(feet)
Minimum
10
20
Maximum
24
28
*
This standard may be revised where PennDOT requires a different standard for an entrance to a state road, or where the applicant demonstrates to the Zoning Officer that a wider width is needed for truck access.
(2) 
Drainage. Adequate provisions shall be made to maintain uninterrupted parallel drainage along a public street at the point of driveway entry. The City may require an applicant to install an appropriate type and size of pipe at a driveway crossing.
(3) 
Clear sight distances. A driveway shall be designed and located to minimize obstructions to vision by motorists and pedestrians of other traffic. PennDOT also has sight distance requirements for driveways entering onto a state road.
(4) 
Driveway setbacks. A new driveway shall be set back a minimum of five feet from a utility pole or fire hydrant.
(5) 
Slope and width. The slope of a driveway shall not exceed 10% within 20 feet of a street right-of-way. The slope and width of a driveway and the clear height above it shall be sufficient to allow access by emergency vehicles.
(6) 
Driveway grading. Grading shall allow drainage to continue to gutters, unless an alternative method of drainage is approved.
(7) 
Number. A lot shall have a maximum of two points of vehicle access onto a street, unless specifically approved otherwise by PennDOT or by the City as part of a subdivision or land development.
(8) 
Setback. Driveways and parking areas must be located a minimum of one foot from the side and rear lot line. However, a residential driveway may be located on the lot if it physically abuts a driveway on the adjacent lot. This location will only be allowed if agreed to by the owners of each lot, and such approval is recorded as a shared driveway on a City-approved plan.
(e) 
Paving, grading and drainage.
(1) 
Parking and loading facilities and including driveways shall be graded and adequately drained to prevent erosion or excessive water flow across streets or adjoining properties.
(2) 
Except for landscaped areas, all portions of required parking areas for commercial, industrial, multifamily and institutional uses involving four or more spaces, off-street loading facilities and driveways serving such uses shall be surfaced with asphalt, concrete, paving block, or other low-dust materials preapproved by the City.
A. 
If a residential driveway is over 100 feet long, only the first 25 feet is required to have such hard surfaces, while the remainder may be crushed stone.
B. 
Driveways limited to use by emergency vehicles are not required to be paved provided the Fire Company approves the proposed surface.
C. 
Driveways and parking that serve public uses, public parks and public recreation areas are not required to be paved.
D. 
However, by special exception, the Zoning Hearing Board may allow parking areas with low or seasonal usage to be maintained in stone, grass or other suitable surfaces. For example, the Board may allow parking spaces to be grass, while major aisles are covered by stone.
E. 
If the design and materials are found to be acceptable in writing by the City Engineer, portions of parking areas may be covered with a low-dust porous pavement surface that is designed to promote groundwater recharge.
(3) 
Motor vehicles shall not routinely be parked on grass or dirt surfaces, except where specifically approved under the above provisions. Entrances to parking spaces shall only occur at lawful driveway locations.
(f) 
Lighting of parking areas. See "light and glare control" in § 1310.07.
(g) 
Parking for persons with disabilities.
(1) 
Number of spaces. See requirements under the Federal Americans With Disabilities Ac[1]t for parking for persons with disabilities. The following is a summary of some of the relevant requirements in effect as of the enactment of this title.
Total Number of Parking Spaces on the Lot
Required Minimum Number/Percent of ADA-Accessible Parking Spaces
1 to 25
1 van-accessible
26 to 50
2, 1 of which must be van-accessible
51 to 75
3, 1 of which must be van-accessible
76 to 100
4, 1 of which must be van-accessible
101 to 150
5, 1 of which must be van-accessible
151 to 200
6, 1 of which must be van-accessible
201 to 300
7, 1 of which must be van-accessible
301 to 400
8, 1 of which must be van-accessible
401 to 500
9, 2 of which must be van-accessible
501 to 1,000
2% of total number of spaces, 1/8 of which must be van-accessible
1,001 or more
20 plus 1% of spaces for each 100 over 1,000 spaces, 1/8 of which must be van-accessible
[1]
Editor's Note: see 42 U.S.C. § 12101 et seq.
(2) 
Location. Handicapped parking spaces shall be located where they would result in the shortest reasonable accessible distance to a handicapped accessible building entrance. Curb cuts shall be provided as needed to provide access from the handicapped spaces.
(3) 
Minimum size and slope. See requirements of the Americans With Disabilities Act regulations.
(4) 
Marking. All required handicapped spaces shall be well-marked in compliance with the Americans With Disabilities Act. Such signs and/or markings shall be maintained over time.
(5) 
Paving. Handicapped parking spaces and adjacent areas needed to access them with a wheelchair shall be covered with a smooth surface that is usable with a wheelchair.
(6) 
Note: A separate City ordinance addresses placement of an individual handicapped parking space in front of a home.
(h) 
Paved area setbacks (including off-street parking setbacks).
(1) 
Intent. To ensure that parked or moving vehicles within a lot do not obstruct sight distance or interfere with pedestrian traffic, to aid in stormwater management along streets, and to prevent vehicles from entering or exiting a lot other than at approved driveways.
(2) 
Any new or expanded vehicle parking or vehicle storage area of four or more parking spaces that serves a principal nonresidential use shall be separated from a public street by a planting strip. The planting strip shall have a minimum width of eight feet and be maintained in grass or other attractive vegetative ground cover. The planting strip may be on one or both sides of any sidewalk, provided the planting width totals eight feet. This eight-foot width shall be increased to 15 feet for a lot including 30 or more parking spaces that are visible from the street.
A. 
The planting strip shall not include heights or locations of plants that would obstruct safe sight distances, but may include deciduous trees that allow motorists to maintain views under the leaf canopy.
B. 
The planting strip may be placed inward from the shoulder of an uncurbed street or inward from the curb of a curbed street. The planting strip may overlap the street right-of-way, provided it does not conflict with PennDOT requirements, and provided that the City and PennDOT as applicable maintain the right to replace planting areas within the right-of-way with future street improvements.
C. 
The planting strip may be crossed perpendicularly by driveways.
D. 
The planting strip may consist of vegetative stormwater channels.
E. 
The following shall be prohibited within the planting strip:
1. 
Paving, except as allowed by Subsection C above, and except for street widenings that may occur after the development is completed;
2. 
Fences; and
3. 
Parking, storage or display of vehicles or manufactured homes or items for sale or rent or junk.
F. 
Where feasible, where a sidewalk is not installed, this setback should include an unobstructed generally level width running parallel to a street that is suitable for a person to walk.
(3) 
See landscaping requirements in § 1313.04.
(i) 
Pedestrian route. If a parking lot serving commercial uses will include 50 or more new parking spaces, it shall include a designated pedestrian walkway/wheelchair accessway through the parking lot to at least one major pedestrian entrance, and with a marked pedestrian crossing across any major vehicle route.
[Ord. No. 1-2020, 21, passed 6-22-2020]
(a) 
Each use shall provide off-street loading facilities, which meet the requirements of this section, sufficient to accommodate the maximum demand generated by the use and the maximum size vehicle, in a manner that will not routinely obstruct traffic on a public street and traffic entering and exiting the lot. If no other reasonable alternative is feasible, traffic may be obstructed for occasional loading and unloading along an alley, provided traffic has the ability to use another method of access.
(b) 
At the time of review under this title, the applicant shall provide evidence to the Zoning Officer on whether the use will have sufficient numbers and sizes of loading facilities. The Planning Commission and/or City Council may provide advice to the Zoning Officer on this matter as part of any plan review by such boards. For the purposes of this section, the words "loading" and "unloading" are used interchangeably.
(c) 
Each space and the needed maneuvering room shall not intrude into approved buffer areas and landscaped areas.
(d) 
To the maximum extent feasible, tractor-trailer loading docks shall be designed so that they are buffered from view of dwellings or from adjacent streets by walls or landscaping. However, areas that are only used for short-term unloading of trucks and that do not require use of a dock are not required to be buffered.
[Ord. No. 1-2020, 21, passed 6-22-2020]
(a) 
Fire lanes shall be provided where required by state or federal regulations or other local ordinances.
(b) 
Access shall be also provided so that fire equipment can reach all sides of principal nonresidential buildings and multifamily/apartment buildings. This access shall be able to support a loaded fire pumper truck, but shall not necessarily be paved.
(c) 
The specific locations of fire lanes and fire equipment access are subject to approval by the City, after review by City fire officials.