Frequently-Asked Question FAQ #145

FAQ-145: Parking Lots in HCA Analysis

Question: Are parking lots considered to be outside areas occupied by people in the definition of an identified site (specifically, commercial or industrial parking lots and church parking lots)? If a PIR crosses the back portion of a parking lot where it is unlikely that people will congregate, should this area be considered an identified site? If so, is there any guidance on how many people per parking space should be used to compute the total of 20?

Answer: Where parking lots are used for other purposes (e.g., an antique car club that meets on weekends, regular social gatherings), these uses must be considered on their own merits. Identified sites are defined as areas that are occupied by more than 20 persons for specified periods. While it is possible that sufficient people might be in a parking lot near a pipeline resulting in more than 20 persons in proximity to the pipeline at one time, these persons are considered to be in transit and cannot truly be said to "occupy" the parking lot and therefore are not subject to the regulation.