Small Adaptive Reuse/Urban Church

In a situtation where the buidling is nearly to the lot lines in all four directions and the zoning requires 37 parking spaces, we would need to provide 2 LE/FE stalls under option 1. There are two spaces on the alley side of the property. They are not close to the main entrance, but they are closer than the dedicated shared lot that serves the building users and is about 400 feet away. We expect that we cannot use the shared lot to meet this credit. Could these two spots in the alley count as the dedicated parking to meet this credit?