renovation and repurpose of an old school into an office facility. parking capacity will remain the same, but some existing spots (9 spots out of about 85) are limestone. These are now to be converted into paved spots.

Can these be counted as existing parking? technically, local ordinances do not allow these to count since the ordinance does not allow gravel/stone parking - but they are well documented (google earth, photos, etc) as being regularly used as parking spots.

any one have experience with such a situation w/ this credit?