Guidance on the 2010 ADA Standards for Accessible Design

Analysis and Com menta ry on the 201 0 A DAStandards 200 seats (or fraction thereof) more than Section 221.2.1.3 of the 2010 Standards 5000 are required. See sections 221.1 and clarifies that the scoping requirements for 221.2 of the 2010 Standards. wheelchair spaces and companion seats are to be applied separately to general seating Commenters questioned why scoping areas and to each luxury box, club box, and requirements for large assembly areas are suite in arenas, stadiums, and grandstands. being reduced. During the development In assembly areas other than arenas, of the 2004 ADAAG, industry providers, stadiums, and grandstands, the scoping particularly those representing larger requirements will not be applied separately. stadium-style assembly areas, supplied Thus, in performing arts facilities with tiered data to the Access Board demonstrating boxes designed for spatial and acoustical the current scoping requirements for large purposes, the scoping requirement is to assembly areas often exceed the demand. be applied to the seats in the tiered boxes. Based on the data provided to the Access The requisite number of wheelchair spaces Board, the Department believes the reduced and companion seats required in the tiered scoping requirements will adequately meet boxes are to be dispersed among at least the needs of individuals with disabilities, while twenty percent (20%) of the tiered boxes. balancing concerns of the industry. For example, if a performing arts facility has 20 tiered boxes with 10 fixed seats in each Commenters representing assembly areas box, for a total of 200 seats, at least five supported the reduced scoping. One wheelchair spaces and companion seats commenter asked that scoping requirements must be provided in the boxes, and they must for larger assembly areas be reduced even be dispersed among at least four of the 20 further. Although the commenter referenced boxes. data demonstrating that wheelchair spaces in larger facilities with seating capacities Commenters raised concerns that the 2010 of 70,000 or more may not be used by Standards should clarify requirements for individuals with disabilities, the data was not scoping of seating areas and that requiring based on actual results, but was calculated accessible seating in each luxury box, club at least in part based on probability box, and suite in arenas, stadiums and assumptions. The Department is not grandstands could result in no wheelchair convinced that further reductions should be and companion spaces available for made based upon those projections and that individuals with disabilities in the general further reductions would not substantially limit seating area(s). These comments appear to accessibility at assembly areas for persons misunderstand the requirements. The 2010 who use wheelchairs. Standards require each luxury box, club box, and suite in an arena, stadium or grandstand to be accessible and to contain wheelchair Department of Justice Guidance on the 2010 Standards: Titles II and III - 111