Guidance on the 2010 ADA Standards for Accessible Design

Analysis and Commenta ry o n the 2010 ADAStandards floor elevation. This solution should prevent During the separate rulemaking on the any vertical discrepancies that are not the 2004 ADAAG the Access Board specifically direct result of differences in the sizes and requested public comment on the question of configurations of wheelchairs. whether aisle seats should be required to be located on accessible routes. After reviewing Designated Aisle Seats. Section 4.1.3(19) the comments submitted during the 2004 (a) of the 1991 Standards requires one Access Board rulemaking, the Access Board percent (1%) of fixed seats in assembly concluded that this could not be done without areas to be designated aisle seats with making significant and costly changes in the either no armrests or folding or retractable design of most assembly areas. However, armrests on the aisle side of the seat. The section 221.4 of the 2004 ADAAG required 2010 Standards, at sections 221.4 and 802.4, that designated aisle seats be the aisle seats base the number of required designated closest to accessible routes. The Department aisle seats on the total number of aisle seats, proposed the same provision and concurs in instead of on all of the seats in an assembly the Access Board’s conclusion and declines area as the 1991 Standards require. At to implement further changes. least five percent (5%) of the aisle seats are required to be designated aisle seats and to Team or Player Seating Areas. Section be located closest to accessible routes. This 221.2.1.4 of the 2010 Standards requires option will almost always result in fewer aisle that at least one wheelchair space compliant seats being designated aisle seats compared with section 802.1 be provided in each team to the 1991 Standards. The Department is or player seating area serving areas of sport aware that sports facilities typically locate activity. For bowling lanes, the requirement designated aisle seats on, or as near to, for a wheelchair space in player seating accessible routes as permitted by the areas is limited to lanes required to be configuration of the facility. accessible. One commenter recommended that section Lawn Seating. The 1991 Standards, at 221.4, Designated Aisle Seats, be changed to section 4.1.1(1), require all areas of newly require that aisle seats be on an accessible constructed facilities to be accessible, but do route, and be integrated and dispersed not contain a specific scoping requirement throughout an assembly area. Aisle seats, for lawn seating in assembly areas. The by their nature, typically are located within 2010 Standards, at section 221.5, specifically the general seating area, and integration require lawn seating areas and exterior occurs almost automatically. The issue of overflow seating areas without fixed seats to dispersing aisle seats or locating them on connect to an accessible route. accessible routes is much more challenging. 116 - Guidance on the 2010 Standards: Titles II and III Department of Justice