Guidance on the 2010 ADA Standards for Accessible Design

Analysis and Commenta ry o n the 2010 ADAStandards One commenter expressed opposition to sections as in the 1991 Standards. The the new scoping provisions for altered guest revised provisions also limit the overlap rooms, which, according to the commenter, between guest rooms required to provide require greater numbers of accessible guest mobility features and guest rooms required rooms with mobility features. to provide communication features. Section 224.5 of the 2010 Standards requires that Section 224.1.1 of the 2010 Standards at least one guest room providing mobility provides scoping requirements for alterations features must also provide communications to guest rooms in existing facilities. Section features. At least one, but not more than ten 224.1.1 modifies the scoping requirements percent (10%), of the guest rooms required to for new construction in section 224 by limiting provide mobility features can also satisfy the the application of section 224 requirements minimum number of guest rooms required to only to those guest rooms being altered or provide communication features. added until the number of such accessible guest rooms complies with the minimum Commenters suggested that the number required for new construction in requirements for scoping and dispersion section 224.2 of the 2010 Standards. The of guest rooms for persons with mobility minimum required number of accessible impairments and guest rooms with guest rooms is based on the total number communication features are too complex for of guest rooms altered or added instead of the industry to effectively implement. the total number of guest rooms provided. These requirements are consistent with The Department believes the requirements the requirements in the 1991 Standards. for guest rooms with communications Language in the 2010 Standards clarifies features in the 2010 Standards clarify the the provision of section 104.2 of the 2010 requirements necessary to provide equal Standards which requires rounding up values opportunity for travelers with disabilities. to the next whole number for calculations of Additional technical assistance will be made percentages in scoping. available to address questions before the rule goes into effect. Guest Rooms with Communication Features. The revisions at section 224.4 Visible Alarms in Guest Rooms with of the 2010 Standards effect no substantive Communication Features. The 1991 change from the 1991 Standards with respect Standards at sections 9.3.1 and 4.28.4 to the number of guest rooms required require transient lodging guest rooms with to provide communication features. The communication features to provide either scoping requirement is consolidated into a permanently installed visible alarms that are single table, instead of appearing in three connected to the building fire alarm system or portable visible alarms that are connected 122 - Guidance on the 2010 Standards: Titles II and III Department of Justice