Guidance on the 2010 ADA Standards for Accessible Design

Analysis and Com menta ry on the 201 0 A DAStandards less expensive than permanent amusement with the commenter that accessible load and parks. While the Department understands the unload areas may be the same where signs commenter’s concerns, the Department notes that comply with section 216.12 are provided. that most amusement rides are too complex to be reasonably modified or re-engineered to Wheelchair Space or Transfer Seat or accommodate the majority of individuals with Transfer Device. Sections 234.3 and 1002.4 disabilities and that additional complexities - 1002.6 of the 2010 Standards provide and safety concerns are added when the that each new and altered amusement ride, rides are mobile or portable. except for mobile/portable rides and a few additional excepted rides, will be required to A commenter asked that section 234 of provide at least one type of access by means the 2010 Standards make clear that the of one wheelchair space or one transfer seat requirements for accessible routes include or one transfer device (the design of the the routes leading up to and including the transfer device is not specified). loading and unloading areas of amusement rides. Sections 206.2.9 and 1002.2 of the Commenters urged the Department to revise 2010 Standards clarify that the requirements the requirements for wheelchair spaces for accessible routes include the routes and transfer seats and devices because leading up to and including the loading and most amusement rides are too complex to unloading areas of amusement rides. be reasonably modified or re-engineered to accommodate the majority of individuals with A commenter requested that the final rule disabilities. They argued that the experience specifically allow for wheelchair access of amusement rides will be significantly through the exit or other routes, or alternate reduced if the proposed requirements are means of wheelchair access routes to implemented. amusement rides. The commenter stated that the concept of wheelchair access The 2004 ADAAG, which the Department through the exit or alternate routes was a adopted as part of the 2010 Standards, was base assumption for the 2010 Standards. developed with the assistance of an advisory The commenter noted that the concept is committee that included representation from apparent in the signage and load/unload the design staffs of major amusement venues area provisions in Section 216.12 (“ * * * and from persons with disabilities. The where accessible unload areas also serve as Department believes that the resulting 2004 accessible load areas, signs indicating the ADAAG reflected sensitivity to the complex location of the accessible load and unload problems posed in adapting existing rides by areas shall be provided at entries to queues focusing on new rides that can be designed and waiting lines”). The Department agrees from the outset to be accessible. Department of Justice Guidance on the 2010 Standards: Titles II and III - 149