Guidance on the 2010 ADA Standards for Accessible Design

Analysis and Com menta ry on the 201 0 A DAStandards Chapter 4. For example, where the total located in an area with limited space and length of a gangway or series of gangways extreme tidal variations, a disproportionately serving as an accessible route is 80 feet long gangway might intrude into water travel or more an exception permits the slope on routes. The Department has considered a gangways to exceed the maximum slope in wide range of boating facility characteristics section 405.2. including size, water surface areas, tidal fluctuations, water conditions, variable Some commenters suggested that resources, whether the facility is in a highly permissible slope variations could be reduced developed or remote location, and other further by introducing a formula that ties factors. The Department has determined required gangway length to anticipated that the 2010 Standards provide sufficient water level fluctuations. Such a formula flexibility for such broad application. would incorporate predictions of tidal level Additionally, the length requirement for changes such as those issued by the accessible routes in section 1003.2.1 National Oceanographic and Atmospheric provides an easily determinable compliance Administration (NOAA) and the United States standard. Geologic Survey (USGS). This suggested approach would be an alternative to the Accessible Boarding Piers. Where gangway length exceptions and limits in boarding piers are provided at boat launch section 1003.2.1 of the 2010 Standards. ramps, sections 235.3 and 1003.3.2 of the These commenters noted that contemporary 2010 Standards require that at least five building materials and techniques make percent (5%) of boarding piers, but at least gangways of longer length and alternative one, must be accessible. configurations achievable. These commenters provided at least one example Accessible Boat Slips. Sections 235.2 of a regional regulatory authority using this and 1003.3.1 of the 2010 Standards require type of formula. While this approach may be that a specified number of boat slips in each successfully implemented and consistent with recreational boating facility meet specified the goals of the ADA, the example provided accessibility standards. The number of was applied in a highly developed area accessible boat slips required by the 2010 containing larger facilities. The Department Standards is set out in a chart in section has considered that many facilities do not 235.2. One accessible boat slip is required have sufficient resources available to take for facilities containing 25 or fewer total slips. advantage of the latest construction materials The number of required accessible boat slips and design innovations. Other commenters increases with the total number of slips at the supported compliance exceptions for facilities facility. Facilities containing more than one that are subject to extreme tidal conditions. thousand (1000) boat slips are required to One commenter noted that if a facility is provide twelve (12) accessible boat slips plus Department of Justice Guidance on the 2010 Standards: Titles II and III - 151