Guidance on the 2010 ADA Standards for Accessible Design

Section 35.151 -- Title II Regulation and transient lodging requirements to allow The Department has determined that the students with mobility impairments to interact best approach to this type of housing is to and socialize in a fully integrated fashion. continue to require the application of tran- sient lodging standards, but at the same Two commenters supported the time to add several requirements drawn from Department’s proposed approach. One the residential facilities standards related commenter argued that the transient lodg- to accessible turning spaces and work sur- ing requirements in the 2004 ADAAG would faces in kitchens, and the accessible route provide greater accessibility and increase throughout the unit. This will ensure the main- the opportunity of students with disabilities tenance of the transient lodging standard to participate fully in campus life. A sec- requirements related to access to all floors ond commenter generally supported the of the facility, roll-in showers in facilities with provision of accessible dwelling units at more than 50 sleeping rooms, and other places of education, and pointed out that important accessibility features not found in the relevant scoping in the International the residential facilities standards, but will Building Code requires accessible units also ensure usable kitchens and access “consistent with hotel accommodations.’’ to all the rooms in a suite or apartment. The Department has considered the com- The Department has added a new defini- ments recommending the use of the residen- tion to Sec. 35.104, “Housing at a Place of tial facilities standards and acknowledges Education,’’ and has revised Sec. 35.151(f) that they require certain features that are not to reflect the accessible features that now included in the transient lodging standards will be required in addition to the require- and that should be required for housing pro- ments set forth under the transient lodging vided at a place of education. In addition, standards. The Department also recognizes the Department notes that since educational that some educational institutions provide institutions often use their academic hous- some residential housing on a year-round ing facilities as short-term transient lodging basis to graduate students and staff which in the summers, it is important that acces- is comparable to private rental housing, and sible features be installed at the outset. It is which contains no facilities for educational not realistic to expect that the educational programming. Section 35.151(f)(3) exempts institution will be able to adapt a unit in a from the transient lodging standards apart- timely manner in order to provide acces- ments or townhouse facilities provided by sible accommodations to someone attending or on behalf of a place of education that are a one-week program during the summer. leased on a year-round basis exclusively to graduate students or faculty, and do not Department of Justice Guidance on 2010 Standards: Title II - 23