Guidance on the 2010 ADA Standards for Accessible Design

Analysis and Commenta ry o n the 2010 ADAStandards than 1:48 adequately provides for water exception will not apply. It will apply only drainage in most situations. The suggested in the relatively rare situations where the changes would double the allowable cross route between the site arrival point and the slope and create a significant impediment accessible facility dictates vehicular access – for many wheelchair users and others with a for example, an office complex on an isolated mobility disability. site that has a private access road, or a self- service storage facility where all users are Accessible Routes from Site Arrival Points expected to drive to their storage units. and Within Sites. The 1991 Standards, at sections 4.1.2(1) and (2), and the 2010 Another commenter suggested that the Standards, at sections 206.2.1 and 206.2.2, language of section 406.1 of the 2010 require that at least one accessible route Standards is confusing because it states that be provided within the site from site arrival curb ramps on accessible routes shall comply points to an accessible building entrance and with 406, 405.2 through 405.5, and 405.10. that at least one accessible route connect The 1991 Standards require that curb ramps accessible facilities on the same site. The be provided wherever an accessible route 2010 Standards also add two exceptions crosses a curb. that exempt site arrival points and accessible facilities within a site from the accessible The Department declines to change this route requirements where the only means of language because the change is purely access between them is a vehicular way that editorial, resulting from the overall changes does not provide pedestrian access. in the format of the 2010 Standards. It does not change the substantive requirement. Commenters urged the Department to In the 2010 Standards all elements on a eliminate the exception that exempts site required accessible route must be accessible; arrival points and accessible facilities from therefore, if the accessible route crosses a the accessible route requirements where curb, a curb ramp must be provided. the only means of access between them is a vehicular way not providing pedestrian Areas of Sport Activity. Section 206.2.2 access. The Department declines to of the 2010 Standards requires at least accept this recommendation because the one accessible route to connect accessible Department believes that its use will be buildings, facilities, elements, and spaces limited. If it can be reasonably anticipated on the same site. Advisory section 206.2.2 that the route between the site arrival point adds the explanation that an accessible route and the accessible facilities will be used must connect the boundary of each area of by pedestrians, regardless of whether a sport activity (e.g., courts and playing fields, pedestrian route is provided, then this whether indoor or outdoor). Section 206.2.12 of the 2010 Standards further requires that 80 - Guidance on the 2010 Standards: Titles II and III Department of Justice