Analysis Of The Proposed Standarts (Appendix A) - Summary Of The Major Substantive Changes Proposed For The Scoping And Technical Requirements Page 28
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63the space they serve. This requirement also will clarify that the exception for temporary
signs applies to signs used for seven days or less.
The proposed standards retain the option to provide one sign where both visual and tactile
characters are provided or two signs, one with visual, and one with tactile characters.
217 and 704 Telephones
Drive-up Public Telephones. Where public telephones are provided, the 1991 Standards,
at section 4.1.3(17)(a), and proposed section 217.2, Exception, require a certain number
of telephones to be wheelchair accessible. The proposed requirement adds a new
exception that exempts drive-up public telephones.
Public Telephone Volume Controls. Current sections 4.1.3(17), 4.30.7(2), and 4.31.5
require all wheelchair accessible public telephones and twenty-five percent (25%) of all
other public telephones to have volume controls, and to be identified by signs. Proposed
changes at sections 217.3 and 704.3 will require all public telephones to have volume
controls, and will delete the requirement for identifying signs. The 1991 Standards
require volume control telephones to provide a minimum gain of 12 dB and a maximum
gain of 18 dB. A proposed change will require a gain up to 20 dB minimum and an
automatic reset.
The proposed change is expected to have minimum impact since the proposed scoping
and technical requirements are consistent with guidelines and standards issued by the
Access Board under section 255 of the Telecommunications Act of 1998 (36 CFR
1193.43(e), and Section 508 of the Rehabilitation Act of 1973, as amended, (36 CFR
1194.23(f)) which require all new telephones to have volume controls.
TTY. Section 4.1.3(17) of the 1991 Standards require a public TTY if there are four or
more public pay telephones at a site and at least one is in an interior location. Proposed
changes, 217.4.2, will require that a building or facility provide a public TTY on each
floor that has four or more public telephones, and in each telephone bank that has four or
more telephones as proposed by sections 217.4.1, 217.4.3, 217.4.3.1, 217.4.3.2, 217.4.4,
217.4.5, 217.4.6, 217.4.7, and 217.4.8.
Another commenter stated that requiring installation of telephones within the proposed
reach range requirements would adversely impact the public and telephone owners and
operators. According to the commenter, people without disabilities will not use
telephones that are installed within the reach range requirements because they may be
inconvenienced by bending to operate these telephones, and, therefore, owners and
operators will lose revenues because of the reduction in use.
This comment misunderstands the scoping requirements for wheelchair accessible
telephones. Proposed section 217.2 provides that where one or more single units are
provided, only one unit per floor, level, or exterior site is required to be wheelchair
accessible. However, where banks of telephones are provided, only one telephone in
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