Analysis Of The Proposed Standarts (Appendix A) - Summary Of The Major Substantive Changes Proposed For The Scoping And Technical Requirements Page 35
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63sections 221.3 and 802.3 will permit companion seats to be readily removable, but will
not require the seats to be designed so they can also serve as wheelchair spaces when
removed.
One commenter recommended that there should be a requirement at section 802.3 that
when companion seats are fixed, each seat shall be identified by a sign or marker as a
companion seat. The Department believes that it is not necessary to identify the
companion seat with an accessibility symbol because its placement adjacent to the
wheelchair location makes it easily identifiable.
Commenters urged the Department to ensure that companion seats are positioned in a
manner that places the user at the same shoulder height as their companions using
mobility devices. The Department recognizes that some facilities have created difficulty
by locating either the wheelchair space or the companion seat on a different floor
elevation (often a difference of one riser). The proposed standards at section 802.3.1
address this problem by requiring the wheelchair space and the companion seat to be on
the same floor elevation. This should prevent any vertical discrepancies that are not the
direct result of differences in the sizes and configurations of wheelchairs.
Designated Aisle Seats. Existing requirements at section 4.1.3(19)(a) require one percent
(1%) of fixed seats in assembly areas to be designated aisle seats. Designated aisle seats
must have either no armrests or folding or retractable armrests on the aisle side of the
seat.
Proposed sections 221.4; 802.4; 802.4.1; and 802.4.2 base the number of required
designated aisle seats on the number of aisle seats, instead of all the seats in a sports
facility as the 1991 Standards require. At least five percent (5%) of the aisle seats are
required to be designated aisle seats and to be located closest to accessible routes. This
option will almost always result in fewer aisle seats being designated aisle seats
compared to the 1991 Standards. Sports facilities typically locate designated aisle seats
on, or as near to, accessible routes as permitted by the configuration of the facilities.
Dispersion of Wheelchair Spaces and Lines of Sight in Assembly Areas. The 1991
Standards at section 4.33.3 require wheelchair spaces to be an integral part of any fixed
seating plan in assembly areas and to be dispersed, when the seating capacity exceeds
300. The 1991 Standards also require wheelchair spaces to provide individuals with
disabilities lines of sight comparable to the sightlines available to other spectators in
assembly areas. The Department interprets comparable sightlines as requiring wheelchair
spaces in sports stadiums and arenas to provide lines of sight over standing spectators to
the playing field, where spectators are expected to stand during events. The Department
also interprets comparable lines of sight as requiring wheelchair spaces in stadium-style
movie theaters to provide viewing angles comparable to those provided to other
spectators.
The proposed revisions at sections 221.2.2; 221.2.3; 221.2.3.1, Exceptions 1; 221.2.3.2,
Exceptions 1 and 2; 802.2; 802.2.1; 802.2.1.1; 802.2.1.2; 802.2.2; 802.2.2.1; and
35
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