Analysis Of The Proposed Standarts (Appendix A) - Summary Of The Major Substantive Changes Proposed For The Scoping And Technical Requirements Page 37

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related elements and features in customer dressing and fitting rooms that may require
redesigns of entire changing areas or loss of sales or inventory space that will be
redirected to the enlarged dressing and fitting rooms. Comments also expressed
opposition to the accessibility requirements for locker rooms for similar reasons.
The Department reminds the commenters that the requirements in the standards are
designed to apply to new construction and alterations. The Department believes that in
these situations creative designers can mitigate the impact of the changes.
224 and 806 Transient Lodging Guest Rooms
General. The minimum number of guest rooms required to be accessible in transient
lodging facilities is covered by section 224. Access is addressed for people with
disabilities, including people with mobility impairments at section 224.2, and people who
are deaf or hard of hearing at section 224.4.
The U.S. Chamber of Commerce and others representing the hotel industry provided
comments opposing the current requirements for guest rooms accessible to individuals
with mobility impairments stating that statistics provided by the industry demonstrate that
all types of accessible guest rooms are unused. They further claimed that the proposed
requirements are too burdensome to meet in new construction, and that the proposed
requirements will result in a loss of hotel living space. By contrast, commenters
representing people with disabilities urged the Department to increase the number of
guest rooms required to be accessible.
The number of rooms accessible to people with mobility impairments and the number
accessible to people with communication impairments in the proposed standards are
consistent with the 1991 Standards and with IBC. The Department continues to receive
complaints about the lack of accessible guest rooms throughout the country. Accessible
guest rooms are used not only by individuals using mobility devices such as wheelchairs
and scooters, but by individuals with a variety of physical impairments such as those
using walkers, canes, and crutches.
Data provided by the Disability Statistics Center at the University of California, San
Francisco that demonstrated the number of adults who use wheelchairs has been
increasing at the rate of six percent per year from 1969 to 1999; and by 2010, it is
projected that two percent of the adult population will use wheelchairs. In addition to
people who use wheelchairs, three percent of adults used crutches, canes, walkers, and
other mobility devices in 1999; and the number is projected to increase to four percent by
2010. Thus, by 2010, up to six percent of the population may need accessible guest
rooms.
Some commenters have asked the Department to clarify and simplify the dispersion
requirements set forth in section 224.5, in particular the scope of the term “amenities.”
Section 224.5 requires that guestrooms with mobility features and guestrooms with
communication features “[s]hall be dispersed among the various classes of guest rooms,
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