Analysis Of The Proposed Standarts (Appendix A) - Summary Of The Major Substantive Changes Proposed For The Scoping And Technical Requirements Page 8

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people with limited upper body strength, and others with limited use of their arms and
fingers. This proposal was developed by the Access Board over a prolonged period in
which there was extensive public participation. This process did not produce any
significant data to indicate that applying this requirement in new construction or during
alterations would impose a significant burden.
206 and 402 Accessible Routes
Slope. The proposed standards provide that the running slope of walking surfaces have
cross slopes that shall not be steeper than 1:48. The 1991 Standards’ cross slope
requirement is 1:50.
A commenter recommended increasing the cross slope requirement to allow a maximum
of ½ inch per foot (1:24) to prevent imperfections in concrete surfaces from ponding
water.
The requirement that a cross slope shall not be steeper than 1:48 adequately provides for
water drainage in most situations. Changes to the specifications suggested would double
the allowable cross slope and create a significant impediment for many wheelchair users,
and others with mobility impairments. Therefore, the Department declines to accept this
recommendation.
Accessible Routes from Site Arrival Points and Within Sites. The 1991 Standards at
sections 4.1.2(1) and (2) and the proposed changes at sections 206.2.1 Exception 2; and
206.2.2 Exception require, where provided, that at least one accessible route be provided
from site arrival points to an accessible building entrance, and at least one accessible
route connect accessible facilities on the same site. The proposed standards also add two
exceptions that exempt site arrival points and accessible facilities within a site from the
accessible route requirements where the only means of access between them is a
vehicular way that does not provide pedestrian access.
Comments urged the Department to eliminate the exception that exempts site arrival
points and accessible facilities from the accessible route requirements where the only
means of access between them is a vehicular way not providing pedestrian access. The
Department declines to accept this recommendation because the Department believes that
its use will be limited. If it can be reasonably anticipated that the route between the site
arrival point and the accessible facilities will be used by pedestrians, regardless of
whether a pedestrian route is provided, then this exception will not apply. It will apply
only in the relatively rare situations where the route between the site arrival point and the
accessible facility dictates vehicular access – for example, an office complex on an
isolated site that has a private access road, or a self-service storage facility where all users
are expected to drive to their storage units.
Another commenter suggested that the language of section 406.1, General, is confusing
because it states that curb ramps on accessible routes shall comply with the guidelines,
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