Analysis Of The Proposed Standarts (Appendix A) - Summary Of The Major Substantive Changes Proposed For The Scoping And Technical Requirements Page 9
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63and that the 1991 Standards provide that curb ramps shall be provided wherever an
accessible route crosses a curb.
The Department declines to change this language because the change is purely editorial,
resulting from the overall changes in the format. It does not change the substantive
requirement. Under the revised format, all elements within a required accessible route
must be accessible; therefore, if the accessible route crosses a curb, a curb ramp must be
provided.
Limited-use/Limited-application Elevators and Private Residence Elevators. The 1991
Standards at sections 4.1.3(5), Exception 1, and the proposed standards at sections
206.2.3, Exception 1 and 2; and 206.6, Exception 1 and 2 include exceptions to the
scoping requirement for accessible routes that exempt certain facilities from connecting
each story with an elevator. If a facility is exempt from the scoping requirement, but
nonetheless installs an elevator, the 1991 Standards require the elevator to comply with
the technical requirements for elevators. The proposed standards add a new exception
that allows a facility that is exempt from the scoping requirement to install a limited-
use/limited-application (LULA) elevator. LULA elevators are permitted as an alternative
to platform lifts. The proposed standards also add a new exception that permits private
residence elevators in multi-story dwelling and transient lodging units. The proposed
standards contain technical requirements for LULA elevators and private residence
elevators.
A commenter questioned the value of permitting LULA elevators because, as was
claimed, these elevators often are unreliable. LULAs are smaller than other elevators and
have limited travel distance. They are in all other respects subject to the same safety and
reliability standards as other elevators. The Department believes that because LULAs
will be permitted only in situations where accessible vertical access is not now required,
their use will not diminish required access and may, in fact, encourage covered entities to
provide vertical access in situations where it is not now being provided.
Accessible Routes to Tiered Dining Areas in Sports Facilities. The 1991 Standards at
sections 4.1.3(1) and 5.4 and the proposed changes at section 206.2.5 and Exception 3
require an accessible route to be provided to all dining areas in new construction,
including raised or sunken dining areas. The proposed standards will add a new
exception for tiered dining areas in sports facilities. Dining areas in sports facilities are
typically integrated into the seating bowl and are tiered to provide adequate lines of sight
for individuals with disabilities. The new exception requires an accessible route to be
provided to at least 25 percent of the tiered dining areas in sports facilities. Each tier
must have the same services and the accessible route must serve the accessible seating.
Accessible Routes to Press Boxes. The 1991 Standards at sections 4.1.1(1) and 4.1.3(1)
cover all areas of newly constructed facilities required to be accessible, and an accessible
route to connect accessible entrances with all accessible spaces and elements within the
facility. Section 201.1 of the proposed standards requires that all areas be accessible.
The proposed changes at sections 206.2.7(1) and (2) add two exceptions that exempt
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