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Comments on specific provisions of proposed ADAAG
During the course of accepting comments on its proposed rule, the
Department received numerous comments on ADAAG. Those areas that
elicited the heaviest response included assistive listening systems,
automated teller machines, work areas, parking, areas of refuge,
telephones (scoping for TDD's and volume controls) and visual alarms.
Strenuous objections were raised by some business commenters to the
proposed provisions of the guidelines concerning check-out aisles,
counters, and scoping for hotels and nursing facilities. All these
comments were considered in the same manner as other comments on the
Department's proposed rule and, in the Department's view, have been
addressed adequately in the final ADAAG.
Largely in response to comments, the Board made numerous changes
from its proposal, including the following:
Generally, at least 50% of public entrances to
new buildings must be accessible, rather than all entrances, as would
often have resulted from the proposed approach.
Not all check-out aisles are required to be
accessible.
The final guidelines provide greater flexibility
in providing access to sales counters, and no longer require a portion
of every counter to be accessible.
Scoping for TDD's or text telephones was
increased. One TDD or text telephone, for speech and hearing impaired
persons, must be provided at locations with 4, rather than 6, pay
phones, and in hospitals and shopping malls. Use of portable (less
expensive) TDD's is allowed.
Dispersal of wheelchair seating areas in theaters
will be required only where there are more than 300 seats, rather than
in all cases. Seats with removable armrests (i.e., seats into which
persons with mobility impairments can transfer) will also be required.
Areas of refuge (areas with direct access to a
stairway, and where people who cannot use stairs may await assistance
during a emergency evacuation) will be required, as proposed, but the
final provisions are based on the Uniform Building Code. Such areas are
not required in alterations.
(Just notes)