36 CFR Parts 1190 and 1191 ADA and ABA Accessibility Guidelines - Preamble (Discussion of Comments and Changes)

Section 206.4 covers entrances. Substantive changes include:

• increasing scoping for public entrances (206.4.1

• removing a requirement for accessible ground floor entrances (206.4.3 in the proposed rule)

• revision of provision for parking structure entrances (206.4.2)

Editorial changes include reordering of provisions and the addition of requirements specific to transportation facilities (206.4.4) and residential dwelling units (206.4.6) that were previously located in chapters specific to those facilities. Scoping requirements for signs at entrances have been moved to the scoping for signs at section 216.

Comment. The proposed rule specified that at least 50% of public entrances be accessible (206.4.3). Many persons with disabilities urged the Board to increase this scoping so that they have equal access in terms of convenience, entry options, travel distances, and proximity to accessible parking. Some commenters argued that all public entrances should be accessible.

Response. The minimum number of entrances required to be accessible has been increased from 50% to 60% in the final rule. While access to all entrances is desirable, a variety of conditions on a site can make access to every entrance difficult and costly. For example, facilities located on steep hillsides may have entrances elevated significantly above grade. However, this consideration, in the Board’s view, is not as relevant to connections from parking structures. In final rule, the Board has required all pedestrian connections between parking structures and facility entrances to be accessible (206.4.2). This represents an increase from the proposed rule, which required only one to be accessible.

Comment. The proposed rule required that at least one accessible entrance be a ground floor entrance (206.4.3). Commenters recommended that this stipulation be removed since the ground floor may not always be the primary floor. In such conditions, the provision would not enhance accessibility.

Response. The requirement that at least one accessible entrance be a ground floor entrance has been removed in the final rule.