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

209 Passenger Loading Zones and Bus Stops

In general, at least one accessible passenger loading zone is required for every 100 linear feet of loading zone space provided (209.2.1). Additional requirements address bus loading zones and bus stops (209.2.2 and 209.2.3), medical and long-term care facilities (209.3), valet parking (209.4), and mechanical access parking garages (209.5). Revisions have been made to:

• clarify the basic scoping provision (209.2.1)
• integrate requirements for bus loading zones and bus stops previously located in a separate chapter covering transportation facilities (209.2.2 and 209.2.3)
• modify provisions specific to medical care and long-term care facilities (209.3)
• address mechanical access parking garages (209.5)

An accessible passenger loading zone is required for every 100 linear feet of loading zone space provided. The Board has clarified in the final rule that this applies to "fractions" of this amount as well, which is consistent with the intent of this provision as proposed.

The proposed rule addressed bus loading areas and bus stops in Chapter 10 (section 1002.2), which covered transportation facilities. With the integration of this chapter into the preceding chapters, the provisions for bus loading zones and bus stops have been incorporated into the general scoping provisions for passenger loading zones. This reorganization helps clarify that while these areas function as passenger loading zones, they are subject to different technical criteria. No substantive changes have been made to these requirements as part of this reorganization.

Accessible Passenger Loading Zones at Medical Care and Long-Term Care Facilities

Comment. Accessible passenger loading zones are required at licensed medical care and licensed long-term care facilities. The scope of this requirement was not clear to commenters who asked whether the reference to medical care facilities included doctors’ and dentists’ offices, clinics, and similar types of health care facilities.

Response. The Board did not intend this provision to apply to medical facilities that do not generally provide overnight stay. In the final rule, this requirement is limited to those medical and long-term care facilities where the period of stay may exceed 24 hours. This change is consistent with original ADAAG’s use of the term "medical care facility" and corresponds with a similar revision made to scoping provisions for patient bedrooms in such facilities in section 223. In addition, the Board has clarified that this provision applies only to long-term care facilities that are licensed.

Comment. It was recommended that the guidelines address mechanical conveyances used to elevate vehicles to different levels of parking facilities. Comments pointed out that model building codes cover facilities providing these vehicle lifting devices.

Response. The final rule includes a provision for "mechanical access parking garages" that requires accessible passenger loading zones at the vehicle drop-off and pick-up areas. This requirement is consistent with model building codes.