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

Comment. Persons with disabilities considered the 34 inch maximum height too high for surfaces used for any length of time. These commenters recommended that where only a portion of counters are made accessible, the accessible height should be 31 inches maximum. Some commenters also recommended a higher minimum height of 29 inches instead of 28 inches to allow a more comfortable knee clearance.

Response. The Board has not revised the specified height for dining and work surfaces or the minimum clearances for knee and toe space required below since it believes further research is needed on these long-standing specifications, particularly in relation to people who use scooters and other powered mobility aids. Research on powered mobility aids the Board is currently sponsoring through the Rehabilitation Engineering Research Center on Universal Design will provide information on various fundamental specifications the Board may use in future updates of the guidelines.