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Accessibility

INTRODUCTION

Since the Civil Rights Act of 1964, disability rights legislation andincreasing public awareness about the rights of people with disabili-ties have produced various pieces of legislation, the most extensiveof which is the Americans with Disabilities Act, Public Law 101-336.Passed in January 1990, the law identifies equal access as a civil rightand prohibits discrimination on the basis of disability in both privatelyand publicly owned accommodations. Public accommodationsinclude services, programs, activities, goods, and commercial estab-lishments, such as restaurants, hotels, theaters, hospitals, museums,and parks.

The executive branch of the federal government is not bound tothe provisions of the Americans with Disabilities Act. Executiveagencies and recipients of federal funding are required to complywith the accessibility provisions contained in two pieces of earlierlegislation:

• Architectural Barriers Act (1968)

• Section 504 of the Rehabilitation Act (1973)

ACCESSIBILITY REQUIREMENTS

Both the Architectural Barriers Act and Section 504 of the Rehabilita-tion Act contain standards and guidelines that identify the conditionsnecessitating accessibility requirements and give technical specificationsfor new construction, alterations, and additions. For both Acts, theminimum standards of accessibility for federal buildings and facilities isdefined by the Uniform Federal Accessibility Standards (UFAS), pub-lished in 1984 by the Architectural and Transportation Barriers Com-pliance Board.

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For nonfederal public accommodations, minimumaccessibility requirements are outlined in theAmericans with Disabilities Act AccessibilityGuidelines (ADAAG). The ADAAG was pub-lished in 1991 by the Architectural and Transpor-tation Barriers Compliance Board.

The UFAS and ADAAG have common technicalrequirements. The general technical require-ments for ADAAG (titled “Accessible Elementsand Spaces”) are the same as the UFAS technicalrequirements. Both require that the design ofnew construction be accessible; however, theydiffer slightly in their scoping requirements forexisting facilities. ADAAG has many new technicalrequirements for various types of public accom-modations, including restaurants and cafeterias,medical care facilities, business and mercantile,libraries, transient lodging, and transportationfacilities. Both UFAS and ADAAG have specialrules for historic preservation, which are dis-cussed in this text.

The technical requirements common to bothUFAS and ADAAG are actually derived fromaccessibility standards first developed in 1961 bythe American National Standards Institute (ANSI).The ANSI standards have been modified verylittle over the past 30 years despite medical andtechnology advancements and increased aware-ness about the needs and life expectations ofpeople with disabilities.

The federal government intends to revise theUFAS to be at least equivalent to the ADAAG inits technical and scoping requirements. In a June

30, 1993 memorandum, the Department ofJustice requested that until the UFAS are revised,the executive agencies use the higher standardsof the ADAAG whenever the guidelines result inmore universal access. Currently, both the UFASand the ADAAG are being reviewed by theArchitectural and Transportation Barriers Compli-ance Board for possible revisions to their respec-tive technical requirements. This review is beingconducted in conjunction with the Civil RightsDivision of the Department of Justice and the fourstandard-setting agencies under the ArchitecturalBarriers Act: General Services Administration, theUnited States Postal Service, the Department ofHousing and Urban Development, and theDepartment of Defense.

UNIVERSAL DESIGN

Universal design is based on the premise that afacility or product should be usable by anyone.Despite advancements toward universal accessi-bility, the disability community and universaldesign advocates have criticized the use ofaccessibility guidelines. Critics maintain that theuse of minimum construction specifications doesnot promote a greater understanding about theneeds of people with disabilities, or contribute toremoving attitudinal barriers.

Critics believe that for designed environments,attitudinal barriers are more persistent thanarchitectural ones, and the way to remove theattitudinal barriers is to increase awareness aboutthe many distinctive needs of users. Critics assertthat in practice, minimum design standards

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Figure 3. Office walkway following implementation of theaccessibility project. The historic stone edge condition of theoriginal walkway was salvaged and relaid to match thegradient of the new walkway. Frederick Law Olmsted NationalHistoric Site. (NPS, 1997)

become maximum standards, and compliance withminimum standards is viewed as the goal ratherthan the means to achieving universal or equalaccess.

Universal design advocates believe strict adher-ence to accessibility guidelines may result in adesign solution that does not create equal ac-cess. They distinguish accessibility from universaland equal access, noting that separate provisionsfor one group of users may ignore the needs ofanother group with different disabilities. Theyemphasize education about the concept of“fitness for use by anyone” as the basis for theenvironmental design process. (See Figures 1, 2,and 3.)

Figure 1. View of the original office walkway and location of aproposed accessibility project to create universal access.Frederick Law Olmsted National Historic Site. (NPS, 1995)

Figure 2. A sketch of the proposed universal access design,which raises the elevation of the historic entrance porch tomeet the threshold, and includes a new walkway with anaccessible gradient. Frederick Law Olmsted National HistoricSite. (NPS, 1995)

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ACCESSIBILITY IN CULTURALLANDSCAPES

Historically, the needs of people with disabilitieshave not been considered in the design andconstruction of places. As a result, many historicproperties have features that are obstacles to equalaccess. Unfortunately, equal access and historicpreservation have often been portrayed as anti-thetical, technically infeasible, and even impossible.But designing equal access to historic properties,including cultural landscapes, does not have topreclude the preservation of significant resources.

Historic preservation exists to allow experientialaccess to historic properties that are consideredculturally valuable or significant. In this context,the goal of equal access is to create equal accessto the experience as well as improve physicalaccessibility. (See Figure 4.) To create equalaccess to the opportunity to experience thesignificance of a cultural landscape, the goal ofaccessibility needs to be united with the goal ofpreservation. The loss of integrity resulting fromthe implementation of an accessibility projectrepresents a compromise to the goals of bothequal access and preservation.

Equal access to the experience of a culturallandscape is achieved when the significance isconveyed through the physical integrity oflandscape characteristics and associated featuresand when the experience is equally available toall visitors or users. As defined by the NationalRegister of Historic Places, integrity relates tothe presence of physical features that haveexisted since a period of significance and thatcontribute to and convey the significance of a

THE EQUAL FACILITATION CLAUSE

A fundamental difference between the UFAS andADAAG in guiding the creation of universally acces-sible environments is that the ADAAG has an extraclause within the general provisions, titled “EquivalentFacilitation” (ADAAG 2.2). The clause states:

Departures from the particular technicaland scoping requirements of this guide-line by the use of other designs and tech-nologies are permitted where the alter-native designs and technologies used willprovide substantially equivalent or greateraccess to and usability of the facility.

The ADAAG allows designers to depart from thespecifications. For designers to take advantage ofthis creative opportunity, they should understandthe needs of people with disabilities and thereasons underlying the existing guidelines. Forexample, the reason for requiring handrails alongboth sides of a ramp or set of steps is that peoplewith different capabilities on either side of theirbodies (such as people who have sufferedstrokes) can use the handrail matching theirphysical abilities.

Universal design advocates are critical of theprevalence of eight percent gradient ramps withhandrails (permitted by UFAS and ADAAGguidelines), because an eight percent gradient istoo steep for many people with limited mobilityand handrails are unusable by many people withdisabilities. They encourage the use of theADAAG’s Equivalent Facilitation clause because ithas more potential to change attitudes andimprove the usability of designed environments.

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historic property. Therefore, the design ofaccessibility projects in a cultural landscapeshould retain the extant landscape characteristicsand associated features that contribute to andconvey the significance of the landscape. Newfeatures that are added to provide equal accessshould be designed in a manner that is compatiblewith the character of the landscape. The goal isto provide the highest level of access with thelowest level of impact on the integrity of thelandscape. (See A Guide to Cultural LandscapeReports: Appendices, “Appendix I: TreatmentPolicy, Guidelines, and Standards.”)

Accessibility in a cultural landscape is part of thepreservation planning process. Currently, underUFAS scoping requirements, only existing facilitiesundergoing substantial alteration (all alterations inone year amounting to 50 percent or more of theproperty value) trigger requirements for accessibil-ity. Under ADAAG scoping requirements, anyalterations to an existing element, feature, space,or area, triggers new construction standards foraccessibility. Until the UFAS has been revised tothe greater scoping requirement of ADAAG, theDepartment of Justice and the Architectural andTransportation Barriers Compliance Board en-courage the executive agencies to use the greaterscoping requirement of ADAAG for alterations.

ACCESSIBILITY PLANNING

The planning and design of accessibility projects isa multidisciplinary activity involving the expertiseof preservation professionals, accessibility special-ists, and individuals with disabilities and theirorganizations. Accessibility coordinators, usually

located in the National Park Service (NPS) sup-port offices, should be invited to participate in theplanning process.

Accessibility planning and design requires a clearunderstanding of a cultural landscape’s signifi-cance and how it is conveyed through its extantlandscape characteristics and associated features.

Figure 4. Before (top) and after (bottom) existing conditionsplans of Dorchester Heights, the site of an accessibility projectin 1995. The accessibility project occurred as part of arehabilitation treatment plan. It involved "stretching" thepattern of the historic circulation plan (the central walk and thenorth and south ramps were elongated), to achieve a moreshallow, accessible route up to the Dorchester HeightsMonument. Boston Historical Park. (NPS, 1994)

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Equal access must be defined for each particularcultural landscape based on a variety of factors,including significance, landscape characteristics andassociated features, integrity, treatment, andcontemporary use of the landscape. These factorsinfluence how a landscape’s significance ispresented to visitors, and, therefore, affect theextent and location of modifications required toprovide access and the physical appearance ofaccess designs.

If a cultural landscape is eligible for listing or islisted in the National Register of Historic Places,and the access project is a federal undertaking,the planning and design stages of an accessibilityproject involve the review process cited inSection 106 of the National Historic PreservationAct. The NPS initiates consultation with the StateHistoric Preservation Office to develop a Memo-randum of Agreement on the planning and designof access modifications. As a result, the Memo-randum of Agreement outlines actions that areagreed upon and it is submitted to the AdvisoryCouncil for Historic Preservation for comment.The same review procedure is followed whenthe less comprehensive scoping requirements ofUFAS and ADAAG are used to plan and designaccess modifications.

Both UFAS and ADAAG have special rules forhistoric preservation that reduce scoping re-quirements for particularly challenging circum-stances. The rules apply to situations in whichcreating equal access would destroy the integrityof a historic property because its significance iswholly conveyed by the exact location, originalmaterials, original workmanship, or original

design of a feature or features. The special rulesadd flexibility to the process of creating accesschanges that retain the integrity of a historicproperty and therefore allow the significance tobe conveyed and experienced. If using thegeneral scoping requirements for accessibilitywould destroy the integrity of a cultural land-scape, the special rules of UFAS and ADAAGare permitted. The circumstances in which toapply the special rules for historic preservationof UFAS (4.1.7 (2)), and ADAAG (4.1.7 (3)) arerelatively rare and only apply to a small numberof historic properties.

Listed below are the special rules for historicpresentation, which are written to apply mostdirectly to historic buildings.

• Allow only one accessible route from one siteaccess point (such as a parking lot) to anaccessible entrance.

• The accessible entrance may be different tothe one used by the general public (though itcannot be locked and ADAAG requiresdirectional signage to the accessible en-trance).

• A ramp steeper than is ordinarily permittedmay be used in space limitations (a gradient of16.6 percent (1:6) for a maximum run of twofeet).

• Only one accessible restroom is required andit may be unisex.

• Accessible routes are only required at theelevation of the entrance.

• Interpretive materials should be located wherethey can be seen by seated persons.

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ADAAG also has an exception rule for historicpreservation (ADAAG 4.1.7 (1)), which statesthat if the integrity of a historic property couldbe destroyed by following the special rules,scoping requirements are reduced even fur-ther. The exception permits use of alternativemethods to make services and programsavailable (that is, to create the opportunity toexperience the significance of a property).Alternative methods include the use of inter-pretation (such as audio visual materials), usingfacilitators to assist individuals with disabilities,and adopting other innovative methods such asthose invited by the Equivalent Facilitationclause of ADAAG. UFAS has no exception rulefor historic preservation.

SOURCES OF FURTHER INFORMATION

The Uniform Federal Accessibility Standards andinformation can be obtained from:

Architectural and Transportation

Barriers Compliance Board

1111 18th Street, NW, Suite 501Washington, DC 200361-800-USA-ABLE

The Americans with Disabilities Act AccessibilityGuidelines and information can be obtained from:

Office of the Americans with

Disabilities Act—Civil Rights Division

U.S. Department of Justice

P.O. Box 66118Washington, DC 20035-6118202-514-0301

For NPS accessibility enquiries contact:

Accessibility Program Coordinator

Parks Facility Management Division

National Park Service

P.O. Box 37127, Suite 580Washington, DC 20013-7127202-343-3674

TECHNICAL AND SCOPINGACCESSIBILITY REQUIREMENTS FORELEMENTS AND SPACES

Following is a partial list of ADAAG and UFAS“Technical Requirements for Accessible Ele-ments and Spaces,” which are most pertinent toaccess projects in cultural landscapes. For the fulllist of technical and scoping requirements, referto the UFAS or ADAAG.

Accessible Route Minimum Specifications

• Width = 36 inches

• Passing zone = 60 inches wide occurring at200-foot intervals

• Wheelchair 180-degree turning zone = 60inches x 60 inches

• Gradient = 5 percent (1: 20)

• A gradient greater than 5 percent shall becalled a ramp

• Cross pitches (cross slopes) = 2 percent (1: 50)or less

• Abrupt level changes are no greater than 0.5inch in height

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• 0.25-inch level change is permitted without abeveled edge

• 0.5-inch level change must have a bevelededge

• Surfaces must be of stable, firm, slip resistantmaterial

Accessible Parking

• Space = 96 inches wide

• Access aisle is considered to be part of anaccessible route

• Spaces and aisles have a 2 percent (1: 50)maximum gradient in any direction

• Passenger loading zone (access aisle) = 60inches wide x 20 feet long, adjacent andparallel to the vehicle pull-up space

Curb Ramps

• Must be located wherever an accessible routecrosses a curb

• 5 percent (1: 20) gradient or less, unless spaceis limited, then a gradient between 8 percent(1: 12) and 10 percent (1: 10) is permitted fora rise of 6 inches

• Must have flared sides if they are locatedwhere pedestrians must walk across the rampor are not protected by handrails or guardrails

• Maximum gradient of curb ramp flared sides =10 percent

• Must have returned curbs where pedestriansdo not walk across the ramp

• Built-up curb ramps must be located wherethey do not project out into vehicular trafficlanes

• Must have a detectable warning of raised,truncated domes or contrasting color thatextends the full width and depth of the curbramp

• Must be located where they will not be ob-structed by parked vehicles

• Diagonal curb ramps (corner ramps) must haveat least a 48-inch width clear space at thebottom of the ramp

• Where a sidewalk landing beyond a curb rampis less than 48 inches deep, the curb rampgradient must not exceed 8 percent (1: 12)

Ramps

• Must be at least 36 inches wide

• Gradient greater than 5 percent (1: 20) and amaximum of 8 percent (1: 12)

• Maximum rise on any run = 30 inches inheight

• In space limitations, a ramp gradient no greaterthan 16.6 percent (1: 6) may be used for ahorizontal run of 2 feet

• In space limitations, a ramp gradient between 8percent (1: 12) and 10 percent (1: 10) may beused for a maximum vertical rise of 6 inches

• An 8 percent (1: 12) gradient and a rise greaterthan 6 inches, or a horizontal run greater than72 inches, must have handrails on both sides ofthe ramp

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• Surface must be stable, firm, and nonslip

• Ramps and landings with dropoffs on eitherside must have curbs at least 2 inches high

• Must be well draining to prevent the accumula-tion of rainwater

• Cross pitch (cross slope) must be no greaterthan 2 percent (1: 50) gradient

Landings

• Must be located at every 30-inch vertical rise ina ramp

• Dimensions of landing = 36 inches wide x 60inches deep at the top and bottom of a ramp run

• Dimensions of landing = 60 inches wide x 60inches deep at a ramp dogleg

• Drop-offs must have curbs with a minimumheight of 2 inches

• Height of door thresholds = 0.5-inch high orless, with a beveled 50 percent (1: 2) edge

• Width of clear landing on latch side of door =24 inches wide

Handrails

• Not required on curb ramps

• Required on either side of 8 percent (1: 12)gradient ramps with a 6-inch rise or greater, or a72-inch horizontal run, and on either side of stairs

• Must be continuous on the inner side of adogleg ramp or dogleg stairs

• Must continue at least 12 inches beyond thetop and bottom of a ramp and be parallel tothe ground plane

• Must continue at least 12 inches beyond thetop riser of stairs parallel to the ground plane,and continue to slope for a distance of onetread width from the bottom stair riser andbecome parallel to the ground plane for anadditional distance of 12 inches

• Distance from mounting wall = 1.5 inches wide

• Gripping surface must be uninterrupted

• Diameter or width of gripping surface ofhandrail or grab bar must be 1.25 - 1.5 inches,or the shape must provide an equivalentgripping surface UFAS 4.26.2.

• Top of gripping surface = 34 - 38 inches inheight above the ramp or stair tread surface

• Terminal ends of handrails must be rounded offor returned smoothly to the ground, wall or post

Stairs

• Must have uniform tread widths and riserheights

• Width of treads must be no less than 11 incheshigh

• Open risers are not permitted

• Nosings must project no more than 1.5 inches

• Nosing undersides must be angled at nogreater than 60 degrees from the horizontal

• Handrails must be located on either side ofstairs

• Inside handrail at stair dogleg must be continuous

• Handrails must extend 12 inches beyond thetop riser, and at least one tread width and anadditional 12 inches beyond the bottom riser

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• Handrails at the top of stairs must be parallel tothe ground plane, and at the bottom of stairs,handrails must continue to slope for a distanceof one tread from the bottom riser and for anadditional 12 inches be parallel to the groundplane

• Handrail gripping surface must be uninter-rupted and be located 34 - 38 inches abovethe stair treads

• Terminal ends of handrails must be rounded orreturned smoothly to the ground, wall, or post

• Stairs must be well draining to prevent theaccumulation of rainwater

REFERENCES

Adaptive Environments, Inc. 1992. Checklist forExisting Facilities: The Americans with DisabilitiesAct Survey for Readily Achievable Barrier Re-moval. Massachusetts: Adaptive Environments,Inc. and Barrier Free Environments, Inc.

Ballantyne, Duncan. 1984. Accommodation ofDisabled Visitors at Historic Sites in the Na-tional Park System. Washington, DC: USDI,NPS, Park Historic Architecture Division.

Battaglia, David H. 1991. The Impact of theAmericans with Disabilities Act on HistoricStructure. Information Series 55. Washington,DC: National Trust for Historic Preservation.

________. 1991. Americans with DisabilitiesAct: Its Impact on Historic Buildings and Struc-tures. Preservation Law Reporter 1169.

Birnbaum, Charles, A., and Sharon C. Park. June1993. Maintaining Integrity: Accessibility andHistoric Landscapes. Landscape Architecture 83(6). Washington, DC: American Society ofLandscape Architects.

Casciotti, Lynn, M. 1992. Americans with Dis-abilities Act Resource Guide for Park, Recreation,and Leisure Service Agencies. Draft. Virginia:National Recreation and Park Association, Re-source Development Division, Arlington.

Clark, Roger, N., and George H. Stankey. 1979.The Recreation Opportunity Spectrum: A Frame-work for Planning, Management and Research.Washington: USDI, Forest Service, Pacific North-west Forest and Range Experiment Station,Seattle.

Goltsman, Susan, and Timothy Gilbert. 1979.The Accessibility Checklist: An Evaluation Systemfor Buildings and Outdoor Settings. Berkeley,California: MIG Associates.

Harold Russell Associates, Inc. 1978. Accommo-dation of Handicapped Visitors at Historic Sites:The Impact of Accessibility and Historic Preserva-tion Laws, Regulations and Policies on NPSHistoric Sites, Analysis and Recommendations.Washington, DC: USDI, NPS.

Jester, Thomas C., and Judy, L. Hayward, eds.Photocopy 1992. Accessibility and HistoricPreservation Resource Guide. Sponsored byHistoric Windsor; the NPS, Preservation Assis-tance Division; the Advisory Council on HistoricPreservation; the National Conference of State

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Historic Preservation Officers; Accessibility andHistoric Preservation Workshops. Reprint infor-mation available from Historic Windsor, Inc.,Windsor, Vermont.

Jester, Thomas, C., and Sharon C. Park. 1993.Preservation Brief No. 32: Making HistoricProperties Accessible. Washington, DC: USDI,NPS, Preservation Assistance Division.

Kraus, L.E., and S. Stoddard. 1989. Chartbook onDisability in the United States. Washington, DC:National Institute on Disability and RehabilitationResearch.

Mace, Ron, L., Graeme J. Hardie, and Jaine P.Plaice. 1990. Accessible Environments: TowardUniversal Design. Design Interventions: Toward aMore Humane Architecture. Preiser, Vischer, andWhite, editors. New York: Van NostrandReinhold.

Majewski, Janice. 1987. Part of Your GeneralPublic Is Disabled: A Handbook for Guides inMuseums, Zoos, and Historic Houses. Washing-ton, DC: Smithsonian Institution Press, Office ofElementary and Secondary Education.

National Park Service. 1991. Preserving the Pastand Making it Accessible to Everyone: How Easya Task? CRM Supplement 1991. Washington,DC: USDI, NPS.

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National Park Service. 1993. Entrances to thePast. Video recording. Washington, DC: USDI,NPS, Preservation Assistance Division, CulturalResources Training Initiative.

Park, D.C., and A. Farbman. Spring 1989. Acces-sible Outdoor Recreation Facilities. National ParkService and National Recreation and Park Associa-tion Design. Washington, DC: USDI, NPS.

Park, D.C., Wendy Ross and Kay Ellis. 1986.Interpretation for Disabled Visitors in theNational Parks System. Washington, DC:USDI, NPS, Special Programs and PopulationsBranch.

Robinette, Gary, O., and Richard K. Dee.1985. Barrier-Free Exterior Design: AnyoneCan Go Anywhere. New York: Van NostrandReinhold.

Smith, Kennedy. September 1991. The Ameri-cans with Disabilities Act: What it Means toMain Street. Main Street News. Washington,DC: National Trust for Historic Preservation.

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United States Congress. 1990. The Americanswith Disabilities Act. Public Law 101-336.

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The mission of the Department of the Interior is to protectand provide access to our Nation’s natural and culturalheritage and honor our trust responsibilities to tribes.

U.S. Department of the InteriorNational Park ServiceCultural Resources

Park Historic Structures & Cultural Landscapes

United States Department of Justice. July 26,1991. Standards for Accessible Design: ADAAccessibility Guidelines (ADAAG). Appendix A to28 CFR 36 (ADA Title III). Federal Register, vol.56, no. 144.

Walter, Burke. 1994. The Americans with Dis-abilities Act (ADA): Compliance Solutions forHistoric Buildings Using Landscape Architecture.Georgia Landscape 2-3. Georgia: University ofGeorgia School of Environmental Design.