Accessible assembly areas located at Title II and Title III facilities are required to comply with the Americans with Disabilities Act (ADA). This article will discuss the ADA scoping requirements for accessible assembly areas in State and local government facilities, public accommodations, and commercial facilities. Federal regulations 28 CFR 35.151(g) and 28 CFR 36.406(f) and, 2010 ADA Standard 221, cover scoping requirements for accessible assembly areas. Standard 802 covers technical requirements for accessible assembly areas. The graphic above is representative of an accessible assembly area.

2010 ADA Standard 106.5 defines assembly areas as “A building or facility, or portion thereof, used for the purpose of entertainment, educational or civic gatherings, or similar purposes. For the purposes of these requirements, assembly areas include, but are not limited to, classrooms, lecture halls, courtrooms, public meeting rooms, public hearing rooms, legislative chambers, motion picture houses, auditoria, theaters, playhouses, dinner theaters, concert halls, centers for the performing arts, amphitheaters, arenas, stadiums, grandstands, or convention centers.”

A term used frequently when discussing accessible assembly areas is wheelchair space. Note that a wheelchair space is different than a clear space, as defined by the ADA. 2010 ADA Standard 106.5 defines a wheelchair space as “Space for a single wheelchair and its occupant.” Clear spaces are defined using width and length and are typically 30X48 inches in size. Wheelchair spaces are defined by width and depth also, but these measurements can vary. A single wheelchair space is defined as 36 inches wide, minimum. If two wheelchair spaces are placed side-by-side they can be 33 inches wide, minimum. See the graphic below.

The depth of a wheelchair space depends on how the space is entered. Where a wheelchair space can be entered from the front or rear, the wheelchair space shall be 48 inches deep minimum. Where a wheelchair space can be entered only from the side, the wheelchair space shall be 60 inches deep minimum. See the graphic below.

These distinctions are important to remember when discussing accessible assembly areas.

SCOPING REQUIREMENTS

Federal Regulations

Federal Regulations 28 CFR 35.151(g) and 28 CFR 36.406(f) both have the same requirements for assembly areas as follows: “Assembly areas subject to this section shall comply with the provisions of the 2010 Standards applicable to assembly areas, including, but not limited to, sections [Standards] 221 and 802. In addition, assembly areas shall ensure that:

(1) In stadiums, arenas, and grandstands, wheelchair spaces and companion seats are dispersed to all levels that include seating served by an accessible route;

(2) Assembly areas that are required to horizontally disperse wheelchair spaces and companion seats by section 221.2.3.1 of the 2010 Standards (p. 79) and have seating encircling, in whole or in part, a field of play or performance area shall disperse wheelchair spaces and companion seats around that field of play or performance area;

(3) Wheelchair spaces and companion seats are not located on (or obstructed by) temporary platforms or other movable structures, except that when an entire seating section is placed on temporary platforms or other movable structures in an area where fixed seating is not provided, in order to increase seating for an event, wheelchair spaces and companion seats may be placed in that section. When wheelchair spaces and companion seats are not required to accommodate persons eligible for those spaces and seats, individual, removable seats may be placed in those spaces and seats;

(4) Stadium-style movie theaters shall locate wheelchair spaces and companion seats on a riser or cross-aisle in the stadium section that satisfies at least one of the following criteria—

(i) It is located within the rear 60% of the seats provided in an auditorium; or

(ii) It is located within the area of an auditorium in which the vertical viewing angles (as measured to the top of the screen) are from the 40th to the 100th percentile of vertical viewing angles for all seats as ranked from the seats in the first row (1st percentile) to seats in the back row (100th percentile).”

Wheelchair Spaces

2010 ADA Standard 221.1, [Assembly Areas] General, states, “Assembly areas shall provide wheelchair spaces, companion seats, and designated aisle seats complying with [Standards] 221 and 802. In addition, lawn seating shall comply with [Standard] 221.5.”

2010 ADA Standard 221.2.1.1, General Seating, states, “Wheelchair spaces complying with [Standard] 802.1 shall be provided in accordance with Table 221.2.1.1 [Number of Wheelchair Spaces in Assembly Areas].” Table 221.2.1.1 is shown below.

Noteworthy in the chart above is that in any assembly area location with 4 or more seats, at least one ADA accessible wheelchair space is required. If a wheelchair space is required, an accessible route to the wheelchair space is also required.

Also, according to the Federal Regulations above, if temporary seating is installed where permanent seats already exist, the seating chart above should include all seats, temporary and fixed/permanent, when calculating the number of accessible wheelchair spaces and companion seating required. However, the accessible wheelchair spaces and companion seating should not be located in the temporary seating unless the temporary seating is installed at a venue where there is no permanent seating, then accessible wheelchair spaces and companion seating can [and should] be installed within the temporary seating.

2010 ADA Standard 221.2.1.2, [Assembly Areas] Luxury Boxes, Club Boxes, and Suites in Arenas, Stadiums and Grandstands, states, “In each luxury box, club box, and suite within arenas, stadiums, and grandstands, wheelchair spaces complying with [Standard] 802.1 shall be provided in accordance with Table 221.2.1.1.” The number of wheelchair spaces required in luxury boxes, club boxes, and suites within an arena, stadium, or grandstand is to be calculated box by box and suite by suite. The photo above is representative of luxury box seating.

2010 ADA Standard 221.2.1.3, Other Boxes, states, “In boxes other than those required to comply with [Standard] 221.2.1.2, the total number of wheelchair spaces required shall be determined in accordance with Table 221.2.1.1. Wheelchair spaces shall be located in not less than 20 percent of all boxes provided. Wheelchair spaces shall comply with [Standard] 802.1.”

The provision for seating in “other boxes” includes box seating provided in facilities such as performing arts auditoria where tiered boxes are designed for spatial and acoustical purposes. The number of wheelchair spaces required in boxes covered by [Standard] 221.2.1.3 is calculated based on the total number of seats provided in these other boxes. The resulting number of wheelchair spaces must be located in no fewer than 20% of the boxes covered by this section. For example, a concert hall has 20 boxes, each of which contains 10 seats, totaling 200 seats. In this example, 5 wheelchair spaces would be required, and they must be placed in at least 4 of the boxes. Additionally, because the wheelchair spaces must also meet the dispersion requirements of [Standard] 221.2.3, the boxes containing these wheelchair spaces cannot all be located in one area unless an exception to the dispersion requirements applies. The graphic below is representative of an assembly area with tiered box seating. Notice the wheelchair spaces in three locations.

2010 ADA Standard 221.2.2, [Assembly Area] Integration, states, “Wheelchair spaces shall be an integral part of the seating plan.” The graphic below is representative of an accessible wheelchair space and companion seat that is integral to the seating for individuals who are not disabled.

The requirement that wheelchair spaces be an “integral part of the seating plan” means that wheelchair spaces must be placed within the footprint of the seating area. Wheelchair spaces cannot be segregated from seating areas. For example, it would be unacceptable to place only the wheelchair spaces, or only the wheelchair spaces and their associated companion seats, outside the seating areas defined by risers in an assembly area. In the graphic below, a row of gymnasium seats has been recessed to create accessible space for wheelchairs so the disabled individuals can sit within the same seating areas as all other participants.

Lines of Sight and Dispersion

2010 ADA Standard 221.2.3, [Assembly Area] Lines of Sight and Dispersion, covers horizontal and vertical dispersion of wheelchair seating in an assembly area. Line of sight can be over people sitting or standing and, over heads or through heads over shoulders. Horizontal dispersion is left to right with respect to the performance area. Vertical dispersion is front to back in the seating spaces of the assembly area. The graphic below is representative of a sports assembly area where line of sight and horizontal and vertical dispersion would be considerations.

The concept of assembly area accessible seating dispersion is consistent with the overall intent of the ADA which is that individuals who use wheelchairs must be provided equal access so that their experience is substantially equivalent to that of other members of the audience. Thus, while individuals who use wheelchairs need not be provided with the best seats in the house, neither may they be relegated to the worst. There are some exceptions to horizontal and vertical dispersion in assembly areas with 300 or fewer seats. Please see the ADA Standards for details.

Companion Seats

2010 ADA Standard 221.3, [Assembly Areas] Companion Seats, states, “At least one companion seat complying with [Standard] 802.3 shall be provided for each wheelchair space required by [Standard] 221.2.1.” The graphic below is representative of a companion seat.

The intent of the companion seat is to align the shoulders of the companion with the disabled seating.

Designated Aisle Seats

2010 ADA Standard 221.4, [Assembly Areas] Designated Aisle Seats, states, “At least 5 percent of the total number of aisle seats provided shall comply with [Standard] 802.4 and shall be the aisle seats located closest to accessible routes.” There is an exception for team or player seating areas serving areas of sport activity which are not required to comply with [Standard] 221.4. The graphic below is representative of a designated aisle seat close to the accessible route.

When selecting which aisle seats will meet the requirements of [Standard] 802.4, those aisle seats which are closest to, not necessarily on, accessible routes must be selected first. For example, an assembly area has two aisles (A and B) serving seating areas with an accessible route connecting to the top and bottom of Aisle A only. The aisle seats chosen to meet [Standard] 802.4 must be those at the top and bottom of Aisle A, working toward the middle. Only when all seats on Aisle A would not meet the five percent minimum would seats on Aisle B be designated.

Seat and row designations in assembly areas are not required to comply with 2010 ADA Standard 216 for signs [216.1, ex. 1]. However, designated aisle seats are required to be identified with signage or a marker and Advisory 802.4.2, Designated Aisle Seats, Identification, states, “Seats with folding or retractable armrests are intended for use by individuals who have difficulty walking. Consider identifying such seats with signs that contrast (light-on-dark or dark-on-light) and that are also photo luminescent.” It is recommended that signs be used to mark these spaces and that the signs comply with the ADA Standards for signage. The photo on the left is representative of signage for a designated aisle seat in an assembly area. Notice how small the sign is and how low to the floor. This sign would be difficult to see from a distance when a disabled individual is searching for accessible seating.

Lawn Seating

2010 ADA Standard 221.5, [Assembly Areas] Lawn Seating, states, “Lawn seating areas and exterior overflow seating areas, where fixed seats are not provided, shall connect to an accessible route.” In other words, the accessible route only has to connect to the area, not specific accessible lawn seating itself. The graphic on the right is representative of lawn seating at a ball field.

Miscellaneous Requirements

Other installation requirements to consider for accessible assembly areas include assistive listening systems (ALS), an accessible route within the assembly area, and press boxes.

The assembly area may require an assistive listening system if audible communication is integral to the use of the space. In other words, if a microphone and speakers are used to communicate to the seating area from the performance area, ALS should be available.

The accessible route within an assembly area sometimes includes ramped routes to reach the seat rows. Requirements for these routes may include handrails. In assembly areas, handrails are not required on both sides of aisle ramps where a handrail is provided at either side or within the aisle width [505.2]. Ramp handrail extensions are not required for ramp handrails in assembly area aisles serving seating where the handrails are discontinuous to provide access to seating and to permit crossovers within aisles. The graphic below is representative.

An accessible route is not required in an assembly area to serve fixed seating where wheelchair spaces required to be on an accessible route are not provided [206.2.4, ex. 2]. Aisle stairs in assembly areas are not required to comply with the ADA Standards in 504.4 [210.1, ex. 3].

Finally, there should be a direct connection from the seating area (bowl) onto the performance area (stage). 2010 ADA Standard 206.2.6, Performance Areas, states, “Where a circulation path directly connects a performance area to an assembly seating area, an accessible route shall directly connect the assembly seating area with the performance area. An accessible route shall be provided from performance areas to ancillary areas or facilities used by performers unless exempted by 206.2.3 Exceptions 1 through 7.” There should not be a requirement to reach the performance area by an alternate route (different than the route used by non-disabled).

Press Boxes

Press boxes greater than 500 square feet in size and located in an assembly area should be on an assessible route. An accessible route is not required to press boxes in bleachers that have points of entry at only one level provided that the aggregate area of all press boxes is 500 square feet (46 m2) maximum. An accessible route shall not be required to free-standing press boxes that are elevated above grade 12 feet (3660 mm) minimum provided that the aggregate area of all press boxes is 500 square feet (46 m2) maximum [2010 ADA Standard 206.2.7]. The photo below is a press box more than 12 feet above grade, freestanding, with only one entry, and a size of less than 500 SF.

SUMMARY

Accessible assembly areas located at Title II and Title III facilities are required to comply with the ADA. Requirements include accessible routes and spaces for disabled individuals including wheelchair spaces, companion seating, and designated aisle seats. Accessible wheelchair spaces should be dispersed throughout the seating area(s) where there are 4 or more seats available, including all locations such as box and mezzanine seating. For an article about the technical requirements for accessible areas please see Technical Requirements.

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If you observe a facility or assembly area that are not ADA compliant and you would like to know how to proceed, please see the link at What To Do When A Building Is Not ADA Compliant or Accessible.

ADA Inspections Nationwide, LLC, offers ADA/ABA/FHA accessibility compliance inspections for buildings and facilities, as applicable to the different laws, and expert witness services with respect to ADA/ABA/FHA laws for building owners, tenants and managers. Also, ADAIN offers consulting for home modifications as a CAPS consultant for people wishing to age in place in their homes. For a complete list of services please see ADAIN Services.

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