Accessible Stadium Style Movie Theaters as Defined by the ADA
Retail Site Including Shopping Area, Restaurant, and Movie Theater
Accessible stadium style movie theaters located at Title III facilities are required to comply with the Americans with Disabilities Act (ADA). Movie theaters are also sometimes referred to as motion picture houses. Movie theaters and motion picture houses are also assembly areas and, as such must comply with the ADA Standards for assembly areas. This includes from the site arrival points all the way into and within the individual movie theater auditorium(s), and almost everything in between. Movie theaters can be part of a larger facility or can be a separate facility specifically for the movie theater. The graphic above is representative of a retail site including a shopping area, restaurant, and movie theater.
This article will discuss the ADA scoping and technical requirements for accessible stadium style movie theaters available to the public in Title III facilities. Federal regulation 28 CFR 36.406(f) and 2010 ADA Standard 221 cover scoping requirements for assembly areas, including movie theaters. Standard 802 covers the technical requirements.
A representative list of elements and issues at a movie theater site that will be required to meet the ADA requirements include:
site arrival points
vehicle parking
exterior routes
exterior and interior doors
interior route
toilet rooms
ticket counters
queue lines
arcades
food service lines
ramps
stairs
seating in the theater auditorium including wheelchair spaces, companion seats, and designated aisle seats
line of sight in the theater from accessible seating to the performance area [movie screen]
assistive listening systems
closed captioning
ATMs
telephone installations
protruding objects
operable parts
Some of the key components in the list above will be discussed below with respect to movie theater auditoriums.
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.”
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.
2010 ADA Standard 802.1.4, [Wheelchair Space] Approach, states, “Wheelchair spaces shall adjoin accessible routes. Accessible routes shall not overlap wheelchair spaces.” Because accessible routes serving wheelchair spaces are not permitted to overlap the clear floor space at wheelchair spaces, access to any wheelchair space cannot be through another wheelchair space. So if you have two wheelchair spaces side-by-side, you cannot access the 2nd space by going through the 1st space. The graphic below is representative of a wheelchair space not overlapping an accessible route in an assembly area. Note that the wheelchair space is allowed to overlap the aisle accessway.
Wheelchair Space Not Overlapping Accessible Aisle
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.
Integral Accessible Wheelchair Space and Companion Seat
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.
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.
Accessible Wheelchair Space and Companion Seat
The intent of the companion seat is to align the shoulders of the companion with the disabled seating.
Designated Aisle Seat Close to Accessible Route
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.” The graphic on the right 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.
Assembly Area Accessible Seating with Sign
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.
Line of Sight
Federal Regulation 28 CFR 36.406(f) has requirements specifically for movie theaters in Title III facilities as follows: “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).” These requirements will impact the dispersion requirements below.
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 [movie screen]. Vertical dispersion is front to back in the seating spaces of the assembly area. At movie theaters it is expected that people will remain seated through most of the presentation. Therefore, line-of-sight requirements over the heads for seated patrons in seats that are aligned would be applicable.
2010 ADA Standard 802.2.1.1, [Seated Spectators] Lines of Sight Over Heads, states, “Where spectators [patrons] are provided lines of sight over the heads of spectators seated in the first row in front of their seats, spectators seated in wheelchair spaces shall be afforded lines of sight over the heads of seated spectators in the first row in front of wheelchair spaces.” In this installation the seats are aligned with the seats in the first row in front of the disabled seat. The following graphic is representative.
Movie Theater Line of Sight Over Heads of Seated Spectators
Interior Routes in the Movie Theater
The accessible route within a stadium style movie theater 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.
Assembly Seating with Modified Handrails on the Ramped Route
Aisle stairs in assembly areas are not required to comply with the ADA Standards in 504.4 [210.1, ex. 3].
Assistive Listening System [ALS] , Closed Captioning and Audio Description
A movie theater uses visual and audible communication that is integral to the use of the space. Because the ADA’s effective communication requirements apply to all public accommodations (including movie theaters) and protect the rights of persons with disabilities in every jurisdiction in the United States, all movie theaters that offer digital movies must ensure that they meet those requirements by providing closed movie captioning, audio description, and an assistive listening system upon request to all patrons who are deaf or hard of hearing, or blind or have low vision, unless doing so results in an undue burden or a fundamental alteration. See 2010 ADA Standard 219 and 216.10 for ALS. See DOJ Press Release 16-1366 for closed captioning and audio description ruling.
SUMMARY
Accessible stadium style movie theaters located at Title III facilities are required to comply with the ADA. A facility housing a movie theater must comply with the ADA Standards throughout the entire facility. This includes from the site arrival points all the way into and within the movie theater space(s), and almost everything in between such as routes and toilet rooms. Within the individual theater auditoriums wheelchair spaces, companion seating, and designated aisle seats are some of the key components that need to comply.
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