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224 and 806 Transient Lodging Guest Rooms

Scoping. The minimum number of guest rooms required to be accessible in transient lodging facilities is covered by section 224 of the 2010 Standards. Scoping requirements for guest rooms with mobility features and guest rooms with communication features are addressed at section 224.2 and section 224.4, respectively. Under the 1991 Standards all newly constructed guest rooms with mobility features must provide communication features. Under the 2010 Standards, in section 224.5, at least one guest room with mobility features must also provide communication features. Additionally, not more than ten percent (10%) of the guest rooms required to provide mobility features and also equipped with communication features can be used to satisfy the minimum number of guest rooms required to provide communication features.

Some commenters opposed requirements for guest rooms accessible to individuals with mobility disabilities stating that statistics provided by the industry demonstrate that all types of accessible guest rooms are unused. They further claimed that the requirements of the 2010 Standards are too burdensome to meet in new construction, and that the requirements will result in a loss of living space in places of transient lodging. Other commenters urged the Department to increase the number of guest rooms required to be accessible. The number of guest rooms accessible to individuals with mobility disabilities and the number accessible to persons who are deaf or who are hard of hearing in the 2010 Standards are consistent with the 1991 Standards and with the IBC. The Department continues to receive complaints about the lack of accessible guest rooms throughout the country. Accessible guest rooms are used not only by individuals using mobility devices such as wheelchairs and scooters, but also by individuals with other mobility disabilities including persons who use walkers, crutches, or canes.

Data provided by the Disability Statistics Center at the University of California, San Francisco demonstrated that the number of adults who use wheelchairs has been increasing at the rate of six percent (6%) per year from 1969 to 1999; and by 2010, it was projected that two percent (2%) of the adult population would use wheelchairs. In addition to persons who use wheelchairs, three percent (3%) of adults used crutches, canes, walkers, and other mobility devices in 1999; and the number was projected to increase to four percent (4%) by 2010. Thus, in 2010, up to six percent (6%) of the population may need accessible guest rooms.

Dispersion. The 2010 Standards, in section 224.5, set scoping requirements for dispersion in facilities covered by the transient lodging provisions. This section covers guest rooms with mobility features and guest rooms with communication features and applies in new construction and alterations. The primary requirement is to provide choices of types of guest rooms, number of beds, and other amenities comparable to the choices provided to other guests. An advisory in section 224.5 provides guidance that "factors to be considered in providing an equivalent range of options may include, but are not limited to, room size, bed size, cost, view, bathroom fixtures such as hot tubs and spas, smoking and nonsmoking, and the number of rooms provided."

Commenters asked the Department to clarify what is meant by various terms used in section 224.5 such as "classes," "types," "options," and "amenities." Other commenters asked the Department to clarify and simplify the dispersion requirements set forth in section 224.5 of the 2010 Standards, in particular the scope of the term "amenities." One commenter expressed concern that views, if considered an amenity, would further complicate room categories and force owners and operators to make an educated guess. Other commenters stated that views should only be a dispersion criteria if view is a factor for pricing room rates.

These terms are not to be considered terms of art, but should be used as in their normal course. For example, "class" is defined by Webster´s Dictionary as "a division by quality." "Type" is defined as "a group of * * * things that share common traits or characteristics distinguishing them as an identifiable group or class." Accordingly, these terms are not intended to convey different concepts, but are used as synonyms. In the 2010 Standards, section 224.5 and its advisory require dispersion in such a varied range of hotels and lodging facilities that the Department believes that the chosen terms are appropriate to convey what is intended. Dispersion required by this section is not "one size fits all" and it is imperative that each covered entity consider its individual circumstance as it applies this requirement. For example, a facility would consider view as an amenity if some rooms faced mountains, a beach, a lake, or other scenery that was considered to be a premium. A facility where view was not marketed or requested by guests would not factor the view as an amenity for purposes of meeting the dispersion requirement.

Section 224.5 of the 2010 Standards requires that guest rooms with mobility features and guest rooms with communication features "shall be dispersed among the various classes of guest rooms, and shall provide choices of types of guest rooms, number of beds, and other amenities comparable to the choices provided to other guests. When the minimum number of guest rooms required is not sufficient to allow for complete dispersion, guest rooms shall be dispersed in the following priority: guest room type, number of beds and amenities."

This general dispersion requirement is intended to effectuate Congress´ directive that a percentage of each class of hotel rooms is to be fully accessible to persons with disabilities. See H.R. Rep. No. 101-485 (II) at 391. Accordingly, the promise of the ADA in this instance is that persons with disabilities will have an equal opportunity to benefit from the various options available to hotel guests without disabilities, from single occupancy guest rooms with limited features (and accompanying limited price tags) to luxury suites with lavish features and choices. The inclusion of section 224.5 of the 2010 Standards is not new. Substantially similar language is contained in section 9.1.4 of the 1991 Standards.

Commenters raised concerns that the factors included in the advisory to section 224.5 of the 2010 Standards have been expanded. The advisory provides: "[f]actors to be considered in providing an equivalent range of options may include, but are not limited to, room size, bed size, cost, view, bathroom fixtures such as hot tubs and spas, smoking and nonsmoking, and the number of rooms provided."

As previously discussed, the advisory materials provided in the 2010 Standards are meant to be illustrative and do not set out specific requirements. In this particular instance, the advisory materials for section 224.5 set out some of the common types of amenities found at transient lodging facilities, and include common sense concepts such as view, bathroom fixtures, and smoking status. The intention of these factors is to indicate to the hospitality industry the sorts of considerations that the Department, in its enforcement efforts since the enactment of the ADA, has considered as amenities that should be made available to persons with disabilities, just as they are made available to guests without disabilities.

Commenters offered several suggestions for addressing dispersion. One option included the flexibility to use an equivalent facilitation option similar to that provided in section 9.1.4(2) of the 1991 Standards.

The 2010 Standards eliminated all specific references to equivalent facilitation. Since Congress made it clear that each class of hotel room is to be available to individuals with disabilities, the Department declines to adopt such a specific limitation in favor of the specific requirement for new construction and alterations found in section 224.5 of the 2010 Standards.

In considering the comments of the hospitality industry from the ANPRM and the Department´s enforcement efforts in this area, the Department sought comment in the NPRM on whether the dispersion requirements should be applied proportionally, or whether the requirements of section 224.5 of the 2010 Standards would be complied with if access to at least one guest room of each type were to be provided.

One commenter expressed concern about requiring different guest room types to be proportionally represented in the accessible guest room pool as opposed to just having each type represented. Some commenters also expressed concern about accessible guest rooms created in pre-1993 facilities and they requested that such accessible guest rooms be safe harbored just as they are safe harbored under the 1991 Standards. In addition, one commenter requested that the proposed dispersion requirements in section 224.5 of the 2010 Standards not be applied to pre-1993 facilities even when they are altered. Some commenters also offered a suggestion for limitations to the dispersion requirements as an alternative to safe harboring pre-1993 facilities. The suggestion included: (1) Guest rooms´ interior or exterior footprints may remain unchanged in order to meet the dispersion requirements; (2) Dispersion should only be required among the types of rooms affected by an alteration; and (3) Subject to (1) and (2) above and technical feasibility, a facility would need to provide only one guest room in each guest room type such as single, double and suites. One commenter requested an exception to the dispersion criteria that applies to both existing and new multi-story timeshare facilities. This requested exception waives dispersion based on views to the extent that up to eight units may be vertically stacked in a single location.

Section 224.1.1 of the 2010 Standards sets scoping requirements for alterations to transient lodging guest rooms. The advisory to section 224.1.1 further explains that compliance with 224.5 is more likely to be achieved if all of the accessible guest rooms are not provided in the same area of the facility, when accessible guest rooms are added as a result of subsequent alterations.

Some commenters requested a specific exemption for small hotels of 300 or fewer guest rooms from dispersion regarding smoking rooms. The ADA requires that individuals with disabilities be provided with the same range of options as persons without disabilities, and, therefore, the Department declines to add such an exemption. It is noted, however, that the existence of this language in the advisory does not require a place of transient lodging that does not offer smoking guest rooms at its facility to do so only for individuals with disabilities.

Guest Rooms with Mobility Features. Scoping provisions for guest rooms with mobility features are provided in section 224.2 of the 2010 Standards. Scoping requirements for alterations are included in 224.1.1. These scoping requirements in the 2010 Standards are consistent with the 1991 Standards.

One commenter expressed opposition to the new scoping provisions for altered guest rooms, which, according to the commenter, require greater numbers of accessible guest rooms with mobility features.

Section 224.1.1 of the 2010 Standards provides scoping requirements for alterations to guest rooms in existing facilities. Section 224.1.1 modifies the scoping requirements for new construction in section 224 by limiting the application of section 224 requirements only to those guest rooms being altered or added until the number of such accessible guest rooms complies with the minimum number required for new construction in section 224.2 of the 2010 Standards. The minimum required number of accessible guest rooms is based on the total number of guest rooms altered or added instead of the total number of guest rooms provided. These requirements are consistent with the requirements in the 1991 Standards. Language in the 2010 Standards clarifies the provision of section 104.2 of the 2010 Standards which requires rounding up values to the next whole number for calculations of percentages in scoping.

Guest Rooms with Communication Features. The revisions at section 224.4 of the 2010 Standards effect no substantive change from the 1991 Standards with respect to the number of guest rooms required to provide communication features. The scoping requirement is consolidated into a single table, instead of appearing in three sections as in the 1991 Standards. The revised provisions also limit the overlap between guest rooms required to provide mobility features and guest rooms required to provide communication features. Section 224.5 of the 2010 Standards requires that at least one guest room providing mobility features must also provide communications features. At least one, but not more than ten percent (10%), of the guest rooms required to provide mobility features can also satisfy the minimum number of guest rooms required to provide communication features.

Commenters suggested that the requirements for scoping and dispersion of guest rooms for persons with mobility impairments and guest rooms with communication features are too complex for the industry to effectively implement.

The Department believes the requirements for guest rooms with communications features in the 2010 Standards clarify the requirements necessary to provide equal opportunity for travelers with disabilities. Additional technical assistance will be made available to address questions before the rule goes into effect.

Visible Alarms in Guest Rooms with Communication Features. The 1991 Standards at sections 9.3.1 and 4.28.4 require transient lodging guest rooms with communication features to provide either permanently installed visible alarms that are connected to the building fire alarm system or portable visible alarms that are connected to a standard 110-volt electrical outlet and are both activated by the building fire alarm system and provide a visible alarm when the single station smoke detector is activated. Section 215.4 of the 2010 Standards no longer includes the portable visible alarm option and instead requires that transient lodging guest rooms with communication features be equipped with a fire alarm system which includes permanently installed audible and visible alarms in accordance with NFPA 72 National Fire Alarm Code (1999 or 2002 edition). Such guest rooms with communication features are also required by section 806.3.2 of the 2010 Standards to be equipped with visible notification devices that alert room occupants of incoming telephone calls and a door knock or bell.

The 2010 Standards add a new exception for alterations to existing facilities that exempts existing fire alarm systems from providing visible alarms, unless the fire alarm system itself is upgraded or replaced, or a new fire alarm system is installed. Transient lodging facilities that alter guest rooms are not required to provide permanently installed visible alarms complying with the NFPA 72 if the existing fire alarm system has not been upgraded or replaced, or a new fire alarm system has not been installed.

Commenters representing small providers of transient lodging raised concerns about the proposed changes to prohibit the use of portable visible alarms used in transient lodging guest rooms. These commenters recommended retaining requirements that allow the use of portable visible alarms.

Persons who are deaf or hard of hearing have reported that portable visible alarms used in transient lodging guest rooms are deficient because the alarms are not activated by the building fire alarm system, and the alarms do not work when the building power source goes out in emergencies. The 2010 Standards are consistent with the model building, fire, and life safety codes as applied to newly constructed transient lodging facilities. One commenter sought confirmation of its understanding of visible alarm requirements from the Department. This commenter interpreted the exception to section 215.1 of the 2010 Standards and the Department´s commentary to the NPRM to mean that if a transient lodging facility does not have permanently installed visible alarms in its communication accessible guest rooms, it will not be required to provide such alarms until such time that its fire alarm system is upgraded or replaced, or a new fire alarm system is installed. In addition, this commenter also understood that, if a hotel already has permanently installed visible alarms in all of its mobility accessible guest rooms, it would not have to relocate such visible alarms and other communication features in those rooms to other guest rooms to comply with the ten percent (10%) overlap requirement until the alarm system is upgraded or replaced.

This commenter´s interpretation and understanding are consistent with the Department´s position in this matter. Section 215.4 of the 2010 Standards requires that guest rooms required to have communication features be equipped with a fire alarm system complying with section 702. Communication accessible guest rooms are required to have all of the communication features described in section 806.3 of the 2010 Standards including a fire alarm system which provides both audible and visible alarms. The exception to section 215.1 of the 2010 Standards, which applies only to fire alarm requirements for guest rooms with communication features in existing facilities, exempts the visible alarm requirement until such time as the existing fire alarm system is upgraded or replaced, or a new fire alarm system is installed. If guest rooms in existing facilities are altered and they are required by section 224 of the 2010 Standards to have communication features, such guest rooms are required by section 806.3 to have all other communication features including notification devices.

Vanity Counter Space. Section 806.2.4.1 of the 2010 Standards requires that if vanity countertop space is provided in inaccessible transient lodging guest bathrooms, comparable vanity space must be provided in accessible transient lodging guest bathrooms.

A commenter questioned whether in existing facilities vanity countertop space may be provided through the addition of a shelf. Another commenter found the term "comparable" vague and expressed concern about confusion the new requirement would cause. This commenter suggested that the phrase "equal area in square inches" be used instead of comparable vanity space.

In some circumstances, the addition of a shelf in an existing facility may be a reasonable way to provide a space for travelers with disabilities to use their toiletries and other personal items. However, this is a determination that must be made on a case-by-case basis. Comparable vanity countertop space need not be one continuous surface and need not be exactly the same size as the countertops in comparable guest bathrooms. For example, accessible shelving within reach of the lavatory could be stacked to provide usable surfaces for toiletries and other personal items.

Shower and Sauna Doors in Transient Lodging Facilities. Section 9.4 of the 1991 Standards and section 206.5.3 of the 2010 Standards both require passage doors in transient lodging guest rooms that do not provide mobility features to provide at least 32 inches of clear width. Congress directed this requirement to be included so that individuals with disabilities could visit guests in other rooms. See H. Rept. 101-485, pt. 2, at 118 (1990); S. Rept. 101-116, at 70 (1989). Section 224.1.2 of the 2010 Standards adds a new exception to clarify that shower and sauna doors in such inaccessible guest rooms are exempt from the requirement for passage doors to provide at least 32 inches of clear width. Two commenters requested that saunas and steam rooms in existing facilities be exempt from the section 224.1.2 requirement and that the requirement be made applicable to new construction only.

The exemption to the section 224.1.2 requirement for a 32-inch wide clearance at doors to shower and saunas applies only to those showers and saunas in guest rooms which are not required to have mobility features. Showers and saunas in other locations, including those in common use areas and guest rooms with mobility features, are required to comply with the 32-inch clear width standard as well as other applicable accessibility standards. Saunas come in a variety of types: portable, pre-built, pre-cut, and custom-made. All saunas except for custom-made saunas are made to manufacturers´ standard dimensions. The Department is aware that creating the required 32-inch clearance at existing narrower doorways may not always be technically feasible. However, the Department believes that owners and operators will have an opportunity to provide the required doorway clearance, unless doing so is technically infeasible, when an alteration to an existing sauna is undertaken. Therefore, the Department has retained these requirements.

Platform Lifts in Transient Lodging Guest Rooms and Dwelling Units. The 1991 Standards, at section 4.1.3(5), exception 4, and the 2010 Standards, at sections 206.7 and 206.7.6, both limit the locations where platform lifts are permitted to be used as part of an accessible route. The 2010 Standards add a new scoping requirement that permits platform lifts to be used to connect levels within transient lodging guest rooms and dwelling units with mobility features.

806 Transient Lodging Guest Rooms

In the NPRM, the Department included floor plans showing examples of accessible guest rooms and bathrooms designs with mobility features to illustrate how compliance with the 2010 Standards could be accomplished with little or no additional space compared to designs that comply with the 1991 Standards.

Commenters noted that the Department´s plans showing accessible transient lodging guest rooms compliant with the 2010 Standards were not common in the transient lodging industry and also noted that the plans omitted doors at sleeping room closets.

The Department agrees that the configuration of the accessible bathrooms is somewhat different from past designs used by the industry, but this was done to meet the requirements of the 2010 Standards. The plans were provided to show that, with some redesign, the 2010 Standards do not normally increase the square footage of an accessible sleeping room or bathroom with mobility features in new construction. The Department has also modified several accessible guest room plans to show that doors can be installed on closets and comply with the 2010 Standards.

A commenter stated that the Department´s drawings suggest that the fan coil units for heat and air conditioning are overhead, while the typical sleeping room usually has a vertical unit, or a packaged terminal air conditioning unit within the room. The Department´s drawings are sample plans, showing the layout of the space, relationship of elements to each other, and required clear floor and turning spaces. It was not the intent of the Department to provide precise locations for all elements, including heating and air conditioning units.

Commenters noted that in guest rooms with two beds, each bed was positioned close to a wall, reducing access on one side. Another commenter stated that additional housekeeping time is needed to clean the room when beds are placed closer to walls. The 2010 Standards require that, when two beds are provided, there must be at least 36 inches of clear space between the beds. The plans provided in the NPRM showed two bed arrangements with adequate clear width complying with the 1991 Standards and the 2010 Standards. Additional space can be provided on the other side of the beds to facilitate housekeeping as long as the clear floor space between beds is at least 36 inches wide.

Commenters stated that chases in sleeping room bathrooms that route plumbing and other utilities can present challenges when modifying existing facilities. In multi-story facilities, relocating or re-routing these elements may not be possible, limiting options for providing access. The Department recognizes that relocating mechanical chases in multi-story facilities may be difficult or impossible to accomplish. While these issues do not exist in new facilities, altered existing facilities must comply with the 2010 Standards to the extent that it is technically feasible to do so. When an alteration cannot fully comply because it is technically infeasible to do so, the alteration must still be designed to comply to the greatest extent feasible.

Commenters noted that on some of the Department´s plans where a vanity is located adjacent to a bathtub, the vanity may require more maintenance due to exposure to water. The Department agrees that it would be advisable that items placed next to a bathtub or shower be made of materials that are not susceptible to water damage.

Transient Lodging Guest Room Floor Plans and Related Text

The Department has included the following floor plans showing application of the requirements of the 2010 Standards without significant loss of guest room living space in transient lodging compared to the 1991 Standards.


Plan 1A: 13-Foot Wide Accessible Guest Room

This drawing shows an accessible 13-foot wide guest room with features that comply with the 2010 Standards. Features include a standard bathtub with a seat, comparable vanity, clothes closet with swinging doors, and door connecting to adjacent guest room. Furnishings include a king bed and additional seating.
 
This drawing shows an accessible 13-foot wide guest room with features that comply with the 2010 Standards. Features include a standard bathtub with a seat, comparable vanity, clothes closet with swinging doors, and door connecting to adjacent guest room. Furnishings include a king bed and additional seating. 
 

The following accessible features are provided in the bathroom:
• Comparable vanity counter top space (section 806);
•Bathtub with a lavatory at the control end (section 607.2);
•Removable bathtub seat (section 607.3);
•Clearance in front of the bathtub extends its full length and is 30 inches wide min. (section 607.2);
•Recessed bathtub location permits shorter rear grab bar at water closet (section 604.5.2);
•Circular turning space in room (section 603.2.1);
•Required clear floor spaces at fixtures and turning space overlap (section 603.2.2);
•Turning space includes knee and toe clearance at lavatory (section 304.3);
•Water closet clearance is 60 inches at back wall and 56 inches deep (section 604.3);
•Centerline of the water closet at 16-18 inches from side wall (section 604.2); and
•No other fixtures or obstructions located within required water closet clearance (section 604.3).

The following accessible features are provided in the living area:
•T-shaped turning space (section 304.3.2);
•Accessible route (section 402);
•Clear floor space on both sides of the bed (section 806.2.3);
•Maneuvering clearances at all doors (section 404.2);Accessible operable window (section 309); and
•Accessible controls for the heat and air conditioning (section 309).
 


Plan 1B: 13-Foot Wide Accessible Guest Room

This drawing shows an accessible 13-foot wide guest room with features that comply with the 2010 Standards. Features include a standard bathtub with a seat, comparable vanity, clothes closet with swinging doors, and door connecting to adjacent guest room. Furnishings include two beds.
 
This drawing shows an accessible 13-foot wide guest room with features that comply with the 2010 Standards. Features include a standard bathtub with a seat, comparable vanity, clothes closet with swinging doors, and door connecting to adjacent guest room. Furnishings include two beds. 
The following accessible features are provided in the bathroom:
•Comparable vanity counter top space (section 806);
•Bathtub with a lavatory at the control end (section 607.2);
•Removable bathtub seat (section 607.3);
•Clearance in front of the bathtub extends its full length and is 30 inches wide min. (section 607.2);
•Recessed bathtub location permits shorter rear grab bar at water closet (section 604.5.2);
•Circular turning space in room (section 603.2.1);
•Required clear floor spaces at fixtures and turning space overlap (section 603.2.2);
•Turning space includes knee and toe clearance at lavatory (section 304.3);
•Water closet clearance is 60 inches at back wall and 56 inches deep (section 604.3);
•Centerline of the water closet at 16-18 inches from side wall (section 604.2); and
•No other fixtures or obstructions located within required water closet clearance (section 604.3);

The following accessible features are provided in the living area:
•T-shaped turning space (section 304.3.2);
• Accessible route (section 402);
•Clear floor space between beds (section 806.2.3);
•Maneuvering clearances at all doors (section 404.2);
•Accessible operable window (section 309); and
• Accessible controls for the heat and air conditioning (section 309).
 


Plan 2A: 13-Foot Wide Accessible Guest Room

This drawing shows an accessible 13-foot wide guest room with features that comply with the 2010 Standards. Features include a standard roll-in shower with a seat, comparable vanity, wardrobe, and door connecting to adjacent guest room. Furnishings include a king bed and additional seating.
 
This drawing shows an accessible 13-foot wide guest room with features that comply with the 2010 Standards. Features include a standard roll-in shower with a seat, comparable vanity, wardrobe, and door connecting to adjacent guest room. Furnishings include a king bed and additional seating. 
The following accessible features are provided in the bathroom:
•Comparable vanity counter top space (section 806);
• Standard roll-in type shower with folding seat (section 608.2.2);
•Recessed roll-in shower location permits shorter rear grab bar at water closet (section 604.5.2);
•Clear floor space adjacent to shower min. 30 inches wide by 60 inches long (section 608.2.2);
•Circular turning space in room (section 603.2.1);
• Required clear floor spaces at fixtures and turning space overlap (section 603.2.2);
•Turning space includes knee and toe clearance at lavatory (section 304.3);
•Water closet clearance is 60 inches at back wall and 56 inches deep (section 604.3);
•Centerline of the water closet at 16-18 inches from side wall (section 604.2); and
• No other fixtures or obstructions located within required water closet clearance (section 604.3).

The following accessible features are provided in the living area:
•T-shaped turning space (section 304.3.2);
•Accessible route (section 402);
•Clear floor space on both sides of the bed (section 806.2.3);
•Maneuvering clearances at all doors (section 404.2);
•Accessible operable window (section 309); and
•Accessible controls for the heat and air conditioning (section 309).

 
 


Plan 2B: 13-Foot Wide Accessible Guest Room

This drawing shows an accessible 13-foot wide guest room with features that comply with the 2010 Standards. Features include an alternate roll-in shower with a seat, comparable vanity, wardrobe, and door connecting to adjacent guest room. Furnishings include two beds.
 
This drawing shows an accessible 13-foot wide guest room with features that comply with the 2010 Standards. Features include an alternate roll-in shower with a seat, comparable vanity, wardrobe, and door connecting to adjacent guest room. Furnishings include two beds.
The following accessible features are provided in the bathroom:
•Comparable vanity counter top space (section 806);
•Alternate roll-in type shower with folding seat is 36 inches deep and 60 inches wide (section 608.2.3);
•Alternate roll-in shower has a 36-inch wide entry at one end of the long side of the compartment (section 608.2.3);
•Recessed alternate roll-in shower location permits shorter rear grab bar at water closet (section 604.5.2);
•Circular turning space in room (section 603.2.1);
•Required clear floor spaces at fixtures and turning space overlap (section 603.2.2);
•Turning space includes knee and toe clearance at lavatory (section 304.3);
•Water closet clearance is 60 inches at back wall and 56 inches deep (section 604.3);
•Centerline of the water closet at 16-18 inches from side wall (section 604.2); and
• No other fixtures or obstructions located within required water closet clearance (section 604.3)

The following accessible features are provided in the living area:
•T-shaped turning space (section 304.3.2);
•Accessible route (section 402);
•Clear floor space between beds (section 806.2.3);
•Maneuvering clearances at all doors (section 404.2);
•Accessible operable window (section 309); and
•Accessible controls for the heat and air conditioning (section 309).
 


Plan 3A: 12-Foot Wide Accessible Guest Room

This drawing shows an accessible 12-foot wide guest room with features that comply with the 2010 Standards. Features include a bathtub with a seat, comparable vanity, open clothes closet, and door connecting to adjacent guest room. Furnishings include a king bed and additional seating.
 
This drawing shows an accessible 12-foot wide guest room with features that comply with the 2010 Standards. Features include a bathtub with a seat, comparable vanity, open clothes closet, and door connecting to adjacent guest room. Furnishings include a king bed and additional seating. 
The following accessible features are provided in the
 bathroom:
• Comparable vanity counter top space (section 806);
•Bathtub (section 607.2);
•Removable bathtub seat (section 607.3);
•Clearance in front of the bathtub extends its full length and is 30 inches wide min. (section 607.2);
•Recessed lavatory with vanity countertop permits shorter rear grab bar at water closet (section 604.5.2);
•Circular turning space in room (section 603.2.1);
•Required clear floor spaces at fixtures and turning space overlap (section 603.2.2);
•Turning space includes knee and toe clearance at lavatory (section 304.3);
•Water closet clearance is 60 inches at back wall and 56 inches deep (section 604.3);
•Centerline of the water closet at 16-18 inches from side wall (section 604.2); and
•No other fixtures or obstructions located within required water closet clearance (section 604.3).

The following accessible features are provided in the living area:
•T-shaped turning space (section 304.3.2);
•Accessible route (section 402);
•Clear floor space on both sides of the bed (section 806.2.3);
•Maneuvering clearances at all doors (section 404.2);
•Accessible operable window (section 309); and
•Accessible controls for the heat and air conditioning (section 309).
 


Plan 3B: 12-Foot Wide Accessible Guest Room

This drawing shows an accessible 12-foot wide guest room with features that comply with the 2010 Standards. Features include a standard roll-in shower with a seat, comparable vanity, wardrobe, and door connecting to adjacent guest room. Furnishings include two beds.
 
This drawing shows an accessible 12-foot wide guest room with features that comply with the 2010 Standards. Features include a standard roll-in shower with a seat, comparable vanity, wardrobe, and door connecting to adjacent guest room. Furnishings include two beds. 
The following accessible features are provided in the bathroom:
•The following accessible features are provided in the bathroom:
•Comparable vanity counter top space (section 806);
•Standard roll-in type shower with folding seat (section 608.2.2);
•Recessed lavatory with vanity counter top permits shorter rear grab bar at water closet (section 604.5.2);
•Clear floor space adjacent to shower min. 30 inches wide by 60 inches long (section 608.2.2);
•Circular turning space in room (section 603.2.1);
•Required clear floor spaces at fixtures and turning space overlap (section 603.2.2);
•Turning space includes knee and toe clearance at lavatory (section 304.3);
•Water closet clearance is 60 inches at back wall and 56 inches deep (section 604.3);
•Centerline of the water closet at 16-18 inches from side wall (section 604.2); and

No other fixtures or obstructions located within required water closet clearance (section 604.3). The following accessible features are provided in the living area:
•T-shaped turning space (section 304.3.2);
•Accessible route (section 402);
•Clear floor space between beds (section 806.2.3);
•Maneuvering clearances at all doors (section 404.2);
•Accessible operable window (section 309); and
•Accessible controls for the heat and air conditioning (section 309).
 


Plan 4A: 13-Foot Wide Accessible Guest Room

This drawing shows an accessible 13-foot wide guest room with features that comply with the 2010 Standards. Features include a standard roll-in shower with a seat, comparable vanity, clothes closet with swinging doors, and door connecting to adjacent guest room. Furnishings include a king bed and additional seating.
 
This drawing shows an accessible 13-foot wide guest room with features that comply with the 2010 Standards. Features include a standard roll-in shower with a seat, comparable vanity, clothes closet with swinging doors, and door connecting to adjacent guest room. Furnishings include a king bed and additional seating.  
The following accessible features are provided in the bathroom:
•Comparable vanity counter top space (section 806);
•Standard roll-in type shower with folding seat (section 608.2.2);
•Clear floor space adjacent to shower min. 30 inches wide by 60 inches long (section 608.2.2);
•Recessed roll-in shower location permits shorter rear grab bar at water closet (section 604.5.2);
•Circular turning space in room (section 603.2.1);
•Required clear floor spaces at fixtures and turning space overlap (section 603.2.2);
•Turning space includes knee and toe clearance at lavatory (section 304.3);
•Water closet clearance is 60 inches at back wall and 56 inches deep (section 604.3);
•Centerline of the water closet at 16-18 inches from side wall (section 604.2); and
•No other fixtures or obstructions located within required water closet clearance (section 604.3).
•30-inch wide by 48-inch long minimum clear floor space provided beyond the arc of the swing of the entry door (section 603.2.3 exception 2).

The following accessible features are provided in the living area:
•T-shaped turning space (section 304.3.2);
•Accessible route (section 402);
•Clear floor space on both sides of the bed (section 806.2.3);
•Maneuvering clearances at all doors (section 404.2);
•Accessible operable window (section 309); and
•Accessible controls for the heat and air conditioning (section 309). 13’-0” 7’-6” 15’-4
 

 


Plan 4B: 13-Foot Wide Accessible Guest Room

This drawing shows an accessible 13-foot wide guest room with features that comply with the 2010 Standards. Features include an alternate roll-in shower with a seat, comparable vanity, wardrobe, and door connecting to adjacent guest room. Furnishings include two beds.
 
This drawing shows an accessible 13-foot wide guest room with features that comply with the 2010 Standards. Features include an alternate roll-in shower with a seat, comparable vanity, wardrobe, and door connecting to adjacent guest room. Furnishings include two beds.  
The following accessible features are provided in the bathroom:
•Comparable vanity counter top space (section 806);
•Alternate roll-in type shower with folding seat is 36 inches deep and 60 inches wide (section 608.2.3);
•Alternate roll-in shower has a 36-inch wide entry at one end of the long end of the compartment (section 608.2.3);
•Recessed alternate roll-in shower location permits shorter rear grab bar at water closet (section 604.5.2);
•Circular turning space in room (section 603.2.1);
•Required clear floor spaces at fixtures and turning space overlap (section 603.2.2);
•Turning space includes knee and toe clearance at lavatory (section 304.3);
•Water closet clearance is 60 inches at back wall and 56 inches deep (section 604.3);
•Centerline of the water closet at 16-18 inches from side wall (section 604.2); and
•No other fixtures or obstructions located within required water closet clearance (section 604.3).

The following accessible features are provided in the living area:
•T-shaped turning space (section 304.3.2);
•Accessible route (section 402);
•Clear floor space between beds (section 806.2.3);
•Maneuvering clearances at all doors (section 404.2);
• Accessible operable window (section 309); and
•Accessible controls for the heat and air conditioning (section 309).
 


Plan 5A: 13-Foot Wide Accessible Guest Room

This drawing shows an accessible 13-foot wide guest room with features that comply with the 2010 Standards. Features include a transfer shower, comparable vanity, clothes closet with swinging door, and door connecting to adjacent guest room. Furnishings include a king bed and additional seating.
 
This drawing shows an accessible 13-foot wide guest room with features that comply with the 2010 Standards. Features include a transfer shower, comparable vanity, clothes closet with swinging door, and door connecting to adjacent guest room. Furnishings include a king bed and additional seating.  The following accessible features are provided in the bathroom: • Comparable vanity counter top space (section 806);
• Transfer shower (section 603.2);
• Shower seat (section 610.3);
• Clearance in front of the shower extends beyond the seat and is 36 inches wide min. (section 607.2);
• Recessed transfer shower location permits shorter rear grab bar at water closet (section 604.5.2);
• Circular turning space in room (section 603.2.1);
• Required clear floor spaces at fixtures and turning space overlap (section 603.2.2);
• Water closet clearance is 60 inches at back wall and 56 inches deep (section 604.3);
• Centerline of the water closet at 16 inches from side wall (section 604.2); and
• No other fixtures or obstructions located within required water closet clearance (section 604.3).

The following accessible features are provided in the living area:
• Circular turning space (section 304.3.2);
• Accessible route (section 402);
• Clear floor space on both sides of the bed (section 806.2.3);
• Maneuvering clearances at all doors (section 404.2);
• Accessible operable window (section 229); and
• Accessible controls for the heat and air conditioning (section 309).
 


Plan 5B: 13-Foot Wide Accessible Guest Room

This drawing shows an accessible 13-foot wide guest room with features that comply with the 2010 Standards. Features include a transfer shower, comparable vanity, open clothes closet, and door connecting to adjacent guest room. Furnishings include two beds.
 
This drawing shows an accessible 13-foot wide guest room with features that comply with the 2010 Standards. Features include a transfer shower, comparable vanity, open clothes closet, and door connecting to adjacent guest room. Furnishings include two beds.  The following accessible features are provided in the bathroom:
• Comparable vanity counter top space (section 806);

• Transfer shower (section 603.2);

• Shower seat (section 610.3);

• Clearance in front of the shower extends beyond the seat and is 36 inches wide min. (section 607.2);
• Lavatory with vanity counter top recessed to permit shorter rear grab bar at water closet (section 604.5.2);
• T-shaped turning space in room (section 603.2.1);
• Required clear floor spaces at fixtures and turning space overlap (section 603.2.2);
• Water closet clearance is 60 inches at back wall and 56 inches deep (section 604.3);
• Centerline of the water closet at 16-18 inches from side wall (section 604.2); and
• No other fixtures or obstructions located within required water closet clearance (section 604.3).

The following accessible features are provided in the living area:
• T-shaped turning space (section 304.3.2);
• Accessible route (section 402);
• Clear floor space between beds (section 806.2.3);
• Maneuvering clearances at all doors (section 404.2);
• Accessible operable window (section 229); and
• Accessible controls for the heat and air conditioning (section 309).
 


Plan 6A: 12-Foot Wide Accessible Guest Room

This drawing shows an accessible 12-foot wide guest room with features that comply with the 2010 Standards. Features include a transfer shower, water closet length (rim to rear wall) 24 inches maximum, comparable vanity, clothes closet with swinging door, and door connecting to adjacent guest room. Furnishings include a king bed and additional seating.
 
This drawing shows an accessible 12-foot wide guest room with features that comply with the 2010 Standards. Features include a transfer shower, water closet length (rim to rear wall) 24 inches maximum, comparable vanity, clothes closet with swinging door, and door connecting to adjacent guest room. Furnishings include a king bed and additional seating. 
The following accessible features are provided in the bathroom:
• Comparable vanity counter top space (section 806);
• Transfer shower (section 603.2);
• Shower seat (section 610.3);
• Clearance in front of the shower extends beyond the seat and is 36 inches wide min. (section 607.2);
• Recessed lavatory with vanity counter top permits shorter rear grab bar at water closet (section 604.5.2);
• T-shaped turning space in room (section 603.2.1);
• Required clear floor spaces at fixtures and turning space overlap (section 603.2.2);
• Water closet clearance is 60 inches at back wall and 56 inches deep (section 604.3);
• Centerline of the water closet at 16 inches from side wall (section 604.2); and
• No other fixtures or obstructions located within required water closet clearance (section 604.3).

The following accessible features are provided in the living area:
• T-shaped turning space (section 304.3.2);
• Accessible route (section 402);
• Clear floor space on both sides of the bed (section 806.2.3);
• Maneuvering clearances at all doors (section 404.2);
• Accessible operable window (section 229); and
• Accessible controls for the heat and air conditioning (section 309).

 
 


Plan 6B: 12-Foot Wide Accessible Guest Room

This drawing shows an accessible 12-foot wide guest room with features that comply with the 2010 Standards. Features include a transfer shower, water closet length (rim to rear wall) 24 inches maximum, comparable vanity, wardrobe, and door connecting to adjacent guest room. Furnishings include two beds.
 
This drawing shows an accessible 12-foot wide guest room with features that comply with the 2010 Standards. Features include a transfer shower, water closet length (rim to rear wall) 24 inches maximum, comparable vanity, clothes closet with swinging door, and door connecting to adjacent guest room. Furnishings include a king bed and additional seating. 
The following accessible features are provided in the bathroom:
•Comparable vanity counter top space (section 806);
•Transfer shower (section 603.2);
•Shower seat (section 610.3);
•Clearance in front of the shower extends beyond the seat and is 36 inches wide min. (section 607.2);
•Recessed lavatory with vanity counter top permits shorter rear grab bar at water closet (section 604.5.2);
•T-shaped turning space in room (section 603.2.1);
•Required clear floor spaces at fixtures and turning space overlap (section 603.2.2);
•Water closet clearance is 60 inches at back wall and 56 inches deep (section 604.3);
•Centerline of the water closet at 16 inches from side wall (section 604.2); and
•No other fixtures or obstructions located within required water closet clearance (section 604.3).

The following accessible features are provided in the living area:
•Circular turning space (section 304.3.2);
•Accessible route (section 402);
•Clear floor space between beds (section 806.2.3);
•Maneuvering clearances at all doors (section 404.2);
•Accessible operable window (section 229); and
•Accessible controls for the heat and air conditioning (section 309).

224 Transient Lodging Guest Rooms

224.1 General. Transient lodging facilities shall provide guest rooms in accordance with 224. [See additional requirements for places of lodging at 28 CFR 36.406(c) and for housing at a place of education at 28 CFR 35.151(f) and 28 CFR 36.406(e).]

Advisory 224.1 General. Certain facilities used for transient lodging, including time shares, dormitories, and town homes may be covered by both these requirements and the Fair Housing Amendments Act. The Fair Housing Amendments Act requires that certain residential structures having four or more multi-family dwelling units, regardless of whether they are privately owned or federally assisted, include certain features of accessible and adaptable design according to guidelines established by the U.S. Department of Housing and Urban Development (HUD). This law and the appropriate regulations should be consulted before proceeding with the design and construction of residential housing.

224.1.1 Alterations. Where guest rooms are altered or added, the requirements of 224 shall apply only to the guest rooms being altered or added until the number of guest rooms complies with the minimum number required for new construction.

Advisory 224.1.1 Alterations. In alterations and additions, the minimum required number of accessible guest rooms is based on the total number of guest rooms altered or added instead of the total number of guest rooms provided in a facility. Typically, each alteration of a facility is limited to a particular portion of the facility. When accessible guest rooms are added as a result of subsequent alterations, compliance with 224.5 (Dispersion) is more likely to be achieved if all of the accessible guest rooms are not provided in the same area of the facility.

224.1.2 Guest Room Doors and Doorways. Entrances, doors, and doorways providing user passage into and within guest rooms that are not required to provide mobility features complying with 806.2 shall comply with 404.2.3.

EXCEPTION: Shower and sauna doors in guest rooms that are not required to provide mobility features complying with 806.2 shall not be required to comply with 404.2.3.

Advisory 224.1.2 Guest Room Doors and Doorways. Because of the social interaction that often occurs in lodging facilities, an accessible clear opening width is required for doors and doorways to and within all guest rooms, including those not required to be accessible. This applies to all doors, including bathroom doors, that allow full user passage. Other requirements for doors and doorways in Section 404 do not apply to guest rooms not required to provide mobility features.

224.2 Guest Rooms with Mobility Features. In transient lodging facilities, guest rooms with mobility features complying with 806.2 shall be provided in accordance with Table 224.2.

Table 224.2 Guest Rooms with Mobility Features (text version)

Total Number of Guest Rooms Provided

Minimum

Number of Required Rooms Without

Roll-in Showers

Minimum

Number of Required Rooms With

Roll-in Showers

Total Number of Required Rooms

1 to 25

1

0

1

26 to 50

2

0

2

51 to 75

3

1

4

76 to 100

4

1

5

101 to 150

5

2

7

151 to 200

6

2

8

201 to 300

7

3

10

301 to 400

8

4

12

401 to 500

9

4

13

501 to 1000

2 percent of total

1 percent of total

3 percent of total

1001 and over

20, plus 1 for each 100, or fraction thereof, over 1000

10, plus 1 for each 100, or fraction thereof, over 1000

30, plus 2 for each 100, or fraction thereof, over 1000

224.3 Beds. In guest rooms having more than 25 beds, 5 percent minimum of the beds shall have clear floor space complying with 806.2.3.

224.4 Guest Rooms with Communication Features. In transient lodging facilities, guest rooms with communication features complying with 806.3 shall be provided in accordance with Table 224.4.
 

Table 224.4 Guest Rooms with Communication Features

Total Number of Guest Rooms Provided

Minimum Number of Required Guest Rooms With Communication Features

2 to 25

2

26 to 50

4

51 to 75

7

76 to 100

9

101 to 150

12

151 to 200

14

201 to 300

17

301 to 400

20

401 to 500

22

501 to 1000

5 percent of total

1001 and over

50, plus 3 for each 100 over 1000

224.5 Dispersion. Guest rooms required to provide mobility features complying with 806.2 and guest rooms required to provide communication features complying with 806.3 shall be dispersed among the various classes of guest rooms, and shall provide choices of types of guest rooms, number of beds, and other amenities comparable to the choices provided to other guests. Where the minimum number of guest rooms required to comply with 806 is not sufficient to allow for complete dispersion, guest rooms shall be dispersed in the following priority: guest room type, number of beds, and amenities. At least one guest room required to provide mobility features complying with 806.2 shall also provide communication features complying with 806.3. Not more than 10 percent of guest rooms required to provide mobility features complying with 806.2 shall be used to satisfy the minimum number of guest rooms required to provide communication features complying with 806.3.

Advisory 224.5 Dispersion. Factors to be considered in providing an equivalent range of options may include, but are not limited to, room size, bed size, cost, view, bathroom fixtures such as hot tubs and spas, smoking and nonsmoking, and the number of rooms provided.