ANDSCAPE L INES

13

Accessibility INTRODUCTION

Since the Civil Rights Act of 1964, disability rights legislation and

increasing public awareness about the rights of people with disabilities have produced various pieces of legislation, the most extensive

of which is the Americans with Disabilities Act, Public Law 101-336.

Passed in January 1990, the law identifies equal access as a civil right

and prohibits discrimination on the basis of disability in both privately

and publicly owned accommodations. Public accommodations

include services, programs, activities, goods, and commercial establishments, such as restaurants, hotels, theaters, hospitals, museums,

and parks.

The executive branch of the federal government is not bound to

the provisions of the Americans with Disabilities Act. Executive

agencies and recipients of federal funding are required to comply

with the accessibility provisions contained in two pieces of earlier

legislation:

• Architectural Barriers Act (1968)

• Section 504 of the Rehabilitation Act (1973) ACCESSIBILITY REQUIREMENTS

Both the Architectural Barriers Act and Section 504 of the Rehabilitation Act contain standards and guidelines that identify the conditions

necessitating accessibility requirements and give technical specifications

for new construction, alterations, and additions. For both Acts, the

minimum standards of accessibility for federal buildings and facilities is

defined by the Uniform Federal Accessibility Standards (UFAS), published in 1984 by the Architectural and Transportation Barriers Compliance Board.
2 L A N D S C A P E L I N E S

For nonfederal public accommodations, minimum

accessibility requirements are outlined in the

Americans with Disabilities Act Accessibility

Guidelines (ADAAG). The ADAAG was published in 1991 by the Architectural and Transportation Barriers Compliance Board.

The UFAS and ADAAG have common technical

requirements. The general technical requirements for ADAAG (titled “Accessible Elements

and Spaces”) are the same as the UFAS technical

requirements. Both require that the design of

new construction be accessible; however, they

differ slightly in their scoping requirements for

existing facilities. ADAAG has many new technical

requirements for various types of public accommodations, including restaurants and cafeterias,

medical care facilities, business and mercantile,

libraries, transient lodging, and transportation

facilities. Both UFAS and ADAAG have special

rules for historic preservation, which are discussed in this text.

The technical requirements common to both

UFAS and ADAAG are actually derived from

accessibility standards first developed in 1961 by

the American National Standards Institute (ANSI).

The ANSI standards have been modified very

little over the past 30 years despite medical and

technology advancements and increased awareness about the needs and life expectations of

people with disabilities.

The federal government intends to revise the

UFAS to be at least equivalent to the ADAAG in

its technical and scoping requirements. In a June

30, 1993 memorandum, the Department of

Justice requested that until the UFAS are revised,

the executive agencies use the higher standards

of the ADAAG whenever the guidelines result in

more universal access. Currently, both the UFAS

and the ADAAG are being reviewed by the

Architectural and Transportation Barriers Compliance Board for possible revisions to their respective technical requirements. This review is being

conducted in conjunction with the Civil Rights

Division of the Department of Justice and the four

standard-setting agencies under the Architectural

Barriers Act: General Services Administration, the

United States Postal Service, the Department of

Housing and Urban Development, and the

Department of Defense.

UNIVERSAL DESIGN

Universal design is based on the premise that a

facility or product should be usable by anyone.

Despite advancements toward universal accessibility, the disability community and universal

design advocates have criticized the use of

accessibility guidelines. Critics maintain that the

use of minimum construction specifications does

not promote a greater understanding about the

needs of people with disabilities, or contribute to

removing attitudinal barriers.

Critics believe that for designed environments,

attitudinal barriers are more persistent than

architectural ones, and the way to remove the

attitudinal barriers is to increase awareness about

the many distinctive needs of users. Critics assert

that in practice, minimum design standards
A C C E S S I B I L I T Y 3

Figure 3. Office walkway following implementation of the

accessibility project. The historic stone edge condition of the

original walkway was salvaged and relaid to match the

gradient of the new walkway. Frederick Law Olmsted National

Historic Site. (NPS, 1997)

become maximum standards, and compliance with

minimum standards is viewed as the goal rather

than the means to achieving universal or equal

access.

Universal design advocates believe strict adherence to accessibility guidelines may result in a

design solution that does not create equal access. They distinguish accessibility from universal

and equal access, noting that separate provisions

for one group of users may ignore the needs of

another group with different disabilities. They

emphasize education about the concept of

“fitness for use by anyone” as the basis for the

environmental design process. (See Figures 1, 2,

and 3.)

Figure 1. View of the original office walkway and location of a

proposed 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 to

meet the threshold, and includes a new walkway with an

accessible gradient. Frederick Law Olmsted National Historic

Site. (NPS, 1995)
4 L A N D S C A P E L I N E S

ACCESSIBILITY IN CULTURAL

LANDSCAPES

Historically, the needs of people with disabilities

have not been considered in the design and

construction of places. As a result, many historic

properties have features that are obstacles to equal

access. Unfortunately, equal access and historic

preservation have often been portrayed as antithetical, technically infeasible, and even impossible.

But designing equal access to historic properties,

including cultural landscapes, does not have to

preclude the preservation of significant resources.

Historic preservation exists to allow experiential

access to historic properties that are considered

culturally valuable or significant. In this context,

the goal of equal access is to create equal access

to the experience as well as improve physical

accessibility. (See Figure 4.) To create equal

access to the opportunity to experience the

significance of a cultural landscape, the goal of

accessibility needs to be united with the goal of

preservation. The loss of integrity resulting from

the implementation of an accessibility project

represents a compromise to the goals of both

equal access and preservation.

Equal access to the experience of a cultural

landscape is achieved when the significance is

conveyed through the physical integrity of

landscape characteristics and associated features

and when the experience is equally available to

all visitors or users. As defined by the National

Register of Historic Places, integrity relates to

the presence of physical features that have

existed since a period of significance and that

contribute to and convey the significance of a

THE EQUAL FACILITATION CLAUSE

A fundamental difference between the UFAS and

ADAAG in guiding the creation of universally accessible environments is that the ADAAG has an extra

clause within the general provisions, titled “Equivalent

Facilitation” (ADAAG 2.2). The clause states:

Departures from the particular technical

and scoping requirements of this guideline by the use of other designs and technologies are permitted where the alternative designs and technologies used will

provide substantially equivalent or greater

access to and usability of the facility.

The ADAAG allows designers to depart from the

specifications. For designers to take advantage of

this creative opportunity, they should understand

the needs of people with disabilities and the

reasons underlying the existing guidelines. For

example, the reason for requiring handrails along

both sides of a ramp or set of steps is that people

with different capabilities on either side of their

bodies (such as people who have suffered

strokes) can use the handrail matching their

physical abilities.

Universal design advocates are critical of the

prevalence of eight percent gradient ramps with

handrails (permitted by UFAS and ADAAG

guidelines), because an eight percent gradient is

too steep for many people with limited mobility

and handrails are unusable by many people with

disabilities. They encourage the use of the

ADAAG’s Equivalent Facilitation clause because it

has more potential to change attitudes and

improve the usability of designed environments.
A C C E S S I B I L I T Y 5

historic property. Therefore, the design of

accessibility projects in a cultural landscape

should retain the extant landscape characteristics

and associated features that contribute to and

convey the significance of the landscape. New

features that are added to provide equal access

should be designed in a manner that is compatible

with the character of the landscape. The goal is

to provide the highest level of access with the

lowest level of impact on the integrity of the

landscape. (See A Guide to Cultural Landscape

Reports: Appendices, “Appendix I: Treatment

Policy, Guidelines, and Standards.”)

Accessibility in a cultural landscape is part of the

preservation planning process. Currently, under

UFAS scoping requirements, only existing facilities

undergoing substantial alteration (all alterations in

one year amounting to 50 percent or more of the

property value) trigger requirements for accessibility. Under ADAAG scoping requirements, any

alterations to an existing element, feature, space,

or area, triggers new construction standards for

accessibility. Until the UFAS has been revised to

the greater scoping requirement of ADAAG, the

Department of Justice and the Architectural and

Transportation Barriers Compliance Board encourage the executive agencies to use the greater

scoping requirement of ADAAG for alterations.

ACCESSIBILITY PLANNING

The planning and design of accessibility projects is

a multidisciplinary activity involving the expertise

of preservation professionals, accessibility specialists, and individuals with disabilities and their

organizations. Accessibility coordinators, usually

located in the National Park Service (NPS) support offices, should be invited to participate in the

planning process.

Accessibility planning and design requires a clear

understanding of a cultural landscape’s significance and how it is conveyed through its extant

landscape characteristics and associated features.

Figure 4. Before (top) and after (bottom) existing conditions

plans of Dorchester Heights, the site of an accessibility project

in 1995. The accessibility project occurred as part of a

rehabilitation treatment plan. It involved "stretching" the

pattern of the historic circulation plan (the central walk and the

north and south ramps were elongated), to achieve a more

shallow, accessible route up to the Dorchester Heights

Monument. Boston Historical Park. (NPS, 1994)
6 L A N D S C A P E L I N E S

Equal access must be defined for each particular

cultural landscape based on a variety of factors,

including significance, landscape characteristics and

associated features, integrity, treatment, and

contemporary use of the landscape. These factors

influence how a landscape’s significance is

presented to visitors, and, therefore, affect the

extent and location of modifications required to

provide access and the physical appearance of

access designs.

If a cultural landscape is eligible for listing or is

listed in the National Register of Historic Places,

and the access project is a federal undertaking,

the planning and design stages of an accessibility

project involve the review process cited in

Section 106 of the National Historic Preservation

Act. The NPS initiates consultation with the State

Historic Preservation Office to develop a Memorandum of Agreement on the planning and design

of access modifications. As a result, the Memorandum of Agreement outlines actions that are

agreed upon and it is submitted to the Advisory

Council for Historic Preservation for comment.

The same review procedure is followed when

the less comprehensive scoping requirements of

UFAS and ADAAG are used to plan and design

access modifications.

Both UFAS and ADAAG have special rules for

historic preservation that reduce scoping requirements for particularly challenging circumstances. The rules apply to situations in which

creating equal access would destroy the integrity

of a historic property because its significance is

wholly conveyed by the exact location, original

materials, original workmanship, or original

design of a feature or features. The special rules

add flexibility to the process of creating access

changes that retain the integrity of a historic

property and therefore allow the significance to

be conveyed and experienced. If using the

general scoping requirements for accessibility

would destroy the integrity of a cultural landscape, the special rules of UFAS and ADAAG

are permitted. The circumstances in which to

apply the special rules for historic preservation

of UFAS (4.1.7 (2)), and ADAAG (4.1.7 (3)) are

relatively rare and only apply to a small number

of historic properties.

Listed below are the special rules for historic

presentation, which are written to apply most

directly to historic buildings.

• Allow only one accessible route from one site

access point (such as a parking lot) to an

accessible entrance.

• The accessible entrance may be different to

the one used by the general public (though it

cannot be locked and ADAAG requires

directional signage to the accessible entrance).

• A ramp steeper than is ordinarily permitted

may be used in space limitations (a gradient of

16.6 percent (1:6) for a maximum run of two

feet).

• Only one accessible restroom is required and

it may be unisex.

• Accessible routes are only required at the

elevation of the entrance.

• Interpretive materials should be located where

they can be seen by seated persons.
A C C E S S I B I L I T Y 7

ADAAG also has an exception rule for historic

preservation (ADAAG 4.1.7 (1)), which states

that if the integrity of a historic property could

be destroyed by following the special rules,

scoping requirements are reduced even further. The exception permits use of alternative

methods to make services and programs

available (that is, to create the opportunity to

experience the significance of a property).

Alternative methods include the use of interpretation (such as audio visual materials), using

facilitators to assist individuals with disabilities,

and adopting other innovative methods such as

those invited by the Equivalent Facilitation

clause of ADAAG. UFAS has no exception rule

for historic preservation.

SOURCES OF FURTHER INFORMATION

The Uniform Federal Accessibility Standards and

information can be obtained from:

Architectural and Transportation

Barriers Compliance Board

1111 18th Street, NW, Suite 501

Washington, DC 20036

1-800-USA-ABLE

The Americans with Disabilities Act Accessibility

Guidelines and information can be obtained from:

Office of the Americans with

Disabilities Act—Civil Rights Division

U.S. Department of Justice

P.O. Box 66118

Washington, DC 20035-6118

202-514-0301

For NPS accessibility enquiries contact:

Accessibility Program Coordinator

Parks Facility Management Division

National Park Service

P.O. Box 37127, Suite 580

Washington, DC 20013-7127

202-343-3674

TECHNICAL AND SCOPING

ACCESSIBILITY REQUIREMENTS FOR

ELEMENTS AND SPACES

Following is a partial list of ADAAG and UFAS

“Technical Requirements for Accessible Elements and Spaces,” which are most pertinent to

access projects in cultural landscapes. For the full

list of technical and scoping requirements, refer

to the UFAS or ADAAG.

Accessible Route Minimum Specifications

• Width = 36 inches

• Passing zone = 60 inches wide occurring at

200-foot intervals

• Wheelchair 180-degree turning zone = 60

inches x 60 inches

• Gradient = 5 percent (1: 20)

• A gradient greater than 5 percent shall be

called a ramp

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

or less

• Abrupt level changes are no greater than 0.5

inch in height
8 L A N D S C A P E L I N E S

• 0.25-inch level change is permitted without a

beveled edge

• 0.5-inch level change must have a beveled

edge

• Surfaces must be of stable, firm, slip resistant

material

Accessible Parking

• Space = 96 inches wide

• Access aisle is considered to be part of an

accessible route

• Spaces and aisles have a 2 percent (1: 50)

maximum gradient in any direction

• Passenger loading zone (access aisle) = 60

inches wide x 20 feet long, adjacent and

parallel to the vehicle pull-up space

Curb Ramps

• Must be located wherever an accessible route

crosses a curb

• 5 percent (1: 20) gradient or less, unless space

is limited, then a gradient between 8 percent

(1: 12) and 10 percent (1: 10) is permitted for

a rise of 6 inches

• Must have flared sides if they are located

where pedestrians must walk across the ramp

or are not protected by handrails or guardrails

• Maximum gradient of curb ramp flared sides =

10 percent

• Must have returned curbs where pedestrians

do not walk across the ramp

• Built-up curb ramps must be located where

they do not project out into vehicular traffic

lanes

• Must have a detectable warning of raised,

truncated domes or contrasting color that

extends the full width and depth of the curb

ramp

• Must be located where they will not be obstructed by parked vehicles

• Diagonal curb ramps (corner ramps) must have

at least a 48-inch width clear space at the

bottom of the ramp

• Where a sidewalk landing beyond a curb ramp

is less than 48 inches deep, the curb ramp

gradient must not exceed 8 percent (1: 12)

Ramps

• Must be at least 36 inches wide

• Gradient greater than 5 percent (1: 20) and a

maximum of 8 percent (1: 12)

• Maximum rise on any run = 30 inches in

height

• In space limitations, a ramp gradient no greater

than 16.6 percent (1: 6) may be used for a

horizontal run of 2 feet

• In space limitations, a ramp gradient between 8

percent (1: 12) and 10 percent (1: 10) may be

used for a maximum vertical rise of 6 inches

• An 8 percent (1: 12) gradient and a rise greater

than 6 inches, or a horizontal run greater than

72 inches, must have handrails on both sides of

the ramp
A C C E S S I B I L I T Y 9

• Surface must be stable, firm, and nonslip

• Ramps and landings with dropoffs on either

side must have curbs at least 2 inches high

• Must be well draining to prevent the accumulation of rainwater

• Cross pitch (cross slope) must be no greater

than 2 percent (1: 50) gradient

Landings

• Must be located at every 30-inch vertical rise in

a ramp

• Dimensions of landing = 36 inches wide x 60

inches deep at the top and bottom of a ramp run

• Dimensions of landing = 60 inches wide x 60

inches deep at a ramp dogleg

• Drop-offs must have curbs with a minimum

height of 2 inches

• Height of door thresholds = 0.5-inch high or

less, 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 a

72-inch horizontal run, and on either side of stairs

• Must be continuous on the inner side of a

dogleg ramp or dogleg stairs

• Must continue at least 12 inches beyond the

top and bottom of a ramp and be parallel to

the ground plane

• Must continue at least 12 inches beyond the

top riser of stairs parallel to the ground plane,

and continue to slope for a distance of one

tread width from the bottom stair riser and

become parallel to the ground plane for an

additional distance of 12 inches

• Distance from mounting wall = 1.5 inches wide

• Gripping surface must be uninterrupted

• Diameter or width of gripping surface of

handrail or grab bar must be 1.25 - 1.5 inches,

or the shape must provide an equivalent

gripping surface UFAS 4.26.2.

• Top of gripping surface = 34 - 38 inches in

height above the ramp or stair tread surface

• Terminal ends of handrails must be rounded off

or returned smoothly to the ground, wall or post

Stairs

• Must have uniform tread widths and riser

heights

• Width of treads must be no less than 11 inches

high

• Open risers are not permitted

• Nosings must project no more than 1.5 inches

• Nosing undersides must be angled at no

greater than 60 degrees from the horizontal

• Handrails must be located on either side of

stairs

• Inside handrail at stair dogleg must be continuous

• Handrails must extend 12 inches beyond the

top riser, and at least one tread width and an

additional 12 inches beyond the bottom riser
10 L A N D S C A P E L I N E S

• Handrails at the top of stairs must be parallel to

the ground plane, and at the bottom of stairs,

handrails must continue to slope for a distance

of one tread from the bottom riser and for an

additional 12 inches be parallel to the ground

plane

• Handrail gripping surface must be uninterrupted and be located 34 - 38 inches above

the stair treads

• Terminal ends of handrails must be rounded or

returned smoothly to the ground, wall, or post

• Stairs must be well draining to prevent the

accumulation of rainwater

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A C C E S S I B I L I T Y 11

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12 L A N D S C A P E L I N E S

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