Wheelchair space dispersion

[bill1952]

So drilling down in the IBC and referenced ICC A117.1, in assembly seating wheelchair spaces are required to be dispersed, including at varying distances from the event. Some exceptions and special conditions but assume none apply here: in a typical 750 seat new high school auditorium with stage, would you note or cite as non compliant all eight wheel chair spaces being in one row near the middle? Not is it a violation, but would an average building official/ahj catch it?

(I'm fanatical about this in my work, spreading the spaces around, insuring grandpa and sit with family on both sides and all around. I drove my architect clients a little crazy pushing for accessibility, and trying to make it truly "equal" and not discriminate. But what I see too often is meager accomodation that looks like an after thought.)

 

[Yankee Chronicler]

I would cite it -- but I was a handicapped access advocate and consultant as an architect long before I became licensed as a Building official.

In this state, all new school construction and all major renovations are subject to state approval, so it would definitely be caught by someone. Even if not caught -- it would be an ADA violation, and school districts really don't want to get in a urinating contest with the federal Department of Justice. I think the federal Department of Education still follows UFAS. Section 4.33 of UFAS states:

Wheelchair areas shall be an integral part of any fixed seating plan and shall be dispersed throughout the seating area. They shall adjoin an accessible route that also serves as a means of egress in case of emergency and shall be located to provide lines of sight comparable to those for all viewing areas.


EXCEPTION: Accessible viewing positions may be clustered for bleachers, balconies, and other areas having sight lines that require slopes of greater than 5 percent. Equivalent accessible viewing positions may be located on levels having accessible egress.

 

[bill1952]

I would cite it -- but I was a handicapped access advocate and consultant as an architect long before I became licensed as a Building official.

In this state, all new school construction and all major renovations are subject to state approval, so it would definitely be caught by someone. Even if not caught -- it would be an ADA violation, and school districts really don't want to get in a urinating contest with the federal Department of Justice. I think the federal Department of Education still follows UFAS. Section 4.33 of UFAS states:

I don't think UFAS clearly prevents them from being in the same row and based on the accessible route, almost justifies it. I proposed to ADAAG and for A117.1 leaving that out. Too easy to not design in accessible routes. Require dispersion, and force the accessible routes to be provided.

 

[Yankee Chronicler]

I don't think UFAS clearly prevents them from being in the same row and based on the accessible route, almost justifies it. I proposed to ADAAG and for A117.1 leaving that out. Too easy to not design in accessible routes. Require dispersion, and force the accessible routes to be provided.

I respectfully disagree about the UFAS. IMHO, "dispersed throughout the seating area" pretty clearly doesn't allow placing them all in the same row, near the middle -- and presumably not providing each with a companion seat.

The 2010 ADAAG doesn't have a lot to say about dispersion of wheelchair spaces, but A117.1-2017 says quite a bit on the subject. In my state, building officials don't enforce the ADA, but our building code adopts A117.1-2017 as an enforceable part of the code.

802.10 Wheelchair space dispersion. The minimum number
of wheelchair space locations shall be in accordance with
Table 802.10. Wheelchair space locations shall be dispersed
in accordance with Sections 802.10.1, 802.10.2 and 802.10.3.
In addition, wheelchair space locations shall be dispersed in
accordance with Section 802.10.4 in spaces utilized primarily
for viewing motion picture projection. Once the required
number of wheelchair space locations has been met, further
dispersion shall not be required.
802.10.1 Horizontal dispersion. Wheelchair space locations
shall be dispersed horizontally to provide viewing
options. Where seating encircles the stage or field, in
whole or in part, horizontal dispersion shall include the
entire seating area. Two wheelchair spaces shall be permitted
to be located side-by-side.
Exception: Horizontal dispersion shall not be required
in assembly areas with 300 or fewer seats if the wheelchair
space locations are located within the 2nd and 3rd
quartile of the row length. Intermediate aisles shall be
included in determining the total row length. If the row
length in the 2nd and 3rd quartile of the row is insufficient
to accommodate the required number of companion
seats and wheelchair spaces, the additional
companion seats and wheelchair spaces shall be permitted
to extend into in the 1st and 4th quartile of the row.
802.10.2 Dispersion for variety of distances from the
event. Wheelchair space locations shall be dispersed at a
variety of distances from the event to provide viewing
options.
Exceptions:
1. In bleachers, wheelchair space locations provided
only in rows at points of entry to bleacher seating
shall be permitted.
2. Assembly areas utilized for viewing motion picture
projections with 300 seats or less shall not be
required to comply with Section 802.10.2.
3. Assembly areas with 300 seats or less other than
those utilized for viewing motion picture projections
shall not be required to comply with Section
802.10.2 where all wheelchair space locations are
within the front 50 percent of the total rows.
802.10.3 Dispersion by type. Where assembly seating has
multiple distinct seating areas with amenities that differ
from other distinct seating areas, wheelchair space locations
shall be provided within each distinct seating area.

 

[bill1952]

The UFAS exception that allows clustering - all the same distance from the stage - also results in little dispersion. 5% is nothing an results in poor sightlines.

So Yankee Chronicler feels dispersion is enforced in his jurisdiction. Anyone else?

 

[Jay Smith]

In Texas, I think the average AHJ would defer that topic to the state and the average state reviewer would cite it.

 

[Yankee Chronicler]

Texas is, in a way, a special case. A number of years ago a major venue lost a huge ADA case over the issue of sight lines from accessible seating. I don't remember the specifics, but the case hinged on the fact that Texas had submitted their accessibility requirements to the DOJ and had them "certified" by the DOJ as being equivalent to the ADAAG. The designers followed the Texas requirements, the AHJ approved the design under the Texas guidelines, the facility was built according to the approved plans ... and, after construction, someone complained about sight lines and the DOJ sued the property owner. The owner, in turn sued the architects.

The owner's and architect's defense was that they had followed the Texas requirements, which had been certified by the DOJ as being acceptable. At that point, the DOJ's position was essentially, "Well, yes, we did certify your standards, but we were only kidding. Now that someone has complained, it's not equal any more."

That was one of the things that led my state to NOT submit our handicapped standards to the DOJ for certification. I imagine AHJs in Texas are still a bit gun-shy on this issue.

 

[bill1952]

Sightlines and especially sightlines over standing spectators is a whole other issue, especially for churches, which not subject to feds are usually to building code. Tell me spectators are not expected to stand in church. And most architects don't understand sightlines, so hard to expect building officials to.

But, do you really think the dispersion is enforced?

 

[e hilton]

From a personal opinion perspective, half way back makes sense. But there should be regular seats among the hc spaces to allow family to sit with them. And probably an empty row or cross aisle in front of that so when people stand the hc folks are not completely blocked from seeing the stage.

 

[bill1952]

An empty row in front is not going to give a seated person sightlines over standing spectators unless it's very steeply pitched seating. Just the simple figures in ICC A117.1 illustrate that. The wheelchair space has to be elevated several feet over the rows in front of it (which does sort of go against blending in). The front row of any section - orchestra, mezzanine, balcony and similar by other names - does solve standing spectators.

 

[Yankee Chronicler]

Another aspect to the ADA requirement for dispersion is that the ADA expects there to be accessible seats in all price ranges of seating, and in all tiers or levels. We can't group all the wheelchair spaces in the front row of the orchestra, where people will have to sprain their necks to watch the screen or stage, and likewise we can't put all the wheelchair spaces in the upper tier of the bleachers beyond center field (the "nosebleed seats").

That isn't likely to be a concern in a high school auditorium with only 750 seats, but it is a concern in larger venues such as concert halls and sports arenas and stadiums.

 

[bill1952]

and in all tiers or levels.

Actually just the main level and one of every two other levels. I found front and rear of orchestra, and front of balcony, and none in mezzanine.

The project that prompted my op has the spaces in just one of two sections as well.

Many times, a HS auditorium may only have a handful of students for an event or class, in the first 3 or 4 rows, and wheel chair space is 10 to 12 rows back. Discriminatory?

 

[Msradell]

This issue has been a major concern of mine since I am disabled and in a wheelchair. Here in Louisville Kentucky at our state Performing Arts Center wheelchair accessible seating is on the outside of about 5 rows near the front of the theater the end of the front row in the balcony! Especially the ones in the orchestra section to not give you good sightlines.

 

[bill1952]

This issue has been a major concern of mine since I am disabled and in a wheelchair. Here in Louisville Kentucky at our state Performing Arts Center wheelchair accessible seating is on the outside of about 5 rows near the front of the theater the end of the front row in the balcony! Especially the ones in the orchestra section to not give you good sightlines.

I believe that building was designed pre-ADA, early 80s iirc. Generally, modifying pre-ADA auditoriums to something close to the standards for new results in significant seat count loss, which can threaten the financial viability of the facility.

In balconies in new construction, very difficult to get an accesible route to other than edges, but end of first row is still much better than center of last row.

Accessibility is the single largest impact on theatre design since the renaissance, far outstripping even electricity.

 

[Msradell]

I believe that building was designed pre-ADA, early 80s iirc. Generally, modifying pre-ADA auditoriums to something close to the standards for new results in significant seat count loss, which can threaten the financial viability of the facility.

In balconies in new construction, very difficult to get an accesible route to other than edges, but end of first row is still much better than center of last row.

Accessibility is the single largest impact on theatre design since the renaissance, far outstripping even electricity.

End of the 1st row of the balcony is okay but the end of the rows closer to the stage in the orchestra section are terrible. They have absolutely no sightlines that are reasonable.

 

[bill1952]

End of the 1st row of the balcony is okay but the end of the rows closer to the stage in the orchestra section are terrible. They have absolutely no sightlines that are reasonable.

Well, some of that is basic design of that facility, not accessibility. Poor off axis sightlines for any audience is not necessary.

Interesting you think of off axis sightline issues first and I find the sightlines over seated spectators is the bigger problem.

 

[e hilton]

Interesting you think of off axis sightline issues first and I find the sightlines over seated spectators is the bigger problem.

Sightlines over seated spectators is a problem for many venues, for both HC and regular seating. I would be more concerned about when the audience is standing and the HC people cannot.

 

[bill1952]

Sightlines over seated spectators is a problem for many venues, for both HC and regular seating.

That's because many people designing them don't know squat about sightlines and assembly seating.

I would be more concerned about when the audience is standing and the HC people cannot.

A117.1 uses the qualifiers where spectators are "expected to remain seated" and "expected to stand". I believe that for drama and school theatres, it's reasonable to expect spectators to remain seated. Stadia and arenas I would expect them spectators to stand.

Front rows of seating sections are an opportunity for sightlines over standing spectators but with a few exceptions - first row of ramped seating adjacent to a stage for instance - accessible routes to other than the ends of a row don't work.

All this and not to mention accessible means of egress and CPET from wheelchair spaces, or what is a "distinct seating area".

 

[Mr. Inspector]

2018 IBC 1108.2.2 and 2018 IEBC
I have a existing historic (built 1881) theater that is adding 2 new rows of fixed seating in the back of a non-accessible balcony.
1. Do they only need to count the new seating for the amount of wheelchair spaces?
2. Can they put them on the 1st floor or do they need to be where the new seating is?
3. 1108.2.1 There is a snack bar on the first floor. Will they need one on the balcony too?
4. 1108.2.5 5% of aisle seats to be designated aisle seats. Only 5% of the new aisle seats or the seats in the whole theater? Do they need to be where the new seats are or on the first floor?

 

[bill1952]

2018 IBC 1108.2.2 and 2018 IEBC
I have a existing historic (built 1881) theater that is adding 2 new rows of fixed seating in the back of a non-accessible balcony.
1. Do they only need to count the new seating for the amount of wheelchair spaces?
2. Can they put them on the 1st floor or do they need to be where the new seating is?
3. 1108.2.1 There is a snack bar on the first floor. Will they need one on the balcony too?
4. 1108.2.5 5% of aisle seats to be designated aisle seats. Only 5% of the new aisle seats or the seats in the whole theater? Do they need to be where the new seats are or on the first floor?

These are complicated issues. A lot of the answers depend on how much work is in the project. I'd say if only adding two rows of fixed seating, probably where there once was seating, you have very few obligations. It's furniture.

All my opinions.

1. It's my opinion if operating you should provide the number of spaces required - new or not.
2. In an existing, especially historic, building, I'd try to disperse them but I don't think it's required. So ok all on first floor if not a part of a major renovation.
3. I don't think you have to add a snack bar. It's more if you offer a service to a section of seats, like wait service to at the seats, there needs to be wheel chair spaces in that section. Having the only snack bar on main floor doesn't discriminate if everyone can get to it.
4. Tricky. If upper floor is not on an accesible route, you can put all the designated aisle seats on main floor. Like the total number of wheelchair spaces, you should try to provide all of them - the total number. If these are historic seats, they probably cannot feasibly meet the designated aisle seat requirements. I would look for equivalents. Hard to even guess what that might be without a better understanding if the facility and the chairs.

If this few hundred thousand dollars of work, maybe over several years, it's one thing. If a major many million dollar renovation, you should be able to achieve accessibility same as new.

 

[steveray]

But, do you really think the dispersion is enforced?

It really is gray in that IBC gives specifics on assembly seating in 1109.2, but then ANSI goes further into dispersion on the same level than IBC does...So the question is, does 1109.2 preempt 802.10....Good one to look for an answer on...

[A] 102.4.1 Conflicts​

Where conflicts occur between provisions of this code and referenced codes and standards, the provisions of this code shall apply.

[A] 102.4.2 Provisions in Referenced Codes and Standards​

Where the extent of the reference to a referenced code or standard includes subject matter that is within the scope of this code or the International Codes specified in Section 101.4, the provisions of this code or the International Codes specified in Section 101.4, as applicable, shall take precedence over the provisions in the referenced code or standard.

 

[bill1952]

Good points steveray. I'll consider them in upcoming code change proposals. A number of issues that I believe a little tweaking.

 

[Mr. Inspector]

Steveray, We don't use chapter 1 in PA and the state code does not say this.

 

[steveray]

Steveray, We don't use chapter 1 in PA and the state code does not say this.

How do you get to all of the books then?