Attractions Industry & the ADA
Last month, the U.S. Department of Justice released proposed rules regarding compliance with the Americans with Disabilities Act (ADA). These rules adopt provisions of the Americans With Disabilities Act and Architectural Barriers Act Accessibility Guidelines (2004 ADAAG) which were published by the Architectural and Transportation Barriers and Compliance Board (Access Board) on July 22, 2004. The rules apply to all areas of public accommodation, which will impact all IAAPA constituencies.
We have identified specific provisions for individual constituencies but we strongly encourage members to read all information, as some facilities belong to more than one constituency.
We are asking IAAPA members to submit comments on these issues and other concerns regarding the regulations to the Department of Justice and the IAAPA Government Relations Department. To submit a comment for the record visit the Regulations.gov webpage, then e-mail it to us.
This is the industry’s chance to affect the regulations before they are put into place. We hope you will respond promptly. Please send your comments to IAAPA by August 5, to give us time to develop our industry’s public comments.
Critical IssuesExtend the comment period to 150 days. We would like to ask the Department of Justice to extend the comment period on the new rules. Currently, the comment periodexpires August 17. As this is the height of the season for the attractions industry, IAAPA believes more time should be given for members to examine these complicated proposals. Effective Date. The effective date of these standards could dramatically impact many members of the industry. It is IAAPA’s recommendation that members of the industry request the Department to make the effective date to be 18 months for amusement and water park facilities and 36 to 60 months for amusement ride vehicles. These grace periods reflect the time necessary for effective barrier removal activities. Also, these periods are necessary for the process of capital funding, design and construction that are required to meet the new rules. Economic Analysis. IAAPA has questions about the economic assessment on places of amusement. Many cost impacts are not included in the analysis, such as those related to exterior facilities, retail space, food service establishments, pools, dry play areas, wet play areas, some water park elements, and ride vehicles. We believe the economic impact on places of amusement exceeds $100 million. We believe a parallel but separate economic impact occurs on family entertainment centers, water parks, miniature golf and other small business that make up IAAPA’s membership. Service Animals. IAAPA supports the proposed rules pertaining to service animals. The rules define a service animal as a "dog ot other common domestic animal" and exclude animals whose sole function is to provide emotional support, comfort, therapy, companionship, theraputic benifits or to promote emotional well-being from the service animal definition. |
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ADA ResourcesAmusement Facility Information |