The Realties of ADA Compliance

[David Cole]

** LEGAL DISCLAIMER: This posting, nor any portion thereof, is to be 
construed as a flame or an insult (although I'm certain it will be), and 
this posting, nor any portion thereof, is not to be construed as being 
directed toward any particular person on the AMP-L listserv, nor as a reply 
to any specific posting on the AMP-L listserv. **

Greetings, all...

As a proud member the architecture profession, I have been following this 
thread about ADA compliance with some interest. Of concern to me are some 
of the seemingly unrealistic expectations on the part of some people in the 
disability community about building accessibility, especially for older 
buildings that were built before accessibility became a major concern. 
Unfortunately for those who use wheelchairs, this includes the vast 
majority of the public buildings in the U.S., especially in older cities 
like Chicago, New York and Boston.

For new construction this isn't really an issue, since any 
halfway-competent architect will be aware of accessibility issues from the 
very onset of the project and will design accordingly. However, once the 
concrete has been poured, the bricks laid and the roof installed, any 
aspects of the building's design that compromise its accessibility have 
been pretty much carved in stone (sometimes literally) by this point, and 
certain modifications can become extremely difficult.

This is why ADA has differing standards for new construction vs. existing 
construction. New buildings must be fully compliant to ADA standards, but 
barriers within in existing construction must be removed only where it is 
"readily achievable" to do so. Readily achievable means "easily 
accomplishable and able to be carried out without much difficulty or 
expense." Examples:

Readily achievable: A major hospital replacing its round door knobs with 
level-style handles.

NOT readily achievable: A small mom-and-pop business spending $250,000 to 
add an elevator. Considered an "undue burden" by ADA in most cases.

Items such as shaving off a 1/2" bump from a curb cut (BTW, up to 1/4" is 
allowable under ADA) or reversing the swing of a door are two such 
relatively minor issues that can usually be accomplished with little 
difficulty or expense, and of course, I agree that every effort must be 
made by the building ownership to carry them out.

(As for lazy slobs who park their delivery trucks in designated H/C parking 
stalls, this isn't really an issue of architecture, but more a behavior 
issue. Any moderately-sized public or commercial building will usually have 
a designated loading dock or other service area specifically for 
deliveries. There is no excuse for drivers too lazy to go around back or at 
least use a regular parking spot.)

But here's the rub: What may appear to be a minor modification may actually 
be a far more complicated and expensive process than readily apparent to 
the average person. To illustrate this point, I'll bring up the example of 
a recent flame war I got myself into on a railfan message board that I 
frequent. A little background:

The Chicago Transit Authority is in the design phase of a major 
reconstruction project to bring its 100-year-old Ravenswood "L" line up to 
modern standards. A major portion of the project will involve lengthening 
the station platforms to accommodate CTA standard 8-car trains (this 
crowded line is currently limited to 6-car trains because of short 
platforms at most stations), and building new station houses at street 
level that will include wheelchair-accessible turnstiles and elevators to 
the platforms. Most of the existing station houses, many of which date to 
the turn of the century and are in a sad state of disrepair, will be 
demolished.

As soon as I announced this on the message board, I immediately found 
myself at the business end of a flaming response by a rabid preservationist 
who was vehemently opposed to seeing the old station houses demolished. 
Here is a portion of his response:

<<I went to EVERY SINGLE STATION along that branch, and every station was 
quaint and charming, and still in perfectly good and usable condition. They 
are some of the nicest stations on the system. This is one of the biggest 
wastes of money the CTA has ever come up with. All the Ravenswood stations 
need is a good cleaning!!!! I don't give a damn about elevator access; I 
want the old stations saved. If they can add an elevator and extend the 
platforms of the old stations, that's great. But the line will lose so much 
of it's character if the charming station houses are torn down... If the 
CTA can find a way to put an elevator into an old, beuitiful [sic] station 
without replacing the whole goddamn building that's one thing, but I 
certainly don't agree with their policy of ripping out an entire station 
just to add a simple elevator.>>

After going back and forth a few times, he just couldn't seem to comprehend 
why an elevator couldn't simply be "slipped into" the existing station 
houses. I was then forced to explain in great detail why there is nothing 
simple about adding an elevator:

"For one thing, all these stations have side platforms [as opposed to a 
single center platform], which means they require two elevators each. Also, 
an elevator isn't something that can just be "slipped into" an existing 
building, especially a building as tiny and cramped as the existing station 
houses. A typical elevator installation requires about 100 square feet of 
space for each shaft. An elevator pit must be dug to a depth of at least 
5-6 feet under the shaft, and there needs to be considerable space set 
aside for a machine room. In the case of hydraulic elevators, a shaft must 
also be drilled into the ground for the piston. There also must be adequate 
structural support for the entire assembly. The existing station houses 
don't even have enough space for their current usage patterns, to say 
nothing about the addition of two elevators and their required spaces, in 
addition to the other required mechanical and service spaces planned for 
the new stations."

And so on...

In this case, I happened to be strongly in favor of the modernization 
project, even though the new stations will likely be ugly utilitarian boxes 
that look more like detention facilities than transit stations. (A city 
with Chicago's rich architectural legacy deserves much better, but that's a 
topic for another forum.) However, this person's attitude struck me as 
being similar to a number of people I have encountered within the 
disability community regarding accessible buildings:

"Why can't they just add an elevator?" See above.

"Why can't they just build a ramp?" An ADA-compliant wheelchair ramp 
requires a minimum length of 12" for every 1" in rise, plus handrails and 
intermediate landings as required. There may or may not be enough room for 
such a ramp.

"Why can't they just add an accessible toilet stall?" Such a modification 
may or may not require relocating existing toilet fixtures, which in turn 
would require extensive modification to the plumbing behind the walls 
and/or below the floor, and the plumbing itself may or may not be buried in 
solid concrete. Also, building codes require a certain number of toilets 
per the occupancy load of a building, and it may or may not be a code 
violation to remove an adjacent toilet to make room for an accessible 
stall.

"Why can't they just widen that doorway?" There may or may not be a 
load-bearing structural member within the wall next to the existing door, 
limiting the opening's possible width. Or the swing of a wider door may or 
may not obstruct a required exit corridor, in violation of life safety 
codes.

You get the idea.

The moral of the story, in a nutshell: Be realistic. All newly-constructed 
public buildings, without question, should be fully accessible. And every 
reasonable effort should be made to insure existing buildings are as 
accessible as possible, but there will never come a day when every building 
on the planet is 100% accessible. That's just an unfortunate fact of life 
that people are going to have to learn to deal with. Even though a 
particular barrier may appear to be easily correctable, there is often more 
than meets the eye. On the flip side, a building owner may simply throw up 
his hands and say, "There's no readily achievable way I can correct this 
problem," whereas a creative architect may evaluate the situation and 
develop an innovative, relatively painless solution that may not have been 
completely obvious to the owner. At the very minimum, an investigation 
should be made to determine the specific course of action to be taken in 
each case.

Your local office of the American Institute of Architects can be an 
excellent resource in finding an architect or an architectural consultant 
that specializes in accessibility. Check out the AIA's main website at 
www.e-architect.com for more information.

-- David
Chicago, IL

David S. Cole
E-mail: DavidCole at NthWard.com
The Nth Ward: http://www.NthWard.com

"You will never truly love a city till you can love its alleys too."
-- Nelson Algren