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36 CFR Parts 1190 and 1191 ADA and ABA Accessibility Guidelines - Preamble (Discussion of Comments and Changes)

Comment. Commenters expressed concern that the replacement of telephones would trigger more extensive alterations, such as a requirement to lower a telephone installed at 54 inches (currently permitted by ADAAG) to 48 inches.

Response. Where elements are altered or replaced they must comply with these guidelines. However, in some cases the altered element is part of a larger element which is itself not altered. For example, pay telephone providers sometimes replace existing telephones with new telephones and, as part of the telephone replacement project, they do not replace or alter the existing telephone enclosures or pedestals. The new telephones, when replaced, must provide a volume control in compliance with section 704.3 that provides up to 20 decibels of gain; original ADAAG 4.31.5(2) only required 18 decibels of gain. However, the existing unaltered telephone enclosures or pedestals need not be lowered so that the telephones comply with the new 48 inch reach requirement established in section 308. Similarly, if a narrow door is replaced, the doorway need not be widened as a consequence of the door replacement. However, if new operating hardware is provided for the door, the hardware must comply with section 404.2.7.

Comment. Commenters indicated that it is common practice to reduce the number of existing telephones in telephone banks in order to reconcile the supply of pay telephones with the demand; noting also an overall decrease in the demand for pay telephones. The comments requested clarification as to whether the removal of an inaccessible pay telephone would be an alteration that would trigger a requirement to lower an adjacent wheelchair accessible pay telephone from 54 inches (currently permitted by ADAAG) to 48 inches.

Response. Inaccessible pay telephones may be removed without triggering requirements for lowering adjacent wheelchair accessible pay telephones, provided that the telephone enclosure or pedestal is not altered when telephones are removed.


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