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

Section 704.4 provides specifications for TTYs. The proposed rule included requirements so that TTYs were accessible to persons who use wheelchairs. This included a requirement that the touch surface of TTY keypads be 30 to 34 inches high (704.4.1).

Comment. Many commenters indicated that TTYs are mounted too low to be used comfortably by people not using wheelchairs. According to these commenters, compliance with wheelchair access provisions greatly compromises their usability by the majority of persons with hearing or speech impairments who do not use wheelchairs. Commenters urged that a higher surface height for TTY keypads be specified. Organizations representing persons who are deaf recommended a keyboard height of 33 to 35 inches where users are expected to stand. A manufacturer of TTY-equipped pay telephones indicated that its products provide TTY keypads at a height of 36 to 40 inches and requested that this range be permitted.

Response. The Board has revised the specified height of TTY keypads from the proposed range of 30 to 34 inches to a minimum of 34 inches (704.4.1). In addition, the Board has removed other specifications concerning wheelchair access, which is consistent with the original ADAAG. These specifications include a requirement that the operable parts of both the TTY and the telephone be accessible according to section 309, which specifies accessible reach ranges, and provide clear floor space for a forward approach to the TTY. However, these changes do not impact the requirements for other types of telephones required to be wheelchair accessible according to section 704.2.

Comment. The proposed rule provided an exception from the height and clearance requirements for TTYs at telephones located in cubicles equipped with fixed seats (704.4.1). As proposed, this exception applied only to assembly occupancies and allowed half of TTYs at telephones with seats not to comply. Comments recommended that this exception apply to other types of facilities since seats at phones may provide a desired convenience for TTY users.

Response. As a result of the changes concerning wheelchair access, the exception applies only to the specified keypad height and allows a height below 34 inches where seats are provided at telephones with TTYs. In the final rule, the Board has broadened this exception to apply to all telephones with seats in any type of facility.

Comment. The requirements for TTYs do not address the height of display screens.

Due to the typical character size displayed, users must be in close proximity to the screen. The Board requested information on TTY screen heights that are appropriate for people who use wheelchairs and for standing persons and whether the requirement for ATM display screens is appropriate for TTYs as well (Question 29). Little information was received in response to this question. Respondents to this question reiterated their concern about wheelchair access resulting in TTYs that are too low for persons who are standing. Other commenters recommended that research be conducted to develop information on the appropriate height of display screens.

Response. The Board has not included any specifications concerning the height of TTY display screens in the final rule.


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