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National Endowment for the Arts ADA Tip Sheet


The 2010 ADA Standards for Accessible Design (2010 Standards) were published in the Federal Register on September 15, 2010, and will become mandatory after 18 months.

In the period between September 15, 2010, and March 15, 2012:

  • Places of public accommodation may choose between compliance with the 1991 ADA Standards or the 2010 Standards.
  • State and local governments may choose between compliance with the 1991 ADA Standards, the Uniform Federal Accessibility Standards (UFAS), or the 2010 Standards.

On and after March 15, 2012, the standards mentioned above will be replaced by the 2010 Standards, which become mandatory and enforceable, and must be applied to all new construction, renovations, modifications, alterations, and barrier removal.


A non-profit theater is planning two major renovations. The first renovation is currently in the design phase, is scheduled to start construction April 2011, and will be completed in April 2012. The theater is not going to start the design process on the second renovation until June 2012 for completion in June 2013. The theater can use either the 1991 Standards or the 2010 Standards on the first renovation but can only use the 2010 Standards on the second renovation.


Standards Specific to Assembly Areas

Assembly areas include spaces such as classrooms, lecture halls, meeting rooms, movie theaters, auditoriums, theaters, concert halls, performing arts centers, amphitheaters, arenas, and stadiums.

Most of these changes can be found in sections 221 and 802 of the 2010 Standards. The following are some of the relevant standards for arts and cultural organizations:

Dimensions: A single wheelchair space must be 36 inches wide, while two wheelchair spaces adjacent to one another need only be 33 inches wide each.

Path of Travel: Wheelchair spaces must be on an accessible route but may not overlap another wheelchair space or the circulation path.

• Note: This means that access to a wheelchair space cannot be through another wheelchair space, nor can the wheelchair space stick out into the aisle.

Dispersion of Wheelchair Spaces:

  • Box Seats: Wheelchair spaces must be provided and located in not fewer than 20% of all boxes.Wheelchair spaces must be dispersed vertically, horizontally, to all levels, and around the performance area, if seating encircles the stage.

  • Wheelchair spaces must provide spectators with choices of seating locations and viewing angles that are substantially equivalent to, or better than, seating for other spectators.

  • In stadium-style movie theaters, wheelchair spaces must be located within the rear 60% of the seats in the auditorium.

  • Wheelchair spaces generally should not be on temporary or movable platforms.

Lawn seating: There must be a wheelchair-accessible path of travel to lawn seating and any exterior overflow seating.

Companion Seats: At least one companion seat (fixed or movable, adjacent, and on the same level) must be provided for each wheelchair space, and be equivalent in size, quality, and comfort to other seats in the area.

Designated Aisle Seats: Designated aisle seats are those seats with folding or retractable armrests. Five percent of all aisle seats must be a designated aisle seat, identified as a designated aisle seat, and located close to accessible routes.

Number of Wheelchair Spaces Required: Use the following table to calculate how many wheelchair spaces must be provided:

2010 ADA Standards Number of Wheelchair Spaces in Assembly Areas 
Capacity of Seating (i.e. # of Seats)  Minimum # of Required Wheelchair Spaces
4 to 25 1
26 to 50 2
51 to 150 4
151 to 300 5
301 to 500 6
501 to 5000 6, plus 1 for each 150, or fraction thereof, between 501 through 5000 
5001 and over 36, plus 1 for each 200, or fraction thereof, over 5000 

New Requirements for Assistive Listening Systems (ALS)

You can find most of these changes in sections 219 and 706 of the 2010 Standards.

Requirements: ALSs are required where audible communication is integral to the use of the space, but are not required where audio amplification is not provided.

Hearing Aid Compatibility: 25% of the receivers must be hearing aid compatible, which means that the ALS receiver must be usable with an induction neckloop that interfaces with the telecoil in an individual’s personal hearing aid or cochlear implant.

Technical Requirements

  • Receivers must have a 1/8 inch (3.5 mm) standard monojack.

  • ALSs must be capable of providing sound pressure levels of 110 dB minimum and 118 dB maximum with a dynamic volume control range of 50 dB; the signalto-noise ratio for internally generated noise must be 18 dB minimum; and the peak clipping must not exceed 18 dB of clipping relative to the peaks of speech.

Number of Receivers Required: Use the following table to calculate how many receivers must be provided.

2010 ADA Standards Receivers for Assistive Listening Systems 

Capacity of Seating in Assembly Area 

Minimum # of Required Receivers 

Minimum # of Receivers Required to be Hearing-aid Compatible 

50 or less



51 to 200

2, plus 1 per 25 seats over 50 seats or fraction thereof 


201 to 500

2, plus 1 per 25 seats over 50 seats or fraction thereof 

1 per 4 receivers or fraction thereof 

501 to 1000

20, plus 1 per 33 seats over 500 seats or fraction thereof 

1 per 4 receivers or fraction thereof 

1001 to 2000

35, plus 1 per 50 seats over 1000 seats or fraction thereof

1 per 4 receivers or fraction thereof 

2001 and over

55 plus 1 per 100 seats over 2000 seats or fraction thereof 

1 per 4 receivers or fraction thereof 



Theater A has a maximum seating capacity of 2225. Per the previous chart, they are required to have 55 receivers (the minimum) plus 1 per 100 seats over 2000 seats or fraction thereof (the additional receivers).

Calculate the additional receivers using the chart above. Always round up.

  1. Calculate additional seats: 2225 (total seats) – 2000 = 225
  2. Divide by 100: 225/100 = 2.25

  3. Round up: 3

  4. Add the number of additional receivers to the minimum number required: 55+3= 58 receivers

Calculate the number of hearing-aid compatible receivers. (1 out of 4, or 25%). Always round up.

  1. Take the number of required receivers calculated above: 58
  2. Divide by 4: 58/4 = 14.5.

  3. Round up: 15 receivers.

Theater A is required to have 58 receivers, 15 of which must be hearing-aid compatible. 


State and Local Governments: Title II regulations at 28 CFR 35.151 and the 2004 ADAAG at 36 CFR part 1191, appendices B and D

Places of Public Accommodation: Title III regulations at 28 CFR part 36, subpart D; and the 2004 ADAAG at 36 CFR part 1191, appendices B and D


The 2010 regulations have incorporated an element-by-element “safe harbor” which exempts elements (which can be anything from a door knob to an entire room) that are currently in compliance with the 1991 ADA Standards from compliance or any immediate retrofit obligations under the 2010 Standards until the facility engages in a renovation, modification, alteration, or barrier removal. If an element never complied with the 1991 ADA Standards then there is no safe harbor for that element. Additionally, there is no safe harbor for elements not covered in the 1991 Standards including, but not limited to, swimming pools, amusement rides, play areas, and recreational boating facilities.


In 2005 a museum renovated restrooms and installed paper towel dispensers at 54 inches from the floor in order to be in compliance with the 1991 ADA Standards. The 2010 Standards require paper towel dispensers to be a maximum of 48 inches from the floor. Are they out of compliance?

No. Because the installed dispensers were in compliance with the 1991 ADA Standards, they are in a safe harbor under the new 2010 Standards. The museum will not need to re-install the paper towel dispensers in order to comply with the lower reach range in the 2010 standards until they renovate, alter, or modify the restroom.  


State and Local Governments: §35.150 (b)(2)(i) safe harbor

Places of Public Accommodation: §36.304 (d)(2)(i) safe harbor


In the past, regulations stipulated that once a level of accessibility had been achieved, the entity was required to keep that level of accessibility. However, the revised regulations have added an exception that allows for the reduction of accessible elements in a facility from the number required in the 1991 ADA Standards to those in the 2010 Standards. This exception is limited to physical elements in a facility covered by the 2010 Standards.


Under the 1991 ADA Standards, a theater with 5,000 seats was required to have 51 wheelchair accessible locations. Under the 2010 Standards, the requirements have been lowered such that the same theater would now only be required to have 36 wheelchair accessible locations. The exception in the 2010 Standards would allow the theater to reduce the number of wheelchair accessible locations from 51 to 36. 


State and Local Governments: §35.133 (c) maintenance of accessible features

Places of Public Accommodation: §36.211 (c) maintenance of accessible features


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