AMERICAN GAMING ASSOCIATION
FRANK J. FAHRENKOPF, JR. President & CEO
Ofice of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
1331 F Street, N.W. Suite 1000
Washington, D.C. 20004-1111
Subject: Response to Request for Comments
Americans with Disabilities Act Accessibility Guidelines for Large Passenger Vessels
Docket No. 2004-1
Dear Sir or Madam:
In its revised Americans with Disabilities Act Accessibility Guidelines for Large Passenger Vessels, published in the Federal Register on July 7,2006, the Access Board requested comment on the following question:
The Board is aware that some passenger vessels have spaces which contain a large number of the same type of fixed elements, such as slot machines. In other sections of the draft guidelines, where multiple elements or spaces of the same type are provided, only a certain number are required to comply. For example, V224 does not require every guest room to be accessible, and V228 does not require every vending machine to comply with V309. Should the Board add an exception to V205 which would address situations where a large number of operable parts of the same type are provided in an accessible space? Should five percent, but not less than one, of each type be used? . ..
The American Gaming Association (AGA) agrees that the Access Board's proposed "five percent, but not less than one, of each type [of fixed element]" standard - the same standard as is applied to mail boxes under V228.2 - is appropriately applied to the fixed elements, such as slot machines, that are present on gaming floors. This exception would be supported by AGA.
Frank J. Fahrenkopf, Jr.
1299 PENNSYLVANIA AVENUE, NW - SUITE 1175 - WASHINGTON, DC 20004 202.552-2675 Fax 202-552-2676 www.amertcangaming.org