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8.1 Number of Facilities

Existing Facilities

The 1997 Economic Census counted 1,041 miniature golf courses operated by private entities.63 This number does not include facilities such as family entertainment centers, amusement parks, motels, hotels, resorts, and recreational vehicle parks and camps that operate miniature golf courses, but the activity does not account for the major portion of the facility’s receipts. Public parks and recreation districts may also operate miniature golf courses. The Miniature Golf Association United States (MGAUS) estimated there are 7,500 to 10,000 existing miniature golf courses, including custom design and modular courses.64

New Construction

The MGAUS estimated 550 new custom design and 850 new modular miniature golf courses would be constructed over the next five years. Based on the MGAUS estimate and interviews with companies that make miniature golf courses, we estimated that 150 new custom design and 170 new modular miniature golf courses would be constructed each year.

Small Entities

For miniature golf courses operated by private entities, using the methodology described in Chapter 2, we estimated 100 percent are small entities. For miniature golf courses operated by public entities, we assumed the percentage operated by small governmental jurisdictions is the same as in Table 2.1.

8.2 Final Guidelines

Table 8.1 summarizes the final guidelines for miniature golf courses.

Table 8.1 - Final Guidelines: Miniature Golf

Section Requirement

15.5.1 General

Application


Newly designed and constructed and altered miniature golf courses must comply with 15.5.

15.5.2 Accessible Holes

Scoping

Exception - Consecutive Accessible Holes


At least 50% of holes must be accessible. Accessible holes must be consecutive.

One break in sequence of consecutive accessible holes permitted, provided last hole on course is last hole in sequence.

15.5.3 Accessible Route

General

Exceptions - Accessible Route Located on Playing Surface

Accessible Route Adjacent to Playing Surface

Accessible route must connect course entrance and start of play area of each accessible hole. Course must be configured to allow exit from last accessible hole to course entrance/exit without traveling back through holes.

Where accessible route located on playing surface, carpet and handrail requirements do not apply; 1 inch maximum curb permitted for 32 inches minimum width to contain ball; 1:4 maximum slope permitted for 4 inch maximum rise; landings required by 4.8.4 permitted to be 48 inches minimum in length; landings required by 4.8.4(3) permitted to be 48 inches by 60 inches minimum; and landing slopes permitted to be 1:20 maximum.

Where accessible route located adjacent to playing surface, accessible route requirements apply.

15.5.4 Start of Play Areas

General


Start of play areas at accessible holes must be 48 inches by 60 inches minimum and have slopes not steeper than 1:48.

15.5.5 Golf Club Reach Range

General


All areas within accessible holes where golf balls rest must be within 36 inches maximum of accessible route having maximum slope of 1:20 for 48 inch length.
 

 

8.3 Alternatives

Table 8.2 presents the alternatives considered in the proposed guidelines and final guidelines. The significant comments raised during the public comment period are summarized in the preamble to the final rule, along with the Access Board’s assessment of the comments and the reasons for selecting the alternative adopted in the final guidelines. The Access Board minimized the significant economic impact of the final guidelines by requiring at least 50 percent of holes on miniature golf courses to be accessible, and permitting one break in the sequence of accessible holes, provided the last hole on the course is the last hole in the sequence. The final guidelines also allow designers and operators greater flexibility in applying the accessible route requirements in ADAAG to new and altered miniature golf courses.65

Table 8.2 - Miniature Golf Alternatives

Item Proposed Guidelines Final Guidelines
Accessible Holes - Scoping Each hole must be accessible. Exception permits at least 50% of elevated holes to be accessible. At least 50% of holes must be accessible. Accessible holes must be consecutive. Exception permits one break in sequence of consecutive accessible holes, provided last hole on course is last hole in sequence.
Accessible Route - Curbs Readily removable curbs permitted where accessible route intersects playing surface. One inch maximum curb permitted for 32 inches minimum width where accessible route intersects playing surface.
Accessible Route Located on Playing Surface - Exceptions Where accessible route located on playing surface, handrail requirements do not apply and 1:4 maximum slope permitted for 4 inch maximum rise. Where accessible route located on playing surface, carpet and handrail requirements do not apply; 1:4 maximum slope permitted for 4 inch maximum rise; landings required by 4.8.4 permitted to be 48 inches minimum in length; landings required by 4.8.4(3) permitted to be 48 inches by 60 inches minimum; and landing slopes permitted to be 1:20 maximum.
Start of Play Areas Start of play areas at accessible holes must be 60 inches by 60 inches minimum and have slopes not steeper than 1:48. Start of play areas at accessible holes must be 48 inches by 60 inches minimum and have slopes not steeper than 1:48.
Golf Club Reach Range Level areas within accessible holes where golf balls rest must be within 27 inches maximum of accessible route with 1:20 maximum slope. All areas within accessible holes where golf balls rest must be within 36 inches maximum of accessible route having maximum slope of 1:20 for 48 inch length.
 

 

8.4 New Construction Impacts

To better understand the new construction impacts, we interviewed several companies that make custom design and modular miniature golf courses.66 These courses are constructed outdoors and indoors.

Custom Design Courses

Although each company considered its designs to be unique, custom design miniature golf courses can generally be divided into three types: low profile courses, challenge courses, and adventure style courses. We examined the potential impacts of the final guidelines in terms of size of the course and additional construction costs.

The final guidelines generally would not require an increase in the size of the course, except possibly for the high end adventure style courses that design accessible holes into the side of a mountain and need additional space for ramps. However, the companies stated that the final guidelines would have an impact on the selection of sites. Land that is low priced like landfills, mountains, and irregular sites may be more expensive to develop. Some developers may decide not to build miniature golf courses on such sites, or may decide to acquire more expensive sites that are less expensive to develop.

Modular Courses

Modular courses are pre-engineered and manufactured off site, and then installed at a site. The courses may be permanently installed, or temporarily installed. The impacts will vary depending on whether the course is installed indoors or outdoors.

For purposes of this assessment, we assumed the final guidelines will add $5,000 to the cost of new modular courses for providing accessible routes around at least 50 percent of the holes. The total annual compliance costs for new modular courses are $0.9 million.

Revenues and Profitability

The MGAUS has expressed concern that the real financial impact of the final guidelines is not the initial construction costs, but the long term effect on revenues and profitability. The MGAUS believes that making new miniature golf courses accessible would “adversely affect the quality and recreational entertainment of the miniature golf experience in an increasingly competitive market place (i.e., reducing the miniature golf experience to the lowest common denominator, instead of offering the high quality and value experience for all players regardless of ability or disability . . .”). The Access Board has recognized the industry’s concerns and has modified the final guidelines to require at least 50 percent of the holes on new miniature golf courses to be accessible. In the absence of the final guidelines, enforcement action by the Department of Justice or litigation could result in 100 percent of holes being accessible. Many of the companies that custom design miniature golf courses said they are using the draft final guidelines to design new courses. Some companies said they have been designing accessible courses for several years. None of the companies presented information that an accessible course they designed was unprofitable. Most of the companies said they can design a course that provides high quality recreational entertainment and complies with the final guidelines. The only company that expressed reservations about the guidelines compromising designs builds high end adventure style courses.

8.5 Alterations Impacts

The alterations impacts are minimal. Miniature golf courses typically do not replace or reconstruct holes unless the holes are unplayable because of problems such as the ball failing to roll true, or the ball being too easily hit outside the hole into landscape and waterscape areas. Most of the alterations involve changes to landscaping, themeing, hole carpeting, and hole edging. These types of alterations would not generally trigger accessible route requirements.

8.6 Total Costs

For miniature golf courses, the total annual compliance costs are $5.4 million.