T.

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XX

DEC 22

XX
XX
Lake Charles, Louisiana 70601

Dear XX

The Architectural and Transportation Barriers compliance

Board (Access Board) has asked us to respond to your letter
asking about the application of the Americans with Disabilities
Act (ADA) to places of public accommodation that have exterior
doors that are heavy and difficult to open. I apologize for our
delay in responding to you.

The ADA authorizes the Department of Justice to provide

technical assistance to individuals and entities that have rights
or responsibilities under the Act. This letter provides informal
guidance to assist you in understanding the ADA and the
Department's regulation. However, this technical assistance does
not constitute a legal interpretation of the ADA, and it is not
binding on the Department.

Your letter addresses several issues pertaining to building

entrances, but your primary concern appears to be that certain
places of public accommodation have not installed automatic doors
at the entrances to their facilities. Places of public
accommodation have an obligation under title III to remove
architectural barriers to access where such removal is readily
achievable. However, where the ADA Standards for Accessible
Design for new construction specify requirements for a particular
element, the barrier removal obligation does not require existing
facilities to exceed the Standards. The ADA Standards for
Accessible Design applicable to new construction do not require
electric doors, nor do they set a limit for the maximum door
opening force for exterior hinged doors. See the ADA Standards
for Accessible Design sections 4.13.11 and 4.13.12 (Appendix A to
the enclosed regulation). Therefore, because the ADA Standards
specifically do not require the installation of electric doors in
new buildings, their installation is not required under the ADA's
barrier removal requirements for existing buildings.
cc: Records, Chrono, Wodatch, Blizard, FOIA, Friedlander
n:\Udd\blizard\adaltrs\ XX (b)(6)

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For your information, I am enclosing a copy of this

Department's regulation implementing title III of the ADA and the
Title III Technical Assistance Manual. These documents further
explain the requirements of the ADA that apply to places of
public accommodation.

I hope that this information is helpful to you.

Sincerely,

John L. Wodatch
Chief
Public Access Section

Enclosures

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