Historic Preservation - Technical Procedures
- Handicapped Accessibility Planning Guidance
- Procedure code:
- Center For Public Buildings
- General Requirements
- Regulatory Requirements
- Last Modified:
- Handicapped Accessibility Planning Guidance
- Last Modified:
HANDICAPPED ACCESSIBILITY PLANNING
Federal Buildings serve the public and receive substantial public visitation. It is the desire of GSA to make the programs and facilities at all locations accessible to disabled individuals and groups. For historic properties, the objective of GSA is to make programs accessible while protecting the historic fabric of the property.
There is a legislative and regulatory history to provide guidance in the accessibility planning. Important regulatory documents include the following:
The Architectural Barriers Act of 1968
The Rehabilitation Act of 1973
The Americans with Disabilities Act (ADA)
The Uniform Federal Accessibility Standards (UFAS)
For purposes of accessibility planning, it is recommended that the Uniform Federal Accessibility Standards (UFAS) be the guiding policy. Several Federal agencies were signatories to UFAS, including the General Services Administration (GSA) and the U.S. Postal Service, however, it remains up to the individual agencies to establish policies with regard to specific properties and to implement those policies. Even for agencies and tenants who were not a signatory to UFAS, these standards represent the best guidance for a Federal agency to adopt in its accessibility planning process. Other documents as noted above and numerous publications on making historic properties accessible may be used for additional background.
Congress recognizes that the preservation of historic properties is
in the national interest and that, in some cases, full compliance
with ADA or UFAS would cause loss or damage to historic building
fabric and loss of historic or architectural character. Alternative
provisions for historic properties are included in both the
Americans with Disabilities Act Accessibility Guidelines (ADAAG)
and UFAS. When compliance will result in unacceptable loss of
fabric or character, deviations from the guidelines are allowed.
This places the burden on the administrators of historic properties
to plan for accessibility by balancing the need for access with the
protection of historic building(s). Removal of architectural
barriers should always be a prime objective. However, when the
required modifications to achieve this objective potentially cause
irreversible damage or loss of historic fabric, alternative means
of program accessibility may be utilized. This can include
alternative entrances, access to limited areas, reduced restroom
requirements and the development of special or assistive programs.
In planning for accessibility in any facility, a process is needed
to guide decision making and assure maximum compliance without loss
of character. The following three-step hierarchy is recommended,
based on guidance from the National Park Service, in the
application of ADA and UFAS.
I. Recognize that to the maximum extent possible historic
buildings should be as accessible as other buildings.
II. When a loss of architectural character or
integrity would result from full compliance,
apply alternative standards and seek to
provide at least:
- One accessible entrance
- One accessible restroom
- One accessible route
III. When an unacceptable loss of historic fabric
or architectural character would result from
the treatments in item II above, then
'alternative experiences' may be developed.
Alternative experiences could include audio-
visual presentation of inaccessible areas,
staff assigned to accessible areas, or other
innovative means of program delivery.
In developing a final accessibility plan for a specific building,
the following process is recommended:
- Identify significant features
- Determine accessibility needs
- Understand products and solutions
- Evaluate options.
This process has been followed at a preliminary level or planning
level to prepare recommendations for this report.
STEP 1 - IDENTIFICATION OF SIGNIFICANT FEATURES
The significant character-defining features of some GSA historic
buildings have been identified in the individual Historic Building
Preservation Plan, (HBPP) reports, or Historic Structure Reports
(HSR's). Contact the Regional Historic Preservation Officer,
(RHPO), to determine if either of these studies has been developed
for historic properties in question. The HBPP program was
developed for GSA and includes a feature rating system to indicate
the relative value of each component inventoried. This six-level
rating system is based on National Register of Historic Places
guidelines and the Secretary of Interior's Standards for Historic
Preservation projects. Features are rated as follows:
1. Preserve - repair if deteriorated.
2. Preserve - replace-in-kind if deteriorated.
3. Preserve if Possible - replace with compatible new
4. Preserve Unless There is Compelling Reason to Remove.
5. Remove, Alter or Replace.
6. No Treatment Specified; No Cultural Value.
By reviewing the feature ratings when planning future modifications
or repair projects, planners and designers can determine which
features should not be damaged, changed or removed, i.e., features
rated as 1's or 2's. Conversely, features which have less
significance can also be identified so that changes can be planned
for areas and features which are not the primary contributors to
the property, such as features rated 5 or 6.
The historic ratings are printed adjacent to each feature name on
the left margin of the reports.
STEP 2 - DETERMINING ACCESSIBILITY NEEDS
Management may do additional planning and survey work to develop a
formal statement of accessibility needs and objectives. However,
a preliminary review of current operations indicates that visitors
come to Federal buildings for many reasons, including but not
limited to: business with the Postal Service, Courts, or any
Federal agency tenant; work required by their jobs; supporting
systems in place at the building, or visiting to appreciate the
historic character of the public spaces.
GSA may wish to determine that, in any particular building,
there may be no accessibility needs for the non-public accessportions of that building. If there
are disabled staff working in
the facilities, planning should be undertaken to address the
particular needs and circumstances of the individual(s) and their
work assignments. Conditions may change after the "accessibility
needs" determination has been made, so that accessibility planning
should be looked at as an ongoing process.
Areas of the building may have different requirements for access,
as well as different levels of historic significance. In some
cases it may be difficult or impossible to modify portions of a
historic building to permit access without changes which will cause
a loss of historic character. In cases like this, planners and
designers may wish to consider "alternative" techniques, which
could include making the program or service available in areas
which are accessible, or presenting the information from the non-
accessible spaces in a presentation or exhibit in accessible
Difficult situations with conflicting program needs, can be
complicated, and require creativity and initiative to find
satisfactory solutions. The needs determination is a critical step
in the overall process. For that reason, every effort should be
made to involve the appropriate parties and resources from Field
Offices and the Regions, and/or other experts as needed, in
developing the needs statement, and proposing alternatives where
STEP 3 - UNDERSTAND PRODUCTS AND SOLUTIONS
Once the Needs Determination has been developed in Step 2 above,
there may be a need for products and solutions beyond the familiar
restroom equipment and accessories. When specific needs for
products and solutions occur, there are generally centers of
information on accessibility planning, products and solutions in
each state, which can be contacted for consultation. These centers
are often associated with the major state universities in each
state. They should be used appropriately along with GSA sources in
the development of proposed solutions.
STEP 4- EVALUATING THE OPTIONS
A series of preliminary options is available for classifying areas
within the buildings as public-use and non-public use. In
addition, sources (HBPP's and HSR's) were identified to classify
areas and components of the buildings based on their historical and
architectural significance. All of these factors should be
considered by GSA in developing an accessibility plan for each
building. Other factors should be considered as appropriate. Once
there is reasonable confidence that the needs and objectives for
accessibility are clear, then the objectives and policy for the
building in question should be stated as a basis for action.
In conclusion, GSA staff should recognize that maintaining a viable
accessibility plan is a dynamic process. The plan should be
reviewed annually, or more frequently if needed. Changes in
building use, staffing, visitation or technology may change the
balance achieved in the present plan and require changes in the
plan and/or the facilities.
For additional guidance in accessibility planning, see BPP
procedures 01060-05-S "UFAS 4.1.7 Accessibility Standards for
Historic Buildings", 01091-01-S "State Historic Preservation Office
and ADA Technical Assistance Resource List", 01100-09-S
"Accessibility Checklist for Historic Properties", 01100-10-S
"Americans with Disabilities Act: Checklist for Barrier Removal",
and 01100-11-S "Making Historic Properties Accessible".
END OF SECTION