AMERICAN HOTEL & MOTEL ASSOCIATION
1201 New York Avenue, N.W.
Washington, D.C. 20005

May 15, 2000
EXECUTIVE SUMMARY

History
In January 1998, the American Hotel and Motel Association (�AH&MA�) asked the TriData Corporation to study the relative frequency with which ADA compliant hotel and motel guest rooms were being used by travelers with disabilities (TWD) and to learn what those travelers desired in lodging accommodations. This summary report draws from that larger study to address only the issue raised in the pending NPRM issued 11/16/99 by the U.S. Access Board regarding the adequacy of the number of accessible guest rooms required of hotels under the Americans with Disabilities Act Accessibility Guidelines (�ADAAG�).

Findings
Overall, the data supports the contention that more accessible hotel guest rooms do not need to be added to the inventory of hotel and motel rooms currently available in the United States to meet present or even future demand. Further, the occupancy of such accessible guestrooms is so low as to suggest that the number of such guestrooms now required by ADAAG can be reduced without fear of having any material effect upon such availability. Taken as a whole, the analysis shows that there is ample room for improvement of the services rendered and the quality of the spaces designated as �accessible.� The analyses do not support, however, the contention there is an inadequate supply of accessible rooms. Less than 20 percent of the available hotel room-nights for hotel and motel guest accessible rooms are consumed each year. Not all of those accessible room-nights are even being used by TWD. Some of that occupancy is by able-bodied guests. As such, the true �occupancy� by TWD is overstated.

About three-quarters of the hotels surveyed indicated that they had not turned away (�turndowns�) any guest, with or without reservations, who wanted an accessible room in 1997, and more than 80 percent indicated that they had not walked (i.e., turned away a guest who had a confirmed reservation) any guest who sought an accessible room. Almost all-respondent properties (97 percent) indicated that they had turned away no guests in September and October (96 percent) of 1998. Thus more than 80% of TWD who sought accessible guestrooms were able to get the room of their choice as confirmed by both studies of hotel occupancy and the separate survey of TWD. The latter study reported that fully 18% of TWD do not even request accessible rooms when they travel, suggesting that not all TWD even need such unique accommodations.
This study supports two earlier studies, one by the California Hotel and Motel Association and one by the Florida Hotel and Motel Association, which were entered into testimony by AH&MA in hearings on the original ADAAG in 1991. Then, as now, about 1/10th of 1% of hotel guestroom demand is for �accessible� rooms, despite an approximate 4% requirement for such rooms in hotels in the current ADAAG, (see Section 9), a requirement clearly unwarranted and one which should be modestly reduced given the extraordinary cost associated with the construction of such rooms.

These observations combine to paint a picture of a resource (accessible hotel and motel rooms) that is mandated at a level that is not being fully utilized. No one doubts that there are some travelers with disabilities who show up at a property and are unable to be accommodated. Sloppy management practices do exist, and occasionally bookings fall through the cracks of a property reservations system, as with any guest, disabled or not. However, it would appear that there is little reason to mandate an increase in the number of accessible accommodations because the inventory that now exists is seriously underutilized. The data supports the opposite recommendation, that these numbers can be reduced without fear of having too few accessible rooms. In fact a 50% reduction in the current requirements would still leave the number of accessible room nights available at twenty times the actual demand. Travelers with disabilities themselves have indicated that they are usually well served by the number of accessible hotel and motel rooms available.

The study substantiates this: more accessible rooms are not needed - better accessible rooms and better-trained staffs are.

INTRODUCTION

This report was prepared by the American Hotel and Motel Association (AH&MA) and documents the hotel usage and accommodation needs of travelers with disabilities (TWD). This is the only known study of its kind and the only known current data on this subject. In January 1998, the AH&MA asked the TriData Corporation of Arlington, Virginia to study the relative frequency with which ADA-compliant hotel and motel guest rooms are being used by TWD and to learn what those travelers desire in lodging accommodations. 

This report draws from the larger TriData survey. Despite the acknowledged lack of data to support the ADAAG transient lodging guestroom requirements in 1991, in the intervening 9 years the Access Board has not undertaken any validation or demand studies to further evaluate this requirement.

METHODOLOGY

The project was broken into two main components - 

• an analysis of the occupancy rates of ADA-compliant guest rooms in AH&MA-member properties across the United States, and 
• a public opinion poll of the intended end-users of those rooms: travelers with disabilities.

TriData conducted two studies of the occupancy rate of ADA-compliant transient lodging rooms in AH&MA member hotels. 

The first was a retrospective analysis for all of 1997.

The second was a prospective count for September and October 1998.

Two questionnaires were developed and sent to two groups of AH&MA member properties. 

The first group included 600 properties drawn at random from the AH&MA membership database and about 300 properties drawn from the databases of large hotel chains. This group received questionnaires asking them to provide information on occupancy for the entire year of 1997. From this �retrospective� mailing, 271 responses were received, for a response rate of 30 percent.

A second questionnaire was sent to a group of 600 properties drawn at random from the AH&MA membership database and about 300 properties drawn from the databases of large hotel chains. This group received questionnaires asking them to provide occupancy information for the months of August, September, and October 1998. This second survey differed from the retrospective survey in that respondents were asked to gather the data contemporaneously - not retrospectively. Ultimately, the survey was released too late to include the data from August, so responses were only analyzed for the months of September and October 1998, two of the peak travel months for the lodging industry. From this �prospective� mailing, 372 responses were received, for a response rate of 41 percent.

Responses from both questionnaires were hand-entered into separate SPSS databases. Data were analyzed using SPSSTM v. 7.0 (SPSS, Inc., Chicago, IL).

Survey of Travelers With Disabilities

TriData Corporation prepared a form to survey travelers with disabilities (TWD). In order to learn more about the needs of TWD and the appropriate construction of the survey instrument, the draft form was distributed to attendees of the 1998 meeting of the Society for Advancement of Travel for the handicapped (SATH).  Additionally, TriData and AH&MA staff members visited the campus and met with personnel at Gallaudet University, the National Paralyzed Veterans of America, the National Association of the Deaf, and the American Council of the Blind.

The comments from these groups, as well as those of the SATH meeting attendees, were incorporated in the final survey form, which was printed in a computer-readable format and in alternate formats for the visually impaired. This completed survey form was distributed to nearly 1,300 TWD through several means, including:

distribution through travel agents specializing in TWD accommodations; distribution by TriData and AH&MA staff at the annual National Wheelchair Games in Pittsburgh, PA , July 9-11, 1998, and the annual meeting of the National Association for the Deaf in San Antonio, TX in July 4-11, 1998; distribution by representatives of Paralyzed Veterans of America at the Disabilities Expo in Chicago, IL; directly to interested person who requested them via the internet or telephone; distribution to members by the Bay State Federation of the Blind (Massachusetts).

Of the approximately 1,300 survey forms distributed, a total of 299 forms were returned providing a response rate of 23%. Responses from the forms were read into a SPSS database using an optical Scanner (NCS OpScan5). The alternate format forms for the visually impaired were hand-entered into the database. Data were analyzed using SPSSTM v. 7.0 (SPSS, Inc., Chicago, IL).

FINDINGS

The prospective and retrospective surveys of occupancy rates of ADA compliant rooms reinforced each other.  The questions were answered in a substantially similar manner across both surveys. In other words, although the percentages of people responding to a given question are not exactly the same between the two surveys, they are very close (and certainly always of the same magnitude). Because the surveys were sent to mutually exclusive samples, the closeness of the response percentages tends to confirm the validity of the responses.

An overwhelming majority of hotels in the U.S. at the time of this study were built before the new construction rules of the ADA became effective. This means that the property might not have accessible guestrooms unless it has undergone �alterations�. Properties that have been (or are being) altered need to provide a certain number of accessible rooms dependent upon their total room count, see ADAAG Section 9.

Table 1 shows the number of properties that were opened BEFORE January 25, 1993 (the effective date of the ADA for newly constructed hotels).

Table 3 shows the breakdown of the responses by the number of rooms that the property had. The ranges of the numbers of rooms parallel the ranges found in the ADAAG.

Table 4 shows the breakdown of properties indicating that such a notation is made in reservations.

In addition to noting requests for accessible rooms in the reservations record, about two-thirds of the properties surveyed indicated that they instruct reservation clerks to ask whether the guest will have any special needs. Table 5 shows the breakdown of properties indicating reservation clerks are so instructed.
 

Tables 7 and 8 record the frequency with which properties are unable to accommodate TWD. The survey examined two such measures: 

• the �turndown� rate (defined as an occurrence in which a guest arrived at a property without a reservation and asked for an accessible room but could not be accommodated, i.e., all the accessible guest rooms were occupied), and 
• the �walk� (defined as a guest arriving at a property with an accessible room reservation, but being declined accommodation because none were available, i.e., the accessible room was not held for the guest or the current guest did not vacate the room as scheduled).

As the surveys measured different time periods, the data are presented in different tables, Table 7 for the prospective survey and Table 8 for the retrospective survey.

Table 7: Turndowns Recorded in September and October 1998                  Table 8: Turndowns and Walks Recorded in 1997

As the data in Table 9 indicates, of available accessible room nights, less than 20% are actually consumed, a conclusion confirmed by both studies.
 

APPENDIX B

May 15, 2000

AMERICAN HOTEL & MOTEL ASSOCIATION
1201 New York Avenue, N.W.
Washington, D.C. 20005

Accessible and Usable Buildings and Facilities
OBJECTIONS

4.2.5 Forward Reach

Since the inception of accessibility codes in the 1960�s, the maximum unobstructed reach height has been 54� provided the clear floor space allows a parallel or side approach by a person who uses a wheelchair. The reach height of 48� was previously found to only apply to cases where: 1) the clear floor space did not allow a side approach and 2) an unobstructed forward approach was all that was available to reach the object. Prior to the current revision of this standard, the reach height of Little People of America (people of short stature) has not been considered. 

The Little People of America (LPA) claim that the failure of a public accommodation to provide access to facilities is discrimination on the basis of disability. The compelling evidence, which is driving the current proposed change, is based upon one study, Anthropometric National Survey of Adult Dwarfs, July 1995. This study found, based on a sample population of 163, that the average or mean unobstructed vertical reach height of dwarfs (i.e. individuals whose short stature is caused by a medical condition) born in the United States is 54 inches with a standard deviation of 6.8 inches. According to the study results, 19% of the population would not be able to reach an unobstructed height of 48 inches. Furthermore, a sample with only 163 observations is subject to fluctuation, which could further increase the number of persons unable to access the reach height to as much as 21% and still be within the customary 95% confidence interval. 

If the proposed reach height of 48 inches is acceptable to LPA, it implies that the exclusion of as much as 19% of the population is also acceptable. This percentage could easily be as much as 21% and is derived from their own study. This percentage selected is entirely arbitrary and if interpolated to represent the total U.S. dwarf population not served, approximately 6,300 persons would still not be able to reach the proposed height of 48 inches. Further, the study is based upon 163 observations and if we conducted a study on a different sample of respondents, we would obtain a different value for the mean. Therefore, the percentage or number served would vary.

At first glance, it appears the proposed change is both premature and lacks proper substantiation. No other studies have come forth yielding these same results on unobstructed reach height for dwarfs. Other handicapped groups or persons may yet come forward with similar, but contradictory evidence citing that reaching down the proposed additional 6 inches is equally impairing. Assuming the values generated by the study and the percentages recommended by LPA are accurate and appropriate, the proposed provisions would create or perpetuate an environment where disabled persons of a certain segment of the population cannot function. Therefore, the provisions would not be in the spirit of intent of the American with Disabilities Act. 
There is no basis or rationale for this committee to promulgate requirements based upon the arbitrary selection of an acceptable percentage of a disabled population. The proposed reduction in height is in itself discriminatory in that a significant portion of the affected population will be knowingly excluded from access to objects in places of public accommodation. This change, if approved, enables and fosters continued discrimination against a known population of disabled persons and may necessitate further upward adjustment as other affected populations come forth with contradicting concerns.

4.13.1.7 Thresholds at Doorways

The installation of thresholds as high as ¾� on exterior sliding doors between guestrooms and balconies or patios has not been adequately substantiated as creating a barrier to the wheels of a wheelchair. This provision protects properties against wind driven rain in hurricane and coastal areas. As this provision is found to apply to accessible guestrooms, it is excessive in the fact that the supply of accessible guestrooms far exceeds the demand for these rooms.

4.25.3.5.3 Location (Guestroom Visual Alarms)

In the past hotels were allowed to use portable systems that could be kept at the front desk and given out to any hearing impaired guest, thereby allowing them to stay in any room. Hotel guestrooms equipped with permanently installed visual fire alarms will require hardwired connections to a supervised fire alarm system and only these designated rooms will meet ADA requirements. This provision is excessive for the mandatory supply of designated guestrooms, 9% must be hearing impaired accessible guestrooms, exceeds the demand for such rooms and it limits choices available to disabled guests.