The Historic Theater Entrance
A 1920s downtown theater is being rehabilitated. The main entrance has three doors: a central pair of double doors and two single side doors. The central doors are 32 inches clear; the side doors are 30 inches clear. There are two steps up from the sidewalk to the lobby, and the ticket counter is 42 inches high with no lowered section. The project is a certified historic structure, and the owner wants to preserve the original door surrounds and the stepped entry. The scope includes new finishes, a new box office window, and replacement of the lobby lighting. The owner proposes to keep the entrance as-is and add a portable ramp at the side door during events only.
1. Which elements of the scope trigger accessibility obligations, and how does historic status affect them?
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The project is an alteration, and alterations must comply with accessibility requirements to the maximum extent feasible. Historic status does not exempt the project; it changes the analysis. For a certified historic structure, the applicable standard allows alternatives when strict compliance would threaten or destroy the historic significance of the feature or the structure. That determination must be documented - it is not a self-certification by the owner. Here the new box office window and the altered lobby are clearly within scope and must comply: the ticket counter needs a lowered section at 36 inches maximum above the finished floor with knee clearance, or an equivalent accessible transaction point. The lighting replacement is in scope but is not itself an accessibility feature unless it affects means of egress or signage. The stepped entry and the door widths are the contested items; they must be evaluated under the historic-structure provision, not simply preserved by preference.
2. Assess the owner's proposal to keep the stepped entry and use a portable ramp at the side door only during events.
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The proposal fails on several grounds. First, a portable ramp deployed only during events is not a compliant accessible route; the route must be available whenever the facility is open, and a temporary device that staff must install is not an independent means of access. Second, the side door at 30 inches clear is below the 32-inch minimum clear width for a door in an accessible route, so even the side-door route is noncompliant. Third, a portable ramp must meet slope, edge protection, and landing requirements to be usable, and event-day deployment rarely does. Fourth, the entrance is the primary means of access; the accessible route must connect the public way and accessible parking to the entrance and through the lobby. The correct approach: evaluate whether the steps can be modified (a ramp integrated into the lobby, a platform lift, or regrading) without destroying historic significance; if strict compliance is infeasible, document the maximum extent feasible alternative - for example, a permanent accessible entrance at a side location with a compliant door and a permanent ramp or lift, signed as the accessible entrance.
3. What documentation should accompany the historic-structure determination?
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The file should contain: (1) verification of certified historic status (the applicable listing or certification); (2) a written finding identifying each feature where strict compliance is claimed to be infeasible and the specific threat to historic significance - not a general statement that the building is old; (3) the alternative selected and why it provides access to the maximum extent feasible, including the route, door widths, and any lift or ramp; (4) consultation with the appropriate historic preservation authority, if the jurisdiction requires it; and (5) as-built verification after construction showing the alternative actually works - door clear widths measured with the door open at 90 degrees, ramp slope measured, counter height measured. The determination should be made before construction, not retrofitted to excuse a completed design. If the jurisdiction does not recognize the certification, the standard alteration rules apply without the historic exception.