Government Regulations

Important ADA Changes Affecting Mini Golf!

Last month, the U.S. Department of Justice (the Department) released proposed rules regarding compliance with the Americans with Disabilities Act (ADA). These rules adopt provisions of the Americans With Disabilities Act and Architectural Barriers Act Accessibility Guidelines (2004 ADAAG) which were published by the Architectural and Transportation Barriers and Compliance Board (Access Board) on July 22, 2004.The rules apply to all areas of public accommodation, but contain several specific provisions for miniature golf courses.

IALEI, the International Association of Amusement Parks and Attractions (IAAPA) and the Miniature Golf Association of the United States (MGAUS) are working together to coordinate the industry’s message on this matter.

This is probably the most important issue the miniature golf industry has ever faced!

Below is a list of critical issues addressed in the new regulations, but we strongly encourage you to read the entire report to fully comprehend all of the potential implications of the new regulations on the miniature golf community.

We are asking all miniature golf course owners to submit comments on these issues and other concerns regarding the regulations to the Department of Justice and the IAAPA Government Relations Department. To submit a comment for the record visit the Regulations.gov webpage, then e-mail it to us.

This is the industry’s chance to affect the regulations before they are put into place. We hope you will respond promptly.

Critical Issues

Extend the comment period to 150 days. We would like to ask the Department of Justice to extend the comment period on the new rules. Currently, the comment period expires August 17. As this is the height of the season for the attractions industry, IALEI believes more time should be given for members to examine these complicated proposals.

Potential exception for certain existing courses. The 2004 ADAAG states at least fifty percent (50%) of the holes on miniature golf courses should be accessible and connected to an accessible route. The Department is considering creating an exception for existing miniature golf facilities that are of a limited total square footage, have a limited amount of available space within the course, or were designed with extreme elevation changes. The Department is soliciting feedback on the parameters that should be used to determine whether a miniature golf course should be exempted if this exception were created. We urge IALEI members to support this option and call on IALEI members with design expertise to aid in the creation of parameters.

ADA Resources
ADA Miniature Golf Report

   Regulations.gov

    DOJ ADA Reference Page

   Talking Points for Media
Waterpark Information
Amusement Facilities Information
Contact IALEI

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Accessible route. The 2004 ADAAG states the accessible holes on a miniature golf course should be connected to an accessible route. The current requirement is that those holes be consecutive, with one break permissible in the sequence of accessible holes, if the last hole in the sequence is the last hole on the course. The Department is considering allowing “multiple breaks” in the sequence of holes, provided the accessible holes are connected by an accessible route. We believe this will give golfers with a disability a chance to enjoy more of the landscaping, water elements and theme structures that make miniature golf a unique recreation design of miniature golf courses. We urge IALEI members to support this option.

Course Alterations. This is an area of particular concern to the committee. Currently, issues such as re-carpeting of miniature golf holes and other “normal maintenance tasks” would be classified as an “alteration”. It is not uncommon for some owners to re-carpet their courses each year as part of normal maintenance. This designation (Alteration) requires additional work and expense due to the requirement of allotting an additional 20% of the cost of “alterations” to create an “accessible path of travel” to/from the altered area.
Worn carpeting and other routine maintenance items can create safety issues to all guests if not addressed on a regular basis. These issues can fundamentally alter the quality and enjoyment of the miniature golf experience when left unchecked. We would like the Department to reclassify these types of issues. All tasks done on a regular basis should NOT be considered an alteration; they should be classified as “Regular Maintenance.” We strongly encourage IALEI members to list these types of regular miniature golf course maintenance items in their comments to the DOJ.

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