Accessible Teeing Grounds, Putting Greens and Weather Shelters
The Department’s proposed requirements mandate an accessible (pedestrian) route that connects all accessible elements within the boundary of the golf course and facility, including teeing grounds, putting greens, and weather shelters. Requiring access to necessary features of a golf course ensures that persons with mobility disabilities may fully and equally participate in a recreational activity.
From an economic perspective, the Department’s RIA (“Regulatory Impact Analysis”) assumes that virtually every tee and putting green on an existing course will need to be regraded in order to provide compliant accessible (pedestrian) routes to those features. However, the Department’s proposal also excuses compliance with the requirement for an accessible (pedestrian) route so long as a ‘golf car passage’ (i.e. the path typically used by golf cars) is otherwise provided to the teeing ground, putting green, or other accessible element of the course. Because it is likely that most public and private golf courses in the United States already provide golf passages to most or all holes, the actual costs of this requirement for owners and operators of existing golf courses should be reduced with little to no practical loss to accessibility.
Question 6 (NPRM): The Department seeks information from the owners and operators of golf courses, both public and private, on the extent to which the courses already have golf car passages to teeing grounds, putting greens, and weather shelters, and if so, whether they intend to avail themselves of the proposed exception.
Model Comment: Compliance with the Department’s “accessible (pedestrian) route” requirement should only be excused by a “golf car passage” if the golf car passage provides unobstructed access to the edge of and onto the “teeing ground, putting green, or other accessible element of the course” so that an accessible golf car, or standard golf car, can have full and complete access to those elements of the golf course. In other words, full and equal access is not provided if a golfer is required to navigate a steep climb up or down a hill or a flight of stairs in order to gain access the “teeing ground, putting green, or other accessible element of the course.”
Ultimately, the Department inquired whether it should raise this requirement with the Access Board for further consideration. Based on the fact that the actual cost will likely be far less than projected, given the RIA’s extremely tenuous assumption (that virtually all tees and putting greens will have to be regraded), and that access to tees and greens means – for golfers with mobility impairments – the difference between playing and not playing, we urge the Department to include the current standard without asking the Access Board to revisit it.