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December 15, 2014 Bowers Museum, SSA Project #14048 SALLY SWANSON AACWT113S fret. Knee and toe space applies generally to forward approach conditions and is to be provided when a turning or maneuvering space or a clear floor space passes under an accessible facility element. Examples of such spaces include the area under a work or sales counter, under a lavatory or drinking fountain, under an interpretive table display or similar type conditions. Knee space is required to be 30" wide minimum and is defined as the area between 9" and 27" above the finish floor (AFF). It is permitted to extend to a maximum of 25" in depth under an element. That is not to say that an element cannot have greater than 25" in clear depth but rather, to say that only 25" D maximum is allowed for the "required" portion thereof. Where the knee space is an extension of the required clear space the dimensions reduce. In these conditions, the depth is limited to an 11" projection at 9" AFF and 8" at a point 27" AFF. Between 9" and 27" AFF, the knee space clearance reduces on a straight -line ratio of 1 "D:6 "H (see the graphic below). As noted above, open spaces provided beyond the required spaces are not permitted to be included within the clear or knee space allowances. Toe space is defined as the area from 0" to 9" AFF. Similar to knee space, the toe space may extend to a maximum of 25" in depth under an element. Where part of the required clear floor space, the depth of the toe space is limited to a 6" projection beyond the required and available knee space. Therefore, if conditions permit, the toe space is limited to 11" (for the knee space) plus an additional 6" for the toe space or, 17" maximum total. Section 4.2.3 of the 1991 Standards and Section 304.3 of the 2010 Standards allow turning space to be either a circular space or a T- shaped space. Section 304.3 permits turning space to include knee and toe clearance complying with section 306. Section 4.2.3 of the 1991 Standards did not specifically permit turning space to include knee and toe clearance. The Department of Justice recognizes that the technical specifications for T- shaped and circular turning spaces in the 1991 and 2010 Standards, which are based on manual wheelchair dimensions, may not adequately meet the needs of individuals using larger electric scooters. However, there is no consensus about the appropriate dimension on which to base revised requirements. The Access Board continues to conduct research to study this issue in order to determine if new requirements are warranted. The Department plans to wait for the results of this study and action by the Access Board before considering any changes to the Department's rules. The Department has issued a statement indicating that covered entities may wish to consider providing more than the minimum amount of turning space in confined spaces where a turn will be required. Appendix section A4.2.3 and Fig. A2 of the 1991 Standards provide guidance on additional space for making a smooth turn without bumping into surrounding objects. December 15, 2014 SSA Project #14048 Page 21 of 28