My Comments to the DOJ

As promised, here are my comments to the DOJ regarding their proposed changes to the ADAAG; more specifically about the room blocking issue.

Candy B. Harrington
Emerging Horizons
P.O. Box 278
Ripon, CA 95366

August 3, 2008

ADA NPRM
P.O. Box 2846
Fairfax, VA 22031-0846

RE: Proposed ADAAG

As the editor of a magazine about accessible travel, I receive thousands of letters from readers every year. Although not every letter is a complaint about the system or a tale of a trip gone bad; the one issue that comes up consistently in the complaint letters is the fact that some hotels don’t block accessible rooms upon reservation. As you are aware, this can really throw a curve to even the most experienced traveler; which is why I applaud you for addressing this issue in Section 36.302(e) of the proposed regulations.

I am however concerned about the use of the language in this section, more specifically about the use of the word “guarantee”. In hotel lingo, the term guarantee, means to guarantee with a credit card, so that the customer will receive a room at a specific rate. So for example if someone reserved a standard single at $75 per night, but the only thing available when they arrived was a suite; then the customer would be entitled to a suite at no additional charge, because of the guarantee.

As you can well imagine, that doesn’t work so well for accessible rooms, because they are available in a limited quantity. I’ve known many people who have guaranteed their accessible room, only to arrive and be “upgraded” to a non-accessible room. Technically the guarantee was fulfilled in those situations, as the guarantee addresses the price, not the specific room amenities.

So instead of the word guarantee, I’d like to see the term “block” used in this section. In hotel lingo, block means to hold a specific room for a specific person on a specific day at the time of reservation. And with modern reservation software, most properties are capable of doing this. I say “most” because if the accessible rooms are not flagged in the inventory, then they of course cannot be blocked.

Emerging Horizons has been addressing the need for blocked rooms for the past 11 years; with a list of hotels that have roll-in showers and block accessible rooms, in every issue. Over the years, the percentage of properties that block accessible rooms upon reservation has risen from approximately 30% in 1997 to about 80% today. I also have to say that this practice is also highly variable, depending on the geographic location of the property. Some areas of the country are just more proactive than others when it comes to access issues.

Still, some properties will not block accessible rooms upon reservation. And of course third party reservation services such as Hotels.com only treat a reservation for an accessible room as a “request”. Both practices are totally unacceptable, as they can result in travelers arriving to find that the accessible room they reserved has been given away.

And to that end I urge you to consider stronger language in this section; more specifically the use of the word “block” instead of the word “guarantee”.

After all, there’s no sense in going through the trouble to reserve an accessible room, if it’s not going to be there for you when you arrive. And the only way to make sure it will be, is to require properties to block accessible rooms upon reservation. Blocking accessible rooms should be the standard practice in the industry; and I encourage you to add that requirement to the final regulations.

Sincerely,
Candy B. Harrington
Editor, Emerging Horizons

And don’t forget, you still have time to submit your own comments. Just use the handy form. It only takes a few minutes, but make sure you do it soon as the deadline is August 18, 2008.