Comment NumberOL-100625
OrganizationAmerican Council of the Blind
Received05/31/2005 05:16:56 PM
Commenter
First NameLast NameState/Province
DayAl-MohamedDC
AgencyU. S. Department of Justice
Docket IDCRT Docket No. 2004-DRS01
RuleNondiscrimination on the Basis of Disability in State and Local Government Services; Nondiscrimination on the Basis of Disability by Public Accommodations and in Commercial Facilities
Attachments
AttachmentPlug-in
OL-100625.pdf Adobe Acrobat Reader

CommentsAnswers to Specific Questions


1-ACB Comment: We feel strongly that DOJ should elect Option 2 as the effective date of implementation of the ADA standards. Option 2 offers a six-month period of time in which covered entities need to comply with the ADA standards. We feel that six-months is sufficient because there is more information available from more sources on compliance with the standards. In addition, the language in the ANPRM specifically states: “…the changes in scoping and technical specification to the revised ADA Standards are primarily incremental”. Fifteen years of ADA implementation has been more than adequate for familiarization with the concept of architectural and programmatic compliance with the various ADA standards.

7-ACB Comment: The ADA standard ensures that covered equipment is independently usable to blind and visually impaired individuals. The American Council of the Blind urges DOJ to not only cover fixed equipment, but also cover previously owned fixed equipment and free-standing equipment in the new ADAAG standard. It is imperative that access standards exist for previously owed fixed equipment and free-standing equipment as well as equipment that is new. Creating separate guidelines for equipment which is defined as previously owed and free-standing is confusing. The access needs for people who are blind and visually impaired are the same regardless whether or not the equipment is previously owned or free-standing. As long as the equipment meets the accessibility standard, it does not make a difference whether it is fixed, free-standing or previously owned. Furthermore, any guidance that is offered by DOJ in the future concerning accessible equipment needs to address the access needs of people who are blind and visually impaired by providing equivalent and independent usability. In closing, we with to state that ACB supports the comments submitted to the Department by the American Foundation for the Blind (AFB) on this issue.
General Comments