DJ 202-PL-18 MAY 11, 1992 Mr.

Mark Lawrence, General Manager International Inn 662 Main Street Hyannis, Massachusetts 02601 Dear Mr. Lawrence: This letter is to follow up my May 11, 1992, letter to you regarding the Americans with Disabilities Act (ADA). The paragraph that begins at the top of page 2 is not totally accurate. That paragraph relates to alterations to guest rooms. ADA Accessibility Guidelines (ADAAG) require that when guest rooms are being altered in an existing facility, at least one sleeping room or suite shall be made accessible for each 25 sleeping rooms, or fraction thereof, of the total number of rooms being altered until the total number of such accessible rooms meets the number required by ADAAG for new construction. The total number of accessible rooms required is not a fixed percentage but is set forth in a table in ADAAG. My earlier letter had stated that all altered guest rooms were required to be made accessible until 5% of the total was reached. I have enclosed a copy of the Department's Title III regulations which includes ADAAG as an Appendix. See generally ADAAG Section 9 and specifically 9.1.5 and 9.1.2. I regret the confusion and hope that this provides clearer guidance for you. Please feel free to contact this office if we can be of further assistance. Sincerely, Joan A. Magagna Deputy Director Office on the Americans with Disabilities Act cc: Records Chrono Wodatch Magagna.pl.18.followup Bread arthur T. 6/10/92 DJ 202-PL-18 MAY 11 1992

Mr. Mark Lawrence, General Manager International Inn 662 Main Street Hyannis, Massachusetts 02601 Dear Mr. Lawrence: This letter responds to your correspondence with several offices of the Department of Justice seeking information about the provisions of the Americans with Disabilities Act (ADA). The ADA authorizes the Department of Justice to provide technical assistance to individuals and entities having rights or obligations under the Act. This letter provides informal guidance to assist you in understanding the ADA accessibility standards. However, it does not constitute a legal interpretation and it is not binding on the Department. Your letter describes various measures the International Inn has taken to comply with the ADA and asks for our further suggestions. You inquire specifically whether 5% of the total number of guest rooms must be made accessible immediately. We commend you for taking steps to bring your facility into compliance with the ADA. However, short of conducting an indepth compliance review, we cannot assess the sufficiency of those efforts. With respect to the 5% requirement, this Department is not authorized to grant a waiver of any statutory requirement. However, the extent of your obligation under the ADA depends on whether you are planning guest room renovations in the ordinary course of business or whether your intent is to make alterations only insofar as required by the ADA. cc: Records; Chrono; Wodatch; Magagna. :uddl:udd:magagna:pl.18​ -2When a public accommodation is engaged (after January 26, 1992) in an alteration or remodeling of an existing facility in the ordinary course of business, it must comply with the ADA Accessibility Guidelines (ADAAG) to the maximum extent feasible-that is, unless it is virtually impossible to comply because of the structure of the building being altered. Cost is not a consideration. This means that all renovations to guest rooms must comply with ADAAG until the requisite number of rooms are

made accessible. Thus, for example, if you now have no accessible rooms and plan to renovate a number of rooms each year, making only one per year accessible, that would not be permissible under the ADA. If you plan full renovations of any rooms, every room so renovated must comply with ADAAG to the maximum extent feasible until 5% of the rooms are made fully accessible. If minor alterations are planned, the altered features in 5% of the rooms must comply with ADAAG. If no alterations are planned in the ordinary course of business, the hotel's obligation is less rigorous. It must remove architectural barriers to accessibility where it "readily achievable" -- that is, where the removal can be done easily and without much difficulty or expense. There are a number of factors to be used in determining whether the removal of a particular barrier is readily achievable. These include: the nature and cost of the action; the financial resources available both to the site and the parent organization; the size and number of employees at the site and overall; and the relationship of the sites to the parent organization. The hotel must take these factors into account in determining whether making one room per year accessible fulfills the barrier removal obligations. I am enclosing a copy of the Department's Title III Technical Assistance Manual which may further assist you in understanding your obligations under the ADA. We hope that this information is useful to you. Sincerely, Joan A. Magagna Deputy Director Office on the Americans with Disabilities Act Enclosure International Inn 662 MAIN STREET HYANNIS, CAPE COD, MA 02601 February 3, 1992 Wayne Budd United States Attorney General U.S. DEPARTMENT OF JUSTICE (508) 775-5600

Washington, DC 20530 Dear Mr. Budd, In our endeavor to conform to the Americans with Disability Act, our Controller contacted the Massachusetts Office on Disability and spoke with Bruce Bruneau. A meeting was set up for January 13, 1992 and the following persons were in attendance: Bruce Bruneau, Massachusetts Office on Disability Pam Berkley and Julie Nolan, Cape Organization for Rights of the Disabled Arthur D. Rittel, President, International Inn Mark Lawrence, General Manager, International Inn Paul Larsen, Chief Engineer, International Inn Let me take this opportunity to state for the record my impression of these fine ladies and gentlemen and their commitment to this cause. On the date of our appointment we experienced a fierce snowstorm and anticipated their cancellation. However, punctually at 10:00 AM there these individuals were, ready, willing, and able. We toured the entire property noting their recommendations in regards to conforming our Sleeping Rooms, Stairways, Indoor and Outdoor Pool accessibilty, certain areas of our Registration Lobby, i.e., height of Registrations Desk, Public Restrooms, and Dining Room. The following will outline each area, along with their recommendations, and what we are doing to conform to these regulations. -Sleeping Rooms: Presently we lodge four Accessible Accommodations. The only recommendations made to each of these rooms is to change the swing of the door which we anticipate being completed in the near future. -Stairway: It was recommended that we close in the risers for the stairway located in the Lobby. This has been completed. Mr. Wayne Budd U.S. DEPT. OF JUSTICE Page Two -Indoor Pool: It was suggested to us that we build a ramp leading from the Hallway to the Pool Entrance with a landing located at the turn in the Hallway. This, too, has been completed.

-Changing Rooms (Located in the Indoor Pool): Widening of the entryways to 36" and building one 5' X 6' Stall to replace the existing stalls was recommended. Also to remove existing vanity and replace with an accessible sink that meets all regulations. At this time, we have completed the widening of the entryways and bringing the interior up to regulation is in process. We are receiving estimates from bidders for the installation of the vanity. -Outdoor Pool: No recommendations were made due to the inclement weather, however, it has come to our attention that a ramp will be needed to facilitate access to the pool area. In the case of both the Indoor and Outdoor Pools a lift must be installed to enable the disabled full use of these amenities. -Registration Lobby: Many recommendations were made as outlined below and we intend to adhere to all of them. 1). Portico: Our slated Entrance Way must be regraded for a more accessible approach to the Front Doors. 2). Registration Desk: A lower-level desk will be installed to enable wheelchair registration. 3). Public Phone: Our Chief Engineer has been in touch with New England Telephone to replace existing equipment with equipment that conforms. 4). House Phone: Our Chief Engineer is presently constructing a split-level phone center to be installed upon completion. 5). Public Restrooms: It was suggested that we create a Unisex Bathroom due to the physical restrictions that are present. We are consulting with Contractors to submit plans for this reconstructive project. This project should be completed by April 1, 1992. -Dining Room: A tour of the Dining Room was conducted and it appears we meet all required regulations. In regards to our Accessible Guest Rooms Quota of 5% of the total number of Guest Rooms, we would like to seek temporary relief in that we presently 01-00747​Mr. Wayne Budd U.S. DEPT. OF JUSTICE Page Three have four such rooms and wish to complete the quota on a scale of one room per year for the next four years. We seek this relief simply because of the hard economic times we are all experiencing in the Lodging Industry. My President, Arthur Rittel, is also owner and operator of The Country Squire Motor Lodge located at 206 Main Street, Hyannis, MA. As this property utilizes less than 25 employees, grosses less than one million dollars annually, and

is only open seven months of the year, it is not required to comply until the required date of July 26, 1992. However, in Mr. Rittel's attempt to be an example to others in our community, he intends to begin renovations prior to the hotels opening in April 1992. In this regard, a meeting has been established with The Cape Organizations for the Rights of the Disabled (CORD) to discuss necessary compliance. I would welcome any suggestions you may have in our endeavor to comply to this long awaited Legislative Ruling. May I have a reply to our request regarding Accessible Rooms Quota? If you require any additional information, please do not hesitate to contact me personally. I anxiously await your reply. Yours Sincerely, THE INTERNATIONAL INN Mark Lawrence General Manager ML/mhf cc: Barbara S. Drake, Deputy Asst. Attorney General Stewart B. Oneglia, Coordination and Review Section John L. Wodatch, Office of the ADA Scott Harshbarger, Mass. Attorney General Bruce Bruneau, Massachusetts Office on Disability Pam Berkley, CORD Julie Nolan, CORD Arthur D. Rittel, CEO International Inn Christina Canning, GM Country Squire Motor Lodge Paul Larsen, Chief Engineer, International Inn 01-00748