NOV 12 1992

The Honorable Gus Yatron U. S. House of Representatives 2205 Rayburn House Office Building Washington, DC 20515 Dear Congressman Yatron: This letter responds to your inquiry on behalf of Opal I. Lebo of Reading Rehabilitation Hospital, concerning the requirements of the Americans with Disabilities Act (ADA) for accessible parking spaces. The ADA authorizes the Department of Justice to provide technical assistance to individuals and entities with rights or obligations under the Act. This letter provides informal guidance to assist Ms. Lebo in understanding the ADA accessibility standards. However, this technical assistance does not constitute a legal interpretation of the statute, and it is not binding on the Department. Existing private medical care facilities are subject to the readily achievable barrier removal requirements of the title III ADA regulations (section 36.304 on page 35597 of the enclosed document). Readily achievable is defined as being easily accomplishable and able to be carried out without much difficulty or expense. Modifications to existing facilities undertaken to remove barriers should be done in conformance with the applicable standards for alterations if it is readily achievable to do so (section 36.304(d)). When new construction or alterations are undertaken, full compliance with the accessibility standards is required. The standards for parking are found in sections 4.1.2 (5) and 4.6 of the Accessibility Guidelines (pages 35612 and 35631 of the enclosed document). Section 4.1.2(5)(d)(ii) states that units and facilities that specialize in treatment or services for persons with mobility impairments must make 20 percent of the total number of parking spaces accessible. cc: Records; Chrono; Wodatch; Harland; McDowney; FOIA; MAF. :net:ss63:udd:harland:yatron.lebo.cong

01-01718​ -2Barrier removal requirements apply to the public portions of places of public accommodation. The 20 percent standard would not apply to parking areas reserved only for employees. Provision of parking spaces to employees is a matter of reasonable accommodation, required under titles I and III of the ADA for an employee with a disability. Reasonable accommodation is determined according to the needs of the individual and the hospital on a case-by-case basis. I hope the information we have provided is helpful to you and your constituent. Sincerely, John R. Dunne Assistant Attorney General Civil Rights Division Enclosure 01-01719​ READING REHABILITATION HOSPITAL October 2, 1992 The Honorable Gus Yatron 1940 North 13th Street Reading, PA 19604 Dear Congressman Yatron: This is to request your assistance in relating the new "Americans with Disabilities Act Accessibility Guidelines for Facilities and Buildings" to our hospital. As you already know, this 92 bed hospital is dedicated to serving the physically disabled. We are committed to doing whatever is necessary and appropriate to meet the needs of our patients in service to this community. In addition to the In-patients, we serve approximately 1200 outpatients annually. Eighty (80%) to ninety (90%) percent of our outpatients are driven to the hospital by family or Barta bus, dropped off and picked up under the canopy at the front entrance. Wheelchairs are located nearby for those who

need them to get to the therapy areas. Being built on a hillside poses its special parking challenges. We have four (4) parking lots, A, B, C and D. The A-level parking lot has 118 spaces, 65 of which are dedicated to outpatients and visitors. Nine (9) of these spaces on A-level are reserved for handicapped parking. Except for four spaces in B-level parking lot, lots B, C, and D are dedicated to staff parking. Lots B and C are carved out of the hillside and accessible only by a steep, narrow road. Lot D is fairly level, but accessibility is also limited to the steep, narrow road. Handicapped staff are provided parking privileges in Lot A. Questions: 1. Does the "20% rule" mentioned in the attached article, apply to all our parking spaces, including staff parking, or may we apply the rule to the spaces reserved for patients/visitors? This would mean adding four (4) spaces to give a total of thirteen (13) handicapped spaces (.20 X 65 = 13). R.D. 1 Box 250, Morgantown Road * Reading, PA 19607-9727 * (215) 777-7615 01-01720​ The Honorable Gus Yatron October 2, 1992 Page 2 2. Since the front entrance has designated, protected spaces for vehichles to load and unload passengers, this decreases the need for handicapped parking spaces. Might this be taken into consideration in assessing how well we are meeting our handicapped parking space needs? Thank you for your consideration and assistance. Sincerely, Opal I. Lebo, V.P., Patient Support Services 01-01721