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FEB 20 1993

DJ 202-PL-553

Ms. Helen S. Found Board of Trustees Pavilion Public Library 7925 Telephone Road Le Roy, New York 14482 Dear Ms. Found: This letter is in response to your inquiry into the applicability of the Americans with Disabilities Act (ADA) to your new library. 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's requirements. However, it does not constitute a legal interpretation or legal advice and it is not binding on the Department of Justice. Entities that are part of a State or local government program, such as public libraries, may choose from two architectural standards when engaging in new construction: Uniform Federal Accessibility Standards ("UFAS"), or the ADA's Standards for Accessible Design ("Design Standards" or "ADAAG"). See discussion in the enclosed title II regulation at section 35.151(c) on pages 35,720 and 35,710. These standards are generally quite similar, but with respect to signage there are some differences. Once a standard has been chosen as the guiding standard for a particular architectural project, that standard must be followed throughout the entire project. For example, an entity cannot design its ramps according to the Design Standards and then install signage that only meets the requirements of UFAS. Private foundations that build or operate public libraries must follow the Design Standards. They cannot choose UFAS as the

governing architectural standard. Please see the enclosed title III regulation at section 36.401 on pages 35,599-600 and 35,57475. cc: Records, Chrono, Wodatch, Breen, Mobley, MAF, FOIA udd\mobley\pletters\found 01-02856 -2You have asked whether there is a height restriction on book shelves or stacks in libraries. Neither UFAS nor the Design Standards restricts maximum shelf height under these circumstances. Please refer to Design Standard section 8.5 at page 35,668, and UFAS section 8.5 at page 58. You have also asked whether signs such as exit signs need to be in Braille as well as print. Under the Design Standards, signs that designate permanent rooms and spaces, including exit signs, must be in Grade 2 Braille and meet other specific design standards. Informational signs and signs that provide direction to functional spaces of the building do not have to be in Braille but have to meet other requirements. Please refer to Design Standard section 4.1.2.(7) at page 35,612 (scoping provisions for new construction), and section 4.30 at page 35,659 (design standards for signage) for more detailed information. UFAS does not require signage to be in Braille. Please refer to UFAS sections 4.1.2(15) and 4.30 (signage) at pages 6 and 47, respectively. I have also enclosed the Technical Assistance Manuals for Titles II and III. The manual for title II discusses obligations applicable to public libraries that are part of a State or local government program. The manual for title III applies to private library foundations. The Department of Justice publishes these manuals to help entities and citizens understand their responsibilities under the ADA. Please refer especially to the comparison of UFAS and the Design Standards (referred to therein as "ADAAG") in the Title II Manual at pages 23-32. If you wish to subscribe to these manuals which will be supplemented annually, please complete the enclosed order form.

If you have additional questions, you may call Mary Lou Mobley, one of our staff attorneys, at (202) 307-0816. I hope this information is useful to you in understanding the requirements of the ADA. Sincerely,

Philip L. Breen Special Legal Counsel Public Access Section Enclosures: Technical Assistance Manuals for Titles II and III Regulations for Titles II and III UFAS Technical Assistance Manual Order Form 01-02857