Welcome to the ADA Distance Learning series, hosted by your regional Disability and Business Technical Assistance Center . Each season we like to bring you up to date with the status of rule making with the U.S. Access Board. We are happy to have with us today, David Capozzi from the U.S. Access Boards, the director of technical information services, hi David.
Hi. How are you?
Fine. Thanks for taking time out of your busy day to join us. I''m sure we have lots of questions for you in the audience. I would like to remind people that the session is being real-time captioned at the Great Lakes web site at www.adagreatlakes.org follow the links where it says real-time captioning. With that said, I''m going to turn it over to you, David, tell us a little bit about what is going on at the Access Board some of your activities when it comes to rule making what we can look forward to.
Actually I''m going to talk about four areas today. First rulemaking. The second topic will be election reform, which is in the news and effects the Access Board. And the third area I will be talking about technical assistance materials and some of the new materials we have available. The last area is some of our other agency initiatives. The first area that I want to talk about is the rulemaking that we are currently working on. There are five different rules that are in various stages of development. I will go through each of them in the order in which it is likely that you are going to see them published in the federal register. The first three are predictable, I can predict when they are going to appear, the last two, get a little bit more difficult to predict. Let me go in order of their appearance. The first is a final rule on recreation facilities. This is a rulemaking that we have been working on for a long time. We started out back in 1993, actually, when we created our first advisory committee on recreation facilities. At that time the advisory committee addressed a whole range of issues, including issues that we have already addressed, play areas which we now have a final rule on, and outdoor developed areas, which I will get to in a minute. Those two we are not dealing within this rule making because we separated those out in separate rule makings. This rule making will cover issues such as access to amusement areas, places of amusement, rides, sports facilities, golf and miniature golf, and boating and fishing facilities. It will also address access into swimming pools as well. It is a fairly comprehensive rule, one that we have been working on for a long time. We had an advisory committee that provided us with advice, we took that advice from the advisory committee, we published an advanced notice of proposed rule making. We received comments on that advanced notice, that was back in 1994 we did that. Then we published a proposed rule in 1999 and held two public hearings on that during the comment period. We had a lengthy comment period for that proposed rule. Then we did an unusual step, we actually published what we called a draft of the final rule and we asked for feedback from the public as to the direction that we were planning on taking for the final rule. We did that in July 2000. Then we held a couple of information meetings around that draft final rule so that we could hear directly from the public about some of the issues and some of the areas that showed the direction that we are planning on taking in the final rule. Based on all of that, we are now ready to vote finally, I hope, on a final rule. The vote is scheduled for our board meeting on March 13th, in a few weeks. We are planning on voting on the final rule and we had actually scheduled a vote at our January board meeting but because we have many new federal members as a result of the change in administration, and some of the federal members did not actually get confirmed until late in the game, and their first board meeting was the last board meeting in January. They didn''t feel like they had enough experience or background in this rule making so they asked us for a briefing which we have already completed. I think they feel comfortable now in voting on the final rule, we will find out. But the vote now is scheduled for March 13th. Once that happens, we will send the rule to OMB which has 90 days by an executive order to review the rule, and clear it. This will be our first rule making with this new administration, it is unclear as to whether they will take the full 90 days, certainly the staff that we work with at OMB has seen the proposed rule, the draft final rule, they have worked with us over several years. It is a question of how much attention this gets from the political appointees at OMB and how much scrutiny it is going to get. That we don''t know and can''t really predict. Assuming that it goes to OMB by the end of March and if they take the full 90 days, we would expect publication of a final rule in the federal register around July. That would be the first rule that you will see published in the federal register. Our practice has always been that the day before the rule is going to be published in the federal register we post it on our web site. We post in html, text and then when it appears in the federal register we add the PDF file that gets published by the federal register. All of that will be on our web site actually the day before it gets published. Please keep visiting our web site for new updates. The second rule making is the revision to ADAAG, the Americans with Disability Act Accessibility Guidelines, and the Architectural Barriers Act Accessibility Guidelines. This also will be a final rule. We had published a proposed rule back in November of 1999. We held a very lengthy public comment period. We held two public hearings, one in Washington, D.C. area and one in Los Angeles. Then we held some information meetings around a few issues that we still needed advice on or some more information on: reach ranges, captioning in theaters, and access to automated teller machines. We feel like we have enough information now. The board has reviewed the preamble that the staff has drafted We have drafted new advisory notes. We have created new figures and the board has reviewed those and we still have one more round of review for the preamble for this rule and we are expecting that the board will vote on the final rule at its May meeting, which is May 15th. Then again following the same process, as the recreation rule making, we would then send it to OMB, Office of Management and Budget, later in the month of May and then I will assume again that they will take the full 90 days and that means that we would publish a final rule around September. Now, because this final rule will come after the Recreation Final Rule, what we will do is we will include those provisions from the Rec Rule into this revision to the ADA and ABA accessibility guidelines. Let me just back up for a second. The Recreation Rule will be published in the old or existing ADAAG format. It won''t be utilized in the new numbering system of the revisions to ADAAG, it will be using the old numbering system or the current numbering system and the current format of ADAAG. Because of that, that is why we are going to be incorporating those provisions into the revisions to ADAAG and we will just renumber provisions, insert them in the right places, and reformat. It won''t be a substantive addition to the revisions to the ADA and ABA rule, we will just be incorporating the Recreation Final Rule and we will also be incorporating the Play Areas Final Rule, because that too was issued in the existing ADAAG format and numbering system. When we publish the final rule for the ADA and ABA guidelines, it will include everything: Play, Recreation, the State and Local Government rules which are already incorporated into the ADA and ABA and the Children''s provisions. When we publish we will have a totally new set of guidelines for the private sector, state and local government sector and federal sector under the Architectural Barriers Act. That will be a huge rule and we are expecting again late September where you will see that in the Federal Register. The third rule is finished, it is a proposed rule on access to outdoor developed areas, trails, beaches, camping, picnic areas, etc. That was a result of regulatory negotiation committee that the board had formed. It is completed but we feel that this rule is probably going to be the most complex, the most costly, and perhaps the most politically charged of the rules that we are working on. We want to make sure we start with our best foot forward with OMB which is why we are starting with the recreation final rule, because it had such a long history and it is, I think well developed. Then we will be sending them the second rule which will be revisions to the ADA and ABA guidelines. And then after we have had some experience with the new administration at OMB, we will then send them what we think will be the most difficult of the three rules, and that is the proposed rule for outdoor developed areas. Like I said, it is finished, we are just strategically waiting until we have experience with the other two before we send that rule for clearance to OMB. The fourth rule is a proposed rule on access to public rights of way. Streets, street crossings, sidewalks, curb ramps, audible pedestrian signals, detectable warnings at curb ramps, public pay toilets, benches, etc. All of that will be dealt within this proposed rule, it is a result of an advisory committee we had formed. I''m estimating that we would have the board vote at the September meeting so publication would be around January, 2003. That is a soft estimate at this point because we are still finalizing the text, we haven''t yet begun to draft the preamble to this proposed rule. I think it is a close estimate that you would expect to see a proposed rule sometime in early 2003. Associated with this rule making our advisory committee is actually still convened, it is still working, we have a subcommittee of the advisory committee which is meeting, actually later this week in Portland, Oregon, to develop technical assistance materials on alterations to public rights of way because that is really where most of the issues lie. Most of the construction that is done in the public right of way, sidewalk construction or crosswalks or signals or roundabouts or on street parking is done in existing constraints and some of the larger issues that we are facing are those that deal with alterations and so the advisory committee is developing some technical assistance materials on alterations for us. Then the fifth and final rule making is a proposed rule on access to passenger vessels. This too was a result of an advisory committee, the committee presented its report to the board last January. We have been working with a group of board members and staff to take a look at the committee''s report, raise some questions and come up with the text of a proposed rule. We still haven''t finished that, we are probably a few months away from doing so. Then we would draft preamble to the proposed rule, etc and go through the same process as I outlined above for the other rules with OMB review and publication in the Federal Register. This would be a proposed rule, I don''t really have an estimate, I don''t want to make one on this rule making because we are still a ways away, I think you have to just sort of stay tuned. And always, as I said, keep an eye on our web site for more information. The second topic area that I wanted to talk about is election reform. There are two bills that have been percolating through Congress. If you had asked me six months ago, there would have been like 30 bills that have been percolating through Congress, but now the House has passed its bill, called HR 3295 on election reform. In that bill there is a new agency that would be created called the Election Assistance Commission, they would develop voluntary standards for both the equipment that is used to cast ballots, and also polling places. A commission would develop in consultation with the Access Board, voluntary standards for maintaining the accessibility and privacy of registration facilities, polling places, and voting methods and then we would also be part of a 15 member technical standards development committee and a 25 member board of advisers that reviews all the standards proposed by this new commission. That was the house bill. It contains lots of other things, mostly an incentive program for states to replace punch card voting systems, but as far as the Access Board''s involvement we would essentially be in a consulting role with a new federal agency in developing election system standards. The senate is in the process of finishing its work, there is a bill called S 565 which began debate last week and will be continuing when the senate gets back from recess in another week or so. Essentially what it would require of the Access Board is that we would work again in consultation with first the Federal Election Commission, to update some voting system standards that they already have in place and then to revise and update those every four years. We would also be responsible for developing what are called general policies and criteria for a grant program to make polling places more accessible to people with disabilities. That would be $ 100 million grant program starting in fiscal year 2002. It too would create a new federal agency, this one they both have the same acronyms EAC, this would be the Election Administration Commission, the other is the Election Assistance Commission. In this case the Senate is creating this new agency called the Election Administration Commission and then it will kind of swallow up everything in a year or so. When this commission would be created it would assume the responsibility to create and update the voting system standards what the Federal Election Commission was working on in consultation with us and then also they would take over the grant program to make polling places more accessible to people with disabilities. There are two other grant programs that don''t have any involvement with our agency. Both of these bills are going to have to go through conference committee and what the final bill winds up to look like is anybody''s guess. The Senate, I think is going to be taking up some amendments to its bill so the final shape of the bill and our role may change. I know there have been some amendments recommended to change our role and broaden it and expand it a bit, but how that turns out I''m not sure. But keep an eye on S 565 and the conference committee that would follow. The third topic area that I want to talk about is some of our new technical assistance material that is available and some that is in the development stage. One is a bulletin that we are working on with the Construction Specifications Institute, CSI, on construction tolerances. There is draft material they developed, a draft bulletin and that is available through our web site, that is probably the easiest way to get to it. It is also available on the CSI web site and also another web site that they maintain. They are looking for feedback. Go to our web site, it is the third story listed on our web site. If you click on the story about construction tolerances, it will explain how to get to the CSI web site and provide them with feedback on the draft TA material that they have developed regarding tolerances. Just as an aside, it is important that this project take place. Partly because in the absence of it, the courts are stepping in and setting construction tolerances. There was a recent decision in Florida in the southern district court of Florida in a case called Access Now v The Ambulatory Surgery Center Group, where the court actually set dimensional tolerances for toilet locations, the distance from the wall, the height of the sink rim, the height under a lavatory apron, grab bar mounting height, height of toilet seats and several other issues. It is not an area that we want courts to get involved in. I think this is an important project. If you have interest in this area, please visit that web site and provide your feedback to the draft material that is available. There is also a bulletin that we have done with Western Michigan University on traffic roundabouts which you can access through our web site. Then there is a series of new bulletins on assistive listening systems and we did those. There are three of them: one for individuals or consumers, one for installers, people that install assistive listening systems, and then one for providers, owners and operators of theaters or other locations where they would use assistive listening systems. We also in light of September 11th developed some evacuation planning material and resources. Evacuation planning is not an area that the board has real jurisdiction over, since we deal with buildings and facilities, but it is an area that we have some in-house expertise on, so we developed some material and it is available through our web site, and then we have lots of links to other groups that do have jurisdiction and that have some active TA materials and other activities under way so we link you to those as well. We are also working on some new technical as assistance material for our recreation final rule. Some of that will be available when the final rule is published and again as I estimated that would probably be around July. The last topic area that I want to talk about are two initiatives that the agency has. One is a new logo and graphics identity. We are updating the eagle that we have on our web site which is kind of the standard fare for most federal agencies which really doesn''t say anything at all about our agency. We contracted with a group called the Society for Environmental Graphics Designers, and did a competition to come up with a new logo and graphics identity for the agency. A competition was held, a winner was selected and we worked with that firm to develop a new logo which the board agreed to at its last meeting and we are going to be soon implementing this new logo and doing new letterhead, new business cards, revamping our web site and also taking a look at all of the existing technical assistance materials that we have and revising those and repackaging those in the with the new logo and new graphics identity. Keep an eye on our web site. When you get letters from us or if you see the business card you will notice the new change. In conjunction with that we will also be translating some of our materials, mostly our guidelines, into other languages, because a more long-range plan that we have is to become more involved in international efforts to improve accessibility worldwide. And really the only way I think that we can do that effectively is to be able to speak the same language, if you will, with other countries, so that we can share with them our guidelines in their language and encourage them to at least look at what we have done and hopefully expand opportunities for people with disabilities in their countries along the lines of what we are doing here in the U.S. The last issue that I want to talk about is our new phone system. Right now we have two phones on all our desks, our old phone system and our new phone system we are still trying to work the bugs out of. We are not yet announcing the new phone numbers, watch our web site for more information on this. We expect probably in the next three weeks to have most of the issues resolved and then we will unveil our new phone system. If you call our existing 800 number, that number will not change. Don''t worry about that. If you call our local 202-272-5434 number, that is the number that will change as well as our fax number will change. But if you dial the old number it will just roll over to the new one for two months after we cut over. We will also be putting an announcements on the phone system, so don''t just press 3 for technical assistance without listening, this way you can catch the new phone numbers so you can change your rolodexes or address books. The 202 numbers will change, the fax number will change, the other thing that will change is all the staff will have a direct dial. You can punch I think it is 1 and you can get a listing of the staff if you don''t know their phone number and you can access them a lot easier. We are also going to be adding a new phone menu selection for our section Section 508 technical assistance that we are providing and when we do that we are going to be adding some more capacity. Dennis Cannon will be joining Doug Wakefield and David Bach and providing technical assistance on Section 508, he will continue to provide TA on ADA issues as well. Those were the areas I wanted to update you on and I have got Jim Pecht here to help me with any questions you might have.
Thanks, David. Let us see we went from swimming pools to voting booths to a new logo and now I am freaking out of all the hand-outs I have to change where I have your phone number listed. We will look forward to getting that information from you. Let me pose my first question to you. Let me ask you first before we open it up for questions, you know that we have John Wodatch from the Department of Justice on in July and I asked him the same tough question that I will ask you. You know right now there are a number of rules that you have issued and now a number of newer rules that you are getting ready to issue specifically recreation and the new ADAAG. The question is how closely are you working currently with the Department of Justice or is there any collaboration with DOJ picking up from where you leave off in issuing their final enforceable rule under the ADA?
Well, there is. You make a very good point. Because it''s now four years. We issued changes to children''s facilities in January 1998 and changes to state and local government facilities, prisons and courthouses also in January of 1998. Those have not yet been adopted by DOJ. There is an ambiguity, we have a final rule that we have issued but Justice has not in fact even issued a proposed rule to adopt those. We recognize that it is an issue, we have also had a very ambitious rule making schedule. My philosophy all along has been that we should continue to publish on an ambitious schedule and finish our work and hopefully DOJ will pick them up so that they are enforceable. But if they don''t I think we should continue to proceed because people are thirsty for information. Frankly people across the country follow our proposed rules in the absence of anything. When they are building a new playground, they follow the guidelines. You know, if they are developing a new trail, they have looked at our advisory committee report. You are right as a technical matter they are not enforceable, it is a quandary, we recognize it, Justice recognizes it. We are actually looking at structural ways that we can streamline this and I''m being vague intentionally. But we recognize it is an issue and we are looking at some ways that we can make this a one stop shop instead of two stop shopping because it has not been working
Very good, thanks David, I will let you know, too, I lobed the question to you more like Larry King, but when John is on you know I ask it a little tougher.
What does he say?
He skirts around it, no, he doesn''t. Actually he has been very up front about it. And actually his comment from the last time that we had John on in July, was that they were very anxious to follow along very quickly, especially with the recreation rule making coming up because we know especially with the recreation rule, that there is probably a lot more policy and procedure issues that are still going to exist that maybe DOJ needs to look further into and, you know, possibly giving out more guidance in those areas.
Absolutely. Like one area that continuously comes up is the use of golf carts and adapted golf carts and the use of motorized golf carts on pudding greens. Those are issues they are going to have to deal with.
Absolutely. A great example. Let us go ahead and open it up for questions.
Rick for the State of Indiana. David, thanks for being here. First of all I saw in the information about the use of truncated domes, does the new ADAAG talk about exterior door tension?
No. Simple answer, no. We didn''t proposed anything, it has been an issue, it is difficult to resolve because of a variety of technical issues. But the five pound of force ohm applies to interior doors we haven''t proposed anything for exterior.
Thanks David. We have our first on line question here. It goes back to the issue we were talking about as far as DOJ picking up on the rules that you have issued. Just for clarification for people, once you issue a rule, DOJ has to adopt, that, correct, for it to be incorporated into the Americans with Disabilities Act?
They have to either adopt what we do or take what we do and issue their own standards based on our guidelines as long as they don''t fall below them. They have to be consistent with it. Historically they have just adopted what we have done. Because we do work very closely with the staff and they are involved rules through the political appointment at the department. It tends to get very well coordinated. When we vote on a final rule, all of their issues have been addressed, the likelihood of them issuing standards that differ from our guidelines is pretty remote.
Okay. In the absence of actual standards yet existing under DOJ, the guidance that we have always received is that you should be following the most current available information; is that right?
Yeah. That is what we say, is that, you know, obviously it is good technical assistance. The only time it gets a little tricky and there is one example that I will give you, the only time that it gets a little tricky is when what we have done falls below a current standard. For example, for prisons, the final guideline that we issued in January of 1998 required 2 percent of new prison cells be accessible. UFAS would currently require 5 percent. So that gets a little trickier. But generally if there are no existing provisions, say for a playground for example, building a new playground, there isn''t anything else available in ADAAG. There isn''t anything in the ADA standards and I would think that a judge in looking at a complaint or at a lawsuit would follow our play final rules because that is the best advice that is available. So even though it is technically not an enforceable standard, it carries a substantial amount of weight.
Thanks David .If we want to go around again if anybody has a question for David we will certainly ask him that. Let me ask you, could you talk a little bit more on the new technical piece that you are doing on construction tolerances? Now these are tolerances that have always existed in the industry; is that right or you are going and looking at further clarifying that?
What we are looking at in this particular project is just tolerances for surface flatness, slope, vibration and rollability. It is not tolerances say for grab bar mounting heights or pipes under a sink or spout heights for drinking fountains, what have you. We started in a street area, that we looked at essentially like an accessible route series of issues. Flatness, slope, and those issues that would be associated with an accessible route. We are just trying to provide more certainty in terms of applying the tolerances that exist within various industries, concrete industry, those that deal with wood, those that deal with, you pick your product-ceramic, because each of them have different tolerances for the installation of materials. And when you layer that on top of the prescriptive figures that we have for making an accessible route, you need to factor in the tolerances that exist within a specific industry on top of our provision and we are just trying to develop some TA material in conjunction with the industry to give people better advice on what tolerances to use. Essentially the attack that CSI is taking is you know, if there is a tolerance of... if you are... let me take an example that most people can probably associate with it, if it says 16 to 18 inches for the toilet from the wall, they are saying don''t design it at 18 inches because you are probably going to miss by an inch or half an inch just because of construction tolerances. It might be 18 and a half inches or 19 inches away from the wall. Then you are out of compliance. They are saying if it is 16 to 18 inch tolerance, design it at 17 inches. Or design a ramp to be less steep than one and 12 that when it is actually built in an environment by whatever tradesman it winds up being a compliant ramp. I think they are taking the right approach. Hopefully this will avoid more courts stepping in and setting their own tolerances.
Hi. In looking at some of your material posted on emergency evacuation, I was wondering if Access Board has any plans for looking at alternative ways out of buildings. Given now there is information on elevator use that might accommodate people with disabilities in the event of an emergency as well as the evac chair. Can you comment on that?
As far as the chairs, we don''t really deal with non-fixed elements. We don''t have jurisdiction over that. Although we have actually had some interest from a couple of members on the House side to develop standards for evacuation chairs, including things like Evacu chair. But right now we don''t have any plans at all to get into that area. As far as the use of elevators in an emergency, I believe in the revisions to ADAAG, we have provisions and I will let Jim address those, we have provisions for the use of what are they called, evacuation elevators?
Firefighter controlled of elevators. In the proposed rule we required at least one elevator in the building where elevators are provided meet the requirements of the elevator safety standard that deals specifically with basically firefighter controlled emergency egress elevators. These are basically elevators that have the ability when an alarm is sounded and the fire rescue personnel show up on the premises, they basically can take control of that elevator, evaluate the situation as to what kind of safety methods are usable and decide whether or not to actually use the elevator whether or not to evacuate people from the building. That was a proposed requirement in the new guidelines.
Thanks, Jim. David, we have another on line question here when it comes to the revised ADAAG. While people are gearing up to retool their ADAAG knowledge base, the on-line question is will you be providing some type of technical assistance piece or hand out that would highlight the major differences between the old ADAAG and the new revised ADAAG?
Yes. We already have a contract in place with one of the local experts that we call on who also was a member of our advisory committee, Larry Perry, who used to work with the Building Owners and Managers Association and did a lot of consulting. He is under contract with us to develop technical assistance materials. The first thing that he is going to be developing is sort of a summary of the major differences between the existing ADAAG and the new provision as well as existing UFAS and the new provision.
Will we call the new ADAAG the new ADAAG or will it get a different name?
There should be a contest, I think.
I think I will name my children ADAAG and UFAS so I hope it is still around.
It beats ABAG.
There you go
But as Jim was saying, it will depend on that the standard setting agencies do, although if I had my way about it, it will be a one stop shop instead of two stop shopping.
Very good.
But the other thing that I did want to mention about that is we will be having a index, we will be doing an index, a table of contents also for the final rule which we didn''t do as much of in the proposed rule so it will be easier to find things.
David, I have another on line question here, this goes back to the recreation rule. And you had issued a notice of proposed rule, I think that was in 1999, and then you also had issued I think it was a year later in 2000 a draft rule of some of the changes and asking more questions. The on-line question asked do you think that you will be following closer to the draft rule that was issued later or are there significant changes from the proposed rule?
It is going to look very much like the draft final rule with some minor changes. Most notably in the boating area: length of gangways, fishing railing height, that was a big issue that I think we finally resolved to everyone''s satisfaction. And just some minor changes to places of amusement and access to amusement rides and attractions. Those will be pretty minor changes. And a couple of very minor tweaks to the miniature golf provisions as well. But it is going to look very much like the draft final rule.
I''m Chris. I have a question on the Florida case on the construction tolerance. In that case did it extend beyond the consent degree just with that case or did it go into district and state and all that. The other question was can people use what is on the web now as a guideline for any elements for construction tolerances?
Let me try to answer your first one. I don''t know that that would be a good idea to do because it is a draft and CSI is looking for feedback. We always give the advice it is never a good idea to follow our proposed rules, it is never a good idea to follow what we say in draft technical assistance, I would wait till we have a final document available. Right now it is really out there for feedback. Let me just try to answer the question about the court case. It related only to the district court in the southern district of Florida, it is only related to that portion of the country which is not surprising, given what is happening in the state of Florida regarding the number of lawsuits that have been filed. But let me again give you the name of the case, it is Access Now v Ambulatory Surgery Center Group (West Law 2001- 617529). Hopefully that helps.
Hi. We were wondering what happens to states who have endorsed their own access laws with ADAAG provisions with the new ADAAG will they have to go back in and redo that?
Right. That is a very good question. The question is about codes that have been certified as equivalent. They have been certified as being equivalent to the ADA standards. I think the question would be when the new standards are issued, would a state or locality, would they have to go back and re-certify and the answer is probably yes. I haven''t spoken with DOJ about that, but I would think probably the answer is yes. But again, they are a ways away from doing that.
With that said, David I will throw it back to you if you have a couple closing comments for us.
No, just thank you for having us, we look forward to doing this again.
Thanks for taking time out of your busy day. I know you just got back yesterday and you are about ready to leave for a Portland meeting with the public rights of way group. We actually will have a follow-up session later in the summer on access to public rights of way for those of you that have interest in that area, as David mentioned, talking about crosswalks and roundabouts and those types of areas, please join us for that Distance Learning Program. Thanks for joining us today. Please come back next month on March 19th when we have John McGovern with us. He is going to talk about access to play areas and some of the highlights of the final rule issued by the Access Board. John is the executive director of the North Suburban Special Recreation Association. He is also a member of the National Recreation and Park Association and served on both the 1993 recreation access advisory committee under the Access Board that developed and made recommendations to the Access Board on the areas of recreation and recreation facilities and playgrounds. He is also a member of the regulatory and negotiating committee that went through the rule for play access. He knows all of the ins and outs of play area access. We are thrilled to have him join us. We have upcoming sessions as well in April on service animals and later in the spring on access to children''s environments, we hope to have you all joining us again. As a reminder the 2002 ADA Distance Learning schedule is posted to the web site at www.adagreatlakes.org and in the event you have a question about the ADA or upcoming sessions, please call your regional DBTAC at 800-949-4232. Thanks for joining us today. We look forward to your future participation.