CAPED Position Paper on Transition Plans

Postsecondary Services for Students with Disabilities Role in Developing
Accessible Campus Transition Plans
A position paper of the California Association for Postsecondary Education
and Disability
August, 2005
The California Association for Postsecondary Education and Disability
(CAPED) is grateful to the Coordinators of the Disabled Students Programs
& Services (DSP&S) of the Los Angeles Community College District
(LACCD), and in particular to Los Angeles Harbor’s Debra Tull, Los
Angeles Valley’s Kathleen Sullivan, and Mark Sakata, formally of Los
Angeles Valley College, for contributing the detailed information leading to
this formal position paper. Their work is of benefit to all community
colleges and universities throughout the State.
Position Statement.
Given the recent passage of many postsecondary construction bonds
throughout the State, many college districts and universities are exploring
the possibility of having campus facilities managers (or appropriate
designees) and postsecondary campus representatives of services for
students with disabilities develop updated accessibility transition plans. The
California Association for Education and Disability (CAPED) is opposed to
this strategy, and strongly recommends, because of liability issues and the
level of expertise necessary, the allocation of sufficient resources be made
available to contract with qualified Americans with Disabilities (ADA)
consultants to work with facilities managers in developing accessibility
transition plans. The expertise necessary to design these plans is very
specialized. There is tremendous liability associated with designing faulty
transition plans that do not meet the true access needs of individuals with
disabilities. Generally speaking, college and university employees do not
have specialized training in this area. Campus professionals providing
reasonable classroom accommodation for students with disabilities have
training as counselors and/or instructors; they usually do not possess ADA
facilities planning expertise. Additionally, requiring the Student Service
staff to develop accessibility transition plans is in violation of the funding
parameters for allowable Disabled Student Service activities focusing on
reasonable classroom accommodation.
Because California colleges and universities have a responsibility to ensure
equitable access to educational programs and services for individuals with
disabilities, the inaccessibility of many of our facilities has been a source of
concern for students with disabilities and the professionals who serve them
for some time. It is also of concern that recent construction/renovation
projects in much of the State have strived for only the minimal compliance
with ADA standards required for project/plan approval by the Division of
State Architects (DSA). It should be recognized that minimal ADA
compliance may not provide adequate accessibility for individuals with
disabilities to educational programs as required under Sections 504 and 508
of the Department of Rehabilitation Act of 1973. Numerous colleges and
universities have been cited for inadequate access under Sections 504 and
508 of the Rehabilitation Act of 1973 and Title II of the Americans with
Disabilities Act (ADA) of 1990. Cases in point include the following: OCR
Case Number 04012068 at Spring Hill College in 2001, OCR Case Number
09002097 at the University of California, Berkeley in 2002, and OCR Case
Number 09032028 at Sacramento City College in 2004. The theme of all
these costly cases was the lack of an expert consultant on hand to guide the
various projects, whether this lack was intentional or not.
Individuals throughout the State voted for construction bonds to allow
California colleges and universities to beautify and rebuild their campuses to
serve the educational needs of the whole community. College districts and
universities were entrusted with the responsibility of developing plans that
meet the needs of all populations. Liability factors and law suit costs aside,
it would certainly be an embarrassment if the citizens within our
communities thought our college districts and universities did not place a
priority on accessibility for individuals with disabilities as we design
campuses to meet the learning needs of the 21st century.
Although postsecondary Student Services professionals may not have the
expertise to design and update campus transition plans, CAPED does offer
recommendations (referred to in this document as College and University
Access Standards) which should assist qualified ADA consultants to update
the existing transition plans. These recommendations were developed in
support for full accessibility of the postsecondary facilities for individuals
with disabilities. After consultation with students with disabilities,
architects, and accessibility professionals in the community college and
university systems, CAPED has developed the following “College and
University Access Standards” as a working document in progress, to
assist qualified ADA consultants in the Statewide, postsecondary
construction/renovation process, which includes the creation and/or updating
of transition plans for each college and university. Please note that when a
standard is not ADAAG referenced, then that standard is recommended
by CAPED as a best practice beyond Amercians with Disabilities Act
Accessibility Guidelines. CAPED respectfully submits the following
access standards as a helpful guide, and a working document in progress.
College and University Access Standards
August, 2005
Access to the Campus and Parking
Major pedestrian crosswalks, including those that serve as portals to the
campus, should have a silent-tactile notification system to indicate to blind
and visually impaired individuals when it is safe to cross the street.
Accessible parking should be located near an accessible entrance for each
building; refer to 4.6.2 of the ADAAG.*
An adequate number of disabled parking spaces (for wheelchair and nonwheelchair users) should be placed on campus. This number may exceed the
prescribed ratio/calculations requirements. An adequate number of parking
meters should be placed so that non-student visitors with disabilities can
easily park near each building.
An adequate number of disabled parking spaces should be appropriately
located on campus even during the construction process.
Pathways should be accessible and not endanger wheelchair users and other
mobility-impaired individuals, even during the construction process. Curb
cuts should be placed in appropriate locations for wheelchair access to
campus crosswalks and pathways. Curb cuts/pathways should not require
wheelchair users to navigate large bumps, overly-sloped ramps, deep
puddles, or piles of leaves or other debris; refer to 4.7 of the ADAAG.
Large easily readable signage (including Braille) should be available to
guide people to various buildings around campus; 4.30 & A4.4.30, ADAAG.
Large easily readable signage should be placed at traffic entrances to campus
to guide drivers with disabilities to appropriate disabled parking areas.
*Americans with Disabilities Act Accessibility Guidelines
Building Entrances/Campus Pathways
Main accessible entrances to buildings should have automatic doors.
Building entrances accessed by stairs or ramps should have high contrast
visual marking indicating the edges of the entrance platform
The edges of ramps should be marked with high contrast visual indicator.
Entranceway steps shall also be marked with a high contrast visual indicator.
Procedures should be put in place for routine assessment and timely
replacement of contrast marking and visual indicators.
Reception/Waiting/Ticket/Service Counter Areas/Bookstore
All departments with a service counter should have a section which is lower
or can be lowered to allow access for wheelchair users; 7.1 of the ADAAG.
Aisles, such as those in Bookstore or Library, should be wide enough to
allow wheelchair maneuverability; refer to 4.3, 8.4 and 8.5 of the ADAAG.
All offices in which college faculty, administrators, and other staff meet with
students should be wheelchair accessible, as required by ADA; refer to
4.2.3. of the ADAAG.
Lecture Halls/Auditoriums/Theatres/Arenas/Stadiums
Presentation venues should have an integrated assistive listening system
available at all times; refer to 4.33.6 and 4.33.7 of the ADAAG.
Presentation venues should provide a variety of accessible viewing locations
that offer views comparable to members of the general public; refer to 4.33.3
of the ADAAG.
Presentation venues should also provide space for placement of a writing
surface for wheelchair users in the viewing locations.
Each building should display in large print and Braille and in a wheelchair
accessible location, emergency information and procedures specific to
individuals with disabilities; refer to 4.30 of the ADAAG.
Each multi-story building should have a wheelchair evacuation system,
which includes accessible equipment and ongoing training in the use of the
equipment for Sheriff's Office, College Emergency Response Team, SEMS,
and building users.
The Sheriff's Office should have a universal emergency wheelchair battery
for recharging dead wheelchair batteries.
Each office that provides services to students and/or the public should have a
TTY (this includes the Sheriff's Office.)
Public telephones located on campus should include TTY and be accessible
to wheelchair users. Public telephones that are easily accessible to
wheelchair users should be located adjacent to all disability transportation
drop-off/pick-up locations.
Accessible Sheriff's Office emergency telephones should be located in all
parking lot areas.
Up-to-date information regarding construction-related conditions such as
classroom changes, road closures, walkway detours, demolition or
construction-related unsafe air quality levels, should be provided on a fully
accessible webpage, as well as on video campus notification monitors
located around the campus.
Eating Areas/Commons Areas
Outdoor tables with built-in bench seating should include some units that
have an opening and/or openings for wheelchair users to sit.
Banks of lockers should include accessible lockers with accessible handles
and locking mechanisms.
If lunch trucks are to be used on campus, they should provide accessible
counters for wheelchair users.
Disability Transportation (Para-transit) Drop-off/Pick-up Areas
Disabled Transportation drop-off/pick-up areas should include covered
weather sheltered areas for wheelchair users and benches for other persons
with disabilities on which to wait.
Public pay phones and free emergency phones should be placed adjacent to
drop-off/pick-up areas.
Drop-off/pick-up areas should be located in areas where small buses and/or
automobiles can safely stop and where the person with a disability and their
equipment can be safely loaded at all times.
Each building that is regularly used by students and/or members of the
public should have a power-assisted door system in at least one male and
one female bathroom on the ground floor. These specific restrooms should
also have one electric paper towel dispenser.
All restrooms should have a trash receptacle system that does not obstruct
access to paper towel dispensers or stalls.
Unisex bathrooms should be placed at
unisex bathroom should be placed in or
education classrooms/gym area, the
presentation venue areas such as
theaters/performance areas.
various locations on campus. A
adjacent to the adaptive physical
swimming pool, and campus
the college auditorium and
Smart Classrooms/Computer Labs/Furnishings/Media Technology
Because DVD, VCR, and media projectors do not have built in decoders,
rooms using multimedia projectors should have a closed-caption decoder
box between the video source (VCR/DVD) and the projector.
According to the California Community Colleges Tech II Strategic Plan, ten
percent of computer workstations should be accessible. Accessible
workstations should have height adjustable tables that can be raised and
lowered on demand. Electric tables are preferred. The knee clearance for
workstations should be a minimum of 32" wide, and height adjustable
between 27" to 34". Computer monitor screens should be a minimum size of
17". The CPU and monitor should not be mounted below the surface of the
Many providers of furniture, fixtures, and equipment claim that their
inventories are ADA compliant. Even so, their products may not adequately
meet particular disabled-user needs. Purchases above a certain amount shall
be made in consultation with DSPS to ensure compliance with ADA and
Section 508 of the Rehabilitation Act, as appropriate.
Self-Service Machines
Self-service machines, including printing stations and Print/Copy card
machines, ATMs, and vending machines, shall be wheelchair accessible and
contain Braille signage.
Equipment/Technology Purchases/Maintenance
Electronic information technology providers and services should comply
with with ADA and Section 508 of the Rehabilitation Act.
All new video/DVD purchases shall be closed-captioned.
Procedures shall be put in place to periodically inspect and perform routine
maintenance activities on accessibility equipment such as evacuation
equipment, swimming pool lifts, adjustable electric tables, wheelchair lifts,
and temporary ramps.
Adapted Physical Education Facilities
The adaptive physical education/gym areas shall include private changing
rooms and unisex bathrooms. Some bathrooms in the areas shall include
power assisted door systems.
Hydraulic pool lift technology, portable pool stairs and/or ramp for access
shall be provided for access to swimming pool.
Adequate space around adapted exercise equipment shall be ensured for
wheelchair access, transfers, and student aides, as appropriate.
Pool temperature is an access issue and water in adapted aquatic exercise
classes shall be maintained between 83 and 88 degrees (from the California
Community College Adapted Physical Education Handbook, 2002).
Locker rooms shall be fully accessible including wheelchair shower stalls
with appropriate seating and handheld showerheads; refer to 4.21 of the