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 Acknowledgement. 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 2 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. 3 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. Signage 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 4 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. 5 Evacuation/Emergency 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. Communication 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. 6 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. Restrooms 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. 7 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 desk. 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. 8 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 ADAAG. 9