Everything You Need To Know About Accessible Parking From Public To Private. Presenter: Aaron McCullough. >> DIEGO: Well, hello everyone and welcome to today's webcast. My name is Diego Demaya and today's webcast is called Everything You Need To Know About Accessible Parking From Public To Private. And my name is Diego Demaya. I'm a legal specialist with the Disability Law Resource Project and I will be the host moderating today's broadcast and before we get started, let me remind you about submitting questions, and the way you do that is if you are using the RealPlayer to listen to your webcast, you can click at the bottom of the screen on the RealPlayer and submit an E-mail question; or, otherwise, you can do an E-mail at webcast@ilru.org. And again, that's webcast@ilru.org. And time permitting, we will try to get to the questions as they come in and we'll do them in the order -- we may shuffle some of them around. Anyway, in order to get started -- forgive me. I'm trying to get to my notes here. If you have technical difficulties listening to the webcast, please go to -- or rather call us at (713)520-0232, and dial 0 for the operator and they will direct you to someone that can provide some technical assistance, if that's possible. And then I also want to remind those who are participating in the webcast to obtain AIA credit -- and I hope I said that right -- please do take the quiz which you will find at the website where you linked to listen to this webcast. And that of course has to be submitted for us to correct. I encourage other people to take the quiz if they want to, but if they're not receiving credit, you don't have to submit to us. In fact, we prefer that you didn't since it takes a lot of time to correct those. Anyway, today's topic, again, is parking and everything you need to know about accessible or handicapped parking from public to private. Basically we're going to review this topic from a very broad standpoint and we're going to try to cover some different areas relating to handicapped accessible parking and so forth. As a provider of technical assistance I, myself, receive hundreds of questions relating to parking and parking accessibility and parking design and parking enforcement and so on and so on, and I'll let Aaron cover some of those so ons, but basically this is a very prevalent topic and everybody has questions about it. Anybody who is a professional, providing a service or anybody who has a disability and has to deal with handicapped accessible parking. Obviously, I have to introduce today's guest, and his name is Aaron McCullough and he is a legal specialist with the Disability Law Resource Project. Yes, we do work together. He, too, fields questions relating to disability laws and just everything relating to the ADA really from architectural questions all the way to employment and special ed, but in this case, we're doing parking and a little bit about Aaron. Basically, Aaron got a law degree from the University of Houston and he has been in this field for several years now doing various sorts of work, including writing on disability issues and producing materials and publications and so on. And so please do go to the webcast website and you'll see his bio there if you want some further details as well as contact information. And with that, let me introduce you to Aaron McCullough. Aaron, are you there? >> AARON: Yes, I'm here. >> DIEGO: You're not asleep yet? >> AARON: I'll reserve that for midway. >> DIEGO: Anyway, let me let you do the quick introduction of the topic and then, you know, say whatever you have planned on how to go about through this topic. >> AARON: All right, Diego. What we're going to do is -- unlike a lot of other webcasts, I'm going to try to get through the content as quickly as possible and leave as much time for specific questions. I've also got to make sure that I cover the more technical questions that are inherent -- and it's AIA quiz that's required for those architects and other AIA members that are intending to get this for credit. I'll apologize in advance for some of the awkwardness of doing something with a lot of technical provisions in a webcast, but I don't think they will be too painful, but again, I do encourage those folks to -- who are seeking credit to fairly quickly take the exam following the webcast, in addition to complete the evaluation form that's also available on the website. I assure you that we will -- that we will respond fairly rapidly with the grading of those necessary quizzes and get everybody the information they need to take those AIA credits or use those in their licensure at the state level. So if you have any questions about those -- clearly those more technical issues, if you could wait until after the webcast to submit those and call us or E-mail. Now, if you have any other parking related questions, including technical provisions, how to properly configure a parking space in a variety of situations or about enforcement, again, I encourage you to be sending those now and we've already received several so I know I need to get through some of this material. In the many lectures that we had done in my first two or three years here, inevitably parking came up. I really don't care what context it was, whether it had to deal with any type of particular disability related federal law or any particular arena of interest, parking always became an issue. I remember initially stating that I never understood why it was such a problem because the technical provisions that govern how you configure a space are fairly straightforward, but I'm going to say right now that we probably made too much light of the concern. As people with disabilities have told me, particularly those with mobility impairments, that for example use walkers, canes or wheelchairs, the ability to have a properly configured space available for you is the mere minimum that they need and so they can safely exit their vehicles, unshift their equipment and enter into -- on to a property that is the least expectation that they have in order to fully enjoy participation in a more integrated society. And also -- this is an answer that I get from a lot of folks with disabilities is that they do not feel the least bit welcome when an institution or business has failed to comply with these fairly minimal requirements with regards to supplying accessible parking. I'm apt to think about how many other aspects of noncompliance or barriers that they might imagine would exist if they failed in their duty to comply with the minimal parking standards. One question that we get quite a bit is who's eligible to park in accessible parking spaces and what does the ADA have to say about that? I'm going to encourage you to right now understand that with regards to eligibility to park in a space, you do not have to be a person with a disability as defined under the Americans with Disabilities Act. States and local governments make decisions as to what are eligibility requirements for a sufficient level of physical impairment to be eligible to get a hangtag or license plate indicating that you can park in a space, even on a temporary basis. Again, this is decided at the state or local level and the ADA merely requires that the spaces exist under certain conditions; and how those spaces need to be configured. So with regards to eligible parking, essentially the lion's share of the law -- law is laid out like this: A person is eligible to park in a parking space provided they have a placard or a hangtag, so a license plate or a hangtag if they are a person with a disability or they're traveling with somebody with a disability. Most laws actually deny coverage for someone who may have a validly issued hangtag, for example, to drive their elderly grandmother around if their elderly grandmother is not in the vehicle with them or being transported by them in that trip. So you can imagine a scenario where someone regularly uses it and has become accustomed to using it with, for example, their grandmother or spouse or child, but when that person without a disability is not -- or that impairment is not in the vehicle, they're not allowed to use it. Well, you might imagine that's an enforcement nightmare, but again, that's the way most laws are configured. So since I've brought up laws, I want to kind of talk about the bredth of the laws that we reviewed in preparation for this and so as much to give you an introduction and to make some clear distinctions. The law that we provide most guidance on is the Americans with Disabilities Act, and with regards to parking, we tend to talk about the Americans with Disabilities Act, and those regulations called the Americans with Disabilities Act Accessibility Guidelines. These are -- these guidelines are written into a set of regulations that breathe life to the built environment requirements for architectural accessibility under the Americans with Disabilities Act; but they are two distinct parts of the overall body of law under the Americans with Disabilities Act. And I think we'll cover that a little bit more clearly a little bit later. In addition, because a lot of federal facilities are not required to comply with the Americans with Disabilities Act, we have to talk about the Uniform Federal Accessibility Standards or those access guidelines that are relevant at most federal facilities such as post offices and V. A. hospitals, et cetera. We're also going to talk about the Fair Housing Act and amendment to that act and the Fair Housing Act Design Manuals. And we're also going to touch on some state and local laws that will impact the technical configuration of the space or how a space needs to be constructed, but certainly that impact enforcement and we encourage, again, some questions on that and I know we'll get some. Let's see, so in looking at these sets of laws as a global reality for people with disabilities who do need to park, we also had to break it down a little bit further and talk about the types of parking, and we're going to go into that in more detail. Now, what does -- when we're talking about a lot as defined under the Americans with Disabilities Act, what do we mean? A lot is -- under the Americans with Disabilities Act is a lot or parking structure. A lot is something that's distinguished from another lot by geography or program. So are we talking about -- let's say a building or site that's served by seven different lots, in the Americans with Disabilities Act we're going to tend to treat each one of those as different lots if they are separated in space or if they are separated in programming such as one is a pay lot reserved for, let's say faculty and staff at a university that is distinct only in the fact that there is a card key barrier. Now, it may actually be encompassed entirely rather or incorporated in a larger lot scheme, but we would tend to treat that one as a separate lot. Now, parking structures can be made to comply with the Americans with Disabilities Act and, again, those that were constructed after 1992 or January of 1992 need to do so. Now, in some parking lots or parking garage or parking structure schemes they can be modified to comply with the Americans with Disabilities Act or portions of them can. I think those of you who are familiar with a lot of older parking structures, they just cannot meet the technical requirements of the Americans with Disabilities Act Accessibility Guidelines due to the fact that every single parking space within them is sloped beyond the 1:50 cross slope allowed under the Americans with Disabilities Act, but we'll talk about that a little bit more. We are we also going to talk about onstreet parking, parking at a temporary event and parking at multi-family housing and also talk about parking provided to employees and special situations such as valet parking, older parking and existing parking structures and the technical provisions underneath there. I was going to take this moment -- Diego, do we have any questions hanging out? >> DIEGO: No, I'll just mention that we have several questions and they range in all different types of topics. So I can try to break some of them down to some kind of logical, you know, order if you want me to mention. >> AARON: I tell you what, how about I talk in general terms about the technical provisions as required under the Americans with Disabilities Act Accessibility Guidelines and then make some of the distinctions and then we'll get to some questions before we start talking about enforcement. >> DIEGO: Right. I want to make a correction/observation, if I may. Earlier when I introduced the webcast, I mentioned accessible parking and I also said handicapped parking. I just want to clarify for some of the listeners out there that the reason I did that is because a lot of our listeners are not going to know what accessible parking means. They might be new to the situation or they might be actual people with disabilities and they don't necessarily have an obligation to know all the legal terminology of the ADA. So that was the purpose why I mentioned handicapped as opposed to accessible parking which is the actual, you know, correct term to refer to parking that people with disabilities can use if they are so authorized by a state tag or license plate. Okay, go ahead, Aaron. >> AARON: That's an interesting point, actually and one that I was going to make. In almost no circumstances are you going to hear us use the phrase handicapped, particularly because in the amendments -- or in the passage of the ADA we began to use people first language or person first language such as a person with a disability. And even the subsequent amendments to The Rehabilitation Act and older laws at the federal level have replaced that older terminology handicapped with person with a disability or persons with disabilities. The one set of circumstances that you're going to hear us refer to the word handicapped is going to be typically only with regards to parking, and why is that? One, a lot of state laws or local laws that impact accessible parking will still use that phrase. A significant amount of the required signs that are required for designated spaces use the phrase handicapped parking. A lot of the enforcement codes that can cause someone to improperly park in those spaces to get a ticket, again, use the phrase violation of handicapped parking. So that's going to be the one time or the context that you're going to tend to hear us talk about that. Now, like I said, I'm going to go forward and talk about how do I accomplish properly configuring a space? How many spaces do I need to have and what kind of impact does the type of facility that I'm operating in have on the type of parking that I need to provide? So I'm going to kind of back into this. Does the Americans with Disabilities Act cover all types of parking lots? The short answer is it potentially can cover all type of parking lots new and existing and even all parking structures. The Americans with Disabilities Act Accessibility Guidelines only cover newly configured parking as defined under the law essentially January of 1992. It's a little more complicated than that on forward or that type of parking is covered by the ADA Accessibility Guidelines. >> DIEGO: New construction, right? >> AARON: New construction. Now, new construction or the ADAAG covers new construction or alterations which I'll go into a little bit in more detail as to what that means. Now, this does not mean that all parking that was in place prior to that date can be left as is. So I think I just need to kind of explain those obligations. It's abundantly clear that under the Americans with Disabilities Act Accessibility Guidelines, or the ADAAG as I'll kind of refer to it from here on out, all newly constructed parking must comply in lock step with the Americans with Disabilities Act Accessibility Guidelines and potentially relevant state and local laws. Alterations to lots -- the obligation is slightly different. The scoping provisions of the ADAAG require this: If a lot is altered, then only those spaces that are altered are required to comply with the Americans with Disabilities Act Accessibility Guidelines. Now, if the lot is reconfigured, let's say it's been expanded and -- it's been expanded, they've changed the very nature of the layout. It's serving other buildings so they had to radically change the traffic lanes and the type of parking that they laid out, including compact parking, including let's say getting off some reserve parking. In that set of circumstances, to the extent that it's technically feasible to do so, then you need to bring the entire lot into those standards or into the strict compliance with the Americans with Disabilities Act accessibility guideline. Now, what does that mean? Well, the technical and feasibility refers to the notion that it's something that you can do from the engineering perspective and it's not prohibited by other relevant law. Let's say a regrade is not part of that change in purpose or redesign. Let's say that it's an older lot that has a fairly steep pitch to it that exceeds the 1:50 relatively flat cross slope required under new construction, because that was the prevailing thought about how to get water away from facilities. Well, if a regrade is not part of that repurposing, then you are you're not going to have to, again, comply with that part of that provision, the 1:50 cross slope. But if you're reconfiguring it, you'll need to paint and properly configure your spaces and have the proper signage, et cetera, and make sure they are on an accessible route, but you wouldn't have to comply with that portion of the provision. And in addition, where parking serves a facility and a part of that facility is altered, let's say for example an office building, you'd have a single parking lot serving a single office building. There may be an obligation -- what they call to improve the path of travel obligation. So I'm not even altering the parking lot, but I am altering the tenth floor of this office building. I have an obligation to improve the path of travel from the parking all the way to that building and that may require that I improve the parking situation such as to provide for some accessible spaces to the extent that to do so is not disproportionally expensive. Now, if you have a question about an alteration of this type, we can provide you some guidance later on the disproportionality standard, but essentially it goes like this. I have to allocate at least 20 percent on an alteration to an area of primary function, in this case an office in an office building to improve the accessibility along a path of travel up to 20 percent. So if my parking is properly configured, then I'll be spending my money on the entrance, the horizontal and vertical circulation and then the secondary spaces like bathrooms, phone rooms, et cetera, and improving access to drinking fountains along the way; but as you can see even in an older facility, you may have to impact parking. What about existing facilities where you aren't even doing an alteration, an unaltered existing facility? Can I leave parking alone? Well, maybe not. Imagine in a traditional hardware store with its own small parking lot, family ran and operated, you know, under a third generation. After the passage of the Americans with Disabilities Act, even in those unaltered facilities, where there has not been any change of occupancy, not been any major construction, there has not been any alteration, you have an obligation to engage in what the ADA calls readily achievable barrier removal. Now, readily achievable barrier removal is a more general set of obligations for those existing facilities open to the public. So like this hardware store, you have to ensure that customers with disabilities have an opportunity to enter into a facility and conduct their business. This may affect parking as you clearly might see. Typically, even in a small lot like that, the Department of Justice considers the creation of a single van accessible space a priority in readily achievable barrier removal, but recall that it's a more general obligation to ensure that your services are accessible rather than requiring that your facility and its site comply in lock step with new construction standards. Like I said, it's a more general obligation. Now, what's possible, again, under readily achievable within let's say a year of the passage of the ADA is vastly different than what is possible 10 or 15 years. Since readily achievable barrier removal is an ongoing obligation, the ability to achieve a perfectly compliant parking space in six months for a small business may not be there, but it's unlikely that the DOJ or the courts would consider ten years an insufficient amount of time to muster the resources and ability to stage an alteration of a single space. So, again, even in these older spaces or older lots, you may have to impact parking and parking is a priority. One of the questions that we get is most often is how do I properly stripe a parking space? I would say that the second most popular publication that we send out electronically or fax or through the mail is a technical bulletin on restriping parking spaces called the ADA Business Brief: Restriping Parking Spaces published by the U.S. Department of Justice. It's a two page fact sheet that's available on our website that, again, we send out more often than anything, and it gives you most of the general requirements for providing an accessible space under the Americans with Disabilities Act, including a thumbnail of the vast majority of the scoping provisions that govern the Americans with Disabilities Act Accessibility Guidelines and parking. So for a Title II entity or state and local governmental entity, a Title III entity or business -- a place of public accommodation or business open to the public, or even an employer who provides parking, there are technical provisions for parking under the Americans with Disabilities Act. The essentials are this: A parking space properly designated needs to be designed to be 96-inches wide, that's eight feet wide if my math is correct. And in addition, it needs to have an adjacent access aisle. And by access aisle I mean an additional designated space to the side of the parking space that's used to allow a person with a wheelchair or a person who has a mobility -- who uses a mobility aid to clear their vehicle with that aid, and allow them to exit the vehicle and enter on to an accessible route to enter the site or the facility. Now, these spaces have to have a parking sign that indicates that it is an accessible space or a handicapped designated space at the front of the parking space. So, again, we've got an eight foot wide parking space and an access aisle. Now, the access aisle has to be in regularly configured accessible spaces, 60-inches wide or five inches wide. Now, there are also van accessible spaces that are required, and these require automatic 96-inch or eight foot wide access aisle. Now, you may ask why do you need a space that wide? The space that wide is to allow a person who uses a lift equipped or ramp equipped van to unshift that ramp and to clear it and get around it so that they can access the accessible route and enter into the facility or the site. So, again, this is allowing somebody who, let's say, typically uses a ramp or a lift to get down that ramp or lift, which may be three to five feet in length, and be able to clear the other side of it. >> DIEGO: I have a question along that line, Aaron. On this topic, one of the really popular questions is -- and I'll very simply put it -- accessible route to the accessible parking, can it travel behind the vehicle? Clarify that. >> AARON: Under most circumstances it should not. Again, it should not where possible. >> DIEGO: So is it actually possible it if there is an architectural infeasibility of some sort? >> AARON: If there is -- well, I mean it should not. There is really no better way of putting it. Ideally if the space is properly configured, you won't. Under certain circumstances, particularly in some parking structures and in -- and I guess in remodeled or renovated parking, you're going to run into the situation where it is. >> DIEGO: And you have to travel behind other vehicles as well? >> AARON: Yeah. >> DIEGO: Okay. >> AARON: So where possible and for very general reasons, liability reasons, you should try to avoid it. It's relatively unsafe, particularly for someone who is in a seated position to have to cross behind vehicles as you might imagine. It would be relatively hard to see somebody even in a small car who was coming behind you in a wheelchair. >> DIEGO: Right. I can think of an example where you go to a department store parking space that's covered, covered parking and generally it's cramped in those buildings, and I notice that they put a lot of accessible parking spaces by the elevator and they are up against the wall. And so you have all these access travel routes behind all the vehicles. And I've seen that several times. >> AARON: And you're going to tend to see that more in existing facilities or existing parking structures. It is possible to efficiently configure in a new parking structure to allow people to travel in front of the space. Now, that brings to mind another question. You do need an access route adjacent to the parking space. Ideally you should put a parking block barrier in front of a space so that you don't have people's vehicles let's say ticking out or nosing out over the sidewalk that makes up part of the accessible aisle. It's all well and good to properly configure a space, but if you create a set of circumstances where you're going to have let's say -- we're in Texas -- large SUV's blocking the accessible route, then all you've done is provide access to a wall rather than a walkway. Now, a question that we get is about the minimum number of spaces. In the Americans with Disabilities Act Accessibility Guidelines, there is a fairly simple chart. The figure that we get is 2 percent tossed around a lot, but that's little bit imprecise. There is a very specific chart on how many minimum number of accessible parking spaces that you have to have based on the size of the lot. For example, if you have a small lot with 25 or less spaces, you only need one accessible parking space; but it needs to be configured to be van accessible. If you jump up to where you have 200 spaces, let's say you have 207 spaces, then you need to have seven total accessible parking spaces, one of those needs to be van accessible and the other six needs to be the regular accessible parking space that has the 60-inch or five foot wide access aisle. Now, two accessible parking spaces may share an access aisle. If you have two accessible parking spaces and they share an access aisle. It does count as two and that is allowed. Some people with disabilities, particularly those who use lifts or ramps tend not to like this because it creates situations where they may have to back into a parking space to properly unshift their lift or ramp, but it is allowed under the law. So we've detailed the access aisles. We've detailed how wide they need to be. We detailed that they need to be on an accessible route and that there needs to be a sign. Well, a common question that we get is what color do we need to make the striping? And a common answer that we often hear from folks is that it needs to be that international safely blue. Well, I'm here to tell you right now that under the Americans with Disabilities Act Accessibility Guidelines, one, a space doesn't necessarily need to be striped. It needs to be indicated. A space needs to be detailed, but it could be done, let's say, with changing the color of the pavement providing an indication that the access riel exists by changing the material so long as you don't interfere with the cross slope requirement of 1:50. >> DIEGO: So contrasting colors. >> AARON: So you need some sort of contrasting colors. Now, this is typically done with pavement paint; but there is no particular color. In addition, the international symbol of accessibility that you typically see painted in the parking space is not a requirement under the Americans with Disabilities Act Accessibility Guidelines. So the ISA or international symbol of accessibility, basically that wheelchair guy, is not required in to be painted on the surface of the parking space under the ADA Accessibility Guidelines. It may be a requirement under a variety of state laws or local building ordinance schemes. So that's going to be another level for those people designing spaces that you check. It may be more specific understate law. What about the sign in does it have to be a particular type of sign? Under the Americans with Disabilities Act, in most cases, no. It requires that there be a sign, that it be configured a certain way, that the international symbol of accessibility be present on that, but it does not require that it be a particular color. If it's a van accessible space, the ADA merely requires that that be -- accessibility guidelines mainly require that that be indicated and that the sign be mounted in such a way that it's not blocked -- that it's not blocked from the vision of the driver. >> DIEGO: So there is no actual height requirement. >> AARON: There is no actual height requirement under the Americans with Disabilities Act Accessibility Guidelines. Now, that's vastly different under a lot of state and local schemes, for example, I believe we provided a link to the Texas accessibility standards which require essentially the sign to be hung with -- at 60-inches to the center of the information or typically the way that's interpreted is the center of the I. S. A. So five feet off the ground. Other states may have other requirements. I also provided a link to I believe it's Arkansas' law which actually requires a particular type of sign. Now, keep in mind this impacts the proper configuration of an accessible space, but has nothing to do with the ADA. These are both local law issues or state law issues, but they may very well impact the ability to enforce accessible parking limits. Under some circumstances, judges have been very generous to the claim that an improperly configured new parking space including having the wrong type of sign or having a less than clear designation of an access aisle has been an excuse for somebody to get away with a fairly expensive ticket, to petition the ticket. So it's important for people who are designing parking who wish this to be available to properly configure it and take an opportunity to look at the state and local laws that impact it. >> DIEGO: Before you move on, and I'm not sure if you're going to go to this topic next or not, one of the things we've gotten several questions on is law enforcement and enforcement of accessible parking rules and regulations. >> AARON: Well, we will talk about enforcement, but I actually wanted to get through some of the more technical requirements and get on to that. So if those can wait, please be patient, I will get to that, I promise you. Now the question that we get somewhat often and I'm surprised we don't get it more often is how big does a space have to be, how long does it have to be? We know how wide an accessible space has to be and the access aisles need to be, but how long? Well, I'm going to tell you right now that the Americans with Disabilities Act Accessibility Guidelines do not deal with that. Now common sense is going to tell you that your space needs to be long enough to accommodate typical vehicle. The space we see most Monday are the ones expressed in ANSI or is IBC which are proprietary codes created by the international code council or a variety of other building codes or industry standards that tend to suggest that the space needs to be at least 20 feet long and that's 20 feet long from the parking lot back. So in addition to that, that's a recommendation under the current version of the ANSI standards and I'm going to tend that's going to say that governs the way parking spaces are configured but are not required under the Americans with Disabilities Act Accessibility Guidelines. Okay, so moving forward, what about on street parking? Public entities that provide parking and enforce parking on streets are required to make some of those parking spaces accessible and comply with the general requirements under the Americans with Disabilities Act to the extent technically feasible. Beyond that, we don't have a lot of guidance yet. The Access Board, which is the federal agency that creates these technical provisions that end up becoming enforceable regulatory law are in process on public rights of way requirements. There are some general requirements, again, that parking spaces do comply, that we have parking spaces for people with disabilities on street side parking, both parallel, angled, et cetera. But we don't have it in the set of enforceable guidelines as yet because we don't have a final set of rules on public rights of way. I encourage those folks who are designing parking to review what we do have, which are some reports on public right of ways and some proposed rules on public rights of way. To the extent -- I can say it's this valuable at least. Right now that's what the federal government is thinking is compliant with regards to street side parking and accessibility. It's not in final form.Ite not enforceable, again, and probably won't be for many years to come, but since there is a general programmatic obligation for public entities like counties and cities to provide parking that is accessible where they provide parking for the public, then they need to attend to this. There are some pretty good guidance on how to properly configure even a parallel parking -- van accessible parallel parking situation. It sounds like it might be difficult but I'll encourage you that is pretty good guidance on that. What about temporary events? We get a lot of concerns brought to our office by folks that have gone to temporary events, such as street fairs, such as fair -- rodeos and fairs sponsored by counties and cities. Where parking is provided for the general public, even in a temporary event, then some provision has to be made for accessible parking for people with disabilities at the temporary event and it must be at that same ratio to the extent that you can as the ADAAG requires. So they need to go to -- they need to plan out the accessible parking. Now, this becomes particularly difficult in a lot of temporary events where -- imagine where you're -- a significant amount of the parking is going to be on occasional use lots, such as, you know, grass fields or gravel fields. Well, again, the requirement is that we have a parking space that meets those requirements and so they need to try to configure the accessible parking on paved lots that meet the standards as well as possible. They need to come up with some solution, particularly if it's a public entity and they need to make that part of their plan for accommodating people with disabilities as part of their overall scheme of accommodating people with disabilities in that setting. So even those more temporary events have to attend to parking as a concern. Now, the Fair Housing Act does govern parking in multi-family housing. Now, we get quite a few concerns about parking at condos and apartment complexes. >> DIEGO: I have questions on that. >> AARON: the general provisions for parking are that they must have a full range of offerings as all other residents. For example, if there is garage parking or covered parking or reserved parking, a full range of those must be offered to residents with disabilities at each parking type. And the general rule of thumb is that you must have at least a minimum of 2 percent of the total spaces configured in each one of those parking types to comply with the ADA -- or rather the Fair Housing Act. Now, the general standards that technical provisions that the Fair Housing Act uses, it defers to the 1997ANSI requirements which are essentially the same as the Americans with Disabilities Act Accessibility Guidelines with regards to cross slope and space size with the exception that it does not address van accessible parking. Nowhere in the Fair Housing Act design manual is van accessible parking dealt with, but since it defaults to an ANSI requirement, they do have a provision that the parking space be configured in new construction at 20 feet. The parking muscles be on an accessible route. In addition, any facility -- you can imagine a large apartment complex or condo complex, must have sufficient parking at all common areas such as lease offices, guest parking, separate parking at a pool, deck or tennis court if such are there and provided. So sufficient means at least one, and perhaps more depending on the size of the space, so 2 percent at least more even at those more common areas. What about parking for employees? I'm going to say that a lot of our calls are generated based on this concern, either the employer's human resource professional or an employee calls us. The Americans with Disabilities Act Accessibility Guidelines makes no distinction between the types of parking. The only -- the significant difference is this: Outside of the requirements for a facility or site, so let's say constructed in 1995 a parking space of -- a parking space or lot or structure of this many spaces has to be configured with this many accessible parking spaces and this many van accessible parking spaces which must meet all those technical provisions that we reviewed. Besides that, an employer that provides parking as a benefit or privilege of employment must accommodate their employees with disabilities with additional parking. So you can imagine the circumstance where all the accessible parking has been taken, all the designated spots and this happens with some regular layer it and an employ ea with disabilities races this as a concern. So where they can be accommodated, they may need to designate additional spots. Now, again, that's an individual workplace accommodation under Title I of the Americans with Disabilities Act that's had an impact on the built environment or the architectural reality of a facility or site; but again, that's an individual accommodation need. So if merely reserving them a spot close to an accessible entrance meets their needs and they are a person with a disability as defined under the Americans with Disabilities Act and that's a proper accommodation under the ADA, you may not have to do anything as extreme as let's say reconfiguring two spaces, putting in an access aisle, a sign, et cetera. You may merely have to reserve that space for somebody if that meets their needs. But again, you may actually have to alter it and add additional spaces. Now, the Americans with Disabilities Act does deal with valet parking. Valet parking under the ADA -- where valet poring is provided you have to have a passengers drop off zone as defined by the accessibility guidelines. That passenger drop off zone must be on an accessible route. Now, the attendants to the Americans with Disabilities Act Accessibility Guidelines recommends that in valet parking situations that you also provide self-park options that these should be given because the fact that many people's cars or van that is are modified for their accessibilities are very difficult or impossible to drive for others such as a valet. Now, valet parking is not addressed in either the uniform federal accessibility standards which govern again federal facilities, federally funded facilities or dealt were in the fair housing design manual and, however, there are of course facilities that are multi-family residents that do have valley parking. I don't live there myself but I know some people who do. Let's say, I think we've covered most of the technical provisions and I wanted to entertain some technical questions and any other technical issues that we didn't deal with will hopefully be revealed through there, but I make sure we cover the quiz content. If you can give me questions more of a technical nature, and then we'll move on to enforcement >> DIEGO: Yeah, I think you kind of glossed over it a little bit earlier, maybe in passing, but basically in a nutshell the question had to do with where you have several parking lots in one facility or serving one facility. Say, for example, one very far away, one very near to the facility, like on the facility, vs one far away where people would have to take a shuttle to get to the office building and so the question was what, you know, with regard to -- in the new construction or alteration for that matter com of those parking spaces would have to be compliant or have accessible parking? >> AARON: Well, typically you treat each lot as a separate lot. Now -- so you're going to look at five lots that serve a larger facility or site and treat each one as separate. Now, in some cases, particularly if we have different ages of construction, you may want to look at clustering your accessible spaces nearer to the -- let's say the building or the lot that is ' closest if that's an issue. This is particularly a concern with regards to public spaces such as parking lots that serve, let's say, large state universities. There may be 30 parking spaces, many of them far and out lying that could be configured to be accessible, but nevertheless would not meet individual students' needs with disabilities. As part of a general parking scheme, and to meet their program accessibility obligations, a university might consider, let's say, centralizing a lot of their designated parking for students, faculty and staff with disabilities. And they should be looking at, again, the reality of their facilities and how those are used. Now, this isn't to say that every lot should be beer reft of parking spaces because think of how parking is used particularly in temporary events at universities. So you may have a large field house that's hardly ever used, but you're going to want to make sure there is some accessible parking space e for alumni, guests and students on are going to let's say a basketball game. But a good strategy is to consider how a facility is going to be used. Now, again, to meet a program accessibility obligation and ensure that students can actually park on a campus and access the programming there as well as visitors, guests, you can consider clustering that parking. I think there was a question along those lines as well. >> DIEGO: You mean about accessible routes? >> AARON: I think about university setting actually. >> DIEGO: Yeah, the question was actually to do with a student who requested the accommodation, but the university wasn't providing -- in other words, it had two parking spaces or two parking lots. One far away from the building where I guess -- let's assume they walked to the school or they might have a shuttle, and the other one next to the building itself. And the question actually pointed out that the parking at the building itself had no designated accessible parking at all and this is a state university. >> AARON: Well, again, at the very least the closer in lot needed to have its proper ratio of designated spaces. There is a university can't argue that that's not a requirement. >> DIEGO: Right. >> AARON: but again, I think in that kind of setting they even need to think of parking as a programmatic access issue and look at their scheme for parking, even under the accessibility guidelines, you can offer an argument of equivalent facilitation and if they've done their homework and figured out how their students and guested fact actually and staff use the facility and chosen to cluster their facilities he can make a descent argument under the ADA. >> DIEGO: Right. Somewhat along those lines and this gets into a slightly different cap but I'll mention this question in case you have something that will take us in this direction. Somebody is asking a question -- one of our listeners is asking a question about what are the maintenance requirements for accessible parking, i.e, snow removal, one, obligations to keep the spaces clear and accessible and so on? >> AARON: Well, that's actually a very excellent question. Snow removal is not a big issue in Houston where I live, but water and debris is a concern as well as just maintaining adequate signage. We decided not to go with the visual presentation even though we have some great slides and a lot of you guys submitted some digital images, but you can imagine a set of circumstances where you have a sign properly configured, but there is some shrubs growing up around it. That's allowed as long as it doesn't interfere with the accessible route, but if they block the sign, you need to clear away the way to see the sign. You certainly need to have a regular course of maintenance to ensure that there is adequate snow removal so you cannot only park in that designated space, but see that it's been indicated that it's a designated space. The general obligation under the Americans with Disabilities Act is to maintain accessible features letter so if a feature of a site or facility had been configured to promote accessibility, then you have an obligation to maintain them. Parking lots -- particularly your accessible lots need to be on a regular course of inspection and maintenance. >> DIEGO: Okay. Something similar to that involves -- I forget what they are called exactly -- is it fire lanes where they are checked off for fire engines to park. >> AARON: Yes. >> DIEGO: And so -- and of course providers of parking spaces having to avoid obviously setting up a parking space there, and so, you know, they are talking about accessibility and the access routing and all of that. >> AARON: That's a good question and one that I'm less than satisfied with the answer for. But it goes sort of like this: The Americans with Disabilities Act Accessibility Guidelines allow you to default in favor of relevant state fire code with regards to this. Most of how are familiar with design and construction of facilities will notice that there tends to be a fire lane wrapped around those buildings. Now, I say the biggest offender in this is large box retailers. I won't name them, but imagine a large discount retailer chain out there, and there are several, when they build new facility, they tend to wrap all the fire lane all the way around the front and the side of the building where all the parking lots are leaving the back open or a significant amount of the back to allow for access to warehouse space, docks, et cetera. Now, this to a certain extent is -- is not totally ill conceived because we do want access for fire engines into facilities where we can save lives. My concern is that most fire codes do not require that you designate that much space. They generally require that so much space on either side of main entrances and secondary entrances, again, depending on how this is -- which state or locality we're looking at be designated at fire lane. Now, obviously you can't have parking in front of a fire lane, but it's general by possible to configure at least some of your accessible parking to be against the building and not across the traffic lane. Which is what you tend to see, a fire lane around the front of the entire building, an accessible route crosshatched in front of the main entrance leading to properly configured accessible spaces. Now, I'm going to say if it's being done in respect to a fire code, then it's probably lawful and allowed under the Americans with Disabilities Act, but I'm going to go out on a limb here and say that it's probably poor design. >> DIEGO: Right. Okay. We need to move away from the technical questions. You've pretty much covered a great area in the technical provisions and technical requirements. So I want to perhaps steer you, if you can, to answering -- there is like three or four questions basically relating to enforcement. And maybe you can touch on that topic. >> AARON: Yeah, why don't we go to the enforcement questions and if it doesn't reveal everything I want the say about enforcement, then I'll do a quick lecture. We've only got another 25 minutes or so. >> DIEGO: Right. Well, basically the main question that summed it up was basically with regard to people -- >> AARON: Read the question, if you will. >> DIEGO: So accessible parking without having a placard. So they are not authorized to park there and they get a fine. And the question was which fine law would apply? You've got local fines, state fines and say a federal fine? >> AARON: Okay. With regards to the fine structures, under the Americans with Disabilities Act there is no fine structure, okay? Enforcement is left up to localities. That's not to say that the federal government doesn't enforce accessible parking because they certainly do. I've got a friend of mine who lost his hangtag and parked at the V. A. hospital and got a ticket. Now, he is a veteran. He was seeking service, he is a person with a disability who is otherwise eligible to park but Lee didn't have his hangtag visible and they properly issued him a ticket. That is ' going to have a considerable fine. Outside of that limited setting, you know, then you're going to rely on state and local law. Now, as to which one that is, I'm going to say every state in the country has some law that makes it illegal, but in most cases, it's not state police that are enforcing the parking provisions, it's going to be parking enforcement or the local police that are going to enforce that. So you're probably going to be looking at a local ordinance that governs which fine structure you are responsible for unless you're talking about something on federal land where you've been issued a ticket by a federal law enforcement officer or security personnel. >> DIEGO: Right. Okay. I found in the stack of questions here something that might be slightly relevant to technical provisions as you asked earlier. And I think it's important to ask it because it's a really interesting question. Somebody is asking about -- say you drive up to a parking lot where you have to grab a ticket to go in and go through the barrier, and the question is are there any standards that regulate the ticket dispensing and the distance from, you know, where you reach out from the car to the ticket dispenser? >> AARON: Well, I'm going to say in most cases, no. I am aware that there are some states that have passed some local building codes that dictate more specifically about what they call fare machines. And this actually gives me a chance to introduce the new ADA ABA accessibility guidelines a little bit, but I'll back off on that a little bit. The guidance that we've been given is that should to the extent possible design or mount these machines in such a way that they meet the usability controls requirements under the Americans with Disabilities Act Accessibility Guidelines; but it's relatively hard to configure them considering the wide variety of vehicles that people use to be perfectly accessible. So, again, I think that's more of an aspiration al issue rather than a requirement. Now, this has given me a chance to open up a discussion of the Access Board's efforts and the Department of Justice's responsibilities with regards to a new set of technical provisions that's coming down the road. The Americans with Disabilities Act Accessibility Guidelines and the Architectural Barriers Act accessibility guidelines or the uniform accessibility standards have been under a process of review and amendment for quite some time. We have a final set of proposed guidelines that are before did U.S. Department of Justice for final regulatory rule-making or the administrative procedures that are required to turn this into enforceable law. In fact, they just closed an early comment period on the technical provision. Now, in all likelihood, we're going to have a set of new technical guidelines sometime in the next few years that look a lot like these proposed guidelines. I can't speculate as to what the date is going to be because things keep on happening, both much more slowly than we expect and then quite a bit faster than we expect it; but suffice it to say, we got quite a bit of time before these become enforceable standards and certainly we're going to have a forward looking effective date. So it's not as if there is going to be, boom, a new requirement and it becomes immediately enforceable, but it something to look for. I'm going to say that with regards to parking, it's done a pretty good job clarifying certain concerns, including addressing certain technical provisions for fare machines such as these fare boxes for pay -- or for fee parking. >> DIEGO: Right. >> AARON: Now, again, with regards to a set of guidelines that you might go to, rather than a set of enforceable standards, these proposed guidelines might be something to look forward to with regards to this, taking the pulse of what the federal government thinks should be done in front of the time when they become an enforceable set of standards. That's a little bit of pan Dora's box to open up, what they are call the Americans with Disabilities Act ABA access gilet guidelines and that's an entire additional presentation which we probably will be offering on down the road; but only after we figure out how to make our visual presentations more accessible. But they have dealt with parking. Now, they've changed -- and I'll thumbnail some of those technical changes. The parking spaces are configured under the Americans with Disabilities Act and the uniform federal accessibility standards with the notable exception that the Architectural Barriers Act or the federal part of that technical provision now require van accessible parking her they didn't touch them before. They allow -- they will be allowing a maximum cross slope of 1:48 rather than a 1:50 which is a little more a cleavable from an engineering perspective in alliance with most other commercially available building codes such as the I. B. C. 2000 and 2003. However, these new set of standards will raise the ratio of van accessible spaces to accessible spaces from essentially one out of eight to one out of six in response to studies of users and comments of users of lift equipped or ramp equipped vehicles. In addition, they clarified the obligation to provide an increased percentage of accessible parking at outpatient clinics and at rehabilitation clinics that serve people with mobility impairments. So, again, my overall comment about the proposed set of guidelines is you cannot follow them yet, but it's something to look forward to. Now, where they deal with issues that the Americans with Disabilities Act Accessibility Guidelines do not cover, they may be some good advice with regards to what you should do absent clear technical provisions. That's about as generous of a use as I can give you for them at this time; but you do need to be thinking about that for those of you who are involved in long term -- long term projects, let's say a major university or hospital facility or municipality, if you're engaged in that kind very long-range planning, you need to be looking ahead and learning about these proposed guidelines because you may have three, five, seven and ten year facility and site goals. And at some point, again, we will in the next few years have a new set of enforceable guidelines governing the federal requirements for accessibility. >> DIEGO: Aaron, let me throw some of these other questions that come in and they're not in any order. >> AARON: Let's get these out of the way to honor the people who are participating. >> DIEGO: For example, who enforces accessibility or parking accessibility laws in a private housing situation or a context? >> AARON: That would be the management. Now, in any private setting, it's going to be the management, but particularly with regards to housing. Now, a comment that -- I'm going to break that into two questions myself. A comment I get is that people with disabilities or property owners of even commercial facilities, let's say a grocery store, getting this answer from the police. It's private property. We can't enforce unlawful parking on private property, which is utter nonsense. That would be like saying let's take it to its most ridiculous extreme, it's private property so I can't enforce the state homicide law. You know, of course not, but in every state and locality in this country, law enforcement officers are allowed to prioritize misdemeanors. Now, where parking violations are even a crime and not -- and in certain jurisdictions they are a civil offense rather than a crime. I'm thinking of Fort Worth here and other places, but again, law enforcement officers are allowed to enforce it. Now, any number of law enforce am agency that we've had contact with have decided to prioritize accessible parking or enforcement of accessible parking laws for a variety of reasons. Generally, because it's good P. R. It's good practice. It's honoring our citizens with disabilities particular need. And to be honest, it's somewhat effective way to generate some income for the municipality. So I'm going to say again that they certainly can choose to, but under most circumstances they can prioritize more serious crimes. >> DIEGO: Would that be the same situation if you are talking about a public facility, like a store or department store? >> AARON: Yeah, I'm focusing on that actually and then I'm going to move on to the housing question. Now, in housing it's going to be management that chooses to enforce the parking provisions or not. Now, a reasonable request -- a reasonable accommodation request is that they do something to ensure accessible parking, that they come up with some scheme. Now, the difficulty is what you do. I don't think there is a great -- there is ever a great solution when we're talking about apartment or condos and inevitably a lion's share of the parking complaints we receive are with regards to housing. Either there has been no designate parking or the designated accessible parking is nowhere near my home or there is a bunch of people not disabled utilizing illegally obtained or counterfeit hangtags, and my management is doing nothing. And these are questions we hear quite often. Now, with regards to counterfeited hangtags or surely not license plates, I think most circumstances there is not a heck of a lot you can do. I mean, that's a law enforcement issue and a fraud or a felony as in Texas. With the fraud of how they are acquired, that's out there for the advocates to work for the licensing that issues eligible hangtags or license plates to have them do a more careful screening of applicants. I've personally seen a taxing authority issue six hangtags to an individual who had six titles to six vehicles they owned. It seemed a little bit over reaching to me, but again, that's not the ADA. That's going to be a local law concern. Now, the scheme that most of us -- well, let's see the solution that we offer here with regards to parking and residence is a tow policy. Where parking is an incredible premium, particularly where it's reserved and paid, you're going to tend to see some apartment complexes or condo complexes enforce a tow policy. Now, I have provided a link to -- I think it's a Louisiana state law that dictates what you have to do to enforce a tow policy. It's going to vary state to state, but the plan kind of lays down like this: Typically, you have to have a well posted and notorious set of signs on every entrance and exit that details that towing is enforced, and provides a 24 hour contact number to the tow company. So you'd have to negotiate with a tow company to enforce your parking. You'd have to come up with some scheme to ensure that someone wasn't wrongly towed and you'd have to ensure that that company could make their -- to make themselves available to somebody who felt that they wanted to reclaim their vehicle. Now, again, it's going to vary state to state, but I gave you a fairly typical one from our region to review if you are, let's say, a business owner or somebody who is designing a facility when you're negotiating for your sign bids, you may want to encourage this if this is going to be one of goals of the management company. >> DIEGO: Okay. Let me throw a couple a letter you that are more policy oriented. >> AARON: Sure. >> DIEGO: for example, you have a public institution like a school, university, public school, where they have a football arena and they provide accessible parking as required by the various ADAAG requirements and UFAS and so forth and then they have limited parking around some of their other buildings and the question was relating to a decision that they would open those accessible parking spaces around the arena for use during daily academic use when there are no games being played, right? Well, the question was what happens when there are games being played and the spaces are not being used? Who would make that decision is the way I interpreted the question and that seems to me like a private policy question more than an enforcement? >> AARON: I'm not sure what they are asking. These spaces are normally open but they are limiting them during game day? >> DIEGO: So everybody goes to watch a game and they can park there. >> AARON: and they wouldn't be open during the regular school week. >> DIEGO: Right. And the question is can they open them during the school week as well as even during a game for that matter? >> AARON: Well, they certainly can. >> DIEGO: So that ends up being basically their own policy? >> AARON: It's a policy issue as long as we're not talking about the same lots and we're not talking about something that's going to reduce the required ratio. If no one gets to use it during game day, then that's okay, because the ADA -- the joke is it only gives you the set of rights as everybody else. So if there is restricted for everybody during a certain amount of time that doesn't reduce the proper ratio, that's perfectly allowable. It seems silly, but it would be allowable. >> DIEGO: and I'm trying to go through some of these which are very long paragraph statements. They're asking about the regulations that enforce parking spaces and where do you find rules like that, whether they are local, state or can you give an idea? >> AARON: Well, you know, at the state level, I'm going to tell you that your governor's office on the concerns of people with disabilities or disability affairs may very well have a list of relevant state laws since parking is such a big issue, you might go there. I know that Texas does have a really good robust outline of state law issues and I've seen other states as well, including a review of the parking code from the state level. Now, with regards to local law such as county and city laws that may impact housing or rather parking, you're just going to have to check with that municipality. Not all -- even large cities have their ordinances online and available to search, about you all of them have a book of ordinances so that you should be able to call your city government or your county government and find somebody who can answer that question. A lot of these are increasingly available online. I know Texas has a county and city ordinance project. I believe at the university of Texas Law Center -- library, so they're trying to put a lot of these online, but it's just incredibly incomplete. Now, I'll tell you some small -- some small cities, and I'm thinking of a tiny city or a tiny town in Arkansas has probably the most searchable ordinance. So it bears in mind it's worth looking online. You may safe yourself some time. >> DIEGO: Okay. We've got just a few minutes left, basically, and for example, another question had to do with a store owner who has a few accessible parking spaces in front like the example you mentioned of the hardware store. And he's basically -- he just can't get people -- he can't get the authorities to enforce accessible parking because they keep using it. Does he have to enforce it and have them towed and have unauthorized people parking there towed? >> AARON: No, not under the Americans with Disabilities Act. >> DIEGO: So he doesn't have an obligation -- >> AARON: He has an obligation to maintain the space. He has an obligation to find a mechanism to serve people with disabilities, but he certainly can have a tow policy, but there is no requirement that that business owner have a tow policy. >> DIEGO: Yeah. Okay. >> AARON: And I'm going to tell you that the retailers tend to be a little bit skittish of this as an issue. >> DIEGO: Yeah. Exactly. >> AARON: They don't want to irritate their customers. >> DIEGO: I suppose the same thing goes for restaurants with a similar situation. >> AARON: Now, again, that's assuming that they have properly configured spaces and amount of spaces. >> DIEGO: Right. Right. And this question about a courthouse -- a courthouse which provides parking for patrons but has no accessible parking in site. That seems more like a programmatic question. >> AARON: Well, it's not a programmatic question. It's a lot configuration issue. >> DIEGO: Like an old courthouse, for example -- >> AARON: It's an old courthouse. They have an obligation to provide some accessible parking. So having none is a clear violation. So to the extent that its technically possible to make that lot comply, they need to do so, particularly as it relates to a courthouse that most of us have to use for one thing or another. >> DIEGO: And let me throw a couple of questions on employment related topics. For example, someone is asking if the employer provides no parking for the employees, may I request an accessible parking in the customer parking area since I use a wheelchair and have a van with a lift? >> AARON: You can request it and it merely has to be reasonable. You have a right to have a reasonable workplace accommodation. If they're going to deny it, then they probably need to -- they'd probably need to justify why it's an unreasonable request and find some other mechanism to accommodate that employee. So I can't imagine the situation where there is no employee parking, but there is plenty of customer parking, but I suppose it can occur. Probably in an urban area would be my guess. >> DIEGO: Okay, the other employment related question was I guess these are on similar grounds, you know, for example, where an employer has an office building and has several available accessible parking spaces on a first come, first serve basis and of course they run out of spaces and they have more employed disabled people than available spaces. Does that seem like another request for accommodation type situation? >> AARON: If they've got the proper amount of spaces configured for the structure or the lot, that's the minimum they have to do with regards to the Americans with Disabilities Act Accessibility Guidelines, but Title I or the employment provisions are a separate obligation, and they have an obligation to reasonably accommodate their employees with disabilities. So if it's abundantly clear that this is not -- that this is the case, that there are, you know, far too many people eligible to use hangtags, then they probably need to designate some additional spaces or start doing an assignment of spaces. Now you may run into a situation where you need to realign some spaces. Any number of people with disabilities don't need the access aisle, but let's say they have cardiopulmonary and maybe joint disease, they need to be close in but they don't have the kind of mobility impairment that requires them to need an access aisle. Then you can a sign them a space and free up a designated space. So human resources or if employer needs to be willing to do that when it's raised as a request for reasonable accommodation. >> DIEGO: Right. And then I had a question here which didn't specify whether it's in relation to private housing or a public area, but basically the question is if an accessible parking space has been in place for a long time, and then it gets removed, is that a violation of the ADA or any law? >> AARON: It would depend on the context. I mean, it would really depend on the context. I mean, have they reassigned it somewhere else? Did they do it so they would have more disbursed or is it a total reconfiguration? I'd have to have a little more question. What I encourage is that you raise that as a technical assistance question and call this in and give us more specific information. >> DIEGO: Okay. Well, with that, I want to bring this to a close. >> AARON: I've got a few closing comments. Again, we used to joke about this being something that was so easy we didn't understand why people had the difficulty complying with it and preparing for this I began to realize it's even more complex than we thought, but the feck nick al provisions are fairly clear. We want to encourage you if you have questions to call our 800 number, 1-800-949-4232. And again, if you're calling from 1 to 5 states you'll get us but otherwise you'll get one of the other nine technical disability business centers. For those of how are participating in credits, I'm going to encourage you again to by tomorrow complete the quiz. We are adhering AIA requirements which requires you complete the quiz and score at least an 80 percent to achieve the credit. If there is some technical error, we will make that decision. We'll give an opportunity for those who wish to dispute their score if they have failed to achieve that to take it again. To make this as nonpunitive as possible. This is our first experience, again, doing an AIA eligible program through a webcast. So I promise you that we will get smoother as the delivery on down the road. If you have any questions, again, please feel free to give us a call and I'm going to hand it over to Diego. >> DIEGO: Thank you, Aaron. I wanted to thank you for being on today's show as they say in the business lingo. And of course people can contact Aaron through our website or the bio information provided at the ilru.org website. I want to encourage people to please go to the Disability Law Resource Project's website at www.dlrp.org, which is where we host a myriad of publications of different sources, a lot of our own publications, other agency publications regarding the ADA and anything you want to know about the ADA but were afraid to ask, as well as the various other disability laws and I want to acknowledge the funding which funds this program, this webcast, which is NIDRR, and that's National Institute on Disability and Rehabilitation Research, and also I want to say thanks to the webcast team without whom this would not be possible, and that would be Marj Gordon, Sharon Finney, Dawn Heinsohn, Vinh Nguyen, Rob Dickehuth and Tajauna Dunning, Marissa Demaya and Maria del Bosque and this is the Disability Law Resource Project signing off from this webcast. Thanks for joining us.