(STAMP) FEB 20 1993

DJ 202-PL-553

Ms. Helen S. Found

Board of Trustees
Pavilion Public Library
7925 Telephone Road
Le Roy, New York 14482

Dear Ms. Found:

This letter is in response to your inquiry into the

applicability of the Americans with Disabilities Act (ADA) to
your new library.

The ADA authorizes the Department of Justice to provide

technical assistance to individuals and entities having rights or
obligations under the Act. This letter provides informal
guidance to assist you in understanding the ADA's requirements.
However, it does not constitute a legal interpretation or legal
advice and it is not binding on the Department of Justice.

Entities that are part of a State or local government

program, such as public libraries, may choose from two
architectural standards when engaging in new construction:
Uniform Federal Accessibility Standards ("UFAS"), or the ADA's
Standards for Accessible Design ("Design Standards" or "ADAAG").
See discussion in the enclosed title II regulation at section
35.151(c) on pages 35,720 and 35,710. These standards are
generally quite similar, but with respect to signage there are
some differences. Once a standard has been chosen as the guiding
standard for a particular architectural project, that standard
must be followed throughout the entire project. For example, an
entity cannot design its ramps according to the Design Standards
and then install signage that only meets the requirements of
UFAS.

Private foundations that build or operate public libraries

must follow the Design Standards. They cannot choose UFAS as the
governing architectural standard. Please see the enclosed title
III regulation at section 36.401 on pages 35,599-600 and 35,574-
75.

cc: Records, Chrono, Wodatch, Breen, Mobley, MAF, FOIA

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You have asked whether there is a height restriction on book

shelves or stacks in libraries. Neither UFAS nor the Design
Standards restricts maximum shelf height under these
circumstances. Please refer to Design Standard section 8.5 at
page 35,668, and UFAS section 8.5 at page 58.

You have also asked whether signs such as exit signs need to
be in Braille as well as print. Under the Design Standards,
signs that designate permanent rooms and spaces, including exit
signs, must be in Grade 2 Braille and meet other specific design
standards. Informational signs and signs that provide direction
to functional spaces of the building do not have to be in Braille
but have to meet other requirements. Please refer to Design
Standard section 4.1.2.(7) at page 35,612 (scoping provisions for
new construction), and section 4.30 at page 35,659 (design
standards for signage) for more detailed information. UFAS does
not require signage to be in Braille. Please refer to UFAS
sections 4.1.2(15) and 4.30 (signage) at pages 6 and 47,
respectively.

I have also enclosed the Technical Assistance Manuals for

Titles II and III. The manual for title II discusses obligations
applicable to public libraries that are part of a State or local
government program. The manual for title III applies to private
library foundations. The Department of Justice publishes these
manuals to help entities and citizens understand their
responsibilities under the ADA. Please refer especially to the
comparison of UFAS and the Design Standards (referred to therein
as "ADAAG") in the Title II Manual at pages 23-32.

If you wish to subscribe to these manuals which will be

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

Sincerely,

Philip L. Breen
Special Legal Counsel
Public Access Section

Enclosures:
Technical Assistance Manuals for Titles II and III
Regulations for Titles II and III
UFAS
Technical Assistance Manual Order Form
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