(University of California, Los Angeles July 24, 1992)
©1992, The Regents of the University of California.
Table of Contents
The landmark Americans with Disabilities Act (ADA) of 1990, provides comprehensive civil rights protections to qualified individuals with disabilities in the areas of employment, public accommodations, State and local government services, and telecommunications. A primary goal of the ADA is the equal participation of individuals with disabilities in the "mainstream" of American society. Title II of the Act took effect on January 26, 1992 and covers programs, activities, and services of public entities, including the University of California. Most requirements of Title II are based on Section 504 of the Rehabilitation Act of 1973, which prohibits discrimination on the basis of disability in federally assisted programs and activities. The ADA extends Section 504's non-discrimination requirement to all activities of public entities, not only those that receive Federal financial assistance.
Under Title II, a public entity may not deny the benefits of its programs, activities, or services to individuals with disabilities because its facilities are inaccessible. A public entity's programs, services, and activities, when viewed in their entirety, must be made readily accessible to and usable by individuals with disabilities, except where to do so would result in a fundamental alteration in the nature of the program; result in undue financial and administrative burdens or threaten or destroy the historic significance of an historic property. This standard, known as "program accessibility" applies to all existing facilities of a public entity. Under this standard, the University is not required to make all its facilities or every part of a single facility accessible. Program accessibility may be achieved by a number of methods, including but not limited to: alteration of existing facilities to remove architectural barriers, the relocation of activities or services from inaccessible to accessible buildings, the redesign of equipment, assignment of aides to beneficiaries, home visits, or delivery of services at alternate accessible sites. When choosing a method of providing program access, priority is to be given to the one that results in the most integrated setting appropriate to encourage interaction among all users, including individuals with disabilities.
Where physical modifications are necessary to achieve program accessibility, a public entity with 50 or more employees must develop a Transition Plan by July 26, 1992. The plan must: list the physical barriers in a public entity's facilities that limit the accessibility of its programs, activities, and services to individuals with disabilities, describe the methods that will be used to remove these barriers, and specify the schedule for taking the necessary steps to comply with Title II of the ADA.
The removal of all physical barriers identified in the Plan must be completed as expeditiously as possible, but, in any event, by January 26, 1995. Interested persons, including individuals with disabilities or organizations representing individuals with disabilities, are required to be provided an opportunity to comment on the Transition Plan. The Plan must also be made available for public inspection for a period of three years.
This is an overview of the Transition Plan that UCLA completed July 24, 1992, in accord with Title II of the ADA. The Plan assesses the extent of architectural barriers to program accessibility on the grounds and within the buildings operated by the campus, estimates costs for their correction, sets priorities for their elimination, and provides a schedule for their removal. An ADA Transition Plan Work Group, comprised of representatives from the various programs and services on the campus as well as technical guidance from Capital Programs and Facilities Management, produced the Plan.
In his 1986 Commencement address, four years before the enactment of the ADA, Chancellor Charles E. Young made a commitment that UCLA would become as accessible as possible within the constraints of its topography. Since that time substantial amounts of funding and other resources have been made available to survey the buildings, identify barriers, and remove them. The effort to enhance campus accessibility endures to this day through major building renovations, special projects, and a process for identifying and eradicating program-specific barriers. The Transition Plan contained in this document is a continuation of that effort. The Plan delineates the extent of work that needs to be accomplished by January 26, 1995.
Many campus buildings were constructed prior to the enactment of access codes and were not originally designed to provide ready access for individuals with disabilities. While facilities constructed in more recent years have differing degrees of accessibility, various features within them are deficient as a result of changing code provisions. Numerous structures, however, have undergone remodel and alterations and consequently do comply more fully with current standards.
The Transition Plan findings, with respect to the general grounds and approximately 100 campus buildings that were reviewed, indicate that there is at least one route into each building (except the Men's Gymnasium and Dance Building) and a considerable number of the public facilities and programs within them are accessible to some degree by current standards. Additional work is needed, however, to remove the remaining obstacles to program accessibility found among such campus features as restrooms, telephones, drinking fountains, teaching laboratories, classrooms, studios, and other specialized use areas. Signage complying with ADA requirements does not currently exist in several campus locations. At a number of sites, fire alarm systems do not have visual signals. Parking is generally accessible, but some improvements are desirable in specific areas such as the Center for Health Sciences. An evaluation of exterior paths among campus buildings, including such features as curb ramps, walks and sidewalks, handrails, and contrasting striping on stairs, has revealed some areas that are deficient as accessible routes. Costs to remove these barriers are summarized in the following table.
| Item | Cost |
|---|---|
| Building Modifications | $15,000,000 |
| Fire Alarms | 1,600,000 |
| Signage | 829,000 |
| Program Stations | 58,000 |
| Exterior Routes/Stairs | 813,000 |
| Soft Costs | 7,000,000 |
| TOTAL | 26,500,000 |
It should be noted that approximately $8,000,000 of these barriers will be removed through the course of other planned building renovation projects.
UCLA's Transition Plan is comprised of fifteen principal sections, the first four of which are included in this overview. Following this introduction and executive summary, Section II describes the background of the campus' involvement in removing access barriers, enumerates the organizations and policies that deal with accessibility issues, and sets the context for the Transition Plan. Section III details the establishment of the ADA Transition Plan Work Group, the design criteria, and the process used to evaluate campus architectural barriers. Section IV summarizes the Group's findings, gives cost estimates, and provides a plan for eliminating the barriers. The remaining sections describe in greater detail the architectural barriers, as well as a methodology for estimating the costs to remove the barriers.
The following is a description of campus organizations concerned with architectural and programmatic barriers.
Chancellor's ADA & 504 Compliance Office. In 1986, the Chancellor created a full-time position of 504 Compliance Office (since 1992 the Chancellor's ADA & 504 Compliance Office). The person currently serving Coordinator of ADA & 504 Compliance is Douglas A. Martin Ph.D. His charge is to:
Chancellor's Advisory Committee on Disability (CACD). This Committee was established in 1982 as an advisory group by the Chancellor to create and maintain a more accessible campus environment. The CACD is comprised of student, faculty, staff, alumni, community, and ex-officio members. The Committee's charge is to analyze and identify problems, propose solutions, and make recommendations on matters of particular concern to persons with disabilities.
Union of Students with Disabilities (USD). The USD is committed to the precept that students with disabilities should be fully integrated into the mainstream of University life and have access to all academic and extracurricular activities. The USD serves as a voice for students with disabilities as an under-represented group on campus, and seeks to educate the non-disabled community about their needs, concerns, and abilities. The USD participates in the CACD as a subcommittee and advocates for improved programming and accessibility for all students with disabilities at UCLA. The USD was granted status as a Student Interest Group (SIG) in the Fall of 1989. As such, USD receives institutional funding, administrative support, office space, and telephone privileges to carry out its goals.
Office for Students with Disabilities (OSD). This office is mandated by the State to deliver core academic support services to students with permanent and temporary disabilities. The mission of the OSD is to assist students with disabilities in their endeavor to be fully integrated into the mainstream of all academic and extracurricular activities on campus. The OSD strives to fulfill this charge by safeguarding the rights of students with disabilities, educating the campus community regarding disability related issues, and facilitating the elimination of physical, programmatic, and attitudinal barriers. OSD has addressed needs such as procuring adaptive equipment, establishing and co-sponsoring a disability awareness month with the USD, and alerting the ADA & 504 Compliance Office of information regarding barriers that impede students' access to campus facilities.
In 1987, UCLA commissioned a private consulting firm specializing in accessibility studies, CHT Associates, to conduct a survey of each campus building to identify existing architectural deficiencies as compared to the access provisions contained in Title 24 CCR. The surveys for the General Campus and Medical Center were compiled into a three-volume document known as the CHT Report. Each of the items listed were assigned a priority ranking of 1 to 5, with 5 being the most serious and in need of immediate attention. The Report did not contain any recommendations for remedial measures, estimates of construction costs, or evaluations of how identified access deficiencies impinged upon program accessibility. The ABPT Subcommittee reviews the CHT Report on a continuing basis, and assesses and makes recommendations for the sequence in which barrier removal projects are undertaken. The assessment process also entails the identification and recommendation of priorities for addressing non-CHT access deficiencies that are identified by campus entities.
Beginning in 1989, UCLA established a formal process to monitor the correction of barriers noted in the CHT Report, and began annual reporting of the results to the State Legislature. Requests for disabled access corrections are channeled from the various entities on the campus mentioned above and monitored through the completion of the projects' construction phase. Since the reporting began, the campus has expended an average of $800,000 per year on the elimination of access barriers. The task of removing architectural barriers has been accomplished primarily in connection with other building renovation and remodeling projects and through special projects.
As noted in the introduction, the University of California is required to provide program accessibility in existing facilities under Title II of the ADA and, where physical modifications are necessary to achieve program accessibility steps required to bring them about. The UCLA Transition Plan is based on reviews of buildings and program areas of the general campus, the Hospital and related schools, Parking, Housing, ASUCLA facilities, and off-campus structures and is concerned with those physical modifications necessary to achieve program accessibility.
UCLA's philosophy and rationale for including items in the Transition Plan were predicated on a combination of factors. These consisted of:
As a strategy for achieving accessibility to programs, activities, and services the Transition Plan Work Group adopted the concept of "principal program access". This concept was then applied to each building or program area. Principal program access was defined as the provision of: (a) at least one accessible route from an accessible parking area and/or public transportation stop to the building, (b) at least one accessible entrance to the building, (c) at least one accessible elevator which reaches all floors containing distinct programs, activities, services, or major administrative functions, (d) at least one pair of accessible restrooms in each building, (e) at least one accessible telephone and drinking fountain in each building, (f) accessible areas in lecture halls, laboratories, auditoriums, and studios - referred to as accessible program stations, (g) key accessible routes throughout the campus grounds, and (h) accessible graphics, including raised letter and braille signage, and (i) accessible life safety features, including visual alarms for individuals with hearing impairments. Exceptions were made for very large and complex structures such as the Center for Health Sciences, Geology/Young Hall/ Slichter Hall, and Mathematical Sciences/Boelter Hall where the need for additional accessible features was addressed.
Reviews of buildings and program areas were conducted in two stages: the first stage assessed barriers associated with such features as parking, entrances, restrooms, signage, alarm systems, drinking fountains, and telephones. The second stage consisted of program-specific reviews with representatives of each of the program areas. These typically dealt with barriers to program stations, and related to such things as lab equipment and counter heights, service counter heights, lecture room seating, podium and stage accessibility, studio accessibility, and assistive listening systems. Each barrier was noted and assessed according to the eight selection criteria described above. As barriers to programs were identified, architectural reviews took place to determine the remedial work required to achieve principal program access. Consultants were then retained to conceptually estimate costs involved in removing these barriers. Concurrent with the cost estimating, the barriers were evaluated and assigned a priority number by the following criteria:
| Priority | Description |
|---|---|
| 5 | Highest priority - Access most urgently needed, this is typically related to a code issue or an identified individual need. |
| 4 | High priority - barrier severely impedes or completely blocks access to a program, service, and/or activity. |
| 3 | Medium priority - a barrier exists with some access but complete access does not exist for all programs, activities, and/or services. |
| 2 | Low priority - brings minor deviations up to code. |
| 1 | While not mandated, correction enhances campus accessibility and exceeds minimum requirements or will be corrected in connection with other planned building renovation projects. |
To estimate the completion dates for removing the barriers, consideration was given to other planned renovation projects. UCLA currently has several other renovation projects in the planning, design, or construction phases. These projects were overlaid with the barriers listed in the Transition Plan. The remaining barriers were assigned completion dates according to the anticipated funding acquisition process for that project. The following table categorizes the completion periods.
| Classification | Projected Completion Period |
|---|---|
| A | August to December 1992 |
| B | January to December 1993 |
| C | January 1994 to December 1994 |
| D | Complete by January 26, 1995 * |
| * For information only: Where scheduled, dates are listed for Planned Capital Improvement Projects. Consideration will be given to advancing project dates to meet ADA requirements. |
Alternative methods of providing program accessibility, including relocating programs from inaccessible to accessible sites, were carefully weighed by the Work Group during its process of building and program area reviews. It was determined, however, that in most cases primacy had to be given to the removal of architectural barriers as a more fitting method of resolving access problems than the relocation of programs. This was based on a number of reasons, including the fact that it was very difficult to determine which programs to make accessible by relocation because the general user population of students, faculty, staff, and alumni with disabilities are involved in an ever widening assortment of activities. Even if these considerations could be taken into account, there is still the necessity to accommodate visitors and patients with disabilities. The broad range of UCLA's programs, activities, services, and events attracts large numbers of individuals to the campus, an unforeseeable proportion of whom have a disability and consequently require access to an unpredictable number of locations. Other factors that supported physical modifications to remove barriers included; the substantial expense likely to be incurred by moving any of the numerous large UCLA programs, not to mention the lack of space available for such purposes; and the singular and program specific nature of much academic space such as laboratories and studios which make them nearly impossible to move.
As mentioned, an ADA Transition Plan Work Group was established from a diverse group of individuals and constituencies to coordinate the reviews and undertake the planning and analytical work required to produce a Transition Plan. The group was composed of the following members:
Representatives from the various campus programs also participated in the review. These include:
Although UCLA has made substantial progress in eliminating access barriers, with respect to the results of building and program area reviews of the general grounds and approximately 100 campus structures, there is still work to be done to provide full program accessibility. Following is a summary of the Work Group's findings regarding program accessibility to these areas.
General Access Within Buildings: Overall, there is at least one route into each campus building (except the Men's Gymnasium and Dance Building), although there are barriers and access deficiencies along various routes by current standards. Once inside the buildings, many areas within programs are accessible; but there are barriers to participation in the form of inaccessible program stations in key classrooms, specialized use laboratories, and studios. There is generally access to public facilities along the path of travel, but the facilities themselves have varying degrees of accessibility within them. This is due principally to less stringent access codes for design when these buildings were constructed, or in some cases, the buildings pre-dated the existence of any accessibility standards.
The current ADA Accessibility Guidelines contain a new provision requiring that signage meet design criteria relating to raised and brailled characters, character height, character proportion, finish, and contrast. The signage is designed to assist individuals with vision impairments to locate accessible routes, building entrances, and interior rooms and areas. There are no buildings on the campus that have exterior or interior signage that complies with the ADA requirements. A comprehensive signage program for the campus was therefore identified and included in the Transition Plan. The Plan calls for installation of these signs either through the course of other remodel projects, or by creating a separate campus-wide signage project.
Interior and exterior stairs were reviewed and those in need of upgrades for accessibility were identified.
In addition to stairs, a review was conducted of other elements comprising exterior routes, such as curb ramps, walks, and sidewalks. The findings show that there are areas where sidewalks are difficult to travel on because of uneven surfaces, and in several cases sidewalks are lacking altogether. In other locations, accessible routes among buildings are very circuitous. As a result, the Transition Plan calls for the removal and replacement of a portion of some sidewalks, and the addition of new ones. A campus-wide plan was also specifically developed for the replacement of substandard curb ramps and the installation of new ones. Because of the construction impacts of the Energy Systems Project, several of these sidewalks and curb ramps will be replaced by December, 1992.
Previous surveys and studies have been carried out to evaluate the provision of fire alarm systems on campus. The findings of the studies reveal that there are no ADA complying visual alarm systems for individuals with hearing impairments in buildings, and that other buildings have inadequate systems. The Transition Plan recommends a project to provide conforming visual strobe systems in the buildings identified as deficient in this regard.
There are two methods available to the campus to eliminate the remaining architectural barriers. One is through the course of planned building remodeling and renovation projects. UCLA is actively engaged in building remodeling projects to modernize facilities for seismic resistance, fire code and other life safety upgrades, and assorted program-related improvements and additions. When funding is obtained for the study phase of a remodeling or renovation project, an analysis is conducted to determine which of the access deficiencies, listed in the CHT Report, the project will likely address. Reviews are then conducted and current applicable code provisions are determined through the preliminary design and working drawing phases of the project by Campus Design & Construction Staff, and the list of proposed access corrections is revised as necessary. Additional examinations of construction documents are conducted by the Chancellor's ADA & 504 Compliance Office. Following the campus evaluations, the plans are reviewed by the Access Compliance Section of the Office of the State Architect prior to construction.
Another method is to develop projects especially tailored to the removal of barriers identified in the Transition Plan. In either case, barrier removal project scope and design will observe the most stringent respective provisions of applicable access codes under ADA, Section 504, and Title 24, CCR. The specific required code provisions will be determined on a project-by-project basis. The costs associated with removing the barriers are shown in Table 4 on the following page, and are further detailed in the in their respective sections. It is expected that UCLA will need to identify additional funding in order to complete these projects by the ADA imposed January 26, 1995 deadline.
NOTE: This document is available in accessible formats (Braille, large print, or computer disc) upon request from:
Chancellor's ADA & 504 Compliance Office
A-239 Murphy Hall
University of California, Los Angeles
Box 951405
Los Angeles, CA 90095-1405
Chancellor's
ADA and 504 Compliance Office
Last updated: 01/19/99
© 1998, Regents of the University of California.
