Approximately 20% of the population has a disability. This means that millions of visitors to National Parks have challenges with mobility, hearing and seeing. The National Park Service (NPS) is obligated by both law and mission to ensure that parks are accessible to everyone.
Constructing and maintaining our facilities to be accessible is critical to ensuring that all visitors can equally benefit from their experiences. Barriers big and small can not only prevent people with disabilities from participating, but they can also pose safety risks. Facilities managers are key players when it comes to accessibility, but very often they haven’t been given the tools and expertise to ensure accessibility even when it is a priority. Sometimes this results in misconceptions about what the NPS needs to do and how it should be done.
Based in the Park Facilities Management Division, WASO Accessibility Program Support (AXS Program) works with facilities managers Service wide to improve accessibility. From experience working with the facilities management community, the AXS Program has seen the following myths about accessibility spread throughout the system.
Myth #1: Accessibility is optional.
Even though laws have required accessibility in facilities since the 1970s, many people still treat accessibility as something “extra” that we do for people with disabilities. In fact, code compliance for accessibility is the same as code compliance for electrical work and fire suppression – it is the law. Accessibility has clearly defined standards incorporated into state, national, and international building codes. Just as other codes are there to minimize danger for building occupants, accessibility codes minimize danger for people with disabilities. Facilities managers would not accept designs that aren’t up to other codes, nor accept the work of contractors that failed to meet the codes, and compliance with accessibility codes should be treated the same.
Myth #2: National Parks follow the codes of the Americans with Disabilities Act.
The Americans with Disabilities Act (ADA) was passed in 1990 and is the most familiar of many laws protecting the rights of people with disabilities. This law applies only to state and local governments and private entities, however. As a Federal entity, the NPS is required to follow the Architectural Barriers Act (ABA) which was passed in 1968 – a full twenty-two years before the ADA. In fact, the ABA is the model for the ADA.
But why is this important? It is important because this means that the NPS follows a different set of standards for construction and alteration of its facilities than other entities, called the Architectural Barriers Act Accessibility Standards (ABAAS). Federal entities are held to a higher standard than others. Contract language must specify that we are holding contractors to following the ABAAS standards, not the ADA standards.
Myth #3: Accessibility standards only apply to buildings.
The NPS maintains trails, campgrounds, picnic areas, beaches, boat launches, and a myriad of other outdoor recreation sites. For many years, there were guidelines for making these environments accessible but no official standards. Many don’t know that official standards were set in 2014 and apply to the NPS. Standards are now in effect for outdoor developed areas.
These standards cover trails, trail heads and trail facilities, outdoor recreation access routes, outdoor constructed features, camping facilities, picnic facilities, viewing areas, and beach access routes.
Myth #4: Exemptions are available when something can’t be made accessible.
It is possible that there are valid reasons for not complying with ABAAS; for example, the historic nature of a building might make it impossible to meet the standard and also preserve the building’s historic character. Even so, there are no exemptions to ABAAS. For buildings and sites, it is possible to request a modification or a waiver of the requirements. These are granted only on a case-by-case basis, and parks cannot grant these to themselves. For the NPS, a request for a waiver or modification has to be approved by the General Services Administration (GSA). Due to the formality of the process, requests for waivers or modifications should be planned well in advance of any work being done on a site.
For outdoor developed areas, exceptions (rather than waivers or modifications) are allowed. However, there are only four conditions for exceptions and the conditions for exceptions should be used only after all other design options are thoroughly explored. While these exceptions are not reviewed and approved by GSA, they need to be documented in writing and, in some cases, submitted to the Access Board.
Perhaps the final myth about accessibility is that facilities managers are expected to be experts in accessibility along with all of their other duties. However, help is available throughout the NPS. Every region has an accessibility coordinator that should be the first stop for questions about accessibility. If your regional coordinator can’t assist, he or she can work with WASO or DSC to get you the information you need. Or, you can contact the WASO AXS program directly at email@example.com.