Accessibility Planning for Persons with Disabilities

Introduction

Federal Buildings serve the public and receive substantial public visitation. It is the desire of GSA to make the programs and facilities at all locations accessible to individuals and groups with disabilities. For historic properties, the objective of GSA is to make programs accessible while protecting the historic fabric of the property.

GSA, along with the US Postal Service and the Department of Defense, has adopted the Architectural Barriers Act Accessibility Standards (ABAAS) as a standard for all new construction and renovations. Numerous publications on making historic properties accessible may be used for additional background.

In the case of historic buildings, ABAAS (F202.5 “Alterations to Qualified Historic Buildings and Facilities”) states that, “where the State Historic Preservation Officer (SHPO) or Advisory Council on Historic Preservation (ACHP) determines that compliance with the requirements for accessible routes, entrances, or toilet facilities would threaten or destroy the historic significance of the building or facility,” federal agencies are required to consult with the SHPO and some exceptions to ABAAS requirements may be permitted.

Identify Significant Building Features

The character-defining features of some GSA historic buildings have been identified in individual Historic Building Preservation Plans (BPPs), or Historic Structure Reports (HSRs). Contact the Regional Historic Preservation Officer, (RHPO), to determine if either of these studies has been developed for historic properties in question. The BPP program for historic buildings includes a feature rating system to indicate the relative value of each component inventoried. This six-level rating system is based on National Register of Historic Places guidelines and the Secretary of Interior’s Standards for Historic Preservation projects. Features are rated as follows:

1. Preserve - repair if deteriorated.

2. Preserve - replace-in-kind if deteriorated.

3. Preserve if possible - replace with compatible new material.

4. Preserve unless there is compelling reason to remove.

5. Remove, alter or replace.

6. No treatment specified; no cultural value.

By reviewing the feature ratings when planning future modifications or repair projects, planners and designers can determine which features should not be damaged, changed or removed, i.e., features rated at Level 1 or 2. Conversely, features which have less significance can also be identified so that changes can be planned for areas and features which are not the primary contributors to the property, such as features rated 5 or 6.

The historic ratings are printed adjacent to each feature name in the left margin of the BPPs and HSRs.

Determine Accessibility Needs

Management may do additional planning and survey work to develop a formal statement of accessibility needs and objectives, or a Needs Determination. However, a preliminary review of current operations indicates that visitors come to Federal Buildings for many reasons, including:

1. Business with the Postal Service, Courts, or any Federal agency tenant

2. Work required by their jobs

3. Providing support for systems that are in the building

4. Visiting to appreciate the historic character of the public spaces

GSA may wish to determine whether, in any particular building, there may be no accessibility needs for the non-public access portions of that building. If there are disabled staff working in the facilities, planning should be undertaken to address the particular needs and circumstances of the individual(s) and their work assignments. Conditions may change after the Accessibility Needs Determination has been made. Therefore, accessibility planning should be treated as an ongoing process.

Areas of a building may have different requirements for access, as well as different levels of historic significance. In some cases, it may be difficult or impossible to modify portions of a historic building to permit access without causing a loss of historic character. In cases like this, planners and designers may wish to consider “alternative” techniques, such as making the program or service available in areas which are accessible, or presenting the information from the non-accessible spaces in a presentation or exhibit in accessible spaces.

Conflicting program needs require creativity and initiative to find satisfactory solutions. The needs determination is a critical step in the overall process. For that reason, every effort should be made to involve the appropriate parties and resources from Field Offices and the Regions, and/or other experts as needed, in developing the Needs Determination statement, and proposing alternatives where required.

Evaluate the Options

A series of preliminary options is available for classifying areas within the buildings as public-use and non-public use. In addition, sources (Historic BPPs and HSRs) were identified to classify areas and components of the buildings based on their historical and architectural significance. All of these factors should be considered by GSA in developing an accessibility plan for each building. Other factors should be considered as appropriate. Once there is reasonable confidence that the needs and objectives for accessibility are clear, the objectives and policy for the building in question should be stated as a basis for action.

GSA recognizes that maintaining a viable accessibility plan is a dynamic process. The plan should be reviewed annually or more frequently if needed. Changes in building use, staffing, visitation or technology may change the balance achieved in the present plan and require changes in the plan and/or the facilities.