Crucial Opportunity: Weigh-In on the 2013 CBC Accessibility Provisions

in: Government Affairs / 37 Comments
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Leddy Maytum Stacy Architects, Ed Roberts Campus, photo by Tim Griffith

The AIACC has the timely but limited chance to shape the accessibility provisions of the 2013 California Building Code. As you are aware, accessibility compliance is one of the thorniest problems we face as practitioners. The Division of the State Architect (DSA) is seeking input on the format of these provisions, which will shape architectural practice in California for years to come, affecting how we make and defend our design decisions. It will, as well, have a significant effect on California’s national standing in current and future access code development.

To assist in the preparation of our response to the DSA, the Council has sought the guidance of three recognized subject matter experts (SME’s) in the area of state and federal access code development: Steve Winkel, FAIA, Jay Whisenant, AIA, and Kerwin Lee, AIA. Their recommendation will be presented to the AIACC Executive Committee for its final decision as the official position of the AIACC.

Your input is crucial, as well. We encourage you to reach out to the DSA directly with your thoughts, using the Stakeholder Input Form they have provided and copying your response to Kurt Cooknick, Assoc. AIA, Director of Regulation and Practice for the AIACC; and to share those thoughts with your colleagues in the Comment thread below.

This is the opportunity for us to engage in—and improve—an area of the practice that has bedeviled us for years, but time is short: responses are due at DSA by 15 February 2012.

The DSA has identified three options, which are summarized and discussed below. The DSA Discussion Paper is available in full here.

  • Option 1 – Current California Provisions – Continuation of current California provisions replacing the IBC Chapter 11 in its entirety, amended to implement State statutory mandates and to be consistent with the 2010 ADA Standards.
  • Option 2 – IBC Chapter 11 Provisions: Replacement of the current California provisions with the IBC Chapter 11 language and reference standard (ICC A117.1 – 2009), amended to implement State statutory mandates and for consistency with the 2010 ADA Standards.
  • Option 3 – 2010 ADA Standards: Replacement of the current California provisions with the federal 2010 ADA Standards amended to implement State statutory mandates.

A discussion of each option is presented below.

Option 1 – Current California Provisions
The CBC uses the IBC as its model code, which is tailored to California’s unique requirements with State Agency Amendments and adopted by the Building Standards Commission (BSC). However, in the area of accessibility the IBC’s provisions have typically been completely replaced with unique California language proposed by various State agencies and approved by the BSC. In essence California has historically developed its own “model” accessibility code with most provisions carried forward to subsequent editions as State amendments during the triennial code adoption process.

This would involve carrying forward the existing CBC Chapter 11B with revisions to the current language to ensure that the accessibility requirements are no less stringent than the revised federal requirements and to implement State statutory mandates. The 2013 CBC accessibility provisions would continue to be California amendments in their entirety.

Option 2 – IBC Chapter 11 Provisions

The IBC utilizes its Chapter 11 for accessibility scoping requirements, and a separately published reference standard, ICC/ANSI A117.1 Accessible and Usable Buildings and Facilities, for its technical guidelines. Scoping requirements indicate when, where or how many of something is required, and the technical guidelines indicate how compliance is achieved. The scoping provisions of IBC Chapter 11 are developed and approved through an open hearing and consensus process by the International Code Council (ICC) utilizing ICC voting members comprised of code enforcement and fire officials. The technical standards and guidelines within ICC/ANSI A117.1 are developed through an open hearing and consensus process supervised utilizing an accredited committee for approval.

Option 2 would require deletion of the current Chapter 11 B language, adoption of the IBC Chapter 11 model code language with California amendments to comply with the new federal design standards, implement State legislative mandates and retain unique California provisions that remain relevant and beneficial.

Option 3 – 2010 ADA Standards
The United States Department of Justice (USDOJ) published revised regulations for Titles II and III of the Americans with Disabilities Act of 1990 (ADA) in the Federal Register on September 15, 2010. These regulations adopted revised enforceable accessibility standards called the 2010 ADA Standards for Accessible Design. Beginning March 15, 2012, compliance with the 2010 Standards will be required for applicable new construction and alterations nationwide.

A goal in revising the federal regulations was to make the design guidelines more consistent with model building codes and industry standards in order to facilitate compliance. The revisions were coordinated extensively with model code groups and standard-setting bodies so that differences could be reconciled. In particular, the Access Board sought to harmonize the guidelines with the International Building Code (IBC) and access standards issued through the American National Standards Institute (ANSI). While the ADA is federal law focused on the civil rights of people with disabilities for equal access, a number of States have used it as a model code upon which their state level building code provisions for accessibility are based.

Option 3 would require deletion of the current Chapter 11 B language, adoption of the federal 2010 ADA Standards as model code language with California amendments to implement State statutory mandates and retain unique California provisions that remain relevant and beneficial.


Kurt Cooknick, Assoc. AIA

Kurt T. Cooknick, Assoc. AIA, is the Director of Regulation and Practice. With experience in the profession and over 15 years as an advocate on behalf of the architectural profession in California, he is passionate about protecting and advancing the profession.

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  1. avatar

    Stupid is as stupid does Daniel.

    Access is not mystery science, it is a receipe. Use common sense and it is easy.

    The best plans are often waylaid by the methods and means of inexperienced contractors or descoping owners.

  2. avatar

    Robert, the issue is one of legislative empowerment. If AIACC “really” wants to improve things then they should offer up a bill that empowers an agency to be the statewide ADA go to folks. Maybe CCDA?
    Right now it is a turf war as to who provides direction. You can ask CBSC for comments if you are a B.O.

  3. avatar

    There are presently 9 new access bills before the assembly and senate in the new cycle trying to dilute the Unrhu Act. AB 1610, 1878, 1879, 1994, 2041, 2282, 2325 & SB 1163, 1186. Read them.

  4. avatar

    The AG has previously issued an opinion that B.O.’s “do not” enforce the ADA. If the code complies with ADA then they will be enforcers.

  5. avatar

    DSA has contracted with one of the top US access experts to assist in resolving the outstanding issues between CBC and the ADA. Eliminating the CA exceptions is one of those issues.

  6. avatar

    Performance vs prescriptive standards, which is your preference? Many do not want to be “told” what to do, only that they “have” to do it. Some carry more E & O then others and some none at all.

  7. avatar

    ICC is trying to do this Don but they are not quite there yet.

  8. avatar

    Paul, you need to participate and comment to CBSC and DSA on the code rewrite process. Contact Dennis Corellis, Deputy State Architect with your thoughts.

  9. avatar

    Thank you for your service Frank. You are a greatly appreciated access pioneer.
    We need to talk, are you still in California?.

  10. avatar


    One day you will look back on your comments and realize that you have an opportunity to leave as your legacy to mankind, buildings and sites that provide “access for all”.

  11. avatar
    Craig R. Smith, AIA

    I agree with Janis Kent. I respect her opinion due to the fact she is so heavily involved with accessibility in our state. Her compilation of the 2010 ADA and the CBC are a big “tool” in our office and we are all looking for that “user-friendly” method and easier process to deal with this issue. I just hope that no matter what is adopted that she will put it into the same excellent format as her “Stepping Thru Accessible Details” compilation.

  12. avatar
    Susan Eschweiler

    All three options share the goal of assuring accessbility for all. However, the current situation with mulitiple conflicting standards and codes asures only that the architect can never be confident that the design is compliant. We owe it to the public to standardize and not keep changing the codes. Clients are very tired of having to pay to replace handicap ramps and restrooms that were designed properly as accessible only a few years ago but no longer meet a dimensional requirement of the current code and may be at risk for a lawsuit. I am in favor of Option 3 because it will be long lasting, less likely to change, and will provide a single unified source for good accessibility design. As architects we will then be able to accurately design and confidently specify the best, long lasting solutions for our clients.

  13. avatar
    Jay Hyde

    Option 3 2010 DOJ ADA Standards) with California Amendments.

  14. avatar
    Theresa Townsend, AIA, LEED AP

    In the spirit of sustainability, Option C will provide safe harbor for ADA projects built in 2014 and thereafter. This would save alot of future resources by not having to rehab projects that at a previous time met the code. Something to consider.

  15. avatar
    Don Gottfeld, AIA,NCARB

    It seems crazy that we, as architects, are required to continue our education on this code issue so often. How many times should we have to go over and over the same accsesibility issues so often? Accesibilty is extremely important, but let’s prioritize and start focusing on other (code) issues that are just as important.

  16. avatar
    Daniel Guich, AIA

    Yes!!! Let’s go with ICC ANSI 117.1!!

  17. avatar
    Daniel Guich, AIA

    I agree with Robert. The ICC gets together to come up with a uniform code that can address a wide variety of issues that are applicable to multiple regions and then in turn could be modified or amended to better fit a particular region. Why does California have an elitist attitude about accessibility. What is the difference between a disable person outside of California vs. from within California. Why doesn’t California just participate in the ICC’s review and consensus meetings for future codes instead of duplicating the ICC’s intentions within California just to produce more gridlock and red tape. Not to mention the conflicts with federal laws. Let’s go with Option 2 and put the issue to rest. I find the ICC ANSI book easy to use and makes a lot of sense.

  18. avatar

    I like option 2. I have used the IBC in other states and I like the ANSI A117.1-2003 booklet. It is easy to use and straight forward and its about time California stops being cool and different. Chapters 11A and 11B are the most convoluted parts of the code and we always spend time looking for things there whereas the ANSI 117.1 book is small, straightforward and easy to use. The most awkward part, being an architect, is that you have to tell your client that they can be sued for civil rights violation just because you have to use chapters 11A and 11B in the design of a building and that parts of the California access codes can conflict with federal laws. I find that pretty STUPID!

  19. avatar
    Janis Kent, AIA, CASp

    As an architect and someone who has been involved in accessibility since the mid-’80’s I find it very disturbing that California as a State has not gotten certified by the Department of Justice in these last 20 years. Being certified will make it easier for Architects and others to be in compliance with the ADA. It will also be easier on building officials since they will no longer have 2 sets of directives, one of which they are obligated to enforce and the other (ADA) which they are not, which does lead to a great amount of confusion.

    So Option 1 of keeping the CBC has not led us to being certified by DOJ and I do not think it will in the future. Option 2, the ICC, does not address all portions in the ADAS nor is it certified by the Department of Justice. I do not see the benefit of adopting yet another standard we need to modify for California.

    Option 3, the 2010 ADAS has a more user-friendly format to follow. And being easier will hopefully lead to better compliance. Be aware though, we would still need to keep Chapter 11A since that is not an ADA issue.

  20. avatar
    Robert P. Demmond, AIA

    Reading the posts and the Options available to us, I support setting aside the current California Access Code and adopting the IBC Model Access Code (Option 2)–regulating how we address accessibilty within the State of California. My support of Option 2 comes with one caviat–we adopt the IBC Model Access Code with no California amendments or legislative mandates.

    In order for the IBC to maintain its relevance from state to state, California must honor what has been agreed upon to be the model for all. Imposing amendments onto the code is to say that California does not agree with provisions within the code, and therefore, California is going to impose its own interpretation onto the code. This elitist attitude (within DSA) must be stopped!!! California is over-regulated and we as a profession, need to stop the regulatory pressures from the State–telling us what it thinks is best for the application of the Access Codes. Considering the fact that DSA will not provide any code interpretation assistance unless it is on state-funded projects, DSA should no longer be in the business of drafting access code language for projects out of its jurisdiction.

    If DSA’s elitist attitudes are not possible to set aside, then maybe there should be two sets of Access Codes–one for state-funded projects and one for all other projects. This option would give the state the ability to have dominion over its own “code” as it wishes–to be applied solely to state-funded projects; and at the same time allowing local jurisdictions to work with a code that is accepted and applied consistently throughout the country (ANSI A117.1).

    The State Legislature should have no authority over the access codes. Special interest groups should have no influence on the code development process. An impartial statewide committee (via AIACC) comprised only of design professionals together with local building officials should be responsible for the oversight of the access codes and how the State of California works together with the other 49 states and ANSI on how the code is to be drafted and applied. Taking this a step further, the statewide committee should be responsible for selecting delegates to participate in the ANSI open-hearing process when code revisions are being considered.

    Putting the code adoption and application process into the hands of design professionals and local jurisdictions is the only way we are going to bring respect to the access codes and how they are enforced throughout the state.

  21. avatar
    Lynn J Muir AIA-E

    I work with code on a daily bases and find that nobody really knows what is required. The codes are grossly over complicated. Accessibility could be simple if people writing the codes understood what accessibility is. What must be stopped is the extortion going on on a daily bases.

  22. avatar
    Miguel Enguidanos

    Working with the building code everyday, it is ridiculous that California continues to support CBC T-24 accessibility. I think it is purely political between the special interest groups.

    In my opinion, option #2 would be a preferable option but would like ADA and ANSI A-117 to be darn close. For example, I am hearing that tactile domes will only be required at transit platforms and no longer at curb ramps, etc. I think that is a fine idea and deals with the whole wheelchair vs. visually impaired issue.

    ADA is currently only enforced as a judicial action. The whole ADA/ A-117.1 must be incorporated into the code so as to make sure it is enforced by code officials and to hopefully reduce these people that just go around and sue when they find barriers.

    We need experts like Kerwin Lee, Steven Winkel and Craig Williams to write some articles.

  23. avatar
    Anne Zimmerman

    My first choice is Option 3, then Option 2 as fall back. One of the biggest issues between ADAAG and CBC right now is that ADAAG is very clear that the 20% limitation for remodels is not just for a limited dollar value project, and in fact that has been a point of contention, as I understand it, between CA and Feds re: getting CBC certified as being in compliance with ADAAG. The most important thing is for the solution to be certified by the Feds as conforming to ADA so that we, as professionals, have a “safe harbor” vis a vis compliance.

  24. avatar
    Dennis Thompson

    This 1/2/3 issue aside for a minute, I would like to see the CCAIA lobby for accessibility code changes at most every 6 years, or two code cycles. As it is now, we constantly have to be trained for the next code, then use it briefly, before we have to be retrained for the next code again. At what point can this code be stabilized? Why is there need for such frequent changes?

  25. avatar
    Douglas Booth

    I have not studied this issue and have only my practice experience and one reading of the three options to guide me. Based on that I would vote strongly for Option 3 with the idea that in the next code cycle option 3 and option 2 would be the same code. I think Californai should excercise its leadership on a national basis rather than strike out on its own. The world is gettign smaller and people with disabilities should be able to expect some consistency in access features wherever in the country they go.

  26. avatar
    Don Watts

    A constructive suggestion:
    Having been in professional private practice for more years than I care to remember, and watching the access standards grow from a thin manual of guidelines, to a huge collection of varying standards and punitive penalties from various government entities, it has become a nightmare, which can be almost impossible to negotiate, unless of course you are an access specialist.
    I think, rather than more of the same, a serious attempt by all code writing agencies should be to write ONE UNIFIED NATIONALCODE.
    Access issues do not change from state to state so radically that it cannot be done.
    It must be done in a way the average citizen can consult and comply with.
    California can be part of a unified effort, also, it would save a lot of money to do so, since the weight of this self perpetuating bureaucracy would help reduce the roadblocks to a financial recovery for the state.
    It’s time to be realistic, and recognize this.

  27. avatar
    Paul Pratt

    My main concern (if we transition from the current California provisions) is the transition for existing buildings and the definition of an existing building (CBC 202 and CBC 1134B). Currently these sections conflicts with federal definitions but provide a level of protection for our clients.

  28. avatar
    Frank Moffett, NCARB

    I served as co-author and publisher of the Washington State Accessibility Regulations (the first in the nation to received DOJ equivalency recognition), and was looked upon in the state of Washington as the Subject Matter Expert on the architectural implications of the regulations between 1972 and 2002 (when I moved to California to work for the Navy).

    Option 3 is the preferred option, as it would reduce the cost of compliance, and establish a standard for California consonant with those of other states and of the DOJ; thereby eliminating much conflict and potential for litigation.

    Enforcement in the state of California is spotty, at best, and downright dismal in many local jurisdictions. The provision in Title III for “readily achievable measures” (to be completed by July, 1992) has been ignored, by and large, and present day efforts to provide accessibility display the general ignorance of (well-meaning) owners, contractors, and, presumably, architects and designers, as related to the ADA.

    Even for those buildings built since the enactment of the ADA in 1990, I can walk through most of them, and using only my eyes, arms, and thumbs as measuring instruments, point out numerous violations of the ADAAG. This fact should bring shame to building officials and all those involved with building design and construction statewide. Unfortunately, it appears that only a few lawyers have made any attempt to call attention to these failures, and it is rumored that they have settled out of court, which gives the impression that they had no concern about the disabled persons for whom the ADA was created.

    Option 3 would establish a benchmark for compliance, but still would require the education of not only architects, but other designers, contractors, and the general public.

    At age 80, the need for reform in California becomes increasingly obvious .

  29. avatar
    Todd Smith AIA

    Option 3 – 2010 ADA Standards – this is what I end up designing to anyway for most of my projects.

  30. avatar

    As a newly licensed architect in CA, I am part of a generation of designers that find themselves in a world of buildings increasingly ruled by codes that are more complicated than ever, for better or worse (CALGreen comes to mind in the for better category). ADA provisions enforced by Federal Title I lawsuits are probably the worst. To put it into perspective, the vast majority of these lawsuits do not have a victim and that means the outcome are costly repairs to the building and lawyers getting paid (up to $10,000 in legal fees and up to $4,000 to the victim per incidence- is your blood boiling yet? It should be). We can follow the building code, satisfy the “Standard of Care,” and our owners can still fall victim to lawsuits. The owners cannot then turn and sue the builder, architect, or building official because they would not win because that is not the standard enforced upon our profession- at least not yet.

    I suppose this is why CA and the DSA are bringing our code into par with the “most restrictive federal standard.” This sounds like a good thing on the surface, but what about existing buildings being remodeled? Some of us may assume that since a building built in 2011 met the building codes that everything is fine, but given the current course of action by our politicians, that would not be a safe assumption. I would like to make the argument that the Federal Standard being imposed on CA is a system that is corrupt, and we should be lobbying Sacramento and Washington to take a good look at who the real “victims” are here.

    California was the first to adopt a model code for accessibility standards. Now, the DOJ wants to enforce their standards on us. Where is the justice when my client gets sued because his/her single-occupancy restroom toilet has a sink within 60″ of an adjacent wall in a restroom that provides plenty of room for a person in a wheelchair to turn around- if we follow the current CBC that is usually a 56-59″ space, with plenty of room to the side for a person in a wheelchair to maneuver (28″ CBC minimum) as well as turn around. However, that is what the CASp “experts” have argued and won in court. A large part of this is, in my opinion, the result of the CASp standards that Governor Schwarzenegger enacted. We were promised more clear laws and less standards and regulations- look how that turned out. Now we have “accessibility experts” arguing their interpretation of the “most restrictive standard” in court, and setting precedents that the rest of us need to hire one of them in order to follow. Oh, and just to mention again that there doesn’t need to be a “victim” with a disability for the lawyers to get paid? Anyone can file a lawsuit, in the name of making the world a better place for people with disabilities.

    My friends, I urge you all to take a look at what legacy you are leaving our younger generations and children to join the profession- run away, run away!!! The model code for accessibility in CA has been largely unaffected by change over the last 20-30 years. So then, why is it that all of a sudden the DOJ can tell us that there are victims if we don’t follow their standards? I firmly believe that the only real victims are our owners. I also firmly believe that not fighting back against the DOJ is doing CA a disservice. If we don’t, only lawyers and politicians benefit.

    I am writing this post anonymously to the public. The only reason for that is that the views expressed here are not necessarily the views of the firm where I currently work.

  31. avatar
    Gus Fischer

    How about an option that addresses the silliness of having two substantially similar (but often annoyingly contradictory) enforced standards. Anyone can understand why California created an accessibility code 25+ years ago in the absence of an accepted code standard. But now with the Federal ADA mandated and adopted as law, there is no reason not to sunset the separate California standards. Why not embrace the ADA and make sure that the IBC codifies it accurately in the model code and then California could just adopt it “as is” without amendments. The California requirements are just not significant enough to justify a completely unique accessibility chapter in every code cycle and the confusion and burden it causes California’s designers, builders, and enforcement officials.

  32. avatar
    Ruth Knapp Vallejos, AIA

    Let me preface my comments by saying I’m not a code maven. But I do have problems with how accessibility has been “codified” or not. I see this effort by the SME’s and AIACC to be time well spent for everyone.

    Firstly, it would be preferable to have the “whichever is strictest” interpretations instituted as part of the code. We do have stacks of interpretations for a variety of situations. The architect should not be left in the position of asking which provision is considered most strict and have the building official shrug his or her shoulders.

    Secondly, there are full blown accessibility manuals that cover this, but it would be great to have an accessibility version of “effective use of the code” that takes the architect thru the most basic decisions and gets to the fine grained stuff at the end. I’m a little tired of projects where people are flipping out over the shape of the shower when you can’t even enter the building effectively.

    Lastly – How will any of these alignments work with differing schedules of change? For instance, if we follow option 3 and follow the ADA primarily, will the code be updated as the ADA is updated? This is a schedule the State has no control over.


  33. avatar
    Rick Grandy

    I perfer option 3, it appears it would reduce the confusion of who’s on first.

  34. avatar
    James C. Dorr AIA

    I agree with Dawn Anderson’s suggestion regarding the reduction of Chapter 11 similar to Chapter 22 by citing provisional references (ADA&ICC/ANSI 117.1). Once accomplished, we could also eliminate the requirement for 5-hrs. Accessibility Continuing Education by reducing it to a simpler Significant Code Change webinar or seminar, simplifying the administration of license renewal.

  35. avatar
    Dennis Thompson

    Frankly, I wish we could have a moratorium on accessibility code updates. This whole issue takes an huge amount of our time to begin with, and the constant code changes complicate matters immensely. Can’t we skip a code cycle or two?

  36. avatar
    Kerwin Lee

    Options 1 or 3 do not use a truly consensus document. There is a misguided perception that adopting the ADA 2010 Standards is going to bring us closer to a single document for disabled accessibility. That is kind of the hope and dreams of people who favor Option 3. There are a couple of real draw backs in using option 3 and the 2010 Standards as the model. First of all the 2010 Standards was not written to align, support or intended to be used with other documents or a part of an overall building code. So sticking this into the CBC/IBC will cause problems and require rewriting the code to make sure that this Chapter 11 supports or is supported by the rest of the code. The second big thing is that the 2010 Standard is not a consensus document and does not have any consensus process for revisions. It has taken DOJ 20 years to revise the standards. It may never happen again. There is no real method to revise the standard other than in participation with the Access Board and the DOJ. Although there is some technical support from DOJ, this is limited to questions. There is no plan review services provided.

    One of the goals and objectives of the Building Standards Commission (BSC) is the adoption of a nationally recognized model code to base the State’s regulations on. Although the State does adopt the International Building Code (IBC) for this purpose, this has never been true for Chapter 11. Option 2 is the only way to bring the State back into alignment with this objective and have a consensus document. In addition to this alignment, there will be many other positive aspects:

    1. This will help to bring a more uniform code for the nation and not code that is applied in California.

    2. This will allow utilization of the national forum for code changes. Both forums for IBC and ANSI A-117.1 are open consensus process.

    3. Using a uniform, open, unbiased, consensus process with participation from all affected parties, including architects and affiliated design professionals, to deliberate adoption California codes and regulations, and make submissions of code changes for review at the National as well as State level. This recognizes the value of national model codes and encouraging the participation of all interested parties, especially state agencies and California interest groups, in the national model code development process to minimize the necessity for California state amendments to national model codes and standards. Although the 2012 edition of the ICB does not incorporate the 2010 Standards, this will happen in the 2015 edition. ICC has already started their code development cycle for the 2015 code, which will have changes to align with the 2010 Standards.

    4. A set of comprehensive, coordinated and contemporary codes for the state based upon a single family of national model codes and regulations.

    5. By aligning with the ICC, the State would be part of a nationwide system recognizing the necessity of integrated education of the public, design professionals, the construction industry, and regulators regarding the development, implementation and interpretation of codes and regulations

    Option 2 is our best answer to our current code dilemma.

    Kerwin Lee, Architect, CASp

  37. avatar
    Dawn Anderson

    California’s Government Code 4451 through 4460 requires that California enforce the strictest interpretation of both the model codes and the ADA, not one or the other. Building officials can only enforce the California Building Code as written – so let’s write it right. We need code that satisfies DSA’s Options 1, 2 and 3 simultaneously. The ICC and State agencies have done well to include and adopt new regulations for seismic design over the years, the CBSC can facilitate a similar same win-win around accessibility codes. Let’s reduce our Accessibility Chapter to 5 pages as we have done with Steel Chapter in the CBC; citing provisional references (ADA & ICC/ANSI 117.1) and including California amendments as needed – less is more! But, perhaps more importantly, our state is falling behind as the administrative leader and bastion of civil freedoms (Unruh remembered) and our shared objective is to be become certified by the DOJ as required under federal law – this shouldn’t take 25 years.

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