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Rochelle Callis <br />CRPD Therapeutic Recreation Program Final Report and Recommendations <br />September 8, 2017 page 40 <br />facilities, alterations to existing sites and facilities, or additions to <br />existing sites and facilities. The Standard was amended in 2010, and <br />became effective March 15, 2012. The 2010 Standards for the first time <br />included design guidance regarding parks and recreation assets, such as <br />playgrounds, sports fields, sports courts, pools, golf courses, fitness <br />facilities, bowling alleys, amusement parks, shooting ranges, boating and <br />fishing areas, and more. <br />There are several design guidelines one step away from becoming a <br />Standard. The 2017 change in Presidential Administrations has resulted <br />in a delay in the completion of standards for trails, campsites, picnic <br />areas, viewing areas, beaches, and more. As of this writing, these are on <br />hold indefinitely. <br />Federal Treatment of Existing Facilities: <br />There are always more existing facilities than new facilities. It is <br />important that the ADA address the treatment of existing facilities, and it <br />does so through the US Department of Justice (DOJ). US DOJ issued the <br />first ADA regulation on July 26, 1991 and it became effective on January <br />26, 1992. The title II regulation was amended and the amended <br />regulation became effective March 15, 2011. Within the ADA, title II <br />applies to CRPD operations, sites, facilities, and programs. It requires: <br />® Per section 35.105, the CRPD must conduct a self-evaluation of <br />policies, programs, and existing facilities. This is called an access <br />audit. Access audits before 2012 would not likely have addressed <br />park assets, e.g., playgrounds, because there were no standards <br />regarding accessible playgrounds. It does not appear that CRPD has <br />completed access audits. <br />Per section 35.150(d), CRPD must prepare a transition plan after it <br />conducts an access audit. A transition plan is a phased schedule of <br />retrofits to existing sites and facilities to assure that the opportunities <br />at those sites and facilities are accessible. It does not appear that <br />CRPD has completed a transition plan. <br />California has no such similar requirement. As a result, an entity such as <br />CRPD can be in full compliance with Title 24 and the federal 2010 <br />Standards, regarding new construction, but out of compliance regarding <br />existing facilities and ADA title il. <br />THE W -T GRd=', �. <br />DBA RECREATION ACCESSIBILITY CONSULI m .0 <br />ONE SOURCE. INFINITE SOLUTIONS. <br />