The document is a letter from a disability rights advocate to school administrators detailing accessibility issues at the Somerville School Administration Building in 5 areas: parking, entrance, doors, signage, and accessible routes/emergency egress. It provides code requirements for each area and estimates costs for resolutions such as resurfacing parking ($6,000), reconstructing the entrance ramp ($3,000), and hiring an ADA consultant. The advocate recommends hiring a consultant to evaluate all school facilities and guide improvements to accessibility and compliance.

1. CAPS attempted to resolve Somerville Schools Administration Building complaint
internally. October, 2009. page 1 of 8
Begin forwarded message:
From: Community Access project <CAPSom@verizon.net>
Date: October 4, 2009 3:13:44 PM EDT
To: Gretchen Kinder <gkinder@k12.somerville.ma.us>
Cc: tpierantozzi@k12.somerville.ma.us,
mbastardi@K12.somerville.ma.us,
mniedergang@k12.somerville.ma.us,
mcardoso@k12.somerville.ma.us,
pbockelman@k12.somerville.ma.us, barry.rafkind@gmail.com,
<ceng@kidsclubs.org>
Subject: Architectural Accessibility Code & ADA issues at
School Administration Building, 181 Washington Ave,
Somerville MA 02143
Dear Gretchen, and Superindendent Pierantozzi, School Committee President
Maureen Bastardi, Vice-President Mark Neidergang, and Facilities Committee
Members Theresa Cardoso and Paul Bockelman, Human Rights Commission Chair
Barry Rafkind, and Boys and Girls Club Director Chile Eng:
This is follow-up on Gretchen and my summer correspondence regarding the
inaccessibility of the Somerville School Administration Building@181 Washington,
Somerville, 02143. I am writing in good faith, but the message is unambiguous:
unintentional discrimination has the same effect as intentional discrimination- good
people are excluded, and good people will be held liable.
Also, there may be a need for clarity regarding whose responsibility this is. It does
not matter that the School Administration is renting from the Boy's and Girl's Club
facility. This is the School's responsibility under Title II of the ADA (28 CFR 35) ,
and, as a recipient of federal funding (34 CFR 104). Of course, it is also necessary
for the Boy's and Girl's Club to be equally accessible to all employees and
participants as well.
This email reviews 521 CMR (and, where appropriate, ADA), to detail the code (and

2. CAPS attempted to resolve Somerville Schools Administration Building complaint
internally. October, 2009. page 2 of 8
civil rights) issues for Parking, Entrance, Door, Signage, Accessible Route and
Emergency Egress- with applicable current photos of the Administration Building
site. A Recommendation concludes this correspondence. (Included are some
ballpark guesstimates derived from facility transition plans. I have absolutely no
business or personal connection or interest with, or in, the construction industry.)
These civil rights issues cannot wait for future relocation solutions! Your
collaborative response is anticipated. I thank you all for caring for Somerville's most
precious resources.
Best Wishes,
Eileen Feldman
DisAbility rights Advocate, Ward 3
Community Acces Project Director
1. HP PARKING
Resurfacing, restriping: ~ $6000 .
You have indicated that this is the accessible Parking space. It needs a level texture
throughout with a cross-slope not exceed 2% throughout. In addition, restriping is
indicated. In addition, this is not yet a viable passenger drop-off spot either. State
AAB code is pasted below for your convenience:
521 CMR 23.00
23.3.2 In parking facilities that do not serve a particular building, accessible parking shall
be located on the shortest accessible route of travel toan accessible pedestrian entrance of
the parking facility.
23.4.3 Slope: Parking spaces shall be level with surface slopes not exceeding 1:50 (2%) in
all directions.

3. CAPS attempted to resolve Somerville Schools Administration Building complaint
internally. October, 2009. page 3 of 8
23.4.5 Delineation: Accessible spaces shall be marked by high contrast painted lines or
other high contrast delineation.
23.4.6 Access aisles: All accessible spaces shall have access aisles that comply with the
following:
b. Access aisles adjacent to accessible spaces shall be five feet (5' = 1524mm) wide
minimum, except adjacent to van accessible spaces the access aisle shall be a minimum of
eight feet (8' = 2438mm) wide.
23.4.7 Van Accessible spaces shall comply with the following: b. Each space shall have
a sign designating it "Van Accessible" as required by 521 CMR 23.6,
Signage.
2. Accessible Pedestrian Entrance.
Reconstruction of ramp w/handrails: ~ $3,000
I have not measured the ramp for slope issues,the cross-slope might be excessive- I'll

4. CAPS attempted to resolve Somerville Schools Administration Building complaint
internally. October, 2009. page 4 of 8
be happy to measure that for you, upon request. The concern I blogged about in
response to your comment is about the exterior pull side clearance. (I have not seen
the inside conditions.) In addition, this entrance should at least contain a reachable
communication system such as an intercom, and/or be unlocked during all
business/meeting hours. State AAB code is pasted below for your convenience.
521 CMR 26.00
26.6.3 a. A minimum of 18 inches (18" = 457mm) of clear floor space shall be
provided on the latch, pull
side of the door when the clear floor space in front of the door is a minimum of 60
inches (60" =
1524mm). see Fig. 26d.
b. A minimum of 42 inches (42" = 10667mm) of clear floor space shall be provided
on the latch, pull side of the door when the clear floor space in front of the door is
more than 54 inches (54" = 1372mm) but less than 60 inches (60" = 1524mm) see
Fig. 26g.
c. A minimum of 24 inches (24" = 610mm) of clear floor space shall be provided on
the latch, pull side of the door when the clear floor space in front of the door is a
minimum of 54 inches (54"= 1372mm) and the door has a closer. see Fig. 26d.
3. LOCKED DOOR (see photo above)- this is a common mistake in other
Somerville school facilities as well. rewiring and installment needed.
ADA TITLE II
The accessible entrance must be left open or unlocked during business hours.
If an accessible entrance needs to be kept locked because of security concerns
relating to its location, it must be equipped with an intercom or buzzer. In such
cases, the button activation needs to be mounted at an accessible level (no more
than 4 feet above the ground).
4. SIGNAGE (See blog at SomervilleVoices.org. Link:
http://www.somervillevoices.org/2009/08/22/schools-and-youth/somsigns-lie/)
Please remember to correct the existing signage and to add Accessible Entrance
Signage at inaccessible entrances when this is completed. ~ $300. State AAB code
is pasted below for your convenience:

5. CAPS attempted to resolve Somerville Schools Administration Building complaint
internally. October, 2009. page 5 of 8
25.6 SIGNAGE
Any entrance/exit of a facility not accessible by persons in wheelchairs shall have a sign
clearly indicating the location of the accessible entrance/exit.
5. ACCESSIBLE ROUTE and EMERGENCY EGRESS
resurfacing may be part of parking lot costing; safety solution will include
handrails, perhaps intercom or safety buzzer here, to alert a staff member to come
out and guide safe passage to the back alternate entrance. State AAB code is pasted
below for your convenience.
We know the right rear route to what is currently indicated as the location for the
only accessible entrance and parking-- is a disaster from all sides:
but the front entrance provides absolutely no accessible pedestrian route from

6. CAPS attempted to resolve Somerville Schools Administration Building complaint
internally. October, 2009. page 6 of 8
Washington street to the alternate left rear entrance, either.
521 CMR 20.00
20.2 LOCATION
Within the boundary of the site, an accessible route(s) shall be provided from accessible
parking, accessible passenger loading zones, and public streets or sidewalks to the
accessible
building entrance they serve. The accessible route(s) shall coincide with the route for the
general public.
20.2.1 At least one accessible route shall connect accessible buildings, facilities, elements
and spaces that are on the same site.
20.3 WIDTH
An accessible route shall have a minimum clear width of 36 inches (36" = 914 mm)

7. CAPS attempted to resolve Somerville Schools Administration Building complaint
internally. October, 2009. page 7 of 8
except at doors and at openings less than 24 inches (24" = 610mm) deep where it shall
comply with 521 CMR 26.00: DOORS AND DOORWAYS.
20.9 SLOPE AND CROSS SLOPE
An accessible route with a running slope steeper than 1:20 (5%) is a ramp and shall
comply with 521 CMR 24.00: RAMPS. Nowhere shall the cross slope of an accessible
route exceed 1:50 (2%). (Refer to 521 CMR 2.4.4d)
20.11 EGRESS
Accessible routes serving any accessible space or element shall also serve as a means of
egress for emergencies or connect to an accessible area of rescue assistance.
20.11.2 The exit discharge shall provide a continuous path of travel from an exit to a
public way by means of a walkway or a ramp.
a. Where public ways are further than 100 feet from an exit, exterior areas of rescue
assistance complying with 20.12.2 may be constructed along the exit discharge located no
closer than 100 feet from the building.
b. in buildings where the grade at the level of exit discharge prohibits construction of
either a walkway or a ramp, a portion of an exterior exit balcony located immediately
adjacent to an emergency exit complying with 521 CMR 20.12.2 may be constructed as an
area of rescue assistance.
20.12.4 Two-way Communication: A method of two-way communication, with both
visible and audible signals, shall be provided between each area of rescue assistance and
the primary entrance to the building. The fire department or appropriate building official
may approve a locationother than the primary entrance to the building. Any operable
mechanism shall comply with 521 CMR
39.00: CONTROLS.
20.12.5 Identification: Each area of rescue assistance shall be identified by a sign that
states "area of rescue assistance" and displays the international symbol of accessibility.
The sign shall be illuminated when exit sign illumination is required. Signage shall also be
installed at all inaccessible exits and where otherwise necessary to clearly indicate the
direction to areas of rescue assistance. In each area of rescue assistance, instructions on
the use of the area under emergency conditions shall be posted adjoining the two-way
communication system.
RECOMMENDATION ON NEXT PAGE

8. CAPS attempted to resolve Somerville Schools Administration Building complaint
internally. October, 2009. page 8 of 8
RECOMMENDATION:
We strongly suggest the School System invest in a knowledgeable ADA/Section 504
Evaluation Consultant to guide the Somerville School Systems to reduce the internal
as well as external Access & Inclusion issues at every public school facility and also
in new construction planning. Such leadership will inevitably aid the City of
Somerville in early identification of avoidable cost overruns in upcoming major
capital projects as well as guide the School system to overcome its legal liabilities.