U.S. Department of Justice
                                        Civil Rights Division
                                        Public Access Section
DJ 202-PL-00044                         P.O. Box 66738
                                        Washington, D.C. 20035-6738

                                                NOV 3 1992

Mr. Michael Milroy
Director of Operations
Deepwood Center
8121 Deepwood Boulevard
Mentor, Ohio 44060 

Dear Mr. Milroy:

        Thank you for your letter dated February 5, 1992, in which
you requested guidance regarding the number of parking spaces
required at certain facilities under your control.

        The ADA authorizes the Department of Justice to provide
technical assistance to individuals and entities that are subject
to the Act. This letter provides informal guidance to assist you
in understanding the ADA accessibility standards. However, this
technical assistance does not constitute a legal interpretation
of the application of the statute to parking and it is not
binding on the Department.

        Section 4.1.2(5) of the ADA Guidelines (ADAAG) lists the
requirements for parking. Section 4.1.2(5)(d)(ii) of the ADAAG
states that units and facilities that specialize in treatment or
services for persons with mobility impairments must make 20
percent of the total number of parking spaces accessible. This
provision applies to facilities and units that offer medical
services if the facility is one where clients may stay for a
period of time exceeding twenty-four hours, i.e., overnight.
Section 6.1 of the ADA Accessibility Guidelines. If the facility
or unit is providing "other services" particularly for people
with mobility impairments (including vocational rehabilitation
services), the overnight requirement does not apply. Since your
workshop offers occupational and physical therapy services to
persons with mobility impairments, it would appear to be covered
by the 20 percent requirement of section 4.1.2(5)(d)(ii).

        However, since your entire facility is not used exclusively
by people with mobility impairments, you should try to determine
what proportion of people with mobility impairments use your
facility for physical therapy and make 20 percent of that number
of spaces accessible rather than 20 percent of the entire parking
lot.

01-01692
                                     - 2 -
        We are enclosing a copy of the title III regulation and this
Department's title III Technical Assistance Manual to assist you
in complying with the ADA.

        I hope this information is useful to you.

                                        Sincerely,

                                     John L. Wodatch
                                        Director
                                  Public Access Section

Enclosures (2)

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