LEECH ARCHITECTS, INC.
     7785 E 126th Street
     Fishers, Indiana 46038
     Telephone 317-842-1931

April 13, 1992

Attn: Mr. Joe Beard
Office on the Americans with Disabilities Act
Civil Rights Division
P.O. Box 66118
Washington, DC 20035-6118


Mr. Beard,

I am writing to confirm my conversation with you during the week
of April 6, 1992., My question to you was regarding elevator/lift
requirements for existing construction to be altered in a retail
store, within a strip shopping mall. You indicated that the ADA
requirements will not allow the elevator exemption for shopping
centers or malls. You then identified to me the definitions for
shopping centers and malls, and you also indicated that once
there are more than (5) retail stores with a common pathway; that
an elevator would be required.

But you then indicated that floors that do not house retail or
rental establishments are not defined as "shopping center or
mall"; therefore you indicated that an elevator to an office area
of less than 3,000 square feet for a retail store probably would
not be required.

Thus, in this scenario, a retail store that is to be remodeled
in such a way as to add a mezzanine area for offices; even though
the main level is considered a shopping mall or center - the
mezzanine level (if it is under 3,000 s.f. or less than (3)
stories, and houses no sales or rental establishments) should be
exempt from the elevator requirement.   This, then, implies that
we are within compliance for the Title III portion of the ADA as
You indicated during our conversation.

As per our conversation and this review I am proceeding, but you
stated that you cannot confirm in writing our conversation unless
specifically requested.   Thus, I am writing to request your
confirmation. I would appreciate it if you could document your
confirmation of this interpretation to me as soon as possible, 
thus verifying all questions regarding elevator/lift requirements
for the project this inquiry has been undertaken.                   

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Thank-you again for your time, I look forward to receiving your
verification promptly after your review of this letter.


Sincerely,




April E. Poland


cc:	William Cooper
	Tom Muller
	Mark Mathias
	Donna Tarr
	Curt Johanson
	Greg Lyons
	Daniel Patterson.


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