NEBRASKA POLIO SURVIVORS ASSOCIATION


                                              P.O. Box 37139
                                          Omaha, Nebraska 68137
                                              402/341-0710


June 12, 1992



U. S. Department of Justice
Civil Rights Division--ADA
P. 0. Box 66118
Washington, D.C. 20035-6118

Re:    ADA Regulations

1.	NPSA requests that the Department of Justice render a policy
statement to clarify when it would NOT be readily achievable for
retail store to rearrange display racks to provide accessible
aisles.

2.	When I called the Department of Justice yesterday with this
question, I was told that stores do not have to move display
racks if to do so would result in significant loss of revenue.
It is my understanding that this (Section 36.304 (f)(1)) was
deleted from the final rule. Please verify.

3.	As I read the regulations, a retail store is not given a
choice between moving its racks to provide access OR providing a
clerk to retrieve inaccessible merchandise; the racks must be
moved unless merchants can prove that it is not readily
achievable to do so.  Please verify.

Sincerely,



John M. Barnett
Executive Director



JMB:nbc






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