October 6, 1992


Mr. John Wodatch, Director 
American's With Disabilities Act
Civil Rights Division
Washington, DC

Dear Mr. Wodatch,

     This office has been retained by XXX, an Episcopalian
School, who would like to build a gymnasium on its campus in XXX,
XXX, XXX.

     It is my understanding that if an organization has a religious
affiliation, it is exempt from certain ADA requirements.

     I would like to obtain an interpretative opinion from you as to
whether or not XXX would qualify for such an exemption.

     In that regard, enclosed you will please find a copy of a Deed
dated September 14, 1992 from the Episcopal Church to XXX, a
Hawaii nonprofit corporation.  You can see from the restrictive
covenants contained therein that the property can only be used for an
Episcopal School.  Further, the property cannot be conveyed or
encumbered without the prior written consent of the Diocesan Council,
the Standing Committee and the Bishop of The Diocese of Hawaii, which
consent may be withheld.  Any breach of the restrictive covenants
causes the property to revert to the Grantor, the Episcopal Church.

     It is my further understanding that the Episcopal Church
maintains insurance coverage on the property, enclosed is a copy of
the Schedule of Insurance indicating the same.

     Please advise if you require any further information in order to
render your opinion.

     Thank you very much for your immediate attention to this matter.

                                   Very truly yours,

                                   JAMES R. JUDGE
                                   of Foley Maehara Judge
JRJ:ec86                                Nip & Chang
Enclosures                                                                     
                                    
cc:  Mr. Tom Olverson
     Dr. Barclay Johnson
     Mr. Frank Skowronski