U.S. Capitol Police: Comments on the Notice of Proposed Rulemaking Implementing Section 210 of the Congressional Accountability Act – October 9, 2014
Posted October 9th, 2014
Dear Ms. Sapin:
Please accept these comments on behalf ofthe United States Capitol Police regarding the Americans with Disabilities Act (“ADA”) Public Access Regulations as proposed. As discussed below, we recommend that the ADA Public Access Regulations not be issued at this time. One primary concern is that the ADA Public Access Regulations do not appear to be coordinated with the statutory responsibilities ofother Congressional entities, and could result in unnecessary conflicts with statutory responsibilities belonging to various entities within the legislative branch.
Additionally, the ADA Public Access Regulations do not appear to be tailored to the legislative branch or publicly accessible areas within the legislative branch. There are conflicts within the ADA Public Access Regulations that appear to exist because ofthe adoption by the Office ofCompliance ofboth Title II and Title III of executive branch regulations. These conflicts should be clarified.
Finally, the methodology for identifying responsible entities is not clear. Because the determination of methodology is a statutory requirement under the Congressional Accountability Act (“CAA”), it is important that the identification of a responsible party be clearly articulated in the Regulations.
We have identified specific concerns with the ADA Public Access Regulations below. Although the itemization is not exhaustive, examples of concern are provided. We appreciate the time and effort spent on the ADA Public Access Regulations and look forward to working with the Office of Compliance on language that takes into consideration all statutory interests.
1) The ADA Substantive Regulations Have Not Been Tailored To The Legislative Branch As Required By The CAA.
2 U.S.C. § 1331(e)(2) requires that regulations be the same as substantive regulations promulgated by the Attorney General and the Secretary of Transportation to implement the statutory provisions referred to in subsection (b) except to the extent that the Board may determine, for good cause shown and stated together with the regulation, that a modification of such regulation would be more effective for the implementation of the rights and protections under this section. However, there are several concerns with the regulations as written.
Learn more and continue to read by downloading the following document(s).
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U.S. Capitol Police: Comments on the Notice of Proposed Rulemaking Implementing Section 210 of the Congressional Accountability Act – October 9, 2014
Posted October 9th, 2014
Dear Ms. Sapin:
Please accept these comments on behalf ofthe United States Capitol Police regarding the Americans with Disabilities Act (“ADA”) Public Access Regulations as proposed. As discussed below, we recommend that the ADA Public Access Regulations not be issued at this time. One primary concern is that the ADA Public Access Regulations do not appear to be coordinated with the statutory responsibilities ofother Congressional entities, and could result in unnecessary conflicts with statutory responsibilities belonging to various entities within the legislative branch.
Additionally, the ADA Public Access Regulations do not appear to be tailored to the legislative branch or publicly accessible areas within the legislative branch. There are conflicts within the ADA Public Access Regulations that appear to exist because ofthe adoption by the Office ofCompliance ofboth Title II and Title III of executive branch regulations. These conflicts should be clarified.
Finally, the methodology for identifying responsible entities is not clear. Because the determination of methodology is a statutory requirement under the Congressional Accountability Act (“CAA”), it is important that the identification of a responsible party be clearly articulated in the Regulations.
We have identified specific concerns with the ADA Public Access Regulations below. Although the itemization is not exhaustive, examples of concern are provided. We appreciate the time and effort spent on the ADA Public Access Regulations and look forward to working with the Office of Compliance on language that takes into consideration all statutory interests.
1) The ADA Substantive Regulations Have Not Been Tailored To The Legislative Branch As Required By The CAA.
2 U.S.C. § 1331(e)(2) requires that regulations be the same as substantive regulations promulgated by the Attorney General and the Secretary of Transportation to implement the statutory provisions referred to in subsection (b) except to the extent that the Board may determine, for good cause shown and stated together with the regulation, that a modification of such regulation would be more effective for the implementation of the rights and protections under this section. However, there are several concerns with the regulations as written.
Learn more and continue to read by downloading the following document(s).
U.S. Capitol Police: Comments on the Notice of Proposed Rulemaking Implementing Section 210 of the Congressional Accountability Act - October 9, 2014
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CATEGORIES: Comments Pending Regulations Substantive Regulations involving the Americans with Disabilities Act (ADA)
TAGS: ADA Notice of Proposed Rulemaking (NPRM)