Proceedings of: Workshop on Improving Building Design for Persons with Low Vision

Welcome and Charge to Participants

Henry L. Green, Hon. AIA, President, National Institute of Building Sciences (NIBS)

Welcome to the National Institute of Building Sciences. It’s very, very peaceful here this morning. I think this is going to be an exciting project for a couple of different reasons. You know, as we age, we actually need other attributes to help us through life. And as a person who is growing older – and I hope to grow much older – I hope the built environment is more conducive to me.

And just a little bit of history from a personal perspective. I used to run a program in Michigan called the “Barrier-Free Design Program.” And it was about accessibility. I’d never thought at the age of 26 that it would affect me. I’m an able-bodied individual. I’ve played basketball when I was in college. I had a lot of fun, and I was very active. I played softball in the league, bowled, did all those things that a young 26-year-old would do until, one day, in playing in a basketball tournament, I fell down and I couldn’t get up. I ruptured my Achilles.

So from that point on, my life was changed. My life was changed from the standpoint of having to go through the surgery and then a year of rehabilitation and the doctor telling me you’ll never play basketball competitively again.

But, I got a real appreciation for different attributes in buildings at that point. And I think that that’s what we all have to appreciate. It’s been said that everyone, at some point in their life, is going to have to have assistance in their life to continue a productive life.

So I think what we’re doing here today is just a phenomenal step toward the continuum of making sure that people have the things that they need to fulfill their life’s expectancy and to do the things that they want in life.

And our built environment has to adjust. It has to adjust from the standpoint of making sure that people can be productive and they can live lives that are very fulfilling.

So again, I think this is very exciting, and I’m happy we’re here today.

I have the distinct honor, though, of first of all, welcoming you here today to the institute and all the marvelous things that we’re doing here. This is one of them. And I also have the distinct honor today to introduce someone that I just met, someone who I had a nice, long conversation with. And it was a very good conversation.

Susan Brita was named the deputy administrator for the U.S. Department of Gen. Services Administration in 2010, a new appointment for her. But in her role over there, she works very closely with the senior management at GSA to provide guidance for GSA employees, to help develop policy and to provide services that provide services to other federal agencies.

Susan is no stranger to GSA broad spectrum of services where she has served as the chief of staff in a previous assignment in the administration of Terence Golden back in 1985 and 1988. She most recently served as deputy director for the House Transportation and Infrastructure Committee, and I think that was a unique role going from an administrative position to a legislative position. She’s got a good balance in terms of looking at this issue from different perspectives.

I think that’s wonderful because, if you just have a singular view, you don’t necessarily appreciate all the nuances that happen, and I think that’s great.

In that role, where she was at – she had a great portfolio of looking at different types of buildings which included the Kennedy Center, the Smithsonian and, also, worked with the Architect of the Capitol, so her vantage point of looking at the various types of federal buildings and how they operate and given the uniqueness of those buildings, particularly when working with an AOC and the legislature, that has got to be a unique challenge, specifically when you think about, every couple of years, there’s this kind of moving chairs around or moving offices.

Susan is very well respected and brings to us a great deal of knowledge and capability. And I just want to introduce to you Susan, who is going to make some opening comments this morning. So Susan, thank you so much for coming in. 

Susan Britta, Deputy Administrator, U.S. General Services Administration (GSA)

Let me just flesh out a few things. For those of you who have been around a long time, I have been in the government for 30 years. I spent 22 years on the Hill and then the rest of the time in the executive branch.

And I must say, as unusual as it sounds, handicapped issued and visually impaired issues have been a constant theme through my entire federal career.

When I was on the Hill working for Jim Oberstar, who was the chairman of the Transportation Committee, he was a strong advocate of employment for handicapped, accessibility for handicapped employees, particularly visually handicapped, and had a Lighthouse in his district. And every six months, we would go up to his office and have a meeting with the executives from the Lighthouse that would come in and talk to us about not only the building but the products that they were providing for the federal government. 

When I was in GSA in the mid-’80s, I had the distinct pleasure – I don’t know if anyone remembers Judge Suchanek. Leonard Suchanek was a pioneer in the field of providing accessibility for handicapped employees, particularly for computers. Len Suchanek was sort of this mythical figure that worked on the seventh floor of GSA. No one went up there because it was the board of contract appeals, and we didn’t want to look like we were trying to influence any decisions. Len was up there not only making decisions but working on behalf of handicapped employees.

He was visually impaired and was a strong advocate for providing – in those days, it was computers, you know, in the mid-’80s – for the visually impaired. And when I went to the Hill, one of the first bills I worked on for Jack Brooks on the Government Reform Committee – which is where I spent my first two years – was a bill for handicapped employees, particularly for visually impaired providing purchasing computers and office equipment for the visually impaired.

And then when I went to the Transportation Committee and had jurisdiction over GSA, the issue of accessibility was huge in federal buildings, providing accessibility, retrofitting existing buildings, making sure that new buildings – this is where my colleague, Tom Williams, is so instrumental – making sure that new buildings are designed with accessibility built right into them, not added on, but built right into them. So accessibility – and, as you know, in the energy bills, even though they talk about energy efficiency and energy savings, the very last line says “and accessibility.”

So accessibility has been a theme and should be a theme. It’s a viable theme in the federal government, and we spent taxpayer dollars. It’s every taxpayer dollar is being spent. And so every taxpayer, whether you’re our employees in the building or a taxpayer going in to use a federal building, should have accessibility and should be, as we’re looking at now, a nuance of that is the lowvision issue and the ability to use federal buildings efficiently.

I don’t need to tell this group the statistics on handicapped people, visually impaired is very large. And the unemployment statistics associated with that category are very high.

GSA has had a long history of working with handicapped issues, and recently, the Federal Acquisition Service, which is the other large service that GSA provides, is working with AbilityOne to put together a workshop which we’re going to have at the end of October that will increase their ability to provide green products. So we’re taking a national theme of sustainability and green products and working it into one of our biggest suppliers, which is AbilityOne, and seeing how they can increase their green supply chain which, again, sort of a national.

So, all of these pieces are fitting together. The handicapped community is no longer something outside that we bring in when necessary. It’s being more fully integrated into all of the GSA activities. And the administration – when I say “administration,” not just GSA but the big administration, the Obama administration, is committed to the ideal of full integration. And we are very aware of the needs of the handicapped community. We’re committed to form a corporation into not only the PBS program but the FAS program.

I work with Tom on the access board. As you know, GSA is a statutory access board. So it’s sort of ingrained into the GSA DNA that this is one of our important, important functions. It may not always be visible, but it is something that we are always thinking about, particularly when we’re – now, we’re using AbilityOne and the handicapped community – business community – to use their products and services as we try to wean the supply chain, promote sustainability and make our federal buildings as efficient and as effective as possible for everyone, not just fully sighted employees, but employees that are visually impaired as well as the public.

People forget the public comes into these federal buildings, and they need the same kinds of added services, and they need the same kind of planning and attention to detail that the visually impaired do. 

So it is one of these powers of small groups. What you’re doing will impact what GSA does. It’s important. It’s important work. I’m just glad to hear over the last week it’s not expensive. This can be built right in with regular planning and regular tenant fit-out. These are not things that require a lot of money. We’re going to do it anyway, so we might as well do it to get the biggest bang for the buck. And it’s an issue that is – it’s out there. It’s coming toward us. We might as well handle it now, and the work of this group will be very, very important and will be of great interest to GSA.

I would like to leave a few minutes for questions, if anyone has any questions that they’d like to ask about what we’re doing at the agency, what we’re doing in this regard. Otherwise, I just want to say I’m delighted to be here. Thank you for the invitation.

As I said, my colleague, Tom Williams is the point person on all these issues. What I know I really gleaned from Tom. And so I am delighted to have him as my colleague and a member of the board. And thank you very much for inviting me. It’s a pleasure to be here. I look forward to the results of your workshop.

Discussion

Comment by Vijay Gupta: I have a comment to make. Thank you, Ms. Brita. I appreciate you coming.

Response by Susan Brita: This is an old colleague.

I tell you, I’m visually impaired, and my problem became more and more serious, so GSA has been very accommodating. I have had all the facilities they could have provided me. They provided me with a computer which talks – “Jaws” software, and I have been a support person for the last eight years, and now I work fulltime for GSA. It’s a great agency to work for, you know, for people who are visually impaired or any other problems.

But as a last note – then I’ll let anybody else ask any questions: the role of engineering should be kept high on the pyramid, because if you don’t have good engineering in the building, you’re going to lose the building. You’re going to lose the functionality. You’re going to lose energy. Clean energy benefits now, but in five years from now, you will find out it’s not going to work. So that’s one thing I will appreciate if you can keep in mind. It’s not only aesthetics. I like architecture but, unfortunately, [the] last decade [has resulted in building performance going] down, down, down. So anyhow, that’s my comment. Anybody else? 

Low Vision Accessibility as a Necessity

Question by [Participant]: Just wondering, has GSA looked at the costs and benefits of accommodating low-vision and other disabilities in terms of what’s lost if you don’t have them and what’s gained not only for the people with disabilities but for others in terms of enhanced?

Response by Susan Brita: I don’t know if they’ve specifically looked at the low-vision issue, but they are always conscious of the handicapped issue. And, quite frankly, because the law requires it, we don’t even demand a cost-benefit analysis because we’re going to do it regardless of what the cost is.

As Vijay said, one of the problems is, when you deal with high-end architecture – and Tom knows this firsthand – a lot of them don’t want to disturb the architecture of their buildings to provide handicapped access, particularly, exterior of these buildings let alone once you get inside, particularly. We are constantly reminding them that this is not a nice-to-have; this is a must-have. It’s going to be incorporated into the design the buildings. 

And sometimes that’s a little push-and-shove. But the low-vision issue, not specifically. That’s why I think this workshop is important because I think you will be coming up with – and I, quite frankly, don’t think it’s going to be expensive. And even if it is, it’s an investment. It’s not a cost; it’s really an investment because there are productivity issues. And if your workers can’t work, then there’s no sense having them there if they can’t work.

And so the recommendations and the outcomes that come out of this workshop will be closely looked at inside GSA. When we talked last week, we did think that having contrasting carpet or having different kind of signage should not be expensive because we’re going to have it anyway. So we might as well do it right the first time. And it’s not just limited to visually impaired. Anyone will benefit from that kind of design element or those kinds of signs. So it’s not like we’re carving a little niche. It’s going to be there anyway.

So I don’t think it’s going to be a big issue. I really don’t. But even if it is some additional cost – which I don’t think there will be – it has to be absorbed anyway. So it’s not like you can say don’t do it because it’s a hundred dollars more. That’s not going into the decision.

But it’s a very iterative process. You know, you start with a concept. You get with the architects. They want to have it this way. You have a particular client. The judges are very, very difficult to deal with when it comes to designing courthouses, which is a huge public building that absolutely everyone ought to be able to get into and use efficiently. Sometimes judges are very stingy in their approach to their building: this is my courtroom. It’s not really yours and mine. It’s the taxpayers’, and everyone should have the same kind of access. 

Question and Comment by [Participant]: In the ADA, in just scan reading it kind of preparing for this, I’ve got the impression that, if you’re totally blind, it’s covered. Low vision is not in the act.

Response by Susan Brita: It’s not defined. It’s not a defined term. 

Memorandum of Understanding as a Possibility

Question and Comment by [Participant]: So, as we move forward in where we’re going today, do you have any comments that you’d like to make for us to address? How can we can [have] some influence on that?

Response by Susan Brita: Well, the way you’re doing things now – which I think is the right way to do when you settle voluntary complaints on the part of the agency that low vision is a nuance of not sighted. I never advocate – because I spent 22 years on the Hill – I never advocate people going to the Hill to try to get an amendment to it because it takes so long. You really never get what you want. You always get a version of what you want.

So if you can get the lead agencies to [sign] an MOU or a memorandum of understanding or a memorandum of agreement that low vision will be – and it is actually part of the Energy Act. So you can sort of work your way in that way.

Going back and amending those two statutes, while there may be a lot of public sentiment, can take forever. And as I said, you generally don’t get what you want. You need an advocate up on the Hill that would help you push a piece of legislation. And this is just an amendment, and it can be tough.

From a political point of view, if it’s an amendment that everyone thinks it’s a great idea, invariably, someone’s going to put something on it that’s a rotten idea to move forward, you know, some whacko idea, and your amendment will never go anywhere. 

I always advise people think twice about going to the Hill because it is a difficult, long process. If you think you can get what you need to get done administratively through memorandums of agreement and understanding, I would try that first. If that doesn’t work, then you can always appeal to the GSA. There’s a great sentiment inside of the agency to be cooperative.

No one inside GSA is going to say we’re not going to do this. And that’s where your next focus would be is go to the individual and, particularly, GSA and say, look, we need some help on this. We need more of an understanding. We need this to be incorporated more. And I’d be very surprised if the agency said, oh, we don’t have the statutory authority to do it. They have huge statutory authority to do it. So I don’t think that that would be the problem.

Statutory Authority for Guidelines and Standards

Comment by Marsha Mazz: In fact, we do have statutory authority. The Americans With Disabilities Act and the Architectural Barriers Act both speak to the board’s responsibility to establish guidelines that address the needs of people with disabilities. People of low vision are included among that very broad category of individuals with disabilities.

The problem, in fact, is that most of the historical research, most of the work has been, heretofore, to develop guidelines and standards for people with mobility limitations and, to a much lesser degree, people who are hard of hearing or deaf, low vision or blind.

And if you reflect on it, I think you’ll come to the conclusion that more accessibility and a builtin environment, the biggest barriers are and have been, over time, barriers to people with mobility impairments. They can’t even get in the building, yet people like myself – I’m lowvision; I’m legally blind – are impacted – Vijay is impacted by the quality – the acoustics in the building, by the lighting in a building, by the sign systems in a building, even the way the building is laid out which may impact your ability to find your way efficiently without having to depend on others.

And so it’s not that we don’t feel authorized to establish these guidelines and standards. It’s that we have very little information. And later on, we’ll talk about what federal law requires of us in terms of support for rulemaking. And so I think that’s our biggest barrier.

And I totally and completely agree with you. It doesn’t usually behoove people to run to the Hill and say write a special law for people who are blind or write a special law for people who are whatever because, in fact, the law is very, very broad and the pressure probably needs to be elsewhere to get the agencies that are already authorized to produce what’s needed.

Response by Susan Britta: A perfect point. It is not that you’re not fully authorized. It’s been lack of attention. But now this is your time. I mean, this is the time to bring up the issue, to get some attention focused on it. It is a legitimate issue. It should be focused on, and this is, you know – this is your time.

Comment by Thomas Williams: A number of years ago, our agency took a lead on an issue that affects all federal buildings across the whole array of the government, and that was entrances. And the standard, despite all the iterations of the standard over time, has never made any allowance for [the] opening force for doors, other than the width of the door and some threshold requirements and the accessible path going to the entrance door of a building.

There are not requirements for what you do with somebody who can’t pull the door open because there is prevailing wind, a force against the door, or the building is pressurized and so the amount of force you need to exert, if you are someone in a wheelchair or something who has got other problems with balance and so forth, is overwhelming. You can’t get in.

So when I started with accessibility about eight years ago, I was asked to run the program. Major issue. And the first thing I saw was countless complaints coming to our agency from the access board addressing entrance issues because people couldn’t get in doors to brand-new federal buildings.

Our monumental, beautiful courthouses with doors that are 10 feet tall, so heavy that an average person would find too difficult to open the door. But suppose it’s located in an environment like Chicago where you’ve got prevailing winds on that door and other issues.

So after dealing with countless complaints on that issue, I decided that the only way we could remedy this was to encourage the leadership of the agency to accept a provision in the facility standards, which is our guideline for the design of all of our federal buildings that would require that entrances to our buildings be equipped with either a power-assist or automatic doors in consonance with what was then the new standard that we had adopted.

We adopted it back in 2005 after the board published their guidelines in 2004, and I was able to get leadership to agree to that. So we amended the facilities standards and put that requirement in it. It’s in our 2005 facilities standards.

And actually, facilities standards was published before we technically had adopted the architecture barriers and accessibility standard. We put it in there, and we were the first agency to do so. And I believe it was the right thing to do, and I think it’s mitigated a lot of complaints that would have occurred otherwise on a continuing basis in our buildings. Marsha noticed that.

Credible Data are a Necessity

Comment by Marsha Mazz: We, at the Access Board were thrilled that GSA took this step. And, while I have you as an audience, I’ll say that, if GSA can collect data on the maintainability of the automatic door openers, the impacts on energy because those – that’s the pushback we get. Anytime we suggest even that we might include a requirement for automatic doors on ADA-covered buildings or even barriers act-covered buildings, the pushback immediately is these things are impossible to maintain; they cost a lot to maintain; and they will affect the energy efficiency of the building and the security of the building.

If GSA can begin to develop a body of data so that the next time we refresh this role, we’ll have GSA’s data to support a requirement for other federal agencies and for ADA-covered agencies, that would go a long way because, without that kind of data to refute the naysayers, we’re stuck because we all have to deal with OMB.

Response by Susan Brita: I know they collect data on things like escalators because there was a move during the energy-efficient days of, you know, like eight or nine years ago, there was a move to stop all down escalators and make people walk down the stairs [for energy savings]. Or when you step on them, they move. When you step off them, they don’t move.

But the maintenance figures came back and said you break them so often when you do that, you might as well just keep them running all the time. So if they can collect data like that, I’m sure they’re going to be able to collect data on the push buttons at the door.

Security and Accessibility

But, the issue of security – people use security now for an excuse for the most ridiculous things. And inside the agency now, we’re always in a tug-of-war between trying to have an open kind of society where public buildings can be used versus everything’s got to be shut; getting into these buildings is almost impossible; you have to almost give a blood sample in order to get in. It’s a huge problem.

Security in federal buildings is enormously expensive. It’s exploded, certainly, since it started after Oklahoma City but really exploded after 9/11. Everything’s got a bollard in front of it now, and it’s just enormously expensive. 

And that’s a static cost. The taxpayer gets nothing for that. That’s a sunk cost for the taxpayer who virtually gets, other than you can say maybe your federal building is a little bit safer because you’ve got a big, potted plant out front.

Security is used all the time. It’s like white noise. I really don’t pay attention to it until you can actually prove that you’re investing in something that really is going to have a return. So I don’t pay any attention to the, gee, it’s going to disturb security issues because it usually doesn’t.

And most of the people that say that, quite frankly, if you go to any of these security meetings, they’re all law enforcement types. So they’re all like super into law enforcement and security and all of that. They’re not building managers. They’re not users of the building. They’re all security types, and there’s no security – there’s nothing you can invest that’s too expensive that they wouldn’t buy to secure a federal building.

And with limited resources, I will tell you, it’s a huge issue. When you’re trying to design a federal building, it’s a huge issue because the tendency is to go to the security and not to go on the handicapped issues. That’s where the tendency is.

GSA needs to be strong at heart and say that we need an appropriate balance and, quite frankly, we have a legal requirement on the handicapped issues. We don’t have a legal requirement on the security issues. 

Comment by [Participant]: But there’s one thing that should be said about that. Those are not mutually exclusive issues that can be designed into a building. I think the outgrowth of this workshop should take into account those issues and address how, in fact, they can be inclusive. That’s the beauty of putting together this kind of program, identifying the obstacles and addressing them from the standpoint of how do we use our intellect to make these things work.

Response by Susan Brita: Right. And demystifying the notion that these kinds of things are expensive. They’re not. They’re not. If designed properly, they’re designed right into the building, and they’re not add-ons. They’re perfectly appropriate and they’re not expensive. 

GSA Leadership

Comment by Tom Williams: I think our agency has an opportunity to take a lead on the issue of the low-vision design environments. It’s a unique opportunity that we have and that we have a leadership role in the federal government in terms of being advocates for the rights of people with disabilities. Not everybody may agree internally within our agency. There are those that think that design for the sake of design is all important, overwhelms everything else, and these things are inconsequential to the greatness of designs that are produced.

But the bottom line is we should not be about being elitists or only concerned about getting our buildings published in Architectural Record. We should be concerned about our buildings working for the American taxpayers who are kind enough to give us the money to design and build these buildings.

And that means all taxpayers. All citizens have the same rights. We have the same treatment by federal government. No exclusivity. The built environment is our obligation to do what we can to make it better, and that includes this low-vision issue and trying to amend our facility standards. It’s one way we can take the leadership to put provisions in our facility standards that will enable our designers to understand these requirements for low vision and incorporate them by mandate in the facility standards so that we comply and do the right thing. That would be a precedent to help the board at a later date because rulemaking is lengthy. It’s years and years long. Getting any kind of changes made to accessibility standards and guidelines is a forever thing. It’s a constantly evolving process. 

The last time it took then 10 years to revise those guidelines. So it’s a lengthy, lengthy process, and whatever we can do to help the process along because of the uniqueness of our ability to do that with our agency is something we should and must do.

Question by Henry Green: Any other questions of Susan?

Response by Susan Britta: Thank you very much. Good luck in your workshop. We expect great things from you. And, as Tom said, these can be designed and incorporated at minimal or no cost. So don’t let anyone tell you it’s going to be expensive because it won’t be. And you have a committed agency. We look forward to the results of the convention.