US ACCESS BOARD PUBLIC HEARING

Wednesday, July 11, 2012

9:30 a.m. – 12:00 p.m. 

Access Board Conference Room

Washington, DC

NOTICE OF PROPOSED RULEMAKING:

EMERGENCY TRANSPORTABLE HOUSING 

WITNESSES:

1. Doug Anderson, Partner, LCM Architects, Chicago, IL

2. Mark Weiss, Sr. Vice President, Manufactured Housing Association for 

Regulatory Reform, Washington, DC 

3. Kelly Buckland, Executive Director, National Council on Independent Living, 

Washington, DC 

4. Lois Starkey, Vice President, Regulatory Affairs, Arlington, VA 

5. Mary Troupe, Director, Just Advocacy of Mississippi, Pearl, MS

6. F.R. Jayar Daily, American Homestar Corporation, League City, TX 

7. Dominic Marinelli, Vice President of Accessibility Services, United Spinal 

Association, West Seneca, NY 

8. Charles Tubre, Systems Advocacy Specialist, The Advocacy Center, New 

Orleans, LA 

9. Robert Solomon, Division Manager, NFPA 

10.Cary LaCheen, Senior Staff Attorney, National Center for Law and Economic 

Justice, New York, NY 

11.Mary Lamielle, Executive Director, National Center for Environmental 

Health Strategies, Inc., Voorhees, NJ 

CART Services Provided by: Metro Reporters

Realtime Reporter: Sherry C. Knox, CBC, CCP

(NOTE: This text is being provided in a rough draft format. Communication 

Access Realtime Translation (CART) is provided in order to facilitate 

communication accessibility and may not be a totally verbatim record of the 

proceedings. )
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US ACCESS BOARD PUBLIC HEARING

Wednesday, July 11, 2012

9:30 a.m. – 12:00 p.m. 

Access Board Conference Room

Washington, DC

NOTICE OF PROPOSED RULEMAKING: 

EMERGENCY TRANSPORTABLE HOUSING 

>> KAREN BRAITMAYER: So, good morning. It's 9:30. Let's start. 

>> KAREN BRAITMAYER: Good morning. My name is KAREN 

BRAITMAYER, and I am vice chair of the Access Board and chair of the ad hoc 

committee that's developing this rulemaking. It is my pleasure to welcome each 

of you today on this board's proposed accessibility guidelines for emergency 

transportable housing. 

All too often we take our housing for granted and in particular we have 

found that when disaster strikes like Hurricane Katrina and Rita, that temporary 

housing units that were used are often not accessible to people with disabilities. 

So the Board developed these proposed accessibility guidelines with the 

help of an advisory committee in order to address variety issues of accessible 

housing including requirements for ramps, floor surfaces, kitchens, showers, and 

bedrooms. 
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In addition, this proposed rule includes provisions for accessible 

communication features such as smoke alarms and weather alert systems. 

All of these requirements have one goal in mind: To enable people with 

disabilities and their families to independently use emergency transportable 

housing should the need ever arise. 

Many of you in the audience today either physically here or listening on the 

phone and many of those who are planning on testifying today served on our 

federal advisory committee that developed the recommendations for this rule. 

We are very grateful for your service to the Board and we are looking 

forward to your comments today. 

And now, Marsha Mazz is going to make a brief presentation describing the 

ground rules for this hearing. 

>> MARSHA MAZZ: Thank you, Karen. 

As Karen said, this is our public hearing on a notice of proposed rulemaking 

to establish...

>> DOUG ANDERSON: ...who have lived in the emergency transportable 
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housing during the aftermath of Hurricanes Katrina and Rita and was extremely 

valuable when you have the feedback from manufacturers and providing 

information about the implications of different changes in the requirements to 

their equipment and their processing or production of those things, and then 

input from FEMA, HUD, and many other federal agencies, including the 

Department of Justice. So. I hope that all that hard work has already 

addressed the major concerns from all sides on these issues and will hasten the 

finalization and the implementation of this important rule. 

You know when you're out here every day in your home environment and 

you live with the all the things you take for granted, ad how significant those 

things can be and how they can impact your life. I was just on a camping trip in 

Colorado and reminded of this challenge of - some of my family members noticed 

the challenges more than I did -- a little gadget can make your life a whole lot 

easier when you're maybe in a camping situation, or a portable emergency 

transportable housing situation, and I know they're not the same, I know it's 

much more difficult to go through the ETH thing, but I bring it up just as an 

example. The shower spray unit at the kitchen sink which was brought up in the 

ETH rule and this might be a fairly inexpensive addition to a unit, but this can 

make everything in life so much easier for people with disabilities, and I can 

remember the committee member from New Orleans claiming how important it 

was, not only for washing dishes but washing hair, and other cleaning-type jobs 

that they would do. 
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So, the change in weather patterns is very evident also in this country. 

When we were in Colorado Springs just for a couple of days, and just after we left, 

the fire was coming into the town of Colorado Springs. And then we got back 

home, and the week of the 4th, a severe storm hit my town, there 200,000 people 

in the Chicago area without power for about 4 days. Our mayor declared a state 

of emergency and all the July 4th events were cancelled. 

>> KAREN BRAITMAYER: Doug --

>> DOUG ANDERSON: This was a very tiny taste of living through an 

emergency, but these things are happening more and more, which just shows 

how important the rule is. 

>> KAREN BRAITMAYER: Doug, we're going to have to conclude your 

comments at this time. 

>> DOUG ANDERSON: Oh. Okay. Well, can I just say two more 

sentences? I'd like to encourage the Board hasten the passage of the 

implementation of these standards, and remind everyone America has many 

more storms on the horizon and in very much need of this rule. Thank you for 

your time. 

>> KAREN BRAITMAYER: Thank you. 
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>> ROSE MARIE BUNALES: OPERATOR, mute Doug Anderson. 

>> OPERATOR: His line is muted. 

>> KAREN BRAITMAYER: And I believe the next individual to testify is 

Mary Troupe, and that she will also be calling in? 

>> ROSE MARIE BUNALES: OPERATOR, locate Mary Troupe, and unmute. 

>> OPERATOR: I just saw that she was in the call and that she's hung up, 

so hopefully she'll call back in. 

>> ROSE MARIE BUNALES: Okay. Karen. 

>> KAREN BRAITMAYER: So we will move to our next presenter. This is 

Mark Weiss. Mark, we'll get your mic on in just a moment, please. 

4.22 >> MARK WEISS: Take Two. Madam Chairman, Board, staff and 

guests. My name's Mark Weiss, I'm Senior Vice President of Manufactured 

Housing Association for Regulatory Reform. 

MHARR is a Washington, DC-based national trade association representing 

the views and interests and producers of manufactured housing regulated by the 

US Housing and Urban Development. MHARR was founded in 1985 and 
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represents mostly smaller and medium-sized manufacturers from around the 

United States. 

MHARR was pleased to participate in the advisory committee convened by 

the Board to prepare accessibility recommendations for emergency transportable 

housing and appreciates the opportunity to offer comments here today. As an 

initial matter, we'd like to commend the Board and its staff for its inclusive and 

proactive approach that it took in developing these guidelines. The advisory 

committee that debated and developed the underlying recommendations for the 

guidelines now before you included a cross-section of all stakeholders and all 

relevant interests, including representatives of both producers and users of 

emergency transportable housing. The process was open and transparent and 

allowed for the careful evaluation, examination and consideration of all 

viewpoints. 

Before addressing certain aspects of the guidelines, it's important to note 

that manufactured housing, unlike other structures that have been used in the 

past for emergency transportable housing is subject to strict Federal construction 

and safety standards that are maintained and enforced by HUD in conjunction 

with approved state agencies. The HUD standards govern not only the 

construction of the homes in the factory, but also the installation of the home at 

the site as well as correction and related notifications post-installation. In these

particulars, manufactured housing is unique among various types of ETA 

structures. 
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As to the substance of the proposed rule MHARR would offer two principle 

comments. 

First, MHARR agrees with the decision not to include a guideline with 

respect to indoor environmental quality. As a member of the advisory 

committee, MHARR supported all the various recommendations with one 

exception - and that was a non-consensus statement regarding indoor 

environmental quality focused principally on formaldehyde vapor. It's important 

to note that as the only type of ETH subject to comprehensive federal 

construction and safety regulation, manufactured homes are already required to 

meet federal criteria for formaldehyde emissions from plywood and particle 

board that did not apply to either recreational vehicles or parked models. These 

regulations adopted in 1984 were the first and for many years the only standard 

for formaldehyde emissions in residential structures and have proven quite 

effective in reducing the number of formaldehyde related complaints in 

manufactured homes to minimal levels. Any guideline different from the HUD 

standard for manufactured homes would not only be unnecessary given the 

success of the HUD standards and impending new standards under the 

Formaldehyde Standards For Composite Wood Products Act, as is noted in the 

preamble to the proposed rule, but would also raise serious compliance issues for 

producers that could impact their participation in programs providing ETH, to the 

detriment of all concerned. And what I'm talking about there is the possibility of 

conflicting standards that the producers might be subject to. 
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Second, as MHARR stressed during deliberations, while we have no 

objections to the proposed guidelines as they relate to the purchase of ETH by 

FEMA and other government entities, the proposed guidelines would not 

necessarily be appropriate for private sector home transactions and MHARR

support for the recommendations of the advisory committee should not be 

construed as an endorsement of the same criteria as the basis for standards 

affecting the private sector including the HUD manufactured housing standards. 

And our reasons for that are two-fold: most fundamentally, the HUD code is a 

construction and safety code. And while accessibility is a relevant issue for 

private sector manufacturers and purchasers, manufacturers always strive to 

meet the needs of their customers HUD's regulatory authority under the 

Manufactured Housing Construction and Safety Standards Act of 1974 is limited 

to life safety issues and structural integrity. 

Furthermore, because manufactured housing is specifically recognized by 

statute as affordable housing, federal manufactured housing law requires that in 

order to be adopted any proposed federal standard has to be both necessary 

from an objective standpoint and cost beneficial for the home-buying public. 

None of the criteria here have been evaluated from that perspective as that 

function was not within the mandate of the advisory committee, nor does MHARR

believe that it would be appropriate to increase the cost of manufactured housing 

for this matter for the general public, when any need -- when any and all 

accessibility features needed or desired by private sector purchasers are already 
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available from industry manufacturers, such as design options. Indeed the 

manufactured housing industry prides itself on being able to deliver the specific 

home features needed or wanted by any purchaser at any time at an affordable 

price that cannot be matched by any other type of residential construction. This 

system has worked well for decades without government mandates and should 

not be replaced by government directives that would impose needless costs on 

purchasers and simultaneously potentially exclude purchasers from achieving the 

American dream of homeownership. That said, Ms. Chairman, we support these 

recommendations and the guidelines as such within the context and if the board 

has any questions, we'd be happy to answer them. 

>> KAREN BRAITMAYER: Thank you. Does the Board have any 

questions? Not seeing any, thank you very much for your testimony. And next 

up is Kelly Buckland. 

>> KELLY BUCKLAND: Thank you, Madam Chair. 

The National Council of Independent Living is the longest running national, 

cross-disability, grass roots organization run by and for people with disabilities in 

the country. Founded in 1982, NCIL represents thousands of organizations and 

individuals including: Centers for Independent Living, Statewide Independent 

Living Councils and individuals with disabilities and other organizations that 

advocate for the human and civil rights of people with disabilities throughout the 

United States. There are currently about 700 physical locations doing business 
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as centers for independent living across America actively providing Independent 

Living services to people with disabilities. 

NCIL would like to thank the Access Board for convening this hearing to 

discuss the proposed accessibility guidelines to amend the Americans with 

Disabilities Act and the Architectural Barriers Act specifically to address the 

emergency transportable housing units provided in response to emergency needs 

for temporary housing. 

NCIL envisions a world in which people with disabilities are valued equally 

and participate fully. 

Housing and emergency preparedness are part of our concentrated 

advocacy work done around this nation. After the devastating events of 9/11 as 

well as the aftermath of many natural disasters around the nation, NCIL was at 

the forefront of educating local, state, and federal government agencies on how 

to effectively, safely and compassionately address those emergency situations for 

people with disabilities. As part of our national advocacy, we have a working 

relationship and meet regularly with the federal emergency management agency 

serving as experts in the area of providing technical assistance and guidance on 

creating better outcomes for people with disabilities. 

Many of you know that centers for independent living were actively 

involved in recovery efforts after 9/11, after Katrina, after the mid-western
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floods, after the tornados in the south and on and on and on and we continue 

that work and we do have a MOU with FEMA that allows centers to access 

disaster recovery centers because we had trouble with that at some other sites. 

So NCIL and centers for independent living continue to play a real active 

role in this and we have a deep commitment to this as it affects people with 

disabilities in very meaningful and substantial ways. 

Temporary housing although it's temporary in nature I think most of you 

know that in many instances it turns out to be years instead of months or weeks 

as people with disabilities after recovery have a hard time finding accessible 

housing. So it's really important that this is done right. 

We agree with the proposed -- the proposed rules in response to these 

issues and in reviewing the guidelines NCIL pretty much supports them as written. 

However, we will provide some written comments later before the deadline for 

submission of written comments. 

We do think that even though it's temporary housing, it needs to be made 

fully accessible; it needs to be safe and it needs to be healthy. 

And there are some exceptions in the rules for ramps and slide-outs and we 

would just I guess voice some cautions with that in regards especially to the 

ramps, although I know that the reason that the exemption is given in the rules 
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because may not be possible to get a ramp according to the ADA guidelines on 

private property. We really do want to make sure that everything possible is 

tried before you give an exemption to make the ramp steeper. So that's one 

thing. And then the second area of the concerns, the slide-outs and we agree 

with the committee's concern that the slide-out requirement may not meet the 

technical provisions for floor services and changes in levels, but again we'd just 

like to make sure that all possible options are tried before we just allow that 

exemption. And there's a number of things that could be done to try to level out 

that slope and stuff, so... we also agree that it's not necessary to amend the 

technical provisions for the floor services and changes in the levels, but as I said 

with the cautions that we mentioned. 

As a membership organization NCIL advances independent living and the 

rights of people with disabilities through consumer group and advocacy. It's 

through our members that we receive and implement much of our advocacy work 

and especially when it comes to disaster recovery centers are on the ground and 

are involved in that. 

And this work includes and in fact is necessary during these emergency 

management conditions and we are committed to ensuring safe, accessible and 

effective outcomes during these times of need. We again thank the Access 

Board for the dedicated work as done to assist with this proposed rule, and with 

that, I'll stand open for any questions you might have. 
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>> KAREN BRAITMAYER: Thank you, Kelly. Does the Board have any 

questions? Not seeing any, I thank you for your testimony. 

>> KELLY BUCKLAND: Thank you. 

>> KAREN BRAITMAYER: Next on our list is Lois Starkey. 

>> LOIS STARKEY: Good morning, madam chairman, and members of the 

Board. My name is Lois Starkey, I'm Vice President for Regulatory Affairs at the 

Manufactured Housing Institute. Thank you very much for the opportunity to 

present comments before the Board on its proposed rulemaking to amend the 

Americans with Disabilities Act and the architectural barriers act Accessibility 

Guidelines to specifically address emergency transportable units provided by 

FEMA. 

MHI's members represent all segments of the manufactured housing 

industry including retailers, community owners, lenders, suppliers, state 

manufactured housing associations and manufacturers who produce over 75 

percent of the annual market share of manufactured housing. 

On behalf of MHI I would like to commend the Board and the members of 

the advisory committee that have worked over the last decade to develop and 

maintain accessibility standards to ensure that the structure and alteration of 

facilities covered by the ABA and the ADA are readily accessible and usable by 
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individuals with disabilities. 

While publicly funded buildings are required to meet these guidelines they 

are voluntary for the private sector and serve as a great resource for the housing 

industry where there is a growing market for accessible housing. 

MHI was pleased to serve as a member of the emergency transportable 

housing federal advisory committee established in 2007 to advise the Access 

Board on issues related to revising and updating accessibility guidelines for 

emergency transportable housing and we note and are pleased that the proposals 

published in the Federal Register on June 18th are based on the committee's 

recommendations submitted to the Access Board. We note that while other 

federal agencies have updated their accessibility standard to the consistent with 

the Access Board board's guidelines for facilities designed or constructed with 

federal funds. HUD is still using the more outdated UFAS standards. MHI 

supports uniform voluntary guidelines for accessible housing that minimize 

duplicate and overlapping requirements and we urge HUD to update its 

accessibility standards for federally funded housing as soon as possible to include 

the proposed recommendations for emergency housing as proposed in last 

month's rulemaking. While MHI plans to submit detailed written comments on 

the proposed rule, I would like to follow with our witness, Jayar Daily with the 

American Homestar Corporation and active member of MHI who would provide 

specific comments on the proposed rule and he'll be calling in from Texas. 
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>> KAREN BRAITMAYER: Thank you, Lois. Does the Board have any 

questions? Great. 

>> OPERATOR: Just to let you know, Mary Troupe's line has rejoined. 

>> KAREN BRAITMAYER: Thank you. I think our next speaker is going to 

be Jayar Daily. 

>> ROSE MARIE BUNALES: OPERATOR, can you locate Jayar Daily, and 

unmute when ready? 

>> OPERATOR: I don't see Jayar Daily's line is in. 

>> KAREN BRAITMAYER: Okay. So let's go ahead and take Mary Troupe 

at this time. 

>> ROSE MARIE BUNALES: OPERATOR can you locate Mary Troupe and 

unmute when ready? 

>> OPERATOR: Mary Troupe's line is open. 

>> MARY TROUPE: Thank you. Thank you for this hearing today and 

allowing us to speak on these rules on the emergency transportable housing. I 

am Mary Troupe. I was Executive Director of Mississippi Coalition for Citizens 
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with Disabilities and now just advocacy of Mississippi. I am also a member of 

FEMA's National Advisory Committee and I was very fortunate and privileged to 

serve on the committee looking at these recommendations. 

I would like to thank Marsha Mazz as one spoke earlier about keeping a 

tight ship and also the Chairman of our Committee, Robert Solomon, who also 

helped to keep us on task. As I said, I'm very privileged to be on this committee 

and with other individuals who are there. We did a lot of hard work. We did a 

lot of looking at different things and discussing different areas that were 

important to us. As an individual who was there during Katrina and working 

with individuals with disabilities in our state and all types of disasters, tornado, 

the flooding of last year and of course Katrina, I can tell you how very, very 

important accessible emergency housing is in these times when everything is 

wiped out. 

During Katrina, we had many obstacles that were placed when it came to 

emergency housing and it being accessible. What was called accessible was not 

accessible. These recommendations that you have before us has looked at 

everything. Of course as technology grows and comes in every day, assistive 

technology, there are things that will need to be addressed in the future. But I 

am very pleased with what we as the committee came up with. 

I believe that it does also accessibility certainly more accessibility than we 

have had in the past. I again would like to tell all of those who served on the 
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committee and to thank the Board, the Access Board for pulling us together to 

look at this. 

It is extremely important in times of stress such as these emergencies that 

our country has gone through and is going through now that individuals with 

disabilities do not have more stress put upon them because of the lack of 

accessibility. We looked, as I said in everything, from the knobs to open 

windows to the heights of the beds, to where plug-ins were accessible. As one 

mentioned before, the sink in the kitchen that could also be used for washing of 

the hair, and storage was very important also because in many cases such as 

Katrina this is a long-term living situation for many individuals. And when 

everything is wiped out, accessible hotel rooms, accessible apartments and so 

forth, it was very difficult for us to find places for individuals where they could 

live, could live their lives, get back to some formality -- normality of their lives. 

And so I hope that everyone will see the hard work that this committee did and 

will appreciate what this committee did and will support these recommendations. 

Thank you very much. 

>> KAREN BRAITMAYER: Thank you. Does the Board have any 

questions? Do we have JAYAR Daily? 

>> OPERATOR: Jayar Daily has rejoined. 

>> ROSE MARIE BUNALES: Connect Mr. Daily then. 
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>> OPERATOR: Jayar Daily, your line is open. 

>> JAYAR DAILY: Hello, Good morning. Has Lois Starkey given her 

remarks yet? 

>> KAREN BRAITMAYER: Yes, she has. 

>> JAYAR DAILY: Okay. Great. So you're just ready for me to provide 

my testimony at this point? 

>> KAREN BRAITMAYER: Yes, please. Go ahead. 

>> JAYAR DAILY: Okay, Great. Good morning. My name is JAYAR Daily. 

I'm the Vice President of Operations with the American Homestar Corporation 

which is outside of Houston. We have manufacturing facilities in Texas and 

Alabama and retail locations in many of the southwestern and southeastern 

states in the country. Our company builds modular and HUD code homes. We 

have been in business for over 40 years and during that time we have sold an 

access of 47,000 homes. In the last seven years we have also been extensively 

involved in building short-term emergency temporary housing and permanent 

replacement housing for families who have lost their homes to the hurricane that 

have devastated the gulf coast. 
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In my position with the MHI I serve as the Vice Chair of the National 

Modular Housing Council and I'm also on the MHI Board of Directors and most 

recently in the past couple of years I'm the chairman of the MHI Disaster Housing 

Task Force which was established to work with FEMA regarding programs for 

emergency housing and recovery. 

I believe that Charlie Boyer is going to try to join me. He is our Vice 

President of Manufacturing Operations. And he would be the person who can 

answer any technical questions that you may have. 

Recently, MHI has been working directly with FEMA to address accessibility 

issues for emergency temporary housing built to the HUD code which is the 

manufacturing code that we follow in the industry. And earlier this year FEMA 

issued a solicitation to temporary housing unit that they refer to as THUs, 

including homes that are intended for placement on individual sites. That is the 

site where the people live, where their homes had been. 

Responding to concerns about the feasibility of building UFAS compliant 

houses under 500 square feet, FEMA responded quickly and changed the 

maximum size requirements to provide more flexibility for homes required to 

meet the UFAS standards; we really appreciated that. Also, we note that a 

number of specifications in the current FEMA solicitation are consistent with the 

guidelines proposed by the Access Board in its proposed rulemaking. And that 

solicitation by the way I believe is due today at noon. So good luck to anybody 
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who hasn't finished theirs. The proposed rule amends scoping and technical 

provisions of the ADA and the ABA in order to provide emergency transportable 

housing required to provide mobility features in a more timely and efficient 

manner. 

In general, they are more flexible and prescriptive than the current 

requirements under UFAS and will provide certainty at the design and 

manufacturing stage and ensure that families with disabilities who lose their 

homes are provided with emergency housing that best suits their 

disability-related needs. 

For example, the current ABA and ADA guidelines permit grab bars to be 

admitted at the time of construction where the walls are reinforced to support 

the installation of grab bars when they're needed at a later time by an occupant 

that has a disability. The advisory committee recommended a grab bar in water 

closets, bathtubs and showers be mandatory for emergency housing required to 

provide mobility features in order to ensure disaster survivors have access to 

housing quickly and more efficiently. FEMA already stipulates that homes 

required to meet UFAS standards must be constructed with grab bars. The 

proposed scoping provisions require accessible emergency transportable housing 

units with mobility and communication to be provided in accordance with section 

504 of the rehabilitation act of the ADA and the Stafford Act which prohibits 

discrimination on the basis of disability. The proposed scoping requirements will 

ensure that homes built and purchased by FEMA will meet the needs of 
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individuals with disabilities based on assessed needs and hopefully eliminate 

inefficient costly production of accessible units that may not be needed or 

utilized. FEMA has been taking this approach in recent years requiring specified 

percentage of its total bid solicitation to the UFAS compliance. This allows 

flexibility to place housing on individual and group site based on individual needs. 

While the proposed guidelines recognize that a one size fits all approach is not 

always beneficial given the range of housing needs and types for people with 

disabilities, it can be challenging for manufactures to utilize manufacturing 

concept to design practices to rely on an economic scale and uniform assembly

line techniques. Therefore, MHI recommends that consideration be given to 

providing more opportunities for workforce training and education for accessible 

design and construction practices. Personally --

>> KAREN BRAITMAYER: JAYAR, you are reached the 5-minute mark. 

>> JAYAR DAILY: Okay. Well, thank you. 

>> KAREN BRAITMAYER: Great. Thank you very much for your 

testimony. Are there any questions for JAYAR? Not hearing any, our next 

speaker will be Dominic Marinelli. 

>> OPERATOR: Dominic's line is open. 

>> DOMINIC MARINELLI: Oh, thank you. This was earlier than I 
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expected, but thank you very much. I hope everybody can hear me. 

>> KAREN BRAITMAYER: Yes. Thank you. 

>> DOMINIC MARINELLI: Listen - I'm very honored to be asked to testify 

and my name is Dominic Marinelli. I am the Vice President for Accessibility 

Services for United Spinal Association, so those of you that might know our name 

used to be Eastern Paralyzed Veterans Association. The organization has been 

around since 1946. It was established by paralyzed veterans after World War II. 

And I was on the committee and really felt like I gained more than I contributed 

from the other committee members and I wanted to say that I certainly benefited 

from some of the manufactured housing folks in FEMA and the Department of 

Justice. 

My particular work and I went through all of my past notes was to develop 

some type of compromise requirement, and so the specific things that I was 

tasked with working I think will work for people with disabilities that need this 

accommodation in these types of an emergency and for the builders of these 

transportable housing. 

So my specific task was to work on some allowances for ramps where 

ramps could not be installed at the perfect 1 to 12 slope in tight situations where 

there are site constraints. So our objective was to provide some flexibility in 

that. 
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And so if you just think about that as we go from the exterior to the inside 

of the unit, flexibility on ramp design was followed up by some logic in how we 

were approaching our work in a kitchen. 

So instead of the UFAS dedicated 30-inch work surface, we just specified 

that the kitchen table could also be used to achieve the work surface required in 

the kitchen, saving valuable space. 

So I did want to mention that and just a few of my favorite things about the 

rule. 

We worked hard on language specific to electrical receptacles and electrical 

outlets. It's very hard to organize them in a kitchen and maintain 12 inches off 

of any obstruction. 

So we specified logical areas for electrical receptacles and just different 

things like that. 

And moving on into the unit, part of our task was to really look at the roll-in 

shower and the bathing and bathing facilities and fixtures in the bathroom. And 

so we provided some flexibility in those areas as well. 

You know, again, specifying roll-in showers and a folding seat which is very 
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valuable and that's what I would want anybody to take out of that conversation is 

the folding seat and roll-in shower. Because we thought it would give the 

greatest flexibility. 

So as we move on and I know I'm up against my time, going through the 

unit we just went through the kitchen and my contribution to the kitchen is the 

bathroom and just wanted to talk about the bedrooms for a minute because one 

of my favorite things here was the idea that we would have clear floor space for 

parallel approach, that 30 by 48 inches on one side of the bed and that that would 

be connected on accessible route from other components, other areas of the 

housing unit. So I wanted to just highlight those areas that I had worked directly 

on and would be happy to answer any questions before my time runs out. 

>> KAREN BRAITMAYER: Thank you, Dom. Are there any questions for 

Dom? Not hearing any, we thank you for your testimony. And at this time --

>> DOMINIC MARINELLI: Thank you very much. 

>> KAREN BRAITMAYER: You're welcome. At this time, we're going to 

take a 5-minute break? Okay. We're going to a 20-minute break. 

>> ROSE MARIE BUNALES: OPERATOR, can you keep us connected, 

please? 
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(Break) 

>> KAREN BRAITMAYER: Thank you. I think we're going to go ahead and 

we have shortened the break a little bit so that we can move forward and I did 

want to let everyone know that Jayar's complete remarks are going to be added 

to the transcript so that we -- since he hit the 5-minute mark a little early. 

Our next speaker I believe will be speaking to us on the phone and that's 

Charles Tubre. 

>> OPERATOR: Charles, your line is open. 

>> CHARLES TUBRE: Good morning. Yes. That's right. Charles Tubre. 

Good morning. My name is Charles Tubre and I work for the Advocacy Center in 

New Orleans, Louisiana. The Advocacy Center was started in 1979. It is the 

agency designated by the State of Louisiana pursuant to federal law to protect 

and advocate for the rights of people with disabilities in Louisiana. In the wake 

of Hurricanes Katrina and Rita, the Advocacy Center assisted hundreds of people 

with disabilities in FEMA trailer parks, hotels and other temporary locations in 

finding accessible housing. 

I have used a wheelchair for mobility since 1955. I have worked my entire 

life to increase the ability of people with disabilities to access public facilities and 

government programs. I evacuated from my home in New Orleans just prior to 
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Katrina and was not able to return to it for many months. I consider myself very 

well qualified to testify about the needs of people with disabilities for accessible 

temporary housing in emergencies. 

I served on the advisory committee that made recommendations to this 

Board for amending the guidelines to address the accessibility of emergency 

transportable housing. I testify today, both as an individual and on behalf of the 

Advocacy Center and the clients that we serve. 

Unfortunately, we cannot support the proposed regulations because the 

proposed scoping provisions, which depart from those the advisory committee 

recommended, do not establish a minimum percentage of accessible units in 

group sites. If the scoping provision were changed, we would wholeheartedly 

support the proposed regulation. It is vitally important for the agencies charged 

with provision of emergency housing in emergencies to have standards to follow 

that will make that housing accessible to people with disabilities, and with the 

exception of the scoping provisions, this regulation accomplishes that goal. 

The regulation must provide that facilities that contain emergency 

transportable housing have an adequate minimum percentage of accessible units. 

FEMA is the agency most likely to construct or lease facilities that have 

emergency transportable housing. After Katrina and Rita, FEMA opened dozens 

of trailer parks in Louisiana and Mississippi. The Advocacy Center assisted 
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numerous people with disabilities who were still in emergency shelters and hotels 

months after the storm, who were unable to move into FEMA trailer parks 

because these FEMA trailer parks had no accessible trailers. This meant that 

people with mobility impairments were trapped in the emergency shelters for 

much longer periods of time than people without disabilities, or they were left in 

hotel rooms in extremely cramped quarters with no cooking facilities simply 

because FEMA had neglected to provide accessible trailers in federally 

constructed trailer parks. The Advocacy Center and the National Center for Law 

and Economic Justice had to sue FEMA to provide accessible trailers and to ensure 

that trailer parks conformed to UFAS guidelines. 

The proposed regulations would give the Access Board's stamp of approval 

to the state of affairs. Following Katrina and Rita, FEMA officials contended that 

said FEMA was assessing the needs of each household and making housing 

decisions based on this assessment. However, because FEMA did not require a 

minimum percentage of accessible units in its trailer parks, these needs were not 

met. 

Trailer parks are planned and developed over a period of weeks following a 

disaster. The situation with disaster victims are in constant state of flux with 

some people finding housing with relatives, and others moving to other cities and 

states, and some learning that they can return to pre-disaster housing. The 

precise needs, housing needs of the population will need to populate the trailer 

park cannot be accurately determined in advance. 
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The trailer parks created after Hurricanes Katrina and Rita remained 

populated for several years after the storm. Katrina struck in August 2005, and 

FEMA closed the last trailer park in mid-2008. While the trailer parks were in 

existence, people moved in, they moved out. A minimum percentage of trailers 

needs to be accessible so that they will be available to later residents as well as 

those who move in initially. While these facilities are temporary they are not 

necessarily so short-term as to do away with the need for the minimum 

accessibility requirement. 

Thus the Advocacy Center believes that it is critically important for these 

standards to contain a minimum number of accessible units in group sites. We 

agree that trailers placed near private homes or in other locations to meet the 

needs of specific individuals should meet the needs of those individuals and there 

is no need for scoping requirements there. 

The Advocacy Center -- the advisory committee recommended that 10% of 

emergency transportable housing units at group sites be accessible to people with 

mobility impairments. We noted that the prevalence of the mobility 

impairments in the population nationally is 8.2%, while FEMA’s experience in 

recent disasters put the numbers higher, 12 to 14% generally, and 18 to 20% in 

Hurricanes Katrina and Rita. There are many reasons why the percentage of 

individuals who need accessible emergency housing after a disaster may be larger 

than the national figure for prevalence of mobility impairments. The prevalence 
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of mobility impairment is larger in some areas of the country. In addition, in all 

disasters, people who are poor are most likely to lack the resources to provide 

emergency housing on their own, and poverty is closely correlated with disability. 

While the advisory committee recommended 10% as the highest minimum 

number, the Advocacy Center would prefer a higher percentage and we 

recommend 14% -- that the Interagency Coordinating Council recommended in 

the 2010 report. I would like to point out that the Housing Authority in New 

Orleans has recently agreed based on estimated need in the New Orleans area to 

make 10% of its newly constructed units accessible to people with mobility 

impairments. 

>> KAREN BRAITMAYER: Charles, I'm going to have to stop you. You 

have reached the 5-minute mark. Thank you very much. 

>> CHARLES TUBRE: Thank you very much. 

Thank you for the opportunity to comment on the proposed regulations. 

We wish we could support them, but we strongly believe that the proposed 

scoping provisions for facilities containing emergency transportable housing 

would represent a big step backwards for the rights of people with disabilities. 

We thank you very much. I appreciate all the work that you've done in this area 

and we hope you will consider our recommendations for an adjustment in the 

scoping provisions, and we can then enthusiastically embrace the 

recommendations. 
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>> KAREN BRAITMAYER: Thank you. 

>> CHARLES TUBRE: Thank you. 

>> KAREN BRAITMAYER: Our next speaker will be Cary LaCheen. 

>> ROSE MARIE BUNALES: OPERATOR, locate Cary LaCheen.

>> OPERATOR: No, I don't show that Cary's on the call. 

>> ROSE MARIE BUNALES: Okay. Do you have a Robert Solomon? 

>> OPERATOR: No. 

>> ROSE MARIE BUNALES: Chairman, did you want to go back just to 

open? We don't have any walk-ins. 

>> OPERATOR: Did you say Robert Solomon? 

>> ROSE MARIE BUNALES: Yes, OPERATOR. 

>> OPERATOR: Ok, I do have Robert Solomon. Let me open his line. 

Robert, your line's open. 
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>> ROBERT SOLOMON. Okay. Thank you. I was getting ready to send 

an e-mail. Good morning. My name is Robert Solomon, a Division Manager 

with NFPA. I appreciate the opportunity to offer some testimony today on this 

important rulemaking issue. 

In my 26 years with NFPA I've had the opportunity to be involved with 

many interesting and challenging projects and I have to say near the top of this 

list is the privilege I've had to chair the advisory committee whose 

recommendations we have been hearing about this morning. 

I would like to thank the members of the advisory committee who worked 

on these issues in 2007 and 2008. It was a great pleasure and honor to work 

with all of you. 

Our group worked diligently over a 14-month period to refine and establish 

recommendations that were issued in the NPRM on June 18th of this year. 

I fully support the recommendations that have been put forth by the Access 

Board. The use of emergency transportable housing units in disasters is a 

feasible and prompt method of getting a roof over your head and a semblance of 

normalcy back. This rule is intended to address these types of units and to 

further enhance programs that FEMA has been managing for many years. 
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The U.S. is no stranger to natural and human caused disasters and events. 

Whether a fire destroyed someone's home, a tornado devastates a community, a 

wild fire wreaks havoc on many hundreds of homes, or a hurricane causes mass 

evacuation of many tens of thousands of people, the resilience of our fellow 

citizens is almost always shown in the phrase: "we will be back and we will 

rebuild." I have never experienced a personal disaster of any significant 

proportion. I can only imagine the feeling of being displaced from your home for 

any period of time, let alone for weeks or months or perhaps years. I also can 

only imagine difficulty of trying to adjust to a physical environment which 

introduces challenges to everyday items like bathing or cooking or getting into 

bed at night. In some cases, even coming back to your own property and getting 

into your house, even a temporary dwelling. 

The ETH federal advisory committee was formed in 2007 to look at issues 

and problems encountered in the 2005 hurricane season relating to Hurricanes 

Katrina and Rita. These events alone challenged the resources of the Federal 

government to not only locate and deploy emergency housing, some which 

remained in use for years, but also to provide a usable, feasible housing unit 

option for displaced residents who may have needed one or more accessible 

features. 

A retired representative from Minnesota is quoted as saying, "The purpose 

of the ADA was to provide clear and comprehensive national standards to 

eliminate discrimination against individuals with disabilities. As a result, 
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individuals with disabilities are not able to live in their homes and have access to 

new careers.” Once the proposed rules on emergency transportable housing are 

finalized, people with disabilities will also have the chance to live in the temporary 

home away from home as well. 

The applicability of implementation of the proposed rules is critical in 2012. 

In just the last year, 81 major disaster declarations have been issued by FEMA. A 

variety of events including an earthquake in Virginia, an eastern seaboard 

hurricane and tropical storm, alluvial coastal and inland flooding, tornados, 

landslides, mudslides, and recently, wildfires have plagued the U.S. and 

confronted the resources of FEMA. The roles and responsibilities of local and 

state governments, tribal and territorial governments, regional compacts and the 

federal government are by and large delineated in the readiness components that 

make up the emergency response strategy of local planners for these events. 

The private sector and NGO community also have a role in responding to and 

assisting government agencies so long as they are part of the planning 

component. 

Providing early warning, rescuing, moving and relocating victims of 

disasters is a part of this overall strategy. And while the ordeal of being away 

from your home is difficult enough, being in a temporary home you cannot easily 

gain access, maneuver without difficulty once inside, prepare meals or get into 

bed without trouble are among the issues that adapted an accessibility ETH units 

can offer to the resident. PPD-8, FIOP, MNS, ODIC, EMPG, NDRF as well as a 
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myriad of various acronyms are now a common part of the emergency planning 

lexicon. 

Since May of 2011, FEMA's EMPG - Emergency Management Performance 

Grant Program, has been emphasizing the importance and need for inclusive 

planning at all levels. In FEMA Information Bulletin 361 issued in May of 2011, 

FEMA says “Homeland Security and emergency managers at all levels are to plan 

for the whole community by integrating and coordinating emergency 

preparedness, response and recovery for children and adults with disabilities and 

others with access and functional needs.” Accessible housing resources are 

among the examples listed in the information bulletin in order to help satisfy that 

goal. 

Likewise, the NDRF, National Disaster Recovery Framework issued in 

September of 2011, outlines and defines the roles and responsibilities to enable 

effective recovery support to disaster impacted states. Temporary fixes or 

bridges as described in the NDRF offer transition to permanent measures. 

Keeping the residents in their own neighborhood by offering ETHUs on their own 

property is one solution rather than relocating residents to centralized sites or 

locations. This allows them to have an at-home feeling, watch their property 

and supervise reconstruction of a damaged or destroyed home. And perhaps 

more importantly maintain the continuity and familiarity of a neighborhood. 

By supporting and accepting these changes much progress will be made 
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toward bridging the resident back to the permanent housing situation. Singer 

Stevie Wonder, among others, is attributed to the quote, if you don't ask, you 

don't get. Today, I urge you and ask you to support the proposed rule. Let's 

get the right kind of temporary housing accommodation for the right 

circumstance. 

Thank you very much for your time this morning. 

>> KAREN BRAITMAYER: Thank you, Robert. And I also wanted to 

acknowledge and thank you in particular for your position as chairing the advisory 

committee. Do we have Cary on the line yet? 

>> OPERATOR: It was Terry, correct? 

>> ROSE MARIE BUNALES: Cary; C A R Y. 

>> OPERATOR: No, Cary's not on the line. 

>> ROSE MARIE BUNALES: Last name is LaCheen. 

>> OPERATOR: No. 

>> KAREN BRAITMAYER: At this time, we have an opportunity if there is 

anybody who was not on the sign-up list and wishes to make public testimony, we 
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have an opportunity for that to happen at this time. 

>> OPERATOR: If you would like to testify, please press star 1, if you're on 

the phone. Again, press star-1 if you would like to testify ... and I don't show 

that Cary LaCheen is on the all.

>> ROSE MARIE: Thank you operator. 

>> KAREN BRAITMAYER: Is there anyone who has previously testified who 

would like to expand on their testimony at this time? 

>> OPERATOR: If anyone would like to expand on their testimony, please 

press star-1. 

>> KAREN BRAITMAYER: Lois, why don't we take you? 

>> LOIS STARKEY: I just wanted to finish JAYAR's testimony because it 

addresses an issue that I know there was much debate on during the advisory 

committee deliberations and it has to do with the ramp proposal. MHI supports 

the proposal and exists as an exception to the existing ramp proposal. We do 

think that there was -- I know there was a lot of discussion about the height of the 

manufactured housing when you have to keep the tires on and we did an informal 

survey of our members, retailers and manufacturers, and the average elevation is 

32 to 36 inches when the tires are not removed. So we do believe that the 
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proposal will allow more people to remain on their own property while their 

permanent home is being repaired or replaced and it will reduce the area needed 

for construction by a substantial amount. 

And I do want to point out that our work with FEMA, we know that they 

work very hard to make sure that individuals who have special needs and I think 

they have learned this from Katrina, get the attention and get the home that they 

need. So it will be up to FEMA to make sure that the individual receiving this 

home with an elevation -- with a ramp that has a higher elevation will be able to --

will want this. They aren't going to provide a home to somebody who feels that 

they can't use that extra rise efficiently. 

So I just want to make that point, that I think there is a -- these proposals 

provide for the opportunity for everybody to get the home that they want. So 

thank you very much. 

>> KAREN BRAITMAYER: Thank you, Lois. Was there anyone else who 

wished to either expand on their testimony or provide new testimony? 

>> OPERATOR: I do have someone on the phone that would like to do so, 

would you like me to open their line? 

>> KAREN BRAITMAYER: And, yes. 
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>> OPERATOR: Charles Tubre, your line is open. 

>> CHARLES TUBRE: Thank you very much. This is Charles Tubre. Just 

to conclude, I had another brief statement that please note that requiring a 

minimum percentage of accessible units in no way limits FEMA's flexibility to 

provide emergency transportable housing units with mobility features based on 

the needs of applicants. Housing that is accessible to people with mobility 

impairments is fully usable and accessible to persons without such impairments 

and FEMA is free to exceed any minimum percentage contained in the regulation. 

Now, to specific features that were addressed by the Board made 

recommendations, one, kitchen features should provide room for people in 

wheelchairs to roll under the sink. It is my understanding that the current 

regulations provide for a front approach to kitchen sinks by a person in a 

wheelchair as well as sufficient knee clearance so that the wheelchair will fit 

under the kitchen sink. The proposed emergency transportable housing 

regulations do not contain a different standard exception insofar they eliminate 

the exception for removable under sink cabinets. If my understanding is 

incorrect and there is no standard requirement that kitchen sinks be approached 

from the front and that a wheelchair be able to roll under the sink, there needs to 

be a specific standard that requires this. 

In addition to the water spray unit required by the proposed regulations, I 

suggest that kitchen sinks in emergency transportable housing be required to be 
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fitted with a swiveling goose neck faucet which increases its versatility and 

movability by people with disabilities. For many people with disabilities, bathing 

is an arduous activity in being able to wash one's hair and perform other tasks in 

the kitchen is very useful. While a water spray unit is also very useful for some 

tasks, it is hard to operate for a person whose hands and arms may be affected by 

a disability. The water spray unit would require good use of one's hands. If 

you don't have an assistant and that would be impossible to wash one's hair at 

the sink. If the goose neck is provided with a swivel feature, then one can lean 

over and have the water running and wash their hair without assistance. 

The standard for maneuvering clearances in the bedroom, we also would 

like to express appreciation for the new standard for a bedroom lighting control 

being able to adjust one's lighting from the bed or a person's ability to transfer in 

and out of bed is limited is one of the things that adds greatly to a person's 

independence. 

Again, we thank the committee for their work. It is a pleasure working 

with the committee under Mr. Solomon's guidance and thank you again for the 

opportunity to speak to the issues at hand this morning. 

>> KAREN BRAITMAYER: Thank you, Charles. Do we have anyone else 

on the line, Rose? 

>> OPERATOR: Cary LaCheen has joined. Would you like me to open? 
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>> ROSE MARIE BUNALES: Yes, please. 

>> OPERATOR: Cary, your line is open. 

>> CARY LACHEEN: Hi. Good morning. Should I start my testimony? 

>> KAREN BRAITMAYER: Yes. That would be great. Welcome. 

>> CARY LACHEEN: Okay. Good morning, everyone. My name is Cary 

LaCheen and I am a senior staff attorney at the National Center for Law and 

Economic Justice. And we were co-counsel with the Advocacy Center of 

Louisiana in a class action lawsuit brought against FEMA after Hurricanes Katrina 

and Rita on behalf of displaced people with disabilities who were not provided 

with accessibility temporary housing. That is our connection to this issue and 

why we're testifying. 

We have been working in the years since the case was settled to make sure 

that FEMA has adequate policies and procedures in place to serve people with 

disabilities in future disasters. 

We support developing specific standards in the ADA and ABA guidelines 

for emergency transportable housing. 
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But we are strongly opposed to some of the standards that have been 

proposed, particularly the scoping requirements for housing units with mobility 

features. 

The proposed standard will not ensure that people with disabilities get the 

accessible temporary housing that they need, and that is why we're opposed to it. 

The current scoping requirement for dwelling units at facilities provided or 

paid for by agencies other than HUD, in other words, FEMA is that 5% of the 

housing units in a facility, but no fewer than one unit, must be accessible to 

people with mobility impairments. 

The Access Board's advisory committee recommended that the minimum 

scoping requirement be doubled to 10%. But instead, the Access Board is 

proposing to eliminate a numerical minimum entirely and replace it with language 

saying that agencies must provide housing with mobility features, quote, in 

accordance with regulations implementing Section 504 of the Rehabilitation Act, 

Stafford Act, and the Americans with Disabilities Act regulations. We think this is 

a terrible idea for several reasons. 

Number one, FEMA officials and officials of other agencies if these ranks 

are relevant to them, who consult these standards during a disaster response 

won't have any idea what to do or how many accessible housing units to put at 

group sites. 
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Number two, the regulations don't have any proposed numerical scoping 

requirements -- I'm sorry. The regulations referred to in this proposed standard 

don't have numerical scoping requirements. And as far as we know, the relevant 

agencies like FEMA are not planning to revise their regulations to add scoping 

requirements. 

The Americans with Disabilities Act doesn't even apply to FEMA programs 

and services or programs and services of other federal agencies. We have no 

idea why that's mentioned in the proposed standard. 

We assume that what this language means is that the proposed standard is 

basically referring to the general antidiscrimination standard in the regulations 

and regs that say that programs and services have to be accessible to and usable 

to and by people with disabilities. 

The whole point of ADA and ABA Accessibility Guidelines is to take general 

requirements for accessibility and nondiscrimination that are in the regulation 

and tell federal agencies what specifically they're supposed to do to achieve 

accessibility. Guidelines that just refer back to the general regulations don't do 

this and are basically circular and meaningless. We think the proposed standard 

is unworkable and ineffective. 

The purpose of a numerical scoping standard is to ensure that facilities with 
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lots of units have at least some accessible units. 

A scoping standard that basically says don't discriminate, give people what 

they need, which is I think what you're after with this proposed standard, doesn't 

ensure that group sites will have any accessible units. 

It's also based on a very unrealistic assumption that FEMA and other 

agencies will know what households need before group sites are set up or while 

they're being set up and before people actually show up at group sites. That's 

not how it works after Katrina and Rita and we don't think it's likely to work that 

way in the future. Households do not all apply for housing assistance at the 

same time and they don't all apply immediately after a disaster. 

Group sites are set up before FEMA knows what families will live there and 

even before FEMA has received applications from everyone who will end up living 

there. 

If group sites are not required to have a minimum number of accessible 

units, some, at least some, if not many, are likely to have no units at all in the 

beginning and then when a family shows up that needs an accessible unit, it may 

have to wait weeks or months until one is delivered. 

In fact, during the time it takes --
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>> KAREN BRAITMAYER: Cary, I need to let you know that you have met 

the 5-minute time limit. 

>> CARY LACHEEN: Okay. 

>> KAREN BRAITMAYER: So if you would just conclude your comments 

with just a few more sentences, that would be great. 

>> CARY LACHEEN: Okay. I was going to talk about the various 

rationales that were offered for this standard. We think all of them are, you 

know, silly, and don't really support the standard. 

We believe the standard should be that 15% of units at group sites be 

accessible to people with mobility impairments. 

The Interagency Council Report from 2010 says that FEMA and HUD were 

working on developing a 14% standard. That's where we get the 15% standard 

from. 

If you're worried about applying a scoping requirement to private homes, 

the scoping requirement should exclude private homes and for private homes the 

standard should just say that people with disabilities should get what they need. 

That's what the advisory committee recommended and that's what we think the 

agency should do in the standard, the Access Board. 
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So I'm happy to answer any questions if there are any. 

>> KAREN BRAITMAYER: Thank you, Cary. Does the Board have any 

questions? Not hearing any, I thank you for your testimony. 

>> CARY LACHEEN: Thank you. Bye-bye. 

>> KAREN BRAITMAYER: So are there any remaining individuals who'd like 

to testify who have not yet done so? 

>> OPERATOR: I do have someone who had cued up to go ahead and 

testify; would you like me to open their line? 

>> KAREN BRAITMAYER: Yes, please. 

>> OPERATOR: Mary Lamielle, your line is open. 

>> MARY LAMIELLE: Thank you. Yes. Hi. My name is Mary Lamielle 

and I'm Executive Director for Environmental Health Strategies, we're a 

nonprofit-based organization in New Jersey that addresses chemical, electrical, 

and other types of sensitivities and reactions to environmental exposures. I was 

a member of the Emergency Transportable Housing Advisory Committee. I'm 

going to send comments and I wanted to make a very brief statement. I don't 
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support the proposed regulations and specifically, I don't support it because I 

believe that they have failed to adequately address indoor environmental quality 

issues and the emergency transportable housing accessibility concerns for those 

disabled by chemicals/electrical sensitivities and to the group I would say what 

about us? 

What about those of us up to 6% of the population with these disabilities 

whose needs need to be addressed in these same emergencies? 

So I intend to -- I'm not going to make a more detailed comment now. I'll 

send something prior to the deadline. But I'm just going to leave that there with 

the folks who are there and on the phone. 

Thank you. 

>> KAREN BRAITMAYER: Thank you, Mary. Are there any questions for 

Mary? Not hearing any, do we have anyone remaining on the line? 

>> OPERATOR As a reminder, if you'd like to make a testimony, please press 

star-1. One moment to see if we have any other testimony interested over the 

phone. I'm showing none over the phone.

>> KAREN BRAITMAYER: Thank you. I thank everyone for attending 

today, and I believe that concludes our hearing. 
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>> ROSE MARIE BUNALES: OPERATOR, our hearing is concluded. Please 

disconnect all lines. Thank you for your assistance. 

(Conclude)