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June 17, 2008 Grace Chung Becker Re: CRT Docket No. 105; 106 Dear Acting Assistant Attorney General Becker: We, the undersigned member organizations of the Consortium for Citizens with Disabilities (CCD), urgently request extension of the period for formal public comment on the Americans with Disabilities Act (ADA) notices of proposed rule making published in today's Federal Register. The ADA directly affects the lives of more than 43 million Americans, their families and friends. The advanced copy of the proposed regulations, only just recently made available in draft form by the Department via the Internet, is voluminous. Taken together, all materials related to this proposed rulemaking include nearly 1,000 pages of content and at least 50 specific questions for discussion. While we value the opportunity to comment on the proposed ADA regulations, their scope is too broad, the questions they pose too involved, and their impact too far-reaching to rush their consideration. We therefore ask that the comment period be extended to at least 120 days to allow the public to provide the most complete and deliberative input that such significant matters deserve. Extending the comment period to at least 120 days would double the opportunity for thoughtful public input. The Department has itself both set precedent for such an extension and previously benefited from it substantially. When the public comment period during the last major ADA regulatory proceeding undertaken by the Department was extended to twice the original time proposed, more than 900 detailed comments were received. By following this practice during this proceeding and at least doubling the period for public comment, both we and the Department could be somewhat more confident in the quantity and quality of comments needed to make the present public comment period meaningful. The Consortium for Citizens with Disabilities is a coalition of more than 100 national consumer, advocacy, provider, and professional organizations advocating for people of all ages with physical, mental, sensory, and intellectual disabilities. Thank you for your consideration of our request. Adapted Physical Activity Council
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