[nfbmi-talk] some public state plan mcb comments

[joe harcz Comcast]

Comments on “Program Access requirements MCB State Plan 2011

 

 

June 21, 2011

 

Comments on aspect of Michigan commission for the Blind 2012 State plan amendments.

 

I am writing today to comment on a component of the MCB State Plan amendments (see section after my signature line especiallly letter “c”).

 

I have documented repeatedly that MCB doesnot meet the program access requirements of the Americans with disabilities Act and the other associated laws. In fact at the most recent MCB quarterly meeting there was not required raised character and Braille signage on even the room we met in let alone throughout  the building. Ditto for each and every location of the so-called public hearings on this very state plan. Ditto for the last quarterly meeting of the MCB Commission.  In fact this occers in all state buildings and signage is a “program access issue as defined under regulations of Title II of the Americans with Disabilities Act of 19900.

 

These are not the only substantial violations of the program access obligations of MCB, but they sure are a stark and tangable and long time documented violation of these obligations and mass discrimination in fact.

 

Simply stating that facilities are accessable as the releases related to public hearings and meetings doesn’t make it so. And in fact is nothing short of a documented lie.

 

Cc: MCB Board

Cc: RSA

 

 

C: Michigan Protection and Advocacy Services, Inc.

 

 

Sincerely,

 

Paul Joseph Harcz, Jr.

 

Advocate who is Blind

 

(Attached reference from State Plan update and MCB web siteJC

 

c

 

 

 

4.9 Methods of administration. (Section 101(a)(6) of the Rehabilitation Act; 34 CFR 361.12, .19 and .51(a) and (b))

(a) In general.

The state agency employs methods of administration, including procedures to ensure accurate data collection and financial accountability, found by the commissioner to be necessary for the proper and efficient administration of the plan and for carrying out all the functions for which the state is responsible under the plan and 34 CFR 361.

(b) Employment of individuals with disabilities.

The designated state agency and entities carrying out community rehabilitation programs in the state, who are in receipt of assistance under Part B, of Title I of the Rehabilitation Act and this State Plan, take affirmative action to employ and advance in employment qualified individuals with disabilities covered under and on the same terms and conditions as set forth in Section 503 of the Rehabilitation Act.

(c) Facilities.

Any facility used in connection with the delivery of services assisted under this State Plan meets program accessibility requirements consistent with the provisions, as applicable, of the Architectural Barriers Rehabilitation Act of 1968, Section 504 of the Rehabilitation Act, the Americans with Disabilities Act of 1990 and the regulations implementing these laws.