Good evening,
I write on behalf of the myriad individuals with mental illness, developmental and intellectual disabilities and those without homes who frequent DC libraries on a daily basis. My comments regarding the above-mentioned proposed revisions to the regulations are as follows:
Many individualized day support programs use our DC public libraries as a drop-off/pick up point and our day programs use them as an outing for the day. I am concerned these stringent rules will force those indivuals who may not understand or have behavioral needs to not have access to their programs, which is an integral part of their interdisciplinary support plan.
810.1 – Many individuals with mental illness, intellectual or developmental disabilities may not understand the search of their belongings and become combative out of confusion. What training is given or will be given to the library employees tasked with this role to avoid a behavioral incident? How often is this training administered, what is the threshold for satisfactory completion of this training? Lastly, who, at each library, is tasked with ensuring those with disabilities are not discriminated against with regard to this search policy?
810.3 – The Library may have individuals with mental illness, IDD/DD who are unable to understand the rules/regulations due to their disability. What accommodations are they afforded so they can continue to frequent the library? Are those police officers assigned to enforce these regulations trained in how to support someone with IDD/DD who may also have a mental illness? Do these officers know who to call if the person should enter into a behavior or have a mental health episode? If they do go into an episode, does that require them to be barred from all libraries for something they cannot control? That is discrimination!
810.4 – How will the individual receive the Notice of Barring and who is going to assist them in appealing that notice. There is nothing in the regulations regarding assistance with appealing for those with disabilities.
810.5 – The reasonable accommodation section doesn’t specify what reasonable modification are available. Does this mean any time a person with a disability or their provider wants to go to the library they must first get approval from the ADA Coordinator if they have a mental illness or IDD/DD?
810.6 – Category One rules seems to be a backdoor attempt to exclude access to libraries by those without a home. See 810.6 (1-6). Libraries have been AND should remain a safe haven for those without a home. They use library resources to contact friends and family, research and apply for housing and jobs and apply for critical city services. Limiting their access because of the size or number of their bags (the only possessions they own) or the fact the have an odor or may take a much needed nap among other category one offenses flies in the face of the supposed DC values that our Mayor touts.
It is clear that the overall role of these revised regulations is to limit access to libraries to those with disabilities and those without homes. The fact that it could also limit access to children, who equally need the safe space of the libraries is I hope unintended.
I humbly ask that these proposed regulations be revised based on the above to ensure they are not used to discriminate against the most vulnerable populations in our city.
I received the following response from the DCPL General Counsel's Office:
Hello Ms. Johnson - Thank you for your comments. For the sections you highlighted, these are the Rules of Behavior that the library has had in place for three or more years. We regularly benchmark ourselves against the rules adopted by other urban library systems, to arrive at a set of guidelines that facilitate safe, welcoming spaces for all - staff and customers alike.
810.1 - Search policy
Frontline staff and public safety officers are trained in de-escalation, typically through a day-long course and regular refreshers. Every library has a dedicated branch manager who is responsible for appropriate implementation of the policy at all levels.
810.3 - IDD/DD customers…