In Part 1, we explored the difference between compliance and equity in park design, and how the High Falls State Park project’s own equity goal — to “express equity in access, engagement, design, and cultural interpretation” — demands more than a compliance approach can deliver. Now let’s get specific. What would an equity approach actually produce at High Falls — and what gets missed when the design process defaults to compliance?

What Gets Missed: Specific Equity Features a Compliance Framework Won’t Catch

Surfaces: The Ground Beneath Our Feet

Here’s a mind-bending concept for people who don’t use wheelchairs: grass is not accessible. We go to parks because there is green space, but that green space isn’t generally usable by people with mobility disabilities. When CDR looked at the current park design, we thought: Green = Not Accessible. There is — appropriately — a lot of green space. The equity challenge is how to make the park maximally accessible while maintaining the primary benefit.

Unpaved surfaces like fines (crushed stone) present similar challenges. When sufficiently compacted and maintained, fines may provide a reasonable surface. When they aren’t, they become an insurmountable barrier. That creates a second “No Disabled People” zone in addition to the grass. As part of the design process, we’ve asked to visit a local site where the fines that have been proposed for this project are in use to evaluate what the surface actually looks like in practice.

The park will be using grade-level wood decking which raises its own questions. Wood can become slippery in damp conditions. How will it be maintained? How will snow be removed? These aren’t abstract concerns. One of our staff members replaced their home ramp with a raised sidewalk because the wood became dangerously slick in Rochester’s climate.

Play Spaces: Disabled Children and Disabled Parents

The current play area design is entirely surrounded by grass — which means it is entirely surrounded by an inaccessible surface. Although the design team has assured us the play surface itself will be accessible and an accessible route will be included, neither is shown in the design documents. That matters. Explicit documentation memorializes intent and creates accountability.

But access to the play area isn’t just about Disabled children. Disabled people are parents too. Think about grass the way you would think about a chain link fence that a parent cannot pass through, but their children can. You can see your children but not get to them except through specific routes. A compliance approach might provide one accessible path to the edge of the play area. An equity approach asks: can a Disabled parent move freely through the play space, interact with their child, reach them quickly if needed? That may mean rethinking the layout of the play area itself.

And representation matters in the design process as well. The presentation images currently show only non-disabled children and spaces designed for non-disabled bodies. As a marginalized community, we do not assume inclusion when nothing is explicitly stated. A lack of representation generally signals a lack of inclusion. Including images of Disabled children using accessible play features sends a message that our children are valued. It also helps educate the broader public about our issues and to recognize the inaccessibility of traditional playgrounds.

Designing Across the Disability Spectrum

Equity demands that we think beyond a single disability experience. People have multiple disabilities. A Deaf person may also use a wheelchair. A DeafBlind person needs design features that work at the intersection of both sensory experiences.

This is where well-intentioned accessibility efforts can actually fail. Imagine a park creates a sensory nature trail — a groundbreaking concept that provides a unique experience for Autistic visitors. But the trail uses unpaved paths. The feature is simultaneously an innovative accessibility achievement and an inaccessible space for people with mobility disabilities. A compliance review might celebrate the trail. An equity analysis would catch the contradiction.

An equity approach considers how features work across disability experiences, including Deaf visitors who need round tables (not rectangular ones) for unimpeded visual access during conversation, clear sightlines in play spaces so Deaf parents can monitor their children, tactile navigation and Braille signage integrated throughout (not just at the entrance), scented gardens and interactive elements that create rich experiences for Blind and DeafBlind visitors, and paths and surfaces that remain accessible for wheelchair users and people with mobility disabilities throughout the park.

Rochester’s Missing History

The Heritage theme of the High Falls project commits the park to honoring the Genesee River’s cultural significance and Rochester’s rich history. The project’s discovery takeaways state that the site offers opportunities for “storytelling and interpretation” of its industrial legacy and cultural heritage. The site legacy timeline traces Rochester’s history from the Seneca Nation of the Haudenosaunee People through the Erie Canal era, the founding of Kodak and Xerox, and the Olmsted park system. The project acknowledges Seneca heritage, highlights Rochester’s connection to Frederick Law Olmsted, and celebrates the city’s history of innovation.

But Disability was absent from the presentation. It is absent from the site legacy timeline. It is absent from the heritage narrative.

This is a significant omission. Rochester has a deep and nationally important connection to disability activism. The September 1966 protest in downtown Rochester that precipitated the creation of the Regional Center for Independent Living has been described as the first protest of the modern disability rights movement. It preceded the Towaway Picket in New York City by months, the Architectural Barriers Access Act by years, and the 504 protests by more than a decade. That history is as much a part of Rochester’s story of innovation and social progress as Kodak, Xerox, or the Olmsted park system.

The project’s own discovery research notes that Rochester has an above-average number of Disabled residents and a large concentration of Deaf residents, reflected in the presence of the National Technical Institute for the Deaf. This isn’t incidental context — it’s a defining feature of Rochester’s identity that has shaped the city’s culture, institutions, and history of activism. A heritage narrative that omits Disability is incomplete.

Despite this history, you don’t see Disabled people or disability rights reflected in the videos and materials promoting the City of Rochester — even the ones celebrating the city’s diversity and hometown heroes. The new High Falls State Park, with its commitment to equity and cultural interpretation and its plan to include a historical walk-through, is an opportunity to correct that erasure.

The park’s proximity to the Rochester School for the Deaf offers one possible connection point. CDR and RCIL’s “Art and Artifacts” project, which documents disability rights history through protest signs and historical materials, offers another. We have asked to meet with the design team to explore how to authentically represent this underrecognized dimension of Rochester’s history.

The Equity Challenge

Rochester surveyed 220 miles of city sidewalks and identified 65,685 unique access barriers as defined by the ADA. That works out to roughly one barrier every 18 feet. The city has proposed a 50-year plan to remove 89% of those barriers — meaning that more than 85 years after the ADA became law, our sidewalks still won’t be fully accessible.

That context is why we are pushing so hard on High Falls. This park is not just a park. It is a statement about what Rochester and New York State believe equity means. The project’s own equity objectives commit to ensuring access for all residents, improving accessibility, and coordinating with the City of Rochester on equitable development. The Connectivity theme calls for safe and inclusive access. The Heritage theme promises storytelling that honors the site’s significance. We are asking the project to live up to the goals it has already set — by extending them fully and meaningfully to Disabled Rochesterians.

We are working to bring together a broader group of Disabled individuals with different perspectives and lived experiences to inform the planning process. We want to partner with the state, the City of Rochester, and the design consultants on this. If you are a Disabled Rochesterian — or if you care about what equity looks like in practice — we want to hear from you.

Interested in getting involved? Contact the Center for Disability Rights about the High Falls State Park project and other accessibility advocacy.

Phone: (585) 546-7510

Email: advocacy@cdrnys.org

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The Center for Disability Rights is working to ensure the full integration, independence, and civil rights of Disabled people.