HomeMy WebLinkAboutItem 07 ADA Self-Evaluation and Transition Plan AGENDA ITEM SUMMARY Meeting Date: 9/5/2017
Meeting Type: Regular Meeting
Staff Contact/Dept.: Tom Mugleston Staff Phone No: 541-726-3724
Estimated Time: 10 Minutes
S P R I N G F I E L D C I T Y C O U N C I L Council Goals: Foster an Environment that Values Diversity
and Inclusion ITEM TITLE:
ADA SELF-EVALUATION AND TRANSITION PLAN
ACTION REQUESTED:
Conduct a public hearing and move to approve/not approve the City’s Americans With Disabilities Act (ADA) Self-Evaluation and Transition Plan
ISSUE
STATEMENT:
In accordance with state and federal law, the City is required to conduct an ADA self-evaluation to review the accessibility of their programs, services and activities.
The law also requires that public entities with more than 50 employees develop a
Transition Plan that sets forth the necessary steps for structural changes to facilities that are needed to make programs accessible.
ATTACHMENTS: Attachment 1: Council Briefing Memo from June 12, 2017 Attachment 2: City of Springfield Americans with Disabilities Act (ADA) Self-
Evaluation and Transition Plan Attachment 3: Public comment received regarding the City’s draft ADA Self-Evaluation and Transition Plan
DISCUSSION/ FINANCIAL IMPACT:
The City Council held a work session on June 12, 2017 to provide input on the
City’s draft Americans with Disabilities Act Self-Evaluation and Transition Plan
and to provide staff with feedback regarding the public outreach strategy for soliciting public comment on the plan. Following the work session, the draft was
posted to the City’s website and made available for public comment through August 21. City staff held four open house events on August 14 and August 16 to solicit in-person feedback. Comments were received in writing from the Lane
Independent Living Alliance; no other public comment was submitted. The draft ADA Self-Evaluation and Transition Plan has been revised to reflect the
comments received and the Council’s input during the June 12 work session. City staff now recommend that the Council hold a public hearing on the final draft of the
Americans with Disabilities Act Self-Evaluation and Transition Plan. If approved
by Council following the public hearing, the final ADA Self-Evaluation and Transition Plan will be posted to the City’s website for at least the next three years.
There is no financial impact to City to adopt the ADA Self-Evaluation and Transition Plan document; funding mechanisms for necessary ADA improvements
are further discussed within the Transition Plan document.
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M E M O R A N D U M City of Springfield
Date: August 31, 2017
To: Gino Grimaldi COUNCIL
From: Tom Mugleston, Risk Manager Kristina Kraaz, Assistant City Attorney BRIEFING
Subject: ADA Self-Evaluation & Transition Plan MEMORANDUM
ISSUE: In accordance with state and federal law, the City is required to conduct an ADA self-evaluation to review the accessibility of their programs, services and activities. The ADA also
requires public entities with more than 50 employees to develop a Transition Plan that sets forth the necessary structural changes to facilities needed to make programs, services, and facilities
accessible. The purpose of this memorandum is to update the Council on the updated draft of
the City’s ADA Self -Evaluation and Transition Plan and to provide information regarding finalizing the plan.
BACKGROUND:
In July 1992, the City of Springfield published its first self-evaluations and Transition Plan, and
published a Final Report in 1995 detailing the progress made up to that point. Since 1995, the original plan and self-evaluations have become outdated as technologies, ADA law, and City
programs and facilities have evolved. This Americans with Disabilities Act Self-Evaluation and Transition Plan updates, revises, and replaces the previously published Transition Plan documents.
In 2014-2015, the City conducted a self-evaluation across all City departments to assess ADA compliance in access to City services, programs, and facilities. The results showed that all departments have made independent efforts to comply with the ADA, but that work had not been
incorporated into a cohesive, city-wide policy. City staff subsequently incorporated the self-evaluation results into a draft ADA Self-Evaluation and Transition Plan. This draft was
presented to Council for feedback at Work Session on March 23, 2015.
Following Council feedback in March 2015, City staff completed a self-evaluation of City-owned buildings and incorporated those results into the draft Transition Plan. The draft
Transition Plan also sets City priorities for making needed structural changes to City-owned
buildings and facilities, including sidewalks. The ADA requires the City to inventory all non-compliant City sidewalks and curb ramps and develop a plan to bring them into compliance
throught the Transition Plan. This draft Transition Plan includes the City Engineeer’s
recommendation for conducting an inventory of the City’s sidewalks and curb ramps and identifies a preliminary plan to bring existing non-compliant curb ramps up to ADA standards.
The ADA requires the City to make the ADA Self-Evaluation and Transition Plan available for
public comment. The draft plan provides for the following public involvment process: a 30-day public comment period on the draft plan, two open houses hosted by the City, notice of the draft
plan in local newspapers and posting on the City’s website, and inviting input from interested stakeholders. City staff will make any necessary revisions to the draft ADA Self-Evaluation and Transition Plan in response to public comment, and will present the final draft for Council
adoption in Fall 2017. Following adoption of this plan, the City will conduct self-evaluation surveys approximately every 2-3 years with updates to the Transition Plan accordingly.
RECOMMENDED ACTION:
Provide recommendations and input regarding the City’s ADA Self-Evaluation Survey and Transition Plan, including the public involvment provisions of the plan.
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City of Springfield
Americans with Disabilities Act Self-Evaluation and Transition Plan
*DRAFT* August 24, 2017
Contents
1. Introduction .................................................................................................................. 2
1.1. ADA Background .................................................................................................. 2
1.2. ADA Coordinator ................................................................................................... 2
1.3. Requesting an Accommodation ............................................................................ 3
1.4. Filing an ADA Complaint ....................................................................................... 3
1.5. Self-Evaluation and Transition Plan Process ........................................................ 4
1.6. Public Outreach .................................................................................................... 5
2. Self-Evaluation of City Services, Programs, and Activities ........................................... 6
2.1. Customer Service (walk-in, telephone & letters/emails) ........................................ 6
2.2. Public Meetings/Hearings & Events ...................................................................... 7
2.3. Printed Materials ................................................................................................... 8
2.4. Website (www.springfield-or.gov) .......................................................................... 8
2.5. Contracting/Purchasing ......................................................................................... 8
2.6. Staff Training ........................................................................................................ 9
3. City Facilities ADA Transition Plan ..............................................................................11
3.1. Public Buildings and Facilities ..............................................................................11
3.2. City Streets, Sidewalks, and Curbs ......................................................................13
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1. Introduction
1.1. ADA Background
In enacting the Americans with Disabilities Act of 1990 (ADA), Congress intended to
"provide a clear and comprehensive national mandate for the elimination of discrimination against individuals with disabilities.” The City of Springfield recognizes the importance of that
mandate, and continually strives to achieve equal access for all its programs, services,
activities, and facilities for persons with disabilities. The Americans with Disabilities Act Self-Evaluation and Transition Plan establishes the City’s ongoing commitment to that effort.
The Rehabilitation Act of 1973
Section 504 of the Rehabilitation Act makes it illegal for the federal government, federal contractors, and any entity receiving federal financial assistance to discriminate on the basis of
disability. Local governments that receive federal funds must ensure that persons with
disabilities have equal access to any programs, services, or activities receiving federal financial assistance. Covered entities also are required to ensure that their employment practices do not
discriminate on the basis of disability.
The Americans with Disabilities Act of 1990
Signed into law in 1990, the ADA builds upon the foundation laid by Section 504 of the
Rehabilitation Act. It uses as its model Section 504's definition of disability and then goes
further, covering all state and local governments. The ADA has five separate titles; Title I and II are applicable to the City of Springfield. Title I prohibits discriminatory employment practices by
public and private employers. Title II prohibits state and local governments from denying
persons with disabilities the equal opportunity to participate in their services, programs, or activities, either directly or indirectly through contractual arrangements.
1.2. ADA Coordinator
Title II of the ADA requires all state or local government entities with 50 or more employees to appoint a responsible person to coordinate the administrative requirements of
ADA compliance and to respond to complaints filed by the public.
The City of Springfield’s ADA Coordinator is responsible for coordinating with the City’s
efforts to comply with Title I and Title II of the ADA, and for investigating any complaints
regarding ADA violations.
ADA complaints, requests for accommodation, and other ADA-related correspondence can be directed to the City ADA Coordinator:
Tom Mugleston
City of Springfield 225 Fifth St
Springfield, OR 97477 Phone: 541 726 3724 Email: tmugleston@springfield-or.gov
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1.3. Requesting an Accommodation
Under Title II of the ADA, all state and local governments are required to take steps to ensure that their communications with people with disabilities are as effective as
communications with others. The City is required to make accommodations for persons with disabilities, except when providing an accommodation would fundamentally alter the nature of
the service or program in question or would result in an undue financial and administrative
burden.
To request an accommodation, a person with a disability or their representative must
submit a request for an accommodation. Other than a request for an interpreter for the hearing impaired at a public meeting, a request for an accommodation should be submitted at least 5
days prior to the date of the scheduled program, activity, or meeting for which the accommodation is requested to allow enough to time to fulfill the request. To arrange for services, contact the City Manager’s Office at 541-726-3700 or cmo@springfield-or.gov or the
city ADA Coordinator Tom Mugleston at 541 726-3724 or tmugleston@springfield-or.gov. The following are some of the accommodations that may be made available upon request.
Hearing Assistance/Sign Language Interpreters
If you need a sign language interpreter or captioning to attend a meeting or public
meeting, please contact the City Manager’s Office or the City ADA Coordinator (contact information provided above). For public meetings, an interpreter or open or real-time captioning
will be provided for the hearing impaired with 48 hours’ notice prior to the meeting. Assistive
listening systems are available for the hearing impaired in the Municipal Courtrooms and City Council Chambers.
Alternate Formats
Requests for City materials such as brochures, forms, newsletters, reports and plans to
be put in alternate formats such as Braille, large print, or electronic form can be made through
the ADA Coordinator or the applicable department. The City will respond to the request for an alternate format within 15 calendar days at no cost to the requestor. All requests for
accommodations will be kept on file for at least three years. If another type of accommodation is requested or if further assistance is needed, please
contact the ADA Coordinator (contact information can be found in section 1.2.).
1.4. Filing an ADA Complaint
To better serve the public, the City of Springfield has instituted a formal ADA complaint
procedure. The complaint procedure provides citizens with a means to file complaints alleging
discrimination on the basis of disability in the City’s provision of services, activities, programs, and benefits, or in the City’s employment practices and policies. A copy of the City’s ADA
Complaint Procedure is available at http://www.springfield-or.gov/accessibility.html.
Complaints should be in writing and should contain specific information about the
alleged discrimination including the name, address, and phone number of the complainant, as well as the location, date, and description of the alleged discrimination. Alternative means of
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filing complaints, such as personal interviews or a tape recording of the complaint, will be made available for persons with disabilities upon request.
The complaint should be submitted to the City by the complainant or their designee as
soon as possible but not later than 60 calendar days after the alleged discrimination occurred. The City has provided a complaint form, available at http://www.springfield-
or.gov/accessibility.html, to assist persons with filing complaints. All complaints should be submitted to the City ADA Coordinator.
The ADA Coordinator or another City representative will contact the complainant within 15 calendar days of receiving the complaint to schedule a meeting to discuss the complaint and possible resolutions. Within 15 calendar days of the meeting, the ADA Coordinator will respond
to the complaint in writing, and where appropriate and requested, in a format accessible to the complainant. The written response will explain the position of the City and offer suggestions for
substantive and feasible resolution of the complaint. If the complainant is not satisfied with the
City ADA Coordinator’s decision, the person may appeal the decision to the City Manager within 15 calendar days of the date of the decision.
The City’s formal complaint process is not exclusive. A person filing a complaint with the City may also file a complaint with other state or federal agencies or in court. Other agencies
may have different time limits for filing complaints. All ADA complaints received by the City,
responses by the City, and other records of resolution of the complaint shall be retained by the City of Springfield for a minimum period of 3 years from the date of the complaint.
1.5. Self-Evaluation and Transition Plan Process
Title II of the ADA requires public entities with more than 50 employees to conduct self-evaluations to review the accessibility of their programs, services, and activities. The ADA also
requires public entities with more than 50 employees to develop a Transition Plan that sets forth
the necessary steps for and program changes or structural changes to facilities that are needed to make programs accessible.
In July 1992, the City of Springfield published its first self-evaluations and Transition Plan, and published a Final Report in 1995 detailing the progress made up to that point. Since
1995, the original plan and self-evaluations have become outdated as technologies, ADA law, and City programs and facilities have evolved. This Americans with Disabilities Act Self-Evaluation and Transition Plan updates, revises, and replaces all other previously published
Transition Plan documents. Every City department that provides a service, program, or activity to the public has
completed a self-evaluation survey to identify any policies or practices that are inconsistent with the requirements of the ADA. The findings of the departmental self-evaluations and the
recommendations for making all City services, programs, and activities accessible can be found
in Section 2 of this plan. A copy of the City’s self-evaluation survey form can be found in the appendix to this plan.
The City is also systematically reviewed the accessibility of buildings and other public facilities owned or operated by the city. The Transition Plan detailing the City’s plan to remove
structural barriers to accessibility in its buildings and public facilities can be found in Section 3 of
this plan. In addition, the City has undertaken a major effort to evaluate the accessibility of city
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streets, sidewalks, and curbs. The steps that the City has taken or will take to evaluate accessibility and remove barriers on city streets, sidewalks, and curbs is also found in Section 3.
Going forward, the City will continue to periodically review the accessibility of its programs, activities, and services, by conducting departmental self-evaluations. Initially, The
Americans with Disabilities Act Self-Evaluation and Transition Plan will be reviewed 18 months after being posted on the City’s website and revised as needed. It will then be reviewed every 3 to 5 years thereafter and updated to track City’s progress in making the needed changes to the
accessibility of City services, programs, and activities and any structural changes to City facilities.
1.6. Public Outreach
As required by the ADA, this The Americans with Disabilities Act Self-Evaluation and
Transition Plan will remain posted on the City’s website for three years. Other ADA documents, including the City of Springfield’s American with Disabilities Notice and Nondiscrimination
Notice, are available on the City’s website at http://www.springfield-or.gov/accessibility.html. Alternate forms of these documents will be made available for persons with disabilities as requested.
An initial draft of this The Americans with Disabilities Act Self-Evaluation and Transition Plan was published by the City to provide an opportunity for public review and comment by
interested persons, including those with disabilities or organizations representing individuals with disabilities. The City’s self-evaluation and input received during the public comment period
will be retained as required by law.
The City’s primary goals for conducting public outreach on the draft Self-Evaluation and
Transition plan are to meet the requirement for public comment opportunity, to inform the public
about the City’s plan and processes regarding removal of barriers to accessibility within the City of Springfield, and to obtain public comment to identify gaps in the proposed plan, including but
not limited to the City’s priorities for accessibility upgrades and the ADA grievance process. The
following is an overview of the City’s public outreach program for the initial draft of this Self-Evaluation and Transition Plan:
Following a work session with the Springfield City Council, an initial draft of this The
Americans with Disabilities Act Self-Evaluation and Transition Plan was published for public review on the City’s website on June 12, 2017.
The City provided a 30-day public comment period from July 21 through August 21, 2017. Public comment was received by the City in writing through August 21.
Comments received during this time will be retained by the City as required by law.
The City of Springfield hosted four Open House events on August 14 and August 16, with the goal of best engaging the public, gathering public comment and address questions.
The draft Self-Evaluation and Transition Plan was made available in alternate formats,
including Braille and large print, upon request.
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After consideration of the public comments received, City staff has revised the draft
Transition Plan as appropriate to address public comment received. City Council will
formally adopt the final Transition Plan in Fall 2017.
2. Self-Evaluation of City Services, Programs, and Activities
2.1. Customer Service (walk-in, telephone & letters/emails)
The City has done an excellent job addressing physical accessibility problems at its
facilities identified in previous transition plans through renovation of existing facilities and
relocation of key departments and services to compliant buildings. In addition, the City has fully embraced and encouraged use of electronic communications tools, like the Internet and email,
to interact with and provide information to its customers. The following non-structural changes to City programs, services, and facilities will be implemented within the next calendar year:
Provide at least one TTY text telephone per City facility.
Publicize the City TTY number in all email signature blocks, letterhead, phone books or Web pages that include the City’s main information telephone number (541-________).
For departments that use automated phone menu systems on their main, public line (i.e.
press 1 for…), ensure there is an easy one-step way to bypass the message and reach
a live person during regular business hours. If lack of staffing makes this impossible, ensure there are other ways for people to reach your staff (e.g. email addresses posted
on your Department’s Web page, allow in-person drop-in visits, etc.).
Publicize the state Relay service number used by the City (711) in all email signature
blocks, letterhead, phone books or Web pages that include an individual employee or department’s regular voice telephone numbers.
Ensure that pathways are clear of protruding or hanging objects and barriers such as
tables, chairs, coat racks, easels, signs, equipment or boxes. Ensure that clear pathway
is at least 36 inches wide.
Ensure that all permanent directional and room identification signage use large fonts, high contrast colors, non-reflective materials, raised lettering and Braille translations
where appropriate, and are clear of visual or physical obstructions.
Install signage at any non-accessible entrance to a public facility with directions to the
nearest accessible entrance.
Include the following information beneath the signature line of every letter or email sent to a member of the public:
To request other formats, please contact [department or division name here].
Voice: 541-____________ / TTY: _____________ / Relay: 711 Email: ______________@springfield-or.gov
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Alternately, when the City’s TTY and Relay numbers are already included elsewhere within the letter or email, the following tag line may be added:
Please contact me to request this document or its attachments in another format, such as Braille, audio recordings or text-only documents.
Whenever possible, ensure that documents sent to a customer as an attachment to an
email are in an accessible format (i.e. a PDF that was created using Adobe Acrobat, NOT a document that was scanned electronically and converted to PDF or TIF).
Post a notice of program and service accessibility flyer in the lobby or public reception area of each department or facility clearly stating the City’s intent to provide equal
access to all services, programs and activities. A copy of the Notice is already posted to
the City’s website and available at http://www.springfield-or.gov/accessibility.html.
2.2. Public Meetings/Hearings & Events
The City works hard to ensure its public meetings, hearings and events are open and
accessible to all citizens, regardless of disability. In addition, the City works directly with community event organizers to help ensure events using City streets, parks or other resources
are compliant with the ADA. The following recommendations will be implemented within the
next calendar year:
Provide accommodations to people with disabilities as requested at all public meetings, hearings or other public events. This includes but is not limited to providing American
Sign Language interpreters, open or real-time captioning, additional wheelchair seating
and additional disabled parking spaces close to the entrance(s). Instructions about how to accommodate these requests should be provided to all employees, with reminders
sent out at least annually.
Clear doorways and primary paths of travel at a meeting or event location of obstructions
or barriers, such as signs, boxes, chairs and electrical cords. Accessible pathways should be at least 36” wide.
Locate and inventory all assistive listening devices/FM transmitters and create a system
for making them available to all departments (e.g. Outlook calendar checkout system), and include step-by-step operating instructions for use with each device. Verify that devices are operational once per year or in advance of any requested use, and
replace/repair devices promptly.
Include the following statement (or similar statement) at the end of any email, news release, advertisement, or mailed invitation regarding City-sponsored meetings or events:
To request a reasonable accommodation at this (meeting/event), please contact [name of event contract, phone #, TTY # - if any, Relay: 711,
Email: ____@springfield-or.gov] by [date that is 5 business days before the
event].
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2.3. Printed Materials
The City produces a variety of informational and promotional materials for public use, including maps, brochures, forms, newsletters, fact sheets, reports, plans and the Senior
Messenger newspaper. The following recommendations will be made as new publications are printed, beginning within the next calendar year:
Provide documents and other printed materials in alternate formats, as requested, in
all departments. This includes Braille, audio recordings, enlarged print and digital
formats at no charge to the individual making the request. Instructions about how to provide these alternate formats should be provided to all employees, with reminders
sent out once a year.
Include the following information (or similar) on all printed materials provided to the
public, including brochures, fact sheets, handouts, flyers, maps, plans, forms, reports and newsletters:
To request other formats, please contact [department or division name here].
Voice: ___________ / TTY: ________ (if any) / Relay: 711 Email: ___________@springfield-or.gov
If a document will be used for longer than one year without updates, select a generic customer service telephone number and email address for your department.
2.4. Website (www.springfield-or.gov)
The City of Springfield is on track to complete a comprehensive redesign of its website in 2017. The new website will include a variety of accessibility-related improvements, including
text size and color, providing alternate text on photos and other graphics consistently, and
providing accessible PDF documents. The following recommendations will be implemented in the new website within the next calendar year:
Ensure that all fillable electronic forms are accessible by computer screen reading
software for those with sight limitations. The Webmaster may want to purchase
screen reading software like that used by people with such disabilities, to test the accessibility of certain key Web pages, forms and documents.
Post links to PDF documents only if they were created using Adobe Acrobat from the
original, editable document.
TIF or JPG formats for documents with text will not be used unless another link to an
accessible PDF or text-only document is provided along with it.
A document scanner will not be used to create a PDF or TIF on any web page unless a text version of the document is also provided.
2.5. Contracting/Purchasing
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The City currently uses criteria that do not discriminate based on disability when selecting contractors, consultants or vendors for City projects or services. However, federal
regulations also require that any outside contractors receiving City funding, or receiving federal
funding through the City, comply with the requirements and regulations of Title II of the ADA and Section 504 of the Rehabilitation Act.
Within the next calendar year, the City will revise its Request for Proposals, contracts, and other bid solicitation documents or Web pages to include a statement explaining that all
businesses, organizations or individuals contracting with the City of Springfield must comply applicable provisions of the Americans with Disabilities Act, 42 USC Section 12101 et seq, and Section 504 of the Rehabilitation Act of 1973. The City will also provide contractors and
potential contractors with links to other resources about the ADA and Section 504.
2.6. Staff Training
A key deficiency revealed by the self-evaluation survey conducted in early 2014 was the
need for regular and recurring employee training about a variety of subjects related to the requirements and regulations of the ADA. This information can be provided to employees through written procedures and other self-directed training tools (e.g. PowerPoint presentations,
videos, etc.), through online training courses or through formal classroom training. The Northwest ADA Center is a great resource for ADA training (www.dbtacnorthwest.org). Training on the following topics will be provided within the next calendar year:
Locating and using TTY text telephones and the State of Oregon third-party Relay
telephone system (placing and receiving calls);
Responding to requests for materials in alternate formats, including accessing Braille printers, getting audio recordings, providing enlarged text, etc.;
Responding to requests for accommodations at public meetings and events, including getting a sign language interpreter, securing additional disabled parking
spots, etc.;
Providing accessible Web content (alternate text, fonts, PDFs);
Working with disabled members of the public (culture and etiquette);
Accommodating individuals with service animals;
General information about the ADA and Section 504 of the Rehabilitation Act of 1973
and their legal requirements as it pertains to the City; and
General information regarding how the ADA and Section 504 are different from Section VI of the Civil Rights Act of 1964.
In addition to providing this information to all existing employees and new hires, the City will provide all employees with annual reminders about the ADA requirements with links to
instructional information. Any changes to the law affecting the City will be monitored and shared with employees as appropriate. This continuing education effort should occur in coordination
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with the annual updates that will be made to The Americans with Disabilities Act Self-Evaluation and Transition Plan.
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3. City Facilities ADA Transition Plan
3.1. Public Buildings and Facilities
The City of Springfield owns and either operates or leases several buildings, facilities,
and parking lots. Some of these properties are not open for public use or do not house public services, programs, or activities that are covered under Title II of the ADA, but many do. The
City of Springfield does not own or operate any parks, community centers, or other recreational
properties because the community is served by Willamalane Parks and Recreation District, which has recently undertaken its own ADA Self-Evaluation.
Since the ADA regulations took effect in 1992, the City has conducted numerous site visits, surveys and inventories of its facilities. The City’s public facilities are extensively ADA
compliant and Staff now focuses its efforts on repairing, renovating and eliminating many of the identified barriers and deficiencies with each project we are budgeted to undertake. The City prioritizes its ADA facility improvements based on how much public use the facility receives and
the types of services it houses. The City is committed to bringing all its facilities in full compliance with the ADA as soon as possible, subject to available funding and other resources.
City Public Facilities
City facilities that offer programs, services, or activities that are covered under Title II of
the ADA as of 2016 are as follows:
City Hall
Springfield Justice Center
Springfield Operations and Maintenance Building
Fire Stations 3, 4, 5, 14 and 16
Carter Building
Springfield Museum
The following list is of facilities that the City owns and leases to other entities, in which
the City does not presently provide any services, programs, or activities:
Booth Kelly
Springfield Depot
138 Main Street, Springfield
Priorities for Accessibility Upgrades
The City’s highest priority is to make its facilities accessibility where specific requests or
complaints identify the need to make accessibility changes. When structural changes must be
made, absent specific requests or complaints, the City prioritizes upgrades to City-owned facilities per the following list, starting with the highest priority:
City Hall, including the Springfield Public Library
Springfield Justice Center
Springfield Operations and Maintenance Building
Fire Stations 3, 4, 5, 14 and 16
Carter Building
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The following is a list of recent changes made to City buildings or other public facilities as part of a continuous effort to upgrade accessibility:
The City installed or updated accessible parking spaces and/or accessible routes at City Hall, Justice Center and Carter Building.
The City installed automatic door operators at entrances accessible to City Hall
elevators.
The City is working on a way-finding and signage project for City Hall that will
provide directional signage and identification signage. We have installed hanging directional signage to date.
The City replaced door knobs on publicly accessible spaces in City Hall to meet
current ADA standards. Temporary accessibility devises will be used upon
request or until it is feasible to fully replace non-compliant door knob.
The City Library, which is located within City Hall, installed ADA Compliant self-checkout stations at the Library. This update also included adding an automatic
door operator at the main Library entrance.
The City renovated the fountain plaza and stairs. The plaza remains ADA
compliant and is now free from large cracks and heaved areas that previously reduced accessibility.
A new employee health clinic has been constructed in City Hall that provides
better services and greater accessibility to employee health benefits. It was
constructed to current ADA standards.
The following is a list of identified changes that should be accomplished to make City
buildings or other public facilities fully accessible under the ADA:
Installing compliant directional and identification signs for all publicly accessible spaces.
The City will incrementally replace all door knobs in City facilities to meet current
ADA standards. Replacement will be prioritized based on frequency of public
use and based upon the receipt of requests for accommodation.
The City of Springfield will evaluate how to provide emergency power to City Hall elevators to provide access should the building operate during a power outage.
Older non-compliant meeting room furniture should be modified or replaced to
allow better accessibility.
City Hall restrooms need the following upgrades for full accessibility; o Sinks and/or counters adjusted to proper mounting heights. o Urinals adjusted to proper mounting heights.
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Two of the three elevators cars at City Hall have car dimensions that do not meet
current standards.
3.2. City Streets, Sidewalks, and Curbs
In 2002, the United States Court of Appeals for the Ninth Circuit, whose jurisdiction includes Oregon, held that city sidewalks and curbs are subject to the ADA's program
accessibility regulations. Barden v. City of Sacramento, 292 F.3d 1073 (9th Cir. 2002). The City of Springfield has over 300 miles of public streets and more than 2100 intersections to maintain.
It has been a priority for the City to improve accessibility for pedestrians and persons with
disabilities through the expansion of an accessible sidewalk network.
The ADA requires that persons with disabilities have equal access to City services,
including sidewalks. Curb ramps allow access to sidewalks and street crossings available to all persons and are required for all streets with sidewalks. Ramps are not required for streets
which do not have sidewalks. Other sidewalk repairs and maintenance are generally
considered to be the responsibility of the property owner. The City collects complaints about sidewalk uplifts and other barriers and notifies property owners of their responsibility to make
the needed repairs. Staff often follow up personally with affected property owners to secure the needed repairs.
Projects needed to bring City sidewalks, curbs, and curb ramps up to present ADA standards are identified in the City’s Capital Improvement Plan when known. The City presently
lacks sufficient funds to complete all identified accessibility projects within the next year, as
explained below. The City is committed to continuing to seek additional sources of funding to accomplish the structural changes required under this plan.
The City has already implemented the following programs, policies, and funding mechanisms to address accessibility needs, including the following:
All new transportation capital projects include pedestrian access and meet current
ADA standards and guidelines.
Funding is provided in all pavement management overlay projects for building
missing or repairing existing ADA curb ramps and sidewalks.
All new developments and site expansions are required to include ADA facilities.
The City continues to seek funding sources for completing projects identified in the system inventory and to address specific citizen requests.
Priority Service Areas
Title II of the ADA requires Transition Plans must “[give] priority to walkways serving entities covered by the Act, including State and local government offices and facilities,
transportation, places of public accommodation, and employers, followed by walkways serving other areas.” To maximize the public benefit of the City’s available funding for ADA upgrades, the City has identified Priority Service Areas for ADA improvements. Priority Service Areas are identified based upon the following characteristics:
Intersections within 1 4 mile of schools;
Intersections within 1 4 mile of public buildings;
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Intersections within 1 4 mile of hospitals;
Intersections within 1 8 mile of transit stops; and
Intersections within 1 4 mile of parks.
System Inventory
In 2013, City staff conducted a preliminary scoping study to provide a preliminary analysis of the City’s need for ADA improvements by providing the City with an estimate of the number of intersections lacking curb ramps. The scoping study used existing data from the City’s GIS program and a public works database system, the Hansen System. Neither the GIS program nor the Hansen System were designed to capture the specific information needed to
fully assess ADA compliance, such as existing noncompliant curb ramps and mid-sidewalk accessibility barriers. The GIS program identified streets in the city limits that have sidewalks.
For those streets with sidewalks, the Hansen system identified street segments that are lacking curb ramps. The results of the 2013 scoping study are provided in Table 1.
Table 1: Results of 2013 Scoping Study
Total Maintained Street Segments 2155
Intersections with ADA Ramps 1360
Intersections without ADA Ramps 795
Percent of Intersections Served 63%? 55%
Intersections in Priority Service Areas without ADA Ramps 355
Percent in Priority Service Areas without ADA Ramps 16%
The City will conduct an assessment survey of sidewalks and curb ramps for all streets within the City limits and develop an ADA inventory. The inventory will include a database and
mapping tool to develop a project needs list and project prioritization. Priority Service Areas are
tentatively scheduled for assessment in FY 2018 with the remainder of the locations planned for FY 19-20.
The City lacks funding to make all needed ADA upgrades to City sidewalks and curbs
within the next year. Funding programmed toward Transportation and Street preservation and rehabilitation continue to be at a level well below the documented $5 million annual need and
reflects a continued increase in the City’s backlog of necessary transportation system repairs.
While the FY17 budget indicates an increase in programmed funding for Transportation and Street related projects, the increase is driven by phase 1 of the Franklin Boulevard Project.
As part of this Transition Plan, all budgeted preservation and reconstruction projects will update ADA facilities within the project area. The proposed FY17 Capital Budget plans funding for two preservation projects (Virginia/Daisy and S. 42nd Street/Jasper Roundabout) utilizing
Surface Transportation Program-Urban Funding (STP-U) and dedicated reserves. In addition, as part of the FY 2015 CIP update, ADA Transition Plan projects were identified as a priority
with a funding request of $55,000 annually. Funding was identified and programmed in FY 2015
and FY 2016; however, this program is currently unfunded in FY 2017 and beyond.
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City of Springfield
Americans with Disabilities Act Self-Evaluation and Transition Plan
*DRAFT* May 22, 2017
This Transition Plan was read and edited (using JAWS accessible software) by
Eugene Organ, Coordinator, Oregon ADA Center, Lane Independent Living
Alliance (LILA). Gene is a Certified ADA Master Trainer through Cornell University.
If you have any questions, please contact Dawn Helwig, ADA Program
Manager (541-607-7020 extn 8 or dhelwig@lilaoregon.org
Suggested changes are in red.
Suggested omissions are crossed-out.
Notations and questions are italicized.
Contents
1. Introduction
1.1. ADA Background
1.2. ADA Coordinator
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1.3. Requesting an Accommodation
1.4. Filing an ADA Complaint
1.5. Self-Evaluation and Transition Plan Process
1.6. Public Outreach
2. Self-Evaluation of City Services, Programs, and Activities
2.1. Customer Service (walk-in, telephone & letters/emails)
2.2. Public Meetings/Hearings & Events
2.3. Printed Materials
2.4. Website (www.springfield-or.gov)
2.5. Contracting/Purchasing
2.6. Staff Training
3. City Facilities ADA Transition Plan
3.1. Public Buildings and Facilities
3.2. City Streets, Sidewalks, and Curbs
1. Introduction
1.1. ADA Background
In enacting the Americans with Disabilities Act of 1990 (ADA), Congress intended to
"provide a clear and comprehensive national mandate for the elimination of discrimination
against individuals with disabilities.” The City of Springfield recognizes the importance of that
mandate, and continually strives to achieve equal access for all its programs, services, activities,
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and facilities for persons with disabilities. The Americans with Disabilities Act Self-Evaluation
and Transition Plan establishes the City’s ongoing commitment to that effort.
The Rehabilitation Act of 1973
Section 504 of the Rehabilitation Act makes it illegal for the federal government, federal contractors, and any entity receiving federal financial assistance to discriminate on the basis of
disability. Local governments that receive federal funds must ensure that persons with
disabilities have equal access to any programs, services, or activities receiving federal financial
assistance. Covered entities also are required to ensure that their employment practices do not
discriminate on the basis of disability.
The Americans with Disabilities Act of 1990
Signed into law by President George H. W. Bush Congress in 1990, the ADA builds upon
the foundation laid by Section 504 of the Rehabilitation Act. It uses as its model Section 504's
definition of disability and then goes further, covering all state and local governments. The
ADA has five separate titles; Title I requires nondiscriminatory practices in employment and Title II is the section specifically applicable to “public entities” (state and local governments) and the programs, services, and activities they deliver. Title II prohibits state and local
governments from denying persons with disabilities the equal opportunity to participate in its
services, programs, or activities, either directly or indirectly through contractual arrangements.
1.2. ADA Coordinator
Title II of the ADA requires all state or local government
entities with 50 or more employees to appoint a responsible
person to coordinate the administrative requirements of ADA
compliance and to respond to complaints filed by the public.
The City of Springfield’s ADA Coordinator is responsible for
coordinating the efforts of the government entity to comply with
Titles I and II and investigating any complaints that the entity
has violated the ADA Title II.
Note: The reference to Pres. Bush is merely an historical
correction. The addition of Title I requirements is necessary
because Springfield has more than 50 employees and must
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adhere to employment regulations, as well as Title II program
requirements.
ADA complaints, requests for accommodation, and other ADA-
related correspondence can be directed to the City ADA
Coordinator:
Tom Mugleston
City of Springfield
225 Fifth St
Springfield, OR 97477
Phone: 541 726 3724
Email: tmugleston@springfield-or.gov
1.3. Requesting an Accommodation
Under Title II of the ADA, all state and local governments are
required to take steps to ensure that their communications with
people with disabilities are as effective as communications with
others. The City is required to make accommodations for
persons with disabilities, except when providing an
accommodation would fundamentally alter the nature of the
service or program in question or would result in an undue
financial and administrative burden.
To request an accommodation, a person with a disability or
their representative must submit a request for an
accommodation. Other than a request for an interpreter for the
hearing impaired at a public meeting, a request for an
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accommodation should be submitted at least 5 days prior to the
date of the scheduled program, activity, or meeting for which the
accommodation is requested to allow enough to time to fulfill
the request. To arrange for services, contact the City Manager’s
Office at 541-726-3700 or cmo@springfield-or.gov or the city
ADA Coordinator Tom Mugleston at 541 726-3724
or tmugleston@springfield-or.gov. The following are some of
the accommodations that may be made available upon
request.
Hearing Assistance/Sign Language Interpreters
If you need a sign language interpreter to attend a meeting or
public meeting, please contact the City Manager’s Office or the
City ADA Coordinator (contact information provided above).
For public meetings, an interpreter will be provided for the
hearing impaired with 48 hours’ notice prior to the
meeting. Assistive listening systems are available for the
hearing impaired in the Municipal Courtrooms and City Council
Chambers
Open captioning as an accommodation for persons with hearing
impairments is available with the 48 hours’ notice.
Alternate Formats
Requests for city materials such as brochures, forms,
newsletters, reports and plans to be put in alternate formats such
as Braille, large print or in electronic form can be made through
the ADA Coordinator or the applicable department. The City
will respond to the request for an alternate format within 15
calendar days at no cost to the requestor. All requests for
accommodations will be kept on file for at least three years.
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Note: 15 day notice seems excessive. It requires persons with
disabilities to be aware of reports or plans to be presented at a
meeting more than 2 weeks prior to the meeting.
If another type of accommodation is requested or if further
assistance is needed, please contact the ADA Coordinator
(contact information can be found in section 1.2.).
1.4. Filing an ADA Complaint
To better serve the public, the City of Springfield has instituted a
formal ADA complaint procedure. The complaint procedure
provides citizens with a means to file complaints alleging
discrimination on the basis of disability in the City’s provision
of services, activities, programs, and benefits, or in the City’s
employment practices and policies. A copy of the City’s ADA
Complaint Procedure is available at http://www.springfield-
or.gov/accessibility.html.
Complaints should be in writing and should contain specific
information about the alleged discrimination including the name,
address, and phone number of the complainant, as well as the
location, date, and description of the alleged
discrimination. Alternative means of filing complaints, such as
personal interviews or a tape recording of the complaint, will be
made available for persons with disabilities upon request.
The complaint should be submitted to the City by the
complainant or their designee as soon as possible but not later
than 60 calendar days after the alleged discrimination
occurred. The City has provided a complaint form, available
at http://www.springfield-or.gov/accessibility.html, to assist
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persons with filing complaints. All complaints should be
submitted to the City ADA Coordinator.
The ADA Coordinator or another City representative will
contact the complainant within 15 calendar days of receiving the
complaint to schedule a meeting to discuss the complaint and
possible resolutions. Within 15 calendar days of the meeting,
the ADA Coordinator will respond to the complaint in writing,
and where appropriate and requested, in a format accessible to
the complainant. The written response will explain the position
of the City and offer suggestions for substantive and feasible
resolution of the complaint. If the complainant is not satisfied
with the City ADA Coordinator’s decision, the person may
appeal the decision to the City Manager within 15 calendar days
of the date of the decision.
The City’s formal complaint process is not exclusive. A person
filing a complaint with the City may also file a complaint with
other state or federal agencies or in court. Other agencies may
have different time limits for filing complaints. All ADA
complaints received by the City, responses by the City, and
other records of resolution of the complaint shall be retained by
the City of Springfield for a minimum period of 3 years from the
date of the complaint.
1.5. Self-Evaluation and Transition Plan Process
Title II of the ADA requires public entities with more than 50
employees to conduct self-evaluations to review the accessibility
of their programs, services, and activities. The ADA also
requires public entities with more than 50 employees to develop
a Transition Plan that sets forth the necessary steps for and
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program changes or structural changes to facilities that are
needed to make programs accessible.
In July 1992, the City of Springfield published its first self-
evaluations and Transition Plan, and published a Final Report in
1995 detailing the progress made up to that point. Since 1995,
the original plan and self-evaluations have become outdated as
technologies, ADA regulations law, and City programs and
facilities have evolved. This Americans with Disabilities Act
Self-Evaluation and Transition Plan updates, revises, and
replaces all other previously published Transition Plan
documents.
Every City department that provides a service, program, or
activity to the public has completed a self-evaluation survey to
identify any policies or practices that are inconsistent with the
requirements of the ADA. The findings of the departmental
self-evaluations and the recommendations for making all City
services, programs, and activities accessible can be found in
Section 2 of this plan. A copy of the City’s self-evaluation
survey form can be found in the appendix to this plan.
The City is also systematically reviewed the accessibility of
buildings and other public facilities owned or operated by the
city. The Transition Plan detailing the City’s plan to remove
barriers to accessibility in its buildings and public facilities can
be found in Section 3 of this plan. In addition, the City has
undertaken a major effort to evaluate the accessibility of city
streets, sidewalks, and curbs. The steps that the City has taken
or will take to evaluate accessibility and remove barriers on city
streets, sidewalks, and curbs is also found in Section 3.
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Going forward, the City will continue to periodically review the
accessibility of its programs, activities, and services, by
conducting departmental self-evaluations. Initially, The
Americans with Disabilities Act Self-Evaluation and Transition
Plan will be reviewed 18 months after being posted on the
City’s website and revised as needed. It will then be reviewed
every 3 to 5 years thereafter and updated to track City’s progress
in making the needed changes to the accessibility of City
services, programs, and activities and any structural changes to
City facilities.
Note: Bravo
1.6. Public Outreach
As required by the ADA, The Americans with Disabilities Act
Self-Evaluation and Transition Plan will remain posted on the
City’s website for public comment for three years. Other ADA
documents, including the City of Springfield’s American with
Disabilities Notice and Nondiscrimination Notice, are available
on the City’s website at http://www.springfield-
or.gov/accessibility.html. Alternate forms of these documents
will be made available for persons with disabilities as requested.
Note: Again bravo
An opportunity for public review and comment on the transition
plan will be made available to interested persons, including
those with disabilities or organizations representing individuals
with disabilities. The City’s self-evaluation and input received
during the public comment period will be retained as required by
law.
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Primary goals for the public outreach
a. Meet the requirement for public comment
opportunity
b. Inform the public about the City’s plan and
processes regarding removal of barriers to
accessibility within the City of Springfield.
c. Obtain public comment to identify gaps in the
proposed accessibility transition plan, including but
not limited to prioritization and grievance
processes.
a. A 30-day plan review comment period will be provided prior
to the final plan preparation for adoption.
b. The City of Springfield will inform the public about
the availability of the draft Transition Plan by the use of:
a. Local newspaper (Register Guard),
b. City of Springfield sponsored Facebook/social
media accounts
c. Copies of the Plan will be made available upon
request.
d. A draft of the plan will be available online
at http://www.ci.springfield.or.us/accessibility.html
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c. The City of Springfield will host two Open House
events during the public comment period with the goal of
best engaging the public, gathering public comment and
address questions.
d. Public comment will be received by the City of
Springfield in writing during an open house event or at
City Hall during regular business hours. Comments may
be submitted via email; also a written log of comments
addressed over the phone will be kept. Phone comments
may be made by contacting the ADA Coordinator Tom
Mugleston at 541-726-3724.
e. After consideration of public comments received, City
staff will review and revise the draft Transition Plan as
appropriate to address any unresolved comments. City
Council will formally adopt the final Transition Plan in
Fall 2017.
2. Self-Evaluation of City Services,
Programs, and Activities
2.1. Customer Service (walk-in, telephone &
letters/emails)
The City has done an excellent job addressing physical accessibility problems at its facilities
identified in previous transition plans through renovation of existing facilities and relocation of
key departments and services to compliant buildings. In addition, the City has fully embraced
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and encouraged use of electronic communications tools, like the Internet and email, to interact
with and provide information to its customers. The following recommendations will be
implemented within the next calendar year:
Provide at least one TTY text telephone for each city facility.
Publicize the City TTY number in all email signature blocks,
letterhead, phone books or Web pages that include the City’s
main information telephone number (541-________).
For departments that use automated phone menu systems on
their main, public line (i.e. press 1 for…), ensure there is an easy
one-step way to bypass the message and reach a live person
during regular business hours. If lack of staffing makes this
impossible, ensure there are other ways for people to reach your
staff (e.g. email addresses posted on your Department’s Web
page, allow in-person drop-in visits, etc.).
Publicize the state Relay service number used by the City
(711) in all email signature blocks, letterhead, phone books or
Web pages that include an individual employee or department’s
regular voice telephone numbers.
Ensure that pathways are clear of temporary or permanent
barriers such as tables, chairs, coat racks, easels, signs,
equipment or boxes.
Ensure that all pathways are sufficiently wide (at least 36
inches) and are free of hanging or protruding objects.
Ensure that all permanent directional and room identification
signage use large fonts, high contrast colors, non-reflective
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materials, raised lettering and Braille translations where
appropriate, and are clear of visual or physical obstructions.
Install signage at any non-accessible entrance to a public
facility with directions to the nearest accessible entrance.
Include the following information beneath the signature line
of every letter or email sent to a customer:
To request other formats, please contact [your
department or division name here].
Voice: 541-____________ / TTY: _____________ /
Relay: 711
Email: ______________@springfield-or.gov
Or, you can include the above contact information in
your signature line and simply add this (or similar)
sentence to your email or letter:
Please contact me to request this document or its
attachments in another format, such as Braille, audio
recordings or text-only documents.
Whenever possible, ensure that documents sent to a customer
as an attachment to an email are in an accessible format (i.e. a
PDF that was created using Adobe Acrobat, NOT a document
that was scanned electronically and converted to PDF or TIF).
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Post a notice of program and service accessibility flyer in the
lobby or public reception area of each department or facility
clearly stating the City’s intent to provide equal access to all
services, programs and activities. A copy of the Notice is
already posted to the City’s website and available
at http://www.springfield-or.gov/accessibility.html.
2.2. Public Meetings/Hearings & Events
The City works hard to ensure its public meetings, hearings and events are open and accessible to all citizens, regardless of disability. In addition, the City works directly with community event
organizers to help ensure events using City streets, parks or other resources are compliant with
the ADA. The following recommendations will be implemented within the next calendar year:
Provide accommodations to people with disabilities as
requested at all public meetings, hearings or other public
events. This includes providing American Sign Language
interpreters, providing open captioning, providing additional
wheelchair seating and providing additional disabled parking
spaces close to the entrance(s). Instructions about how to
accommodate these requests should be provided to all
employees, with reminders sent out once a year.
Clear doorways and primary paths of travel at a meeting or
event location of obstructions or barriers, such as signs, boxes,
chairs and electrical cords. Ensure that pathways are at least 36
inches wide with a 60 inch passing lane periodically along the
route.
Locate and inventory all assistive listening devices/FM
transmitters and create a system for making them available to all
departments (e.g. Outlook calendar checkout system), and
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include step-by-step operating instructions for use with each
device. Verify that devices are operational once per year or in
advance of any requested use, and replace/repair devices
promptly.
Include the following statement (or similar statement) at the
end of any email, news release, advertisement or mailed
invitation sent out about a City-sponsored meeting or event:
To request a reasonable accommodation at this
(meeting/event), please contact [name of event
contract, phone #, TTY # - if any, Relay: 711,
Email: ____@springfield-or.gov] by [insert date that
is 5 business days before the event].
Note: Again, Lane Independent Living Alliance personnel can
assist, including surveys of event locales and working with the
planning process.
2.3. Printed Materials
The City produces a variety of informational and promotional materials for public use, including
maps, brochures, forms, newsletters, fact sheets, reports, plans and the Senior Messenger newspaper. The following recommendations will be made as new publications are printed, beginning within the next calendar year:
Provide documents and other printed materials in
alternate formats, as requested, in all departments. This
includes Braille, audio recordings, enlarged print and
digital formats at no charge to the individual making the
request. Instructions about how to provide these
alternate formats should be provided to all employees,
with reminders sent out once a year.
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Include the following information (or similar) on all
printed materials provided to the public, including
brochures, fact sheets, handouts, flyers, maps, plans,
forms, reports and newsletters:
To request other formats, please contact [your department or division name here].
Voice: ___________ / TTY: ________ (if any) / Relay: 711
Email: ___________@springfield-or.gov
If a document will be used for longer than one year without updates, select a generic customer service telephone number and email address for your department.
2.4. Website (www.springfield-or.gov)
The City of Springfield is on track to complete a comprehensive redesign of its website in
2017. The new website will include a variety of accessibility-related improvements, including text size and color, providing alternate text on photos and other graphics consistently, and
providing accessible PDF documents. The following recommendations will be implemented in
the new website within the next calendar year:
Ensure that all fillable electronic forms are accessible
by computer screen reading software for those with sight
limitations. The Webmaster may want to purchase
screen reading software like that used by people with
such disabilities, to test the accessibility of certain key
Web pages, forms and documents.
Note: I would suggest Jaws as one of those screen-
reading programs frequently used by persons with
vision impairments.
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Post links to PDF documents only if they were
created using Adobe Acrobat from the original, editable
document.
o TIF or JPG formats for documents with text will
not be used unless another link to an accessible PDF
or text-only document is provided along with it.
o A document scanner to create a PDF or TIF
will be not be used on any web page unless a text
version of the document is also provided.
2.5. Contracting/Purchasing
The City currently uses criteria that do not discriminate based on disability when selecting contractors, consultants or vendors for City projects or services. However, federal regulations
also require that any outside contractors receiving City funding, or receiving federal funding
through the City, comply with the requirements and regulations of Titles I and II of the ADA and
Section 504 of the Rehabilitation Act. The following recommendations will be implemented
within the next calendar year:
Include a statement in all Request for Proposals,
contracts or other bid solicitation documents or Web
pages explaining that businesses, organizations or
individuals contracting with the City of Springfield must
comply with Title I of the ADA (if applicable), Title
II of the ADA and Section 504 of the Rehabilitation Act
of 1973, and provide links to Web sites or other
resources about the ADA and Section 504.
Note: The State of Oregon requires that any entity which
employs 6 or more persons must adhere to accessibility
requirements in its employment practices. This is more
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stringent than the ADA which requires employers of 50 or
more persons to do so.
2.6. Staff Training
A key deficiency revealed by the self-evaluation survey conducted in early 2014 was the need for regular and recurring employee training about a variety of subjects related to the requirements and regulations of the ADA. This information can be provided to employees
through written procedures and other self-directed training tools (e.g. PowerPoint presentations,
videos, etc.), through online training courses or through formal classroom training. The
Northwest ADA Center is a great resource for ADA training (www.dbtacnorthwest.org). The following training will be provided within the next calendar year:
Location and use of TTY text telephones (placing and
receiving calls)
Use of State of Oregon third-party Relay telephone
system (placing and receiving calls)
Responding to requests for materials in alternate
formats, including accessing Braille printers, getting
audio recordings, providing enlarged text, etc.
Responding to requests for accommodations at public
meetings and events, including getting a sign language
interpreter, securing additional disabled parking spots,
etc.
Providing accessible Web content (alternate text,
fonts, PDFs)
General information about working with disabled
customers (culture and etiquette)
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General information about the ADA and its legal
requirements as it pertains to the City
General information about Section 504 of the
Rehabilitation Act of 1973 and its legal requirements
How both the ADA and Section 504 are different
from Section VI of the Civil Rights Act of 1964
Note: I am shocked that the Oregon ADA Center at Lane
Independent Living Alliance was not used as a potential
training provider. Obtaining the training and information
from a local provider seems cost effective and prudent.
In addition to providing this information to all existing employees and new hires, the City will
provide all employees with annual reminders about the ADA requirements with links to
instructional information. Any changes to the regulations law affecting the City should also be monitored and shared with employees as appropriate. This continuing education effort should occur in coordination with the annual updates that will be made to The Americans with
Disabilities Act Self-Evaluation and Transition Plan.
Note: Again the folks at the Oregon ADA Center at Lane
Independent Living Alliance are resources for such information.
3. City Facilities ADA Transition Plan
3.1. Public Buildings and Facilities
The City of Springfield owns and either operates or leases several buildings, facilities, and
parking lots. Some of these properties are not open for public use or do not house public
services, programs, or activities that are covered under Title II of the ADA, but many do. The City of Springfield does not own or operate any parks, community centers, or other recreational
properties because the community is served by Willamalane Parks and Recreation District,
which has undertaken their own ADA Self-Evaluation during the past year.
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Since the ADA regulations were issued became law in 1992, the City has conducted numerous
site visits, surveys and inventories of its facilities. The City’s public facilities are extensively
ADA compliant and Staff now focuses its efforts on repairing, renovating and eliminating many of the identified barriers and deficiencies with each project we are budgeted to undertake. The City prioritizes its ADA facility improvements based on how much public use the facility
receives and the types of services it houses. The City is committed to bringing all its facilities in
full compliance with the ADA as soon as possible, subject to available funding and other
resources.
City Public Facilities
City facilities that offer programs, services, or activities that are covered under Title II of the
ADA as of 2016 are as follows:
City Hall
Springfield Justice Center
Springfield Operations and Maintenance Building
Fire Stations 3, 4, 5, 14 and 16
Carter Building
The following list is of facilities that the City owns and leases to other entities, in which the City
does not presently provide any services, programs, or activities:
Springfield Museum
Booth Kelly
Springfield Depot
138 Main Street, Springfield
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Note: It would be wise to ensure that leases are meeting
ADA regulations in the programs housed in city-owned
properties. For example, a structural issue may well be
regarded by the Courts as a financial problem for both the City, as the building owner, and the lease, as the program
administrator.
Priorities for Accessibility Upgrades
The City’s highest priority is to make its facilities accessibility where specific requests or
complaints identify the need to make accessibility changes. When structural changes must be
made, absent specific requests or complaints, the City prioritizes upgrades to City-owned
facilities per the following list, starting with the highest priority:
City Hall, including the Springfield Public Library
Springfield Justice Center
Springfield Operations and Maintenance Building
Fire Stations 3, 4, 5, 14 and 16
Carter Building (areas that have employee access
for Health Clinic)
The following is a list of example changes made to City buildings or other public
facilities in our continued effort to upgrade accessibility:
The City installed or updated accessible parking
spaces and/or accessible routes at City Hall, Justice
Center and Carter Building.
Note: Were parking spaces in compliance with Oregon
State law which is more stringent than the ADA?
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At entrances accessible to City Hall elevators the
City installed automatic door operators.
The City is working on a way-finding and signage
project for City Hall that will provide directional
signage and identification signage. We have installed
hanging directional signage to date
The City replaced door knobs on publicly
accessible spaces in City Hall to meet current ADA
standards. Temporary accessibility devises will be
used upon request or until as identified until it is
feasible to fully replace non-compliant door knob.
The City Library, which is located within City
Hall, recently installed ADA Compliant self-checkout
stations at the Library. This update also included
adding an automatic door operator at the main Library
entrance.
The City recently made renovations to the fountain
plaza and stairs. The plaza remains ADA compliant
and is now free from large cracks and heaved areas
that previously reduced accessibility.
A new employee health clinic is being constructed
in City Hall to provide better services and greater
accessibility to employee health benefits. It is being
constructed to current ADA standards.
The following is a list of identified changes that should be accomplished to make City
buildings or other public facilities fully accessible under the ADA:
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Installing compliant directional and identification
signs for all publicly accessible spaces.
The City will incrementally replace all door knobs
in City facilities to meet current ADA
standards. Replacement will be prioritized based on
frequency of public use and based upon the receipt of
requests for accommodation.
The City of Springfield will evaluate how to
provide emergency power to City Hall elevators to
provide access should the building operate during a
power outage.
Older non-compliant meeting room furniture
should be modified or replaced to allow better
accessibility.
City Hall restrooms need the following upgrades
for full accessibility;
o Sinks and/or counters adjusted to proper
mounting heights.
o Urinals adjusted to proper mounting heights.
Two of the three elevators cars at City Hall have
car dimensions that do not meet current standards.
3.2. City Streets, Sidewalks, and Curbs
The City of Springfield has over 300 miles of public streets and more than 2100
intersections to maintain. In 2002, the United States Court of Appeals for the Ninth Circuit, whose jurisdiction includes Oregon, held that city sidewalks are subject to the ADA's program
accessibility regulations. Barden v. City of Sacramento, 292 F.3d 1073 (9th Cir. 2002). It has
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been a priority for the City to improve accessibility for pedestrians and persons with disabilities
through the expansion of an accessible sidewalk network.
The ADA requires that persons with disabilities have equal access to City services, including sidewalks. Curb ramps allow access to sidewalks and street crossings available to all
persons and are required for all streets with sidewalks. Ramps are not required for streets which
do not have sidewalks. Other sidewalk repairs and maintenance are generally considered to be
the responsibility of the property owner. The city collects complaints about sidewalk uplifts and
other barriers and notifies property owners of their responsibility to make the needed repairs. Staff often follows up personally with affected property owners to secure the needed
repairs.
Projects needed to bring City sidewalks, curbs, and curb ramps up to present ADA standards are identified in the City’s Capital Improvement Plan when known. The City presently lacks sufficient funds to complete all identified accessibility projects within the next year, as
explained below. The City is committed to continuing to seek additional sources of funding to
accomplish the structural changes required under this plan.
The City has already implemented the following programs, policies, and funding mechanisms to address accessibility needs, including the following:
All new transportation capital projects include
pedestrian access and meet current ADA standards and
guidelines.
Funding is provided in all pavement management
overlay projects for building missing or repairing
existing ADA sidewalk ramps and sidewalks.
All new developments and site expansions are
required to include ADA facilities.
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Identify funding sources for completing projects
identified in the system inventory and to address specific
citizen requests.
Note: The Oregon Department of Transportation is currently
under a Settlement Agreement emanating from a lawsuit.
Under the agreement, ODOT will build or repair curb ramps at intersections with State highways. Thus, any intersection
with a State highway within the city of Springfield is eligible
for ODOT construction or repair.
Priority Service Areas
Title II of the ADA requires Transition Plans must “[give] priority to walkways serving
entities covered by the Act, including State and local government offices and facilities, transportation, places of public accommodation, and employers, followed by walkways serving other areas.” To maximize the public benefit of the City’s available funding for ADA
upgrades, the City has identified Priority Service Areas for ADA improvements. Priority Service Areas are identified based upon the following characteristics:
Intersections within mile of schools;
Intersections within mile of public buildings;
Intersections within mile of hospitals;
Intersections within mile of parks; and
Intersections within mile of transit stops.
Note: Personally, I think the intersections within a mile of transit
stops should receive greater consideration than the list above provides.
System Inventory
In 2013, City staff conducted a preliminary scoping study to provide a preliminary analysis of the City’s need for ADA improvements by providing the City with an estimate of the number of intersections lacking curb ramps. The scoping study used existing data from the City’s GIS
program and a public works database system, the Hansen System. Neither the GIS program nor the Hansen System were designed to capture the specific information needed to fully assess ADA compliance, such as existing noncompliant curb ramps and mid-sidewalk accessibility
barriers. The GIS program identified streets in the city limits that have sidewalks. For those
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streets with sidewalks, the Hansen system identified street segments that are lacking curb ramps. The results of the 2013 study are provided in Table 1.
Table 1: Results of 2013 Scoping Stu dy
Total Maintained Street Segments 2155
Intersections with ADA Ramps 1360
Intersections without ADA Ramps 795
Percent of Intersections Served 63%? 55%
Intersections in Priority Service Areas without ADA Ramps 355
Percent in Priority Service Areas without ADA Ramps 16%
The City will conduct an assessment survey of sidewalks and curb ramps for all streets
within the City limits and develop an ADA inventory. The inventory will include a database and
mapping tool to develop a project needs list and project prioritization. Priority Service Areas are
tentatively scheduled for assessment in FY 2018 with the remainder of the locations planned for
FY 19-20.
The City lacks funding to make all needed ADA upgrades to City sidewalks and curbs
within the next year. Funding programmed toward Transportation and Street preservation and
rehabilitation continue to be at a level well below the documented $5 million annual need and
reflects a continued increase in the City’s backlog of necessary transportation system repairs.
While the FY17 budget indicates an increase in programmed funding for Transportation and Street related projects, the increase is driven by phase 1 of the Franklin Boulevard Project.
As part of the transition plan, all budgeted preservation and reconstruction projects will
update ADA facilities within the project area. The proposed FY17 Capital Budget plans funding
for two preservation projects (Virginia/Daisy and S. 42nd Street/Jasper Roundabout) utilizing Surface Transportation Program-Urban Funding (STP-U) and dedicated reserves. In addition, as part of the FY 2015 CIP update, ADA Transition Plan projects were identified as a priority with
a funding request of $55,000 annually. Funding was identified and programmed in FY 2015 and
FY 2016; however, this program is currently unfunded in FY 2017 and beyond.
-- Note: Lane Independent Living Alliance staff can provide a review of
ADA projects, surveys of outdoor and indoor spaces for ADA
compliance and training on a variety of subjects related to serving
persons with disabilities and the ADA and its requirements. I urge the
city of Springfield to contract with a local provider for those services.
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Dawn Helwig
Community Outreach Coordinator
Lane Independent Living Alliance
Oregon ADA Center Office#: 541-607-7020 ext. 8
dhelwig@lilaoregon.org