Americans with Disabilities Act

Policy and Procedure Modifications - Report City of Clarksville January 31, 2005

The City of Clarksville has completed a self-evaluation for compliance with the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act of 1973 (Section 504). Areas addressed in the self-evaluation were the following:

-Review of Policies, Practices and
-Communication Assessment
-Architectural Survey Reports
-Curb Ramps and Sidewalk Assessments

The results of the self-evaluation are summarized in this report as follows.

Policies, Practices and Procedures Review>

-An ADA Compliance Team was established with a representative from all of the major departments as well as an ADA Title II Compliance Coordinator.

-The ADA Compliance Team reviewed programs for compliance through a survey of each department. While all departments were found not to intentionally discriminate when conducting programs, it was evident that procedures to accommodate people with disabilities needed to be formalized. The following policies and practices were developed to achieve this goal:

-Future publications of the City of Clarksville will include the symbol of accessibility and contact information for questions or request for accommodations regarding that program.

-A formal Request for Accommodations procedure was developed and made available on the City of Clarksville's website. This procedure will assist in making reasonable modifications to programs so that they are accessible by everyone.

-A formal Grievance Procedure was developed and adopted by the City Council with forms made available on the City of Clarksville's website. This procedure will give citizens recourse if their request for accommodations was not resolved to their satisfaction.

-Training sessions are planned within each department City wide in order to educate employees on how to receive requests and to make the appropriate modifications to programs and services. This procedure establishes necessary lead times for requests and requires them to be made in writing on standard forms for clarity and documentation. Requests for auxiliary aids and services to ensure effective communications are to be processed in accordance with the Effective Communications Policy that the City adopted.

Communication Assessment

-An Effective Communication Policy was drafted and distributed to all City employees through paychecks on March 31, 2004 and was added to the City Employee Handbook and City Policy Manual.

-An Effective Communications Policy dealing with Police Situations involving people who are deaf or hard of hearing was drafted and added to the Officer Training Manual on March 29, 2004.

-The ADA Title II Compliance Team reviewed programs for communication compliance through a survey of each department. Departments were surveyed to find out what information is available visually and verbally. It was determined that publications can readily be made available in the following formats: large print, Braille, audio tape, readers, verbal descriptions, computer diskette and pictorial signage where applicable. As a result of the communication review the following steps have been taken:

-The City has contacted the League for the Deaf and Hard of Hearing and has established an account for interpreting qualified services. The City of Clarksville will provide this service when needed to ensure effective communication in all City programs. The police department has separate agreements for interpreting services because they can have situations needing immediate service.

-The City has contacted the Center for Independent Living of Middle Tennessee and has established an account for Braille printing services as needed to ensure effective communication.

-The City is researching which City Departments need a TTY and the feasibility of providing closed captioning of City Council broadcasts. Any decision will be included in the City's ADA Transition Plan.

Architectural Survey Report

-The City's Architectural Surveys were performed by City employees and the City's ADA Consultant. Seventy-one (71) City facilities were surveyed using a checklist developed by the ADA Consultant. The checklist addresses areas of compliance and non-compliance with ADAAG in the areas of parking, exterior path of travel, entrances, interior path of travel, restrooms, showers, service counters, meeting rooms, playgrounds and swimming pools. Most facilities were found to have some areas of noncompliance although varying in degree of severity and number of areas. A summary of each survey has been prepared and the summaries and checklists will be used by the City and ADA Advisory panel to determine program accessibility and prioritize modifications.

-Standard language is being developed for contracts and RFP's that requires designers and contractors doing work for the City to ensure that the work will be done in compliance with the ADA. Plans review and site inspections for ADA compliance will be prepared before the City will accept the facility.

Curb Ramps and Sidewalks Assessment

-A survey of all curb ramps and sidewalks was conducted by the Street Department Construction Inspectors and mapped by the GIS Coordinator. Intersections without curb ramps, curb ramps without landings and obstructions in the sidewalks were the most common barriers.

-A Sidewalk Committee was formed to develop an ordinance on sidewalk standards for the City. Included in the new ordinance is that all newly constructed sidewalks must comply with the local regulations or ADA guidelines-the more stringent of the two prevailing.

-Standard drawings for curb ramps and driveway ramps are being developed that require landing for curb ramps and compliant cross slopes in driveway ramps. The standard drawings will comply with the ADA and will be the basis for accepting or rejecting work in the right-of-way.

Summary

The City of Clarksville will continue its efforts to come into compliance with the Americans with Disabilities Act and Section 504 and will have a transition plan in place by June of 2005. The ADA Advisory Panel will help the City develop this plan by assisting in prioritizing work to be done in the future.