SR-106-040 (2)
F/hsd/share/Cmsns-Adv Bds/DCAC/SR/staff report - DCAC recs to CC.doc
Council Meeting: April 9, 2002 Santa Monica, California
TO: Mayor and City Council
FROM: City Staff
SUBJECT: Recommendation to Receive the “Santa Monica Disability Community
Accessibility Committee Report,” and Direct Staff to Develop an Ordinance
Forming a Disabilities Commission
INTRODUCTION:
This report transmits the findings and recommendations of the City Council- appointed
Disability Community Accessibility Committee (DCAC) (Attachment I) and staff’s
recommendations and actions in response. In its report, the DCAC prioritizes issues
facing the disability community in Santa Monica, recommends changes to the City’s
Americans with Disabilities Act (ADA) compliance self evaluation process, and also
recommends the establishment of a Disabilities Commission to serve as a year-round
advisory body to the City Council.
BACKGROUND
One of the administrative requirements of the ADA is to write a Transition Plan, which is
an assessment of the accessibility of each City facility and program and the plan to
bring the facilities into compliance. A Self-Evaluation focuses on programmatic rather
than physical issues. The ADA also requires that public input be obtained and used in
the crafting of the Transition Plan and Self-Evaluation, which was originally
accomplished by the use of a subcommittee of the Social Services Commission and a
community roundtable discussion.
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The City of Santa Monica updated and used both the Transition Plan and ADA Self-
Evaluation until this year, when staff determined that an annual ADA compliance review
would be preferable as both documents have by now been re-written several times.
Confusion over which barriers (i.e. physical or programmatic) are addressed by each
effort can be resolved in this manner. Updates to the Transition Plan and the ADA Self-
Evaluation have, therefore, been combined into the City of Santa Monica ADA
Compliance Review and Update (Attachment II), a review of compliance activities and a
plan to address remaining physical or programmatic barriers to access. A similar
update will be accomplished annually.
On September 11, 2001, the City Council appointed eleven members of the public
representing a diverse cross-section of the disability community to serve on the DCAC,
including persons with disabilities, caregivers, family members and professionals in
disability services. They are:
Martha Alfaro Christofer Arroyo Elizabeth Bancroft
Michael Barrett* Elizabeth Bogen Samuel Genensky
Mary Ann Glicksman J. D. Harber Julie Klein
Christopher Knauf Kecia Weller
*resigned January 3, 2002
The City Council directed that the DCAC: 1) review a draft of the City’s ADA Transition
Plan annual update (now known as the ADA Compliance Review and Update) and
provide input on priorities and implementation plans; 2) discuss disability-related issues
in Santa Monica and identify possible courses of action to facilitate involvement of
persons with disabilities in Civic life; 3) take and analyze comments at a public hearing
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on disability issues; 4) make a report to the City Council outlining its findings annually in
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January so as to be timely for consideration in the City’s budget process; and 5) make
recommendations on the DCAC’s schedule for re-constitution and length of member
appointments.
The DCAC held thirteen meetings from October 4, 2001, to January 31, 2002, and held
a “Town Hall” meeting on December 5, 2001. There were numerous subcommittee
meetings as well. A draft of the ADA Compliance Update was distributed to the public
at the “Town Hall” meeting, and reviewed by the DCAC in December, 2001. DCAC
members were committed to involving community members while crafting a set of
recommendations to the City Council. The meetings were attended, on average, by
seven members of the public. On January 31, 2002, the DCAC approved the final
content and form of the report to Council (Santa Monica Disability Community
Accessibility Committee Report, Attachment I).
DISCUSSION
The final DCAC report contains five key recommendations. The first is that the City
make changes to the process by which the ADA Transition Plan is evaluated annually
and to the City’s ADA grievance process. City staff has identified and begun instituting
necessary changes to both the ADA grievance process and ADA compliance evaluation
process that the DCAC recommends.
The second key recommendation is the City complete a full physical accessibility survey
of all facilities and maintain a record of all repairs, improvements and other changes to
facilities that impact accessibility. The Maintenance Management Division of the
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Environmental and Public Works Management Department has planned and budgeted
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for a survey of all facilities for FY 02-03, and a component of it will identify ADA physical
compliance issues. The specific components of the ADA survey will be based on a
checklist developed by a consultant who will use priorities set forth by the DCAC in its
Final Report.
The DCAC report also recommends the City institute mandatory staff training on
disability awareness and ADA compliance and improve the accessibility of
communication between the City and the public. Training for City staff in disability
awareness and sensitivity is planned to begin in mid-2002, and will include many of
topics suggested by the DCAC, including an emphasis on communicating effectively
with people with various disabilities. Employees with extensive public responsibility will
be trained first. Staff will determine the feasibility of implementing mandatory training
for all City employees.
The DCAC further recommends the City improve outreach on disability issues to private
entities. Potential strategies for outreach to and education of private entities (e.g.
businesses and landlords) will be evaluated. Given staff and financial resources, this is
a longer-term effort that will require regular reassessment.
Lastly, the DCAC report recommends the City Council establish a standing Santa
Monica Disabilities Commission rather than re-convening the DCAC annually. The
report also details the DCAC’s recommendations for the roles of a commission, which
include:
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Advising City Council and staff on disability issues in Santa Monica;
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Advising City Council and staff on policies related to State and Federal laws
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ensuring the protection of the rights of people with disabilities;
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Providing input on the City’s ADA Compliance Update; and
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Acting as a forum for community input on disability issues.
Further detailed recommendations are included in their report.
A Standing Commission
The Social Services Commission and the Commission on Older Americans have
addressed issues related to the disability community within their broader missions.
Creating a standing commission for the disability community would allow for specific
focus and is one commission model that Santa Monica has used to ensure that the
needs of a specific group are addressed. This model provides an opportunity for
interested community members to focus on specific issues and to advise the City
Council, guided by a clear and targeted mission. The disadvantage of this model is
that, due to its traditional format and relatively narrow focus, it may omit possibilities for
collaboration with groups with related missions and issues. The City has yet to conduct
a comprehensive assessment as to the future direction of its advisory group structure.
Absent this assessment and given the level of commitment and success of the current
DCAC, City Staff recommends that the City Council direct the formation of a Disabilities
Commission, rather than re-convening the DCAC annually. Staff also recommends
that, in the longer term, the City conduct a comprehensive evaluation to determine
which advisory models provide the best balance between representing issues in a larger
context while still addressing targeted populations or needs.
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Taking into account both the historic function and structure of commissions in Santa
Monica and recommendations made by the DCAC, staff recommends, in addition to the
duties and responsibilities outlined by the DCAC, that the new commission:
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Include up to nine members;
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Provide suggestions and comments on the annual ADA compliance review to
staff;
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Hold a public hearing on disability issues annually in October to coincide with
Disability Awareness Month;
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Identify and advise staff and the City Council of the highest priority issues of
significance to the disability community annually;
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Suggest a commission work plan annually based on the priority issues to be
considered in depth that year; and
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Make a report annually to the City Council on the status of disability issues in
Santa Monica, including the selected top priorities, for timely consideration in the
budget process.
The Sr. Administrative Analyst for ADA/Disability and Senior Services and a Staff
Assistant III in the Human Services Division will provide staff support for monthly
commission meetings, and occasional committee meetings. Addressing issues
impacting the disability community will also require the active engagement of all City
departments.
All DCAC recommendations, and the City’s implementation strategies, are detailed in
Attachment II- City of Santa Monica ADA Compliance Review and Update, pp. 9-14.
FINANCIAL/BUDGET IMPACT
Acceptance of the report of the DCAC and creation of a standing commission will have
no immediate financial impact. Funds for all projects identified by staff in response to
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DCAC recommendations are included in the FY 01-02 Budget, and the Commission
would be supported by existing staff.
RECOMMENDATIONS
It is recommended that Council receive the attached “Santa Monica Disability
Community Accessibility Committee Report” and direct the City Attorney to develop an
ordinance for the creation of a Disabilities Commission with the general role and
responsibilities outlined above.
Prepared by: Barbara Stinchfield, Director, Community and Cultural Services
Julie Rusk, Manager, Human Services Division
Tracy Scruggs, Supervisor, Human Services Division
Susan Lai, Sr. Administrative Analyst, Human Services Division
Janet Hand, Sr. Administrative Analyst, Human Services Division
Attachments:
I. Santa Monica Disability Community Accessibility Committee Report
II. City of Santa Monica ADA Compliance Review and Update
ATTACHMENT I
SANTA MONICA
DISABILITY
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Formatted
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COMMUNITY
ACCESSIBILITY
COMMITTEE
RF2002
EPORT EBRUARY
TC
ABLE OF ONTENTS
I. BACKGROUND p. 1
II. EXECUTIVE SUMMARY p. 3
III. REPORT OF TOWN HALL MEETING p. 6
IV. RECOMMENDATIONS p. 7
1. Improve Physical Accessibility of City Facilities p. 7
2. Improve the City’s Interaction and Communication with
People with Disabilities p. 9
3. p. 15
Improve Outreach to and Education of Businesses and Landlords
4. Establish a Year-Round Disability Advisory Body p. 16
V. CONCLUSION p. 18
VI. APPENDICES
A. Self Evaluation Survey Recommendations p. 20
B. People First Language p. 22
C. Plain English p. 23
D. Congressional Findings in Enacting the ADA p. 24
E. Glossary of Terms p. 26
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I. BACKGROUND
Up to 20% of the population, or more than 54 million people in the United
States, live with cognitive, physical, and/or mental disabilities. This
percentage increases with age. However, the number of people directly
affected by disability - family, friends, caregivers, employers, co-workers,
students, landlords, business owners, government officials, et al - makes
this an issue that affects everybody.
An Historically Marginalized Community
In passing the Americans with Disabilities Act in 1990, Congress found:
“Census data, national polls, and other studies have documented that
people with disabilities, as a group, occupy an inferior status in our society,
and are severely disadvantaged socially, vocationally, economically, and
educationally.” (Appendix D)
Congress further found that "individuals with disabilities continually
encounter various forms of discrimination, including outright intentional
exclusion, the discriminatory effects of architectural, transportation, and
communication barriers, overprotective rules and policies, [and] failure to
make modifications to existing facilities and practices….”
Fear and misperception about people with disabilities are widespread. They
are the result of the world we grew up in, and the stereotypes we have
been taught. People with disabilities are held back by both architectural
and attitudinal barriers. The ADA was passed to overcome these barriers
so that 20% of the population is able to live, work, play, go to school, and
participate in and contribute to the community along with their families and
friends.
Santa Monica Has Shown Leadership in Addressing Disability Rights
Santa Monica’s proactive stance on disability rights predates the ADA. In
1978, the City began requiring ramps for City owned buildings. It created
the Santa Monica Office on Disabilities in 1982, which has now evolved into
the ADA Coordinator. In 2000, City Council responded to disability
advocates by convening the Disability Task Force to recommend additional
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ways to improve the quality of life for people with disabilities in Santa
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Monica.
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In response to the report by the Disability Task Force, the City Council
constituted the Disability Community Accessibility Committee (DCAC) in
September 2001. Its time-limited assignment was to:
1. Discuss disability related issues in Santa Monica and identify possible
courses of action
2. Review the City’s ADA Transition Plan Annual Update and provide input
on priorities and implementation plans
3. Take and analyze comments at a Public Hearing
4. Make recommendations on the Committee’s schedule for
reconstitution, length of member appointments, and schedule and
format for future public hearings
5. Make a report to City Council on its findings so as to be
timely for consideration in the budget process.
About the DCAC and This Report
The DCAC began meeting in October 2001 and sub-committees were
established to accomplish the assigned goals. Between October 2001 and
January 2002 there were 14 open meetings and numerous sub-committee
meetings. Findings and recommendations in this report are based on the
diversity of committee members’ life experiences, public input, open
committee meetings, sub-committee meetings, a Town Hall Meeting, and
review of policies and documents of Santa Monica and other cities.
The DCAC chose to focus in those areas where the City Council can take
immediate actions to increase the participation of people with disabilities in
the community of Santa Monica. Not all issues that confront people with
disabilities are addressed in this report.
Below is an executive summary of the DCAC’s findings and
recommendations. We urge all Council members to read this report in its
entirety, in which we explain in greater detail the reasoning behind these
recommendations.
II. EXECUTIVE SUMMARY
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Improve Physical Accessibility of All City-Owned, Operated and
Leased Facilities
Physical accessibility is of primary importance. There are still significant
access barriers to people with physical disabilities throughout Santa
Monica, including a lack of curb cuts, parking, adaptive telecommunication
devices, and fully accessible bathrooms. The City Council should devote
as much of the capital budget as possible to complete the ADA mandated
accommodations in 3-5 years.
• Create and maintain a database of ADA compliance in all City facilities
so that future project upgrades may be prioritized and renovations
tracked.
• Create a database of assistive equipment (for example, wheelchair lifts
on buses, Telecommunication Devices for the Deaf [TDD - see
Appendix E - Glossary]. Ensure all assistive equipment is properly
maintained.
• Address the facilities in order of priority set by the staff and a disability
advisory body. Of particular urgency to the public are
- Curb cuts
- City Hall
- Parking structures
Improve the City’s Interaction and Communication with People with
Disabilities
Public servants, e.g. City staff and elected officials, must be well educated
about disabilities in order to ensure that City programs and services are
provided in a non-discriminatory manner. There is much to be learned
about the variety of people with disabilities and how to appropriately
communicate with and about them. Communication with the community
must be improved and the ADA Grievance Procedure strengthened.
• Improve staff training by ensuring that every City staff member and
public official participates in disability training:
- Provide basic education as well as ongoing periodic training;
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- Improve the feedback process and consider ideas from a
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disability advisory body;
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• Improve communication from City Hall to the general public via the
City website, printed materials, and other media;
• Improve the ADA Self-Evaluation Survey to ensure that staff take
various disabilities into account when providing programs and services
(see Appendix A for specific examples);
• Improve the ADA Grievance Procedure to help bring common and/or
repetitive problems to light.
Specific examples on how to improve each of the above points are given in
the main body of the report.
Improve Outreach to and Education of Businesses and Landlords
There is an enormous need for local businesses and landlords to improve
their awareness and responsiveness to the rights of people with disabilities.
The City of Santa Monica can continue its excellent track record of
addressing quality of life issues (i.e., living wage, alternative fuel vehicles)
by improving disability awareness in the private sector. The City should:
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Conduct periodic educational campaigns to inform businesses and
landlords (including healthcare facilities) of disability issues, rights, laws,
and forms of discrimination;
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Inform businesses regarding tax credits already offered by the Federal
and State government for ADA renovations;
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Increase grants to businesses and landlords to make accessibility
upgrades to properties;
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Improve/increase accessibility code enforcement;
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Continue to explore the issue of Visitability.
Establish a Year-Round Disability Advisory Body
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Because of all the complicated issues related to disability, it would benefit
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the City Council and City staff to have an advisory and educational year-
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round disability advisory body to ensure the participation of people with
disabilities in all aspects of civic life. It is essential to have citizen
involvement in prioritizing disability issues and providing input to improve
City programs and services. The advisory body must be year-round
because issues about people with disabilities are too complex and time
consuming to be addressed in a time-limited fashion each year.
A year-round disability advisory body can:
• Take input, deliberate, prioritize issues, develop strategies, and
formulate recommendations for City Council and staff;
• Provide yearly input into the ADA Transition Plan and ADA Self-
Evaluation survey; and
• Provide input into the different Santa Monica Commissions and
Committees as needed.
The year-round disability advisory body should be a Commission
because:
• By deliberating, developing strategies, and formulating
recommendations for City Council and staff, this body will act as a
Commission;
• There is overwhelming community support for a Commission as
evinced by more than 40 letters from elected officials, disability related
organizations, existing Santa Monica Commissions, and others;
• Peer municipalities such as Berkeley, Los Angeles, Pasadena, and
Long Beach have all recognized the value of having a year-round
Disability Commission.
While a Disability Commission is being considered, the City Council should
extend the tenure of the DCAC to (1) meet with the consultant who will be
hired in the Spring of 2002 to draft a new Transition Plan, and (2) to meet
with the consultant who is exploring Visitability in Santa Monica. Both of
these policies directly affect the lives of people with disabilities and need
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input from the disability community to make them thoughtful and
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comprehensive plans.
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III. REPORT OF TOWN HALL MEETING
On December 3, 2001 the Santa Monica DCAC held a town meeting at
Santa Monica Library to elicit input from the community.
While various issues were discussed, the top three issues raised by the
public that were applicable to Santa Monica were:
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that the City Council should create a Santa Monica Disability
Commission;
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improve the availability of accessible and affordable housing; and
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improve transportation (Big Blue Bus and Paratransit Services) in
terms of accessibility (ability to board the vehicle) and service (drivers
should offer to safely secure passengers and announce stops).
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IV.RECOMMENDATIONS
(This is an expanded version of the recommendations made in the
Executive Summary.)
Improve Physical Accessibility of All City-Owned,
1.
Operated and Leased Facilities/Recommendations for
the ADA Transition Plan
Physical accessibility of City owned, operated, and leased facilities is of
primary importance. Basic physical access is not only mandated by the
ADA and California law, but more importantly, promotes the inclusion of
people with various types of disabilities in City life. There are still
significant access barriers to people with physical disabilities throughout
Santa Monica, including a lack of curb cuts, parking, adaptive
telecommunication devices, and fully accessible bathrooms. Physical
access upgrades, which would promote the inclusion of people with
disabilities, were mandated by the ADA in 1992. The City Council should
devote as much of the capital budget as possible to complete the ADA
mandated accommodations in all City facilities in 3-5 years.
The ADA Transition Plan identifies physical barriers in the City’s facilities
that limit the accessibility of its programs and activities to people with
disabilities, describes in detail the methods used that will make those
facilities accessible, and specifies the schedule for taking the steps
necessary to make those facilities accessible. The Transition Plan was first
drafted in 1992 and the progress made towards completing the necessary
renovations was most recently reviewed in 1998. An ADA consultant is
scheduled to be hired in 2002 to write a new Transition Plan.
Recommendations for Improving the Transition Plan
1) Create and maintain a database of ADA compliance in all City facilities
so that future project upgrades may be prioritized and renovations tracked.
At this time the City does not have a comprehensive list of ADA compliance
in City facilities. All City owned, leased or operated properties should have
a thorough ADA compliance survey, even those not normally used by the
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public, so as to ensure that present and future City staff with disabilities are
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accommodated. The survey information will be used to develop a
centralized database which will track the ADA compliance status of each
facility, provide the data necessary to identify future work on the facilities,
and identify priorities for future accommodations and upgrades.
The City should continue monitoring any changes in the architectural
guidelines of the ADA and state law to ensure that all renovations are
consistent with the newest accessibility guidelines.
2) Create a database of assistive equipment. Ensure all assistive
equipment is properly maintained.
A centralized system for maintenance and repair should be developed
for assistive equipment or fixtures. For example, whenever such
equipment is damaged (i.e. a wheelchair lift on a bus, a TDD, a fully
accessible restroom) the damage and repair dates should be tracked.
Baseline data can then be gathered and benchmarks developed to
assure that assistive equipment is fixed in a timely manner.
3) A disability advisory body should be consulted during the formation of
updated and/or future Transition Plans.
Recommendations for Prioritizing Facilities to Upgrade
The City should first focus on upgrading all facilities that do not provide the
following basic physical access:
• Wheelchair accessible front entrances
• At least one fully accessible public restroom
• Where public telephones are provided, at least one phone must be
equipped with a TDD, be compatible with a hearing aid, and contain a
volume control
• Appropriate signage (including Braille and large print)
• In multi-story facilities: fully accessible elevators, at least one fully
accessible restroom, and one TDD per floor
• Conduct a survey to ensure that every corner in every business district
has a curb ramp.
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Beyond basic physical access, the DCAC was asked to prioritize various
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City facilities for ADA upgrade. Because the DCAC had very limited
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information regarding the upgrade status of the various facilities, the
following is a preliminary prioritization of facilities. Once additional
information comes to light, the City’s disability advisory body should be
permitted to revise this prioritization.
Prioritization of Upgrades
Highest Priority:
• City Hall, specifically elevator and restrooms
• Parking structures: improve van accessibility, specifically by increasing
the number of van accessible spaces and make them wider so ramps
may be deployed safely
• Senior centers
• Libraries
• Parks
• Meeting and conference spaces.
High Priority:
• Crosswalks: increase the number of accessible crosswalk buttons,
increase the number of flashing crosswalks, such as those on Pico,
and increase the length of time of crosswalk for pedestrians
• City offices (Fire and Police Departments, Housing Authority, etc.)
• Civic Auditorium
• Cemetery
• Animal shelter
• Airport.
2. Improve the City’s Interaction and Communication
with People with Disabilities
This section provides recommendations that the City may implement to
eliminate programmatic and attitudinal barriers for people with disabilities.
Historically, people with disabilities have been relegated to "second class"
citizenship because of widespread perception that they are physically or
mentally unable to take care of themselves, cannot live independently, and
are somehow less capable than "normal" people. It is the general public's
misperceptions and fears that limit the individual's opportunities to become
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educated, employed, and accepted socially. These misperceptions and
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fears are widespread.
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There are so many kinds of disabilities and different degrees of severity
within disabilities, that it is rare for a person to be aware of and sensitive to
all of them. There is much to be learned about the variety of people with
disabilities and how to appropriately communicate with and about them.
City staff and officials, as public servants, must be well educated about
disabilities. According to public testimony, the Disability Task Force, and
the experiences of DCAC members, City staff need ongoing and
comprehensive disability awareness, knowledge, and competency.
Fortunately, through the ADA Coordinator, the City is already providing
some staff education and intends to expand and improve the training
programs.
The City can and should improve its awareness of and responsiveness to
the rights of people with various kinds of disabilities. Recommendations for
improving interactions with people with disabilities are summarized below
and discussed in detail in this section.
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Improve interpersonal relations between City staff, officials, and
people with various kinds of disabilities through ongoing staff
education;
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Improve the accessibility of communication from City Hall to the
general public via the City website, printed materials, and other
media;
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Improve the Self-Evaluation Survey to ensure that staff take various
disabilities into account when providing programs and services; and
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Implement an effective, universal grievance procedure and review
process to help bring common and/or repetitive problems to light.
Improve Interpersonal Relations Between City Staff and Officials and
People with Disabilities Through Ongoing Staff Education.
As stated above, among the most important issues brought to the DCAC’s
attention is the issue of disability education of City staff and officials. In
keeping with the philosophy that education is a process and not an event, a
number of improvements should be added to the existing training program.
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These improvements will reassure community members that they will be
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provided satisfactory customer service and treated with dignity and respect.
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Staff will also increasingly feel comfortable in delivering services to people
with differing needs.
1) Ensure every City staff member and public official participates in training
at the time of hire/appointment/election and annually thereafter.
All City staff and officials should receive basic disability awareness,
knowledge, and competency training upon beginning their work or
service with the City. This will ensure basic knowledge at the outset so
that appropriate services to people with disabilities are provided.
Training should be annual because information is forgotten, skills need
to be polished, and disability issues are constantly evolving.
Particular emphasis must be placed on public officials and staff that
deal directly with members of the public. This education can and
should be tailored to the role of the staff member or official and the
manner in which they interact with the public.
Only certain departments have received training within the last several
years and elected and appointed officials have received little or no
training. It is essential in running public meetings, addressing
complaints, and providing services in general, that staff and officials
are responsive to the wide variety of people with disabilities.
Some specific examples of staff and officials to include:
• Big Blue Bus drivers
• Police officers
• Fire Department employees
• Members of the City Council, Boards, and Commissions
Examples of periodic training include:
• Conduct exercises to enhance understanding and awareness
• Educate staff on additional disabilities not covered in basic training
• Review and discuss recurring problems or complaints
2) Improve methods of obtaining feedback from trainings and provide the
feedback to a disability advisory body for review and recommendations.
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Effective feedback is essential for improvement, particularly in the case of staff training.
Feedback for existing training may be significantly improved and
participants could be given incentives to provide substantive feedback.
Upon obtaining the feedback, the ADA Coordinator should review the evaluations and
make them available to a disability advisory body that will make
recommendations.
Improve the Accessibility of Communication from City Hall to the General
Public Via the City Website, Printed Materials, and Other Media
1) The City should always use “People First” language (non-discriminatory,
inclusive language for people with disabilities; for example “person with
autism” instead of “an autistic”; see Appendix B) and simplified language
(Plain English; see Appendix C) that allows for people at many levels of
literacy or cognitive development to understand city business in order to
create the most effective communication and dissemination of knowledge
about the City to and about people with disabilities.
2) Adopt new technologies to communicate with people with disabilities by
improving the City website’s accessibility for people who are blind or have
visual difficulties and by creating a disability web page that includes (at a
minimum):
-information about the ADA coordinator
-employment opportunities with the city
-the ADA Transition Plan and Self-Evaluation Survey
-the Big Blue Bus and Paratransit services
-the ADA Grievance Procedure
-information about requesting disability accommodations at City
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sponsored programs and meetings
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-a feedback form that people can use to ask questions, make
suggestions
give compliments, or file a complaint.
3) Improve city procedures for providing auxiliary aids and services at
public events to ensure effective communication for people who are deaf or
hard of hearing.
4) Ensure that all city sponsored advertisements and notices about city
programs and meetings (Seascape, LA Times, etc.) include a statement
about how to ask for reasonable accommodations and the accessibility of
each program and meeting.
5) Improve and fully disseminate the City procedures for providing referrals
to people with disabilities who contact the city for services that the city
cannot provide.
6) Include questions regarding disabilities in the section of identifying
information in the yearly random-digit dialed survey of Santa Monica
residents, so data may be analyzed in terms of disability.
Improve the Self-Evaluation Survey to Ensure that Staff Take Various
Disabilities into Account When Providing Programs and Services
The ADA Self-Evaluation Survey is a periodically self-administered
questionnaire completed by all City departments to assess the accessibility
of City-sponsored programs to people with disabilities. Topics include, but
are not limited to, evaluation of policies and procedures, programmatic
access, communication access, staff training, employment, contracts, and
disaster planning.
1) Overall the current survey is a solid assessment tool but some questions
need to be modified and others need to be added to ensure that:
?
Staff have disability training that enables them to be comfortable and
competent in interacting with and providing services for people with
mental, cognitive and communication disabilities in addition to physical
disabilities;
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Staff know the procedures whereby residents can ask for reasonable
accommodations for service, programs, or meetings;
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All information that is regularly distributed by the city utilizes both
People First and simplified language; and
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Publicly offered communication equipment be accessible to people
who are deaf or hard of hearing.
(Specific questions are found in Appendix A.)
2) The City’s ADA Coordinator should meet each Department ADA Liaison
semiannually to support them in achieving their action items identified in
the Self-Evaluation Survey. Progress that each department makes toward
achieving their goals should be published annually.
Implementing an Effective and Universal Grievance Procedure to Help
Bring Common and/or Repetitive Problems to Light
The ADA requires that every city have a procedure to address grievances
associated with ADA mandates. While the City has a grievance procedure,
the DCAC learned that neither the community nor staff are adequately
informed about it. Community members who do know about it generally
believe it to be ineffectual. In order to remedy this:
1) Strengthen the ADA Grievance Procedure:
• Allow grievances to be filed in “a timely manner” rather than “10
days” as it is now specified to facilitate the City’s investigation of
grievances and to encourage reporting
• Include in the procedure:
-a statement that people have the right to advocacy assistance
and services
-that they be provided with a list of such referrals
-be provided assistance to better understand the process, if
requested as a reasonable accommodation.
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2) The grievance procedure should be widely disseminated:
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• Each City department should post visibly and have available in
alternative formats notification of the ADA Grievance Procedure
• The policy should be discussed and distributed during staff trainings
• There should be a public relations campaign to inform the public
about the ADA Grievance Procedure (using mailings, City website,
Seascape, etc.).
3) Each year the ADA Coordinator should provide a summary report to a
disability advisory body of ADA grievances filed, including the nature of the
complaints, the outcomes, and dates.
3. Improve Outreach to and Education of Businesses
and Landlords
There is an enormous need for local businesses and landlords to improve
their awareness and responsiveness to the rights of people with disabilities.
Many members of the community relayed to the DCAC their frustration in
not being able to shop, dine, go to the movies, find housing, etc. on an
equal basis because of discrimination.
The City of Santa Monica has an excellent track record of addressing
"quality of life" issues in the private sector (i.e., living wage, alternative fuel
vehicles). The City should undertake a campaign to educate private
businesses and landlords of the rights of people with disabilities and the
availability of grants to improve accessibility, so as to further improve
equality of opportunity and, therefore, the quality of life for people with
disabilities in Santa Monica.
?
Conduct periodic educational campaigns to inform businesses and
landlords (including healthcare facilities) of disability issues, rights,
laws, and forms of discrimination;
?
Inform businesses regarding tax credits already offered by the Federal
and State Government for ADA renovations;
?
Increase grants to businesses and landlords to make accessibility
upgrades to properties;
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Improve/increase accessibility code enforcement; and
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Continue to explore the issue of Visitability.
4. Establish a Year-Round Disability Advisory Body
Because of all the complicated issues related to disability, it would benefit
the City Council and City staff to have an advisory and educational year-
round disability advisory body to ensure the participation of people with
disabilities in all aspects of civic life. Citizen involvement in prioritizing
disability issues and ongoing input into City programs and services is
essential. Issues about disabilities are complex and changing; there are
even evolving social and legal definitions of “disability.” City Council and
staff should not be expected to maintain an expertise in these issues on
their own.
A year-round disability advisory body can:
• Take input, deliberate, prioritize issues, develop strategies, and
formulate recommendations for City Council and staff
• Advise on policies that to the mandates of federal and state laws
• Provide yearly input into the ADA Transition Plan and ADA Self-
Evaluation Survey
• Provide input to different commissions and committees including
Housing Commission, Architectural Review Board, Planning
Commission, Social Services Commission, Commission on Older
Americans, Recreation and Parks Commission, and the School District
when disability issues arise
• Be a forum for community input on disability issues, including holding
public meetings
• The disability advisory body should not be an advocacy group or be
involved in individual case management. Those functions are best left
to other groups, both in and out of city government.
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The disability advisory body needs to meet year-round because issues
about disabilities are too complex to be addressed in a time-limited manner
each year. For example, the DCAC met 14 times as an entire committee
from October 2001-January 2002 plus had numerous sub-committee
meetings to address the targeted issues City Council assigned to the
DCAC.
The year-round disability advisory body should be a Commission
because:
• By deliberating, developing strategies, and formulating
recommendations for City Council and staff, this body will act as a
Commission
• There is very strong community support for a Disability Commission, as
evinced by unanimous public comment in DCAC meetings, at the
Town Hall Meeting, the report of the Disability Task Force, the
Coalition for a Santa Monica Disability Commission and the more than
40 letters of support including from:
- -State Senator Sheila Kuehl,
Santa Monica Chamber of Commerce
-US Representative Henry Waxman -Numerous local political figures
-Commission on Older Americans -Santa Monica community groups
-Commission on the Status of Women -Santa Monica residents
-Social Services Commission
• Peer municipalities such as Berkeley, Los Angeles, Pasadena,
Burbank, and Long Beach have all recognized the value of having a
Disability Commission.
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The Disabilities Commission should be constituted in the manner
consistent with other City Commissions with the following exceptions:
• It should have between 9-11 members. The nature of the challenges
that face people with disabilities are so varied and there are so many
different disabilities (physical: mobility, hearing, sight; mental,
developmental, cognitive, chronic disease) and so many aspects of
being involved in the disability community (family; professional care
givers; professional advocates; medical, legal, and technical support)
that in order to be an educational resource for the City Council there
should be as broad a membership as possible without sacrificing
efficiency and the ability for consensus making.
• All members of the Disability Commission should have experience in
the disability community (including consumers, family, professional
care givers, professional advocates, etc.).
• Two-thirds of the Disability Commission should be people with
disabilities, taking care to be consistent with affirmative action and
federal privacy laws regarding disclosure of disability status.
While a Disability Commission is being considered, the City Council should
extend the tenure of the DCAC to (1) meet with the consultant who will be
hired in the spring of 2002 to draft a new Transition Plan, and (2) to meet
with the consultant who is exploring Visitability in Santa Monica. Both of
these policies directly affect the lives of people with disabilities and need
input from the disability community to make them thoughtful and
comprehensive plans.
V. CONCLUSION
Santa Monica is in a position to become a model of municipal accessibility
for children and adults who have disabilities. Our community has all the
elements present. In this new millennium City Council is providing
renewed, proactive leadership in access policy. City Human Services staff
and the ADA Coordinator are knowledgeable and dedicated to progress.
The citizens of Santa Monica are actively involved in promoting a city that
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embraces diversity and understands the barriers to inclusion and
participation of people with various disabilities.
Respectfully Submitted by the Members of the
Santa Monica Disability Community Accessibility Committee:
Martha Alfaro
Christofer Arroyo
Elizabeth Bancroft
Elizabeth Bogen
Samuel Genensky
Mary Ann Glicksman
J. D. Harber
Julie Janower Klein
Christopher Knauf
Kecia Weller
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Appendix A
Self-Evaluation Survey Recommendations
• Ensure the Survey utilizes “People First” language (see Appendix
B)
• Clarify and provide examples for Question #1
• Include question(s) about staff awareness of issues concerning
service animals
• Include question(s) regarding the training of staff concerning
communication with people who have no apparent disabilities or who
communicate differently (i.e., communication devices);
• In the Staff Training section, Question 4a asks if any ADA or
disability-related training occurred within the last four years. Change
this to asking for the date of the last training
• Include question(s) concerning the visibility of the posting of the
ADA Grievance Procedure to both employees and the public
• In the Communication Access section, include Federal Relay
Service number (711) and Speech-to-Speech in the questions as
appropriate
• In the Communication Access section, re-phrase question #4 (and
its sub-questions) to include, "If you provide a public phone, is it
equipped with a TTY/TDD machine?"
• In the Communication Access Section, include “If public phones are
available in your area, do they have volume controls and are hearing
aid compatible?” and other relevant questions
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ADDITIONAL QUESTIONS FOR THE ADA SELF-
EVALUATION SURVEY
• Do the most commonly requested documents/information use
“Plain English?”(See Appendix C)
• Do you have a maintenance log for assistive equipment and
facilities (TDD/TTY machines, wheelchair lifts, wheelchair bathrooms,
assistive listening devices) and how do you follow equipment
breakdowns and repair?
• How do you ensure that all announcements (in Seascape/LA
Times/on the Web) of programs sponsored by your office/department
have accessibility information in them?
How many announcements did you place in the past year?
How many included accessibility information?
•
Do you have written policy and procedures for obtaining assistive
equipment (ex: assisted listening devices) for programs and meetings
sponsored by your department/office?
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Appendix B
People First Language
Positive language empowers and gives respect. When writing or
speaking about people with disabilities, it is important to put the
person first. Group designations such as "the blind," "the deaf" or "the
disabled" are inappropriate because they do not reflect the
individuality, equality or dignity of people with disabilities. Following
are examples of positive and negative phrases. Note that the positive
phrases put the person first.
Affirmative phrases Negative phrases
person with a disability the disabled, handicapped
person who is blind, person who the blind
has vision loss
person with mental retardation retarded, mentally defective
person who is deaf, person who is suffers a hearing loss, the deaf
hard of hearing
person who has multiple sclerosis afflicted by MS
person with cerebral palsy CP victim
person who uses a wheelchair Wheel chair bound, confined or
restricted to a wheelchair
person without a disability normal person (implies that the
person with a disability isn't normal
person who no longer lives in an the deinstitutionalized
institution
person with psychiatric disability crazy, nuts
person with epilepsy, person with epileptic
seizure disorder
says she/he has a disability admits she has a disability
successful, productive has overcome his/her disability;
courageous
seizure fit
unable to speak, uses synthetic dumb, mute
speech
Accessible parking Handicapped parking
Source: President's Committee on Employment of People with Disabilities
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Appendix C
Plain English
The Plain English movement began in the United Kingdom, and is
used by governments and corporations throughout the world
including the United States. The following Australian government
Internet site provides the information in this appendix.
http://www.dest.gov.au/archive/publications/plain_en/
What is Plain English?
Plain English focuses on the message. It uses only as many words
as necessary and avoids jargon, unnecessary technical expressions
and complex language.
Plain English documents are always written for the people who will
be reading and using them, using words they will know. Even
complex concepts can be explained in plain English. Legal
documents, such as contracts and legislation, have been rewritten
in plain English and are still legally accurate.
The Reader Comes First
One of the most important principles of plain English is that
documents are developed and written from the reader's viewpoint.
This means that you may need to rethink the structure and purpose
of your documents. What does the reader need to know? How much
do they understand about the subject? What's the best way to
organize ideas so that they make sense to the reader? The test of
success is not just that a document reads well, but whether it
communicates to your reader.
Plain English is Everywhere
Plain English covers much more than "official" documents.
Organizations need to use plain English for all their communications
with stakeholders -- the public, other organizations, contractors and
their own staff.
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Appendix D
Congressional Findings – Americans with Disabilities Act
1990
§ 12101. Congressional findings and purposes
(a) Findings. The Congress finds that
—
(1)
some 43,000,000 Americans have one or more physical or mental
disabilities, and this number is increasing as the population as a
whole is growing older;
(2)
historically, society has tended to isolate and segregate
individuals with disabilities, and, despite some improvements, such
forms of discrimination against individuals with disabilities continue to
be a serious and pervasive social problem;
(3)
discrimination against individuals with disabilities persists in such
critical areas as employment, housing, public accommodations,
education, transportation, communication, recreation,
institutionalization, health services, voting, and access to public
services;
(4)
unlike individuals who have experienced discrimination on the
basis of race, color, sex, national origin, religion, or age, individuals
who have experienced discrimination on the basis of disability have
often had no legal recourse to redress such discrimination;
(5)
individuals with disabilities continually encounter various forms of
discrimination, including outright intentional exclusion, the
discriminatory effects of architectural, transportation, and
communication barriers, overprotective rules and policies, failure to
make modifications to existing facilities and practices, exclusionary
qualification standards and criteria, segregation, and relegation to
lesser services, programs, activities, benefits, jobs, or other
opportunities;
(6)
census data, national polls, and other studies have documented
that people with disabilities, as a group, occupy an inferior status in
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our society, and are severely disadvantaged socially, vocationally,
economically, and educationally;
(7)
individuals with disabilities are a discrete and insular minority who
have been faced with restrictions and limitations, subjected to a
history of purposeful unequal treatment, and relegated to a position of
political powerlessness in our society, based on characteristics that
are beyond the control of such individuals and resulting from
stereotypic assumptions not truly indicative of the individual ability of
such individuals to participate in, and contribute to, society;
(8)
the Nation's proper goals regarding individuals with disabilities are
to assure equality of opportunity, full participation, independent living,
and economic self-sufficiency for such individuals; and
(9)
the continuing existence of unfair and unnecessary discrimination
and prejudice denies people with disabilities the opportunity to
compete on an equal basis and to pursue those opportunities for
which our free society is justifiably famous, and costs the United
States billions of dollars in unnecessary expenses resulting from
dependency and nonproductivity.
(b) Purpose. It is the purpose of this Act—
(1)
to provide a clear and comprehensive national mandate for the
elimination of discrimination against individuals with disabilities;
(2)
to provide clear, strong, consistent, enforceable standards
addressing discrimination against individuals with disabilities;
(3)
to ensure that the Federal Government plays a central role in
enforcing the standards established in this Act on behalf of individuals
with disabilities; and
(4)
to invoke the sweep of congressional authority, including the
power to enforce the fourteenth amendment and to regulate
commerce, in order to address the major areas of discrimination
faced day-to-day by people with disabilities.
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Appendix E
Glossary of Terms
Accessible
Activities or places which can be used by people with disabilities.
ADA – Americans with Disabilities Act
The federal law passed in 1990 that provides a clear and
comprehensive mandate for the elimination of discrimination of
people with disabilities. It requires public entities to adopt a plan to
improve the physical accessibility of public facilities and buildings and
remove all barriers to participation in programs, services and
activities.
ADA Grievance Procedure
Mandated by the ADA, this is a procedure required of all public
entities. It is designed to provide the prompt and equitable resolution
of complaints alleging discrimination prohibited by the ADA.
ADA Self-Evaluation
Mandated by the ADA, public entities must conduct a "self-
evaluation" of all programs, services, and activities to ensure that
they are provided to the public in a manner that does not exclude or
otherwise discriminate against people with disabilities.
ADA Transition Plan
Mandated by the ADA, this plan was created to identify the physical
barriers in the City’s facilities that limit the accessibility of its programs
and activities to people with disabilities, describes in detail the
methods used that will make those facilities accessible, and specifies
the schedule for taking the steps necessary to make those facilities
accessible.
Assistive or Adaptive Equipment
Any equipment that permits a person to function as independently as
possible. For example, a Telecommunication Device for the Deaf
(TDD) is an adaptive device that permits people who are deaf to
communicate with others using the existing telephone lines.
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Disability
A functional limitation resulting from a physical or mental condition
that affects one or more major life activities, including but not limited
to: walking, seeing, hearing, learning, sleeping, lifting and
reproduction.
Service Animal
Any animal that enables someone to function more independently,
not limited to guide dogs
TDD and TTY
Both refer to telecommunications for the deaf and hard of hearing.
TDD stands for Telecommunication Device for the Deaf, while TTY
stands for Teletext Typewriter. Most public phones today contain a
TTY.
Visitability
The concept that ordinances may be passed ensuring that new
homes and those undergoing major remodeling are accessible,
including measures such as a ramped entry, wide interior hallways,
and at least one completely accessible bathroom.
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Introduction
This report outlines the Americans with Disabilities Act (ADA), its requirements
for local governments, the City’s history of compliance and compliance
evaluation and the plan for ongoing evaluation and compliance. It details the
findings of the 2001 ADA Compliance Department Self-Evaluation survey and
actions to correct barriers identified in the survey, as well as an overview of the
steps the City can take to maintain and enhance both accessibility and the
evaluation process. Recommendations for improvements to physical and
programmatic accessibility by a residents’ advisory group (the Disability
Community Accessibility Committee) and strategies for implementing identified
recommendations are also included.
The ADA
The Americans with Disabilities Act (ADA) was signed into law on July 26, 1990
by President George H. W. Bush; Title I became effective July 26, 1992 and
Titles II and III on January 26, 1992. The intent of the ADA is to “establish a
clear and comprehensive prohibition of discrimination on the basis of disability.”
It is modeled on previous civil rights legislation, most notably the Civil Rights Act
(CRA) of 1964 and Section 504 of the Rehabilitation Act of 1973.
Both the ADA and Section 504 of the Rehabilitation Act stress equal access to
programs and services, not just equal treatment, to eliminate discrimination. To
this end, both acts require covered entities to make reasonable accommodations
in their policies and practices to allow persons with a disability the same
opportunities as those without a disability.
The ADA defines a person with a disability as someone who has a mental or
physical impairment that substantially limits one or more major activities of life.
Entities covered by the ADA include all government entities employing more than
50 people, their facilities, programs and services and most places of public
accommodation, such as most stores, restaurants, theaters, amusement parks,
and other places where the public is admitted. Private clubs that have restricted
membership and are not covered under the CRA of 1964 and houses of worship
are also exempt from complying with the ADA.
The broad guidelines set out in the five major titles of the ADA have been
quantified in part by a federal agency, the Architectural and Transportation
Barriers Compliance Board, also known as the Access Board. The guidelines,
mostly architectural specifications that encompass building, open space,
pedestrian right-of-way, communication and electronic (computer/web) design
standards, are called ADA Accessibility Guidelines or ADAAG’s. Although there
are ADAAG’s for many aspects of the ADA regulations, other areas have been
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subject to interpretation by the courts at every level, especially the definition of a
qualified individual with a disability.
The five titles of the ADA are:
Title I: Employment
Title II: Federal, State and Local governments, including local quasi-
governmental boards, commissions and agencies (e.g. Air
Quality Management Districts and school boards.) This title
covers public transportation and ADA administrative
requirements as well.
Title III: Places of Public Accommodation, public and private sectors
Title IV: Communications
Title V: Miscellaneous
The ADA and the City of Santa Monica
The City of Santa Monica is obligated to observe all requirements of Title I in its
employment practices; Title II in its policies, programs and services; any parts of
Titles IV and V that apply to the City, its programs, services or facilities; and all
ADAAG’s that apply to facilities and other physical holdings (e.g. streets,
beaches, sidewalks and pedestrian rights of way.)
Title II has the broadest impact on the City. Included in Title II are administrative
requirements for all government entities employing more than 50 people. These
administrative requirements are:
?
Completion of a self-evaluation by January 26, 1993;
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Development of an ADA grievance procedure;
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Designation of a person who is responsible for overseeing Title II
compliance; and
?
Development of a Transition Plan if the self-evaluation identifies any
structural modifications necessary for compliance; this must be retained
for three years.
The position of Sr. Administrative Analyst, ADA/Disability and Senior Services in
the Human Services Division of the Community and Cultural Services
Department was designated as ADA Coordinator for the City. A grievance policy
was also developed and implemented.
In 1992, the City conducted the required self-evaluation survey, focusing on
programmatic access, and used a consultant to develop a Transition Plan
identifying structural barriers and plans for their remediation. The self-evaluation
survey assessed key aspects of the City’s policies, programs, services, events
and advisory groups. Also in 1992, the Transition Plan was developed from a
survey of all City-owned and –leased facilities and open spaces and priorities for
barrier removal were set with the assistance of the public through a series of
meetings, forums and public hearings.
The Transition Plan serves as a document detailing physical barriers to access in
all City owned, operated and leased facilities and the steps and length of time
necessary to remove those barriers. Based on ADA guidelines and public input,
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the barrier removal was prioritized, and an estimate of the cost of the removal
included. The ADA administrative guidelines require that the Transition Plan be
retained for three years. It does not need to be rewritten, and the ADA does not
require that it be updated; the ADA requirement is that access be achieved and
maintained, and that new construction and some renovations of existing
structures are designed with full access. The City of Santa Monica used the
original Transition Plan as the basis for annual updates for about five years after
it was written. Because the original Transition Plan is obsolete due to
construction, renovation, acquisition of new facilities and repairs due to damage
from the 1994 Northridge earthquake, remaining accessibility barriers are
addressed through a combination of new construction/renovation and
maintenance projects.
The Transition Plan was based on a self-evaluation survey that included
programmatic access as well as physical access. The results of the
programmatic self-evaluation have evolved into a separate document from the
Transition Plan; one that focuses on the non-physical aspects of access to City
services and programs. This ADA Self-Evaluation is not an ADA required
document, and is used by the City to identify programmatic and communication
access barriers to City services and programs and to detail the strategies for
barrier removal. Examples of survey items include: availability of TTYs
(teletypewriters, used for telephonic communication by deaf and hard of hearing
persons and those with speech impairments), staff training on disability issues
and the ADA, availability of auxiliary aids and alternate formats and emergency
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preparedness for employees and visitors with disabilities. The self-evaluation
survey results are reviewed and updated annually, and the department survey
has historically been repeated every few years.
These ADA-required activities were preceded by almost 10 years of accessibility
activities, projects, education and outreach coordinated and sponsored by the
Office of the Disabled, which was established in 1982. (The original coordinator
of this office was appointed ADA Coordinator in 1991.) These barrier removal
projects, which included curb ramp construction, education for City staff and
Santa Monica businesses, and addition of physical accessibility features to City
facilities, were required, in part, by Section 504 of the Rehabilitation Act of 1973,
which generally applies to all entities, projects and programs receiving federal
money. Activities not required by federal and/or state regulations were the result
of the City’s commitment to address issues faced by the disability community.
These activities include education for local businesses on incentives for and
benefits of hiring people with disabilities, Disability Awareness Month activities,
staff training, and public outreach. In 1986, for instance, the Office of the
Disabled published a guide to accessible businesses and facilities in Santa
Monica.
From 1992 through 1996, the City’s ADA Coordinator reviewed the Transition
Plan and the recommendations of the original self-evaluation survey yearly to
track the progress of the implementation of the original recommendations. (The
ADA requires that the Transition Plan be retained for only three years, and the
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original document has become obsolete; periodic updates are used in place of
the original document.) In FY1996-97, each City department prepared a new
self-evaluation to gather information on the status of programmatic access for
activities instituted since the original survey and planned future activities. A
matrix showing the recommendations and their status was prepared, and a
status report on the projects originally identified in the Transition Plan was
presented to the City Council in 1998.
From 1996 through 2000, the new recommendations (based on both the original
and the updated self-evaluations) were reviewed by the ADA Coordinator. The
matrix of recommendations prepared in 1997 was updated in 2000 and
distributed again to all departments.
In early FY 2001-02, all departments were again asked to complete a self-
evaluation survey, focusing, as before, on programmatic issues. The survey for
each department was completed by an ADA Staff Liaison. The Liaisons are a
group of employees representing every department and most divisions who meet
and interact to increase and facilitate collaboration on interdepartmental ADA
issues. The Staff Liaisons also serve as “point person” in their respective
departments and divisions for dissemination of ADA information and resolution of
ADA complaints. The Staff Liaisons received training on the ADA and its history,
how the ADA applies to the City of Santa Monica, the purpose and completion of
the survey, and the terms used in the survey. Each survey was reviewed by the
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ADA Coordinator and revised by the Liaison until barriers and appropriate
remediation were clearly defined.
The ADA requires that the Transition Plan be retained for three years; there are
no requirements for retaining the Self-Evaluation. Because both of the original
documents are obsolete and have been rewritten several times, a thoughtful
analysis by staff indicates that a new format would be more useful in highlighting
progress toward barrier-removal goals, areas where barriers exist, and areas in
which the spirit of the ADA should be followed beyond the letter of the law. This
report includes programmatic barriers identified by the departmental self-
evaluation, physical barriers identified through various means, including the
facilities survey, and recommendations made by the DCAC with progress on their
implementation. The new report is the City of Santa Monica ADA Compliance
Update.
The City Council has expressed its desire to have the City of Santa Monica
become a leader in municipal accessibility for persons with disabilities. To
achieve this, an awareness of accessibility needs of persons with a disability and
the commitment to achieve accessibility are necessary. To this end, the City
Council appointed the Disability Community Accessibility Committee (DCAC),
which meets annually to provide input to the ADA Compliance Update as well as
to hear, discuss and make recommendations on disability issues in Santa
Monica.
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Summary of the 2001 Self-Evaluation Update
There are several themes that emerge from the 2001 Self-Evaluation department
survey. The most striking is that, while almost every department requested
training on the ADA and disabilities in general, there were few significant
programmatic barriers noted; two departments and one division had no barriers
identified by the self-evaluation. The second important theme to emerge is that
necessary programmatic changes are mostly inexpensive or no-cost solutions
that only require relatively insignificant amounts of staff time to implement. One
notable exception to this is making all City web pages accessible, which is
expected to cost up to $30,000; however this has already been included in the
FY 01-02 budget.
Most of the barriers identified involved making information available in
alternative, accessible formats. This includes the use of auxiliary aids for
communication and the availability of written and oral material in alternative
formats. As important as the availability of material in alternate formats is making
the public aware that these alternate formats are available and how to request
them, which was one of the most common barriers noted in the survey.
Other Accessibility Projects in the City
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Before the self-evaluation survey was completed in August 2001, several
projects were begun and/or completed in FY 00-01 and FY 01-02 as part of the
City’s ongoing commitment to accessibility for all residents and visitors. These
projects are a mix of both programmatic and physical accessibility. These
include:
?
making the 24 hour Jobline available on TTY through City Hall on Call
(completed);
?
installing accessible pedestrian crosswalk call buttons (completion
planned for 2002);
?
adding an accessibility requirement to event permits and developing a
Community Events accessibility checklist (completed);
?
ongoing curb ramp construction (completion planned for 2002);
?
installing an assistive listening device in the Civic Auditorium (completed);
and
?
renewing and training a network of departmental ADA liaisons for
increased coordination of ADA issues and dissemination of information
(ADA Staff Liaisons.)
Since the 1992 review, a number of the identified projects have been moved from
individual Capital Improvement Projects to being subsumed under larger
projects, which are handled by various departments (e.g. park restrooms, the
Public Safety Facility now under construction, and some City Hall accessibility
projects, to name a few.) (This means that the accessibility project is no longer a
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¶
separate project funded by the Capital Improvement Projects budget, but is rolled
into a larger project that is handled by a specific department.) Some accessibility
projects are included in repairs as they come up.
Next Steps
One of the most important aspects of an annual review of the City’s Self-
Evaluation is incorporating feedback from the community into priority and goal
setting. This feedback is often informal, with more formal input through the use
of surveys, public hearings, focus groups, task forces and committees to achieve
a balanced, broader perspective on the issues facing residents of and visitors to
Santa Monica who have a disability. The DCAC reviewed the ADA Compliance
Update and provided important feedback; they are scheduled to review the
Update annually.
Many of the DCAC’s suggestions for revising the self-evaluation survey
instrument and record-keeping process will be adopted for the next full survey.
In addition to eliciting important information on the City’s progress in identifying
and ameliorating barriers to access, the changes will also allow for easier, more
accurate record keeping to track problems and barrier removal. The self-
evaluation survey instrument will be updated to comprehensively identify possible
barriers to access that are not identified by the questions contained in the current
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survey. Additional recommendations made by the DCAC highlighted areas
identified by the survey and through more informal input from City departments to
the ADA Coordinator, lending further weight to the importance of these issues
and the steps being taken and planned to resolve them. A review of the process
by the ADA Liaisons elicited a number of useful suggestions, as well, which will
also be incorporated into future surveys.
The 1992 review of physical accessibility of City-owned and leased facilities
quickly became outdated as a result of the acquisition of new facilities, changes
made during routine and emergency repairs, barriers removed during
renovations and other construction, and repairs necessitated by the 1994
Northridge earthquake. Since the Transition Plan, which was based on a
detailed survey of each City facility, became obsolete fairly quickly, it is not a cost
effective option to repeat such a survey.
An inter-disciplinary group from Environmental and Public Works Department,
City Manager’s Office and Community and Cultural Services Department met to
formulate a plan to address ongoing physical accessibility issues. This group
concluded that a prioritized list of upgrades and barrier removal by type of project
will be a more effective tool and agreed to hire a consultant who will: devise a
facility checklist identifying priority concerns; assist in formulating a City policy
regarding priorities for implementing accessibility projects, including both the type
of project (e.g. restrooms) and the location of the project (e.g. City Hall, Big Blue
Bus); and compile a source book for accessories (handles, toilets, sinks, latches,
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etc.) that are ADA compliant for the City to use for future purchases. The
priorities will be revisited periodically, and will be followed when choices are
made among several projects of the same size and type.The priorities will be
based, whenever possible, on public input and an adherence to the concept of
universal accessibility. The DCAC’s input on priorities will be incorporated into
the design of the survey as well. The cost of the consultant is estimated at
$50,000-$75,000, which has not been budgeted for FY 2001-02. Staff is seeking
funding options, including the use of CDBG fund. Maintenance personnel will
carry out the facility survey, using the consultant’s checklist, during their planned
survey of each City facility.
Several projects currently underway will further both the DCAC’s and City
Council’s commitment to full accessibility. Staff is preparing a citywide training
plan for ADA and disability-related issues. It is anticipated that the plan will be
finished by early 2002, with training beginning in mid 2002. The cost of the
training for City staff, board members and commissioners has been included in
the FY 01-02 Human Services Division budget.
In addition to this training, staff is analyzing the need for new policies regarding
different aspects of accessibility. Staff is also revising an Administrative
Instruction, for all City staff, covering accommodations for employees with
disabilities. This administrative procedure is intended to remind employees who
are not often called upon to make accommodations for persons with disabilities
that accessibility applies to all aspects of City policies, programs, services and
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¶
facilities. It will also serve as a tool to guide employees who have a disability
through the process for requesting an accommodation.
Conclusion
It has been almost 12 years since the ADA was signed, and ten since it became
effective. The outline of the steps the City is required to take to ensure
compliance was specified in the original document and several subsequent
interpretations, but the details of exactly how the City chooses to track necessary
changes were not. The process of implementing the necessary changes and
executing periodic surveys has evolved to fit the particular requirements of the
City of Santa Monica and its administrative structure.
After ten years of incremental progress, the City’s review and update of the Self-
Evaluation and the Transition Plan has evolved into a useful process that
addresses the need for periodic evaluation and training. Because that self-
evaluation process is conducted internally, however, some barriers to full access
are not identified. Awareness of accessibility has been incorporated into the
everyday functioning of the City in many respects, but barriers are still
encountered by members of the community seeking to become part of the
governing process, or to take advantage of a City program, or to conduct
business with the City. The perspective of City staff is that of the service provider
rather than the person seeking the service, so these barriers can remain
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¶
unidentified without assistance from those seeking access to City government.
Thoughtful input by the disability community in Santa Monica will help ensure that
any remaining barriers to access are identified and addressed, and future
programs and facilities are designed to be fully accessible from the outset.
Although the ADA compliance review process has evolved with changing
perspectives and needs, it remains an eminently useful tool. Recognizing that
further evolution will make it even more useful is important, and seeing it as a
dynamic, rather than a static, tool will lead to ever more useful results as the face
of accessibility needs in Santa Monica continues to change.
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DCAC Recommendations and
City Implementation Strategy/Status
DCAC Recommendations City’s Implementation/Strategy
I. Improve physical accessibility of all
Ongoing
City-owned, operated and leased
24
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DCAC Recommendations and
City Implementation Strategy/Status
DCAC Recommendations City’s Implementation/Strategy
facilities and recommendations for the
ADA Transition Plan
1) The City should devote as much of 1) All City facilities meet applicable Title
the capital budget as possible to 24 standards. Because so many are
complete ADA mandated old, they cannot be made to conform
accommodations in all City facilities in with current standards, and/or it
3-5 years. would be too costly.
2) Create and maintain a database of 2) In FY02-03, staff will identify
ADA compliance in all City facilities so compliance status of facilities through
that future projects upgrades may be a survey. Current information will be
prioritized and renovations tracked. maintained.
3) Create a database of assistive 3) The ADA Coordinator will develop a
equipment, ensure all assistive list in conjunction with ADA Liaisons
equipment is properly maintained. by the end of FY01-02. Equipment
will have maintenance plans per
manufacturer specifications.
4) Consult a disability advisory body 4) The City will conduct an annual ADA
during the formation of updated and/or Compliance Review and Update,
future Transition Plans. which will improve upon and replace
the Transition Plan revisions.
II. Improve the City’s interaction and
Ongoing
communication with people with
disabilities
1) Ensure that every City staff member 1) Training for all City staff is planned to
and public official participates in training begin in mid-2002. Staff will analyze
at the time of hire/ appointment/election the feasibility of adding general
and annually thereafter. disability awareness training to new
employee orientations.
2) Improve methods of obtaining 2) Planned for FY02-03.
feedback from trainings and provide the
feedback to a disability advisory body
for review and recommendations
3) Improve accessibility of 3) Ongoing.
communication from City Hall to the
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DCAC Recommendations and
City Implementation Strategy/Status
DCAC Recommendations City’s Implementation/Strategy
general public via the City website,
printed materials and other media
a) Make the website fully a) In FY01-02, City will contract with
accessible consultant to redesign website. New
website will be accessible per Section
508 federal standards.
b) Include more information about: b) The redesigned website will include
all relevant information.
º
the City’s ADA Coordinator;
the annual ADA compliance
o
review;
transportation and paratransit
o
information;
employment opportunities;
o
ADA grievance procedure;
o
Requesting reasonable
o
accommodations at City
sponsored programs and
meetings; and
Providing feedback, asking
o
questions, giving compliments to
staff or programs and filing
complaints available on the
website
c) Make printed and other c) All materials available to the public
materials available in alternate are available in alternate formats.
format
d) The City will disseminate information
d) Use Plain English and People on People First language and Plain
First wording for all materials English through ADA Liaisons, Public
distributed to the public Information Crew, and staff trainings.
e) Improve City procedures for e) Auxiliary aids and services are
providing auxiliary aids and services provided upon request.
at public events to ensure effective
communication for people who are
deaf or hard of hearing.
f) Ensure that all City sponsored f) Statement on advertisements and
26
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DCAC Recommendations and
City Implementation Strategy/Status
DCAC Recommendations City’s Implementation/Strategy
advertisements and notices about notices is already required.
City programs and meetings
(Seascape, L.A. Times, etc.) include
a statement explaining how to ask
for a reasonable accommodation
and describing the accessibility of
each program and meeting.
g) Improve and fully disseminate g) ADA Coordinator provides
City procedures for providing appropriate and up-to-date referrals.
referrals to people with disabilities
who contact the City for services the
City cannot provide.
h) Include questions regarding h) Staff will work to incorporate section
disabilities in the section of in the next survey.
identifying information in the yearly
random-digit dialed survey of Santa
Monica residents, so data may be
analyzed in terms of disability.
4. Improve the departmental ADA self- 4) Improvements will be incorporated in
evaluation survey to ensure that staff the FY02-03 survey.
take various disabilities into account
when providing programs and services.
a) add and/or modify questions to a) Most of the DCAC’s
ensure that staff have appropriate recommendations for changes and
training, know applicable procedures additions to the Self Evaluation survey
for requesting and providing will be incorporated into the next
reasonable accommodations, version.
provide information in Plain English,
written in People First style, and
offer communication equipment for
people who are deaf or hard of
hearing.
b) ADA Coordinator will meet with each b) Liaisons meet 3-4 times annually, and
department ADA Liaison to support the ADA Coordinator meets with each
27
1) 3)
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DCAC Recommendations and
City Implementation Strategy/Status
DCAC Recommendations City’s Implementation/Strategy
them in achieving action items individually. Progress is addressed in
identified in the Self-Evaluation the ADA Compliance Report.
Survey. Progress toward those
goals should be published annually.
5) Implement effective and Ongoing
universal grievance procedure to help
bring common and repetitive problems
to light.
a) Strengthen ADA a) Revision of procedure is in process.
grievance procedure.
b) Widely disseminate b) Upon completion of policy revisions,
grievance procedure, including information will be widely
posting in each department, training disseminated.
staff and using a public relations
campaign.
c) Provide summary c) Summary report can be made
report yearly to disability advisory available annually as part of the
body on ADA grievances filed, compliance review.
including the nature of the
complaints, the outcomes and dates.
III. Improve outreach to and education of Staff will assess the feasibility of this
businesses and landlords. recommendation and make
recommendations for any follow up
in FY02-03. Analysis will consider
available resources and other priority
issues.
1) Conduct periodic educational 1) Under consideration.
campaigns to inform businesses and
landlords (including healthcare facilities)
of disability issues, rights, laws, and
forms of discrimination.
2) Inform businesses of tax 2) Under consideration.
credits already offered by the
28
4) 6) 5)
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DCAC Recommendations and
City Implementation Strategy/Status
DCAC Recommendations City’s Implementation/Strategy
Federal and State
governments for ADA
renovations.
3) Increase grants to businesses and landlords
3) Under consideration.
to make accessibility upgrades to properties.
4) Improve/increase accessibility code 4) Under consideration.
enforcement.
5) Continue to explore the issue of 5) Staff has hired a consultant to
visitability. conduct feasibility study and present
recommendations in early FY02-03.
Staff recommendation to Council will
IV. Establish a year-round disability
be considered on April 9, 2002.
advisory body.
1) 9-11 members 1) Staff recommendation suggests
no more than 9 members.
2) All have experience in the 2) Staff recommendation is consistent.
disability community.
3) 2/3 people with disabilities, 3) It is against State and Federal law to
taking care to be consistent ask an applicant if s/he has a
with affirmative action and disability.
federal privacy laws regarding
disclosure of disability status.
4) DCAC members are encouraged to
4) Extend tenure of DCAC to meet w/ participate actively in the public input
consultant for facilities survey checklist process when Council considers
and consultant on visitability while visitability recommendations. DCAC
permanent, year round body is being priorities will be incorporated into
considered. facilities survey checklist, which will
be developed by an expert in ADA
accessibility standards.
29
$500-Estimated $250 Staff time Staff time stock labels to add info to existing cost of stamp or -Minimal 02 ISD budget-in FY 01 Approx. $30,000, inclu Staff time
Staff time budget from HSD ADA Accom. TTY/accessories purchs’d Staff time Staff time HSD ADA Accom. budget will be purchased from Any equipment necessary Staff time
Accom. Budget if necessarypurchase from HSD ADA TTYNone for analysis, 02-Included in FY 01
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2001 City of Santa Monica ADA Compliance Department Self Evaluation
Deleted:
¶
Dept./ Barrier Action Est. Date Department Budgetary/Financial
Division of Compl. Responsible Impact
Big Blue Bus Main entrance inaccessible due to stairs Install ramp 9/20/01 BBB/EPWM
?
(BBB) BBB budget
City Attorney Publications do not include alternate format All publications will contain information
?
10/31/01 CAO Staff time
(CAO) information on alternate formats
No TTY Analyze necessity for dedicated TTY 01/31/02 CAO
?
No ADA information file in department Develop file with information appropriate 11/30/01 CAO
?
to the City Attorney’s office, announce
availability to staff
No emergency evacuation plan for Develop plan, educate staff, practice 12/31/01 CAO w/
?
employees with disabilities evacuation Fire Dept.
City Mgr’s City has no current general policy statement Write Administrative Instruction 1/31/02 CMO,
?
Office/ re: ADA compliance CCS/HSD
Admin
(CMO) Seascape and Wavelengths do not contain Include this information Fall 2001 CMO
?
alternate format information editions
No TTY at Information Booth 1. Purchase and install, re-train staff 9/30/01 CCS
?
2. Include TTY # in all publications 10/31/01 CMO
City Mgr’s Ads for as-needed and casual employees Consult with Human Resources to 11/30/01 City TV/
?
Ofc./CityTV not placed through Human Resources do not develop appropriate language, add to all CMO
contain notice of non-discrimination display ads
CMO/Info. City’s website is not completely accessible 1.Train web authors to create accessible 02/28/02 ISD/CMO
?
Systems Div. new pages
(ISD) 2. Hire consultant to develop plan for 03/31/02 ISD/CMO
making existing pages accessible
City Mgr’s Claim forms do not contain information on Information will be added to all forms 10/01/01 Risk Mgmt
?
Ofc./ Risk alternate formats or requesting a reasonable /CMO
Mgt accommodation
CMO/Risk Mgt. Not all contracts contain clause stating that Consult with City Atty to develop 05/15/02 Risk Mgmt
?
(con’t) contractors may not discriminate on the appropriate language and insert into /CMO
basis of disability contract at renewal
Community & Not all public documents All documents will contain alternate 11/30/01 CCS/HSD
?
Cultural Svcs/ contain alternate format information format information
Human Svcs
Div.
CCS/HSD/ Accessible entrance to PAL Youth Add signage indicating accessible path 12/01/01 CCS/HSD/
?
30
Staff time Staff time Staff time Staff time Staff time Staff time Staff time Staff time Affairs Staff time t. Staff time Staff time
Staff time Staff time Staff time PAL budget
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Youth & Fitness Center not clearly marked of travel YFP
Family Pgms
No specific outreach for HSD 1.Identify programs serving children with 09/30/01 CCS/HSD/
?
Youth and Family programs targeting disabilities through SMMUSD, provide YFP
children with disabilities outreach directly to those schools and
programs
2. Identify organizations serving youth 12/31/01 CCS/HSD/
with disabilities in the SM area, provide YFP
outreach directly
Staff has no central source of relevant Identify appropriate material w/ help of 10/01/01 CCS/HSD/
?
ADA information ADA Coord., compile, announce to staff YFP
VAPAB, PAL Board and new Municipal The Boards and Commissions 11/30/01 CCS/HSD/
?
Pool Advisory Committee require a review Accessibility Checklist will be reviewed YFP
of their policies and procedures to ensure by staff liaisons and the ADA Coord.
compliance and any necessary changes identified
CCS/Open No procedures in place to provide Establish procedure in consultation 12/31/01 CCS/OSM
?
Space Mgmt alternate formats if requested with ADA Coord
CCS/Admin & Info on alternate formats, accessibility & Add information 11/30/01 CCS/Cul
?
Cult. Affairs auxiliary aids not included in agendas and
meeting notices for committees,commissions
CCS/. Staff coverage for TTY inadequate Train at least 2 more staff in its use 11/30/01 CCS/Comm.
?
Comunity Pgms
Programs Printed materials do not include TTY # Include in all printed materials where 10/31/01 CCS/Comm.
?
voice phone # is provided Pgms
Advertisements for as-needed staff do In conjunction with Human Resources, 11/30/01 CCS/Comm.
?
not include statement of non-discrimination develop appropriate wording, add to Pgms
policy postings for as-needed and PT staff
CCS/ Tennis Program has no specific outreach Tennis Program outreach will be incl. 12/31/01 CCS/Comm. Staff time
?
Community to disability community with Therapeutic Rec. Program outreach Pgms
Programs
(con’t) Tennis reservation publications do not Add information to materials 09/30/01 CCS/C
?
include accessibility information Pgms
Accessibility information not included in Add accessibility information 09/30/01 CCS/Comm.
?
Adult Sports materials
Memorial Park Gym information not available Add information on requesting alternate 09/30/01 CCS/Comm.
?
in alternate formats formats, develop plan for producing in Pgms
alternate format upon request
Sports Advisory Council and Community Information provided to staff liaison to 09/30/01 CCS/C
?
Garden Advisory Board need updated ADA disseminate to SAC and CGAB Pgms
information
Community Gardens not fully accessible- no Analyze cost and feasibility of raising 02/28/02 CCS/Comm.
?
raised beds some or all beds Pgms
31
from HSD ADA Accom. budget. cost of telephone line installation Purchase of TTY andStaff time. No addl cost or stamp Staff time, materials Staff time budget
stage currently) accessible - in EPWM FY 01Included HSD ADA Accom budget will be purchased with Staff time. Any necessary eqpt Staff time (EPWM budget item) per video
produced format; produce new videos with captioning alternate format, captioning not included $100-Staff time, addl $500 Staff time or hard to read text Staff time
Staff time Staff time Staff time Staff time
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CCS/Event Accessibility/alternate format information not Add appropriate information 11/30/01 CCS/ Event
?
Facilities included on receipt, newsletters, brochures, etc Svcs.
Environmental Public forms do not give alternate format info Add to all public forms and documents 12/31/01 EPWM
?
And Public incl. those on the website
Works Mgt.
(EPWM) Physical accessibility and reasonable Add to all meeting and event notices 12/01/01 EPWM
?
accommodation request information not and agendas
ADA information files not available to Create files and inform staff of their 11/01/01 EPWM
?
employees at all sites availability
Staff not familiar with auxiliary aids Develop plan for acquisition (if
?
necessary) 12/01/01 EPWM Staff time
and use of auxiliary aids, train staff
Staff are not trained to make public items Develop policy, train staff, reformat 12/01/01 EPWM
?
clear and legible, with no obscuring overlays existing documents
Staff who answer the phones are not familiar Provide information and training 09/30/01 EPWM
?
with California Relay Service
Videos produced by division not available in Develop plan to provide videos in alt. 01/31/02 EPWM
?
EPWM Contract language does not prohibit Develop appropriate language in 12/31/01 EPWM
?
(con’t) discrimination on the basis of disability conjunction with City Attorney’s office,
add to future contracts
Emergency evacuation plans do not include Develop plan in conjunction with Emerg. 12/31/01 EPWM
?
needs of employees with disabilities Services Coordinator
Engineering counter not wheelchair Remodel for accessibility (in planning 01/31/02 EPWM
?
?
Fire Dept No policy requiring Fire Department events to Develop policy and train appropriate 12/31/01 Fire Dept.
be held in accessible locations personnel
?
No coordinated program for outreach to Analyze feasibility of working with WCIL 01/31/02 Fire Dept.
persons with disabilities and/or Westside Regional Center to
co-sponsor safety programs for persons
with disabilities
?
Publications do not include alternate format 1)Create stamp or label for existing
stock 09/30/01 Fire Dept. Staff time, cost of labels
information with alternate format information
2) Include when ordering new stock
?
Purchased training videos not captioned All new purchased videos will be ongoing Fire Dept
captioned
?
No TTY for information/non-emergency Analyze need for TTY, install if 12/01/01 Fire Dept/
telephone number necessary CCS/HSD
32
Staff time Staff time ADA Accom. budget eqpt. purchased with HSD Staff time. Necessary meStaff ti Staff time stamp or labels Staff time,
cost of Staff time Staff time Staff time Staff time Staff time Staff time Staff time
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?
No plan in place to provide auxiliary aids Develop and implement plan, train 11/30/01 Fire Dept
staff
?
Agreement with AMR Ambulance to provide Develop appropriate language in 12/31/01 Fire Dept
ambulance transportation service does not conjunction with the City Attorney’s ofc;
include clause prohibiting discrimination on inform AMR of ADA regs and City’s
the basis of disability requirement that they follow them
Library No current barriers noted in survey
?
Human No specific outreach/recruitment plan for Analyze feasibility of increased outreach 06/30/02 HR
Resources persons with disabilities specific to persons with disabilities
?
HR (con’t) Personnel Board needs updated ADA Develop and present information 03/31/02 HR,
training
CCS/HSD,
City Atty
?
Police Dept Limited outreach to disability community by Add HSD grantees serving persons with 11/30/01 SMPD
(SMPD) Community Relations Dept. disabilities and seniors to the
Community
Relations mailing list
ADA information file not accessible to or Create file, announce availability to all 12/31/01 SMPD
?
known by all personnel personnel
Records and Accessibility information is not included on Add information 09/06/01 Records/
?
Election Svcs City Council agendas Elect. Svcs
(City Clerk)
Brochures, receipts and Board and Add to existing stock by stamp or label, 12/31/01 Records/
?
Commission applications do not contain add to new stock when re-printed Election
alternate format information Svcs
Rent Control Accessibility information not included on Add information 11/30/01 Rent
?
agendas and meeting notices Control
Alternate format information not included in Add information 11/30/01 Rent
?
newsletter and mailings to tenants, landlords Control
No emergency evacuation plan in place for Develop plan in conjunction with Emerg. 11/30/01 Rent
?
employee with disability Services Coordinator, implement by Control/
training staff Fire Dept
Resource Department members not trained in use of Disseminate information to staff 09/30/01 Resource
?
Management California Relay Service Mgmt
Finance Access to ADA Information not available Compile ADA Information file, make it 11/30/01 Finance and
?
to staff known to staff CCS/HSD
33
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Planning and No current barriers noted in survey
F:hsd/share/ada/transition plan/att’ment II self eval report 2001.doc
Comm. Dev.
34