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HUD Partner. Initiative, HumanMEMORANDUM August 13, 2002 TO: FROM: SUBJECT: The Honorable Mayor and City Council Members Michael C. Van Milligen, City Manager Sub-Contract for HUD Partnership Initiative Human Rights Director Kelly Larson recommends approval of a contract with the Disability Management Consulting Group, EL.C., to perform accessibility audits of multi- family housing. I boncur with the recommendation and respectfully request Mayor and City Council approval. Michael C. Van Milligen MCVM/jh Attachment cc: Barry Lindahl, Corporation Counsel Cindy Steinhauser, Assistant City Manager Kelly Larson, Human Rights Director CITY OF DUBUQUE, IOWA MEMORANDUM August 13, 2002 To: Michael Van Milligen From: Kelly Larson Subject: Sub-Contract for HUD Partnership Initiative The purpose of this memorandum is to request your approval to proceed with a contract between the Human Rights Department and the Disability Management Consulting Group, L.L.C. to perform accessibility audits of multi-family housing. The purpose of the contract is to carry out a HUD partnership initiative that was approved by the City Council last October. The initiative involves subcontracting with a specialist to perform accessibility audits of multi-family housing constructed since 1991. The Disability Management Consulting Group (DMCG) specializes in such audits. Attached please find a proposed contract, a sample of the contractor's work, and accompanying credentials. I am not aware of other companies in our region that engage in this work as a spedalty. The requested action is that you approve my entering into this contract. Disability Management Consulting Group, L.L.C. DMCG - The Forenmner in Dist~#ly Information 2801 Jonquil Place Columbia, MO 65202 Phone (866) 573-DMCG or (800) 949-4232 c-Fax (501) 325-9974 or paper Fax (573) 85~. ~.925 Consultation Agreement Scope of Work August 5, 2002 to December 15, 2002 The Disabffity Management Consulting Group (DMCG) respectfully enters into a subcontractual agreement with the City of Dubuque Human Rights Department (CDHRD) for the provision of expert technical assistance pertaining to the Americans with Disabilities Act, Section 504 of the Rehabilitation Act and the Fair Housing Amendraents Act. Specifically, DMCG va]l perform on-site accesm'lx~ty surveys and written survey reports of approximately thirty five (35) homing complexes located in the City of Dubuque, Iowa- DMCG will provide these services at a cost of $75.00 per hour, but in no case shall the cost exceed $900.00 per homing complex. Based on past experience, DMCG expects the on-site surveys and written reports to average twelve (12) hours per housing complex. In exchange for payment, DMCG agrees to provide the following specitic services: Specific Activities & Services Beginning on or about September 1, 2002, Kent Jofin.qon wffi assist in the performanm of and/or oversee the performance of on-site structural access~tn]ity surveys of all comn~an areas at b~ldings ~d facilities ofhonsing complexes, as specified by CDHRD. These structural acceasfl~lity surveys will be performed for the purpose ofidentifying existing structural barriers as defined by the Fair Housing Amendments Act (PHAA), the Americans with Disabt]ities Act (ADA), and Section 504 of the Reh~on Act (Section 504). Before December 15, 2002, DMCG will provide a written report of each hons~ complex that ha.q been surveyed (approximately 35 housing coirq)lexes total). Each structural aceessfollity survey report vddl consist of three main parts - (Part 1) a cover letter defining the scope of the survey, (Part 2) a stmamry of structural lmrriers, and (Pm 3) the Aecesml~tity Survey Report. Each Accem3ility Survey Report (Part 3) will provide a complete listing of all structural barriers according to FI-IAG, ADAAG and/or UFAS, and each page of this report will consist of the following components: 1. The Area where the barrier was identified; 2. A description of each barrier in this area; 3. The correspondiag FtlAG, ADAAG and/or UFAS Regulation/s pertaining to the specific barrier, and 4. The report will also include a photo of each barrier and may include barrier removal reconmaendations/comn~ats and/or diagrams pertt6ning to each identified accessil~y barrier. (See the attached s~i~01¢ housing Access~3~lity Survey P. eport). · Federal documents to be utilized in detemilning barriers include, but are not lhi,;ted to the Fair Housing Accessibility Guidelines and related FHAA Technical Assistance Manuals; the Americans with Dishes Act Aecessalality Guidelines, federally created documents pertaining to these Guidelines, and ADA Teclmical Assistance Manuals; and the Uniform Federal Accessal~ty Standards and related Section 504 · Per request by CDHRD, Kent Johnson vail provide expert testimony and expert witness services during courtroom or related activities on a fee for service basis at a rate of $150.00 per hour. Per request by CDHRD, DMCG w[ll provide continued technical assistance and exauhte drawings or printed information related to previously surveyed housing complexes and/or the technicalities of disability-related laws effecting housing situations. · All services provided by DMCG, including related documents such as survey reports, pi-inted materials, photographs, etc., will be considered confidential and only dispersed to CDHRD. K~a~t Johnson, O.M. Date Disability Manag~aneat Consulting Group, L.LC. [Federal Tax Nmnhe~ (TIN) 436854945] 2801 Jonquil Plac~ Colmnbia, MO 65202 Phon~ (573) 817-5826 or (800) 949-4232 Kelly Larson City of Dubuque Human Rights Depat ttaeat 1300 Main 5~eet Dalmque, IA 52001 Date 2 Kent L. Johnson 2801 Jonquil Place Columbia, MO 65202 Home Phone (573) 446-8973 Work Phone (866) 573-DMCG (Toll-Free) Qualifications Kent Johnson has been providing technical information, training, and consultation on a variety of disability-related laws, including the Americans with Disabilities Act, for the past fourteen years. He has trained hundreds of organizations and associations; federal, state, and local government agencies; and numerous pdvate business entities regarding the technical regulation and provisions of disability-related laws. Mr. Johnson has created and provided hundreds of specific reports, policies, and practices pertaining to architectural access, program access, and compliant policies in reference to the technicalities of disability law during private consultation with clients. Mr.'Johnson operates a private consulting business providing accurate and timely technical information on disability-related laws to various organizations including federal organizations, state organizations, municipalities, counties, private business and employers. He maintains liaison relationships with numerous federal, state, and local agencies that enforce or create pertinent information on disability-related laws to stay apprised of present national activities and to help ensure the provision of accurate information and consultative guidance. Employment H~tory Co-principle/Operations Mana.qer: Disability Management Consulting Group L.L.C. - Columbia, MO - 1998 to Present. Associate Director: Great Plains Disability & Business Technical Assistance Center - Columbia, MO - 1999 to 2000 Missoud Coordinator: Great Plains Disability & Business Technical Assistance Center-Columbia, MO - 1996 to 1999 Technical Assistance Coordinator: Great Plains Disability & Business Technical Assistance Center- Columbia, MO 1995 to 1996 Americans with Disabilities Act Program Coordinator: Governor's Council on Disability, State of Missouri - Jefferson City, MO - 1994 to 1995 Americans with Disabilities Act Specialist: Governor's Council on Disability, State of Missouri - Jefferson City, MO - 1993 to 1994 Accessibility Specialist: Southwest Center for Independent Living - Springfield, MO - 1989 to 1993. Professional Consultin~l Experience Organizations that Mr. Johnson has recently provided services to and organizations that currently receive services include, but are not limited to, the following: Accessibility Consuitinn Services. Inc. Contact: John Moseley, Owner 408 Manor Drive Columbia, MO 65203 Services Provided: Numerous consulting activities relating to schools, municipalities, and housing complexes. Provision of services includes training, technical assistance, on-site surveys and written accessibility survey reports. 1995 to Present U.S. Department of A~lriculture, Rural Develooment Contact: Charles Marck$, Missouri State Office Program Coordinator 1715 W. Worely Columbia, MO 65202 Services Provided: On-going technical assistance and training on disability-fights laws pertaining to federally funded housing complexes. 1993 to 2001 David P. Calvert. P.A. The Buttermilk Lion Building 532 N. Market Wichita, KS 67214 Services Provided: Technical support, on-site architectural access surveys, and detailed written accessibility survey reports pertaining to buildings and facilities owned or operated by counties, cities and private businesses. Expert deposition regarding Susan Cook, et al. V. Board of County Commissioners. 1998 to Present Victoria L. Herring, Attorney at Law Suite 200, Terrace Place 2600 Grand Avenue Des Moines, IA 50312-5300. Services Provided: Legal case specific technical assistance and research pertaining to the Americans with Disabilities Act and other disability-related laws. 1999 Great Plains Disability & Business Technical Assistance Center Contact: James de ,long, Director 100 Corporate Lake Drive Columbia, MO 65202 Services Provided: On-going subcontractuml and consultation regarding disability-related laws. Provision of services includes technical assistance, training, and materials dissemination to covered entities and protected individuals under the Americans with Disabilities Act and related disability-~ghts laws. 2000 to Present GAP Architects Contact: Paul B. Gloe II, A.I.A. 1900 Swift, Suite 209 North Kansas City, MO 64116 Services Provided: On-site architectural accessibility survey and detailed written accessibility survey report and or>going technical support. 2OOO Rotts & Gibbs, L.L.P. Contact: Le Ann Wiseman, P.A. 16 N. Eighth Street Columbia, MO 65265 Services PrOvided: Technical support, omsite architectural access surveys, and detailed written accessibility survey reports pertaining to buildings and facilities owned or operated by menicipelities. Expert testimony regarding Raymond E. Holzschuh V. City of Owensville. 2000 to Present Ladue School Distdct Contact: Charlotte Roberts, Asst. Adm. 9703 Conway Road St. Louis, MO 63124 Services Provided: On-site accessibility survey and detailed written survey report identifying architectural and program bar, ers according to the technical provisions of the Americans with Disabilities Act of all school district buildings and facilities, including sports arenas, public common areas, swimming pools, auditoriums, and gymnasiums. 1999 Professional Consulting Experience (continued) Saint Lonis County Contact: Dana McAuliffe, ADA Coordinator 41 South Central Avenue St. Lousi, MO 63105 Services Provided: On-site accessibility surveys and detailed written survey reports identifying architectural and program barriers according to the technical provisions of the Americans with Disabilities Act. Numerous trainings including training the entirety of County Police personnel. 2001 to Present Qtraker Oats. In~ Contact: Stan Stuck 4501 Pads Road Columbia, MO 65202 Services Provided: Examination of intemai employment policies and practices, and recommendations for change regarding ADA compliant employment practices. 20O0 UMB Bank Pavilion (PJverport Ambitheater- St_ Louis. MO) Contact:. Jennifer Rawlings, Assoc Counsel Clear Channel Entertainment 2000 West Loop South, Suite 1300 Houston, TX 77027 Services Provided: On-site accessibility survey and detailed written survey report identifying architectural ban~em according to the technical provisions of the Americans with Disabilities Act - 2002 Cox Medical Center North Contact: John Mentgen, VP of Support Services 1423 N. Jefferson Ave. Spdngfieid, MO 658O2 Services Provided: On-site accessibility survey and detailed written survey report identifying architectural barriers according to the Americans with Disabilities Act of all hospital buildings and facilities. 2000 Kelly Mescher, Counsel University of Missouri 227 University Hall Columbia, MO 65211 Services Provided: Expert depos'~on pertaining to Coinmach v. University of Missouri Curators. 2001 Wallace Architects Contact: Cindy Anderson ~615 W. Broadway Sedalia, MO 65301 Services Provided: On-site accessibility surveys and detailed written mpods identifying arc~itecturai and program barriers according to the Americans with Disabilities Act, the Rehabilitation Act, and the Fair Housing Amendments Act of numerous federally funded housing complexes. Glessman, Bird & Braun. LLP. Contact: Todd R. Stramel 113W. 13~ Street Hays, KS 67601-0727 Services Provided: Expert opinions, technical information, and research regarding specific provisions and regulation of the Americans with Disabilities Act in reference to elevators, Umited Use/Limited Access elevators, and local government program access. 1999 to 2001 AHAL Contractin~ Comoanv. Inc. Contact: Gary Rickert, Risk Manager 3746 Pennridge Road Bndgeton, MO 63~.-1264 Services Provided: Examination of internal employment policies and practices, and recommendations for change regarding ADA compliant employment practices. 2OOO G~..n County Libraries Contact: Ellen Ken', SPHR, HR Manager 4653 South Campbell Avenue Sp~ngfield, MO 65801-0760 Services Provided: Examination of intemai employment policies and practices, and recommendations for change regarding ADA compliant employment practices, including 2OOO Josh Douglas, Staff Attomev Missoud Protection & Advocacy Services Contact: Robin Tropper 925 S. Country Club Drive Jefferson City, MO 65109 Services Provided: Training on disability- related housing laws and general disability rights laws, on-site survey technical assistance and written survey reports - 2002 to Present. 4 Professional Consulting ExPerience - Housirm The Disability & Fair Housina Pmiect LINK/HUD Contact: Robin Tropper 2401 E. 13th Street Hayes, KS 67601 Services Provided: Technical Assistance and Training on Housing Laws. 2002 to Present. Broadway Village Pleasant Hill, Missouri Services Provided: Survey entirety of housing complex for the purpose of identifying architectural and program bardem in reference to the Americans with Disabilities Act, the Fair Housing Amendments Act, and Section 504 of the Rehabilitation Act. Cameron Manor Apartments Cameron, Missouri Services Provided: Survey entirety of housing complex for the puq3ose of identifying architectural and program barriers in reference to the Americans with Disabilities Act, the Fair Housing Amendments Act, and Section 504 of the Rehabilitation Act. Eidon E..~ates 1 Eidon, Missouri Services Provided: Survey entirety of housing complex for the purpose of identifying architectural and program barriers in reference to the Americans with Disabilities Act, the Fair Housing Amendments Act, and Section 504 of the Rehabilitation Act. 20OO Eldon Manor Eidon, Missouri Services Provided: Survey entirety of housing complex for the purpose of identifying architectural and program barriers in reference to the Americans with Disabilities Act, the Fair Housing Amendments Act, and Section 504 of the Rehabilitation Act. 2OO0 Grand River Senior Housing Udch, Missouri Services Provided: Survey entirety of housing complex for the purpose of identifying architectural and program barriers in reference to the Americans with Disabilities Act, the Fair Housing Amendments Act, and Section 504 of the Rehabilitation Act. - 2000 Mad( Jones, Director Kansas City Fair Housing Center 3033 Prospect Ave. Kansas City, MO 64128 Services Provided: On-site housing complex accessibility surveys, expert testimony, and housing law training. 2001 to Present. Cameron Greens Apartments Cameron, Missouri Services Provided: Survey entirety of housing complex for the purpose of identifying architectural and program bah'leto in reference to the Americans with Disabilities Act, the Fair Housing Amendments Act, and Section 504 of the Rehabilitation Act. 2O0O Creighton Senior Housing Creighton, Missouri Services Provided: Survey entiraty of housing complex for the purpose of identifying architectural and program barriers in reference to the Amedcaus with Disabilities Act, the Fair Housing Amendments ACt, and Section 504 of the Rehabilitation Act. 2OO0 Eidon Estates II Eldon, Missouri Services Provided: Survey entirety of housing complex for the purpose of identifying architectural and program barriers in reference to the Americans with Disabilities Act, the Fair Housing Amendments Act, and Section 504 of the Rehabilitation Act. 2O00 Frazier Estates Drexel, Missouri Services Provided: Survey entirety of housing complex for the purpose of identifying architectural and program banters in reference to the Americans with Disabilities Act, the Fair Housing Amendments Ac~ and Section 504 of the Rehabilitation Act. 2O00 Highland Downs Housing Complex Nevada, Missouri Services Provided: Survey entirety of housing complex for the purpose of identifying architectural and program barders in reference to the Americans with Disabilities Act, the Fair Housing Amendments Act, and Section 504 of the Rehabilitation Act - 2000 5 Professional Consulfin.q Experience - HousinR (Continued) Jonesberg Properties Jonesberg, Missouri Services Provided: Survey entirety of housing complex for the purpose of identifying architectural and program barriers in reference to the Americans with Disabilities Act, the Fair Housing Amendments ACt, and Section 504 of the Rehabilitation Act. 2OO0 Lebanon Properties I Lebanon, Missouri Services Provided: Survey entirety of housing complex for the purpose of identifying architectural and program barriers in reference to the Americans with Disabilities Act, the Fair Housing Amendments Act, and Section 504 of the Rehabilitation Act. 2OOO Lebanon Properties III Lebanon, Missouri Services Provided: Survey entirety of housing complex for the purpose of identifying architectural and program barriers in reference to the Americans with Disabilities Act, the Fair Housing Amendments Act, and Section 504 of the Rehabilitation Act. 2000 Mary's Home Housing Mary's Home, Missouri Services Provided: Survey entirety of housing complex for the purpose of identifying architectural and program bardem in reference to the Americans ~ Disabilities Act, the Fair Housing Amendments Act, and Section 504 of the Rehabilitation Act. 2OOO Nevada Estates Nevada, Missouri Services Provided: Survey entirety of housing complex for the purpose of identifying architectural and program barriers in reference to the Americans with Disabilities ACt, .the Fair Housing Amendments Act, and Section 504 of the Rehabilitation Act. Keystar Osceola Apartments Osceola, Missouri Services Provided: Survey entirety of housing complex for the purpose of identifying architectural and program barriers in reference to the Americans with Disabilities Act, the Fair Housing Amendments Act, and Section 504 of the Rehabilitation Act. Lebanon Properties 11 Lebanon, Missoud Services Provided: Survey entirety of housing complex for the purpose of identifying arch'~ectural and program barriers in reference to the Americans with Disabilities Act, the Fair Housing Amendments Act, and Section 504 of the Rehabilitation Act. 2000 Lehon Court Warrensburg, Missouri Services Provided: Survey entirety of housing complex for the purpose of identifying architectural and program barriers in reference to the Americans with Disabilities Act, the Fair Housing Amendments ACt, and Section 504 of the Rehabilitation Act. Montgomery City Properties Montgomery City, Missouri Services Provided: Survey entirety of housing complex for the purpose of identifying architec~aral and program bardem in reforence to the Americans with Disabilities ACt, the Fair Housing Amendments ACt, and Section 504 of the Rehabilitation ACt. 2OOO Smithville Properties (Elderly) Smithville, Missouri Services Provided: Survey entirety of housing complex for the purpose of identifying architectural and program barfiem in reference to the Americans with Disabilities Act, the Fair Housing Amendments ACt, and Section 504 of the Rehabilitation Act. 2OOO The organizations listed above are only a sampling of recent consultation activities. Mr. Johnson has consulted with hundreds of public and pdvate organizations over the past 12 years regarding differing types of disability-related issues and disability-related laws. Speaking En;a;ements Mr. Johnson has provided training to more than 10,000 individuals on the technical provisions of the Americans with Disabilities Act, Fair Housing Amendments Act and other disability-laws and legislation in the form of keynote speaker, lectures, and workshops across the Nation with a focus on the central U.S. All organizations and associations that trainings have been provided to are too numerous to list; however a small portion of the entities having received training are listed below. Intemational Facility Management AssociaUon Iowa Amhitectural Institute of Amedca & Interior Design Annual Conference Iowa Building Code Officials Association of Kansas Building Code Officials Disability & Business Technical Assistance Centem Missouri Municipal League National Multiple Sclerosis Society Recreation Council of Greater St. Louis Regional ADA Symposium Conference Iowa League of Cities Missouri Library Association Missouri Job Service Employer Committee Missouri Department of Elementary and Secondary Education Annual Conf. United States General Services Administration Kansas City Research College of Nursing City of Springfield, Missouri Employees Missouri Department of Mental Health Training Institute Universal Design in Higher Education 2001 Annual Conference Johnson County Iowa ADA Symposium Missoud Assistive Technology Annual Conference Missoud Bar Association Society of Govemment Meeting Professionals 2001 Annual Education Conf. City of Prairie Village Police Investigation Personnel U.S. Depa~iment of Agriculture - Rural Development American Society of Plumbing Engineers U.S. Department of Housing and Urban Development Missouri School Plant Managers Association International Federal Management Association Institute for Inclusive Education Annual Conference HR Management Association of Salina, Kansas Stanley Architects, Muscatine Iowa Iowa League of Cities Annual Conference Iowa Human Rights Commission Annual Conference Missouri Association of Risk Managers University of Iowa School of Law National Council on Independent Living St. Louis Human Resource Management Association Midwest Labor Management Association Federal Depa~b~ent of Labor, General Services Administration 5~' Annual Conf. of the International Association of Human Rights Agencies Published Documents Mr. Johnson has written numerous articles and documents including one published book titled "Disability Management in the Workplace - Recruitment" and another book to be published this year titled "Disability-Related Employment Laws." These works are published by RPM Press, PO Box 31483, Tucson, AZ 85751. Technical ADA Related Education Mr. Johnson has received on-going education on the Americans with Disabilities Act and related Laws on a regular basis for the past ten years. The majority of the education he has received is not typically provided by educational institutions, such as state universities, where a degree or license is an end result. This type of formal education on the technicalities of the Americans with Disabilities Act and related laws is not available. Typically, Mr. Johnson is one of the few individuals in the central U.S. who provides such formalized classes, workshops and instruction on the ADA and related laws for state universities, community colleges, and other educational entities. Mr. Johnson's education has been partially obtained via on-going work shops, seminars, and intensive week-long subject specific trainings provided by federal enforcement agencies, of which, some are listed below. Mr. Johnson maintains regular contact with these and other federal or state enforcement agencies and organizations that produce technical materials or information pertaining to disability-rights laws. He maintains this contact to help ensure the provision of timely and accurate consultative information. Disability Rights Education and Defense Fund, Washington, DC U.S. Department of Justice, Civil Rights Division, Washington, DC American Bar Association, Washington, DC U.S. Equal Employment Opportunity Commission, Washington, DC U.S. Office of Housing and Urban Development, Kansas City, MO U.S. Access Board, Washington, DC U.S. Department of Education, Office of Civil Rights, Kansas City, MO U.S. Department of Education, Disability & Business Technical Asst. Cbs. U.S Department of Transportation, Office of Civil Rights, Washington, DC Missouri & Kansas Advocacy and Protective Services Missoud Commission of Human Rights U.S. Department of Labor, Washington DC President's Committee on Employment of People with Disabilities Community Activities Human Resource Association of Central Missoud Member - 1998 to Present Independent Living Resource Center Board of Directors President - 1995 to 2001 Indepen~dent Living Resource Center Community Activities (Continued) Board of Directors Past President - 2001 to Present Missoud Disability Rights Coalition Vice President- 1993 to 1994 Regional Advisory Council on comprehensive Psychiatric Services Board Member- 1994 to Present Mid-MO Barrier Free Housing for the Physically Handicapped Board Member- 1993 to 1995 Formal Education B.S. Southwest Missoud State College Psychology (Major) HR Management (Minor) Disability Management Consulting Group, LLC December 18, 2001 atLaw Kan.ms City, MO 64111 Dear Mr. Slough: I am writing in reference to the I Spr s Apartments complex, which I surveyed on November 20, 2001. You requested that I examine these buildings and facilities and provide a technical report on the level of accessibility and overall compliance with the provisions and regulation of the Americans with Disabilities Act (ADA), including the ADA Accessibility Guidelines (ADAAG) and the Fair Housing Amendments Act (FHAA), including the Fair Housing Aecess~ility Guidelines (FHAG). I have completed and enclosed an original Accessibility Survey Report pertaining to the 1 Springs Apartments complex. The purpose of this Report is to identif2¢ structural barriers at this apartment complex, which prohibit access to facilities, programs or activities by individuals with disabilities. The barriers listed in the Report were det,~mined according to ADAAG and FI-IAG. Although every effort was made to identify all existing barriers, some barriers may have been overlooked. Therefore, when determinations are made regarding barrier removal additional on-site inspection may be necessary. Each page of the following Access~illty Survey Report is made up of five separate sections. These sections are as follows: Area - the general area where the barrier was found; Description of Barrier - the exact barrier that was identified during the on-site survey; ADAAG/FHAG Requirements - ADA/ADAAG and FHA.SdFHAG regulations in reference to each barrier; Recommendations/Observations - additional comments regarding the barrier; and a final section which typically includes photos oftbe barrier and drawings, depictions or specifications pertsining to the appropriate regulation~ In addition to the following Access~illty Survey Report, I feel it is necessary to provide supplementary comments and observations here so that an overall understand~ is ~ly realized regarding the nature and severity of existing structmal barriers at the/ Springs Apartments. In my professional opinion, based on more than 12 years of surveying housing complexes and numerous other buildings and facilities for the purpose of determining compliance or non-compliance of pertinent disability-fights laws and related building guidelines, the buildings and facilities which make up the I Springs Apartments are highly inaecess~le to individuals with disabilities. Abundant architectural barriers exist to such 2801 Jonquil Place · Columbia, MO 65202-1278 Toll Free (866) 573-DMCG or (578) 817-5826 · AX (501) 325-9974 · E-Mail: DMCG@peoplelvc.com a high degree that many programs and services Provided by the / Springs Apartments are inaccessible to tenants, guests, and individuals from the general public with disabilities. Most ofthe barriers that are identified in the enclosed Accessibility Survey Report are easy to remove without much difficulty or expense. Many of the barriers listed in the Report are also safety hazards (such'as abrupt drop-offs at the sides of built-up curb ramps~ ) to individuals with disabilities and others who attest to make use of the buildings or facilities. Some of the barriers listed in the Report were the product of recent modifications. Therefore, not only is it disquieting to realize that the facility was either designed or constructed in a manner which does not comply with the ADA nor the FHA& but present modifications to structures are still being performed that do not comply with these federal laws. The ADA typically does not cover or require mnltifamily housing developments to meet the accessibility Provisions of ADAAG. However, public and common use spaces, such as rental offices and amenities such as restrooms, which are open to the general public (.people other than strictly tenants and guests), are considered "public accommodations" under Title Ill of the ADA. These areas at multifamily housing developments are required to meet ADAAG specifications. The new construction requirements specified by ADAAG apply to facilities first occupied a~er January 26, 1993 or for which the last application for a building permit or permit extension is certified as coa~lete after January 26, 1992. The public accommodations in the I Springs Apartments do not comply with these new construction requirements. All newly constructed facilities must comply with these new construction requirements unless it is "structurally impracticable" to do so. According to the Title m Technical Assistance Manual developed by the Department of Justice, the structurally impracticable exception is very narrow and should not be used in cases of merely hilly terrain. This exception should only be used in rare and unusual circumstances. According to the Fair Housing Design and Construction Requirements issued by the Department of Housing and Urban Development, Mnltifamily dwellings and common use areas pertaining to these dwellings which are first occupied after March 13, 1991 are required to be designed and constructed according to these Requirements unless it is "impractical" to do so because of the terrain or unusual characteristics of the site. There is no known evidence to indicate that the existing or pre-existing building site of the I spas Apartments would be considered impractical according to the FHAA or structurally impractical according to the ADA. Ill summary, the I Springs Apartments complex is highly structurally inaccessible to individuals with disabilities according to the regulations of the ADA and FHAA. In addition, this complex may also be covered by state or local building codes, which provide more stringent requirements pertaining to struc~ral accessib'flity. The information furnished in this letter, including attachments, is intended to be precise and accurate. However, this information is Provided with the understanding that the 2 Disability Management Consulting Group is not engaged in rendering legal advise and has no enforcement authority regarding ADA or FHAA compliance. Sincerely, Kent Johnson Operations Manager SUMMARY OF STRUCTURAL BARRIERS Spnngs Apartments 1. Upright signage showing the symbol of accessibility and van access~le signage does not exist at the accessible parking spaces serving the office and community rooms. (Accessibility Survey Report- Page #1). 2. The access aisle, at the accessible parking spaces serving the office and community rooms, is not clear and level with the vehicle parking spaces. (Accessibility Smwey Report - Page #2). 3. The asphalt curb ramp,, which protrudes into the access aisle at accessible parking serving the office and community rooms, is inaccessible and a safety hazard due to very steep side flares. (Accessibility Survey Report- Page #3). 4. Resident aceess~le parking spaces are not reserved by a sign showing the symbol of aceessibiIity. (Aeccssibility Survey Report- Page g4). 5. The built-up curb ramp, located in front ofUnit ~9, is too steep, projects into the access aisle, and has steep side flares. (Accessibility Survey Report - Page ~4). 6. Designated accessible parking for Unit #29 is not located on the shortest path of travel to the unit entrance. (Access~ility Survey Report - Page #5). 7. A curb without a curb cut exists on the pathway leading from the closest vehicle parking space to the entrance of Unit #29. (Accessibility Survey Report - Page #5). 8. The sidewalk leading to the east entrance of Unit #29 has a running slope greater than 1:20 and does not provide handrails on each side. (Accessibility Survey Report- Page #5). 9. Four separate pathways exist leading to the exterior entrances of Unit #29; all of these pathways are inaccessible due to steep running slopes, steep cross slopes, and/or a lack of handrails at ra ~mped surfaces. (Accessibility Survey Report- Page g45). 10. The slope of the ramps, leading directly to the entrances of the manager's office and eomm~mity room, are too steep (beyond 1:12). (Accessibility Survey Report- Page 11. The exterior ground and floor spaces, located directly in front o£ the manager's office and community room, are not level with the door thresholds and are not dear of obstructions. (Access~ility Survey Report - Page #7). 12. The exterior ran~, located directly in front of the entrances leading to the manager's office and community room, are safety ha?ards and inaccessible due to steep drop- offs on each side. (Access~illty Survey Report - Page #7). 13. The widths of all exterior doors at this housing complex are too narrow, measuring between 29-inches and 31-inches wide. (Accessibility Survey Report - Page #8). Summary of Structural Barriers Page 2 14. All entrances at the homing complex are inaccessible due to two doors in series without appropriate space between the doors. (Accessibility Survey Report - Page #8). 15. Appropriate maneuvering clearance does not exist at the exterior of primary entrances of numerous dwelling units. (Accessibility Survey Report - Page #9). 16. The public restroom serving the manager's office and community room in inaccessible due to numerous barriers. (Access~ility Survey Report - Page #10). 17. Doorknobs exist on all doors in the commuuity room and on all primary entry doors to the dwelling units that were surveyed. (Accessibility Survey Report - Page #11). 18. The community room offers exercise equipment to tenants on an inaccessl'ble lower level, which is accessible only by steps. (Accessibility Survey Report- Page #12). 19. The interior doorway widths of all dwelling units are too narrow, measuring 29- inches to 30-inches wide. (Accessibility Survey Report- Page #13). 20. Bathroom walls are not reinforced at required locations. (Accessibility Survey Report - Page #14). Accessibility Survey Report ~ Spnngs Apartments Lee's Summit, Missouri Prepared by Kent Johnson Disability Management Consulting Group L.L.C. 2801 Jonquil Place Columbia, MO 65202 Facility: ~ Springs Apartments, Lee's Summit, Misso~.; - November, 2001 Area Description of ADAAG/FHAG Requirements Barrier Exterior The accessible parking Accessible parking spaces shall be located on the shortest - space serving the Office accessible route of travel from adjacent parking to an accessible Parking md Community Rooms entrance (ADAAG 4.6.2). If parking spaces are provided for self- does not provide upright parking by employees or visitors, or both, then accessible spaces signage showing the complying with 4.6 shall be provided in each such parking area symbol of accessibility (ADAAG 4.1.2(5)). Aceessible parking spaces shall be designated and does not provide a as reserved by a sign showing the symbol of accessibility (see "van accessible" sign. ' 4.30.7). Spaces complying with 4.1.2(5)(b) shall have an additional sign "Van-Accessible" mounted below the symbol of aceessibillty. Such signs shall be located so they cannot be obscured by a vehicle parked in the space (ADAAG 4.6.4). One in every eight accessible spaces, but not less than one, shall be served by an access aisle 96" wide minimum and shall be designated "van accessible" as required by 4.6.4 (ADAAG 4.1.2(5)(b)). Recommendations/Observations ' ~?~x~;~ ~ ~ '~ ~ "~ currently no upright signage exists showing the symbol of access~ility and van aceess~le language. An upright symbol of accessibility and "van access~le" signage will need to be provided at the front of the vehicle parking space with the bottom of the sign at least 6 feet high to comply with ~DAAG parking signage spceificatlons. Access symbols on the parking surface (such ~s the existing symbol in the adjacent photo), sometimes required by local codes, are obscured by vehicles parked in the space and cannot substitute for post- or wall-mounted signage. (See ADAAG 4.30 for signage specifications). Photo showing the exterior front of the Office and Comm~lnt~y fac'dities. Note: Regulations cited ~om ADAAG or FHAG may not be exact quotes and may not provide a complete reference, so the actual regulation should be referred to when making physical modifications to facilities. 1 Accessibility Survey Report Facility: ~lm Sprin~ Apartments, Lee's Summit~ Missouri - November, 2001 Area Description of ADAAG/FHAG Requirements Barrier Exterior The existing access aisle, Parking access aisles shall be part of an accessible route to the which is adjacent to the building or facility enlrance and shall comply with 4.3. Parking access~le vehicle parldng Parking spaces and access aisles shall be level with surface space, is not level because slopes not exceeding 1:50 (2%) in all directions (ADAAG the asphalt ramp leading 4.6.3). Built-up curb ramps are permitted where they do not from the sidewalk projects project into vehicular traffic lanes or access aisles at parking into the access aisle, spaces and passenger loading zones (ADAAG Manual, page 37). Recommendations/Observations ADAAG requires that each accessible vehicle parking space provide an adjacent access aisle which is level with the vehicle park~g space. Access aisles are required to be as long as the parking space (ADAAG Manual, page 32). A maximum slope of 2% ~s required in all directions for both the larking space and access aisle. For this reason, built-up curb ramps cannot project into access aisles. As can be seen by the adjacent photo, the existing curb ramp does project into the access aisle. This complex could have easily been designed and constructed, with little or no additional expense, so that a fully aceess~le path of travel exists from accessible parking to the sidewalk level At this point in time the existing access aisle could be brought into compliance with ADAAG by removing the curb ramp and creating a sidewalk cut with opposing ramps leading to the sidewalk level or by restriping the parking lot so the existing curb ramp exists outside the access aisle. Other solutions for removing this barrier may also exist. See the adjacent ~hotos and drawings for more informatiox~ Example of compliant and usable access "~ aisle level with vehicle parking Note: Regulalloes cited from ADAAG or FI-IAG may not be exact quotes and may not provide a complete reforence~ so thc ~ regulation should be referred to when malting physical modifications to facilities. 2 Accessibility Survey Report Facility: ~ Springs Apartments, Lee's Summit~ Misson, i - November, 2001 Area Description of ADAAG/FHAG Requirements Barrier Exterior The asphalt curb ramp is If a curb ramp is located where pedestrians must walk across ' inaceess~le and a safety the ramp, or where it is not protected by handrails or Parking hazard due to very steep side gnardrails, it shall have flared sides; the maximum slope of the flares, flare shall be 1:10 (ADAAG 4.7.5). Recommendations/Observations According to ADAAG, ifa curb ramp is not protected by handrails or guardrails then it shall have flared sides with slopes no steeper than 1:10 (rise/mn = 1/10). The existing curb ramp is not protected by handrails or guardrails and the side flares are extremely steep with slopes much steeper than 1:10. The curb ramp does not comply with ADAAG specifications regarding flared sides and aecording to a publication by the U.S. Depat huent of Justice steep unprotected side flares are a safety hazard which may cause ~eople to trip and be injured (Common ADA Errors and Omissions in New Construction and Alterations, page 3). This complex could have easily been designed and constructed, with little or no ad 'daional expense, so that an appropriate access~le pathway leads from the aceess~le parking to the sidewalk level See the Adjacent photos for more detailed information. Example of an ADAAG comp ' built' -up curb ramp Note: Regolatien~s cited from ADAAO or FI-IAG may not be exact quotes and may not provide a complete reference, so the actual regulation should be refemxl m when making physical modifications to facilities. 3 Accessibility Survey Report Facility: ~ Springs Apartments~ Lee's Snmmit~ Missouri - November, 2001 Area Description ADAAG/FItAG Requirements of Barrier Exterior 1. Resident 1. A minimum of 2% of the parking spaces serving covered dwelling acoessibte units must be made accessible and located on an aceessible route to Parking parking spaces wheelchair users. Also, if a resident requests and aceess~le space, are not additional accessible parking spaces would be necessary if the two reserved by a percent are already reserved (FHAG- Requirement 2). Accessible sign showing parking spaces shall be designated as res~xved for physically the symbol of handicapped people by a sign showing the symbol of accessibility. accessibility. Such signs shall not be obscured by a vehicle parked in the space 2. The built-up (ANSI A117.1-1986, section 4.6.2). curb ramp 2. The slopes of curb ramps shall comply with 4.8.2 (ANSI A117. I- located at Unit 1986, section 4.7). The maximum slope of a ramp in new #9 is too construction shall be 1:12 (2 (ANSI A117.1-1986, section 4.8.2). steep. Recommendations/Observations 1. Under requirement #2 of the Fair Housing Accessibility Guidelines (FHAG) the ANSI Al 17.1-1986 is reference& The pertinent sections of ANSI are cited above. Signage showing the symbol of acoess~ility are readily available, easily installed and should have been provided at each aceess~le vehicle parking space at the time this facility was constructed. Also, additional accessible parking spaces should have been provided at the request of tenants with disabilities and these spaces should have a sign showing the symbol of accessibility. 2. The curb ramp located in front of Unit #9 spans a 4-inch rise and is only 29-inches in length. This is an extremely steep slope measuring an approximate 1:7.25 rise to run ratio. This steep slope is not only inaceess~le but is also a safety hazard to various in~viduals with disabilities. This built-up curb ramp and others located at this housing complex should be modified to conform to ANSI or ADAAO specifications. Appropriate sidewalk cuts could have easily and inexpensively been part of the facility design. Sec the adjacent photo for additional informafion~ Note: Regulations cited from ADAAG or FHAG may not be exact quotes and may not provide a complete referenceo so the actual regulation should be referred to whea making physical modifications to facilities. Photo of South parking area directly in front of Unit An upright sign showing the symbol of accessibility does not exist and the built-up curb ramp is inaccessible due to a very steep slope. 4 Accessibility Survey Report Facility: ~ Sorings Aoartments, Lee's Summit, Missouri - November, 2001 Area Description of Barrier ADAAG/FHAG Requirements Exterior 1. Designat~l a~cessible 1. Parking spaces designated for physically handicapped parking for Unit #29 is not people shall be located on the shortest possible Parking located on the shortest path accessible circulation rome to an accessible entrance of travel to the unit entrance, of the building (ANSI A117.1-1986, section 4.6.1)~ 2. A curb exists on the pathway 2. Entrances to a building or facility that are part of an leading fxom the closest accessible route shall be connected to accessible vehicle parking space to the parking (ANSI A117.1-1986, section 4.14). entrance of Unit #29. 3. Any part of an accessible route with a slope greater 3. The sidewalk lead'mg to the than 1:20 shall be considered a ramp and shall comply east entrance of Unit #29 has with 4.8. If a ramp has a rise greater than 6-inches or a slope greater than 1:20 and a horizontal projection greater than 72-inches, then it does not provide handrails shall have handrails on both sides (ANSI All7.1- on each side. 1986, section 4.8). Recommendations/Observations FI-IAG refers to ANSI A117.1-1986 for the standards to follow for public and common use areas at covered hous'mg complexes. ANSI requires that accessible parking be located on the closest possible accessible circulation route to the dwelling unit entrance. However, the accessible parking space serving Unit #29 is not located on the closest possible accessible circulation route because the closest possible route is inaccessible due to eithcx poor design or construction of the facility. Since vehicle parking is lomted directly in front of the east exterior entrance to Unit #29, this parking location should have been designated accessible with an accessible route leading to this entrance. However, since access~le parking was not designated at this loeation and harri~s were created (carhs, steep rannhg slopes, etc.) from parking to the entrance, the spirit, int~at, and letter of the Fair Housing Act were not followed. Other accessible parking does exist in the north parking lot serving Unit #29, but the pathway leading fi.om this parking to the front entrance is still not accessible due to steep slopes, lack of handrails, and steep cross slopes. Since all units at this complex are required to be accessible according to FHAA, a pathway leading to Unit #29 should be modified so that at least one accessible route leads to an entrance door. This access~le route should connect an eah~ance and the closest accessible parking space. A fully accessible route leading to the closest parking would have been easily and inexpensively incorporated into the original design and conatmotion ofthis facility. See the adjacent photos for mere information. Close-up photo of Unit 829 entrance and pathway Note: Regulations cited from ADAAG or FHAG may not be exact quotes and may not provide a complete reference, so the actual regulation should be referred to whma making physical modifications to facilities. Accessibility Survey Report Facility: ~ Springs Apartments~ Lee's Summit~ Missou. ~ - November, 2001 Area Description of ADAAG/FHAG Requirements Barrier Exterior Four separate pathways exist Covered muhifamily dwellings for first occupancy after march - which lead to the exterior 13, 1991 shall be designed and constructed to have at least one Common entrances of Unit #29. All building entrance on an accessible rome unless it is Areas of these pathways are impractical to do so because of the terrain or unusual inaccessible due to steep characteristics of the site. The burden of establishing running slopes or steep cross impracticality because of terrain unusual site characteristics is slopes and/or lack of on the person or persons who designed or constructed the handrails at ramped surfaces, housing facility (FHAG, Section 3 (§100.205 Design and construction requirements)). Recommendations/Observations FI-lAG refers to ANSI Al17.1-1986 for the standards to follow for public and cormnon uso areas at covered housing complexes. ANSI requires handrails on any ramps that are part of an accessible path of travel. ANSI also requires that a ramp not exceed a llmnlng slope of 1:12 and nowhere shall the cross slope of an accessible route exceed 1:50. There is no pathway leading to Unit #29 that meets all of these specifications as can be seen from the adjacent photos. In addition, a new sidewalk has been constructed leading from the mailbox closest to Unit #29. The running slope of this newly constructed sidewalk is steeper than 1:20 and handrails do not exist. A portion of this newly constructed sidewalk also has a steep cross slope (steeper than 1:50). Therefore, not only was the facility orJ~nally designed and/or constructed in a non-compliant manner (according to FHAA), but recent modifications still do not meet appropriate specifications, which define accessibility. Refer to the previous page for additional observations and recommendations regarding an accessible pathway leading to Unit #29. See the adjacent photos for more details. Steep pathway with no handrails leadinoo from Unit #29 to other commoll Steep pathway with no handrails leadlno~ from Unit ~29 to north parking. Recently constructed sidewalk leading from mail boxes to Unit #29 Note: Regulations cited from ADAAG or FIIAO may not be exact quotes and may not provide a complete reference, so the actual regulation should be referred to whan making physical modifications to facilities. 6 Accessibility Survey Report Facility: ~ Springs Apartments, Lee's Summit, Missouri - November, 2001 Area Exterior Common Areas Description of Barrier 1. The slope of the ramps leading to the entrances of the Manager's Office and Comm~ty Room arc too steep. 2. The exterior of the entrance doors to the Manager's Office and the Comm~mity Room are not level with the door thresholds and are not clear of obstructions. 3. The exterior ramps at the entrances to the Manager's Office and the Community Room have steep drop- offs on each side. ADAAG/FHAG Requirements 1. The least poss~le slope shall be used for any ramp. The maximum slope of a ramp in new construction shall be 1:12 (ADAAG 4.8.2). 2. Minimum maneuvering clearances at doors that are not automatic or power-assisted shall be as shown in Fig. 25. The floor ground area within the required clearances shall be level and clear (ADA. AG 4.13.6). 3. Ramps and landings with drop-offs shall have curbs, walls, railings, or projecting surfaces that prevent people from slipping off the ramp (ADAAG 4.8.7). Recommendations/Observations According to the ADA, the minimum number of acoeSsl'ble public building or facility eaWances must equal or exceed the number of required exits or 50% of the number of public entrances, whichever is grcetia' (Scop'mg O. 1.3(8) ADAAG Manual). S'mee the underlying intend of the ADA is to help mainstream individuals with disabilities, ADAAG scoping provisions and specifications tcad ensu~ that buildings and facilities are constructed so that people with disabliities use the facilities in the same or similar manner as does the general public. The~ore, the ADA requires that eatrances intended to serve a majority of visitors or empfoyees be part of the rn]nlm~an lllllllbor ~ accessible (Primary Entrances (4.1.3(8) ADAAG Manual). In order for the cnl~nces at the Mimager's Office and Community room to be accessible, level and unobstructed maneuvering clearances will need to exist on the exterior of each door. NOt only do the exisling ramps impede this required clear space, they are also safety hazards due to the steep drop-offs an eech side ead they are too steep, well beyond the ADAAG maximum of 1:12. (Ibc existing ramps span a 3 ~- inch height and are only 20-1riches long orang ~m ~i,pl,,ximate slope of 1:5.3). See the adjacent drawing See the edjaceni photo for more visual datals. Since the facil'r;y was either not designed or consWacted to c~nply with the ADA, it may now require considerable altoratians and expense to provide the appropriate clear and level space at thc~e Drawing shows the minimmn dimensions required by ADAAG ~t the pull side of an accessible entrance door. · . Note: Regulations cited from ADAAG or FI-LAG may not be exact quotes and may not provide a complete refarence, so the actual, regulation should be refe~rred to whan m~king physical, modifications to facilities. 7 Facility: Accessibility Survey Report Springs Apartments~ Lee's Summit, Missou.; - November, 2001 Area Exterior Common Description of Barrier 1. The width of all exterior doors is too narrow, measuring between 29- inches to 31-inches wide depending on the particular door measured. Exterior doors that were measured include entrances leading to the Manager's Office, Commnnity Room, Unit #29, Unit #8, Unit #44, and Unit g43. The entrances to all common areas including the Manager's Office, Community Room, Unit #29, Unit #8, Unit #44, and Unit ~M3 consist of two doors in series with only 3- inches to 4-inches between the doors. ADAAG/FHAG Requirements 1. Doorways shall have a minimum clear opening of 32 inches with the door open 90 degrees (ADAAG 4.13.5). Covered multifamily dwellings with a building entrance on an accessible route shall be designed in such a manner that all doors designed to allow passage into and within all premises are sufficiently wide to allow passage by handicapped persons in wheelchairs. On accessible routes in public and common nsc areas, and for primary entry doors to covered units, doors that comply with ANSI 4.13 would meet this requirement (FHAG, Requirement 3 (§100.205©(2)) usable doors). Doorways intended for user passage shall have a minimum clear opening of 32-inches (ANSI Al17.1-1986, section 4.13.5). 2. The minimum space between two hinged doors in series shall be 48 inches plus the width of any door swinging into the space (ADAAG 4.13.7). The minimum space between two hinged or pivoted doors in series shall be 48-inches plus the width of any door swinging into the space ANSI A117.1-1986, section Recommendations/Observations 1. The ADA requires the entrances to public accommodations (facilities which are open to the general public) be fully accessible. The FHAA requires the entrances to common areas and covered dwelling units to be fully accessible. Both laws provide identical minimum specificafians to determine the access~ility and usability of a door. An access~le door provides at least 32-inches of clear passageway space. The entrance doors at this housing complex do not meet this mlnlm~ml requirement. Appropriate and compliant door frames could have been easily and inexpensively installed. 2. The screen doers oo the exterior of common ereas and dwelling units create two doors in series with a very small space between the screen door and the interier door. This requirement exists so that individuals with various r disabilities are only required to manipulate one door at a \ time. Adhering to the above specifications regarding doors in series is critical for safe egress in emergency situations. This berri~x could be removed by replacing the serean doors and interior doors with one exterior entrance door. See the adjacent photo and drawing for more infrnnnation. l~ote: Regalations cited fxom ADAAG or FtlAG may not be exact quotes and may not provide a complete referco~e, so the actual regulation should be referred to when making physical modifications to fadlities. ADAAG Specificafiot Accessibility Survey Report Facility: ~ Sorings Apartments~ Lee's Summit~ Missouri - November, 2001 Area Description of Barrier ADAAG/FHAG Requirements Exterior Appropriate maneuvering Covered multifamily dwellings with a building entrance - clearance does not exist on the on an accessible route shall be designed in such a manner Common exterior of primary entrances to that all doors designed to allow passage into and within all Areas numerous dwelling units, premises are sufficiently wide to allow passage by handicapped persons in wheelchairs. On accessible routes in public and common use areas, and for primary entry doors to covered units, doors that comply with ANSI 4.13 would meet this requiremeut (FHAG, Requkement 3 (§100.205©(2)) usable doors). Minimum maneuvering clearances at doors that are not automatic or power- assisted shall be as shown in Fig. 25. The floor ground area within the required clearances shall be level and clear (ANSI Al17.1-1986, section 4.13.6). Recommendations/Observations As can be seen fi.om the adjacent photos, appropriate maneuvering clearance at primary entrance doors to dwelling units would have been easy and inexpensive to incorporate into the design and construction of this housing complex. The maneuvering clearances at entrance doors do not even meet the minimum requirements of the FHAG or ANSI. Both of these documents recommend more stringent specifications than the minimum requirements to meet the needs of individuals with differing types of disab'flifies. See the Adjacent drawing for FI-lAG/ANSI specifications. Drawhig shows the minimum dimensions required by FHAG/ANSI at the pull ~ide of an ..accessible entrance door. Note: ~ons cited from ADAAG or FHAG may not b~ exact kluotes and may not l~SV~de a complete refe~ence~ so the actual regnlAtlon should be referred to when making physical modifications to facilities. 9 Accessibility Survey Report Facility: ~ Springs Apartments, Lee's Summit, Missouri - November, 2001 Area Description of ADAAG/FHAG Requirements Barrier Public Thc public restroom, If toilet facilities are provided on a site, then each such public Restroom serving the Manager's or common use toilet facility shah comply with 4.22 (ADAAG Office and Community 4.1.2(6)). Handles, pulls, latches, locks, and other operating Room is inaccessible due to devices on accessible doors shall have a shape that is easy to numerous barriers including grasp with one hand and does not require fight grasping, tight but not limited to the pinching, or twisting of the wrist to operate (ADAAG 4.13.9). following: a door knob Faucets shah comply with 4.27.4. Lever-operated, posh-type, exists on the entrance door, and electronically controlled mechanisms are examples of knobs exist on the lavatory acceptable designs. If self-closing valves are osed the faucet faucet controls, appropriate shall rema'm open for at least I0 seconds (ADAAG 4.19.5). ). knee clearance does not A clear floor space of at least 30" by 48" complying with 4.2.4 exist under the lavatory due shall be provided in front of a sink to allow a forward to cabinets, the entrance approach. The clear floor space shall be on an accessible door swings into the clear route and shall extend a max/mum of 19" underneath the sink floor space required for the i (ADAAG 4.24.5). All doors to accessible toilet rooms shall lavatory, the water closet ~ comply with 4.13. Doors shall not swing into the clear floor I flush control valve is space required for any fixture (ADAAG 4.22.2). Flush mounted on the wrong side, controls shall be hand operated or automatic and shall comply appropriate clear floor with 4.27.4. Controls for flosh valves shall be mounted on the space does not exist at the wide side of toilet areas no more than 44 in (1120 mm) above water closet due to cabinets the floor (ADAAG 4.16.5). Clear floor space for water closets under the lavatory, and the not in stalls shah comply with Fig. 28 (ADAAG 4.16.2). Grab grab bar at the rear of the bars for water closets not located in stalls shall comply with water closet is too short at 4.26 and Fig. 29. The grab bar behind the water closet shall 24-inches long. be 36 in (915 mm) minimum (ADAAG 4.16.4). Recommendations/Observations In orde~ to economically and expediently process this survey report the specifications of an accessible res~oom, as defiued by ADAAG will not be discussed here in detail. Currently, tlfis public restroom is highly inaccessible with numerous barriers, all of which could have ms'fly and inexpensively beea incorporated into the design and construction ofthis facility. However, sincethe facility was not designed and/or constructed to comply with the ADA, it may now be both difficult and expensive to alter the restroom so that it fully complies with the appropriate specifications and is accessible to tenants and their guests er individuals from the gme~l public. Note: Regulations cited from ADAAG or FHAG may not be exact quotes and n~ the actual regulation should be referred to when making physical modifications to facilities. 10 Accessibility Survey Report Facility: ~ Springs Apartments~ Lee's Summit~ Missouri - November, 2001 Area Description of Barrier ADAAG/FHAG Requirements Interior Doorknobs exist on all doors in the Covered multifamily dwellings with a building - Community Room and all primary entry entrance on an aceess~le route shall be designed Common doors to the dwelling units that were in such a manner that all doors designed to allow Areas surveye& passage into and within all premises are sufficiently wide to allow passage by handicapped persons in wheelchairs. On accessible routes in public and common use areas, and for primary entry doors to covered units, doors that comply with ANSI 4.13 would meet this requirement (FHAG, Requirement 3 (§100.205©(2)) usable doors). Handles, pulls, latches, locks, and other operating devices on accessible doors shall have a shape that is easy to grasp with one hand and does not require tight grasping, tight pinching, or twisting of the wrist to operate (ANSI Al17.1- 1986, section 4.13.9). Recommendations/Observations According to FHAG, doors in public and common use areas and primary entry doors of covered dwelling units must meet more stringent requirements for access~ility than doors that are located inside each dwelling unit. FI-lAG refers to ANSI Al17.1-1986 for the standards to follow for public and common use areas at covered housing complexes. Door hardware consisting of round knobs are not considered to meet the above cited ANSI specifications because they require tight grasping and twisting of the wrist to operate. Lever-type hardware is readily available and easy to install. See the adjacent photos for more details. Rotmd door knob Note: Regulations cited from ADAAG or FHAG may not be exact quotes and may not provide a complete re fe~ence, so the acVaal regulation should be referred to whe~ making physical modifications to facilities. 1 1 Accessibility Survey Report Facility: --Springs Apartments, Lee's Summit, Missou, ~ - November, 2001 Al'~a Interior Consnson Description of Barrier The Comnsunity Room offers exercise equipment to tenants on a lower level. The only route of travel to this exercise room is via stairs. ADAAG/FHAG Requirements Whenever only one type of reereational facility is provided at a particular location on the site, it must be accessible and connected by an accessible route to the covered dwelling units (Fair Housing Act Design Manual, page 2.7). Stairs shall not be part of an accessible route (ANSI A117.1-1986, section 4.3~8). Recommendations/Observations According to FItAG and ANSI, a stair can never be part of an aecess~le route, i.e., a stair can never interrupt or be part of the ~ath of an access~le route. Elevators, ramps, and mechanical litts, however, can be part of an access~le route. Therefore, installing an elevator, ramp, or mechanical litt to this lower level in order to provide access to the exercise equipment are alternatives for removing this barrier. However, other, non-stmctaral, solutions may also exist. For example, providing similar exercise equipment on the upper level, which oouid be located on an accessible route, is another barrier removal solution. Once again, incorporating a fully accessible exercise room into the original design and construction of the facility would have been easy and inexpensive, and may actually have been less expensive than digging a lower leveL See the adjacent ~hoto for more details. Note: Regulations cited from ADAAG or FI-IAG may not be exact q es mayno prom eacomp re erence~ so the actual regulation should be referred to when making physical modifications to facilities. 12 Accessibility Survey Report Facility: iffill Sorings Aoartments, Lee's Summit, Missouri - November, 2001 Area Description of Barrier ADAAG/FHAG Requirements Dweilin~ The interior doorway widths of all Within individual dwelling units, doors intended Units - dwelling units are too narrow at 29- for user passage through the unit which have a Interior inches to 30-inches wide. clear opening of at least 32-inches nominal width Note: Only certain doors were measured when the door is open 90 degrees, measured in Units #8, g44 and #43. However, the between the face of the door and the stop, would on-site manager stated that all units were meet this requirement (FHAG, Requirement 3 identical in reference to doors and size (§ 100.205©(2)) usable doors). and arrangement of interior spaces. Recommendations/Observations Usable doors which are required to be accessible include aH passage doors within covered dwelling units, such as doors between rooms, doors into walk-in closets, and doors into ufiYay/storage rooms or rooms that contain washers and dryers. These interior doors must meet different access~ility standards than common use and primary entrance doors. For example the interior doors must be a nominal 32- inches clear width. In other words, the doorway width may vary from the 32-inch clear width by a nominal of small mount. Tolerances of ¼-inch to 3/8-inch are an acceptable range. This tolerance does not apply to common use and primary entrance doors. However, even with the allowed tolerances, the interior doors of dwelling units still do not meet the minimum specifications for clear width inorder for the doors to be considered accessible and usable. Once again, it would have been inexpensive and easy to incorporate fully access~le doors into the original design and construction of these dwclYmganits. See the adjacent photo and drawing for more details. Required interior doorway width ~. Note: Regtflafions cited from ADAAG or FHAG may not be eomct quotes and may not provide a complete reference, so the actual regulation should be referred to whea making physical modifications to facilities. ~ ,. Accessibility Survey Report Facility: ~ Springs Apartments~ Lee's Summit~ Missouri - November, 2001 Area Description of Barrier ADAAG/FHAG Requirements Dwelling Bathroom walls do not appear Covered multifamlly dwellings with a building entrance on Units - to be reinforced at required an aocess~le route shall be designed and constructed in such Interior locations at ~es. a manner that all premises within covered multifamily dwelling units contain reinforcements in bathroom walls to allow later installation of grab bars around toilet, tub, shower stall and shower seat, where such facilities are provided (FHAG, Requirement 6 (§ t00.205©(3)(ii0) Reinforced walls for grab bars). Recommendations/Observations FHAG provides two specifications to design bathrooms. In both specifications reinforced walls at certain fixtures are required. Bathroom walls must be sufficiently strong to allow the later installation of grab bars for resident use. The bathroom layout (floor plan) in the existing dwelling units is similar to the adjacent drawing. The adjacent drawing shows various specifications and dimensions, including the locations of required wall reinforcements. Since the on- site manager would not allow drilling tiny holes into the specified locations, a tapping procedure was utilized to determine if reinforcement existed. The tapping procedure did not produce differing sounds at required reinforcement locations as opposed to non-required locations. Therefore, it was determined that reinforcement does not exist. Note: Regulations cited from ADAAG or FHAG may not be exact quotes and may not pro~ide a complete reference, so the actual regulation should be referred to when malting physical modifications to facilities. 14