Americans with Disabilities Act Compliance Plan

City of Columbia TDOT ADA Transition Plan

The City of Columbia has been working on a transition plan that will reflect the results of the survey that is in progress to determine which the five sections (called Titles) in ADA: Employment (Title I), Public Services and Transportation (Title II), Public Accommodations (Title III), Telecommunications (Title IV), and Other Provisions (Title V) require improvement.

Our early work suggests that both programmatic and architectural barriers to persons with disabilities interested in accessing the City of Columbia's programs and service exist. The City has inventoried our facilities, walkways and streets to compile a list of things that need to be addressed to enable the citizens of Columbia with a disability to be provided the same programs and services as other citizens.

Although a number of steps have been taken to ensure compliance with Title I of the ADA, such as policies and procedures to request accommodations, policies on discrimination and harassment, the establishment of the ADA coordinator, established complaint procedure and training for new employees during the onboarding process, additional steps are necessary. The City has reviewed the recruitment process and written guidelines have been developed and will be widely disseminated to all hiring authorities after Council approves a charter revision. The establishment of an accommodation committee with disabled citizens and more training are currently being worked on. Each aspect of employment must be conducted without bias or discrimination towards disabled individuals.

The City created a task force with representation from each department to perform the study and inventory facilities and program accessibility weaknesses. The ADA Task Force was established and charged with developing a self-evaluation instrument. The Task Force meets regularly as needed throughout the year to monitor compliance issues as identified in this report.

The Parks and Recreation Department offers most of the City's events and programs. They have inventoried all of the 21 parks within the City. The outdoor pavilion at Cook Soccer Park has been completed with ADA accessibility to pavilion and field 5. Completed accessibility to two restrooms and parking at Cook. Splash Pad at Riverwalk Park was made ADA accessible with an outdoor path. In addition, Riverwalk Park, Betty Lee Park and Ridley Park are ADA accessible. Woodland Park playground and playground

pavilion is ADA accessible along with the Parks and Recreation office, entrance and parking at the Rainey House (office) Fairview Park has one ballfield accessible and the Fairview Center has an accessible entrance, kitchen and restrooms.

The remaining parks have been assessed and based on what is required, establish a priority list that includes but is not limited to, provision of adaptive equipment, reassignment of services to accessible buildings, provision of auxiliary aids and services, delivery of services at alternate accessible sites, or the alteration of existing facilities.

The following still need to be addressed:

Parks and Recreation

All other City departments have surveyed their buildings and facilities and established a list of areas to be addressed. The codes enforcement department is assisting with this process.

Police Department

Fire Station 1

Fire Station 2 – Lion Parkway

Fire Station 4 - Trotwood

Fire Station 5 – Nashville Highway

City Hall

Wastewater

Public Works

Streets and Sidewalks

Public Works has been bringing projects into compliance upon reconstruction. All established sidewalks are being evaluated for needed improvements. A list of these improvements has been compiled. The prioritized projects are addressed as funding becomes available and based on the schedule provided.

The Engineering department maintains a pavement management system which contains an inventory of all City streets, and each year determines which projects will be funded.

1. and appropriate number of spaces

Projects continue to be addressed as funding is available. Yearly planning for the highest priority projects should continue with the budget process.

Many City buildings were constructed prior to the enactment of access codes and were not originally designed to provide ready access for individuals with disabilities. While facilities constructed in more recent years have differing degrees of accessibility, various features within them are deficient as a result of changing code provisions. Some structures, however, have undergone remodeling and alterations and consequently do comply more fully with current standards. In general with respect to City facilities that were reviewed, there is at least one route into most buildings and a considerable number of the public facilities and programs within them are accessible to some degree by current standards. An evaluation of exterior passage ways among City buildings, including such features as curb ramps, walks and sidewalks, handrails, and contrasting striping on stairs, has revealed some areas that are deficient as accessible routes. Additional work is needed to remove the remaining obstacles to program accessibility found among features such as restrooms and other specialized use areas.

Accessibility is not only for individuals with needs related to mobility disabilities, but also for individuals with needs related to speech, cognitive, vision and hearing disabilities. There are many potential barriers to accessibility of City services, and the following are simply a few of the more common examples:

Physical Barriers

A public entity may not deny the benefits of its programs, activities, and services to individuals with disabilities because its facilities are inaccessible. A public entity's services, programs, or activities, when viewed in their entirety, must be readily accessible to and usable by individuals with disabilities. This standard, known as "program accessibility," applies to all existing facilities of a public entity. Public entities, however, are not necessarily required to make each of their existing facilities accessible.

Criteria for Determining Existence of Impediment

Criteria have been established to determine whether corrective action needs to be

taken at a particular facility. The criterion includes, but is not limited to:

1. The nature of unique programs or services. Some facilities and sites are the

   only location that a particular program or service may be provided; so there

   is limited flexibility to move the program or service to a more accessible facility.

2. Facilities already in compliance with ADA accessibility guidelines. Several of the City's major facilities were constructed or underwent major renovations after the effective date of the ADA, including City Hall, the Police

   Department, Fire Station #2 and the Public Works Facility.

3. Ability to relocate programs from one facility to another accessible facility. Because the City may offer special programs and services at more than one location, consideration was given to distribution of the special programs and services when viewed in their entirety;
4. Current state of accessibility. The current condition of each facility in terms of barriers already removed, or planned to be removed.
5. Cost. The cost of alternatives to physical barrier removal versus the cost of an alternative corrective action plan; and public use.

f)   Population Served. The population served by a particular program or service and whether the public can obtain service from an alternative City location.

Projects are prioritized based on the sidewalks level of use, project cost, and potential to improve overall City connectivity. Sidewalk improvement projects will be implemented as funding is identified, or in association with other City projects that necessitate construction in the City street right-of-way or on City property.

Action Plan

Through these self-evaluations, deficiencies in the City of Columbia's facilities that diminish the ability of disabled persons to benefit from the City's programs, services and activities have and will continue to be identified. For those buildings that have had an assessment, a correction plan or other course of action has been noted for each deficiency, along with a schedule for completion of the correction.

An Action Log has been created for those facilities that have not yet been addressed.

PROGRAMMATIC BARRIERS

The City recognizes not all barriers to the City's programs, services and activities are physical in nature. Other administrative barriers exist that must be overcome to provide complete government services to those who are disabled. The City conducted a self-survey of all City Departments to identify any programmatic barriers that may impact accessibility of City programs, services or activities.  Those items identified are included in other established listing for correction.

Survey Results

The City of Columbia conducted a detailed survey to evaluate each department in the City with regard to ADA compliance. The purpose of this exercise was to identify areas where the City falls short in accommodating people with disabilities.

The majority of City departments interact with the public outside the confines of a public facility. For example, the Police, Fire and Public Works Departments generally interact with the public in the field. As a result, the employees in many cases are forced to adapt to situations that arise in the field. For example, in responding to a call or incident, the physical or mental health of the person needing assistance is not necessarily provided through dispatch. As a result, those responding may need to modify the approach for resolving the issue.

The City departments that have the most routine contact with the public at a City facility are Development Services, the City Recorder's Office, Personnel, and Parks and Recreation.

The Development Services Department handles all permitting and inspections in the City and thus has a significant amount of public traffic. The City Recorder's Office handles billing, business licensing, permitting and taxes, which also results in high volumes of people accessing a City facility on a daily basis. It is estimated that a very small percentage of the public that is dealt with on a regular basis has no obvious disabilities. However, each of these departments is committed to providing quality service to all residents in the City and is taking the necessary steps to confirm that they provide their service in a manner that is accessible to all residents.

The Parks and Recreation Department has the most regular contact with residents in the City. This department provides numerous programs for all ages. This department is similar to other city departments in that there is no formal policy in place for accommodating participants with disabilities. However, the department strives to make programs available for anyone to participate. Generally, each case is handled independently and the appropriate accommodations have been made.

Action Plan

Based on the results of the self-surveys, the City will identify future steps and activities that the City can explore to ensure that people with disabilities have access to City services and programs. The City's future plan must address the following elements:

Communication

Effective communication is essential to providing accessible services in that whatever is written or spoken must be as clear and understandable to people with disabilities as it is for people who do not have disabilities. The City used many

forms of communications with residents including the web site, communications relating to City administration and open public meetings, and other communications regarding the City's programs, services and activities. In order to ensure that all forms of communication are accessible, the City is taking specific actions to improve communications, including the following:

1. ADA Grievance Policy and Procedures. The City has developed a formal Grievance Policy and Procedure for ADA compliance. This document will be made available on the City's website and by contacting Personnel.
2. Reasonable Modification Policy. The City has will work with individuals to determine an accommodation that meets the needs of the citizen/employee and the City without creating a hardship.
3. Public Information. All forms of public communication about City programs and activities must address ADA compliance issues specific to the program or activity. In order to ensure that public communication has the appropriate verbiage/statement regarding ADA compliance, they must be approved by the ADA coordinator.
4. Agenda text. The City posts the agenda to the website so that disabled persons can enhance the size of the print, and in the Council Chambers, all agenda items are displayed on large TV screens in a PowerPoint presentation so citizens can more easily read the items.
5. Accommodations for participation in Public Meetings. The City will research the feasibility of incorporating equipment, available upon request, specially designed to assist hearing impaired persons to fully participate in City Council Meetings. The City will explore the feasibility of acquiring other aids or services.
6. Accessibility of Public Meetings. The City has, as discussed above, already taken substantial efforts toward ensuring public meetings are held in ADA-accessible facilities. The City conducts all public meetings in ADA accessible facilities, and to the extent feasible will make specific accommodations, where necessary, to ensure that meetings among residents and City staff can be held within ADA accessible facilities.
7. Accessibility of Phone Communication. All City departments are equipped with TTD phone line (s).
8. Interpreter Services -The City will hire an interpreter when advance notice is given and all departments have access to the AVAZA language line.
9. ADA Compliance in Legal Documents. The City includes appropriate ADA compliance language in all legal documents including, but not limited to: contracts, request for proposals, requests for qualifications, bid requests, job advertisements, and public notices.

10. ADA Compliance for Hiring Procedures. The ADA Compliance officer will review the application, interview and hiring procedures within each department of the City to ensure compliance with ADA.

Municipally Sponsored Programs

The City is committed to allowing persons with disabilities to participate in municipally sponsored programs. This includes recreation opportunities sponsored by the City's Parks and Recreation Department, community meetings and other events hosted or sponsored by the City. The City will achieve this goal by integrating all of the steps outlined above into these programs, including providing for effective communications and ensuring meeting and events are, to the extent possible, held in ADA-accessible parks and facilities. The City is taking additional specific actions to improve accessibility, including the following:

1. Formal ADA Recreational Policy: The Parks and Recreation Department will develop a formal policy for accommodating disabled persons, where feasible. The City will look into adding a handicap accessible lift at the public pool, and has historically allowed disabled children to participate in City sponsored recreational programs on a case by case basis. However, a formal policy has not previously been established. It shall be the City's policy not to discriminate again disabled persons wishing to participate in a City-sponsored recreational activity, and as such, the City will do their best to accommodate all participants.
2. Accessible Vehicle Transportation: Departments that operate transportation vehicles for the public include Parks and Recreation and Police. Neither department currently has a handicap accessible vehicle. At least one handicap accessible vehicle should be purchased by the City, or be made available to rent at short notice for use by these departments
3. Backdoor Trash Pickup: The city provides backdoor trash pickup for elderly or disabled residents who are unable to bring their bin to the curb. This service is advertised publicly though alternate forms of communication to ensure that disabled residents are aware of the service.

Training for City Staff on ADA Compliance

In order to ensure effective implementation of this plan, and to afford staff with the tools necessary to provide better accessibility, the City will provide the following training on the following topics for staff:

1. ADA Transition Plan training for all City staff
2. Specialized training for field staff who may deal with the public as part of their job duties.
3. ADA Coordinator training