Under the agreement, Marriott will implement policies requiring: (1) that accessible rooms will not be reserved for non-disabled persons unless all other rooms in a facility have been reserved and accessible rooms are the only ones available; (2) that the central reservations office will be able to guarantee accessible rooms for any Courtyard hotel at a customer's request, provided such rooms are available; (3) that Marriott's Guest Relations Office will maintain a list of accessible rooms at all Courtyard hotels and will keep the list updated; and (4) that employees at all Courtyard facilities will receive training so that they are generally familiar with the obligations of places of lodging under the ADA.

Additionally, Marriott will undertake substantial barrier removal in the parking area, two public restrooms, and guest rooms at a Courtyard by Marriott facility about which we received a complaint, and will purchase equipment to make five additional rooms at that facility accessible to persons with hearing impairments. The complainant alleged that although he and his wife, who has a disability and uses a wheelchair, were guaranteed an accessible room at the facility, they were assigned to an inaccessible room and hotel staff did not offer them adequate assistance with finding suitable accommodations elsewhere. Marriott will pay the complainants $10,000 in compensatory damages and will pay a civil penalty of $7,500.

SETTLEMENT AGREEMENT

BETWEEN THE UNITED STATES OF AMERICA,

MARRIOTT INTERNATIONAL, INC.,

AND COURTYARD MANAGEMENT CORPORATION

UNDER THE AMERICANS WITH DISABILITIES ACT

BACKGROUND

1. This matter was commenced when David Williams, a resident of Oklahoma, filed a complaint with the Public Access Section (now known as the "Disability Rights Section") of the Civil Rights Division of the United States Department of Justice, claiming that the Courtyard by Marriott Hotel located at 6015 East Park Avenue in Memphis, Tennessee ("the Park Avenue East Courtyard"), had violated title III of the Americans with Disabilities Act of 1990 ("ADA"), 42 U.S.C. §§ 12181-12189, and the Department of Justice's title III implementing regulation, 28 C.F.R. Pt. 36. The complaint stated that although Mr. Williams was told that the room he reserved at the Park Avenue East Courtyard would be accessible to his wife, Mary Ann Williams, who has a disability and uses a wheelchair for mobility, the room to which he and his wife were actually assigned, room 107, was not accessible. Specifically, Mr. Williams alleged that the room's doors were too narrow; that there were no grab bars at the toilet; that the grab bars in the shower were inadequate; and that furniture in the room was configured in such a way as to make the room inaccessible to individuals who use wheelchairs.
2. The investigation of this matter revealed that room 107 is not one of the eight rooms that have been designated as "accessible" at the Park Avenue East Courtyard. Marriott International and the Park Avenue East Courtyard maintain that although the hotel had a room designated as "accessible" when Mr. Williams made his reservation, room 109, and intended to assign this room to Mr. and Mrs. Williams, an error by a hotel employee who allegedly entered the wrong number into the hotel's reservations system resulted in the Williams' being assigned to room 107 instead. The Department maintains that no attempt was made to determine whether there were non-disabled guests staying in any of the designated "accessible" rooms on June 16, 1993, who could be relocated to room 107 so that the Williams' could be assigned to an accessible room in the same facility. The Department further maintains that the Williams' did not investigate whether an "accessible" room was available at the Courtyard by Marriott hotel at the Memphis airport, after they were told by an employee at the Park Avenue East Courtyard that "accessible" rooms at that facility were designed in the same manner as room 107 at the Memphis Courtyard. Instead, an employee from the Park Avenue East Courtyard attempted to make a reservation for Mr. and Mrs. Williams at another hotel in the Memphis area. Mr. and Mrs. Williams went to this facility, but found that the designated "accessible" room did not meet their needs. Mr. and Mrs. Williams ultimately found an accessible room which met their needs, located several miles from the Park Avenue East Courtyard.
3. The investigation further revealed that at the time Mr. Williams made his reservation at the Park Avenue East Courtyard, the central reservations office for Courtyard by Marriott facilities did not maintain a list of those rooms designated as "accessible" and had insufficient policies or procedures to ensure that accessible rooms would be available to customers who sought to reserve them.
4. The investigation further revealed that two employees in Marriott International's Guest Relations Department to whom David Williams spoke by telephone on June 16, 1993, were unable to identify room 107 at the Park Avenue East Courtyard as inaccessible when Mr. Williams described its physical characteristics. Employees in the Guest Relations Department did not maintain a list of rooms at Courtyard facilities that were accessible.
5. On October 3, 1994, staff from the Department of Justice conducted a site investigation of the Park Avenue East Courtyard. It revealed that several barriers to access exist in the facility's parking area, common areas, and its guest rooms. A list of those barriers to access discovered during the site investigation is attached to this agreement as "Exhibit A" and is incorporated by reference as part of this agreement.
6. The October 3, 1994 site investigation also revealed that the Park Avenue East Courtyard has auxiliary aids on the premises sufficient to make significantly fewer rooms accessible to persons with hearing impairments than would be required in a comparably-sized facility that qualifies as "new construction" under the ADA.

PARTIES

7. The parties to this agreement are the United States of America, Marriott International, Inc. ("Marriott International"), and Courtyard Management Corporation, a wholly owned subsidiary of Marriott International.
8. Marriott International is incorporated under the laws of the state of Delaware and has its principal place of business at 10400 Fernwood Road, Bethesda, Maryland 20817. It operates a toll-free central reservations system, through which individuals in any one of the fifty states in the United States can make reservations at any Courtyard by Marriott facility.
9. Along with Marriott International, Courtyard Management Corporation manages and operates the Park Avenue East Courtyard.

AGREEMENT

In order to avoid protracted litigation and without admitting to any violation of the ADA, the parties agree as follows:

General Obligations Under the ADA

10. The Park Avenue East Courtyard and the more than two hundred Courtyard by Marriott hotels that Marriott International and Courtyard Management Corporation own, lease, lease to other entities, or operate are places of transient lodging, which are "public accommodations" within the meaning of 42 U.S.C. § 12181(7) and section 36.104 of the Department of Justice's title III implementing regulation, 28 C.F.R. § 36.104.
11. According to the complaint, Mary Ann Williams has a physical condition that requires her to use a wheelchair. She is an individual with a disability within the meaning of 42 U.S.C. § 12101(2); 28 C.F.R. § 36.104.
12. David Williams, the complainant, is the husband of Mary Ann Williams. He does not have a disability, but is protected under the ADA, pursuant to 42 U.S.C. § 12182(b)(1)(E) and 28 C.F.R. § 36.205, from acts or omissions that discriminate against him because of his known "association with" an individual who has a disability.
13. Prior to June 16, 1993, when attempting to reserve an accessible guest room, David Williams identified himself to employees at both the central reservations office for Courtyard by Marriott facilities and to employees at the Park Avenue East Courtyard as an individual either with a disability or associated with an individual with a disability. On and after June 16, 1993, it became known to employees at the Park Avenue East Courtyard, to Marriott International, Inc., and to Courtyard Management Corporation, that David Williams was associated with an individual with a disability.
14. The Park Avenue East Courtyard opened in 1986, and is an existing facility within the meaning of title III of the ADA.
15. At the time the events giving rise to David Williams' complaint occurred, Marriott International and the Courtyard Management Corporation had an obligation, pursuant to 42 U.S.C. §§ 12182(a) and 12182(b)(1)(E), and 28 C.F.R. §§ 36.201(a) and 36.205, to ensure that no individual with a disability or person associated with an individual with a disability was discriminated against with respect to the provision of any of the goods, services, facilities, privileges, advantages, or accommodations available at the Park Avenue East Courtyard.
16. Pursuant to 42 U.S.C. §§ 12182(a) and 12182(b)(1)(E), and 28 C.F.R. §§ 36.201 and 36.205, discrimination includes denying the full and equal enjoyment of the goods, services, facilities, privileges, advantages, or accommodations available at a place of public accommodation to an individual with a disability or to any other individual because of that individual's known association with an individual with a disability.
17. Pursuant to 42 U.S.C. § 12182(b)(1)(A)(iii) and 28 C.F.R. § 36.203(c), discrimination also includes offering goods or services to individuals with disabilities that are separate from, unequal to, and different than those offered to individuals who do not have disabilities.
18. Pursuant to 42 U.S.C. § 12182(b)(2)(A)(ii) and 28 C.F.R. § 36.302(a), discrimination also includes a failure by the operator of a place of public accommodation to make reasonable modifications to existing policies, practices, and procedures when necessary to avoid discrimination on the basis of disability.
19. Pursuant to 42 U.S.C. § 12182(b)(2)(A)(iv) and 28 C.F.R. § 36.304(a), discrimination also includes a failure to remove barriers to access in places of public accommodation located in existing facilities when removal is readily achievable (i.e., easily accomplishable and able to be carried out without much difficulty or expense).
20. The Department maintains that the Park Avenue East Courtyard's failure to provide David Williams and Mary Ann Williams with a room accessible to individuals who use wheelchairs when one was available at the time David Williams made his reservation, resulted in the denial to Mary Ann Williams of the goods, services, facilities, privileges, advantages, and accommodations available at that facility because of her disability, and resulted in the denial of the same goods, services, facilities, privileges, advantages, and accommodations to David Williams because of his known association with an individual with a disability.
21. The Department maintains that failing to have in place policies and procedures allowing an individual with a disability to reserve an accessible room when one is available on the date for which it is requested results in the provision of goods and services to individuals with disabilities that are separate from, unequal to, or different than those goods and services offered to individuals who do not have disabilities.
22. The Department's position is that it is "readily achievable" to remove all of the barriers to access listed in Exhibit A, which is incorporated by reference as part of this agreement, and that such barrier removal is required by law.

Payment of Compensatory Damages

23. The ADA authorizes the Attorney General to seek and a court to award compensatory damages on behalf of individuals aggrieved as the result of violations of the Act. 42 U.S.C. § 12188(b)(2)(B); 28 C.F.R. 36.504(a)(2).
24. The Department maintains that as the result of acts by Marriott International, Courtyard Management Corporation, and the Park Avenue East Courtyard, Mary Ann Williams and David Williams suffered compensable injuries for which Marriott International and Courtyard Management Corporation agree to pay them $10,000 in settlement, in exchange for an appropriate release (attached hereto as "Exhibit B"). Payment shall be made by forwarding to David and Mary Ann William a check made payable to them jointly, within 10 days of the receipt of the executed copy of said release.

Payment of Civil Penalties

25. The ADA authorizes the Attorney General to seek and a court to award civil penalties in the amount of $50,000 for a first violation of title III of the ADA and $100,000 for each subsequent violation. 42 U.S.C. § 12188(b)(2)(C) and (b)(3); 28 C.F.R. § 36.504(a)(3) and (b).
26. Marriott International and Courtyard Management Corporation agree to pay to the United States the sum of $7,500 in settlement of the Park Avenue East's alleged violation of the rights of Mary Ann Williams and David Williams under title III of the ADA. Payment of this sum shall be made by forwarding a check made payable to the United States to the Disability Rights Section, Civil Rights Division, U.S. Department of Justice, P.O. Box 66738, Washington, D.C 20035-6738, within 10 days of the effective date of this agreement.

Reservations Policy

27. Marriott International and Courtyard Management Corporation shall take all steps necessary to ensure that within 60 days of the effective date of this agreement, appropriate staff at each Courtyard by Marriott facility will have access to a list of all accessible rooms in the facility, will update the list any time additional rooms are provided or the location of an accessible room is changed, and will inform both the central reservations office and the Guest Relations Department for Courtyard by Marriott hotels of such changes, so that the number of accessible rooms, which are required pursuant to paragraphs 28 and 30 of this agreement, can be updated.
28. Within 60 days of the effective date of this agreement, Marriott International and Courtyard Management Corporation shall ensure that the central reservations office for Courtyard by Marriott hotels will have input fifty percent (50%) of its accessible room inventory into the central reservation system. Marriott International and Courtyard Management Corporation agree to inform the central reservations office that its computer system must be updated promptly each time it receives information from individual Courtyard by Marriott facilities in accordance with the requirements of paragraph 27 of this agreement.
29. Marriott International and Courtyard Management Corporation agree that within 60 days of the effective date of this agreement, each Courtyard by Marriott hotel that accepts reservations directly and the central reservations office for Courtyard by Marriott hotels will have implemented a system that will allow them to determine, within no more than twenty-four hours after having received a request for an accessible room, whether such a room is actually available on the date(s) for which it is requested.
30. Within 60 days of the effective date of this agreement, a list of every room designated as accessible at every Courtyard by Marriott facility shall be available to all employees in Marriott International's Guest Relations Department. Information shall be updated as soon as it is received pursuant to the procedure outlined in paragraph 28 of this agreement.
31. Within 30 days of the effective date of this agreement, Marriott International and Courtyard Management Corporation shall issue to the central reservations office for Courtyard by Marriott hotels and to every Courtyard by Marriott hotel, a memorandum stating that it is the policy of Marriott International and Courtyard Management Corporation:
    1. That no accessible room will be reserved for an individual who does not have a disability, unless all inaccessible rooms have been reserved for the date on which a room is requested and accessible rooms are the only ones available;
    2. That an accessible room of the type requested by a person with a disability shall be reserved for that person, if, at the time a reservation is made, an accessible room is available for the date(s) on which it is being requested;
    3. That if, at the time the reservation is placed, an accessible room is available on the date(s) for which it is requested, the individual making the request will receive a confirmation number which will serve as proof that an accessible room has been "reserved" for the date(s) in question;
    4. That, at an individual customer's request, written confirmation that an accessible room has been "reserved" will be provided in addition to the confirmation number.
    5. That if the customer has been assigned inadvertently to an inaccessible room, all reasonable and diligent efforts must be made to find an accessible room in the same facility (e.g., by reassigning a non-disabled person who may be located in an accessible room to an inaccessible room in the same facility, assuming one is available);
    6. That if the customer has been assigned inadvertently to an inaccessible room and an accessible room cannot be found in the same facility, the facility will make all reasonable and diligent efforts to locate suitable accommodations elsewhere and will pay any difference between the cost of these accommodations and its own room rates;
    7. That the same efforts will be made to find suitable lodging at another facility for a customer with a disability whose reservation of an accessible room cannot be honored (despite the efforts described in paragraph 33) because a customer has held over in an accessible room past his or her reservation date, as are made for non-disabled customers similarly situated; and
    8. That reasonable efforts, including requesting non-disabled persons occupying accessible rooms to move to available inaccessible rooms, will be made to assign a customer with a disability who does not have a reservation to an accessible room.
32. Except as provided in paragraphs 31A through F, the same conditions and restrictions may be attached to accessible rooms that are reserved as are attached to other rooms that are reserved (e.g., accessible rooms may be held for a longer period of time for customers who make their reservations with valid credit cards than for those who make their reservations without credit cards). A valid credit card shall not, however, be required to reserve an accessible room, unless it is required of any person in order to reserve any room in a facility.
33. Within 30 days of the effective date of this agreement, Marriott International and Courtyard Management Corporation shall instruct every Courtyard by Marriott hotel in writing to take all reasonable steps necessary to ensure that individuals who do not have disabilities but who are occupying accessible rooms under the circumstances described in paragraph 31A, do not remain in such rooms past the date for which they have been reserved and, as a result, make them unavailable to persons with disabilities who have reserved them or who request them without reservations. Such reasonable steps shall include, but shall not necessarily be limited to the following:
    1. Informing individuals who reserve accessible rooms that it is the policy of Marriott International and Courtyard Management Corporation that customers reserving accessible rooms not remain in them after their reservations dates under the circumstances described above;
    2. If, on the last date of a customer's reservation of an accessible room it appears necessary to do so, notifying the customer of the policy stated in paragraph 33A; and
    3. Offering to re-assign any individual who wishes to remain in an accessible room after the dates for which it was reserved to an inaccessible room at the same facility, if one is available.
34. The requirements of paragraphs 27 through 33 shall apply both to rooms that are designated as accessible to persons with mobility impairments and to rooms in which auxiliary aids for persons with hearing impairments have been permanently installed (as opposed to rooms where such aids can be installed at a customer's request). The requirements of paragraphs 29, 31C and D, and 33 only shall apply equally to requests for rooms accessible to individuals with hearing impairments when the auxiliary aids needed to make such rooms accessible can be installed upon request.
35. Marriott International and Courtyard Management Corporation agree that within 90 days of the effective date of this agreement a report shall be furnished to the Department of Justice describing the policies, procedures, and implementation plans adopted pursuant to paragraphs 27 through 34.

Employee Training

36. Marriott International and Courtyard Management Corporation agree that within 90 days of the effective date of this agreement, it will take steps necessary to ensure:
    1. That all employees at every Courtyard by Marriott location who handle customer reservations, customer check-in, and customer complaints are generally familiar with obligations that the ADA imposes upon places of lodging, and with the elements that the ADA requires in accessible guest rooms, including guest rooms accessible to individuals with hearing impairments; and
    2. That all employees in Courtyard by Marriott's Guest Relations Department are generally familiar with the elements that the ADA requires in accessible guest rooms; and with the obligations of places of lodging under the ADA.
37. Within 10 days of taking those steps required to comply with paragraphs 36 A and B, Marriott International and Courtyard Management Corporation shall furnish to the Department of Justice written assurance of compliance.

Use of the Term "Accessible"

38. Use of the terms "accessible" and "accessible guest room(s)" in this agreement is not intended as an admission by the Department of Justice that rooms designated accessible by Marriott International and Courtyard Management Corporation actually comply with applicable requirements of the ADA Standards for Accessible Design.

Removal of Barriers to Access

39. Within 60 days of the effective date of this agreement, Marriott International and Courtyard Management Corporation shall furnish to the Department of Justice detailed plans for accomplishing the barrier removal measures specified in Exhibit A to this agreement at the Park Avenue East Courtyard.
40. Within 120 days of the Department of Justice's approval of the plans provided in compliance with the preceding paragraph, Marriott International and Courtyard Management Corporation will ensure that all barrier removal measures specified in Exhibit A are complete.
41. Removal of a barrier to access will be deemed complete only if the element as to which the barrier is being removed complies with those portions of the ADA Standards for Accessible Design ("the Standards"), 28 C.F.R. Pt. 36, Appendix A, referred to in Exhibit A.

Rooms Accessible to Persons with Hearing Impairments

42. Within 90 days of the effective date of this agreement, Marriott International and Courtyard Management Corporation will purchase appropriate auxiliary aids necessary to make five additional guest rooms at the Park Avenue East Courtyard hotel accessible to persons with hearing impairments.

ENFORCEMENT

43. The Attorney General is authorized, pursuant to section 308(b)(1)(B) of the Act, 42 U.S.C. § 12188(b)(1)(B), to bring a civil action enforcing the ADA in any situation where a pattern or practice of discrimination is believed to exist or a matter of general public importance is raised. In consideration of the terms of this agreement set forth above, the Attorney General agrees to refrain from taking more formal enforcement action in this matter during the pendency of this agreement, as long as Marriott International and Courtyard Management Corporation comply with this agreement.
44. In the event that Marriott International and/or Courtyard Management Corporation fail to comply in a timely fashion with any requirement of this agreement, all terms of this agreement shall become enforceable in federal district court. Failure by the Department of Justice to enforce this entire agreement with regard to any deadline herein shall not be construed as a waiver of its right to do so with regard to future deadlines and provisions of this agreement.
45. The Department of Justice may review compliance with this agreement at any time. If the Department believes that this agreement or any requirement(s) thereof has been violated, it will inform Marriott International and Courtyard Management Corporation of this fact, and the parties will negotiate in good faith to resolve any issue(s) raised. If the parties cannot resolve any issue(s) raised by the Department within 30 days of the Department's having notified Marriott International and Courtyard Management Corporation of the issues in dispute, the Department may institute a civil action in federal district court. If the Department demonstrates in such a civil action that Marriott International and/or Courtyard Management Corporation have failed to comply with any material provision of this agreement, Marriott International and/or Courtyard Management Corporation shall correct such noncompliance and shall pay to the United States civil penalty in an amount no less than $5,000.00, and shall pay an appropriate amount of compensatory damages to any individual(s) aggrieved by such noncompliance.

PUBLIC AGREEMENT

46. This document is a public agreement. A copy of this agreement or any information contained herein may be made available pursuant to the Freedom of Information Act.

SCOPE OF AGREEMENT

47. This agreement constitutes the entire agreement between the parties on the matters raised herein, and no other statement, promise or agreement, either written or oral, made by either party or agents of either party, that is not contained in this written agreement shall be enforceable. This agreement is limited to the facts set forth in paragraphs 1 through 6, and it does not purport to remedy any other potential violations of the ADA or any other federal law. This agreement does not affect Marriott International's or Courtyard Management Corporation's continuing responsibility to comply with all aspects of the ADA. Specifically, this agreement does not affect duties raised with respect to
    1. policies, practices, and procedures in effect at the Park Avenue East Courtyard other than those specified in this agreement;
    2. barrier removal at any Courtyard by Marriott facility other than the Park Avenue East Courtyard;
    3. the provision of auxiliary aids and services necessary for effective communication at the Park Avenue East Courtyard by Marriott, other than those specified in paragraph 42;
    4. the provision of auxiliary aids and services necessary for effective communication, including equipment to make guest rooms accessible to persons with hearing impairments, at any Courtyard by Marriott location other than the Park Avenue East Courtyard by Marriott;
    5. any facility owned, leased (or leased to), or operated by Marriott International or any of its subsidiaries other than Courtyard by Marriott facilities; and
    6. policies, practices, or procedures in effect at the central reservations office for Courtyard by Marriott facilities or in Marriott International's Guest Relations Department other than those specifically mentioned in this agreement.
48. A signor of this document in a representative capacity for a partnership, corporation, or other such entity, represents that he or she is authorized to bind such partnership, corporation or other entity to this agreement. This agreement shall be binding on all of Marriott International's and Courtyard Management Corporation's successors in interest, and Marriott International and Courtyard Management Corporation have a duty to so notify all such successors in interest.

EFFECTIVE DATE/TERMINATION DATE

49. This agreement shall become effective as of the date of the last signature below. This agreement shall terminate three years after the Department of Justice's approval of the plans submitted in compliance with paragraph 39 of this agreement, but in no event later than forty

EXHIBIT A

BARRIER REMOVAL MEASURES

TO BE TAKEN AT THE COURTYARD BY MARRIOTT,

PARK AVENUE EAST, MEMPHIS, TENNESSEE

1. Parking
   1. Accessible parking spaces that comply fully with the ADA Standards for Accessible Design ("Standards"), 28 C.F.R. Pt. 36, Appendix A, as to number and configuration, including the proper number of "van accessible" spaces, will be provided for the facility. §§ 4.1.2(5)(a) and (b), 4.6.3, and 4.6.4.
   2. A curb ramp complying with relevant portions of § 4.7 of the Standards will be part of the accessible route leading from accessible parking spaces to the building's entrance.
2. Entrance -- The interior set of front doors for the facility will be adjusted so that the force required to open them will not exceed five pounds. Standards, § 4.13.11.
3. Lounge Area -- The ramp leading from the lobby to the lounge area will be brought into full compliance with § 4.8.5 of the Standards.
4. Men's Public Toilet Room on the First Floor
   1. One accessible stall complying with Standards, § 4.17 (including all sections of the Standards and figures referenced therein) will be provided.
   2. The urinal will be brought into compliance with the requirements of Standards, § 4.18.
   3. A lavatory complying with Standards, § 4.19 (including all sections of the Standards and figures referenced therein) will be provided.
   4. A mirror with the bottom edge of its reflecting surface no higher than 39" above the finish floor will be provided. Standards, § 4.19.6 and Fig. 31.
   5. One of each type of dispenser provided, if any, will be mounted so that it provides a proper reach range for persons who use wheelchairs and will have controls that can be operated without tight grasping, pinching, or twisting of the wrist to operate. Standards, §§ 4.2.6, 4.2.7, 4.23.7, and 4.27.
   6. The entry door will comply with Standards, § 4.13.
   7. A turning space with a minimum 60" diameter will be provided in the restroom for persons who use wheelchairs. Standards, § 4.2.3.
5. Women's Public Toilet Room on the First Floor
   1. One accessible stall complying with Standards, § 4.17 (including all sections of the Standards and figures referenced therein) will be provided.
   2. A lavatory complying with Standards, § 4.19 (including all relevant sections of the Standards and figures referenced therein) will be provided.
   3. A mirror with the bottom edge of its reflecting surface no higher than 39" above the finish floor will be provided. Standards, § 4.19.6 and Fig. 31.
   4. One of each type of dispenser provided, if any, will be mounted so that it provides a proper reach range for persons who use wheelchairs and will have controls that can be operated without tight grasping, pinching, or twisting of the wrist. Standards, §§ 4.2.6, 4.2.7, 4.23.7, and 4.27.
   5. The entry door will comply with Standards, § 4.13.
   6. A turning space with a minimum 60" diameter will be provided in the restroom for persons who use wheelchairs. Standards, § 4.2.3.
6. Guest Rooms
   1. Tactile signage will be provided for all 146 guest rooms in the facility. Standards, §§ 4.1.3(16)(a), 4.30.4, and 4.30.6.
   2. Two guest rooms currently designated as "accessible" will be modified in the following ways:

      (1) Adequate maneuvering clearances will be provided for the door leading into each room, or an automatic door opener will be installed on the pull side of each door. Standards, § 4.13.6.

      (2) A minimum 36" clear width will be provided along both sides of the bed, or if two beds are provided, a 36" minimum maneuvering space will be provided between the beds. Standards, § 9.2.2(1).

      (3) Hardware complying with Standards, § 4.13.9 will be provided for the door leading from the accessible room to the adjoining room and on the door for the bathroom. See also Standards, § 9.2.2(3).

      (4) Grab bars complying with Standards, §§ 4.16.4 and 4.26 and with Fig. 29,will be provided in each bathroom. See also Standards, § 9.2.2(6)(e).

      (5) A roll-in shower complying with Standards, § 4.21 (including all relevant sections of the Standards and figures referenced therein) and with Fig. 57(a) or Fig. 57(b) will be provided. See also Standards, §§ 9.1.2 and 9.2.2(6)(e).

      (6) An accessible clothes rod complying with the requirements of Standards, § 4.25.3 (including all relevant sections of the Standards and figures referenced therein) will be provided in the closet. See also Standards, § 9.2.2(4).

7. Public Pay Telephones
   1. One public pay telephone will be lowered so that it provides for a forward approach. Standards, §§ 4.1.3(17)(a) and 4.2.6.
   2. The same telephone that will be lowered to comply with the "forward reach" requirements of the Standards will be equipped with a volume control. Standards, § 4.1.3(17)(b).
   3. Signage will be installed indicating that a TDD is available at the front desk for use with the public pay telephones. Standards, § 4.31.9.

February 19, 2008