Settlement Agreement between the City of Memphis, Tennessee, Attachment (J)

Attachment J

Altered Facilities

Please Note: Paragraph 33 of the Settlement Agreement requires that within 12 months of the effective date of this Agreement, the City will provide signage as necessary to comply with 28 C.F.R. § 35.163(b), after having surveyed all facilities that are the subject of this Agreement for the purpose of identifying those that have multiple entrances not all of which are accessible.

In order to ensure that the following spaces and elements in the City's facilities, for which construction was commenced before January 26, 1992 and for which alterations took place on or after January 26, 1992, are readily accessible to and usable by persons with disabilities, the City will take the following actions:

1. Within 24 months of the effective date of the Agreement, the City will complete the following modifications to the Cook Convention Center, located at 255 North Main Street, Memphis, TN:

A. Parking

1) The van accessible parking reserved for persons with disabilities on Parking Level P1, Zone A6, lacks the appropriate signage. At van accessible spaces, provide a "Van-Accessible" sign located below the International Symbol of Accessibility such that the sign cannot be obstructed by vehicles parked in the space. Standards §§ 4.6.4, 4.30.7(1).

2) The parking reserved for persons with disabilities on Level P2, near Zone B4, is inaccessible because the access aisles measure only 48 inches wide. Provide designated accessible parking spaces that are a minimum of 96 inches wide and served by access aisles at least 60 inches wide. Provide van accessible spaces that are a minimum of 96 inches wide and served by access aisles at least 96 inches wide. Standards §§ 4.1.2(5), 4.6.3, Fig.9.

3) The signage designating parking on Level P2, near Zone B4, as reserved for persons with disabilities is too low. At each space designated as reserved for persons with disabilities, provide a vertical sign with the International Symbol of Accessibility located such that it cannot be obstructed by vehicles parked in the space. Standards §§ 4.6.4, 4.30.7(1).

4) Three of the four parking spaces reserved for persons with disabilities on P3 Level, near Zone 3I, lack appropriate signage. At all spaces designated as reserved for persons with disabilities, provide vertical signs with the International Symbol of Accessibility located such that they cannot be obstructed by parked vehicles. At van accessible spaces, provide an additional "Van-Accessible" sign located below the International Symbol of Accessibility. Standards §§ 4.6.4, 4.30.7(1).

5) The route from the 8 standard accessible spaces on P3 Level, near Zones 3I and 3D to the elevators is inaccessible because both curb ramps have lips measuring 0.75 inches high. Provide a curb ramp that is at least 36 inches wide, has a maximum slope of 1:12, is located so that it cannot be obstructed by parked vehicles, and has a stable, firm, and slip-resistant surface with a detectable warning extending the full width and depth of the ramp. If the curb ramp is located where pedestrians must walk across it, provide either flared sides (with a maximum slope of 1:10) or handrails or guardrails to protect against cross traffic. Standards § 4.3.8, 4.7, Fig. 12.

6) The built-up curb ramp impermissibly extends into the vehicular traffic lanes. Provide a curb ramp located so that it does not project into this element and all aspects of the ramp or curb cut comply with the Standards. Standards §§ 4.1.2(1), 4.1.2(2), 4.1.6(1)(b), 4.3.8, 4.7.6.

B. Offices and Counters

1) The Information Counter at the Grand Lobby North is inaccessible because the counter surface is mounted 44 inches above the finished floor. Provide a counter on an accessible route such that a portion of the counter is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary counter with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, a clip board made available to the public, or other means. Standards §§ 7.2(2), 4.3.

2) The Ticket Counter at the Grand Lobby North is inaccessible because the counter surface is 42 inches above the finished floor. Provide a counter on an accessible route such that a portion of the counter is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary counter with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, a clip board made available to the public, or other means. Standards §§ 7.2(2), 4.3.

C. Drinking Fountains

1) The drinking fountains in the Convention Center have spouts that range from 38 to 41 inches above the finished floor. Ensure that at least 50% of all drinking fountains throughout the Convention Center have spout heights no higher than 36 inches, measured from the finished floor or ground surface to the spout outlets, and that otherwise comply with the Standards. Standards §§ 4.15, 4.27.4, Fig. 27.

2) Although accessible drinking fountains are provided, there is no drinking fountain provided for people who have difficulty bending or stooping. Provide a drinking fountain in each area of the Convention Center that is accessible to people who have difficulty bending or stooping. This can be accommodated by the use of a "hi-lo" fountain; by providing one fountain accessible to those who use wheelchairs and one fountain at a standard height convenient for those who have difficulty bending; by providing a fountain accessible to people who use wheelchairs and a cup dispenser, or by such other means as would achieve the required accessibility for each group of people. Standards § 4.1.3(10)(a).

3) The drinking fountain in the Grand Lobby South is not accessible because the fountain requires 10 pounds of force to operate, and because it lacks adequate knee clearance. Provide at least one drinking fountain with a spout height no higher than 36 inches, measured from the finished floor or ground surface to the spout outlet; and a spout located at the front of the unit that directs the water flow in a trajectory that is nearly parallel to the front of the unit and is positioned so the flow of water is within 3 inches of the front edge of the fountain and at least 4 inches high. Ensure that fountain controls are operable with one hand, require 5 lbf or less to operate without tight grasping, pinching, or twisting of the wrist; and are front mounted or side mounted near the front edge. Additionally, provide a drinking fountain that is accessible to people who have difficulty bending or stooping. This can be accommodated by the use of a "hi-lo" fountain; by providing one fountain accessible to those who use wheelchairs and one fountain at a standard height convenient for those who have difficulty bending; by providing a fountain accessible to people who use wheelchairs and a cup dispenser; or by such other means as would achieve the required accessibility for each group of people. Standards §§ 4.1.3(10), 4.1.6(1)(b), 4.15, 4.27.4, Fig. 27.

4) The drinking fountain at the Grand Lobby North is inaccessible because it lacks adequate knee clearance. Provide a drinking fountain with clear knee space between the bottom of the apron and the finished floor or ground of at least 27 inches high, 30 inches wide, and 17 to 19 inches deep; and a minimum clear floor space of 30 inches by 48 inches to allow a person in a wheelchair to approach the unit facing forward. Standards §§ 4.1.3(10), 4.1.6(1)(b), 4.15.5(1), Figs. 27(a), (b).

5) The drinking fountain at the West Plaza South is inaccessible because there is insufficient knee clearance provided. Provide a drinking fountain with clear knee space between the bottom of the apron and the finished floor or ground of at least 27 inches high, 30 inches wide, and 17 to 19 inches deep; and a minimum clear floor space of 30 inches by 48 inches to allow a person in a wheelchair to approach the unit facing forward. Standards §§ 4.1.3(10), 4.1.6(1)(b), 4.15.5(1), Figs. 27(a), (b).

D. Convention Center Toilet Rooms

1) Grand Lobby South Women's Toilet Room

a) The Women's Toilet Room in the Grand Lobby South is inaccessible because the pressure required to open the door is greater than 5 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

b) The route from the door to the toilet is inaccessible because at least one paper towel dispenser protrudes into the path of travel. Provide an accessible route at this location such that no objects with their bottom leading edges measuring between 27 inches and 80 inches above the finished floor protrude more than 4 inches into walks, halls, corridors, passageways, or aisles. Free-standing objects mounted on posts or pylons may overhang 12 inches maximum from 27 inches to 80 inches above the ground or finished floor. Standards § 4.4.

c) The baby changing table in the Women's Toilet Room with Stalls at the Grand Lobby South is inaccessible because it is mounted in such a way that when open it is 39 inches high. Provide a changing surface on an accessible route such that a portion of the surface is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary surface with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, or other means. Standards §§ 7.2(2), 4.3.

d) The lavatory is inaccessible because the bottom edge is 27.5 inches above the finished floor. Provide a lavatory with the top of its rim or counter 34 inches or less above the finished floor; the bottom edge of the apron at least 29 inches above the finished floor; and knee and toe clearances that comply with Fig. 31. Standards § 4.19.2, Fig. 31.

e) The toilet paper dispensers in the accessible and ambulatory stalls are inaccessible because they are mounted above the side grab bar. Provide a toilet paper dispenser in each accessible and ambulatory stall that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

f) Although there is an ambulatory stall provided, it does not have a self closing stall door. Provide at least one stall that is exactly 36 inches wide with a toilet 18 inches from each wall or partition, an outward swinging, self-closing door, and parallel grab bars complying with Fig 30(d). Standards §§ 4.22.4, Fig. 30(d).

2) Grand Lobby South Men's Toilet Room with Stalls

a) The door to the Men's Toilet Room in the Grand Lobby South is inaccessible because the pressure required to open the door is greater than 5 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

b) The lavatory is inaccessible because the bottom edge is 28 inches above the finished floor. Provide a lavatory with the top of its rim or counter 34 inches or less above the finished floor; the bottom edge of the apron at least 29 inches above the finished floor; and knee and toe clearances that comply with Fig. 31. Standards § 4.19.2, Fig. 31.

c) The toilet paper dispenser is inaccessible because it is mounted above the side grab bars in the standard accessible stall. Provide a toilet paper dispenser that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

3) Grand Lobby North Men's and Women's Toilet Rooms

a) The doors to the Men's and Women's Toilet Rooms in the Grand Lobby North are inaccessible because the pressure required to open the doors is greater than 5 pounds. Provide a door to each toilet room that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

b) The toilet room sign for the Men's and Women's Toilet Rooms in the Grand Lobby North are inaccessible. Provide a toilet room sign for each toilet room with the International Symbol of Accessibility and raised and Braille characters mounted on the wall adjacent to the latch side of the door with the centerline of the sign 60 inches above the finished floor and situated such that a person can approach within 3 inches of the sign without encountering an obstruction or standing within a door swing. Standards §§ 4.1.2(7)(d), 4.30.1, 4.30.4, 4.30.5, 4.30.6, 4.30.7.

c) The baby changing tables at the Toilet Rooms are inaccessible because they require a 57 inch reach (Women's) or a 55 inch reach (Men's) to open them, and are mounted at 41 inches (Women's) or 39 inches (Men's) above the finished floor. Provide a baby changing table in each toilet room on an accessible route such that a portion of the surface is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary surface with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, or other means. Standards §§ 7.2(2), 4.3.

d) The toilet paper dispensers are inaccessible because they are positioned above the side grab bars in both toilet rooms. Provide a toilet paper dispenser in each toile troom that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

e) The route within the toilet room is inaccessible because the paper towel dispenser is a protruding object. Provide an accessible route at this location such that no objects with their bottom leading edges measuring between 27 inches and 80 inches above the finished floor protrude more than 4 inches into walks, halls, corridors, passageways, or aisles. Free-standing objects mounted on posts or pylons may overhang 12 inches maximum from 27 inches to 80 inches above the ground or finished floor. Standards §§ 4.1.2(3), 4.1.6(1)(b), 4.4.

4) West Plaza North - Ground Level Men's and Women's Toilet Rooms

a) The door to the Men's and Women's Toilet Rooms in the West Plaza North is inaccessible because the pressure required to open the door is greater than 5 pounds. Provide a door to each toilet room that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

b) The toilet room sign for the Men's and Women's Toilet Rooms in the West Plaza North are not accessible. Provide a toilet room sign in each toilet room with the International Symbol of Accessibility and raised and Braille characters mounted on the wall adjacent to the latch side of the door with the centerline of the sign 60 inches above the finished floor and situated such that a person can approach within 3 inches of the sign without encountering an obstruction or standing within a door swing. Standards §§ 4.1.2(7)(d), 4.30.1, 4.30.4, 4.30.5, 4.30.6, 4.30.7.

c) The baby changing tables at Men's and Women's Toilet Rooms are inaccessible because they require a 55 inch reach to open them, and are mounted at 39 inches above the finished floor. Provide a baby change table in each toilet room on an accessible route such that a portion of the counter is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary counter with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, a clip board made available to the public, or other means. Standards §§ 7.2(2), 4.3.

d) The toilet paper dispensers in the accessible stalls are inaccessible because they are mounted above the side grab bars in both locations. Provide a toilet paper dispenser in each toilet room that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

e) (Women's Toilet Room only:) The toilet paper dispenser is inaccessible because it is located above the side grab bar. Provide a toilet paper dispenser that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

f) The route within the toilet room is inaccessible because the paper towel dispensers are protruding objects. Provide an accessible route at this location such that no objects with their bottom leading edges measuring between 27 inches and 80 inches above the finished floor protrude more than 4 inches into walks, halls, corridors, passageways, or aisles. Free-standing objects mounted on posts or pylons may overhang 12 inches maximum from 27 inches to 80 inches above the ground or finished floor. Standards §§ 4.1.2(3), 4.1.6(1)(b), 4.4.

5) West Plaza South - Men's and Women's Toilet Rooms

a) The doors to the Men's and Women's Toilet Rooms are inaccessible because the pressure required to open each door is greater than 5 pounds. Provide a door to each toilet room that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

b) The route within the toilet room is inaccessible because the paper towel dispensers are protruding objects. Provide an accessible route at this location such that no objects with their bottom leading edges measuring between 27 inches and 80 inches above the finished floor protrude more than 4 inches into walks, halls, corridors, passageways, or aisles. Free-standing objects mounted on posts or pylons may overhang 12 inches maximum from 27 inches to 80 inches above the ground or finished floor. Standards §§ 4.1.2(3), 4.1.6(1)(b), 4.4.

c) The baby changing tables at the Men's and Women's Toilet Rooms are inaccessible because they require a 57 inch reach to open, and are mounted at 41 inches high. Provide a baby changing table in each toilet room on an accessible route such that a portion of the surface is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary counter with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, or other means. Standards §§ 7.2(2), 4.3.

d) The lavatory in each toilet room is inaccessible because the bottom edge of each lavatory is 23 inches above the finished floor. Provide a lavatory in each toilet room with the top of its rim or counter 34 inches or less above the finished floor; the bottom edge of the apron at least 29 inches above the finished floor; and knee and toe clearances that comply with Fig. 31. Standards § 4.19.2, Fig. 31.

e) The toilet paper dispensers in the accessible stalls are inaccessible because they are mounted above the side grab bars. Provide a toilet paper dispenser in each toilet room that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

f) (Women's Toilet Room only:) The toilet paper dispenser in the ambulatory stall is inaccessible because it is mounted above the side grab bar. Provide a toilet paper dispenser that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

g) (Women's Toilet Room only:) Although there is an ambulatory stall provided, it lacks a self closing stall door. Provide at least one stall that is exactly 36 inches wide with a toilet 18 inches from each wall or partition, an outward swinging, self-closing door, and parallel grab bars complying with Fig 30(d). Standards §§ 4.22.4, Fig. 30(d).

6) Convention Mezzanine Level North and South Men's and Women's Toilet Rooms (two sets with four toilet rooms)

a) The signs for these toilet rooms are not accessible. Provide a toilet room sign for each toilet room with the International Symbol of Accessibility and raised and Braille characters mounted on the wall adjacent to the latch side of the door with the centerline of the sign 60 inches above the finished floor and situated such that a person can approach within 3 inches of the sign without encountering an obstruction or standing within a door swing. Standards §§ 4.1.2(7)(d), 4.30.1, 4.30.4, 4.30.5, 4.30.6, 4.30.7.

b) The doors to these rooms are inaccessible because the pressure required to open the doors is greater than 5 pounds. Provide a door to each toilet room that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

c) The route from the entrance to the toilet stalls are inaccessible because each toilet room has at least one paper towel dispenser that protrudes into the path of travel. Provide an accessible route through each toilet room such that no objects with their bottom leading edges measuring between 27 inches and 80 inches above the finished floor protrude more than 4 inches into walks, halls, corridors, passageways, or aisles. Free-standing objects mounted on posts or pylons may overhang 12 inches maximum from 27 inches to 80 inches above the ground or finished floor. Standards § 4.4.

d) The baby changing table in each toilet room is inaccessible because they require a 55 inch reach when closed to open, and are mounted 39 inches above the finished floor. Provide a baby changing table on an accessible route such that a portion of the counter is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary counter with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, a clip board made available to the public, or other means. Standards §§ 7.2(2), 4.3.

e) The lavatory in each toilet room is inaccessible because the bottom edge in each toilet room is 23.5 inches from the finished floor. Provide a lavatory in each toilet room with the top of its rim or counter 34 inches or less above the finished floor; the bottom edge of the apron at least 29 inches above the finished floor; and knee and toe clearances that comply with Fig. 31. Standards § 4.19.2, Fig. 31.

f) The toilet paper dispensers in the designated accessible stall in each toilet room are inaccessible because they are mounted above the side grab bar. Provide a toilet paper dispenser in each toilet room that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

7) Convention Pre-Function Areas East and West Men's and Women's Toilet Rooms (two sets with four toilet rooms)

a) The doors to these toilet rooms are inaccessible because the pressure required to open each door is greater than 5 pounds. Provide a door to each toilet room that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

b) The baby changing tables at the Men's and Women's Toilet Rooms in the Convention Pre-function Areas East and West are inaccessible because when closed, they require a 59 inch reach to open, and they are mounted 41 inches above the finished floor. Provide a baby changing table in each toilet room on an accessible route such that a portion of the surface is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary counter with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, or other means. Standards §§ 7.2(2), 4.3.

c) The lavatory in each toilet room is inaccessible because the bottom edge is 23.5 inches above the finished floor. Provide a lavatory in each toilet room with the top of its rim or counter 34 inches or less above the finished floor; the bottom edge of the apron at least 29 inches above the finished floor; and knee and toe clearances that comply with Fig. 31. Standards § 4.19.2, Fig. 31.

d) The toilet paper dispenser in each accessible stall of the Women's Toilet Rooms is inaccessible because it is mounted above the side grab bar. Provide a toilet paper dispenser in each accessible stall of the Women's Toilet Rooms that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

8) Cannon Center West and East Concourse Men's and Women's Toilet Rooms all levels

a) Although the facility contains an emergency alarm system, the alarm system is inaccessible because the stalls furthest from the visual alarms in the Women's Rooms are not within their line of sight. Provide visual alarm devices in toilet rooms and any other general usage areas (e.g., meeting rooms), hallways, lobbies, and any other area for common use. Such devices shall be integrated into the facility alarm system and shall meet the requirements of the Standards for lamp type, color, pulse duration, intensity, and flash rate. Visual alarm appliances shall be placed 80 inches above the highest floor level within the space or 6 inches below the ceiling, whichever is lower. Visual alarm appliances shall be located such that no place in any room or space, including common corridors or hallways, required to have a visual alarm appliance shall be more than 50 feet from the signal. In large rooms and spaces exceeding 100 feet across, without obstructions 6 feet above the finished floor, devices may be placed around the perimeter, spaced a maximum of 100 feet apart, in lieu of suspending appliances from the ceiling. Standards § 4.28.3.

b) The baby changing tables in each of these toilet rooms are inaccessible because when closed they require a 59 inch reach to open, and they are mounted at 41 inches from the finished floor. Provide a baby changing table in each toilet room on an accessible route such that a portion of the surface is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary counter with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, or other means. Standards §§ 7.2(2), 4.3.

c) The toilet paper dispensers in the designated accessible stalls in each toilet room are inaccessible because they are missing or are mounted above the side grab bars. Provide a toilet paper dispenser in each toilet room that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

d) Although there are ambulatory stalls provided, they measure 42 inches wide and the outward swinging doors do not self close. Provide at least one stall in each toilet room containing 6 or more stalls, that is exactly 36 inches wide with a toilet 18 inches from each wall or partition, an outward swinging, self-closing door, and parallel grab bars complying with Fig 30(d). Standards §§ 4.22.4, Fig. 30(d).

9) Cannon Center Central Concourse Men's and Women's Toilet Rooms all levels

a) No accessible mirror has been provided in each toilet room. Provide a mirror in each toilet room with the bottom edge of its reflecting surface no more than 40 inches above the finished floor. Standards § 4.19.6.

b) The baby changing table in each toilet room is inaccessible because when closed it requires a 58 inch reach to open, and it is mounted 40 inches above the finished floor. Provide a baby changing table in each toilet room on an accessible route such that a portion of the surface is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary counter with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, or other means. Standards §§ 7.2(2), 4.3.

c) The toilet paper dispenser in each accessible stall and each ambulatory stall in each toilet room is inaccessible because they are mounted above the side grab bar. Provide a toilet paper dispenser in each toilet room that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

d) Although there are ambulatory stalls provided, they are 42 inches wide. In each toilet room with 6 or more stalls, provide at least one stall that is exactly 36 inches wide with a toilet 18 inches from each wall or partition, an outward swinging, self-closing door, and parallel grab bars complying with Fig 30(d). Standards §§ 4.22.4, Fig. 30(d).

E. Cannon Center for the Performing Arts

1) Entranceway Doors

a) The interior entrance doors to the Cannon Center for the Performing Arts are inaccessible because the pressure required to open them is greater than 5 pounds. Provide doors that require no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

2) Ramps

a) Ramp to seats Mezzanine level west side of the Cannon Center

(1) The ramp is inaccessible because a 4-foot section of the ramp has a slope of 10%; the handrails on both sides are 33 inches above the finished floor; there are 2 inches between the wall and the handrail; and the diameter of the handrails is 1.75 inches. Provide a ramp that is at least 36 inches wide with a slope not exceeding 1:12 and a cross slope not exceeding 1:50; with level landings at least as wide as the ramp and 60 inches long at the top and bottom of the ramp; and with edge protection at least 2 inches high at the drop off sides. Provide handrails that are between 1¼ inches and 1½ inches in diameter with a continuous gripping surface along both sides of the ramp, extending at least 12 inches beyond the top and bottom of the ramp parallel with the ground surface. Ensure that handrails are mounted between 34 inches and 38 inches above the ramp surface and 1½ inches from the wall, with ends rounded or returned smoothly to the floor, wall, or post, and that they do not rotate within their fittings. Ensure that the ramp and approaches are designed so that water will not accumulate on walking surfaces. Standards §§ 4.3.8, 4.8.

b) Ramp to seats Mezzanine level east side of the Cannon Center

(1) The ramp is inaccessible because a portion of the ramp has a slope of 9.5%; the handrails on either side are 33 inches above the finished floor; there are 2 inches between the wall and the handrail; and the diameter of the handrails is 1.75 inches. Provide a ramp that is at least 36 inches wide with a slope not exceeding 1:12 and a cross slope not exceeding 1:50; with level landings at least as wide as the ramp and 60 inches long at the top and bottom of the ramp; and with edge protection at least 2 inches high at the drop off sides. Provide handrails that are between 1¼ inches and 1½ inches in diameter with a continuous gripping surface along both sides of the ramp, extending at least 12 inches beyond the top and bottom of the ramp parallel with the ground surface. Ensure that handrails are mounted between 34 inches and 38 inches above the ramp surface and 1½ inches from the wall, with ends rounded or returned smoothly to the floor, wall, or post, and that they do not rotate within their fittings. Ensure that the ramp and approaches are designed so that water will not accumulate on walking surfaces. Standards §§ 4.3.8, 4.8.

c) Ramp to seats Parterre level east side of the Cannon Center

(1) The ramp is inaccessible because a portion of the ramp has a slope of 9.4%; the handrails on either side are 33 inches above the finished floor; there are 2 inches between the wall and the handrails; and the diameter of the handrails is 1.75 inches. Provide a ramp that is at least 36 inches wide with a slope not exceeding 1:12 and a cross slope not exceeding 1:50; with level landings at least as wide as the ramp and 60 inches long at the top and bottom of the ramp; and with edge protection at least 2 inches high at the drop off sides. Provide handrails that are between 1¼ inches and 1½ inches in diameter with a continuous gripping surface along both sides of the ramp, extending at least 12 inches beyond the top and bottom of the ramp parallel with the ground surface. Ensure that handrails are mounted between 34 inches and 38 inches above the ramp surface and 1½ inches from the wall, with ends rounded or returned smoothly to the floor, wall, or post, and that they do not rotate within their fittings. Ensure that the ramp and approaches are designed so that water will not accumulate on walking surfaces. Standards §§ 4.3.8, 4.8.

d) Ramp to seats Parterre level west side of the Cannon Center

3) Dressing rooms designated as being accessible for people with disabilities

a) Single User Toilet Rooms

(1) The door to each single user toilet room at the accessible dressing rooms is inaccessible because there is a 0.75 inch threshold. Provide a door to each toilet room with a threshold no greater than ¼ inch, or between ¼ inch and ½ inch and beveled with a slope no greater than 1:2. Standards §§ 4.13.8, 4.5.2.

(2) The toilet paper dispenser and side grab bar in each toilet room is inaccessible because the distance between the side grab bar and the dispenser is only 1 inch. Provide a side grab bar that has at least 1½ inches between the grab bar and any other object, such as the toilet paper dispenser. Standards §§ 4.1.3(11), 4.22.4, 4.16.4, 4.26.2, Fig. 39.

2. The City represents that it is currently in the process of deciding whether to change the use of the The Pyramid, at 1 Auction Avenue, Memphis, TN. In the event that the City decides to continue to use this facility as a venue for sporting events, within 30 months of the effective date of this agreement, the City will make the following modifications:

A. South/North Parking Lot

1) The Pyramid is inaccessible because it lacks directional signage at the north parking lot directing persons with disabilities to the south parking lot which has all of the accessible parking spaces. Provide accessible directional signage with the International Symbol of Accessibility at inaccessible parking lots directing users to the parking lot with spaces reserved for persons with disabilities, and provide accessible signage with the International Symbol of Accessibility at all entrances to the south parking lot. Standards §§ 4.1.3(16)(b), 4.30.

2) The existing parking spaces reserved for persons with disabilities are inaccessible because the access aisles provided are too narrow for van-accessible spaces. For one out of every eight designated accessible parking spaces (for a minimum total of 9 spaces to be designated as being van-accessible), provide a van accessible space a minimum of 96 inches wide, served by access aisles at least 96 inches wide, with vertical signs with the International Symbol of Accessibility located such that they cannot be obstructed by parked vehicles, and with an additional "Van-Accessible" sign located below the International Symbol of Accessibility. Standards §§ 4.1.2(5)(b), 4.1.6(1)(b), 4.6, 4.30.7(1).

B. All entrances into the Pyramid

1) The Pyramid is inaccessible because it lacks directional signage at inaccessible entrances directing persons with disabilities to the accessible entrance, and signage at the accessible entrance marking it as being accessible. Provide accessible directional signage with the International Symbol of Accessibility at inaccessible entrances directing users to the accessible entrance, and provide accessible signage with the International Symbol of Accessibility at all permanent accessible entrances. Standards §§ 4.1.3(8)(d), 4.13, 4.30.

C. Lower Level Telephone

1) The telephone on the Lower Level in the Pyramid is inaccessible because it lacks volume control. Provide an accessible telephone with a clear floor space of at least 30 inches by 48 inches that allows either a forward or parallel approach by a person using a wheelchair such that bases, enclosures, and fixed seats do not impede approaches to the telephone; with the highest operable part of the telephone mounted no more than 48 inches above the floor for a front approach or no more than 54 inches above the floor for a side approach; that is hearing aid compatible and has a volume control mechanism; with telephone books, if provided, located between 15 and 48 inches above the finished floor for a front approach or between 9 and 54 inches above the finished floor for a side approach; with a cord of at least 29 inches long from the telephone to the handset; and with signage that complies with the Standards. Standards §§ 4.31, 4.30.7(2).

D. Ramp inside the Pyramid at the south parking drop-off zone

1) The ramp is inaccessible because three of its four legs (excepting the bottom leg) have a slope that exceeds 1:12. In addition, the level landing in between the bottom and next higher leg has a slope of 3.3%. Provide a ramp that is at least 36 inches wide with a slope not exceeding 1:12 and a cross slope not exceeding 1:50; with level landings at least as wide as the ramp and 60 inches long at the top and bottom of the ramp; and with edge protection at least 2 inches high at the drop off sides. Provide handrails that are between 1¼ inches and 1½ inches in diameter with a continuous gripping surface along both sides of the ramp, extending at least 12 inches beyond the top and bottom of the ramp parallel with the ground surface. Ensure that handrails are mounted between 34 inches and 38 inches above the ramp surface and 1½ inches from the wall, with ends rounded or returned smoothly to the floor, wall, or post, and that they do not rotate within their fittings. Ensure that the ramp and approaches are designed so that water will not accumulate on walking surfaces. Standards §§ 4.3.8, 4.8.

E. South East Plaza Level-Women Toilet Room with Stalls (applies to four sets of toilet rooms similar to each other) for each toilet room:

1) No accessible mirror has been provided. Provide a mirror in each toilet room with the bottom edge of its reflecting surface no more than 40 inches above the finished floor. Standards § 4.19.6.

2) Designated accessible standard toilet stall:

a) The toilet paper dispenser in each toilet room is inaccessible because it is mounted above the grab bar. Provide a toilet paper dispenser in each toilet room that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

3) Designated accessible ambulatory toilet stall:

a) The ambulatory stall toilet paper dispenser in each toilet room is inaccessible because it is mounted above the grab bar and is 36.5 inches from the rear wall. Provide a toilet paper dispenser in each toilet room that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

4) The route near the baby changing table in each toilet room is inaccessible because the baby changing table protrudes into the main walkway and would not be detectable to a blind person using a cane. Provide an accessible route in each toilet room at this location such that no objects with their bottom leading edges measuring between 27 inches and 80 inches above the finished floor protrude more than 4 inches into walks, halls, corridors, passageways, or aisles. Free-standing objects mounted on posts or pylons may overhang 12 inches maximum from 27 inches to 80 inches above the ground or finished floor. Standards § 4.4.

F. South East Plaza Level-Men Toilet Room with Stalls (applies to four sets of toilet rooms similar to each other) for each toilet room:

1) No accessible mirror has been provided in each toilet room. Provide a mirror in each toilet room with the bottom edge of its reflecting surface no more than 40 inches above the finished floor. Standards § 4.19.6.

2) Designated accessible standard toilet stall:

a) The toilet in each toilet room is inaccessible because the flush control is on the closed side. Provide a flush control in each toilet room mounted on the "open" side of the toilet's clear floor space; 44 inches or less above the finished floor; and requiring a maximum of 5 pounds of force to operate; or provide an automatic flush device. Standards §§ 4.16.5, 4.17.2, 4.27.4.

b) The toilet paper dispenser in each toilet room is inaccessible because it is mounted above the grab bar. Provide a toilet paper dispenser in each toilet room that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

c) The rear grab bar at the toilet in each toilet room is inaccessible because it is only 24 inches long, the closer end is 7 inches from the side wall and it is mounted 32 inches above the finished floor. Provide a rear grab bar in each toilet room that is at least 36 inches in overall length, with the closer end no more than 6 inches from the side wall; mounted 33 to 36 inches above the finished floor; with a diameter between 1¼ and 1½ inches; with 1½ inches between the grab bar and the wall; and at least 1½ inches between the grab bar and any other object, such as a toilet seat cover dispenser. Standards §§ 4.17.6, 4.26.2, Fig. 30.

3) Designated accessible ambulatory toilet stall:

a) The toilet paper dispenser in each ambulatory stall is inaccessible because it is mounted above the side grab bar. Provide a toilet paper dispenser in each toilet room that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

b) In each ambulatory stall, the farther end of the parallel grab bars are 52 inches from the rear wall and the closer end is 10 inches from the rear wall. Provide at least one stall in each toilet room that is exactly 36 inches wide with a toilet 18 inches from each wall or partition, an outward swinging, self-closing door, and parallel grab bars complying with Fig 30(d). Standards §§ 4.22.4, Fig. 30(d).

G. Mezzanine Level Near Elevator - Women's Toilet Room with Stalls

1) The toilet room sign is inaccessible. Provide a toilet room sign with raised and Braille characters mounted on the wall adjacent to the latch side of the door with the centerline of the sign 60 inches above the finished floor and situated such that a person can approach within 3 inches of the sign without encountering an obstruction or standing within a door swing. Standards §§ 4.1.2(7)(d), 4.30.1, 4.30.4, 4.30.5, 4.30.6.

2) The mezzanine level women's toilet room is inaccessible because the pressure required to open the door is 14 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

3) The lavatory is inaccessible because the hot water pipes are not insulated or otherwise configured to protect against contact. Provide hot water and drain pipes that are insulated or otherwise configured to protect against contact. Standards § 4.19.4.

4) The toilet is inaccessible because its centerline measures 19½ inches from the side wall. Provide a toilet with a centerline that measures 18 inches from the near side wall. Standards § 4.17.3, Fig. 30.

5) No accessible coat hook has been provided. Provide a coat hook at a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that is accompanied by clear floor space of 30 by 48 inches that allows a forward or parallel approach by a person using a wheelchair. Standards §§ 4.25.2, 4.25.3, 4.2.4, 4.2.5, 4.2.6.

6) The toilet paper dispenser is inaccessible because it is mounted above the grab bar. Provide a toilet paper dispenser that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

H. Mezzanine Level Near Elevator - Men's Toilet Room with Stalls

2) The mezzanine level men's toilet room is inaccessible because the pressure required to open the door is 20 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

4) The toilet is inaccessible because its centerline measures 19 inches from the side wall. Provide a toilet with a centerline that measures 18 inches from the near side wall. Standards § 4.17.3, Fig. 30.

I. Family Unisex Toilet Room Single User on the Mezzanine and Plaza Levels (two sets, similar to each other) for each toilet room:

1) The toilet room sign is mounted on the door. Provide a toilet room sign with raised and Braille characters mounted on the wall adjacent to the latch side of the door with the centerline of the sign 60 inches above the finished floor and situated such that a person can approach within 3 inches of the sign without encountering an obstruction or standing within a door swing. Standards §§ 4.1.2(7)(d), 4.30.1, 4.30.4, 4.30.5, 4.30.6.

2) The mezzanine level unisex toilet room is inaccessible because the pressure required to open the door is 16 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

3) The toilet is inaccessible because there is insufficient clear floor space. Provide clear floor space at the toilet that complies with Fig. 28. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.4, 4.16.2, Fig. 28.

4) The toilet paper dispenser is inaccessible because it is mounted on the wrong wall. Provide a toilet paper dispenser that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.4, 4.17.3, Fig. 30(d).

5) The toilet seat cover dispenser is inaccessible because the controls are mounted too high above the finished floor. Provide a toilet seat cover dispenser with the controls a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that is accompanied by clear floor space of 30 by 48 inches that allows a forward or parallel approach by a person using a wheelchair. Standards §§ 4.1.3(13), 4.1.6(1)(b), 4.27.2, 4.27.3, 4.2.4, 4.2.5, 4.2.6.

J. Arena / Event Area - Men's Toilet Room with Stalls (applies to four sets of toilet rooms similar to each other) for each toilet room:

2) The toilet paper dispenser in each toilet room is inaccessible because it is mounted above the grab bar. Provide a toilet paper dispenser in each toilet room that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

K. Arena / Event Area - Women's Toilet Room with Stalls (applies to four sets of toilet rooms similar to each other) for each toilet room:

2) Designated accessible standard toilet stall:

a) The toilet in each toilet room is inaccessible because the top of the seat is 20 inches above the finished floor. Provide a toilet in each toilet room with a seat that measures 17 to 19 inches above the finished floor. Standards §§ 4.16.3, 4.17.2, Fig. 30(d).

3) The route within the toilet room is inaccessible because the sanitary napkin dispenser is a protruding object. Provide an accessible route at this location such that no objects with their bottom leading edges measuring between 27 inches and 80 inches above the finished floor protrude more than 4 inches into walks, halls, corridors, passageways, or aisles. Free-standing objects mounted on posts or pylons may overhang 12 inches maximum from 27 inches to 80 inches above the ground or finished floor. Standards § 4.4.

L. Mezzanine Level near Sections 147 and 121

1) The routes in these locations are inaccessible because stairways pose an overhead hazard. Provide an accessible route at this location with a 80 inch minimum clear head room at all times. Barriers may be used at these locations. Standards § 4.4.2.

M. East Mezzanine Level - Women's Toilet Room with Stalls

1) No accessible mirror has been provided. Provide a mirror with the bottom edge of its reflecting surface no more than 40 inches above the finished floor. Standards § 4.19.6.

2) Designated accessible standard toilet stall:

a) The toilet is inaccessible because the flush control is on the closed side. Provide a flush control mounted on the "open" side of the toilet's clear floor space; 44 inches or less above the finished floor; and requiring a maximum of 5 pounds of force to operate; or provide an automatic flush device. Standards §§ 4.16.5, 4.17.2, 4.27.4.

b) The toilet paper dispenser is inaccessible because it is mounted above the side grab bar. Provide a toilet paper dispenser that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

c) The side grab bar at the toilet is inaccessible because the far end is mounted only 49½ inches from the rear wall. Provide a side grab bar that is at least 40 inches in overall length, with the far end mounted at least 52 inches from the rear wall and the closer end 12 inches or less from the rear wall; mounted 33 to 36 inches above the finished floor; with a diameter between 1¼ and 1½ inches; with 1½ inches between the grab bar and the wall; and at least 1½ inches between the grab bar and any other object, such as the toilet paper dispenser. Standards §§ 4.17.6, 4.26.2, Figs. 30(a), (d).

d) The rear grab bar at the toilet is inaccessible because it is only 34 inches long. Provide a rear grab bar that is at least 36 inches in overall length with the closer end no more than 6 inches from the side wall. Standards § 4.17.6, Fig. 30.

3) Designated accessible ambulatory stall:

a) The partitions in the ambulatory stall are 37½ inches apart. Provide at least one stall that is exactly 36 inches wide with a toilet 18 inches from each wall or partition, an outward swinging, self-closing door, and parallel grab bars complying with Fig 30(d). Standards §§ 4.22.4, Fig. 30(d).

b) The ambulatory stall toilet paper dispenser is inaccessible because it is mounted above the side grab bar. Provide a toilet paper dispenser that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

N. East Mezzanine Level - Men's Toilet Room with Stalls

1) No accessible mirror has been provided. Provide a mirror with the bottom edge of its reflecting surface no more than 40 inches above the finished floor. Standards § 4.19.6.

2) Designated accessible standard toilet stall:

a) The toilet paper dispenser is inaccessible because it is mounted above the side grab bar. Provide a toilet paper dispenser that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

b) The side grab bar at the toilet is inaccessible because the far end is mounted only 48 inches from the rear wall. Provide a side grab bar that is at least 40 inches in overall length, with the far end mounted at least 52 inches from the rear wall and the closer end 12 inches or less from the rear wall; mounted 33 to 36 inches above the finished floor; with a diameter between 1¼ and 1½ inches; with 1½ inches between the grab bar and the wall; and at least 1½ inches between the grab bar and any other object, such as the toilet paper dispenser. Standards §§ 4.17.6, 4.26.2, Figs. 30(a), (d).

c) The rear grab bar at the toilet is inaccessible because it is only 34 inches long. Provide a rear grab bar that is at least 36 inches in overall length with the closer end no more than 6 inches from the side wall. Standards § 4.17.6, Fig. 30.

O. West Mezzanine Level - Men's Toilet Room with Stalls

1) No accessible mirror has been provided. Provide a mirror with the bottom edge of its reflecting surface no more than 40 inches above the finished floor. Standards § 4.19.6.

2) The toilet paper dispenser is inaccessible. Provide a toilet paper dispenser that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

3) Designated accessible standard toilet stall:

a) The side grab bar at the toilet is inaccessible because the far end is mounted only 48 inches from the rear wall. Provide a side grab bar that is at least 40 inches in overall length, with the far end mounted at least 52 inches from the rear wall and the closer end 12 inches or less from the rear wall; mounted 33 to 36 inches above the finished floor; with a diameter between 1¼ and 1½ inches; with 1½ inches between the grab bar and the wall; and at least 1½ inches between the grab bar and any other object, such as the toilet paper dispenser. Standards §§ 4.17.6, 4.26.2, Figs. 30(a), (d).

b) The rear grab bar at the toilet is inaccessible because it is only 34 inches long. Provide a rear grab bar that is at least 36 inches in overall length with the closer end no more than 6 inches from the side wall. Standards § 4.17.6, Fig. 30.

P. West Mezzanine Level - Women's Toilet Room with Stalls

1) No accessible mirror has been provided. Provide a mirror with the bottom edge of its reflecting surface no more than 40 inches above the finished floor. Standards § 4.19.6.

2) Designated accessible standard toilet stall:

3) Designated accessible ambulatory toilet stall:

a) The ambulatory stall partitions are 37½ inches apart. Provide at least one stall that is exactly 36 inches wide with a toilet 18 inches from each wall or partition, an outward swinging, self-closing door, and parallel grab bars complying with Fig 30(d). Standards §§ 4.22.4, Fig. 30(d).

b) The ambulatory stall toilet paper dispenser is inaccessible because it is mounted above the grab bar. Provide a toilet paper dispenser that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

Q. Pyramid Room - Women Toilet Room with Stalls

1) No accessible mirror has been provided. Provide a mirror with the bottom edge of its reflecting surface no more than 40 inches above the finished floor. Standards § 4.19.6.

2) No accessible coat hook has been provided. Provide a coat hook at a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that is accompanied by clear floor space of 30 by 48 inches that allows a forward or parallel approach by a person using a wheelchair. Standards §§ 4.25.2, 4.25.3, 4.2.4, 4.2.5, 4.2.6.

3) The toilet paper dispenser is inaccessible because it is mounted above the side grab bar. Provide a toilet paper dispenser that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

R. Pyramid Room - Men's Toilet Room with Stalls

1) The men's toilet room is inaccessible because the pressure required to open the door is 10 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

2) No accessible mirror has been provided. Provide a mirror with the bottom edge of its reflecting surface no more than 40 inches above the finished floor. Standards § 4.19.6.

3) No accessible coat hook has been provided. Provide a coat hook at a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that is accompanied by clear floor space of 30 by 48 inches that allows a forward or parallel approach by a person using a wheelchair. Standards §§ 4.25.2, 4.25.3, 4.2.4, 4.2.5, 4.2.6.

4) The toilet paper dispenser is inaccessible because it is mounted above the side grab bar. Provide a toilet paper dispenser that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

S. Plaza Level - Drinking Fountain

1) Although there are two drinking fountains on the plaza level, there is no accessible drinking fountain because the water flow is 6 inches from the front of the fountain, and the controls require 8 pounds to operate. Provide at least one drinking fountain with a spout height no higher than 36 inches, measured from the finished floor or ground surface to the spout outlet; and a spout located at the front of the unit that directs the water flow in a trajectory that is nearly parallel to the front of the unit and is positioned so the flow of water is within 3 inches of the front edge of the fountain and at least 4 inches high. Ensure that fountain controls are operable with one hand, require 5 pounds of force or less to operate without tight grasping, pinching, or twisting of the wrist; and are front mounted or side mounted near the front edge. Additionally, provide a drinking fountain that is accessible to people who have difficulty bending or stooping. This can be accommodated by the use of a "hi-lo" fountain; by providing one fountain accessible to those who use wheelchairs and one fountain at a standard height convenient for those who have difficulty bending; by providing a fountain accessible to people who use wheelchairs and a cup dispenser; or by such other means as would achieve the required accessibility for each group of people. Standards §§ 4.15, 4.27.4, Fig. 27.

T. Pyramid Room Level - Drinking Fountain

1) Although there is one drinking fountain on the pyramid room level, there is no accessible drinking fountain because the controls require 8 pounds to operate, and insufficient knee space has been provided. Provide at least one drinking fountain with a spout height no higher than 36 inches, measured from the finished floor or ground surface to the spout outlet; and a spout located at the front of the unit that directs the water flow in a trajectory that is nearly parallel to the front of the unit and is positioned so the flow of water is within 3 inches of the front edge of the fountain and at least 4 inches high. Ensure that fountain controls are operable with one hand, require 5 lbf or less to operate without tight grasping, pinching, or twisting of the wrist; and are front mounted or side mounted near the front edge. Additionally, provide a drinking fountain that is accessible to people who have difficulty bending or stooping. This can be accommodated by the use of a "hi-lo" fountain; by providing one fountain accessible to those who use wheelchairs and one fountain at a standard height convenient for those who have difficulty bending; by providing a fountain accessible to people who use wheelchairs and a cup dispenser; or by such other means as would achieve the required accessibility for each group of people. Standards §§ 4.15, 4.27.4, Fig. 27.

U. South Mezzanine - Elevator

1) The elevator is inaccessible because the time from the notification that a car is answering a call until the doors of that car close is less than 5 seconds. Provide doors that open and close automatically with a reopening device that will stop and reopen the car door and hoistway door automatically if the door becomes obstructed by an object or person. Ensure that the device is capable of completing these operations without requiring contact for obstructions passing through the opening at heights of 5 inches and 29 inches above the finished floor; that door reopening devices remain effective for at least 20 seconds, after which the doors may close; that the minimum time from notification that a car is answering a call until the doors of that car start to close is 5 seconds; and that the minimum time for elevator doors to remain fully open in response to a car call is 3 seconds. Standards §§ 4.10.6, 4.10.7, 4.10.8, Figs. 20, 21.

2) The elevator is inaccessible because, although an emergency communications system is provided, it does not work without voice communications, it requires tight grasping to use them, the emergency communication system is not identified by raised a symbol and lettering, and the highest operable part of the emergency communications is more than 48 inches high. Provide a two-way communication system such that it does not require voice communication, the highest operable part is a maximum of 48 inches above the finished floor of the car, and it is identified by a raised symbol and lettering located adjacent to the device. If the system uses a handset, ensure that the length of the cord from the panel to the handset is at least 29 inches. If the system is located in a closed compartment, ensure that the compartment door hardware operates without tight grasping, pinching or twisting of the wrist. Standards § 4.10.14.

V. Sink Near Gate # 1

1) The lavatory is inaccessible because the hot water pipes are not insulated or otherwise configured to protect against contact. Provide hot water and drain pipes that are insulated or otherwise configured to protect against contact. Standards § 4.19.4.

2) The route near the sink near gate # 1 is inaccessible because the wall-mounted sink protrudes into the main walkway and would not be detectable to a blind person using a cane. Provide an accessible route at this location such that no objects with their bottom leading edges measuring between 27 inches and 80 inches above the finished floor protrude more than 4 inches into walks, halls, corridors, passageways, or aisles. Free-standing objects mounted on posts or pylons may overhang 12 inches maximum from 27 inches to 80 inches above the ground or finished floor. Standards § 4.4.

W. Portable Concession Counters

1) The Portable Concession counters in the Pyramid are inaccessible because their surfaces are 37½ inches above the finished floor. Provide a counter on an accessible route such that a portion of the counter is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary counter with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, a clip board made available to the public, or other means. Standards §§ 4.1.1(2), 7.2(2), 4.1.3(1), 4.3.

X. Chorus Room Dressing Rooms Arena Level

1) There is no designated accessible standard toilet stall; instead, there is a designated accessible ambulatory toilet stall with 39 inches between partitions, two side grab bars, and a rear grab bar. Provide a "standard" accessible toilet stall at least 60 inches wide and at least 59 inches deep (or at least 56 inches deep with a wall-mounted toilet) such that all of the stall's elements, including stall door, stall door hardware, water closet, size and arrangement, toe clearances, grab bars, controls, and dispensers, comply with the Standards. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.4, 4.22.7, 4.13, 4.16, 4.17, 4.26, 4.27, Fig. 30.

Y. Tournament - Unisex Locker Room

1) The unisex locker room lacks accessible signage. Provide a locker room sign with the International Symbol of Accessibility and raised and Braille characters. The sign shall be mounted on the wall adjacent to the latch side of the door with the centerline of the sign at 60 inches above the finished floor and situated such that a person can approach within 3 inches of the sign without encountering an obstruction or standing within a door swing. Standards §§ 4.1.2(7)(d), 4.30.1, 4.30.4, 4.30.5, 4.30.6, 4.30.7.

Z. Visitor's Unisex Locker Room

3. Within 12 months of the effective date of the Agreement, the City will complete the following modifications to the Court Square, located at 45 North Second St, Memphis, TN:

A. Lawn areas: The route from the sidewalks to all lawn areas is inaccessible because, although the lawn areas are open to the public, curbs prevent people with disabilities from entering the lawn areas. Provide a curb ramp to each lawn area, that is at least 36 inches wide, has a maximum slope of 1:12, is located so that it cannot be obstructed by parked vehicles, and has a stable, firm, and slip-resistant surface with a detectable warning extending the full width and depth of the ramp. If the curb ramp is located where pedestrians must walk across it, provide either flared sides (with a maximum slope of 1:10) or handrails or guardrails to protect against cross traffic. Standards §§ 4.1.2(1), 4.1.2(2), 4.1.6(1)(b), 4.3.8, 4.7, Fig. 12.

4. Within 24 months of the effective date of the Agreement, the City will complete the following modifications to the Ed Rice (Frayser) Community Center, located at 2907 Watkins Street, Memphis, TN:

A. The route from the parking area to the facility is inaccessible because the curb ramp has an excessive cross-slope of 2.1 degrees. Provide a curb ramp that is at least 36 inches wide, has a maximum slope of 1:12, is located so that it cannot be obstructed by parked vehicles, and has a stable, firm, and slip-resistant surface with a detectable warning extending the full width and depth of the ramp. If the curb ramp is located where pedestrians must walk across it, provide either flared sides (with a maximum slope of 1:10) or handrails or guardrails to protect against cross traffic. Standards § 4.1.6(1)(a), 4.3.8, 4.7, Fig. 12.

B. The circulation path near the hi-lo drinking fountain in the lobby is inaccessible because the high fountain is not detectable to a blind person using a cane. Provide a high drinking fountain at this location such that its bottom leading edges measure no more than 27 inches above the finished floor or protrude no more than 4 inches into the walkway, or provide a cane-detectable barrier to alert blind people to this feature. Standards § 4.1.6(1)(b), 4.4.

C. Toilet rooms with stalls adjacent to gym Men's and Women's

1) The toilet room sign for each toilet room is inaccessible. Provide a toilet room sign for each toilet room with raised and Braille characters mounted on the wall adjacent to the latch side of the door with the centerline of the sign 60 inches above the finished floor and situated such that a person can approach within 3 inches of the sign without encountering an obstruction or standing within a door swing. Standards §§ 4.1.2(7)(d), 4.30.1, 4.30.4, 4.30.5, 4.30.6.

2) The toilet room door to each toilet room is inaccessible because the pressure required to open the door is 8 pounds. Provide a door to each toilet room that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

3) Designated accessible standard toilet stall in each toilet room:

a) (Women's toilet room only) The toilet is inaccessible because the top of the seat is 20 inches above the finished floor. Provide a toilet with a seat that measures 17 to 19 inches above the finished floor. Standards §§ 4.16.3, 4.17.2, Fig. 30(d).

b) No accessible coat hook has been provided. Provide a coat hook in each toilet room at a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that is accompanied by clear floor space of 30 by 48 inches that allows a forward or parallel approach by a person using a wheelchair. Standards §§ 4.25.2, 4.25.3, 4.2.4, 4.2.5, 4.2.6.

D. Unisex single-user toilet room

E. The ramp is inaccessible because the handrails extensions at the bottom are not level. Provide handrails that are between 1¼ inches and 1½ inches in diameter with a continuous gripping surface along both sides of the ramp, extending at least 12 inches beyond the top and bottom of the ramp parallel with the ground surface. Ensure that handrails are mounted between 34 inches and 38 inches above the ramp surface and 1½ inches from the wall, with ends rounded or returned smoothly to the floor, wall, or post, and that they do not rotate within their fittings. Standards § 4.8.5.

5. Within 24 months of the effective date of the Agreement, the City will complete the following modifications to the Ed Rice Pool, located at 2907 N. Watkins Street, Memphis, TN:

A. Family Changing Room

1) The door to the family changing room is inaccessible because the pressure required to open the door is 13 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

2) No accessible mirror has been provided. Provide a mirror with the bottom edge of its reflecting surface no more than 40 inches above the finished floor. Standards § 4.19.6.

3) The lavatory is inaccessible because the apron is mounted at 26.75 inches high. Provide a lavatory with the top of its rim or counter 34 inches or less above the finished floor; the bottom edge of the apron at least 29 inches above the finished floor; and knee and toe clearances that comply with Fig. 31. Standards § 4.19.2, Fig. 31.

4) The toilet in the designated accessible stall is inaccessible because the top of the seat is 20.5 inches above the finished floor. Provide a toilet with a seat that measures 17 to 19 inches above the finished floor. Standards §§ 4.16.3, 4.17.2, Fig. 30(d).

5) The bench in the family changing room is only 38.5 inches long. Provide a 24 inch by 48 inch bench fixed to the wall along the bench's longer dimension. Ensure that the bench has sufficient structural strength and is mounted with its surface between 17 inches and 19 inches above the finished floor. Provide clear floor space alongside the bench to allow a person using a wheelchair to make a parallel transfer onto the bench. Standards §§ 4.35.4, 4.26.3.

6) The route of travel in the family changing room is inaccessible because the hand dryer is a protruding object. Provide an accessible route at this location such that no objects with their bottom leading edges measuring between 27 inches and 80 inches above the finished floor protrude more than 4 inches into walks, halls, corridors, passageways, or aisles. Free-standing objects mounted on posts or pylons may overhang 12 inches maximum from 27 inches to 80 inches above the ground or finished floor. Standards § 4.4.

B. Men's Toilet Room / Locker Room

2) Designated accessible standard stall:

a) The toilet is inaccessible because its centerline measures 19 inches from the side wall. Provide a toilet with a centerline that measures 18 inches from the near side wall. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.4, 4.17.3, Fig. 30.

b) The toilet is inaccessible because the flush control is on the closed side. Provide a flush control mounted on the "open" side of the toilet's clear floor space; 44 inches or less above the finished floor; and requiring a maximum of 5 pounds of force to operate; or provide an automatic flush device. Standards §§ 4.16.5, 4.17.2, 4.27.4.

3) The roll-in shower is inaccessible because there is a .25 inch curb at the entrance to the shower. For shower stalls that are exactly 36 inches wide and 36 inches deep, provide a curb at the shower entrance that is no higher than ½ inch. For shower stalls that are at least 30 inches deep and 60 inches wide, ensure that there is no curb or threshold at the shower entrance. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.21.7.

4) The bench in the Men's Locker Room is only 18.5 inches wide. Provide a 24 inch by 48 inch bench fixed to the wall along the bench's longer dimension. Ensure that the bench has sufficient structural strength and is mounted with its surface between 17 inches and 19 inches above the finished floor. Provide clear floor space alongside the bench to allow a person using a wheelchair to make a parallel transfer onto the bench. Standards §§ 4.35.4, 4.26.3.

C. Women's Toilet Room / Locker Room

2) Designated accessible standard stall:

a) The toilet is inaccessible because the top of the seat is 20.5 inches above the finished floor. Provide a toilet with a seat that measures 17 to 19 inches above the finished floor. Standards §§ 4.16.3, 4.17.2, Fig. 30(d).

b) The toilet is inaccessible because its centerline measures 19 inches from the side wall. Provide a toilet with a centerline that measures 18 inches from the near side wall. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.4, 4.17.3, Fig. 30.

c) The toilet is inaccessible because the flush control is on the closed side. Provide a flush control mounted on the "open" side of the toilet's clear floor space; 44 inches or less above the finished floor; and requiring a maximum of 5 pounds of force to operate; or provide an automatic flush device. Standards §§ 4.16.5, 4.17.2, 4.27.4.

6. Within 24 months of the effective date of the Agreement, the City will complete the following modifications to the Ed Rice / Frayser Tennis Court, located at 2907 Watkins Street, Memphis, TN:

A. The entrance door is inaccessible because there is no level landing within the door's required maneuvering clearance, and no automatic door opener is provided. Provide a door so that the floor or ground area within the required clearances is level and clear. Standards § 4.13.6, Fig. 25.

B. Toilet rooms with stalls Men's and Women's

1) Each toilet room sign is inaccessible. Provide a toilet room sign in each toilet room with raised and Braille characters mounted on the wall adjacent to the latch side of the door with the centerline of the sign 60 inches above the finished floor and situated such that a person can approach within 3 inches of the sign without encountering an obstruction or standing within a door swing. Standards §§ 4.1.2(7)(d), 4.30.1, 4.30.4, 4.30.5, 4.30.6.

2) Each toilet room door is inaccessible because the pressure required to open the door is greater than 5 pounds. Provide a door to each toilet room that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

3) No accessible mirror has been provided in each toilet room. Provide a mirror in each toilet room with the bottom edge of its reflecting surface no more than 40 inches above the finished floor. Standards § 4.19.6.

4) The lavatory in each toilet room is inaccessible because the apron bottom edges are 21 and 22 inches high. Provide a lavatory in each toilet room with the top of its rim or counter 34 inches or less above the finished floor; the bottom edge of the apron at least 29 inches above the finished floor; and knee and toe clearances that comply with Fig. 31. Standards § 4.19.2, Fig. 31.

5) The lavatory in each toilet room is inaccessible because the faucets require twisting for operation. Provide a lavatory in each toilet room with a faucet that can be operated with 5 pounds of force or less and can be used with one hand and without tight grasping, pinching, or twisting of the wrist (lever-operated, push-type, and electronically controlled mechanisms are examples of acceptable designs). Standards §§ 4.19.5, 4.27.4.

6) (Men's toilet room only) The urinal is inaccessible because the urinal rim and flush control heights are 23.5 and 52 inches high, respectively. Provide a urinal with an elongated rim mounted 17 inches or less above the finished floor, a clear floor space of at least 30 inches wide and 48 inches deep centered on the urinal, and a flush control height of 44 inches or less above the finished floor. Standards §§ 4.18.2, 4.18.3, 4.18.4.

7) Designated standard accessible toilet stall:

a) The designated accessible stall is incorrectly configured as an ambulatory stall, and there is no standard accessible stall provided. Provide a "standard" accessible toilet stall at least 60 inches wide and at least 59 inches deep (or at least 56 inches deep with a wall-mounted toilet) such that all of the stall's elements, including stall door, stall door hardware, water closet, size and arrangement, toe clearances, grab bars, controls, and dispensers, comply with the Standards. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.13, 4.16, 4.17, 4.26, 4.27, Fig. 30.

8) The shower in each toilet room is inaccessible. Provide a shower in each room that is exactly 36 inches wide and 36 inches deep with a 48 inch long and 36 inch wide clear floor space alongside the shower opening, and an L-shaped shower seat mounted on the wall opposite the controls and extending the full depth of the stall; OR a shower that is at least 30 inches deep and 60 inches wide with no curb or threshold and with a 36 inch deep and 60 inch wide clear floor space at the shower opening. Ensure that the shower has grab bars, controls, a shower spray unit, and a seat, curb, and enclosure, if provided, that comply fully with the Standards and with Figs. 35, 36, and 37, as applicable. Standards § 4.21, Figs. 35, 36, 37.

7. Within 24 months of the effective date of the Agreement, the City will complete the following modifications to the Memphis Botanic Garden, located at 750 Cherry Road, Memphis, TN:

A. Parking (altered portion)

1) Although the parking lot has a total of 232 parking spaces of which 8 are designated as being accessible to people with disabilities, an inadequate number are van accessible. On the shortest accessible route to the accessible entrance, provide 1 van accessible space a minimum of 96 inches wide, served by access aisles at least 96 inches wide, with vertical signs with the International Symbol of Accessibility located such that they cannot be obstructed by parked vehicles, and with an additional "Van-Accessible" sign located below the International Symbol of Accessibility. Standards §§ 4.1.2(5)(b), 4.1.6(1)(b), 4.6, 4.30.7(1).

B. Exterior entrance

1) The building is inaccessible because the exterior entrance lacks the proper signage. Provide accessible directional signage with the International Symbol of Accessibility at inaccessible entrances directing users to the accessible entrance, and provide accessible signage with the International Symbol of Accessibility at all permanent accessible entrances. Standards §§ 4.1.3(8)(d), 4.1.3(16)(b), 4.1.6(1)(b), 4.13, 4.30.

C. Ramp to Main Entrance

1) The ramp is inaccessible because the upper leg has a slope of 8.8%, the ramp has a cross slope of 2.9%, and the ramp has handrails that extend only 8 inches beyond the top and bottom of the ramp. Provide a ramp that is at least 36 inches wide with a slope not exceeding 1:12 and a cross slope not exceeding 1:50; with level landings at least as wide as the ramp and 60 inches long at the top and bottom of the ramp; with level landings measuring at least 60 inches by 60 inches when the ramp changes direction; and edge protection that is at least 2 inches high at the drop off sides. Provide handrails that are between 1¼ inches and 1½ inches in diameter such that the inside handrail is continuous and both handrails have a continuous gripping surface along both sides of the ramp extending at least 12 inches beyond the top and bottom of the ramp parallel with the ground surface; the handrails do not rotate within their fittings; and both handrails are mounted between 34 inches and 38 inches above the ramp surface and 1½ inches from the wall, with ends rounded or returned smoothly to the floor, wall, or post. Ensure that the ramp and approaches are designed so that water will not accumulate on walking surfaces. Standards §§ 4.1.2(1), 4.1.2(2), 4.1.6(1)(b), 4.3.8, 4.8.

D. Ramp to Hardin Hall

1) The ramp is inaccessible because the bottom leg has a slope of 9.6%, the top leg has a slope of 8.5%, and a planter on the middle landing interferes with accessibility. In addition, the handrails are mounted too low, are too far from the wall at 2.25 inches, and are too wide at 3 inches. Provide a ramp that is at least 36 inches wide with a slope not exceeding 1:12 and a cross slope not exceeding 1:50; with level landings at least as wide as the ramp and 60 inches long at the top and bottom of the ramp; with level landings measuring at least 60 inches by 60 inches when the ramp changes direction; and edge protection that is at least 2 inches high at the drop off sides. Provide handrails that are between 1¼ inches and 1½ inches in diameter such that the inside handrail is continuous and both handrails have a continuous gripping surface along both sides of the ramp extending at least 12 inches beyond the top and bottom of the ramp parallel with the ground surface; the handrails do not rotate within their fittings; and both handrails are mounted between 34 inches and 38 inches above the ramp surface and 1½ inches from the wall, with ends rounded or returned smoothly to the floor, wall, or post. Ensure that the ramp and approaches are designed so that water will not accumulate on walking surfaces. Standards §§ 4.1.2(1), 4.1.2(2), 4.1.6(1)(b), 4.3.8, 4.8.

E. Coat check counter

1) The coat check counter is inaccessible because it is 42 inches high. Provide a counter on an accessible route such that a portion of the counter is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary counter with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, a clip board made available to the public, or other means. Standards §§ 4.1.1(2), 4.1.6(1)(b), 7.2(2), 4.1.3(1), 4.3.

F. Benches in hallway

1) The benches in the hallway are 19 inches deep. Provide a 24 inch by 48 inch bench fixed to the wall along the bench's longer dimension. Ensure that the bench has sufficient structural strength and is mounted with its surface between 17 inches and 19 inches above the finished floor. Provide clear floor space alongside the bench to allow a person using a wheelchair to make a parallel transfer onto the bench. Standards §§ 4.1.3(21), 4.1.6(1)(b), 4.35.4, 4.26.3.

G. Women's Toilet Room with Stalls near Hardin Hall

1) The door to the Women's Toilet Room with Stalls near Hardin Hall is inaccessible because the pressure required to open the door is 10 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards §§ 4.1.3(7)(b), 4.1.6(1)(b), 4.13.11(2)(b).

2) The paper towel dispenser is inaccessible because the controls are mounted at 71 inches above the finished floor. Provide a paper towel dispenser with the controls a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that is accompanied by clear floor space of 30 by 48 inches that allows a forward or parallel approach by a person using a wheelchair. Standards §§ 4.1.3(13), 4.1.6(1)(b), 4.27.2, 4.27.3, 4.2.4, 4.2.5, 4.2.6.

4) There is no accessible stall provided. Provide a "standard" accessible toilet stall at least 60 inches wide and at least 59 inches deep (or at least 56 inches deep with a wall-mounted toilet) such that all of the stall's elements, including stall door, stall door hardware, water closet, size and arrangement, toe clearances, grab bars, controls, and dispensers, comply with the Standards. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.4, 4.22.7, 4.13, 4.16, 4.17, 4.26, 4.27, Fig. 30.

H. Men's Toilet Room with Stalls near Hardin Hall

1) The door to the Men's Toilet Room with Stalls near Hardin Hall is inaccessible because the pressure required to open the door is 10 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards §§ 4.1.3(7)(b), 4.1.6(1)(b), 4.13.11(2)(b).

3) The lavatory is inaccessible because the bottom edge is 28 inches high. Provide a lavatory with the top of its rim or counter 34 inches or less above the finished floor; the bottom edge of the apron at least 29 inches above the finished floor; and knee and toe clearances that comply with Fig. 31. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.6, 4.19.2, Fig. 31.

4) The lavatory is inaccessible because the hot water pipes are not insulated or otherwise configured to protect against contact. Provide hot water and drain pipes that are insulated or otherwise configured to protect against contact. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.6, 4.19.4.

5) The urinal is inaccessible because the rim height is 18.5 inches. Provide a urinal with an elongated rim mounted 17 inches or less above the finished floor, a clear floor space of at least 30 inches wide and 48 inches deep centered on the urinal, and a flush control height of 44 inches or less above the finished floor. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.5, 4.18.2, 4.18.3, 4.18.4.

6) The toilet is inaccessible because the top of the seat is 15.5 inches above the finished floor. Provide a toilet with a seat that measures 17 to 19 inches above the finished floor. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.4, 4.16.3, 4.17.2, Fig. 30(d).

7) The toilet paper dispenser is inaccessible because it is broken. Provide a toilet paper dispenser that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.4, 4.17.3, Fig. 30(d).

8) The rear grab bar at the toilet is inaccessible because the closer end is 7.5 inches from the side wall. Provide a rear grab bar that is at least 36 inches in overall length with the closer end no more than 6 inches from the side wall. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.4, 4.17.6, Fig. 30.

I. Drinking Fountain between toilet rooms near Hardin Hall

1) The route near the hi-lo drinking fountain near Hardin Hall is inaccessible because the high fountain is not detectable to a blind person using a cane. Provide a high drinking fountain at this location such that its bottom leading edges measure no more than 27 inches above the finished floor or protrude no more than 4 inches into the walkway, or provide a cane-detectable barrier to alert blind people to this feature. Standards §§ 4.1.2(3), 4.1.6(1)(b), 4.4.

J. Outdoor Ramp to North Entrance to Hardin Hall

1) The ramp is inaccessible because it is missing its inside handrails, and its other handrails are mounted at 33 inches, with 2.5 inches between the rails and the wall. Provide handrails that are between 1¼ inches and 1½ inches in diameter with a continuous gripping surface along both sides of the ramp, extending at least 12 inches beyond the top and bottom of the ramp parallel with the ground surface. Ensure that handrails are mounted between 34 inches and 38 inches above the ramp surface and 1½ inches from the wall, with ends rounded or returned smoothly to the floor, wall, or post, and that they do not rotate within their fittings. Standards §§ 4.1.2(1), 4.1.2(2), 4.1.6(1)(b), 4.8.5.

K. Indoor ramp to Orientation / Meeting Room

1) The ramp is inaccessible because there are no handrail extensions beyond the top and bottom of the ramp, and the handrails are mounted 2.5 inches from the wall. Provide handrails that are between 1¼ inches and 1½ inches in diameter with a continuous gripping surface along both sides of the ramp, extending at least 12 inches beyond the top and bottom of the ramp parallel with the ground surface. Ensure that handrails are mounted between 34 inches and 38 inches above the ramp surface and 1½ inches from the wall, with ends rounded or returned smoothly to the floor, wall, or post, and that they do not rotate within their fittings. Standards §§ 4.1.2(1), 4.1.2(2), 4.1.6(1)(b), 4.8.5.

L. Snack Shop

1) The retail counter at Snack Shop is inaccessible because it is 37 inches high. Provide a counter on an accessible route such that a portion of the counter is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary counter with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, a clip board made available to the public, or other means. Standards §§ 4.1.1(2), 7.2(2), 4.1.3(1), 4.3.

M. Men's & Women's Toilet Rooms with Stalls

1) There is no signage directing people with disabilities to the accessible toilet rooms. Provide accessible directional signage with the International Symbol of Accessibility at inaccessible toilet rooms indicating the location of the nearest accessible toilet room, and provide accessible signage with the International Symbol of Accessibility at all accessible toilet rooms. Standards §§ 4.1.2(7)(d), 4.1.6(3)(e)(iii), 4.30.1, 4.30.2, 4.30.3, 4.30.5, 4.30.7.

N. Goldsmith Auditorium

1) The Goldsmith Auditorium is inaccessible to people with hearing impairments because although there are 50 or more fixed seats, there is no assistive listening system. Provide a permanently installed assistive listening system serving the fixed seating. Ensure that the seating served by the system is located within a 50 foot viewing distance of the stage or playing area and has a complete view of the stage or playing area. Provide a number of receivers equal to 4% of total seats (or a minimum of 2) for use by the general public and signage indicating their availability. 28 C.F.R. § 35.160; Standards §§ 4.30, 4.33.

2) The Counter at the Memphis Botanical Gardens Goldsmith Civic Auditorium is inaccessible because it is 42 inches high. Provide a counter on an accessible route such that a portion of the counter is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary counter with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, a clip board made available to the public, or other means. Standards §§ 7.2(2), 4.3.

O. Goldsmith Hall Fountain

1) The drinking fountain has a spout that is 42.5 inches above the finished floor. Provide a fountain that has a spout height no higher than 36 inches, measured from the finished floor or ground surface to the spout outlet, and that otherwise complies with the Standards. Standards §§ 4.15, 4.27.4, Fig. 27.

2) The drinking fountain is inaccessible because no knee space is provided. Provide a drinking fountain with clear knee space between the bottom of the apron and the finished floor or ground of at least 27 inches high, 30 inches wide, and 17 to 19 inches deep; and a minimum clear floor space of 30 inches by 48 inches to allow a person in a wheelchair to approach the unit facing forward. Standards § 4.15.5(1), Figs. 27(a), (b).

8. Within 24 months of the effective date of the Agreement, the City will complete the following modifications to the Galloway Golf Course located at 3815 Walnut Grove Road, Memphis, TN:

A. Parking

1) Although the parking lot has a total of 120 parking spaces, only 2 are designated as reserved for persons with disabilities, none are van accessible, they are not located on the shortest accessible route, and some lack proper signage. On the shortest accessible route to the accessible entrance, provide 1 van accessible space and 4 standard spaces designated as reserved for people with disabilities. Ensure that standard accessible spaces are a minimum of 96 inches wide and served by access aisles at least 60 inches wide. Ensure that van accessible spaces are a minimum of 96 inches wide and served by access aisles at least 96 inches wide. At all spaces designated as reserved for persons with disabilities, provide vertical signs with the International Symbol of Accessibility located such that they cannot be obstructed by parked vehicles. At van accessible spaces, provide an additional "Van-Accessible" sign located below the International Symbol of Accessibility. Ensure that all spaces and access aisles for persons with disabilities are flat and level, with slopes and cross-slopes not exceeding 1:50 in all directions, and that their surfaces are firm, stable, and slip-resistant. Standards §§ 4.1.2(5), 4.1.6(1)(b), 4.6, 4.30.7(1).

B. Golf Carts

1) Although the City has golf carts for public use at this facility, none are accessible to persons who use wheelchairs. The next time that golf carts are purchased or leased, the City will acquire at least one accessible golf cart to provide program accessibility. 28 C.F.R. § 36. 202(b). The City will implement policies to ensure the accessible cart's availability to persons with disabilities. These will include, for example, allowing persons with disabilities to reserve it or use it without reservations; renting out the accessible golf cart to non-disabled users only when all other carts are in use; charging the same for the use of the accessible cart as others; and maintaining it in good condition. The accessible cart may be used by non-disabled golfers when consistent with the policies set out above.

C. Ramp

1) The ramp is inaccessible because the lower leg has a slope of 9.7%, and the upper leg has a slope of 9.1%. In addition, the upper leg lacks handrail extensions at the top and bottom. Provide a ramp that is at least 36 inches wide with a slope not exceeding 1:12 and a cross slope not exceeding 1:50; with level landings at least as wide as the ramp and 60 inches long at the top and bottom of the ramp; with level landings measuring at least 60 inches by 60 inches when the ramp changes direction; and edge protection that is at least 2 inches high at the drop off sides. Provide handrails that are between 1¼ inches and 1½ inches in diameter such that the inside handrail is continuous and both handrails have a continuous gripping surface along both sides of the ramp extending at least 12 inches beyond the top and bottom of the ramp parallel with the ground surface; the handrails do not rotate within their fittings; and both handrails are mounted between 34 inches and 38 inches above the ramp surface and 1½ inches from the wall, with ends rounded or returned smoothly to the floor, wall, or post. Ensure that the ramp and approaches are designed so that water will not accumulate on walking surfaces. Standards §§ 4.1.2(1), 4.1.2(2), 4.1.6(1)(b), 4.3.8, 4.8.

D. Pro Shop Counter

1) The retail counter at the Pro Shop is inaccessible because it is 42 inches high. Provide a counter on an accessible route such that a portion of the counter is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary counter with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, a clip board made available to the public, or other means. Standards §§ 4.1.1(2), 7.2(2), 4.1.3(1), 4.3.

E. Snack Shop Counter

1) The retail counter at the Snack Shop is inaccessible because it is 42 inches high. Provide a counter on an accessible route such that a portion of the counter is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary counter with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, a clip board made available to the public, or other means. Standards §§ 4.1.1(2), 7.2(2), 4.1.3(1), 4.3.

F. Condiment Counter

1) The tableware and condiment area is inaccessible because the dispensing devices are 64 inches high. Provide tableware and condiment dispensers located between 15 and 48 inches above the finished floor for a front approach or between 9 and 54 inches above the finished floor for a side approach. Standards §§ 4.1.6(1)(b), 5.6, 4.2.5, 4.2.6, Fig. 54.

G. Women's Toilet Room with Stalls

1) The door to the Women's Toilet Room with stalls is inaccessible because the pressure required to open the door is 7 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards §§ 4.1.3(7)(b), 4.1.6(1)(b), 4.13.11(2)(b).

3) The toilet paper dispenser is inaccessible because it is mounted 39 inches from the rear wall. Provide a toilet paper dispenser that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.4, 4.17.3, Fig. 30(d).

4) The side grab bar at the toilet is inaccessible because the far end is mounted 48 inches from the rear wall. Provide a side grab bar that is at least 40 inches in overall length, with the far end mounted at least 52 inches from the rear wall and the closer end 12 inches or less from the rear wall. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.4, 4.17.6, Figs. 30(a), (d).

5) The bench in the Women's Locker Room is 16.5 inches deep, and is free standing rather than affixed to a wall. Provide a 24 inch by 48 inch bench fixed to the wall along the bench's longer dimension. Ensure that the bench has sufficient structural strength and is mounted with its surface between 17 inches and 19 inches above the finished floor. Provide clear floor space alongside the bench to allow a person using a wheelchair to make a parallel transfer onto the bench. Standards §§ 4.1.3(21), 4.1.6(1)(b), 4.35.4, 4.26.3.

6) No accessible mirror has been provided. Provide a mirror with the bottom edge of its reflecting surface no more than 40 inches above the finished floor. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.6, 4.19.6.

H. Men's Toilet Room with Stalls

1) The door to the Men's Toilet Room with Stalls is inaccessible because the pressure required to open the door is 6.5 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards §§ 4.1.3(7)(b), 4.1.6(1)(b), 4.13.11(2)(b).

2) The soap dispenser is inaccessible because the controls are mounted at 39 inches above the finished floor over a 21 inch deep trash can. Provide a soap dispenser such that the controls comply with Fig. 5 for a forward reach or with Fig. 6 for a side reach and such that it is accompanied by clear floor space of 30 by 48 inches that allows a forward or parallel approach, respectively, by a person using a wheelchair. Standards §§ 4.1.3(13), 4.1.6(1)(b), 4.27.2, 4.27.3, 4.2.4, 4.2.5, 4.2.6.

3) The toilet is inaccessible because its centerline measures 19 inches from the side wall. Provide a toilet with a centerline that measures 18 inches from the near side wall. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.4, 4.17.3, Fig. 30.

4) No accessible coat hook has been provided. Provide a coat hook at a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that is accompanied by clear floor space of 30 by 48 inches that allows a forward or parallel approach by a person using a wheelchair. Standards §§ 4.1.3(12)(a), 4.1.6(1)(b), 4.25.2, 4.25.3, 4.2.4, 4.2.5, 4.2.6.

5) The side grab bar at the toilet is inaccessible because the far end is mounted 48 inches from the rear wall. Provide a side grab bar that is at least 40 inches in overall length, with the far end mounted at least 52 inches from the rear wall and the closer end 12 inches or less from the rear wall. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.4, 4.17.6, Figs. 30(a), (d).

6) The rear grab bar at the toilet is inaccessible because the closer end is mounted 7 inches from the side wall. Provide a rear grab bar that is at least 36 inches in overall length with the closer end no more than 6 inches from the side wall. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.4, 4.17.6, Fig. 30.

7) The bench in the Men's Locker Room is 16.5 inches deep and is free standing, rather than affixed to a wall. Provide a 24 inch by 48 inch bench fixed to the wall along the bench's longer dimension. Ensure that the bench has sufficient structural strength and is mounted with its surface between 17 inches and 19 inches above the finished floor. Provide clear floor space alongside the bench to allow a person using a wheelchair to make a parallel transfer onto the bench. Standards §§ 4.1.3(21), 4.1.6(1)(b), 4.35.4, 4.26.3.

9. Within 24 months of the effective date of the Agreement, the City will complete the following modifications to the Randolph Branch Library, located at 3752 Given Avenue, Memphis, TN:

A. Parking

1) Although the parking lot has a total of 36 parking spaces with two designated accessible standard parking spaces, none are van accessible. On the shortest accessible route to the accessible entrance, provide 1 van accessible space a minimum of 96 inches wide, served by access aisles at least 96 inches wide, with vertical signs with the International Symbol of Accessibility located such that they cannot be obstructed by parked vehicles, and with an additional "Van-Accessible" sign located below the International Symbol of Accessibility. Standards §§ 4.1.2(5)(b), 4.6, 4.30.7(1).

2) The signage designating parking spaces as reserved for persons with disabilities is too low. At each space designated as reserved for persons with disabilities, provide a vertical sign with the International Symbol of Accessibility located such that it cannot be obstructed by vehicles parked in the space. Standards §§ 4.6.4, 4.30.7(1).

B. Accessible Route

1) The route from the designated accessible parking spaces to the entrance is inaccessible because the curb ramp has a slope of 10.6%. Provide a curb ramp that is at least 36 inches wide, has a maximum slope of 1:12, is located so that it cannot be obstructed by parked vehicles, and has a stable, firm, and slip-resistant surface with a detectable warning extending the full width and depth of the ramp. If the curb ramp is located where pedestrians must walk across it, provide either flared sides (with a maximum slope of 1:10) or handrails or guardrails to protect against cross traffic. Standards § 4.3.8, 4.7, Fig. 12.

2) The built-up curb ramp impermissibly extends into the access aisle. Provide a curb ramp located so that it does not project into this element and all aspects of the ramp or curb cut comply with the Standards. Standards §§ 4.3.8, 4.7.6.

C. Entrance

1) The main entrance is inaccessible to people with disabilities. The accessible side entrance is locked and requires people with disabilities to use a doorbell to have staff unlock the door. Provide at least one accessible route within the boundary of the site connecting these elements that, to the maximum extent feasible, coincides with the route for the general public. The accessible route must have a minimum clear width of 36 inches, or a minimum clear width of 42 inches if there is a turn around an obstruction less than 48 inches wide; have passing spaces at least 60 inches by 60 inches at least every 200 feet; have a minimum clear headroom of 80 inches; have a surface that is firm, stable, and slip resistant; have, in the absence of a curb ramp, ramp, elevator, or platform lift, no level changes in excess of ½ inch vertically; and have a running slope of less than 1:20 (5%) (or have been constructed as a fully accessible ramp) and a cross slope of less than 1:50 (2%). Standards §§ 4.1.3(1), 4.1.6(1)(b), 4.3, 4.5, Fig. 7.

D. Women's Toilet Room with Stalls

1) The toilet room sign is inaccessible. Provide a toilet room sign with the International Symbol of Accessibility and raised and Braille characters mounted on the wall adjacent to the latch side of the door with the centerline of the sign 60 inches above the finished floor and situated such that a person can approach within 3 inches of the sign without encountering an obstruction or standing within a door swing. Standards §§ 4.1.2(7)(d), 4.30.1, 4.30.4, 4.30.5, 4.30.6, 4.30.7.

2) The door to the Women's Toilet Room is inaccessible because the pressure required to open the door is 10 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

5) The rear grab bar at the toilet is inaccessible because it measures only 24 inches long. Provide a rear grab bar that is at least 36 inches in overall length with the closer end no more than 6 inches from the side wall. Standards § 4.17.6, Fig. 30.

E. Men's Toilet Room with Stalls

2) The door to the Men's Toilet Room with stalls is inaccessible because the pressure required to open the door is 10 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

F. Drinking Fountain

1) The route near the drinking fountain is inaccessible because the fountain is not detectable to a blind person using a cane. Provide a drinking fountain at this location such that its bottom leading edges measure no more than 27 inches above the finished floor or protrude no more than 4 inches into the walkway, or provide a cane-detectable barrier to alert blind people to this feature. Standards § 4.4.

2) The drinking fountain has a spout that is too high. Provide a fountain that has a spout height no higher than 36 inches, measured from the finished floor or ground surface to the spout outlet, and that otherwise complies with the Standards. Standards §§ 4.15, 4.27.4, Fig. 27.

G. Library

1) The Check Out Counter at the Library is inaccessible because the counter is mounted 39.5 inches from the floor. Provide a counter on an accessible route such that a portion of the counter is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary counter with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, a clip board made available to the public, or other means. Standards §§ 7.2(2), 4.3.

10. The City represents that it is currently in the process of planning alterations to the Pink Palace Mansion, Museum, and Planetarium, located at 3050 Central, Memphis, TN. Within six months of the effective date of this Agreement, the County shall submit for the Department's review, complete design and construction documentation, including construction drawings, as built drawings, project manuals, addenda, and change orders for the alteration of the this facility. The Department will review the documentation for conformity to the ADA Standards for Accessible Design and will note any deficiencies. The County will then ensure that any deficiencies are corrected and that construction or alteration is carried out in a way that meets the Department's approval. In the event the City does not have a plan in place to alter this facility, within 24 months of the effective date of this Agreement, the City will make the following modifications:

A. Parking and Passenger Loading Zone

1) The curb ramp from the passenger loading zone is inaccessible because the curb ramp has a slope of 10%, and the flared ends are steeply sloped. Provide a curb ramp that is at least 36 inches wide, has a maximum slope of 1:12, is located so that it cannot be obstructed by parked vehicles, and has a stable, firm, and slip-resistant surface with a detectable warning extending the full width and depth of the ramp. If the curb ramp is located where pedestrians must walk across it, provide either flared sides (with a maximum slope of 1:10) or handrails or guardrails to protect against cross traffic. Standards §§ 4.1.2(1), 4.1.2(2), 4.1.6(1)(b), 4.3.8, 4.7, Fig. 12.

2) The curb ramp from the parking lot is inaccessible because the flared ends are steeply sloped. Provide a curb ramp that is at least 36 inches wide, has a maximum slope of 1:12, is located so that it cannot be obstructed by parked vehicles, and has a stable, firm, and slip-resistant surface with a detectable warning extending the full width and depth of the ramp. If the curb ramp is located where pedestrians must walk across it, provide either flared sides (with a maximum slope of 1:10) or handrails or guardrails to protect against cross traffic. Standards §§ 4.1.2(1), 4.1.2(2), 4.1.6(1)(b), 4.3.8, 4.7, Fig. 12.

B. Interior Ramps:

1) Natural History Exhibits Ramp near bird exhibits (existing)

a) The ramp is inaccessible because the slope of this ramp is 9.0%, and there is inadequate edge protection. In addition, the handrails are not continuous, do not have 12 inch extensions at the top and bottom, and do not have ends that are rounded or return to a post or wall. Provide a ramp that is at least 36 inches wide with a slope not exceeding 1:12 and a cross slope not exceeding 1:50; with level landings at least as wide as the ramp and 60 inches long at the top and bottom of the ramp; and with edge protection at least 2 inches high at the drop off sides. Provide handrails that are between 1¼ inches and 1½ inches in diameter with a continuous gripping surface along both sides of the ramp, extending at least 12 inches beyond the top and bottom of the ramp parallel with the ground surface. Ensure that handrails are mounted between 34 inches and 38 inches above the ramp surface and 1½ inches from the wall, with ends rounded or returned smoothly to the floor, wall, or post, and that they do not rotate within their fittings. Ensure that the ramp and approaches are designed so that water will not accumulate on walking surfaces. Standards §§ 4.1.2(1), 4.1.2(2), 4.1.6(1)(b), 4.3.8, 4.8.

b) The route along the ramp is inaccessible because part of the exhibit protrudes into the main walkway and would not be detectable to a blind person using a cane. Provide an accessible route at this location such that no objects with their bottom leading edges measuring between 27 inches and 80 inches above the finished floor protrude more than 4 inches into walks, halls, corridors, passageways, or aisles. Free-standing objects mounted on posts or pylons may overhang 12 inches maximum from 27 inches to 80 inches above the ground or finished floor. Standards §§ 4.1.2(3), 4.1.6(1)(b), 4.4.

2) Natural History Exhibit ramp leading to mammals exhibit (existing)

a) The ramp is inaccessible because the slope of this ramp is 8.5%, and there are no handrails. Provide a ramp that is at least 36 inches wide with a slope not exceeding 1:12 and a cross slope not exceeding 1:50; with level landings at least as wide as the ramp and 60 inches long at the top and bottom of the ramp; and with edge protection at least 2 inches high at the drop off sides. Provide handrails that are between 1¼ inches and 1½ inches in diameter with a continuous gripping surface along both sides of the ramp, extending at least 12 inches beyond the top and bottom of the ramp parallel with the ground surface. Ensure that handrails are mounted between 34 inches and 38 inches above the ramp surface and 1½ inches from the wall, with ends rounded or returned smoothly to the floor, wall, or post, and that they do not rotate within their fittings. Ensure that the ramp and approaches are designed so that water will not accumulate on walking surfaces. Standards §§ 4.1.2(1), 4.1.2(2), 4.1.6(1)(b), 4.3.8, 4.8.

3) Natural History Exhibit ramp leaving mammals exhibit (existing)

a) The ramp is inaccessible because the slope of this ramp is 9.9%, and there are no handrails. Provide a ramp that is at least 36 inches wide with a slope not exceeding 1:12 and a cross slope not exceeding 1:50; with level landings at least as wide as the ramp and 60 inches long at the top and bottom of the ramp; and with edge protection at least 2 inches high at the drop off sides. Provide handrails that are between 1¼ inches and 1½ inches in diameter with a continuous gripping surface along both sides of the ramp, extending at least 12 inches beyond the top and bottom of the ramp parallel with the ground surface. Ensure that handrails are mounted between 34 inches and 38 inches above the ramp surface and 1½ inches from the wall, with ends rounded or returned smoothly to the floor, wall, or post, and that they do not rotate within their fittings. Ensure that the ramp and approaches are designed so that water will not accumulate on walking surfaces. Standards §§ 4.1.2(1), 4.1.2(2), 4.1.6(1)(b), 4.3.8, 4.8.

4) Natural History Exhibit ramp leading to "A Walk Through Time"

a) The ramp is inaccessible because the handrails are only on one side, and there are no 12-inch handrail extensions. Provide handrails that are between 1¼ inches and 1½ inches in diameter with a continuous gripping surface along both sides of the ramp, extending at least 12 inches beyond the top and bottom of the ramp parallel with the ground surface. Ensure that handrails are mounted between 34 inches and 38 inches above the ramp surface and 1½ inches from the wall, with ends rounded or returned smoothly to the floor, wall, or post, and that they do not rotate within their fittings. Standards §§ 4.1.2(1), 4.1.2(2), 4.1.6(1)(b), 4.8.5.

5) Natural History Exhibit ramp leaving "A Walk Through Time"

a) The ramp is inaccessible because the slope of this ramp is 8.5%, and there is a cross-slope of 2.4%. Intermediate landings in between ramp slopes are not the same width of the ramp for at least 60 inches in length. In addition, handrails are only on one side, do not run the entire length of the ramp, and do not have 12-inch handrail extensions. Provide a ramp that is at least 36 inches wide with a slope not exceeding 1:12 and a cross slope not exceeding 1:50; with level landings at least as wide as the ramp and 60 inches long at the top and bottom of the ramp; and with edge protection at least 2 inches high at the drop off sides. Provide handrails that are between 1¼ inches and 1½ inches in diameter with a continuous gripping surface along both sides of the ramp, extending at least 12 inches beyond the top and bottom of the ramp parallel with the ground surface. Ensure that handrails are mounted between 34 inches and 38 inches above the ramp surface and 1½ inches from the wall, with ends rounded or returned smoothly to the floor, wall, or post, and that they do not rotate within their fittings. Ensure that the ramp and approaches are designed so that water will not accumulate on walking surfaces. Standards §§ 4.1.2(1), 4.1.2(2), 4.1.6(1)(b), 4.3.8, 4.8.

6) Natural History Exhibit ramp leading to Natural History Exhibit area

a) The ramp is inaccessible because the slope of this ramp is 11%, and there are no handrails. Provide a ramp that is at least 36 inches wide with a slope not exceeding 1:12 and a cross slope not exceeding 1:50; with level landings at least as wide as the ramp and 60 inches long at the top and bottom of the ramp; and with edge protection at least 2 inches high at the drop off sides. Provide handrails that are between 1¼ inches and 1½ inches in diameter with a continuous gripping surface along both sides of the ramp, extending at least 12 inches beyond the top and bottom of the ramp parallel with the ground surface. Ensure that handrails are mounted between 34 inches and 38 inches above the ramp surface and 1½ inches from the wall, with ends rounded or returned smoothly to the floor, wall, or post, and that they do not rotate within their fittings. Ensure that the ramp and approaches are designed so that water will not accumulate on walking surfaces. Standards §§ 4.1.2(1), 4.1.2(2), 4.1.6(1)(b), 4.3.8, 4.8.

7) Pink Palace Mansion ramp entry into mansion from museum

a) The ramp is inaccessible because the handrails do not have 12-inch handrail extensions at every landing on both sides of the ramp. Provide handrails that are between 1¼ inches and 1½ inches in diameter with a continuous gripping surface along both sides of the ramp, extending at least 12 inches beyond the top and bottom of the ramp parallel with the ground surface. Ensure that handrails are mounted between 34 inches and 38 inches above the ramp surface and 1½ inches from the wall, with ends rounded or returned smoothly to the floor, wall, or post, and that they do not rotate within their fittings. Standards §§ 4.1.2(1), 4.1.2(2), 4.1.6(1)(b), 4.8.5.

8) Pink Palace Mansion curved Natural History Exhibit ramp leading to Natural History Exhibit area

a) The ramp is inaccessible because the slope of this ramp is 9.5%, and the handrails do not have 12-inch handrail extensions at every landing on both sides of the ramp. Provide a ramp that is at least 36 inches wide with a slope not exceeding 1:12 and a cross slope not exceeding 1:50; with level landings at least as wide as the ramp and 60 inches long at the top and bottom of the ramp; and with edge protection at least 2 inches high at the drop off sides. Provide handrails that are between 1¼ inches and 1½ inches in diameter with a continuous gripping surface along both sides of the ramp, extending at least 12 inches beyond the top and bottom of the ramp parallel with the ground surface. Ensure that handrails are mounted between 34 inches and 38 inches above the ramp surface and 1½ inches from the wall, with ends rounded or returned smoothly to the floor, wall, or post, and that they do not rotate within their fittings. Ensure that the ramp and approaches are designed so that water will not accumulate on walking surfaces. Standards §§ 4.1.2(1), 4.1.2(2), 4.1.6(1)(b), 4.3.8, 4.8.

9) Pink Palace Mansion final ramp

a) The ramp is inaccessible because there is inadequate edge protection. Provide edge protection at least 2 inches high at the drop off sides. Standards §§ 4.1.2(1), 4.1.2(2), 4.1.6(1)(b), 4.3.8, 4.8.7.

C. Elevator near Palace Bookshop

1) The elevator is inaccessible because, although emergency communications are provided, the system does not work without voice communication. Provide a two-way communication system such that it does not require voice communication, the highest operable part is a maximum of 48 inches above the finished floor of the car, and it is identified by a raised symbol and lettering located adjacent to the device. If the system uses a handset, ensure that the length of the cord from the panel to the handset is at least 29 inches. If the system is located in a closed compartment, ensure that the compartment door hardware operates without tight grasping, pinching or twisting of the wrist. Standards §§ 4.1.3(5), 4.1.6(1)(b), 4.10.14.

2) The elevator is inaccessible because the hall call button is mounted at 47 ½ inches above the finished floor. Provide hall (lobby) call buttons with visual signals indicating when each call is registered and when each call is answered. Ensure that the call buttons are centered at 42 inches above the finished floor, a minimum of ¾ inch in the smallest dimension, with the button designating the up direction on top; that the call buttons are raised or flush; and that objects mounted beneath hall call buttons do not project into the elevator lobby more than 4 inches. Standards §§ 4.1.3(5), 4.1.6(1)(b), 4.10.3, Fig. 20.

3) The elevator is inaccessible because no hall lanterns are provided. Provide hall lanterns at each hoistway entrance that emit a visible and audible signal indicating which car is answering a call. Ensure that audible signals sound once for the up direction and twice for the down direction or have verbal annunciators that say "up" or "down;" and that visible signals are mounted so that their centerline is at least 72 inches above the lobby floor, they are at least 2½ inches in the smallest dimension, and they are visible from the vicinity of the hall call button. Lanterns located in cars, visible from the vicinity of hall call buttons, and conforming to the above requirements, are acceptable. Standards §§ 4.1.3(5), 4.1.6(1)(b), 4.10.4, Fig. 20.

4) The elevator is inaccessible because no hoistway signage is provided. Provide signage at hoistway entrances with raised and Braille floor designations on both jambs such that the centerline of the characters is 60 inches above the finished floor and the characters are 2 inches high. Standards §§ 4.1.3(5), 4.1.6(1)(b), 4.10.5, Fig. 20.

D. Drinking Fountains

1) Ground floor near museum shop: The drinking fountain protrudes into the path of travel and is not detectable to a blind person using a cane. Provide a drinking fountain at this location such that its bottom leading edges measure no more than 27 inches above the finished floor or protrude no more than 4 inches into the walkway. Standards §§ 4.1.2(3), 4.1.6(1)(b), 4.4.

2) 1^st floor Wilson Wing: The drinking fountain has a spout that is 38 inches above the finished floor. Provide a fountain that has a spout height no higher than 36 inches, measured from the finished floor or ground surface to the spout outlet, and that otherwise complies with the Standards. Standards §§ 4.1.3(10), 4.1.6(1)(b), 4.15, 4.27.4, Fig. 27.

3) Lower Level Education Center: The drinking fountain protrudes into the path of travel and is not detectable to a blind person using a cane. Provide a drinking fountain at this location such that its bottom leading edges measure no more than 27 inches above the finished floor or protrude no more than 4 inches into the walkway, or provide a cane-detectable barrier to alert blind people to this feature. Standards §§ 4.1.2(3), 4.1.6(1)(b), 4.4.

4) Lower Level near IMAX toilet rooms: The drinking fountain protrudes into the path of travel and is not detectable to a blind person using a cane. Provide a drinking fountain at this location such that its bottom leading edges measure no more than 27 inches above the finished floor or protrude no more than 4 inches into the walkway, or provide a cane-detectable barrier to alert blind people to this feature. Standards §§ 4.1.2(3), 4.1.6(1)(b), 4.4.

E. Planetarium (altered)

1) There is no signage informing the public of the availability of an assistive listening system. Provide accessible signage indicating the availability of the assistive listening system. 28 C.F.R. § 35.160; Standards §§ 4.1.3(19)(b), 4.1.6(1)(b), 4.30.

2) The Planetarium containing 130 seats is inaccessible because, although 8 wheelchair seating areas are provided, most of these are located inside routes of egress. Provide at least 4 wheelchair seating areas, each with a minimum clear ground or floor space of 66 inches wide by 48 inches deep for forward or rear access, or 66 inches wide by 60 inches deep for side access. Ensure that the ground or floor at all wheelchair locations is level, firm, stable, and slip resistant; that wheelchair seating areas are an integral part of the fixed seating plan and are located so as to provide people with physical disabilities a choice of lines of sight comparable to those available for members of the general public; that wheelchair seating areas adjoin an accessible route that also serves as a means of egress in case of emergency; and that at least one fixed companion seat is provided next to each wheelchair seating area. Standards §§ 4.1.3(19)(a), 4.1.6(1)(b), 4.5, 4.33.

F. IMAX Theater (new construction)

1) The IMAX Theater containing 104 seats is inaccessible because only 2 wheelchair seating areas are provided. Provide 4 wheelchair seating areas, each with a minimum clear ground or floor space of 66 inches wide by 48 inches deep for forward or rear access, or 66 inches wide by 60 inches deep for side access. Ensure that the ground or floor at all wheelchair locations is level, firm, stable, and slip resistant; that wheelchair seating areas are an integral part of the fixed seating plan and are located so as to provide people with physical disabilities a choice of admission prices and lines of sight comparable to those available for members of the general public; that wheelchair seating areas adjoin an accessible route that also serves as a means of egress in case of emergency; and that at least one fixed companion seat is provided next to each wheelchair seating area. Standards §§ 4.1.3(19)(a), 4.1.6(1)(b), 4.5, 4.33.

G. Toilet Rooms with Stalls

1) Ground floor by the museum shop near elevator both men's and women's toilet rooms

a) The toilet room sign in each toilet room is inaccessible. Provide a toilet room sign in each toilet room with the International Symbol of Accessibility and raised and Braille characters mounted on the wall adjacent to the latch side of the door with the centerline of the sign 60 inches above the finished floor and situated such that a person can approach within 3 inches of the sign without encountering an obstruction or standing within a door swing. Standards §§ 4.1.2(7)(d), 4.1.6(1)(b), 4.30.1, 4.30.4, 4.30.5, 4.30.6, 4.30.7.

b) The pressure needed to open the door to each toilet room is 8 pounds (women's toilet room) and 9 pounds (men's toilet room). The entrance door to each toilet room is inaccessible because the pressure required to open the door is 8 pounds (women's toilet room) and 9 pounds (men's toilet room) pounds. Provide a door to each toilet room that requires no more than 5 pounds of force to open. Standards §§ 4.1.3(7)(b), 4.1.6(1)(b), 4.13.11(2)(b).

c) No accessible mirror has been provided in each toilet room. Provide a mirror in each toilet room with the bottom edge of its reflecting surface no more than 40 inches above the finished floor. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.6, 4.19.6.

d) Women's toilet room only: The toilet seat cover dispenser is inaccessible because the controls are mounted over an obstruction. Provide a toilet seat cover such that the controls comply with Fig. 5 for a forward reach or with Fig. 6 for a side reach and such that it is accompanied by clear floor space of 30 by 48 inches that allows a forward or parallel approach, respectively, by a person using a wheelchair. Standards §§ 4.1.3(13), 4.1.6(1)(b), 4.27.2, 4.27.3, 4.2.4, 4.2.5, 4.2.6.

e) The lavatory in each toilet room is inaccessible because the bottom edge of the lavatory apron is 24 inches above the finished floor. Provide a lavatory in each toilet room with the top of its rim or counter 34 inches or less above the finished floor; the bottom edge of the apron at least 29 inches above the finished floor; and knee and toe clearances that comply with Fig. 31. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.6, 4.19.2, Fig. 31.

f) The lavatory in each toilet room is inaccessible because the hot water pipes are not insulated or otherwise configured to protect against contact. Provide hot water and drain pipes that are insulated or otherwise configured to protect against contact. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.6, 4.19.4.

g) Men's toilet room only: The urinal is inaccessible because the urinal rim and flush heights are 22 and 49 inches high, respectively. Provide a urinal with an elongated rim mounted 17 inches or less above the finished floor, a clear floor space of at least 30 inches wide and 48 inches deep centered on the urinal, and a flush control height of 44 inches or less above the finished floor. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.5, 4.18.2, 4.18.3, 4.18.4.

h) Designated accessible toilet stall in each toilet room:

(1) The toilet in each toilet room is inaccessible because there is insufficient clear floor space. Provide clear floor space in each toilet room that complies with Fig. 30 at the toilet. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.4, 4.17.3, Fig. 30.

(2) The door to the designated accessible toilet stall in each toilet room is inaccessible because the door hardware requires tight grasping and twisting. Provide a door in each toilet room with hardware usable with one hand and without tight grasping, pinching, or twisting of the wrist. Lever-operated, push-type, and U-shaped handles are acceptable designs. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.2, 4.13.9.

(3) Women's toilet room only: The toilet is inaccessible because the top of the seat is 21 inches above the finished floor. Provide a toilet with a seat that measures 17 to 19 inches above the finished floor. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.4, 4.16.3, 4.17.2, Fig. 30(d).

(4) The toilet in each toilet room is inaccessible because its centerline measures 19 inches from the side wall. Provide a toilet in each toilet room with a centerline that measures 18 inches from the near side wall. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.4, 4.17.3, Fig. 30.

(5) Women's toilet room only: The toilet is inaccessible because the flush control is on the closed side. Provide a flush control mounted on the "open" side of the toilet's clear floor space; 44 inches or less above the finished floor; and requiring a maximum of 5 pounds of force to operate; or provide an automatic flush device. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.4, 4.16.5, 4.17.2, 4.27.4.

(6) No accessible coat hook has been provided in each toilet room. Provide a coat hook in each toilet room at a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that is accompanied by clear floor space of 30 by 48 inches that allows a forward or parallel approach by a person using a wheelchair. Standards §§ 4.1.3(12)(a), 4.1.6(1)(b), 4.25.2, 4.25.3, 4.2.4, 4.2.5, 4.2.6.

(7) The grab bars (women's toilet room only) at the toilet are inaccessible because they are mounted with 2 inches of space between the bars and the wall. Provide grab bars such that there is 1½ inches between the grab bar and the wall. Standards § 4.26.2, Fig. 39.

(8) The toilet paper dispenser in each accessible stall interferes with use of the side grab bar. Provide a toilet paper dispenser that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

(9) There is no rear grab bar in the accessible stall in each toilet room. Provide a rear grab bar that is at least 36 inches in overall length, with the closer end no more than 6 inches from the side wall; mounted 33 to 36 inches above the finished floor; with a diameter between 1¼ and 1½ inches; with 1½ inches between the grab bar and the wall; and at least 1½ inches between the grab bar and any other object, such as a toilet seat cover dispenser. Standards §§ 4.17.6, 4.26.2, Fig. 30.

2) Ground floor near the snack bar both men and women's toilet rooms

a) The toilet room sign for the Men's and Women's Toilet Rooms lack the International Symbol of Access, the sign is not mounted with its centerline at 60 inches, and it has no Braille or raised characters. Provide a toilet room sign with raised and Braille characters mounted on the wall adjacent to the latch side of the door with the centerline of the sign 60 inches above the finished floor and situated such that a person can approach within 3 inches of the sign without encountering an obstruction or standing within a door swing. Standards §§ 4.1.2(7)(d), 4.30.1, 4.30.4, 4.30.5, 4.30.6.

b) The Men's and Women's toilet room doors are inaccessible because the pressure required to open each door is 10 and 9 pounds, respectively. Provide a door that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

c) (Women's toilet room only) No accessible coat hook has been provided. Provide a coat hook at a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that is accompanied by clear floor space of 30 by 48 inches that allows a forward or parallel approach by a person using a wheelchair. Standards §§ 4.25.2, 4.25.3, 4.2.4, 4.2.5, 4.2.6.

d) The lavatory is inaccessible because the lavatory apron in each toilet room is 27 inches above the finished floor. Provide a lavatory with the top of its rim or counter 34 inches or less above the finished floor; the bottom edge of the apron at least 29 inches above the finished floor; and knee and toe clearances that comply with Fig. 31. Standards § 4.19.2, Fig. 31.

e) Designated accessible toilet stall:

(1) The designated accessible toilet stall is inaccessible because the men's stall is 45.5 inches wide in the front but only 27 inches in the back, by 68 inches deep, and the women's is 44 inches wide by 65.5 inches deep. Provide a toilet stall in each toilet room that is at least 60 inches wide and at least 56 inches deep for a wall-mounted toilet or at least 59 inches deep for a floor-mounted toilet, such that the centerline of the toilet is exactly 18 inches from the near side wall or partition, and there is at least 9 inches of toe clearance above the floor at the front partition if the stall is no more than 60 inches deep. Standards § 4.17, Fig. 30.

(2) The toilet is inaccessible because its centerline measures 15 and 18.5 inches from the side wall in the men's and women's toilet rooms, respectively. Provide a toilet with a centerline that measures 18 inches from the near side wall. Standards § 4.17.3, Fig. 30.

(3) The side grab bar at the Women's toilet room accessible stall is inaccessible because the far end is only 53 inches from the rear wall. Provide a side grab bar that is at least 40 inches in overall length, with the far end mounted at least 52 inches from the rear wall and the closer end 12 inches or less from the rear wall. Standards § 4.17.6, Figs. 30(a), (d).

(4) The baby changing table at the Women's Toilet room is inaccessible because it is ounted more than 36 inches high. Provide a counter on an accessible route such that a portion of the counter is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary counter with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, a clip board made available to the public, or other means. Standards §§ 7.2(2), 4.3.

(5) The rear grab bar at the toilet is inaccessible because none has been provided. Provide a rear grab bar that is at least 36 inches in overall length, with the closer end no more than 6 inches from the side wall; mounted 33 to 36 inches above the finished floor; with a diameter between 1¼ and 1½ inches; with 1½ inches between the grab bar and the wall; and at least 1½ inches between the grab bar and any other object, such as a toilet seat cover dispenser. Standards §§ 4.17.6, 4.26.2, Fig. 30.

(6) The door to the Men's Toilet Room, which is accessed from the latch side of the door, is inaccessible because it has less than 18 inches of maneuvering clearance. On the pull side of the door, provide a path of travel at least 48 inches wide for a side approach and at least 24 inches of clear maneuvering space adjacent to the latch side of the door. Standards § 4.13.6, Fig. 25(c).

(7) There is insufficient turning space within the Men's toilet room. Provide an unobstructed turning space at least 60 inches in diameter or a T-shaped space complying with Fig. 3(b). Standards §§ 4.22.3, 4.2.3, Fig. 3.

(8) The Women's toilet is inaccessible because the flush control it is mounted on the closed side. Provide a flush control mounted on the "open" side of the toilet's clear floor space; 44 inches or less above the finished floor; and requiring a maximum of 5 pounds of force to operate; or provide an automatic flush device. Standards §§ 4.16.5, 4.17.2, 4.27.4.

3) First Floor in the History Exhibit area both men and women's toilet rooms

a) The toilet room sign for the Men's and Women's Toilet Rooms is inaccessible. Provide a toilet room sign with raised and Braille characters mounted on the wall adjacent to the latch side of the door with the centerline of the sign 60 inches above the finished floor and situated such that a person can approach within 3 inches of the sign without encountering an obstruction or standing within a door swing. Standards §§ 4.1.2(7)(d), 4.30.1, 4.30.4, 4.30.5, 4.30.6.

b) The door to the Men's and Women's toilet rooms is inaccessible because the pressure required to open the door is 13 and 12 pounds respectively. Provide a door that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

c) No accessible mirror has been provided. Provide a mirror with the bottom edge of its reflecting surface no more than 40 inches above the finished floor. Standards § 4.19.6.

d) The lavatory is inaccessible because the bottom apron edge in each toilet room is 24 inches high. Provide a lavatory with the top of its rim or counter 34 inches or less above the finished floor; the bottom edge of the apron at least 29 inches above the finished floor; and knee and toe clearances that comply with Fig. 31. Standards § 4.19.2, Fig. 31.

e) The lavatory is inaccessible because the hot water pipes are not insulated or otherwise configured to protect against contact. Provide hot water and drain pipes that are insulated or otherwise configured to protect against contact. Standards § 4.19.4.

f) The baby changing table in the Men's and Women's Toilet Rooms is inaccessible because the handle is mounted 56 inches above the floor, and when open is positioned at 36.5 and 38 inches high, respectively. Provide a counter on an accessible route such that a portion of the counter is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary counter with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, a clip board made available to the public, or other means. Standards §§ 7.2(2), 4.3.

g) Designated accessible toilet stall:

(1) The designated accessible toilet stall is inaccessible because it is only 39 inches wide by 57 inches deep in the Men's Room, and 39 inches wide by 56 inches deep in the Women's Room. Provide a toilet stall in each toilet room that is at least 60 inches wide and at least 56 inches deep for a wall-mounted toilet or at least 59 inches deep for a floor-mounted toilet, such that the centerline of the toilet is exactly 18 inches from the near side wall or partition, and there is at least 9 inches of toe clearance above the floor at the front partition if the stall is no more than 60 inches deep. Standards § 4.17, Fig. 30.

(2) The door to the designated accessible stall is inaccessible because the hardware requires tight grasping and twisting. Provide a door with hardware usable with one hand and without tight grasping, pinching, or twisting of the wrist. Lever-operated, push-type, and U-shaped handles are acceptable designs. Standards § 4.13.9.

(3) The toilet is inaccessible because the top of the seat is 21 inches above the finished floor. Provide a toilet with a seat that measures 17 to 19 inches above the finished floor. Standards §§ 4.16.3, 4.17.2, Fig. 30(d).

(4) The toilet is inaccessible because its centerline measures 19 inches from the side wall. Provide a toilet with a centerline that measures 18 inches from the near side wall. Standards § 4.17.3, Fig. 30.

(5) (Men's toilet room only) No accessible coat hook has been provided. Provide a coat hook at a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that is accompanied by clear floor space of 30 by 48 inches that allows a forward or parallel approach by a person using a wheelchair. Standards §§ 4.25.2, 4.25.3, 4.2.4, 4.2.5, 4.2.6.

(6) The toilet paper dispenser is inaccessible because it is mounted on the wrong wall. Provide a toilet paper dispenser that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

(7) No rear grab bar has been provided. Provide a rear grab bar that is at least 36 inches in overall length, with the closer end no more than 6 inches from the side wall; mounted 33 to 36 inches above the finished floor; with a diameter between 1¼ and 1½ inches; with 1½ inches between the grab bar and the wall; and at least 1½ inches between the grab bar and any other object, such as a toilet seat cover dispenser. Standards §§ 4.17.6, 4.26.2, Fig. 30.

(8) The side grab bar at the toilet is inaccessible because the toilet paper dispenser interferes with its use. Provide a side grab bar that has at least 1½ inches between the grab bar and any other object, such as the toilet paper dispenser. Standards §§ 4.17.6, 4.26.2, Fig. 39.

(9) The Women's toilet is inaccessible because the flush control is mounted on the closed side. Provide a flush control mounted on the "open" side of the toilet's clear floor space; 44 inches or less above the finished floor; and requiring a maximum of 5 pounds of force to operate; or provide an automatic flush device. Standards §§ 4.16.5, 4.17.2, 4.27.4.

4) First Floor in the Wilson Wing both men and women's toilet rooms

a) The toilet room sign for the Men's and Women's Toilet room is inaccessible. Provide a toilet room sign with raised and Braille characters mounted on the wall adjacent to the latch side of the door with the centerline of the sign 60 inches above the finished floor and situated such that a person can approach within 3 inches of the sign without encountering an obstruction or standing within a door swing. Standards §§ 4.1.2(7)(d), 4.30.1, 4.30.4, 4.30.5, 4.30.6.

b) The door to the Men's and Women's Toilet Room is inaccessible because the pressure required to open the door is 12 and 10 pounds respectively. Provide a door that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

c) No accessible mirror has been provided. Provide a mirror with the bottom edge of its reflecting surface no more than 40 inches above the finished floor. Standards § 4.19.6.

d) The lavatory in each toilet room is inaccessible because each lavatory apron is mounted 24 inches above the finished floor. Provide a lavatory with the top of its rim or counter 34 inches or less above the finished floor; the bottom edge of the apron at least 29 inches above the finished floor; and knee and toe clearances that comply with Fig. 31. Standards § 4.19.2, Fig. 31.

f) The baby changing table in each toilet room is inaccessible because the controls are mounted at 56 inches above the finished floor. Provide a baby changing table with the controls a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that is accompanied by clear floor space of 30 by 48 inches that allows a forward or parallel approach by a person using a wheelchair. Standards §§ 4.27.2, 4.27.3, 4.2.4, 4.2.5, 4.2.6.

g) Designated accessible toilet stall:

(1) The designated accessible toilet stall is inaccessible because they are only 40 inches wide, by 66 inches deep. Provide a toilet stall that is at least 60 inches wide and at least 56 inches deep for a wall-mounted toilet or at least 59 inches deep for a floor-mounted toilet, such that the centerline of the toilet is exactly 18 inches from the near side wall or partition, and there is at least 9 inches of toe clearance above the floor at the front partition if the stall is no more than 60 inches deep. Standards § 4.17, Fig. 30.

(2) The toilet is inaccessible because the top of the seat is 21 inches above the finished floor. Provide a toilet with a seat that measures 17 to 19 inches above the finished floor. Standards §§ 4.16.3, 4.17.2, Fig. 30(d).

(3) The toilet is inaccessible because its centerline measures 19 inches from the side wall. Provide a toilet with a centerline that measures 18 inches from the near side wall. Standards § 4.17.3, Fig. 30.

(4) (Women's toilet room only) No accessible coat hook has been provided. Provide a coat hook at a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that is accompanied by clear floor space of 30 by 48 inches that allows a forward or parallel approach by a person using a wheelchair. Standards §§ 4.25.2, 4.25.3, 4.2.4, 4.2.5, 4.2.6.

(5) (Women's toilet room) The side grab bar at the toilet is inaccessible because the toilet paper dispenser interferes with its proper use. Provide a side grab bar that has at least 1½ inches between the grab bar and any other object, such as the toilet paper dispenser. Standards §§ 4.17.6, 4.26.2, Fig. 39.

(6) (Men's toilet room) The toilet paper dispenser is inaccessible because it is mounted on the wrong wall. Provide a toilet paper dispenser that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

5) Lower Level near IMAX Theater women's toilet room (altered)

a) The lavatory is inaccessible because the apron is mounted 27.5 inches above the finished floor. Provide a lavatory with the top of its rim or counter 34 inches or less above the finished floor; the bottom edge of the apron at least 29 inches above the finished floor; and knee and toe clearances that comply with Fig. 31. Standards § 4.19.2, Fig. 31.

b) The lavatory is inaccessible because the hot water pipes are not insulated or otherwise configured to protect against contact. Provide hot water and drain pipes that are insulated or otherwise configured to protect against contact. Standards § 4.19.4.

c) Designated accessible standard toilet stall:

(1) The toilet is inaccessible because its centerline measures 20 inches from the side wall. Provide a toilet with a centerline that measures 18 inches from the near side wall. Standards § 4.17.3, Fig. 30.

(2) No accessible coat hook has been provided. Provide a coat hook at a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that is accompanied by clear floor space of 30 by 48 inches that allows a forward or parallel approach by a person using a wheelchair. Standards §§ 4.25.2, 4.25.3, 4.2.4, 4.2.5, 4.2.6.

d) Designated accessible alternate ambulatory toilet stall:

(1) No accessible coat hook has been provided. Provide a coat hook at a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that is accompanied by clear floor space of 30 by 48 inches that allows a forward or parallel approach by a person using a wheelchair. Standards §§ 4.25.2, 4.25.3, 4.2.4, 4.2.5, 4.2.6.

(2) The toilet paper dispenser is inaccessible because it is mounted 41.5 inches from the rear wall. Provide a toilet paper dispenser that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

6) Lower Level near IMAX Theater men's toilet room (altered)

a) The urinal is inaccessible because it does not have an elongated rim. Provide a urinal with an elongated rim mounted 17 inches or less above the finished floor, a clear floor space of at least 30 inches wide and 48 inches deep centered on the urinal, and a flush control height of 44 inches or less above the finished floor. Standards §§ 4.18.2, 4.18.3, 4.18.4.

b) The toilet is inaccessible because its centerline measures 20 inches from the side wall. Provide a toilet with a centerline that measures 18 inches from the near side wall. Standards § 4.17.3, Fig. 30.

7) Pink Palace 1^st Level Toilet Rooms

a) Women's

(1) The door to the Women's Toilet Room is inaccessible because the pressure required to open the door is 8 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

(2) The lavatory is inaccessible because the provided knee height is only 27 inches from the finished floor. Provide a lavatory with the top of its rim or counter 34 inches or less above the finished floor; the bottom edge of the apron at least 29 inches above the finished floor; and knee and toe clearances that comply with Fig. 31. Standards § 4.19.2, Fig. 31.

(3) The lavatory is inaccessible because the hot water pipes are not insulated or otherwise configured to protect against contact. Provide hot water and drain pipes that are insulated or otherwise configured to protect against contact. Standards § 4.19.4.

(4) There is no accessible stall provided. Provide a "standard" accessible toilet stall at least 60 inches wide and at least 59 inches deep (or at least 56 inches deep with a wall-mounted toilet) such that all of the stall's elements, including stall door, stall door hardware, water closet, size and arrangement, toe clearances, grab bars, controls, and dispensers, comply with the Standards. Standards §§ 4.13, 4.16, 4.17, 4.26, 4.27, Fig. 30.

b) Men's

(1) The door to the Men's Toilet Room is inaccessible because the pressure required to open the door is 8 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

(2) No accessible mirror has been provided. Provide a mirror with the bottom edge of its reflecting surface no more than 40 inches above the finished floor. Standards § 4.19.6.

(3) There is no accessible stall provided. Provide a "standard" accessible toilet stall at least 60 inches wide and at least 59 inches deep (or at least 56 inches deep with a wall-mounted toilet) such that all of the stall's elements, including stall door, stall door hardware, water closet, size and arrangement, toe clearances, grab bars, controls, and dispensers, comply with the Standards. Standards §§ 4.13, 4.16, 4.17, 4.26, 4.27, Fig. 30.

11. Within 24 months of the effective date of the Agreement, the City will complete the following modifications to the C.W. Davis Community Center and Park, located at 3371 Spotswood Avenue, Memphis, TN:

A. Parking Lots:

1) Parking lot near the main entrance to the community center

a) Although the parking lot has a total of 56 parking spaces, an inadequate number are designated as reserved for people with disabilities. On the shortest accessible route to the accessible entrance, provide 1 van accessible space and 2 standard spaces designated as reserved for people with disabilities. Standard accessible spaces shall be a minimum of 96 inches wide and served by access aisles at least 60 inches wide. Van accessible spaces shall be a minimum of 96 inches wide and served by access aisles at least 96 inches wide. All spaces designated as reserved for people with disabilities shall have vertical signs with the International Symbol of Accessibility located such that they cannot be obstructed by parked vehicles. Van accessible spaces shall have an additional "Van-Accessible" sign located below the International Symbol of Accessibility. Standards §§ 4.1.2(5), 4.6, 4.30.7(1).

b) The built-up curb ramp impermissibly extends into the access aisle. Provide a curb ramp located so that it does not project into this element and all aspects of the ramp or curb cut comply with the Standards. Standards §§ 4.3.8, 4.7.6.

2) Parking lot near park / new gym:

a) There is no appropriate access aisle for the van-accessible space. At each van accessible space, provide an access aisles at least 96 inches wide. Ensure that all access aisles are flat and level, with slopes and cross-slopes not exceeding 1:50 in all directions, and that their surfaces are firm, stable, and slip-resistant. Standards §§ 4.1.2(5), 4.6.3, Fig. 9.

b) The van accessible parking reserved for persons with disabilities lacks the appropriate signage. At van accessible spaces, provide a "Van-Accessible" sign located below the International Symbol of Accessibility such that the sign cannot be obstructed by vehicles parked in the space. Standards §§ 4.6.4, 4.30.7(1).

B. Community Center:

1) Routes of travel:

a) The building is inaccessible because its entrances do not have signage indicating accessibility, or directing persons with disabilities to the nearest accessible entrance. Provide accessible directional signage with the International Symbol of Accessibility at inaccessible entrances directing users to the accessible entrance, and provide accessible signage with the International Symbol of Accessibility at all permanent accessible entrances. Standards §§ 4.1.3(8)(d), 4.13, 4.30.

b) The exterior entrance to the old gym is inaccessible because there is no level approach within the door's required maneuvering clearance on the exterior side. Provide a door so that the floor or ground area within the required clearances is level and clear. Standards § 4.13.6, Fig. 25.

c) The curb ramp is inaccessible because it has steep flared ends. Provide a curb ramp that is at least 36 inches wide, has a maximum slope of 1:12, is located so that it cannot be obstructed by parked vehicles, and has a stable, firm, and slip-resistant surface with a detectable warning extending the full width and depth of the ramp. If the curb ramp is located where pedestrians must walk across it, provide either flared sides (with a maximum slope of 1:10) or handrails or guardrails to protect against cross traffic. Standards § 4.3.8, 4.7, Fig. 12..

2) Men and Women's Toilet Rooms with stalls near new gym:

b) The lavatory in each toilet room is inaccessible because the top of each lavatory is 35 inches high. Provide a lavatory in each toilet room with the top of its rim or counter 34 inches or less above the finished floor; the bottom edge of the apron at least 29 inches above the finished floor; and knee and toe clearances that comply with Fig. 31. Standards § 4.19.2, Fig. 31.

c) No accessible coat hook has been provided in each toilet room. Provide a coat hook in each toilet room at a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that is accompanied by clear floor space of 30 by 48 inches that allows a forward or parallel approach by a person using a wheelchair. Standards §§ 4.25.2, 4.25.3, 4.2.4, 4.2.5, 4.2.6.

d) The toilet paper dispenser in each toilet room is inaccessible because it is mounted 39 inches from the rear wall in the men's room, and 44 inches in the women's. Provide a toilet paper dispenser in each toilet room that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

3) The picnic tables are inaccessible. Provide at least one picnic table on an accessible route such that there is knee space at the table at least 27 inches high, 30 inches wide, and 19 inches deep, and such that the height of the top of the table is between 28 inches and 34 inches above the ground. Standards §§ 4.32.3, 4.32.4.

4) The drinking fountain has a spout that is 39 inches above the finished floor. Provide a fountain that has a spout height no higher than 36 inches, measured from the finished floor or ground surface to the spout outlet, and that otherwise complies with the Standards. Standards §§ 4.15, 4.27.4, Fig. 27.

12. Within 24 months of the effective date of the Agreement, the City will complete the following modifications to the Lewis Davis Park, located at 1420 Pendleton, Memphis, TN:

A. Accessible route:

1) There is no accessible route to the basketball court. Provide at least one accessible route within the boundary of the site connecting these elements that, to the maximum extent feasible, coincides with the route for the general public. The accessible route must have a minimum clear width of 36 inches, or a minimum clear width of 42 inches if there is a turn around an obstruction less than 48 inches wide; have passing spaces at least 60 inches by 60 inches at least every 200 feet; have a minimum clear headroom of 80 inches; have a surface that is firm, stable, and slip resistant; have, in the absence of a curb ramp, ramp, elevator, or platform lift, no level changes in excess of ½ inch vertically; and have a running slope of less than 1:20 (5%) (or have been constructed as a fully accessible ramp) and a cross slope of less than 1:50 (2%). Standards §§ 4.3, 4.5, Fig. 7.

13. It is noted that there are numerous violations of the ADA throughout the Liberty Bowl, located at 335 South Hollywood, Memphis, TN, including routes of travel, ramps, toilet rooms, counters, inadequate number of wheelchair seating areas, elevators, and drinking fountains. The Department has shared its report of violations for this facility with the City. Within six months of the effective date of this Agreement, the City shall submit for the Department's review a complete plan on addressing these violations. The Department will review the documentation for conformity to the ADA Standards for Accessible Design and will note any deficiencies. The County will then ensure that any deficiencies are corrected and that the alteration of this facility is carried out in a way that meets the Department's approval.