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

Existing 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 each of the City's programs, services, and activities operating at a facility that is the subject of this Agreement, when viewed in its entirety, are readily accessible to and usable by persons with mobility impairments, the City will take the following actions:

1. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to City Hall, located at 125 North Mid America Mall, Memphis, TN:

A. Council Chambers

1) The Council Chambers containing 401 seats is inaccessible because the wheelchair seating area is less than 33 inches wide. Provide 6 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), 4.5, 4.33.

B. Accessible Routes

1) The interior doors throughout the building are inaccessible because the pressure required to open the doors exceeds 5 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

2) The route from level 1B to the stairway leading to the first floor has a low overhead clearance and presents a hazard for those that are blind or have low vision. 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. Standards § 4.4.

3) The signage provided is inaccessible because it does not include Braille. Provide permanent room signage with upper case, sans serif or simple serif type letters and numerals, meeting the requirements of the Standards for character height, raised characters, finish and contrast, accompanied by Grade 2 Braille; mounted on the wall adjacent to the latch side of the door or on the nearest adjacent wall at a height of 60 inches above the finished floor to the centerline of the sign; and located so that a person may approach within 3 inches of the signage without encountering protruding objects or standing within the swing of a door. Standards §§ 4.30.1, 4.30.4, 4.30.5, 4.30.6.

C. Drinking Fountains

1) Although 2 drinking fountains are provided on level 1B, there is no accessible drinking fountain because the spout heights of both fountains is 42 inches high, and there is no forward approach knee space depth. 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.

2) The circulation path near the drinking fountains on level 1B is inaccessible because the fountains are not detectable to a blind person using a cane. Provide an accessible route at this location such that there are no objects protruding into the curculation path with a leading edge at a height between 27 and 80 inches and without cane detectable barriers. Standards § 4.4.

3) Although 2 drinking fountains are provided on the first floor, there is no accessible drinking fountain because the spout height on the existing fountains is 37 inches above the finished floor, and there is no fountain provided for persons who have trouble bending or stooping. 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.

4) The circulation paths near the drinking fountains on the 3^rd, 4^th, 5^th, and 6^th floors are inaccessible because the fountains protrude 5.5 inches into the path of travel and are not detectable to a blind person using a cane. Provide a circulation path at this location such that there are no objects protruding into the curculation path with a leading edge at a height between 27 and 80 inches and without cane detectable barriers. Standards § 4.4.

5) Although drinking fountains are provided, there is no accessible drinking fountain because the existing fountain lack adequate forward approach knee space depth. 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.

6) Although drinking fountains are provided on the 3^rd, 4^th, 5^th, and 6^th floors , there is no drinking fountain provided for people who have difficulty bending or stooping. 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)(a).

D. Offices and Counters

1) Counters

a) The Security Counter at City Hall is inaccessible because it measures 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.

b) The Employment Applications Counter at the Personnel Division (Room 1B33) is inaccessible because the counter is mounted 41 inches above the mounted 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) The Employment Application Counter at the Personnel Division is inaccessible because the counter is a protruding object. Provide a circulation path 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.

d) The Executive Division Counter at the Public Services Division (Room 200) is inaccessible because the counter is mounted 39 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.

e) The Accessible Counter at the Treasurer's Office is inaccessible because it is obstructed by furniture. 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.

f) The Payroll Counter at the Finance and Administration Division (Room 354) is inaccessible because it is mounted 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.

g) The Comptroller Accounting Counter at Finance and Administration Division (Room 348) is inaccessible because the counter is mounted 41 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.

h) The City Attorney's Office Counter at the Law Division (Room 336) is inaccessible because it is mounted 42.5 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.

i) The Executive Office Counter at the Legislative Division (Room 514) is inaccessible because the counter is mounted 42.5 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.

j) The Building Design and Construction Counter at the Engineering Division is inaccessible because the counter is mounted 43 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.

k) The Receptionist's Counter at the Office of the Mayor (7^th floor) is inaccessible because the counter is mounted 41 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 examination/application tables in the Employment Applications area of the Personnel Division (Room1B33) are inaccessible because they are not accessible to persons using wheelchairs. Provide at least 1 accessible table on an accessible route at least 36 inches wide. Ensure that the table(s) has a clear floor space of 30 inches wide by 48 inches deep, knee clearance of at least 27 inches high by 30 inches wide by 19 inches deep, and a writing surface between 28 and 34 inches above the finished floor. Standards §§ 8.2, 4.2.4.1, 4.32.

3) The door to the Office of Planning and Development (Room 468), 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).

E. Toilet Rooms

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.

2) 1^st Floor Women's Toilet Room with Stalls NE Corner

a) The signage provided is inaccessible because it is not mounted on the latch side of the door. Provide permanent room signage with upper case, sans serif or simple serif type letters and numerals, meeting the requirements of the Standards for character height, raised characters, finish and contrast, accompanied by Grade 2 Braille; mounted on the wall adjacent to the latch side of the door or on the nearest adjacent wall at a height of 60 inches above the finished floor to the centerline of the sign; and located so that a person may approach within 3 inches of the signage without encountering protruding objects or standing within the swing of a door. Standards §§ 4.30.1, 4.30.4, 4.30.5, 4.30.6.

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) The lavatory is inaccessible because it does not provide 29 inches of knee height clearance. 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.

d) The doors to the stalls are inaccessible because the stall 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.

e) The rear grab bar at the toilet is inaccessible because the air freshener interferes with its use. Provide a rear grab bar that has 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. 39.

f) The toilet paper dispenser is inaccessible because it is not located under 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).

3) 1^st Floor Women's Toilet Room with Stalls NW Corner

a) The toilet room is inaccessible despite signage indicating otherwise. 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.

4) 1^st Floor Men's Toilet Room with Stalls NW Corner

a) The signage provided is inaccessible because it is not mounted on the latch side of the door, and its centerline is not 60 inches above the finished floor. Provide permanent room signage with upper case, sans serif or simple serif type letters and numerals, meeting the requirements of the Standards for character height, raised characters, finish and contrast, accompanied by Grade 2 Braille; mounted on the wall adjacent to the latch side of the door or on the nearest adjacent wall at a height of 60 inches above the finished floor to the centerline of the sign; and located so that a person may approach within 3 inches of the signage without encountering protruding objects or standing within the swing of a door. Standards §§ 4.30.1, 4.30.4, 4.30.5, 4.30.6.

b) The toilet is inaccessible because its centerline measures 16.5 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.

c) 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 toilet paper dispenser is inaccessible because it is not mounted under 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).

e) The rear grab bar at the toilet is inaccessible because the air freshener and the toilet seat cover dispenser interfere with its use. Provide a rear grab bar that has 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. 39.

f) The doors to the stalls are inaccessible because the hardware requires tight grasping and twisting to operate. 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.

5) 3^rd Floor Unisex Toilet Room

6) Men and Women's Toilet Rooms with Stalls 3^rd, 4^th, 5^th, and 6^th Floors: On each of these floors, the following inaccessible features were found throughout all of these toilet rooms with stalls. The City may make all of these toilet rooms accessible. Alternatively, the City may make toilet rooms on every other floor accessible and 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.

a) The toilet room sign for the Men's and Women's Toilet Rooms with Stalls on the 3^rd, 4^th, 5^th and 6^th floors does not display the International Sign of Accessibility. 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.

b) 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.

c) The paper towel dispenser is inaccessible because the controls are mounted at 56 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 §§ 4.27.2, 4.27.3, 4.2.4, 4.2.5, 4.2.6.

d) 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.

e) 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.

f) The seat cover dispenser is inaccessible because the controls are mounted at 55 inches above the finished floor with a required 24 inch reach over the toilet. Provide a seat cover 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 §§ 4.27.2, 4.27.3, 4.2.4, 4.2.5, 4.2.6.

g) The door to each toilet room, which is accessed from the hinge side of the door, is inaccessible because it has less than 54 inches of maneuvering clearance on the pull side. On the pull side of the door, provide a path of travel at least 60 inches wide when the approach is a side approach from the hinge side and there is a minimum of 36 inches to the latch side of the door, OR provide a path of travel between 54 inches and 59 inches wide when the approach is a side approach from the hinge side and there is a minimum of 42 inches to the latch side of the door. Standards § 4.13.6, Fig. 25(b).

2. Within three months of the effective date of this Agreement, the City will complete the following modifications to Massey House - City Beautiful Program, located at 664 Adams Avenue, Memphis, TN:

A. The entire facility is inaccessible to persons with disabilities, including the entranceway, routes of travel, changes in level, toilet rooms, and all other elements within the facility. Within three months of the effective date of this Agreement, the County shall begin to provide all Massey House City Beautiful Program services at an alternate location upon request by persons with disabilities. Also within three months of the effective date of this Agreement, the County will implement and report to the Department its written plan regarding how the programs, activities, or services provided at the Massey House City Beautiful Program will be provided to persons with disabilities at an alternate location and how persons with disabilities will be informed of this change.

3. The Department has determined that the Mallory - Neely House, located at 652 Adams Avenue, Memphis, TN is inaccessible to persons with disabilities, including the entranceway, routes of travel, changes in level, toilet rooms, and all other elements within the facility. The City has advised the Department that it has closed this facility to the public and does not intend to reopen this facility. Consequently, there is no longer a requirement for the County to remove the identified accessibility barriers. If the City opts to reopen this facility to the public in the future, it would need to provide all services provided at this facility at an alternate location upon request by persons with disabilities. Within six months of its decision to reopen this facility, the County will implement and report to the Department its written plan regarding how the programs, activities, or services provided at this facility will be provided to persons with disabilities at an alternate location and how persons with disabilities will be informed of this change.

4. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Downtown Vehicle Inspection Station, located at 590 Washington, Memphis, TN:

A. Parking

1) The parking lot is inaccessible because there is no access aisle. At each standard accessible space, provide an access aisle at least 60 inches wide. 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.

2) The parking reserved for persons with disabilities lacks 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).

3) The parking reserved for persons with disabilities is inaccessible because the designated accessible space is not level. Provide designated accessible parking spaces and access aisles that are flat and level, with slopes and cross-slopes not exceeding 1:50 in all directions, with surfaces that are firm, stable, and slip-resistant. Standards §§ 4.3.6, 4.5.1, 4.6.3.

B. Counter

1) The Vehicle Inspection Counter at the Downtown Vehicle Inspection Station is inaccessible because it is mounted 42 inches from 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 Fountain

1) 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 §§ 4.15, 4.27.4, Fig. 27.

5. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Josephine K. Lewis Center for Senior Citizens, located at 1188 North Parkway, Memphis, TN:

A. Parking

1) Although the parking lot has a total of 75 parking spaces of which 5 are designated as standard accessible spaces, none are designated as being van-accessible. On the shortest accessible route to the accessible entrance, provide 1 van accessible space designated as reserved for people with disabilities. 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), 4.6, 4.30.7(1).

3) The parking lot is inaccessible because there are no access aisles. At each standard accessible space, provide an access aisle at least 60 inches wide. 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. West End Exterior Entrance

1) The west end exterior entrance inaccessible because there is an unbeveled ½ inch threshold. Provide a door 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.

C. South End (North Parkway) Exterior Entrance and Doors

1) The building is inaccessible because it lacks 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), 4.13, 4.30.

2) The south end exterior door is inaccessible because there is a 1 inch change in level at the threshold to the door. Provide an accessible door with a threshold that is no greater than ¼ inch, or is no greater than ½ inch and is beveled with a slope no greater than 1:2. Standards §§ 4.13.8, 4.5.2.

D. East End Exterior Entrance and Doors

2) The route from the East End Exterior Entrance and Doors is inaccessible because the ashtray is a protruding object that is not 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.

E. North End Entrance and Doors

2) The north end door is inaccessible because there is a ¾ inch change in level at the threshold to the door. Provide an accessible door with a threshold that is no greater than ¼ inch, or is no greater than ½ inch and is beveled with a slope no greater than 1:2. Standards §§ 4.13.8, 4.5.2.

3) The north end door is inaccessible because there is a slope of 5.2% within the door's required maneuvering clearance. Provide a door such that the floor or ground area within the required clearances is level and clear. Standards § 4.13.6, Fig. 25.

F. The route throughout the facility is inaccessible because the wall-mounted fire extinguishers protrude into the main walkway and would not be detectable to a blind person using a cane. Provide a circulation path 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.

G. Ramp to Ground Level Multi-purpose Room

1) The ramp is inaccessible because the handrails are 32¼" in height, the extensions are less than 12 inches from the ground surface, no extensions are provided for the inside handrails, and the handrails are 2¼" 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 § 4.8.5.

H. Toilet rooms: the City may make all of the following toilet rooms accessible to people with disabilities. Alternatively, the City may make one set of toilet rooms accessible or create an accessible unisex toilet room, with accessible directional signage with the International Symbol of Accessibility at inaccessible toilet rooms indicating the location of the nearest accessible toilet room, and 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.

1) Men's 1^st Floor West Side Toilet Room with Stalls

a) The toilet room lacks accessible signage 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 1^st floor west side toilet room is inaccessible because it is only 29" wide. Provide a door with a clear opening at least 32 inches wide when measured from the face of the door to the opposite stop when the door is opened 90 degrees and 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 §§ 4.13.5, 4.13.9.

c) The door to the men's 1^st floor west side 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).

d) There is no accessible mirror. Provide a mirror with the bottom edge of its reflecting surface no more than 40 inches above the finished floor. Standards § 4.19.6.

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 route within the toilet room is inaccessible because the door closer hangs into the door clear opening at 70 inches and is a protruding object that is not 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.

g) 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 §§ 4.13, 4.16, 4.17, 4.26, 4.27, Fig. 30.

2) Women's 1^st Floor West Side Toilet Room with Stalls

b) The door to the women's 1^st floor west side toilet room is inaccessible because it is only 30 inches wide. Provide a door with a clear opening at least 32 inches wide when measured from the face of the door to the opposite stop when the door is opened 90 degrees and 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 §§ 4.13.5, 4.13.9.

c) The door to the women's 1^st floor west side toilet room is inaccessible because the pressure required to open the door is 12 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

d) The door to the women's 1^st floor west side toilet room, which is accessed through a front approach, is inaccessible because it has only 8 inches of maneuvering clearance on the latch side of the door. On the pull side of the door, provide maneuvering clearance at least 60 inches deep and provide a minimum of 18 inches (24 inches is preferred) of maneuvering clearance on the latch side of the door. Standards § 4.13.6, Fig. 25(a).

e) 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.

f) The toilet seat cover dispensers are inaccessible because it is mounted 61 inches above the finished floor. Provide toilet seat covers with mechanical controls, if any, that can be operated with 5 lbf or less and that 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). Ensure that the controls are a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that it 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, 4.27.4, 4.2.4, 4.2.5, 4.2.6.

g) 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.

h) The route within the toilet room is inaccessible because the door closer hangs into the door clear opening at 70 inches and is not 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.

i) The route from the counter to the toilet stall is inaccessible because it is only 21 inches wide. 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.

j) 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 §§ 4.13, 4.16, 4.17, 4.26, 4.27, Fig. 30.

3) Men's 2^nd Floor Toilet Room with Stalls

a) Accessible signage is not provided. 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.

b) The door to the men's second floor toilet room with stalls is inaccessible because it has an opening width of only 29 inches. Provide a door with a clear opening of 32 inches with the door open 90 degrees, measured between the face of the door and the opposite stop. Standards § 4.13.5, Fig. 24.

c) The door to the men's second floor toilet room with stalls is inaccessible because the pressure required to open the door is 12 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

d) The door to the men's second floor toilet room with stalls is inaccessible because there is a 1¼ inch threshold. Provide a door 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.

e) 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.

f) The paper towel dispenser is inaccessible because the controls are mounted at 57 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 §§ 4.27.2, 4.27.3, 4.2.4, 4.2.5, 4.2.6.

g) The lavatory is inaccessible because the bottom edge of the apron is 27½ 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.

h) 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 §§ 4.13, 4.16, 4.17, 4.26, 4.27, Fig. 30.

i) The route between the wall and a partition is 27½ inches wide. Provide an accessible route throughout the toilet room with a minimum clear width of 36 inches. Standards § 4.3.3.

4) Women's 2^nd Floor Toilet Room with Stalls

a) The women's second floor toilet room with stalls contains a number of inaccessible elements and is not accessible to people with disabilities. Provide an accessible toilet room such that all of the room's elements, including signage, door, door hardware, clear floor space, water closet, stall size and arrangement, stall door, urinal (if provided), grab bars, lavatory, mirror, controls, and dispensers, comply with the Standards. Standards §§ 4.13, 4.16, 4.17, 4.18, 4.19, 4.26, 4.27, 4.30, Fig. 30.

I. 1^st Floor Drinking Fountains

1) The drinking fountain has a spout that is 37½ 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 circulation path near the drinking fountain is inaccessible because the wall-mounted drinking fountain 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, or provide a cane-detectable barrier to alert blind people to this feature. Standards § 4.4.

J. Drinking Fountains Next to Lockers

1) The wall-mounted drinking fountain at the lockers is inaccessible because no knee clearance has been 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).

K. Elevators North Entrance from Parking

1) The elevator is inaccessible. Provide accessible directional signage with the International Symbol of Accessibility indicating the location of the nearest accessible elevator. Standards §§ 4.30.1, 4.30.2, 4.30.3, 4.30.5, 4.30.7.

L. Elevators South Entrance

1) The elevator is inaccessible because the call button are centered at 39½ 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 § 4.10.3, Fig. 20.

2) The elevator is inaccessible because no Braille is provided. Provide car control buttons that are at least ¾ inch in their smallest dimension and are raised or flush and that are designated by Braille and by raised standard alphabet characters for letters, arabic characters for numerals, or standard symbols. Ensure that the call button for the main entry floor is designated by a raised star at the left of the floor designation; that all raised designations for control buttons are placed immediately to the left of the buttons to which they apply; that floor buttons are provided with visual indicators to show when each call is registered and are extinguished when each call is answered; that all floor buttons are no higher than 54 inches above the finished floor for a side approach and no more than 48 inches above the finished floor for a front approach; and that emergency controls, including the emergency alarm and emergency stop, are grouped at the bottom of the panel and have their centerlines no less than 35 inches above the finished floor. Standards § 4.10.12, Fig. 23.

3) The elevator is inaccessible because, although emergency communications are provided, they are inoperative. 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.

6. Within 30 months of the effective date of this Agreement, the City will complete the following modifications to Mud Island, located at 280 Mud Island, Memphis, TN:

A. Mississippi River Museum

1) The information counter is inaccessible because it is 42¼ 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 counter at the museum gift shop is inaccessible because it is 40 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.

3) 1^st Floor Drinking Fountain

a) Although an accessible drinking fountain is provided, there is no drinking fountain provided for people who have difficulty bending or stooping. 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)(a).

4) 2^nd Floor Drinking Fountain

a) The drinking fountain on the second floor is inaccessible because the control requires 7 pounds of force to operate and the controls are not mounted in front or side-mounted near front edge. Provide a drinking fountain with controls mounted on or near the front edge that are operable with one hand, that require 5 lbf or less to operate, and that can be operated without tight grasping, pinching, or twisting of the wrist. Standards §§ 4.15.4, 4.27.4.

b) Although a low drinking fountain is provided, there is no drinking fountain provided for people who have difficulty bending or stooping. 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)(a).

5) Theater:

a) The theater 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 2 receivers for use by the general public and signage indicating their availability. 28 C.F.R. § 35.160; Standards §§ 4.30, 4.33.

b) The theater is inaccessible because it has 103 fixed seats and only three designated wheelchair seating areas. In addition, these wheelchair seating areas impermissibly extend into aisles. 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 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), 4.5, 4.33.

c) The door to the theater is inaccessible because it must be opened by an usher for persons using wheelchairs. Provide a door with a clear opening at least 32 inches wide when measured from the face of the door to the opposite stop when the door is opened 90 degrees and 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. Unless an automatic door operator is provided, there must be clear and level maneuvering clearances at the pull side and the push side of the door as indicated in Fig. 25. The door's threshold must be ½ inch or less in height and beveled with a slope of no greater than 1:2. If a door closer is provided, it must be set so that the sweep period of the door will, from an open position of 70 degrees, take 3 seconds to move to a point 3 inches from the latch, measured to the leading edge of the door. The door must not take more than 5 pounds of force to open or close. Standards § 4.13, Fig. 25.

d) The theater lacks fixed aisle seating without armrests. Provide at least 2 aisle seats with no armrests on the aisle side, or with removable or folding armrests on the aisle side, identified by a sign or marker. Provide signage in the ticket office notifying patrons that such seating is available. Standards § 4.1.3(19)(a).

e) The ramp to the stage is inaccessible because no edge protection has been provided. Provide edge protection at least 2 inches high at the drop off sides. Standards § 4.8.7.

6) Museum Exhibits

a) The route to the boat exhibit is inaccessible because the exhibit is a protruding object that is not 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.

7) Lower Level Men's Toilet Room with Stalls

a) The toilet room sign is inaccessible because it 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. the swing of a door. Standards §§ 4.30.1, 4.30.4, 4.30.5, 4.30.6.

b) The entryway door to the lower level men'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).

c) The entryway door is inaccessible because there is a 1.5 inch threshold. Provide a door 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.

d) The interior door is inaccessible because there is a 1.75 inch threshold. Provide a door 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.

e) 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.

f) The air dryer is inaccessible because it is mounted 57¼ inches above the finished floor. Provide a air dryer with mechanical controls, if any, that can be operated with 5 lbf or less and that 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). Ensure that the controls are a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that it 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, 4.27.4, 4.2.4, 4.2.5, 4.2.6.

g) The lavatory is inaccessible because the counter is 36¼ 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.

h) 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.

i) 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 §§ 4.13, 4.16, 4.17, 4.26, 4.27, Fig. 30.

8) Lower Level Women's Toilet Room with Stalls

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

c) The lower level women's toilet room 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 § 4.13.11(2)(b).

d) The interior door to the toilet room, which is accessed from the latch side of the door, is inaccessible because it has inadequate maneuvering clearance on the pull side. 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).

e) The entryway door is inaccessible because there is a 1.5 inch threshold. Provide a door 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.

f) The interior door is inaccessible because there is a 1.75 inch threshold. Provide a door 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.

g) 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.

h) The lavatory is inaccessible because the counter is 35¾ 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.

i) 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.

9) Second Level Men's Toilet Room with Stalls

a) The toilet room sign to the second level men's toilet room is on the hinge side of 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.

b) The entryway door to the second level men's toilet room is inaccessible because the pressure required to open the door is 12 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

c) The entryway door to the toilet room is inaccessible because there is a 1.5 inch threshold. Provide a door 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.

d) The door to the second level men'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).

e) The interior door to the toilet room is inaccessible because there is a 1.75 inch threshold. Provide a door 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.

f) The toilet seat cover dispenser is inaccessible because it requires a reach up to 60 inches above the finished floor. Provide a toilet seat cover dispenser with mechanical controls, if any, that can be operated with 5 lbf or less and that 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). Ensure that the controls are a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that it 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, 4.27.4, 4.2.4, 4.2.5, 4.2.6.

g) The air dryer is inaccessible because it is 57 inches above the finished floor. Provide an air dryer with mechanical controls, if any, that can be operated with 5 lbf or less and that 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). Ensure that the controls are a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that it 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, 4.27.4, 4.2.4, 4.2.5, 4.2.6.

h) The lavatory is inaccessible because the counter is 35¾ inches above the finished floor and the apron 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.

10) Second Level Women's Toilet Room with Stalls

b) The entryway door to the second 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).

d) The interior door to the second level women's 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).

f) The interior door, which is accessed from the latch side of the door, is inaccessible because it has insufficient maneuvering clearance on the pull side. 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).

g) The toilet seat cover dispenser is are inaccessible because it requires a reach up to 57½ inches above the finished floor. Provide a toilet seat covers dispenser with mechanical controls, if any, that can be operated with 5 lbf or less and that 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). Ensure that the controls are a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that it 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, 4.27.4, 4.2.4, 4.2.5, 4.2.6.

h) The air dryer is inaccessible because it is mounted 57¼ inches above the finished floor. Provide toilet seat covers with mechanical controls, if any, that can be operated with 5 lbf or less and that 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). Ensure that the controls are a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that it 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, 4.27.4, 4.2.4, 4.2.5, 4.2.6.

i) The lavatory is inaccessible because the counter is 36 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.

j) 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.

k) 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 §§ 4.13, 4.16, 4.17, 4.26, 4.27, Fig. 30.

11) Ramp to Lower Level River Boat Entrance

a) The route to lower level river boat entrance is inaccessible because no handrails are provided. On both sides of the ramp, provide handrails between 1¼ inches and 1½ inches in diameter with a continuous gripping surface. Ensure that the handrails extend at least 12 inches beyond the top and bottom of the ramp parallel with the ground surface, that they are mounted between 34 inches and 38 inches above the ramp surface, that they will not rotate within their fittings, and that they have ends that are rounded or return smoothly to floor, wall, or post. Standards §§ 4.3.8, 4.8.

12) Entrance to River Boat Exhibit

a) The route to the River Boat Exhibit is inaccessible because there is no handrail on one side, there are 1¾ inches between the handrail and the wall, and the handrail is 2 inches in diameter. On both sides of the ramp, provide handrails between 1¼ inches and 1½ inches in diameter with a continuous gripping surface. Ensure that the handrails extend at least 12 inches beyond the top and bottom of the ramp parallel with the ground surface, that they are mounted between 34 inches and 38 inches above the ramp surface, that they will not rotate within their fittings, and that they have ends that are rounded or return smoothly to floor, wall, or post. Standards §§ 4.3.8, 4.8.

13) Museum Exit

a) The exit door hardware is inaccessible because knob hardware is used. Provide a door with hardware that is easy to grasp with one hand and that does not require tight grasping, pinching, or twisting of the wrist to operate. Lever-operated mechanisms, push-type mechanisms, and U-shaped handles are acceptable designs. Standards § 4.13.9.

B. Gulf Port Grill

1) Men's Toilet Room with Stalls

a) 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.

c) There is insufficient turning space within the 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.

d) 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.

e) The towel dispenser is inaccessible because it is mounted 61 above the finished floor. Provide a towel dispenser with mechanical controls, if any, that can be operated with 5 lbf or less and that 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). Ensure that the controls are a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that it 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, 4.27.4, 4.2.4, 4.2.5, 4.2.6.

f) The circulation path near the towel dispenser is inaccessible because the wall-mounted towel dispenser protrudes into the main walkway and would not be detectable to a blind person using a cane. Provide a circulation path 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, or provide a cane-detectable barrier to alert blind people to this feature. Standards § 4.4.

g) 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.

h) 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) Women's Toilet Room with Stalls

a) 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.

d) 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.

e) The towel dispenser is inaccessible because it is mounted 61 inches above the finished floor. Provide a towel dispenser with mechanical controls, if any, that can be operated with 5 lbf or less and that 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). Ensure that the controls are a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that it 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, 4.27.4, 4.2.4, 4.2.5, 4.2.6.

f) 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 § 4.4.

h) Although an ambulatory stall is provided, its toilet seat is 19.5 inches above the finished floor, the coat hook height is 68 inches above the finished floor, the toilet paper dispenser is mounted above the side grab bar, and the distance of the farther end of both side grab bars is 52 inches from the rear wall. 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). Provide a toilet with a seat that measures 17 to 19 inches above the finished floor. 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 §§ 4.16.3, 4.17.2, 4.17.3, 4.22.4, Fig. 30(d).

C. Island Treasures

1) The counter at Island Treasures is inaccessible because it is 40 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.

D. Information Center / Ticket Booth

1) The counter at the information center/ticket booth is inaccessible because it is 40 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.

E. River Center

1) Men's 1^st Level Toilet Rooms with Stalls

a) The entrance door is inaccessible because knob hardware is used. Provide a door with hardware that is easy to grasp with one hand and that does not require tight grasping, pinching, or twisting of the wrist to operate. Lever-operated mechanisms, push-type mechanisms, and U-shaped handles are acceptable designs. Standards § 4.13.9.

b) The route to the stalls is inaccessible because it is only 31½ inches wide. Provide an accessible route to the stalls with a minimum clear width of 36 inches. Standards § 4.3.3.

c) The toilet seat cover dispenser is inaccessible because it is mounted 59½ inches above the finished floor. Provide toilet seat cover dispensers with mechanical controls, if any, that can be operated with 5 lbf or less and that 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). Ensure that the controls are a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that it 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, 4.27.4, 4.2.4, 4.2.5, 4.2.6.

d) The towel dispenser is inaccessible because it is mounted 57½ inches above the finished floor. Provide a towel dispenser with mechanical controls, if any, that can be operated with 5 lbf or less and that 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). Ensure that the controls are a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that it 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, 4.27.4, 4.2.4, 4.2.5, 4.2.6.

e) The lavatory is inaccessible because the counter is 36 inches above the finished floor and the apron is 28 inches above the finished. 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 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 §§ 4.13, 4.16, 4.17, 4.26, 4.27, Fig. 30.

2) Women's 1^st Level Toilet Rooms with Stalls

b) The route to the stalls is inaccessible because it is only 31½ inches wide. Provide an accessible route to the stalls with a minimum clear width of 36 inches. Standards § 4.3.3.

c) The toilet seat cover dispenser is inaccessible because it is mounted 59½ inches above the finished floor. Provide toilet seat covers with mechanical controls, if any, that can be operated with 5 lbf or less and that 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). Ensure that the controls are a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that it 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, 4.27.4, 4.2.4, 4.2.5, 4.2.6.

3) 1^st Level Drinking Fountains

a) East End Drinking Fountain

(1) The drinking fountain has a spout that is 41¼ 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 wall-mounted drinking fountain protrudes into the main walkway and would not be detectable to a blind person using a cane. Provide a circulation path 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, or provide a cane-detectable barrier to alert blind people to this feature. Standards § 4.4.

b) South End Drinking Fountain

(1) The drinking fountain has a spout that is 43 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 at the south end is inaccessible because its controls require 11 pounds to operate. Provide a drinking fountain with controls mounted on or near the front edge that are operable with one hand, that require 5 lbf or less to operate, and that can be operated without tight grasping, pinching, or twisting of the wrist. Standards §§ 4.15.4, 4.27.4.

c) North End Drinking Fountain

(2) The route to the drinking fountain is inaccessible because the trash shoot protrudes into the main walkway and would not be detectable to a blind person using a cane. Provide a circulation path 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.

4) Elevator

a) The elevator is inaccessible because no hoistway signage has been 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 § 4.10.5, Fig. 20.

b) The elevator is inaccessible because there is only 3 seconds from notification that a car is answering a call until the doors of that car close. 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.

c) The elevator door is inaccessible because there is a 1½ inch change in level at the threshold to the door. Provide an accessible door with a threshold that is no greater than ¼ inch, or is no greater than ½ inch and is beveled with a slope no greater than 1:2. Standards §§ 4.13.8, 4.5.2.

d) The elevator is inaccessible because it lacks Braille and raised characters to the left of the car control buttons, and the car control button for the main entry floor is not designated by a raised star at the left of the floor designation. Provide car control buttons that are at least ¾ inch in their smallest dimension and are raised or flush and that are designated by Braille and by raised standard alphabet characters for letters, arabic characters for numerals, or standard symbols. Ensure that the car control button for the main entry floor is designated by a raised star at the left of the floor designation; that all raised designations for control buttons are placed immediately to the left of the buttons to which they apply; that floor buttons are provided with visual indicators to show when each call is registered and are extinguished when each call is answered; that all floor buttons are no higher than 54 inches above the finished floor for a side approach and no more than 48 inches above the finished floor for a front approach; and that emergency controls, including the emergency alarm and emergency stop, are grouped at the bottom of the panel and have their centerlines no less than 35 inches above the finished floor. Standards § 4.10.12, Fig. 23.

e) The elevator is inaccessible because of the lack of car position illuminators. Provide visual car position indicators above the car control panel or over the door to show the position of the elevator in the hoistway. Ensure that indicators emit an audible and visual signal as the car passes or stops at a floor served by the elevator, with the corresponding floor designation being illuminated; and that numerals are a minimum of ½ inch high. Standards § 4.10.13.

F. River Terrace Restaurant

1) North Parking

a) Although the parking lot has a total of 26 parking spaces, an inadequate number are designated as reserved for people with disabilities. On the shortest accessible route to the accessible entrance, provide one van accessible space and one standard space 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 route to Point Lookout is inaccessible because only steps have been provided, and those have no handrail extensions. Provide a ramp that is at least 36 inches wide and has a slope not exceeding 1:12 and a cross slope not exceeding 1:50. Provide level landings at the top and bottom of the ramp that are at least as wide as the ramp and at least 60 inches long. If the ramp changes direction, provide a level landing measuring at least 60 inches by 60 inches at the change in direction. On both sides of the ramp, provide handrails between 1¼ inches and 1½ inches in diameter with a continuous gripping surface. Ensure that the handrails extend at least 12 inches beyond the top and bottom of the ramp parallel with the ground surface, that they are mounted between 34 inches and 38 inches above the ramp surface, that they will not rotate within their fittings, and that they have ends that are rounded or return smoothly to floor, wall, or post. Provide edge protection that is at least 2 inches high at the ramp's drop off sides. Ensure that the ramp and its level landing at the top and bottom are designed and maintained so that water does not accumulate on walking surfaces. Standards §§ 4.3.8, 4.8.

c) The ramp is inaccessible because the intermediate landing slopes more than 5%, the handrails are not continuous and do not have level extensions, and there is a gap in the handrail at a column. 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 §§ 4.3.8, 4.8.

d) The entrance is inaccessible because there is an abrupt unbeveled level change exceeding ½ inch. Provide an accessible door with a threshold that is no greater than ¼ inch, or is no greater than ½ inch and is beveled with a slope no greater than 1:2. Standards §§ 4.13.8, 4.5.2.

G. Amphitheater (Altered element)

1) The amphitheater containing 5,129 seats is inaccessible because there are only 31 wheelchair locations. Provide 53 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), 4.5, 4.33.

2) Concession stands

a) The counter at the top deck on the north side is inaccessible because it is 49 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.

b) The concession stand at the top deck on the south side is inaccessible because it is 48¼ 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.

3) Elevator

a) The elevator is inaccessible because there is only a 2 seconds interval from notification that a car is answering a call until the doors of that car close, and the doors do not automatically reopen if obstructed. 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.

b) The elevator is inaccessible because the main entry floor car control button is not designated by a raised star at the left of the floor designation. Provide car control buttons that are at least ¾ inch in their smallest dimension and are raised or flush and that are designated by Braille and by raised standard alphabet characters for letters, arabic characters for numerals, or standard symbols. Ensure that the car control button for the main entry floor is designated by a raised star at the left of the floor designation; that all raised designations for control buttons are placed immediately to the left of the buttons to which they apply; that floor buttons are provided with visual indicators to show when each call is registered and are extinguished when each call is answered; that all floor buttons are no higher than 54 inches above the finished floor for a side approach and no more than 48 inches above the finished floor for a front approach; and that emergency controls, including the emergency alarm and emergency stop, are grouped at the bottom of the panel and have their centerlines no less than 35 inches above the finished floor. Standards § 4.10.12, Fig. 23.

c) The elevator is inaccessible because of the lack of car position illuminators. Provide visual car position indicators above the car control panel or over the door to show the position of the elevator in the hoistway. Ensure that indicators emit an audible and visual signal as the car passes or stops at a floor served by the elevator, with the corresponding floor designation being illuminated; and that numerals are a minimum of ½ inch high. Standards § 4.10.13.

4) 2^nd Floor Men's Toilet Room with Stalls

a) This toilet room is inaccessible, and 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.

5) 2^nd Floor Women's Toilet Room with Stalls

6) Top level Single-User Unisex Toilet Rooms (4 sets, all duplicates)

7) Series of ramps to Amphitheater base

a) The series of ramps is inaccessible because the handrails are mounted between 29.5 and 32.75 inches above the ramp surface; the handrails are not continuous; the ends are not rounded or returned smoothly to the floor, wall, or post, and there are no level extensions at the landings; and the ramp's slope often exceeds the maximum allowable slope of 8.33%. Within nine months of the effective date of this Agreement, the City shall submit for the Department's review a complete plan on addressing these violations. This plan shall include a study showing the feasibility of bringing these ramp slopes within compliance with the ADA. 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.

H. Memphis-Side Entry to Mud Island

1) Elevator

a) The elevator is inaccessible because it lacks hall lanterns. 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 § 4.10.4, Fig. 20.

b) The elevator is inaccessible because it lacks both car position illuminators and audible / visual hall arrival signals. Provide visual car position indicators above the car control panel or over the door to show the position of the elevator in the hoistway. Ensure that indicators emit an audible and visual signal as the car passes or stops at a floor served by the elevator, with the corresponding floor designation being illuminated; and that numerals are a minimum of ½ inch high. Standards § 4.10.13.

c) The elevator is inaccessible because main entry floor car control button is not designated by a raised star at the left of the floor designation, and the call buttons do not have Braille and raised characters to the left of the buttons. Provide car control buttons that are at least ¾ inch in their smallest dimension and are raised or flush and that are designated by Braille and by raised standard alphabet characters for letters, arabic characters for numerals, or standard symbols. Ensure that the car control button for the main entry floor is designated by a raised star at the left of the floor designation; that all raised designations for control buttons are placed immediately to the left of the buttons to which they apply; that floor buttons are provided with visual indicators to show when each call is registered and are extinguished when each call is answered; that all floor buttons are no higher than 54 inches above the finished floor for a side approach and no more than 48 inches above the finished floor for a front approach; and that emergency controls, including the emergency alarm and emergency stop, are grouped at the bottom of the panel and have their centerlines no less than 35 inches above the finished floor. Standards § 4.10.12, Fig. 23.

2) Parking Garage Elevator

a) The elevator is inaccessible because main entry floor car control button is not designated by a raised star at the left of the floor designation, and the call buttons do not have Braille and raised characters to the left of the buttons. Provide car control buttons that are at least ¾ inch in their smallest dimension and are raised or flush and that are designated by Braille and by raised standard alphabet characters for letters, arabic characters for numerals, or standard symbols. Ensure that the car control button for the main entry floor is designated by a raised star at the left of the floor designation; that all raised designations for control buttons are placed immediately to the left of the buttons to which they apply; that floor buttons are provided with visual indicators to show when each call is registered and are extinguished when each call is answered; that all floor buttons are no higher than 54 inches above the finished floor for a side approach and no more than 48 inches above the finished floor for a front approach; and that emergency controls, including the emergency alarm and emergency stop, are grouped at the bottom of the panel and have their centerlines no less than 35 inches above the finished floor. Standards § 4.10.12, Fig. 23.

c) The elevator is inaccessible because, although emergency communications are provided, they are not identified by a raised symbol and lettering located adjacent to the device, and 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 § 4.10.14.

3) Men's Toilet Room with Stalls (Near Parking)

a) The toilet room signage is not accessible. 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 toilet room door is inaccessible because there is a threshold of more than 0.5 inches. Provide a door 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.

c) The paper towel dispenser is inaccessible because it mounted too high above the finished floor. Provide a towel dispenser with mechanical controls, if any, that can be operated with 5 lbf or less and that 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). Ensure that the controls are a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that it 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, 4.27.4, 4.2.4, 4.2.5, 4.2.6.

d) The lavatory is inaccessible because the bottom edge of the apron is 28 inches above the finished floor, the pipes are not covered or otherwise configured to protect against contact, and the faucet has twist knobs. 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; knee and toe clearances that comply with Fig. 31; hot water and drain pipes covered or otherwise configured to protect against contact; clear floor space at least 30 inches wide and 48 inches deep centered on the lavatory; and 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 §§ 4.19.2, 4.19.3, 4.19.4, 4.19.5, 4.27.4, Figs. 31, 32.

e) The toilet paper dispenser is inaccessible because it is mounted above the grab bar and is not centered at least 19 inches above the ground floor. 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).

4) Women's Toilet Room with Stalls (Near Parking)

c) The towel dispenser is inaccessible because it is too high above the finished floor. Provide a towel dispenser with mechanical controls, if any, that can be operated with 5 lbf or less and that 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). Ensure that the controls are a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that it 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, 4.27.4, 4.2.4, 4.2.5, 4.2.6.

d) The lavatory is inaccessible because the bottom edge of the apron is less than 29 inches above the finished floor, the pipes are not covered or otherwise configured to protect against contact, and the faucet has twist knobs. 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; knee and toe clearances that comply with Fig. 31; hot water and drain pipes covered or otherwise configured to protect against contact; clear floor space at least 30 inches wide and 48 inches deep centered on the lavatory; and 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 §§ 4.19.2, 4.19.3, 4.19.4, 4.19.5, 4.27.4, Figs. 31, 32.

e) 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 §§ 4.13, 4.16, 4.17, 4.26, 4.27, Fig. 30.

5) The route outside the toilet room is inaccessible because an expansion joint causes an abrupt rise that is not beveled. Provide a route 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.

6) Ticket Counter:

a) The ticket counter at the Mud Island entrance is inaccessible because it is 42¾ 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.

7) Ramp providing access from the street to the Memphis-side Mud Island entrance:

a) The ramp is inaccessible because it lacks handrails on one side, the existing handrail is 32 inches above the ramp surface, the existing handrail lacks extensions at the top and bottom of the ramp, and there are no level landings at 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; 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.

8) Escalators: The route under the escalators is inaccessible because the escalators are overhead hazards. 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.

9) Harbor Landing Entryway

a) The route from the street / sidewalk to the Harbor Landing entryway is inaccessible because the walkway has a slope of 5.9% without ramp features. 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.

7. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to the Fire Station #1, located at 211 Jackson Avenue, Memphis, TN:

A. Parking

1) The route from the parking area is inaccessible because no curb cut has been provided. 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) Although the parking lot has a total of 11 parking spaces, none are designated as being accessible to persons with disabilities. On the shortest accessible route to the accessible entrance, provide 1 van accessible space 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), 4.6, 4.30.7(1).

8. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Overton Park, located at 281 East Parkway North, Memphis, TN:

A. Parking Area at Veterans Plaza

1) Although the parking lot has a total of 16 parking spaces with one standard accessible parking space, 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).

B. Parking Area at Rainbow Lake

1) Although the parking lot has a total of 39 parking spaces with two standard accessible parking spaces, none are van accessible. In addition, the standard spaces designated for persons with disabilities lack appropriate signage and has unclear pavement markings. On the shortest accessible route to the accessible entrance, provide a total of 1 van accessible space and 1 standard space 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).

C. Toilet Rooms at Rainbow Lake

1) The toilet room signs for the Men's and Women's Toilet Rooms are 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.

D. Playground area at Rainbow Lake

1) The picnic tables are inaccessible because no accessible table has been provided. 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.

E. Ball Field at Rainbow Lake

1) There is no accessible route to the ballfield. 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.

2) The picnic tables are inaccessible because none provide a 19 inch deep clearance.. 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.

3) There is no accessible route to the play equipment, and no play equipment is accessible to persons who use wheelchairs. 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%). Ensure program access by providing at least one piece of play equipment that is on an accessible route and has a transfer platform to enable children who use wheelchairs to use it. Standards §§ 4.3, 4.5, Fig. 7.

F. Drinking Fountain at Ballfield at Rainbow Lake

1) Although a drinking fountain is provided, there is no accessible drinking fountain because the spout is not mounted at the front, and it is more than 36 inches above the finished floor,. 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.

2) The drinking fountain at the ballfield at Rainbow Lake is inaccessible because its clear space is less than 30 inches by 48 inches. Provide a drinking fountain with a clear floor space of at least 30 inches by 48 inches that allows a person in a wheelchair to make a parallel approach to the unit. Standards §§ 4.15.5(2), 4.2.4, Figs. 27(c), (d).

3) The route to the water fountain is inaccessible because no route has been provided to the concrete pad where the fountain is located. 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.

G. Route from East Park Parking Area to East Park Playground

1) The route from the East Park parking area to the East Park Playground is inaccessible because the slope of the route is 8% and it has no ramp features such as edge protection and handrails. Provide a ramp that is at least 36 inches wide and has a slope not exceeding 1:12 and a cross slope not exceeding 1:50. Provide level landings at the top and bottom of the ramp that are at least as wide as the ramp and at least 60 inches long. If the ramp changes direction, provide a level landing measuring at least 60 inches by 60 inches at the change in direction. On both sides of the ramp, provide handrails between 1¼ inches and 1½ inches in diameter with a continuous gripping surface. Ensure that the handrails extend at least 12 inches beyond the top and bottom of the ramp parallel with the ground surface, that they are mounted between 34 inches and 38 inches above the ramp surface, that they will not rotate within their fittings, and that they have ends that are rounded or return smoothly to floor, wall, or post. Provide edge protection that is at least 2 inches high at the ramp's drop off sides. Ensure that the ramp and its level landing at the top and bottom are designed and maintained so that water does not accumulate on walking surfaces. Standards §§ 4.3.8, 4.8.

9. The City represents that it is currently in the process of planning alterations to the Memphis Zoo, located at 2000 Prentiss Place, 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 30 months of the effective date of this Agreement, the City will make the following modifications:

A. Parking

1) Although the parking lot has a total of 628 parking spaces of which 14 are designated as being accessible to persons with disabilities, an inadequate number are van accessible. On the shortest accessible route to the accessible entrance, provide 2 additional 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 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. Ticket Counter

1) The Ticket Counter at the Zoo is inaccessible because the counter is mounted 40 inches above the ground. 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 Fountain near Toilet Rooms at Knox Administration Building

1) The drinking fountain has a spout that is 37.5 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.

D. Pay Telephone near Toilet Rooms at Knox Administration Building

1) The telephone at the Knox Administration Building, near the toilet rooms, is inaccessible because no volume control is provided, and no directional signage to the nearest accessible phone has been provided. 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).

E. Elephant's Trunk Zoo Shop

1) The Sales Counter at Elephant's Trunk Shop is inaccessible because it is mounted 40 inches above the ground. 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.

F. Drinking Fountain near Discovery Center

1) The circulation path near the drinking fountain near the Discovery Center is inaccessible because the fountain is not detectable to a blind person using a cane. Provide a circulation path at this location such that bottom leading edges of all objects 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) Although an accessible drinking fountain is provided, there is no drinking fountain provided for people who have difficulty bending or stooping. 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)(a).

G. Drinking Fountain near toilet rooms near Discovery Center

1) The drinking fountain has a spout that is 37 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 circulation path near the drinking fountain near the toilet rooms near the Discovery Center is inaccessible because the fountain is not detectable to a blind person using a cane. Provide a circulation path at this location such that the bottom leading edges of all objects 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.

H. Ticket Counter at Panda Exhibit

1) The Ticket Counter at the Panda Exhibit is inaccessible because it is mounted at 39 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.

I. Theater for Panda Movie

1) The Panda Theater containing 125 seats is inaccessible because no designated wheelchair seating locations 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 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), 4.5, 4.33.

2) The Panda Theater is inaccessible to people with hearing impairments because no assistive listening or closed captioning system is provided. Provide a permanently installed assistive listening system (ALS) or a portable ALS with an adequate number of electrical outlets or other supplementary wiring necessary to support a portable assistive listening system. Also provide 4 receivers for use by the general public and signage indicating their availability. 28 C.F.R. § 35.160; Standards §§ 4.30, 4.33.

J. Route from Panda Movie Theater to Panda Exhibit

1) The route from the Panda Theater to the Panda Exhibit is inaccessible because it has a slope of 8.6% and no handrails. 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.

K. Bamboo Shop

1) The Check Out Counter at the Bamboo Shop is inaccessible because it is mounted 40 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.

L. Ramp at Tropical Bird House

1) The ramp is inaccessible because no level landing is provided between the 2^nd and 3^rd legs 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 §§ 4.3.8, 4.8.

M. Aviary / Bird House Entrance

1) The double-leaf exterior entrance door is inaccessible because each leaf is only 28 inches. Provide a designated accessible entrance that has at least one active leaf with a minimum 32 inch clear opening width with the door open 90 degrees, measured between the face of the door and the opposite stop; that has either an automatic door operator or clear and level maneuvering clearance that complies fully with Fig. 25; and that has a threshold not exceeding ½ inch in height and beveled with a slope no greater than 1:2. Ensure that all hardware and operating devices have shapes that are easy to grasp with one hand and do not require tight grasping, pinching, or twisting of the wrist to operate, and that they are mounted no higher than 48 inches above the finished floor. Standards § 4.13, Figs. 24, 25.

2) The exterior entrance door is inaccessible because there is a 1 inch change in level at the threshold to the door. Provide an accessible door with a threshold that is no greater than ¼ inch, or is no greater than ½ inch and is beveled with a slope no greater than 1:2. Standards §§ 4.13.8, 4.5.2.

3) The route just outside the entrance door is inaccessible because an ashtray is an 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.

4) The double-leaf interior doors are inaccessible because each leaf is only 29 inches. Provide a door at this location that has at least one active leaf with a clear opening at least 32 inches wide when measured from the face of the door to the middle edge of the other door when one door is opened 90 degrees and that has hardware usable with one hand and without tight grasping, pinching, or twisting of the wrist OR provide an automatic door opener that opens both doors simultaneously. Where no automatic opener is provided, door hardware may be lever-operated, push-type, or a U-shaped handle. Unless an automatic door operator is provided, there must be clear and level maneuvering clearances at the pull side and the push side of the active leaf as indicated in Fig. 25. The doors' threshold must be ½ inch or less in height and beveled with a slope of no greater than 1:2. If a door closer is provided, it must be set so that the sweep period of the active leaf will, from an open position of 70 degrees, take 3 seconds to move to a point 3 inches from the latch, measured to the leading edge of the door. The active leaf must not take more than 5 pounds of force to open or close. Standards § 4.13, Figs. 24, 25.

N. Drinking Fountain at Entrance at Tropical Bird House

O. Ramp to viewing area within Tropical Bird House

1) The ramp is inaccessible because it has a slope of 1:6, has handrails on one side only, provides no handrails extensions, and has handrails mounted 2.5 inches from the wall with no rounded ends. 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.

P. Sea Lion Theater

1) The Sea Lion Theater containing 250 seats is inaccessible because there are no designated areas for wheelchair seating. 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 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), 4.5, 4.33.

Q. Drinking Fountain at Cat House Café

1) Although 1 drinking fountain is provided, there is no accessible drinking fountain because the fountain provided has a knee depth of only 18.5 inches, and has a spout that is 37.5 inches above the finished floor. In addition, there is no access for people who have trouble bending or stooping. 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.

2) The circulation path near the drinking fountain at the Cat House Cafe is inaccessible because the fountain is not detectable to a blind person using a cane. Provide a circulation path at this location such that the bottom leading edges of all objects 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.

R. Toilet Rooms: The City may make all of the following toilet rooms accessible. Alternatively, the City may make a set of toilet rooms in each general area accessible and 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. In addition, the City shall update Zoo information maps and displays to indicate the locations of 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.

1) Women's Toilet Room near Knox Administration Building (stalls)

a) The toilet room sign for the Women's 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 Women's Room, which is accessed through a front approach, is inaccessible because it has only 13 inches of maneuvering clearance on the pull side. On the pull side of the door, provide maneuvering clearance at least 60 inches deep and provide a minimum of 18 inches (24 inches is preferred) of maneuvering clearance on the latch side of the door. Standards § 4.13.6, Fig. 25(a).

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 apron is mounted 27.5 inches above the ground. 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 standard toilet stall:

(1) The toilet is inaccessible because the top of the seat is 16 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).

(2) 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) 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 17 inches above the finished floor. 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) The side grab bar at the toilet is inaccessible because it measures only 36 inches long. 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).

(6) The door to the accessible stall, which is accessed from the latch side of the door, is inaccessible because it has only 18 inches of maneuvering clearance on the pull side. 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).

f) Although there are 6 stalls, there is no ambulatory stall provided. 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).

g) The baby changing area is inaccessible because it is mounted with no knee space provided, and its controls are 62 inches above the finished floor when closed and 44 inches when open. 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.

2) Men's Toilet Room near Knox Administration Building (stalls)

a) The toilet room sign to the Men'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 Toilet Room, which is accessed through a front approach, is inaccessible because it has only 17 inches of maneuvering clearance on the pull side. On the pull side of the door, provide maneuvering clearance at least 60 inches deep and provide a minimum of 18 inches (24 inches is preferred) of maneuvering clearance on the latch side of the door. Standards § 4.13.6, Fig. 25(a).

c) The door to the Men's Toilet Room is inaccessible because there is an unbeveled 0.75 inch threshold. Provide a door 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.

d) 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.

e) The lavatory is inaccessible because the apron is mounted 26.75 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) Designated accessible toilet stall:

(1) The 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.

(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 17 inches above the finished floor. 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).

(4) The side grab bar at the toilet is inaccessible because it is only 36 inches in length and is mounted with its farther end 52 ½ 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).

3) Women's Toilet Room near Discovery Center (stalls)

a) The toilet room sign at the Women's Toilet Room near the Discovery Center 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) 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 toilet paper dispenser is inaccessible because it is mounted at only 16.75 inches above the finished floor. 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).

e) The grab bars at the toilet are inaccessible because the space between the grab bar and the wall is 1.75 inches. Provide grab bars such that there is 1½ inches between the grab bar and the wall. Standards § 4.26.2, Fig. 39.

f) The side grab bar at the toilet is inaccessible because the farther edge is 44.5 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).

g) The baby changing table is inaccessible because the controls are mounted at 57 inches above the finished floor when closed, and 38 inches high when open. 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.

4) Men's Toilet Room near Discovery Center (stalls)

a) The toilet room sign for the Men's Toilet Room near the Discovery Center 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) 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.

c) The toilet is inaccessible because the top of the seat is 24 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).

d) The toilet is inaccessible because its centerline measures 23.5 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.

e) The toilet paper dispenser is inaccessible because it is mounted 17 inches above the finished floor. 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 side grab bar at the toilet is inaccessible because there is only 0.5 inches between the bar and the toilet paper dispenser. 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.

g) The side grab bar at the toilet is inaccessible because it is mounted 13.5 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).

h) The rear grab bar at the toilet is inaccessible because it is mounted at 32.5 inches above the finished floor. 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.

i) The baby changing table is inaccessible because the controls are mounted at 57.25 inches high when closed, and at 37 inches high when open. 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.

j) The door to the toilet room, which is accessed from the hinge side of the door, is inaccessible because it has insufficient maneuvering space on the pull side of the door. On the pull side of the door, provide a path of travel at least 60 inches wide when the approach is a side approach from the hinge side and there is a minimum of 36 inches to the latch side of the door, OR provide a path of travel between 54 inches and 59 inches wide when the approach is a side approach from the hinge side and there is a minimum of 42 inches to the latch side of the door. Standards § 4.13.6, Fig. 25(b).

5) Men's Toilet Room near Eagle Area (stalls)

a) The toilet room sign is centered at 65 inches high, and 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.

b) The door to the Men's Toilet Room near the Eagle Area is inaccessible because there is no smooth landing at the entrance. 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 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.

d) Although there are 6 or more stalls, there is no ambulatory stall provided. 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) Designated accessible standard 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.

f) The route through the toilet 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.

6) Women's Toilet Room near Eagle Area (stalls)

a) The toilet room sign is inaccessible because its centerline is mounted at 65 inched high, and 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.

c) Designated accessible standard toilet stall:

(1) 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.

d) Designated accessible ambulatory toilet stall:

(1) The partitions in the ambulatory stall are 36.5 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).

e) The route through the toilet 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.

f) The baby changing table is inaccessible because the controls are mounted at 54 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.

7) Men's Toilet Room at Cat House Café (stalls)

a) The toilet room sign is mounted with its centerline at 64 inches high, and 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.

b) The door to the 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).

c) The entrance to the toilet room is inaccessible because the vestibule between the two doors in a series does not provide at least 48 inches clearance when both doors are open. Provide an accessible entrance to the toilet room, such that the space between any two doors in series is at least 48 inches plus the width of any door swinging into the space. Ensure that doors in series swing either in the same direction or away from the space between the doors. Standards § 4.13.7, Fig. 26.

d) 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.

f) The urinal is inaccessible because the flush control is 46 inches high. 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.

g) The side grab bar at the toilet is inaccessible because the toilet paper dispenser is mounted above the grab bar. 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.

h) 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 §§ 4.16.3, 4.17.2, Fig. 30(d).

i) The toilet is inaccessible because its centerline measures 19.5 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.

j) 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.

k) The side grab bar at the toilet is inaccessible because the farther end is mounted 46.5 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).

8) Women's Toilet Room at Cat House Café (stalls)

a) The toilet room sign is inaccessible because it is mounted with its centerline at 64 inches and 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.

b) The door to the vestibule, 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).

d) 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).

e) 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 §§ 4.16.3, 4.17.2, Fig. 30(d).

f) The toilet is inaccessible because its centerline measures 17.5 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.

g) The rear grab bar at the toilet is inaccessible because it is mounted at 32 inches above the finished floor. 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.

h) The side grab bar at the toilet is inaccessible because the farthest end is only 47 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).

10. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to the Memphis Brooks Museum of Art, located at 1934 Poplar, Memphis, TN:

A. Ramp up to Entrance

1) The ramp is inaccessible because the handrails provided are on one side of the ramp only, there are no handrail extensions, there is more that 1.5 inches between the rail and the wall, the handrails have a diameter of 2 inches, and they do not have edges that are rounded or return smoothly to the floor or 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 § 4.8.5.

B. Interior Entrance Door

1) The Interior Entrance Door 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).

C. Museum Films

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. Standards §§ 4.1.3(19)(b), 4.30.

D. Women's Main Level (2^nd floor) Toilet Room (stalls)

1) The toilet room sign on the Main Level is not accessible. 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 door to the Women's Main Level Toilet room, which is accessed through a front approach, is inaccessible because it has only a 6 inch pull side maneuvering clearance. On the pull side of the door, provide maneuvering clearance at least 60 inches deep and provide a minimum of 18 inches (24 inches is preferred) of maneuvering clearance on the latch side of the door. Standards § 4.13.6, Fig. 25(a).

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 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 §§ 4.13, 4.16, 4.17, 4.26, 4.27, Fig. 30.

E. Men's Main Level Toilet Room (stalls)

1) The toilet room sign for the Men's Main Level 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.

2) The door to the toilet room, which is accessed through a front approach, is inaccessible because it has only 6 inches of maneuvering clearance on the pull side. On the pull side of the door, provide maneuvering clearance at least 60 inches deep and provide a minimum of 18 inches (24 inches is preferred) of maneuvering clearance on the latch side of the door. Standards § 4.13.6, Fig. 25(a).

4) The lavatory is inaccessible because the faucets require twisting and tight grasping to operate. Provide a lavatory 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.

5) 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 §§ 4.13, 4.16, 4.17, 4.26, 4.27, Fig. 30.

F. Drinking fountains

1) Main (2^nd) floor: The drinking fountain is inaccessible because the spout location is not in front, and the controls require a pressure of 7 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 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.

2) 3^rd Floor: The drinking fountain is inaccessible because the spout location is not in front, and the controls require a pressure of 7 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 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.

G. Elevator

1) The elevator is inaccessible because there is no raised star to the left of the main entry floor car control button. Provide car control buttons that are at least ¾ inch in their smallest dimension and are raised or flush and that are designated by Braille and by raised standard alphabet characters for letters, arabic characters for numerals, or standard symbols. Ensure that the car control button for the main entry floor is designated by a raised star at the left of the floor designation; that all raised designations for control buttons are placed immediately to the left of the buttons to which they apply; that floor buttons are provided with visual indicators to show when each call is registered and are extinguished when each call is answered; that all floor buttons are no higher than 54 inches above the finished floor for a side approach and no more than 48 inches above the finished floor for a front approach; and that emergency controls, including the emergency alarm and emergency stop, are grouped at the bottom of the panel and have their centerlines no less than 35 inches above the finished floor. Standards § 4.10.12, Fig. 23.

H. Women's Toilet Room at 3^rd Floor (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 door to the 3^rd floor Women's Toilet room, which is accessed through a front approach, is inaccessible because it has only 6 inches of push side maneuvering clearance. On the push side of the door, provide maneuvering clearance at least 48 inches deep and provide a minimum of 12 inches of maneuvering clearance on the latch side of the door, or remove the closer or the latch. Standards § 4.13.6, Fig. 25(a).

4) The lavatory is inaccessible because the faucets require twisting to operate. Provide a lavatory 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.

I. Men's Toilet Room at 3^rd Floor (stalls)

2) The door to the 3^rd floor Men's Toilet room, which is accessed through a front approach, is inaccessible because it has only 6 inches of push side maneuvering clearance. On the push side of the door, provide maneuvering clearance at least 48 inches deep and provide a minimum of 12 inches of maneuvering clearance on the latch side of the door, or remove the closer or the latch. Standards § 4.13.6, Fig. 25(a).

4) The lavatory is inaccessible because the faucets require twisting for operation. Provide a lavatory 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.

11. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to the Fire Prevention Bureau, located at 2688 Avery Road, Memphis, TN:

A. Parking lot 14 spaces, with 1 standard accessible parking space.

1) The parking reserved for persons with disabilities lacks 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).

B. Entrances

1) The building is inaccessible because there are no signs provided at the inaccessible main entrance directing people with disabilities to the 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.

2) The double-leaf doors at the designated accessible entrance are inaccessible because each door leaf only has a width of 26.25 inches. Provide a designated accessible entrance that has at least one active leaf with a minimum 32 inch clear opening width with the door open 90 degrees, measured between the face of the door and the opposite stop; that has either an automatic door operator or clear and level maneuvering clearance that complies fully with Fig. 25; and that has a threshold not exceeding ½ inch in height and beveled with a slope no greater than 1:2. Ensure that all hardware and operating devices have shapes that are easy to grasp with one hand and do not require tight grasping, pinching, or twisting of the wrist to operate, and that they are mounted no higher than 48 inches above the finished floor. Standards § 4.13, Figs. 24, 25.

3) The designated accessible entrance is inaccessible because there is a slope of 2.5 degrees within the door's required maneuvering clearance. 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. Toilet rooms

1) The door to each toilet room is inaccessible because it provides a clear opening of only 27.5 inches. Provide a door to each toilet room with a clear opening at least 32 inches wide when measured from the face of the door to the opposite stop when the door is opened 90 degrees and 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 §§ 4.13.5, 4.13.9.

2) Each toilet room contains a number of inaccessible elements and is not accessible to people with disabilities. Provide an accessible toilet room(s) such that all of the room's elements, including signage, door, door hardware, clear floor space, water closet, stall size and arrangement, stall door, urinal (if provided), grab bars, lavatory, mirror, controls, and dispensers, comply with the Standards. Standards §§ 4.13, 4.16, 4.17, 4.18, 4.19, 4.26, 4.27, 4.30, Fig. 30.

D. Offices and Counters

1) Front Lobby

a) The counter at the front lobby is inaccessible because it is mounted 40 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) Permits office

a) The entrance door to the Permits office is inaccessible because knob hardware is used. Provide a door with hardware that is easy to grasp with one hand and that does not require tight grasping, pinching, or twisting of the wrist to operate. Lever-operated mechanisms, push-type mechanisms, and U-shaped handles are acceptable designs. Standards § 4.13.9.

b) The counter at the Permits Office is inaccessible because it is mounted 48 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.

12. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Fire Station #6, located at 924 Thomas Street, Memphis, TN:

A. Although the parking lot has a total of 8 parking spaces, none are designated as reserved for people with disabilities. On the shortest accessible route to the accessible entrance, provide 1 van accessible space 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).

13. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Fire Station #30, located at 4258 Overton Crossing, Memphis, TN:

14. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to North Frayser Community Center, located at 2555 St. Elmo Avenue, Memphis, TN:

A. Parking lot

1) Although the parking lot has a total of 36 parking spaces of which two are designated as standard accessible parking spaces, none are van accessible, and the standard accessible parking spaces are served by access aisles that are only 43-44 inches wide. In addition, the signage designating parking as reserved for persons with disabilities is too low. On the shortest accessible route to the accessible entrance, provide 1 van accessible space and 1 standard space 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), 4.6, 4.30.7(1).

B. Accessible Route

1) The route from the designated parking spaces to the walkway is inaccessible because the slope of the curb ramp is 6.3 degrees, and the route has existing cracks that creates abrupt level changes that are not beveled. 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 route from the walkway to the entrance is inaccessible because the slope is 5.1 to 5.2 degrees, with a cross slope of 2.2 to 2.3 degrees. Provide a ramp that is at least 36 inches wide and has a slope not exceeding 1:12 and a cross slope not exceeding 1:50. Provide level landings at the top and bottom of the ramp that are at least as wide as the ramp and at least 60 inches long. If the ramp changes direction, provide a level landing measuring at least 60 inches by 60 inches at the change in direction. On both sides of the ramp, provide handrails between 1¼ inches and 1½ inches in diameter with a continuous gripping surface. Ensure that the handrails extend at least 12 inches beyond the top and bottom of the ramp parallel with the ground surface, that they are mounted between 34 inches and 38 inches above the ramp surface, that they will not rotate within their fittings, and that they have ends that are rounded or return smoothly to floor, wall, or post. Provide edge protection that is at least 2 inches high at the ramp's drop off sides. Ensure that the ramp and its level landing at the top and bottom are designed and maintained so that water does not accumulate on walking surfaces. Standards §§ 4.3.8, 4.8.

C. Entrance door

1) The entrance door is inaccessible because knob hardware is used. Provide a door with hardware that is easy to grasp with one hand and that does not require tight grasping, pinching, or twisting of the wrist to operate. Lever-operated mechanisms, push-type mechanisms, and U-shaped handles are acceptable designs. Standards § 4.13.9.

D. Drinking fountain in lobby area

1) Although an accessible drinking fountain is provided, there is no drinking fountain provided for people who have difficulty bending or stooping. 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)(a).

E. Toilet Rooms with Stalls off main lobby Men's and Women's

1) The toilet room signs for the Men's and Women's Toilet Rooms off the Main Lobby are 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 designated accessible stall is incorrectly configured as an ambulatory stall, and there is no standard accessible stall provided. Provide a "standard" accessible toilet stall in each toilet room 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.

15. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Frayser Recreational Association, located at 4241 O.K. Robertson Road, Memphis, TN:

A. Parking lot

1) Although the parking lot has a total of approximately 50 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 1 standard space 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. Toilet rooms

1) The Men's and Women's toilet rooms contain a number of inaccessible elements and are not accessible to people with disabilities. Provide an accessible toilet room such that all of the room's elements, including signage, door, door hardware, clear floor space, water closet, stall size and arrangement, stall door, urinal (if provided), grab bars, lavatory, mirror, controls, and dispensers, comply with the Standards. Standards §§ 4.13, 4.16, 4.17, 4.18, 4.19, 4.26, 4.27, 4.30, Fig. 30.

16. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Rodney Baber Park 1 East, located at 2283 James Road, Memphis, TN:

A. Parking lot

B. Toilet rooms

1) The Men's and Women's toilet rooms contain a number of inaccessible elements and are not accessible to people with disabilities. Provide an accessible toilet room for each gender such that all of the room's elements, including signage, door, door hardware, clear floor space, water closet, stall size and arrangement, stall door, urinal (if provided), grab bars, lavatory, mirror, controls, and dispensers, comply with the Standards. Standards §§ 4.13, 4.16, 4.17, 4.18, 4.19, 4.26, 4.27, 4.30, Fig. 30.

17. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Rodney Baber Park 1 West, located at 2283 James Road, Memphis, TN:

A. Parking lot

B. Toilet rooms

18. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to John D. Holt Police Training Academy, located 4371 O.K. Robertson Rd, Memphis, TN:

A. Parking lot

1) 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. Drinking Fountain

1) The circulation path near the hi-lo drinking fountain outside the Men's and Women's Toilet Rooms off 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 § 4.4.

C. Toilet rooms with stalls:

1) Off of front lobby Men's toilet room

a) The toilet room door 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).

b) The door to the Men's Toilet Room is inaccessible because knob hardware is used. Provide a door with hardware that is easy to grasp with one hand and that does not require tight grasping, pinching, or twisting of the wrist to operate. Lever-operated mechanisms, push-type mechanisms, and U-shaped handles are acceptable designs. Standards § 4.13.9.

c) 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 §§ 4.13, 4.16, 4.17, 4.26, 4.27, Fig. 30.

d) The route through 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 § 4.4.

2) Off of front lobby Women's toilet room

a) The door to the toilet room is inaccessible because the pressure required to open the door is 18 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

b) The door to the Women's Toilet Room is inaccessible because knob hardware is used. Provide a door with hardware that is easy to grasp with one hand and that does not require tight grasping, pinching, or twisting of the wrist to operate. Lever-operated mechanisms, push-type mechanisms, and U-shaped handles are acceptable designs. Standards § 4.13.9.

c) The lavatory is inaccessible because the apron height 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.

d) 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 §§ 4.13, 4.16, 4.17, 4.26, 4.27, Fig. 30.

e) The route through 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 § 4.4.

19. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Hollywood Community Center, located at 1560 North Hollywood St., Memphis, TN:

A. Parking lot

1) Although the parking lot has a total of 68 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. Drinking fountain in lobby

1) Although a drinking fountain is provided, there is no accessible drinking fountain because the water flow height is only 1 inch high, and the knee space provided under the unit is only 24.5 inches high. In addition, there is no access for people who have trouble bending or stooping. 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. 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, 4.27.4, Figs. 27(a), (b).

C. Toilet room with stalls in lobby Men's and Women's

1) The toilet room signs for the Mens' and Women's toilet rooms in the lobby are 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 entrance to the Men's and Women's Toilet Rooms are inaccessible because there is a 1.5 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.

3) 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.

4) The lavatory is inaccessible because the apron is mounted at 27.5 inches high in the Women's Toilet Room, and at 26.5 inches high in the Men's. 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 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.

6) The designated accessible stall in each toilet room is incorrectly configured as an ambulatory stall, and there is no standard accessible stall provided. Provide a "standard" accessible toilet stall in each toilet room 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.

20. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Audubon Golf Course, located at 4160 Park Avenue, Memphis, TN:

A. Parking

1) Although the parking lot has a total of 113 parking spaces, there are only 2 spaces designated as reserved for persons with disabilities, none of which are van accessible, and both have access aisles blocked by dumpsters. 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), 4.6, 4.30.7(1).

B. Curb cut

1) The route from the spaces designated as reserved for persons with disabilities to the entrance is inaccessible because the slope is 14.7%, with a severe cross slope. 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.

C. 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.

D. Exterior Entrance to Pro Shop

1) The entrance from the parking spaces designated as reserved for persons with disabilities is inaccessible because there is no automatic door opener and there is a slope of 10.6% with a cross slope of 2.1% within the door's required maneuvering clearance. Provide a door so that the floor or ground area within the required clearances is level and clear. Standards § 4.13.6, Fig. 25.

E. Pro Shop Counter

1) The retail counter at the Pro Shop/Main Entrance is inaccessible because it measures 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.

F. Food Counter

1) The retail counter at the Food Counter is inaccessible because while it has a lower portion 36 inches high, it is not at least 36 inches wide. 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. Women's Locker Room

1) The signage provided is inaccessible. Provide permanent room signage with upper case, sans serif or simple serif type letters and numerals, meeting the requirements of the Standards for character height, raised characters, finish and contrast, accompanied by Grade 2 Braille; mounted on the wall adjacent to the latch side of the door or on the nearest adjacent wall at a height of 60 inches above the finished floor to the centerline of the sign; and located so that a person may approach within 3 inches of the signage without encountering protruding objects or standing within the swing of a door. Standards §§ 4.30.1, 4.30.4, 4.30.5, 4.30.6.

2) The door to the locker 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).

3) The entrance to the Women's Locker Room is inaccessible because the vestibule does not have 48 inches of space beyond the door swing. Provide an accessible entrance to the locker room such that the space between any two doors in series is at least 48 inches plus the width of any door swinging into the space. Ensure that doors in series swing either in the same direction or away from the space between the doors. Standards § 4.13.7, Fig. 26.

4) The entrance door 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 paper towel and soap dispensers are inaccessible. Provide paper towel and soap dispensers with mechanical controls, if any, that can be operated with 5 lbf or less and that 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). Ensure that the controls are a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that it 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, 4.27.4, 4.2.4, 4.2.5, 4.2.6.

6) 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.

7) The lavatory is inaccessible. 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; knee and toe clearances that comply with Fig. 31; hot water and drain pipes covered or otherwise configured to protect against contact; clear floor space at least 30 inches wide and 48 inches deep centered on the lavatory; and 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 §§ 4.19.2, 4.19.3, 4.19.4, 4.19.5, 4.27.4, Figs. 31, 32.

8) The shower in the locker room is inaccessible. Provide a shower in this 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.

9) The path of travel is inaccessible because the paper towel dispenser is a protruding object. Provide circulation path 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.

H. Men's Locker Room

2) The locker room door 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).

3) The paper towel and soap dispensers are inaccessible. Provide paper towel and soap dispensers with mechanical controls, if any, that can be operated with 5 lbf or less and that 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). Ensure that the controls are a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that it 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, 4.27.4, 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 §§ 4.13, 4.16, 4.17, 4.26, 4.27, Fig. 30.

5) The lavatory is inaccessible. 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; knee and toe clearances that comply with Fig. 31; hot water and drain pipes covered or otherwise configured to protect against contact; clear floor space at least 30 inches wide and 48 inches deep centered on the lavatory; and 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 §§ 4.19.2, 4.19.3, 4.19.4, 4.19.5, 4.27.4, Figs. 31, 32.

6) The shower in the locker room is inaccessible. Provide a shower in this 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.

I. Drinking Fountain

1) The drinking fountain is inaccessible because it has a spout that is 42 inches above the finished floor, and the controls require 11 pounds of force 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 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.

21. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Audubon Park, located at 640 Goodlett and 750 Cherry Road, Memphis, TN:

A. Parking-Goodlett Street Entrance

1) Although the parking lot has a total of 120 parking spaces, only 3 are designated as being accessible, none are van-accessible, only one has a 75 inch access aisle, and one does not have a vertical sign with the symbol of access. On the shortest accessible route to the accessible entrance, provide a total of 1 van accessible space and 4 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. Parking- Southern Street Entrance

1) Although the parking lot has a total of 34 parking spaces of which 3 are designated as standard accessible parking spaces, none are van accessible, the access aisles are either too narrow or missing, one does not have the vertical sign with the symbol for access, and one space is not level. On the shortest accessible route to the accessible entrance, provide a total of 1 van accessible space and 1 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).

C. Accessible Route

1) The routes to the picnic tables, playground, drinking fountain (Southern Street entrance), and baseball field are inaccessible. 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.

D. Picnic Tables

1) 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.

E. Drinking fountainSouthern Street entrance

22. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to North Police Precinct, located at 3633 Old Allen Road, Memphis, TN:

A. Parking

1) Although the parking lot has a total of 14 parking spaces of which 2 are designated as standard accessible 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).

B. The signage provided throughout the facility is inaccessible. Provide permanent room signage with upper case, sans serif or simple serif type letters and numerals, meeting the requirements of the Standards for character height, raised characters, finish and contrast, accompanied by Grade 2 Braille; mounted on the wall adjacent to the latch side of the door or on the nearest adjacent wall at a height of 60 inches above the finished floor to the centerline of the sign; and located so that a person may approach within 3 inches of the signage without encountering protruding objects or standing within the swing of a door. Standards §§ 4.30.1, 4.30.4, 4.30.5, 4.30.6.

C. Main Lobby Counter

1) The Counter at the Main Lobby is inaccessible because it is mounted at 45.5 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.

D. Traffic Violations Counter

1) The Traffic Violations Counter is inaccessible because it is mounted 48 inches high for the counter / slide area, and 65 inches high for the talk area. 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.

E. Women's Toilet Room with Stalls

2) The door to the Women's Toilet Room is inaccessible because the pressure required to open the door is 12 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 door swings into the lavatory's clear floor space. Provide a lavatory with clear floor space at least 30 inches wide and 48 inches deep centered on the lavatory. Standards § 4.19.3, Fig. 32.

4) 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.

5) There is insufficient turning space within the 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.

6) The lavatory is inaccessible because the bottom edge is 28 inches high, the hot water pipes are not insulated or otherwise configured to protect against contact, and the faucet knobs require twisting to operate. 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; knee and toe clearances that comply with Fig. 31; hot water and drain pipes covered or otherwise configured to protect against contact; clear floor space at least 30 inches wide and 48 inches deep centered on the lavatory; and 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 §§ 4.19.2, 4.19.3, 4.19.4, 4.19.5, 4.27.4, Figs. 31, 32.

7) The designated accessible toilet stall is inaccessible because it is 36 inches wide, and lacks clear floor space. 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.

8) The toilet is inaccessible because the top of the seat is 15 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).

9) 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.

10) 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.

11) 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.

12) The toilet paper dispenser is inaccessible because it is on the wrong side of the 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).

13) The side grab bar at the toilet is inaccessible. 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).

14) There is no rear grab bar at the toilet. 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.

F. Men's Toilet Room with Stalls

2) The door to the Men's Toilet Room is inaccessible because the pressure required to open the door is 11 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

4) 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.

7) The designated accessible toilet stall is inaccessible because it is only 36 inches wide and lacks clear floor space. 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.

10) The 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.

12) The toilet paper dispenser is inaccessible because it is mounted on the wrong side of the 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).

14) 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.

15) The paper towel dispenser is inaccessible because the controls are mounted at 52 inches above the finished floor and require a forward approach. 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 §§ 4.27.2, 4.27.3, 4.2.4, 4.2.5, 4.2.6.

G. Drinking Fountain

1) The drinking fountain has a spout that is 41 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 "wall-mounted" drinking fountain is inaccessible because it has no 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 § 4.15.5(1), Figs. 27(a), (b).

3) Although a low drinking fountain is provided, there is no drinking fountain provided for people who have difficulty bending or stooping. 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)(a).

23. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Raleigh Branch Library, located at 3157 Powers Road, Memphis, TN:

A. Parking

1) Although the parking lot has a total of 35 parking spaces of which two are designated as standard accessible parking spaces, 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), 4.6, 4.30.7(1).

B. Exterior Entrance / Interior Entrance (Doors in a series)

1) The interior door is inaccessible because the pressure required to open the door is 11 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

C. Telephone (in lobby)

1) The telephone counter in the lobby is inaccessible because it is mounted at 41.5 inches above the finished floor. Provide a counter mounted at between 28 to 34 inches above the finished floor. Standards §§ 4.31, 4.30.7(2).

2) The telephone in the lobby is inaccessible because the highest operable part is 63 inches above the finished floor, and has no signage. 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).

3) The route past the lobby telephone is inaccessible because the telephone is a protruding object, protruding 12 inches with a leading edge 36 inches high. 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.

D. Check Out Counter

1) The Check Out Counter at is inaccessible because it is mounted at 39 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.

E. Information Counter

1) The Information Counter at is inaccessible because it is mounted at 43 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.

F. Magazine Displays

1) The magazine display is inaccessible because the topmost magazines require a reach of 61 inches above the finished floor. Provide a magazine display with a minimum of 36 inches of clear width between units and with reach ranges of between 18 inches and 54 inches (maximum height of 48 inches is preferred) above the finished floor. Standards § 8.4, Fig. 55.

2) The card catalog is inaccessible because the bottom of the catalog is 15 inches above the finished floor. Provide a card catalog with a minimum of 36 inches of clear width between units and with reach ranges of between 18 inches and 54 inches (maximum height of 48 inches is preferred) above the finished floor. Standards § 8.4, Fig. 55.

G. Women's Toilet Room with Stalls

1) The toilet room sign is mounted on the toilet room 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 toilet room door is inaccessible because the pressure required to open the door is 17 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

3) The toilet room door is inaccessible because knob hardware is used. Provide a door with hardware that is easy to grasp with one hand and that does not require tight grasping, pinching, or twisting of the wrist to operate. Lever-operated mechanisms, push-type mechanisms, and U-shaped handles are acceptable designs. Standards § 4.13.9.

4) The door to the toilet room, which is accessed from the latch side of the door, is inaccessible because it has inadequate maneuvering clearance on the pull side. 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).

5) 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.

6) The designated accessible toilet stall is inaccessible because it is only 40 inches wide and lacks adequate clear floor space. 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.

7) The door to the accessible stall is inaccessible because it is fitted with knob hardware. 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.

8) 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.

9) The toilet paper dispenser is inaccessible because it is mounted 38 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).

10) The side grab bar at the toilet is inaccessible because the farther end is not at least 52 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).

11) 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.

H. Men's Toilet Room with Stalls

2) The door to the toilet room is inaccessible because the pressure required to open the door is 12 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

4) 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.

5) The lavatory is inaccessible because the bottom edge is 30 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.

6) The soap dispenser is inaccessible because the controls are mounted at 52 inches above the finished floor. Provide a soap 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 §§ 4.27.2, 4.27.3, 4.2.4, 4.2.5, 4.2.6.

7) The designated accessible toilet stall is inaccessible because it is only 40 inches wide, and lacks adequate clear floor space. 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.

8) The door to the accessible stall is inaccessible because it is fitted with knob hardware that requires twisting to operate. 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.

9) The stall door swings into the required clear floor space inside the toilet stall. Ensure that no door swings into the required clear floor space at any accessible fixture. Standards § 4.22.2.

10) 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.

11) 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.

12) The toilet paper dispenser is inaccessible because it is mounted 38 inches from the rear wall and 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).

13) 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.

I. Drinking Fountain

1) Although a drinking fountain is provided, there is no accessible drinking fountain because its spout height is 37 inches above the finished floor, and the knee space height provided is only 26.5 inches high. 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, ensure that there is 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.

24. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Raleigh Tennis Center, located at 3680 Powers Road, Memphis, TN:

A. Parking

1) Although the parking lot has a total of 35 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 1 standard space 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. Exterior Entrance

1) The exterior entrance is inaccessible because there is a 3 inch change in level at the threshold to the door. Provide an accessible door with a threshold that is no greater than ¼ inch, or is no greater than ½ inch and is beveled with a slope no greater than 1:2. Standards §§ 4.13.8, 4.5.2.

C. Accessible Route to Courts

1) The building is inaccessible because it lacks directional signage along the side of the building, directing persons to the accessible route to the courts. 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.

D. Counter

1) The Counter is inaccessible because it is 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.

25. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Raleigh Frayser Senior Center, located at 3985 Egypt Central Road, Memphis, TN:

A. Parking

1) Although the parking lot has a total of 163 parking spaces of which 11 are designated as standard accessible parking spaces, an inadequate number are van accessible, and no spaces have access aisles. On the shortest accessible route to the accessible entrance, provide at least 1 van accessible space and 5 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), 4.6, 4.30.7(1).

B. Interior doors

1) The interior doors throughout the facility are inaccessible because knob hardware is used. Provide a door with hardware that is easy to grasp with one hand and that does not require tight grasping, pinching, or twisting of the wrist to operate. Lever-operated mechanisms, push-type mechanisms, and U-shaped handles are acceptable designs. Standards §§ 4.1.3(7)(b), 4.13.9.

C. Drinking fountains

1) The circulation path near the hi-lo drinking fountain near the Main Entrance is inaccessible because the high fountain is not detectable to a blind person using a cane, as it protrudes 16 inches from the wall. 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), 4.4.

2) The circulation path near the hi-lo drinking fountain near the Director's Office is inaccessible because the high fountain is not detectable to a blind person using a cane, as it protrudes 19 inches from the wall. 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), 4.4.

D. Women's Toilet Room with Stalls

1) The toilet room signage 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 lavatory is inaccessible because the top is 35 inches high and it has no knee or toe clearance. 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), 4.22.6, 4.19.2, Fig. 31.

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 §§ 4.1.3(11), 4.22.4, 4.22.7, 4.13, 4.16, 4.17, 4.26, 4.27, Fig. 30.

4) Designated accessible ambulatory stall:

a) The ambulatory stall provided is 38 inches wide, the toilet centerline is 19 inches from the side wall, and side grab bars are not mounted at the proper height. 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 §§ 4.1.3(11), 4.22.4, Fig. 30(d).

b) 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), 4.25.2, 4.25.3, 4.2.4, 4.2.5, 4.2.6.

c) The door to the stall is inaccessible because it is fitted with knob hardware. 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 §§ 4.1.3(11), 4.22.2, 4.13.9.

E. Men's Toilet Room with Stalls

3) The designated accessible stall in each toilet room is incorrectly configured as an ambulatory stall, and there is no standard accessible stall provided. Provide a "standard" accessible toilet stall in each toilet room 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.

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), 4.25.2, 4.25.3, 4.2.4, 4.2.5, 4.2.6.

5) The door to the stall is inaccessible because it is fitted with knob hardware. 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 §§ 4.1.3(11), 4.22.2, 4.13.9.

F. Ramp to Stage

1) The ramp is inaccessible because handrails are not provided on both sides of the ramp, the handrail provided is not continuous, and it lacks handrail extensions at the top and bottom 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), 4.8.5.

26. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Fire Station #46, located at 3423 Scenic Highway, Memphis, TN:

A. Parking

1) Although the parking lot has a total of 3 parking spaces, none are designated as reserved for people with disabilities. On the shortest accessible route to the accessible entrance, provide 1 van accessible space 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).

27. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Fire Station #47, located at 3510 Coleman Road, Memphis, TN:

A. Parking

1) Although the parking lot has a total of 12 parking spaces, none are designated as reserved for people with disabilities. On the shortest accessible route to the accessible entrance, provide 1 van accessible space 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).

28. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Fire Station #48, located at 4985 Raleigh LaGrange Road, Memphis, TN:

A. Parking

29. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Fire Station #49, located at 4351 New Allen Road, Memphis, TN:

A. Parking

1) Although the parking lot has a total of 20 parking spaces, none are designated as reserved for people with disabilities. On the shortest accessible route to the accessible entrance, provide 1 van accessible space 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).

30. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Fire Station 23, located at 3468 Jackson Avenue, Memphis, TN:

A. Parking

1) Although the parking lot has a total of less than 25 parking spaces, they are not demarcated, so there is no designated accessible spaces provided. On the shortest accessible route to the accessible entrance, provide 1 van accessible space 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).

31. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Fire Station 17, located at 611 National Street, Memphis, TN:

A. Parking

1) Although the parking lot has a total of 9 parking spaces, none are designated as reserved for persons with disabilities. On the shortest accessible route to the accessible entrance, provide 1 van accessible space 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), 4.6, 4.30.7(1).

32. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to the Alzheimer Day Care Center, located at 4585 Raleigh LaGrange Road, Memphis, TN:

A. Parking

1) Although the parking lot has a total of 23 parking spaces of which one is designated as a standard parking space, 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).

B. Men's and Women's Toilet Rooms

1) The toilet room sign is not accessible. 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 designated accessible stall in each toilet room is incorrectly configured as an ambulatory stall, and there is no standard accessible stall provided. Provide a "standard" accessible toilet stall in each toilet room 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.

33. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to the Kennedy Park, located at 4575 Raleigh LaGrange Road, Memphis, TN:

A. Parking

1) Although the parking lot has a total of 250 parking spaces, only 3 are designated as standard accessible parking spaces, none are van-accessible, there are no access aisles, and there are no vertical signs with the International symbol of access. On the shortest accessible route to the accessible entrance, provide 1 van accessible space and 6 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. Accessible Seating

1) The ballparks 6-9, the Gotshall Soccer fields, and ballparks 1-5 contain a number of bleacher seats which are inaccessible because there is no seating provided for persons using wheelchairs. Provide at least one wheelchair seating area at each ballpark and soccer field, 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), 4.5, 4.33.

C. Accessible Route

1) The route from the parking area to ballparks 1-5 and the Gotshall soccer fields is inaccessible. 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.

D. Drinking Fountains

1) Although drinking fountains are provided, there is no accessible drinking fountains at ballparks 1-5 because their spout locations and heights are inaccessible. Provide at least one drinking fountain at or near each ballpark 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.

E. Men's and Women's Toilet Rooms at Ballparks 1-5

1) The toilet room sign for the Men's and Women's Toilet Room at ballparks 1-5 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.

34. The City represents that it is currently in the process of planning a replacement facility for the Gaisman Community Center, located at 4223 Macon Road, Memphis, TN. Within six months of the effective date of this Agreement, or as soon as they are available, 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 replace this facility, within 30 months of the effective date of this Agreement, the City will make the following modifications:

A. Parking

1) Although the parking lot has a total of 38 parking spaces of which 8 are designated as standard accessible 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).

B. Entrance

1) The main entrance is inaccessible because there is a slope of 6.8% within the door's required maneuvering clearance. 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. Women's Toilet Room with Stalls

1) The signage provided is inaccessible because it is currently centered at 58 inches, and has no Braille or raised characters. 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) 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 accessible stall provided is only 43 inches by 60 inches. Provide clear floor space that complies with Fig. 30 at the toilet. Standards § 4.17.3, Fig. 30.

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) The 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.

6) 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.

7) 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).

8) The rear grab bar at the toilet is inaccessible because the air freshener interferes with the use of the rear grab bar. Provide a rear grab bar that has 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. 39.

D. Men's Toilet Room with Stalls

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 top of the lavatory is 35 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), 4.22.6, 4.19.2, Fig. 31.

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 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).

7) The rear grab bar at the toilet is inaccessible because the air freshener interferes with its use. Provide a rear grab bar that has at least 1½ inches between the grab bar and any other object, such as a toilet seat cover dispenser. Standards §§ 4.1.3(11), 4.22.4, 4.17.6, 4.26.2, Fig. 39.

E. Drinking Fountains

35. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to the Fire Station #34, located at 3909 Knight Arnold Road, Memphis, TN:

A. Parking lot: the parking lot is unmarked, and there is no parking space designated as being accessible for persons with disabilities. On the shortest accessible route to the accessible entrance, provide 1 van accessible space 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), 4.6, 4.30.7(1).

B. Route of travel: Persons using wheelchairs could travel from the parking lot into the Fire Station via open bay doors. However, there is a 3 inch lip at the open bay doors. Provide at least one accessible route within the boundary of the site connecting the parking lot to the entrance 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.

36. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to the McFarland Community Center, located at 4955 Cottonwood, Memphis, TN:

A. Parking lot: there are 115 total parking spaces, 7 of which are designated as standard accessible parking spaces.

1) Designated accessible parking space in front of building:

a) 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) The parking reserved for persons with disabilities is inaccessible because the parking space and access aisle is cracked and uneven. Provide designated accessible parking spaces and access aisles that are flat and level, with slopes and cross-slopes not exceeding 1:50 in all directions, with surfaces that are firm, stable, and slip-resistant. Standards §§ 4.3.6, 4.5.1, 4.6.3.

c) The built-up curb ramp impermissibly extends into the access aisle that serves the parking space reserved for persons with disabilities. 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.

d) There is an abrupt rise between the asphalt and the concrete walk that is not beveled. 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.

2) Designated accessible parking spaces in rear of building:

a) Two of the four parking spaces reserved for persons with disabilities lacks 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).

b) Two of the four designated accessible spaces do not have an access aisle. At each standard accessible space, provide an access aisle at least 60 inches wide. 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.

3) Designated accessible parking spaces on side of building:

a) Both of the designated accessible parking spaces do not have vertical 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).

b) One of the two designated accessible parking spaces has an access aisle that is 50 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.

B. Front and Rear Entrances: The front and rear entrances are inaccessible because their hardware requires tight grasping. Provide a door at each entrance with hardware that is easy to grasp with one hand and that does not require tight grasping, pinching, or twisting of the wrist to operate. Lever-operated mechanisms, push-type mechanisms, and U-shaped handles are acceptable designs. Standards § 4.13.9.

C. Rooms:

1) Game Room: the light switch height is 55 inches above the finished floor. The light switch is inaccessible because the switch is mounted at 55 inches above the finished floor. Provide a light switch 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.

2) Multiple Purpose Room: all coat hooks are 67 inches above the finished floor. Provide a coat hook 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.

D. Drinking fountain:

1) 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. Ensure that there is 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)(a), 4.15, 4.27.4, Fig. 27.

E. Gym

1) The door to the gym is inaccessible because a single leaf opening has an opening width of only about 29 inches. Provide a door with a clear opening of 32 inches with the door open 90 degrees, measured between the face of the door and the opposite stop. Standards § 4.13.5, Fig. 24.

F. Men's Toilet Room with stalls across from police office

1) The toilet room signage does not have raised and Braille characters. 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 entrance doorway is inaccessible because there is a 1 inch threshold. Provide a door 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.

3) 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.

4) The route through the toilet room is inaccessible because the wall-mounted paper towel dispenser 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.

5) The lavatory is inaccessible because the bottom edge of the lavatory apron is 26.5 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; knee and toe clearances that comply with Fig. 31; hot water and drain pipes covered or otherwise configured to protect against contact; clear floor space at least 30 inches wide and 48 inches deep centered on the lavatory; and 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 §§ 4.19.2, 4.19.3, 4.19.4, 4.19.5, 4.27.4, Figs. 31, 32.

6) The toilet is inaccessible because there is insufficient clear floor space. Provide clear floor space that complies with Fig. 30 at the toilet. Standards § 4.17.3, Fig. 30.

7) 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.

8) 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.

9) The toilet paper dispenser is inaccessible because its distance from the rear wall is 38.5 inches. 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).

10) The side grab bar at the toilet is inaccessible because the distance of the farther end of the side grab bar to the rear wall is not at least 52 inches. 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).

11) There is no rear grab bar provided in the designated accessible stall. 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.

G. Women's toilet room with stalls (across from police office)

3) 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.

4) The soap dispenser control is inaccessible because the controls are mounted at 50 inches above the finished floor, and a front reach above the lavatory is required. Provide a soap 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 §§ 4.27.2, 4.27.3, 4.2.4, 4.2.5, 4.2.6.

5) The paper towel dispenser is inaccessible because the controls are mounted at 55.5 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 §§ 4.27.2, 4.27.3, 4.2.4, 4.2.5, 4.2.6.

6) The lavatory is inaccessible because the bottom edge of the lavatory apron 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; knee and toe clearances that comply with Fig. 31; hot water and drain pipes covered or otherwise configured to protect against contact; clear floor space at least 30 inches wide and 48 inches deep centered on the lavatory; and 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 §§ 4.19.2, 4.19.3, 4.19.4, 4.19.5, 4.27.4, Figs. 31, 32.

7) The toilet is inaccessible because there is insufficient clear floor space. Provide clear floor space that complies with Fig. 30 at the toilet. Standards § 4.17.3, Fig. 30.

8) 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.

9) 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.

10) The side grab bar at the toilet is inaccessible because the farther end of the side grab bar is not at least 52 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).

37. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Fox Meadows Golf Course, located at 3064 Clarke, Memphis TN:

A. Parking Lot: There are 121 parking spaces, of which only 2 are designated as being accessible to persons with disabilities. In addition, the access aisle is 53 inches wide. 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), 4.6, 4.30.7(1).

B. Paths of Travel:

1) Main Entranceway: The main entranceway is inaccessible because there is a 1 inch change in level at the threshold to the door. Provide an accessible door with a threshold that is no greater than ¼ inch, or is no greater than ½ inch and is beveled with a slope no greater than 1:2. Standards §§ 4.13.8, 4.5.2.

2) Exit to concession area: The exit to the concession area is inaccessible because there is a 1 ½ inch change in level at the threshold to the door. Provide an accessible door with a threshold that is no greater than ¼ inch, or is no greater than ½ inch and is beveled with a slope no greater than 1:2. Standards §§ 4.13.8, 4.5.2.

3) Entrance room: The route alongside the counter window is inaccessible because a row of hooks / holders 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.

C. Golf Carts: 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.

D. Drinking Fountain near concession stand The drinking fountain has a spout that is 40 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.

E. Men'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 toilet room, which is accessed through a front approach, is inaccessible because it has only about 42 inches maneuvering space depth. On the push side of the door, provide maneuvering clearance at least 48 inches deep and provide a minimum of 12 inches of maneuvering clearance on the latch side of the door, or remove the closer or the latch. Standards § 4.13.6, Fig. 25(a).

3) 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.

4) The paper towel dispenser is inaccessible because the controls are mounted at 56 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 §§ 4.27.2, 4.27.3, 4.2.4, 4.2.5, 4.2.6.

6) Designated accessible stall:

a) The toilet is inaccessible because there is insufficient clear floor space. Provide clear floor space that complies with Fig. 30 at the toilet. Standards § 4.17.3, Fig. 30.

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.

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.

d) 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.

e) The toilet paper dispenser is inaccessible because it is not mounted below 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 side grab bar at the toilet is inaccessible because the farther end of the side grab bar is not at least 52 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).

g) There is no rear grab bar 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.

F. Women's Toilet Room:

2) The entrance door to the toilet room is inaccessible because it has knob hardware. 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 light switch is inaccessible because the switch is mounted at 58 inches above the finished floor. Provide a light switch with 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.

4) 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.

6) Designated accessible stall:

a) The toilet is inaccessible because there is insufficient clear floor space. Provide clear floor space that complies with Fig. 30 at the toilet. Standards § 4.17.3, Fig. 30.

e) The side grab bar at the toilet is inaccessible because the farther end of the side grab bar is not at least 52 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).

f) There is no rear grab bar 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.

38. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Cherokee Public Library, located at 3300 Sharpe Avenue, Memphis, TN:

A. Parking lot:

1) Although the parking lot has a total of 31 parking spaces, only 1 space is designated as being accessible to people with disabilities, and there is no access aisle nor van-accessible signage. In addition, the parking space surface is not firm, stable, and slip-resistant. On the shortest accessible route to the accessible entrance, provide 1 van accessible space and 1 standard space 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), 4.6, 4.30.7(1).

B. Routes of travel:

1) The route (including the sidewalk and built-up curb ramp) from the parking lot to the building is cracked and not firm or slip-resistant. 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.

2) There is no signage at the parking lot directing persons with disabilities to the accessible route from the parking lot to the entrance. Provide accessible directional signage with the International Symbol of Accessibility directing users to the accessible entrance. Standards §§ 4.1.2(7), 4.30.

3) Rooms do not have accessible permanent signage. Provide permanent room signage with upper case, sans serif or simple serif type letters and numerals, meeting the requirements of the Standards for character height, raised characters, finish and contrast, accompanied by Grade 2 Braille; mounted on the wall adjacent to the latch side of the door or on the nearest adjacent wall at a height of 60 inches above the finished floor to the centerline of the sign; and located so that a person may approach within 3 inches of the signage without encountering protruding objects or standing within the swing of a door. Standards §§ 4.30.1, 4.30.4, 4.30.5, 4.30.6.

C. Drinking fountain by toilet rooms:

1) Although 1 drinking fountain is provided, there is no accessible drinking fountain. 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.

D. Toilet rooms:

1) Men's Toilet Room with Stalls

a) The toilet room signage is not accessible. 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.

b) The inside vestibule door, which is accessed through a front approach and which has both a closer and a latch, is inaccessible because it has less than 12 inches of maneuvering clearance on the latch side. On the push side of the door, provide maneuvering clearance at least 48 inches deep and provide a minimum of 12 inches of maneuvering clearance on the latch side of the door, or remove the closer or the latch. Standards § 4.13.6, Fig. 25(a).

c) The inside vestibule door, which is accessed through a front approach, is inaccessible because it has less than 18 inches of maneuvering clearance on the latch side. On the pull side of the door, provide maneuvering clearance at least 60 inches deep and provide a minimum of 18 inches (24 inches is preferred) of maneuvering clearance on the latch side of the door. Standards § 4.13.6, Fig. 25(a).

d) The doors to the toilet room are inaccessible because they are each 29 inches wide. Provide doors with a clear opening at least 32 inches wide when measured from the face of the door to the opposite stop when the doors are opened 90 degrees and 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 §§ 4.13.5, 4.13.9.

e) The toilet room doors are inaccessible because the pressure required to open the doors is 10 pounds. Provide doors that require no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

f) The entrance to the toilet room is inaccessible because there is less than 48 inches of vestibule space between the two entrance doors. Provide an accessible entrance to the toilet room, such that the space between any two doors in series is at least 48 inches plus the width of any door swinging into the space. Ensure that doors in series swing either in the same direction or away from the space between the doors. Standards § 4.13.7, Fig. 26.

g) 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.

h) 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.

i) The lavatory is inaccessible because the bottom edge of the apron is 26 inches above the finished floor, the hot water pipes are not insulated or otherwise configured to protect against contact, and the faucet has knob hardware. 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; knee and toe clearances that comply with Fig. 31; hot water and drain pipes covered or otherwise configured to protect against contact; clear floor space at least 30 inches wide and 48 inches deep centered on the lavatory; and 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 §§ 4.19.2, 4.19.3, 4.19.4, 4.19.5, 4.27.4, Figs. 31, 32.

j) The toilet is inaccessible because there is insufficient clear floor space. Provide clear floor space that complies with Fig. 30 at the toilet. Standards § 4.17.3, Fig. 30.

k) 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.

l) 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.

m) The side grab bar at the toilet is inaccessible because the farther end of the side grab bar is not at least 52 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).

n) There is no rear grab bar 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.

2) Women's Toilet Room with Stalls

b) The inside vestibule door, which is accessed through a front approach and which has both a closer and a latch, is inaccessible because it has less than 12 inches maneuvering clearance on the latch side. On the push side of the door, provide maneuvering clearance at least 48 inches deep and provide a minimum of 12 inches of maneuvering clearance on the latch side of the door, or remove the closer or the latch. Standards § 4.13.6, Fig. 25(a).

c) The inside vestibule door, which is accessed through a front approach, is inaccessible because it has less than 18 inches maneuvering clearance on the latch side. On the pull side of the door, provide maneuvering clearance at least 60 inches deep and provide a minimum of 18 inches (24 inches is preferred) of maneuvering clearance on the latch side of the door. Standards § 4.13.6, Fig. 25(a).

e) The outer and inner toilet room doors are inaccessible because the pressure required to open the doors is 10 and 15 pounds, respectively. Provide doors that require no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

h) 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.

i) The lavatory is inaccessible because the bottom edge of the apron is 27 inches above the finished floor, the hot water pipes are not insulated or otherwise configured to protect against contact, and the faucet has knob hardware. 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; knee and toe clearances that comply with Fig. 31; hot water and drain pipes covered or otherwise configured to protect against contact; clear floor space at least 30 inches wide and 48 inches deep centered on the lavatory; and 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 §§ 4.19.2, 4.19.3, 4.19.4, 4.19.5, 4.27.4, Figs. 31, 32.

j) The toilet is inaccessible because there is insufficient clear floor space. Provide clear floor space that complies with Fig. 30 at the toilet. Standards § 4.17.3, Fig. 30.

m) The side grab bar at the toilet is inaccessible because the farther end of the side grab bar is 51 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).

3) Library

a) The entrance door 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).

39. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Youth Activities, located at 315 South Hollywood, Memphis, TN:

A. Although the parking lot has a total of approximately 50 parking spaces, none are designated as being accessible. On the shortest accessible route to the accessible entrance, provide 1 van accessible space and 1 standard space 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), 4.6, 4.30.7(1).

B. The building is inaccessible because there is no signage at the front, locked entrance directing persons with disabilities to the accessible, open rear 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.

C. Ramp leading from rear parking lot to rear entrance:

1) The ramp is inaccessible because the lower leg has a slope of 9.0%, and the upper leg has a slope of 8.5%. In addition, there are no handrail extensions, the handrail ends are not rounded or returned smoothly to the floor, wall, or post, the diameter of the handrails or gripping surfaces is greater than 1 ½ inches, and the handrails are not smooth and free of splinters and sharp objects. 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 §§ 4.3.8, 4.8.

D. Drinking fountain on 1^st floor:

2) The drinking fountain protrudes into the circulation path 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 § 4.4.

E. Locker Room:

1) No accessible clothes hook has been provided. Provide a clothes 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.

F. Unisex single-user toilet room:

2) 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.

3) The lavatory is inaccessible because the bottom edge of the apron is about 26 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.

4) 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.

5) No rear grab bar is 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 §§ 4.16.4, 4.26.2, Fig. 29.

6) The toilet paper dispenser is inaccessible because it is mounted above the side grab bar. Provide a toilet paper dispenser that is mounted within reach, with its top at least 1½ inches under the side grab bar, and centered at least 19 inches above the finished floor. Standards § 4.16.6, Fig. 29(b).

7) 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, 4.27.4.

40. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Bethel Labelle Community Center, located at 2698 LaRose Avenue, Memphis, TN:

A. Parking lot: There are ten parking spaces. One is designated as being accessible. No access aisle or van-accessible signage is provided, and pavement markings are not clear.

2) 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. The signage provided throughout the building is inaccessible because they do not have raised and Braille characters. Provide permanent room signage with upper case, sans serif or simple serif type letters and numerals, meeting the requirements of the Standards for character height, raised characters, finish and contrast, accompanied by Grade 2 Braille; mounted on the wall adjacent to the latch side of the door or on the nearest adjacent wall at a height of 60 inches above the finished floor to the centerline of the sign; and located so that a person may approach within 3 inches of the signage without encountering protruding objects or standing within the swing of a door. Standards §§ 4.30.1, 4.30.4, 4.30.5, 4.30.6.

C. Men's and women's toilet rooms with stalls near lobby:

1) The signage for each toilet room is 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.

2) 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.

3) The route through each toilet room is inaccessible because the wall-mounted paper towel dispenser protrudes into the main walkway and would not be detectable to a blind person using a cane. 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.

4) The lavatory in each toilet room is inaccessible because it has twist / knob hardware. 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.

5) 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 § 4.19.4.

6) Men's toilet room only: The urinal is inaccessible because its rim height is higher than 17 inches above the finished floor. 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 accessible toilet stall in each toilet room:

a) The toilet 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 § 4.17.3, Fig. 30.

b) The toilet paper dispenser in each toilet room is inaccessible because it is not mounted under 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) There is no rear grab bar provided in each toilet room. 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.

d) Men'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 §§ 4.16.5, 4.17.2, 4.27.4.

41. Within 12 months of the effective date of this Agreement, the City will complete the following modifications to Humane Shelter, located at 3456 Tchulahoma, Memphis, TN:

A. Parking lot: There are 12 spaces, one of which is designated as being accessible.

B. The main entrance is inaccessible because there is a slope within the door's required maneuvering clearance. The nearby drop-off entrance is 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. The route alongside the adoption counter is inaccessible because the counter protrudes into the main walkway and would not be detectable to a blind person using a cane. Provide circulation path 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.

D. Ramp to animal drop-off entrance door

1) The ramp is inaccessible because the handrails are not on both sides of the ramp, do not have 12 inch extensions at the top and bottom of the ramp, and do not return to a wall, ground or post and are not rounded. 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.

42. It is noted that there are numerous violations of the ADA throughout the Mid-South Coliseum, located at 996 Early Maxwell Boulevard, 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. In addition, the City has represents that it is currently in the process of deciding whether to change the use of this facility. In the event that the City decides to use this facility as a venue for sporting events, within twelve 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.

43. The City represents that it is currently in the process of planning an expansion for the Charles E. Powell Community Center, located at 810 Western Park Drive, Memphis, TN. Within six months of the effective date of this Agreement, or as soon as they are available, 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 replace this facility, within 30 months of the effective date of this Agreement, the City will make the following modifications:

A. Parking: Although the parking lot has a total of approximately 50 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 the appropriate number of standard space(s) designated as reserved for people with disabilities. See chart at Standards § 4.1.2(8). 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. Exterior Entrance: The exterior entrance doors are inaccessible because the hardware used requires tight grasping. Provide a door with hardware that is easy to grasp with one hand and that does not require tight grasping, pinching, or twisting of the wrist to operate. Lever-operated mechanisms, push-type mechanisms, and U-shaped handles are acceptable designs. Standards § 4.13.9.

C. Men's Toilet Room (stalls)

1) The toilet room sign is inaccessible because none has been provided. 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 door to the Men's Toilet Room is inaccessible because the pressure required to open the door is 25 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

3) 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.

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 § 4.19.4.

D. Women's Toilet Room (stalls)

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.

4) The paper towel dispenser is inaccessible because the controls are mounted at more than 54 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 §§ 4.27.2, 4.27.3, 4.2.4, 4.2.5, 4.2.6.

5) The door to the stall is inaccessible because the hardware requires tight grasping to operate. 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.

6) 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 §§ 4.13, 4.16, 4.17, 4.26, 4.27, Fig. 30.

E. Exterior

1) There is no accessible route to the basketball court and the picnic tables. 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.

2) Although a drinking fountain is provided, it is not accessible. 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.

3) The entrance door is inaccessible because knob hardware is used. Provide a door with hardware that is easy to grasp with one hand and that does not require tight grasping, pinching, or twisting of the wrist to operate. Lever-operated mechanisms, push-type mechanisms, and U-shaped handles are acceptable designs. Standards § 4.13.9.

44. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to the Whitehaven Community Center, located at 4318 Graceland Drive, Memphis, TN:

A. Parking

1) Although the parking lot has a total of 42 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 1 standard space 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. North side Men's and Women's Toilet Rooms with Stalls

1) The toilet room signs are 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 doors to the toilet rooms, which are accessed through a front approach, is inaccessible because it has only 7 inches of maneuvering space. On the pull side of the door to each toilet room, provide maneuvering clearance at least 60 inches deep and provide a minimum of 18 inches (24 inches is preferred) of maneuvering clearance on the latch side of the door. Standards § 4.13.6, Fig. 25(a).

3) There is no accessible stall provided in each toilet room. Provide a "standard" accessible toilet stall in each toilet room 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.

C. Drinking Fountains Northeast and Southeast sides

1) The operating controls of the drinking fountains are not mounted near the front of the units. 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.

45. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Whitehaven Tennis Center, located at 4318 Graceland Drive, Memphis, TN:

A. Although the parking lot has a total of 24 parking spaces, no spaces are designated as accessible. On the shortest accessible route to the accessible entrance, provide 1 van accessible space 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), 4.6, 4.30.7(1).

B. Entrance

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

2) The entrance door, which is accessed through a front approach, is inaccessible because it has insufficient pull side maneuvering clearance. On the pull side of the door, provide maneuvering clearance at least 60 inches deep and provide a minimum of 18 inches (24 inches is preferred) of maneuvering clearance on the latch side of the door. Standards § 4.13.6, Fig. 25(a).

C. There is no accessible route throughout the building. 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%). Alternatively, the City may provide services upon request at a centralized, accessible location. Standards §§ 4.3, 4.5, Fig. 7.

D. The main counter is inaccessible because it is mounted 49 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.

E. Men's and Women's toilet rooms near the entrance: The toilet rooms contain a number of inaccessible elements and are not accessible to people with disabilities. Provide an accessible toilet room (or rooms) such that all of the room's elements, including signage, door, door hardware, clear floor space, water closet, stall size and arrangement, stall door, urinal (if provided), grab bars, lavatory, mirror, controls, and dispensers, comply with the Standards. Alternatively, the City may create an accessible unisex toilet room, and provide directional signage at all inaccessible toilet rooms directing persons with disabilities to the nearest accessible toilet room. Standards §§ 4.13, 4.16, 4.17, 4.18, 4.19, 4.26, 4.27, 4.30, Fig. 30.

46. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Goodwill Homes Senior Center, located at 163 W Raines Road, Memphis, TN:

A. Men's Toilet Room (stalls)

1) The toilet room lacks an accessible sign. 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) 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 counter is mounted 35.5 inches high, and lacks adequate knee and toe clearance. 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. Women's Toilet Room (stalls)

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 counter height is 35.5 inches high, and lacks adequate knee and toe clearance. 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 route within the toilet room is inaccessible because the paper towel dispenser is more than 27 inches above the finished floor, extend more than 4 inches into the path of travel, is not cane detectible and is, therefore, a protruding object. Provide a circulation path 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. Parking:

1) Although the parking lot has a total of approximately 100 parking spaces, only three are designated as being standard accessible parking spaces. In addition, these three do not have pavement markings or have access aisles. On the shortest accessible route to the accessible entrance, provide 1 van accessible space and the appropriate number of standard spaces designated as reserved for people with disabilities. See chart at Standards § 4.1.2(8). 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), 4.6, 4.30.7(1).

D. Interior doors throughout the facility: Numerous doors throughout the facility are inaccessible because the knob 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.

E. Hallway drinking fountains

1) The circulation paths near the drinking fountains are inaccessible because the fountains are not detectable to a blind person using a cane. Provide a drinking fountain at each 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.

47. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to South Police Precinct, located at 791 East Raines Road, Memphis, TN:

A. Men's Single-User Toilet Room at Main Lobby

1) The toilet room sign is not accessible. 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 door to the toilet room is inaccessible because it uses knob hardware. 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) 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.

4) The seat cover dispenser is inaccessible because the controls are mounted at 51 inches above the finished floor over the toilet and a forward reach is required. Provide a 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 §§ 4.27.2, 4.27.3, 4.2.4, 4.2.5, 4.2.6.

5) The lavatory is inaccessible because the bottom edge of the lavatory apron is mounted at 28 inches above the finished floor, the hot water pipes are not insulated or otherwise configured to protect against contact, and the faucets require twisting to operate. 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; knee and toe clearances that comply with Fig. 31; hot water and drain pipes covered or otherwise configured to protect against contact; clear floor space at least 30 inches wide and 48 inches deep centered on the lavatory; and 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 §§ 4.19.2, 4.19.3, 4.19.4, 4.19.5, 4.27.4, Figs. 31, 32.

6) The toilet is inaccessible because the top of the seat is 16 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, Fig. 29(b).

7) The toilet is inaccessible because its centerline measures 23 inches from the side wall. Provide a toilet with a centerline that measures 18 inches from the near side wall. Standards § 4.16.2, Fig. 28.

8) No rear grab bar is 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 §§ 4.16.4, 4.26.2, Fig. 29.

B. Women's Single-User Toilet Room at Main Lobby

2) The door to the toilet room is inaccessible because knob hardware is used. 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 lavatory is inaccessible because the bottom edge of the lavatory apron is mounted at 28 inches above the finished floor, the hot water pipes are not insulated or otherwise configured to protect against contact, and the faucets require twisting to operate. 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; knee and toe clearances that comply with Fig. 31; hot water and drain pipes covered or otherwise configured to protect against contact; clear floor space at least 30 inches wide and 48 inches deep centered on the lavatory; and 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 §§ 4.19.2, 4.19.3, 4.19.4, 4.19.5, 4.27.4, Figs. 31, 32.

4) The toilet is inaccessible because the top of the seat is 16 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, Fig. 29(b).

5) The toilet is inaccessible because its centerline measures 23 inches from the side wall. Provide a toilet with a centerline that measures 18 inches from the near side wall. Standards § 4.16.2, Fig. 28.

6) No rear grab bar is 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 §§ 4.16.4, 4.26.2, Fig. 29.

C. Drinking Fountain

1) The circulation path 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.

48. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Pine Hill Golf Course and Community Center, located at 973 Alice Avenue, Memphis, TN:

A. Parking

1) Although the parking lot has a total of approximately 75 parking spaces, there are no spaces designated as being accessible to persons with disabilities. On the shortest accessible route to the accessible entrance, provide 1 van accessible space and the appropriate number of standard spaces designated as reserved for people with disabilities. See chart at Standards § 4.1.2(8). 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), 4.6, 4.30.7(1).

B. Golf Course:

1) Accessible Route (from Parking to Pro Shop / Clubhouse)

a) The front entrance into the Pro Shop is inaccessible, and there is no directional signage directing people with disabilities to the 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 route from the parking area to the rear (accessible) entrance of the Pro Shop / Clubhouse is inaccessible because the ground is not firm, stable, and slip resistant, and is not level. In addition, the accessible (rear) entrance has two steps in front of it. 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.

c) The rear entrance is inaccessible because there is an excessive slope within the door's required maneuvering clearance. Provide a door so that the floor or ground area within the required clearances is level and clear. Standards § 4.13.6, Fig. 25.

2) Golf Carts: 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.

3) Drinking Fountain at the clubhouse: the drinking fountain has a spout that is more than 36 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.

4) The concession counter at the golf course is inaccessible because its surface is mounted 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.

5) Men's Locker Room (Clubhouse)

a) 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.

b) The toilet room contains a number of inaccessible elements and is not accessible to people with disabilities. 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.

c) The shower is inaccessible. Provide a shower in this 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.

d) The Men's Locker Room is inaccessible. Provide at least one accessible locker room in this area on an accessible route with accessible signage indicating its location. Ensure that accessible locker rooms fitted with swinging or sliding doors contain sufficient clear floor space to allow a person using a wheelchair to make a 180-degree turn inside the room and that no door swings into any part of the turning space. Ensure that private accessible locker rooms fitted with curtained openings at least 32 inches wide contain either a clear space of 60 inches in diameter, or a "T" shaped turning space that complies with Fig. 3(b). Provide a bench 24 inches by 48 inches fixed to the wall along the longer dimension and mounted between 17 and 19 inches above the finished floor to the top of the bench. If mirrors are provided in dressing rooms of the same use, provide one full-length mirror, measuring at least 18 inches wide by 54 inches high, mounted in a position affording a view to a person on the bench as well as to a person in a standing position. Standards §§ 4.35, 4.30, 4.26.3, 4.2, 4.3, Fig. 3.

6) Women's Locker Room (Clubhouse)

b) The door to the toilet room, which is accessed from the latch side of the door, is inaccessible because it has insufficient maneuvering space at the pull side / latch side and the depth on the push side. 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).

c) The toilet room contains a number of inaccessible elements and is not accessible to people with disabilities. Provide an accessible toilet room such that all of the room's elements, including signage, door, door hardware, clear floor space, water closet, stall size and arrangement, stall door, urinal (if provided), grab bars, lavatory, mirror, controls, and dispensers, comply with the Standards. Standards §§ 4.13, 4.16, 4.17, 4.18, 4.19, 4.26, 4.27, 4.30, Fig. 30.

d) The shower is inaccessible. Provide a shower in this 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.

e) The locker room is not accessible. Provide at least one accessible locker room in this area on an accessible route with accessible signage indicating its location. Ensure that accessible locker rooms fitted with swinging or sliding doors contain sufficient clear floor space to allow a person using a wheelchair to make a 180-degree turn inside the room and that no door swings into any part of the turning space. Ensure that private accessible locker rooms fitted with curtained openings at least 32 inches wide contain either a clear space of 60 inches in diameter, or a "T" shaped turning space that complies with Fig. 3(b). Provide a bench 24 inches by 48 inches fixed to the wall along the longer dimension and mounted between 17 and 19 inches above the finished floor to the top of the bench. If mirrors are provided in dressing rooms of the same use, provide one full-length mirror, measuring at least 18 inches wide by 54 inches high, mounted in a position affording a view to a person on the bench as well as to a person in a standing position. Standards §§ 4.35, 4.30, 4.26.3, 4.2, 4.3, Fig. 3.

C. Community Center:

1) Drinking Fountains

a) Basketball Court

(1) The circulation path near the drinking fountain at the basketball court 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.

b) Community Center

(1) The circulation path near the drinking fountain at the community center 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) Women's Toilet at the Community Center

a) The toilet room sign at the community center is not accessible because it is not centered at 60 inches high. 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) 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.

c) The circulation path 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, or provide a cane-detectable barrier to alert blind people to this feature. Standards § 4.4.

d) 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).

e) 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) Men's Toilet at the Community Center

a) 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.

b) The paper towel dispenser is inaccessible because the controls are mounted at too high 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 §§ 4.27.2, 4.27.3, 4.2.4, 4.2.5, 4.2.6.

c) 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).

d) The designated accessible toilet stall is inaccessible because the stall door swings into the toilet's required clear floor space. 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.

49. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Skinner Handicap Center, located at 712 Tanglewood Street, Memphis, TN:

A. Parking

B. East entrance

1) The east entrance is inaccessible because there is no level landing within the door's required maneuvering clearance. 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. Interior Ramps

1) The interior ramp (with a stone wall on one side) is inaccessible because handrails have been provided on only one side of the ramp, and are mounted at 33 inches high with no extensions at the bottom 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 § 4.8.5.

2) The interior ramp (with a brick wall on one side) is inaccessible because the handrails have only one extension at the top of the ramp and none at the bottom, are mounted 33 inches high, and have at least one end that is not smooth or rounded. 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.

D. Women's Toilet Room on the central corridor (single-user)

1) The toilet room sign is not centered at 60 inches. 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 door to the toilet room is inaccessible because the thumb latch / deadbolt requires twisting and tight grasping. 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) 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.

4) The lavatory is inaccessible because the apron is mounted at 28 inches above the finished floor, the hot water pipes are not insulated or otherwise configured to protect against contact, and the faucets require twisting to operate. 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; knee and toe clearances that comply with Fig. 31; hot water and drain pipes covered or otherwise configured to protect against contact; clear floor space at least 30 inches wide and 48 inches deep centered on the lavatory; and 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 §§ 4.19.2, 4.19.3, 4.19.4, 4.19.5, 4.27.4, Figs. 31, 32.

5) The toilet is inaccessible because there is insufficient clear floor space in front of the toilet. Provide clear floor space at the toilet that complies with Fig. 28. Standards § 4.16.2, Fig. 28.

8) The 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, 4.27.4.

9) The side grab bar at the toilet is inaccessible because it is 24 inches long, mounted at 30 inches above the finished floor, has a diameter of 1 inch, and has a 2 ½ inch space between the grab bar and the wall. Provide a side grab bar that is at least 42 inches in overall length, with the far end mounted at least 54 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 §§ 4.16.4, 4.26.2, Fig. 29.

10) 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 §§ 4.16.4, 4.26.2, Fig. 29.

11) Shower stall

a) The shower in the toilet room is inaccessible because it is 36 by 44 inches, and there is no transfer seat or grab bars provided. Provide a shower in this 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.

b) The circulation path within the toilet room to the shower stall is inaccessible because the shelf 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, or provide a cane-detectable barrier to alert blind people to this feature. Standards § 4.4.

E. Men's Toilet Room on the central corridor (single-user)

2) The door to the toilet room is inaccessible because the thumb latch / deadbolt hardware requires twisting and tight grasping to operate. 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) 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.

5) The toilet is inaccessible because there is insufficient clear floor space at the toilet. Provide clear floor space at the toilet that complies with Fig. 28. Standards § 4.16.2, Fig. 28.

8) The side grab bar at the toilet is inaccessible because it is 24 inches long, mounted at 30 inches above the finished floor, has a diameter of 1 inch, and has a 2 ½ inch space between the grab bar and the wall. Provide a side grab bar that is at least 42 inches in overall length, with the far end mounted at least 54 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 §§ 4.16.4, 4.26.2, Fig. 29.

9) 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 §§ 4.16.4, 4.26.2, Fig. 29.

10) Shower stall

b) The circulation path within the toilet room is inaccessible because the shelf 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, or provide a cane-detectable barrier to alert blind people to this feature. Standards § 4.4.

F. Women's Toilet Room near East entrance (stalls)

1) The toilet room sign is not centered at 60 inches, and is not located on the latch side of 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 door to the toilet room is inaccessible because the pressure required to open the door is 9 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards § 4.13.11(2)(b).

3) 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.

G. Men's Toilet Room near East entrance (stalls)

1) The toilet room sign is not centered at 60 inches and is not located on the latch side of 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 door to the 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).

3) 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.

4) The route within the toilet room is inaccessible because the lavatory and the hand dryer 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 § 4.4.

H. Women's toilet room near art studio (stalls)

2) The toilet room door 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 apron is mounted 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.

I. Men's toilet room near art studio (stalls)

3) 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.

4) Designated accessible standard toilet stall:

a) 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.

b) The toilet paper dispenser is inaccessible because it is mounted 44 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).

c) The rear grab bar at the toilet is inaccessible because the air freshener interferes with its use. Provide a rear grab bar that has 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. 39.

d) No accessible clothes hook has been provided in the locker room. Provide a clothes 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.

J. Women's locker room

1) The door to the 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 rim is 36 inches high, with knee and toe clearance of 7 inches. 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 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 §§ 4.13, 4.16, 4.17, 4.26, 4.27, Fig. 30.

4) Shower

a) The shower is inaccessible. Provide a shower in this 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..

5) Three dressing rooms; zero accessible dressing rooms

a) None of the dressing rooms is accessible because there is insufficient clear floor space, there are no benches or signage, and the clothes hooks are mounted too high. Provide at least one accessible dressing room in this area on an accessible route with accessible signage indicating its location. Ensure that accessible dressing rooms fitted with swinging or sliding doors contain sufficient clear floor space to allow a person using a wheelchair to make a 180-degree turn inside the room and that no door swings into any part of the turning space. Ensure that private accessible dressing rooms fitted with curtained openings at least 32 inches wide contain either a clear space of 60 inches in diameter, or a "T" shaped turning space that complies with Fig. 3(b). Provide a bench 24 inches by 48 inches fixed to the wall along the longer dimension and mounted between 17 and 19 inches above the finished floor to the top of the bench. If mirrors are provided in dressing rooms of the same use, provide one full-length mirror, measuring at least 18 inches wide by 54 inches high, mounted in a position affording a view to a person on the bench as well as to a person in a standing position. Standards §§ 4.35, 4.30, 4.26.3, 4.2, 4.3, Fig. 3.

K. Men's locker room

1) The men's locker room door is inaccessible because the pressure required to open the door is 18 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 bottom edge is 27 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) Shower

5) Several dressing rooms; zero accessible dressing rooms

L. Drinking fountains

1) East entrance: Although a drinking fountain is provided, there is no accessible drinking fountain because the water height is less than 4 inches, and there is no access for people who have difficulty bending or stooping. 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.

2) Multi-purpose room: The spout height is higher than 36 inches. 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.

3) Playground: Although 2 drinking fountains are provided, there is no accessible drinking fountain because the water height is less than 4 inches, and it does not reach within 3 inches of the front. 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.

50. Within 24 months of the effective date of this Agreement, the City will complete the following modifications to Memphis Senior Citizen Center, located at 1620 Marjorie Street, Memphis, TN:

A. The Counter at the Main Entrance is inaccessible because it is mounted 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.

B. Men's Toilet Room on west wing (stalls)

3) The lavatory is inaccessible because it has a twist faucet. Provide a lavatory 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.

4) 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.

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.

C. Women's Toilet Room on west wing (stalls)

4) 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.