DEPARTMENT OF JUSTICE COMPLAINT NUMBER 204-3-12
Settlement Agreement | Department of Justice Press Releases
BACKGROUND
A. SCOPE OF THE INVESTIGATION
This matter was initiated by a complaint filed under title II of the Americans with Disabilities Act of 1990 ("ADA"), 42 U.S.C. §§ 12131-12134, with the United States Department of Justice ("Department") against the City of Robertsdale, Alabama ("City"). The complaint was received by the Civil Rights Division of the Department of Justice, under the authority of 28 C.F.R. Part 35, Subpart F. The complainant alleges that the programs provided by the City in the City Hall Building are not accessible to individuals with disabilities.
Because the City receives financial assistance from the Department of Justice, the investigation was also conducted under the authority of § 504 of the Rehabilitation Act of 1973, 29 U.S.C. § 794, and the Department's implementing regulation, 28 C.F.R. Part 42, Subpart G.
The Department expanded the scope of the investigation to include the City's compliance with the following title II requirements:
- to conduct a self-evaluation of its services, policies, and practices, including those in the area of employment, by July 26, 1992, and make modifications necessary to comply with the Department's title II regulations (28 C.F.R. Part 35), 28 C.F.R. § 35.105;
- to notify applicants, participants, beneficiaries, and other interested persons of their rights and the City's obligations under title II and the Department's regulations, 28 C.F.R. § 35.106;
- to designate a responsible employee to coordinate its efforts to comply and carry out the City's ADA responsibilities, 28 C.F.R. § 35.107(a);
- to establish a grievance procedure for resolving complaints of violations of title II, 28 C.F.R. § 35.107(b);
- to operate each program, service, or activity so that, when viewed in its entirety, it is readily accessible to and usable by individuals with disabilities, 28 C.F.R. § 35.150, by:
- delivery of services, programs, or activities in alternate ways, including, for example, redesign of equipment, reassignment of services, assignment of aides, home visits, or other methods of compliance or, if these methods are not effective in making the programs accessible;
- physical changes to buildings (required to be made by January 26, 1995), in accordance with the Department's title II regulation, 28 C.F.R. § 35.151, and the ADA Standards for Accessible Design ("Standards") or the Uniform Federal Accessibility Standards ("UFAS");
- to ensure that facilities for which construction or alteration was begun after January 26, 1992, are readily accessible to and usable by people with disabilities, in accordance with 1) the Department's title II regulation and 2) the Standards or UFAS, 28 C.F.R. § 35.151;
- to ensure that communications with applicants, participants, and members of the public with disabilities are as effective as communications with others, including furnishing auxiliary aids and services when necessary, 28 C.F.R. § 35.160;
- where the City communicates by telephone, to communicate through a teletypewriter ("TTY"), or other equally effective telecommunications system, with individuals who have hearing or speech impairments, 28 C.F.R. § 35.161;
- to provide information for interested persons with disabilities concerning the existence and location of the City's accessible services, activities, and facilities, 28 C.F.R. § 35.163(a);
- to provide signs at all inaccessible entrances to each of its facilities, directing users to an accessible entrance or to information about accessible facilities, 28 C.F.R. § 35.163(b).
The Department limited its program access review to those of the City's programs, services, and activities that operate in the following facilities: the Post Office, Day Care Center, Library, Walking Trail, City Hall, City Council Chambers and Municipal Court, Police Department, Senior Citizens Center, Utilities Building, Garrett Park, Park Avenue Baseball and Soccer Field, Municipal Pool, PZK Civic Center, and Fire Station. Of those facilities, the Post Office, Day Care Center, Library, and Walking Trail constitute construction commenced after January 26, 1992. The following facilities were altered after January 26, 1992: PZK Civic Center and the Park Avenue Baseball and Soccer Field.
B. JURISDICTION
1. The ADA applies to the City because it is a "public entity" as defined by title II. 42 U.S.C. § 12131(1).
2. The Department is authorized under 28 C.F.R. Part 35, Subpart F, to investigate the complaint in this matter to determine the compliance of the City with title II of the ADA and the Department's implementing title II regulation, to issue findings and, where appropriate, to negotiate and secure a voluntary compliance agreement. Furthermore, the Attorney General is authorized, under 42 U.S.C. § 12133, to bring a civil action enforcing title II of the ADA should the Department fail to secure voluntary compliance.
3. The Department is authorized under 28 C.F.R. Part 42, Subpart G, to investigate the complaint in this matter to determine the City's compliance with § 504 of the Rehabilitation Act of 1973, to issue findings, and, where appropriate to negotiate and secure voluntary compliance agreements. Furthermore, the Attorney General is authorized, under 29 U.S.C. § 794 and 28 C.F.R. §§ 42.530, 42.108-110, to suspend or terminate federal financial assistance authorized by the Department of Justice to the City should the Department fail to secure voluntary compliance pursuant to Subpart G or to bring a civil suit to enforce the rights of the United States under applicable federal, state, or local law.
C. ACTIONS TAKEN BY THE CITY
4. The City has amended its employment application to comply with title I of the ADA.
5. The City has adopted an ADA grievance procedure included within the City of Robertsdale Personnel Policy manual, revised in 1998. The procedure provides for appeals to be made to the municipal governing body for a hearing before a grievance committee.
6. The City has recently constructed a walking trail and U.S. Post Office building.
The parties to this Agreement are the United States of America and the City of Robertsdale, Alabama. In order to avoid the burdens and expenses of an investigation and possible litigation, the parties hereby agree as follows:
REMEDIAL ACTION
7. In consideration of, and consistent with, the terms of this Agreement as set forth below, the Attorney General agrees to refrain from filing a civil suit in this matter regarding the areas covered in Paragraphs 9 through 27 of this Agreement, except as provided in Paragraphs 31 and 34, below.
8. The Parties agree that the technical requirements and, where appropriate, the scoping requirements of the Standards are used as a guide for determining whether a program or activity held in an existing facility is "readily accessible to and usable by" persons with disabilities, and for determining what changes are necessary to make this program or activity accessible if it continues to be provided in the existing facility in question. See 28 C.F.R. §§ 35.150(b)(1), 35.151. The Standards appear at 28 C.F.R. Part 36, Appendix A.
9. Within 30 days of the effective date of this Agreement, the City will designate an employee to serve as its ADA Coordinator, to coordinate its efforts to comply with and carry out its responsibilities under title II of the ADA. The name, office address, and telephone number of the ADA coordinator will be made available to all interested persons.
10. The City will submit architectural plans for the new City Jail /Police Department facility as well as the finalized plans for the future expansion and renovation of the Garrett Park baseball facility to the Department for its review prior to the commencement of construction.
11. Within 90 days of the effective date of this Agreement, the City will distribute the attached Notice (Attachment A) to all agency heads and post copies in conspicuous locations in its public buildings. It will refresh the posted copies, and update the contact information contained on the Notice, as necessary, for the life of the Agreement. Copies will also be provided to any person upon request.
A. CITY COMMUNICATIONS
12. Within 90 days of the effective date and for the life of this Agreement, the City will publicize its TTY number on the same basis as its voice telephone numbers, through such means as official stationary, business cards, civic newsletters, and the public telephone book.
13. The City will take steps to ensure that all appropriate employees are trained and practiced in using a TTY to make and receive calls, as appropriate, and that any TTY's are maintained in good working order through test calls every six months for the life of this Agreement.
14. The City will report to the Department the actions it has taken to implement these provisions within 120 days of the effective date of this Agreement.
B. SIGNAGE AT ENTRANCES
15. Within six months of the effective date of this Agreement, the City will survey the facilities that are the subject of this Agreement for the purpose of identifying those that have multiple entrances not all of which are accessible, and will install signage as necessary in compliance with 28 C.F.R. § 35.163(b). §§ 4.1.2(7)(c), 4.30.7.
C. PHYSICAL MODIFICATIONS
In order to ensure that the following facilities, for which construction commenced after January 26, 1992, are readily accessible to and usable by individuals with disabilities, the City will take the following actions.
16. The City shall complete the following modifications to the Day Care Center within six months of the effective date of this Agreement:
a. There are no designated accessible parking spaces provided. Establish designated accessible parking spaces, including at least one van-accessible space, that are in compliance with the Standards and are located on the shortest accessible route to the accessible entrance of the building. §§ 4.1.2(5), 4.6.
b. There is a 1¼ inch change in level at the threshold of the front entrance. Alter the threshold so that there is a change in level no greater than ½ inch and beveled with a slope no greater than 1:2, or install a ramp with a slope no greater than 1:12 that ends in a level landing at least 60 inches long and wide enough to provide the required level maneuvering clearance for the door. §§ 4.1.3(7)(a), 4.13.8, 4.5.2, 4.8.
c. The doors have knob hardware throughout the interior of the building. Replace the knobs with hardware that is easy to grasp with one hand and does not require tight grasping, pinching, or twisting of the wrist to operate. §§ 4.1.3(7), 4.13.9.
d. The hot water and drain pipes beneath the lavatories in some of the classrooms are not insulated or configured to protect against contact. Insulate the hot water and drain pipes consistent with the Standards. §§ 4.1.3(11), 4.22.6, 4.19.4.
e. Classroom Toilet Rooms
(1) The toilets intrude on the 18 inch wide by 60 inch deep maneuvering clearance required at the door and the toilet rooms do not provide the 48 inch wide by 56 inch deep clear floor space required at the toilet. Reconfigure the toilet rooms so that the maneuvering clearance and clear floor space requirements are met. §§ 4.1.3(7)(11), 4.13.6, and Fig. 25, 4.22.2, 4.22.3, 4.22.4, 4.16.2, and Fig. 28.
(2) There no rear or side grab bars located at the toilets as required by the Standards §§ 4.1.3(11) and 4.22.4. For guidance regarding suggested heights for children's facilities, see American with Disabilities Act Accessibility Guidelines for Buildings and Facilities; Building Elements Designed for Children's Use, 4.16.7(3).
(3) The centerlines of the toilets are located 21 to 22 inches from the side wall. Re-mount the toilets so that the centerlines are an appropriate distance from the side wall for use by children. §§4.1.3(11), 4.22.4. For guidance regarding suggested measurements for children's facilities, see American with Disabilities Act Accessibility Guidelines for Buildings and Facilities; Building Elements Designed for Children's Use, § 4.16.7(1).
f. Unisex Bathroom
(1) The farthest end of the side grab bar at the toilet extends 51 inches from the rear wall. Reposition or replace the grab bar so that the end nearest the back wall begins no more than 12 inches from the wall, it is at least 42 inches long, and its end farthest from the back wall is located at least 54 inches from the wall. §§ 4.1.3(11), 4.23.1, 4.23.4, 4.22.4, 4.16.4 & Fig. 29(b).
(2) The length of the rear grab bar is 32 1/4 inches. Provide a rear grab bar that is at least 36 inches long with the end closer to the side wall no more than 6 inches from the side wall. §§ 4.1.3(11), 4.23.1, 4.16.4 & Fig.29(a).
(3) The centerline of the toilet is located 14 inches from the side wall. Re-mount the toilet so that the centerline is exactly 18 inches from the side wall. §§ 4.1.3(11), 4.22.4, 4.16.2 & Fig. 28.
(4) The bathtub does not have an in-tub seat or a seat at the head end of the tub; no grab bars are provided at the tub; the controls require tight grasping, pinching, or twisting of the wrist to operate; and a shower spray unit with a hose is not provided. Replace or modify the tub and hardware so that the seat, grab bar, controls, and shower unit requirements of the Standards are met. §§ 4.1.3(11), 4.23.1, 4.20.1, 4.20.3, 4.20.4, 4.20.5, 4.20.6, & Fig.s 33 & 34, 4.26, 4.27.4.
g. There is a 11/2 inch change in level at the threshold on the outside of the doorway opening onto the playground. Alter the threshold so that there is a change in level no greater than 1/2 inch and beveled with a slope no greater than 1:2, or install a ramp with a slope no greater than 1:12 that ends in a level landing at least 60 inches long and wide enough to provide the required level maneuvering clearance for the door. §§ 4.1.3(7)(a), 4.13.8, 4.5.2, 4.8.
h. There is a 1 inch change in level at the threshold to side entrance door from the public parking lot. Alter the threshold so that there is a change in level no greater than 1/2 inch and beveled with a slope no greater than 1:2, or install a ramp with a slope no greater than 1:12 that ends in a level landing at least 60 inches long and wide enough to provide the required level maneuvering clearance for the door. §§ 4.1.3(7)(a), 4.13.8, 4.5.2, 4.8.
i. There is a 1 1/2 inch change in level at the threshold on the interior of the doorway to the teachers parking lot and a 2 inch change in level at the exterior of the doorway. Alter this threshold so that there is a change in level no greater than 1/2 inch and beveled with a slope no greater than 1:2, or install a ramp with a slope no greater than 1:12 that ends in a level landing at least 60 inches long and wide enough to provide the required level maneuvering clearance for the door. §§ 4.1.3(7)(a), 4.13.8, 4.5.2, 4.8.
17. The City shall complete the following modifications to the Library within one year of the effective date of this Agreement:
a. There are two designated accessible parking spaces that share one reserved parking sign, the access aisle are not demarcated, and neither space is designated van-accessible. Re-stripe the spaces to provide 96 inch wide parking spaces and at least one van-accessible parking space served by an access aisle at least 96 inches wide, and install an additional "van-accessible" sign mounted below the symbol of accessibility in a location that cannot be obscured by a vehicle parked in the space. Raise the signage on the remaining space so that it also cannot be obscured by a vehicle parked in the space. §§ 4.1.2(5), 4.6.3 & Fig. 9, 4.6.4.
b. The designated accessible computer counter that provides access to the electronic card catalog has a top surface that is 26 inches from the surface of the floor, and a person using a wheelchair must hold the keyboard in his or her lap to access it. This is not required of persons who do not use wheelchairs. Raise the computer counter so that the top surface is between 28 and 34 inches above the surface of the floor and there is a knee space at least 27 inches high, 30 inches wide, and 19 inches deep. Provide access to the keyboard that is equivalent to the access provided to persons who do not use wheelchairs. §§ 4.1.3(18), 4.32.
c. Men's Toilet Room
(1) The alcove in which the urinal is located is 23 1/2 inches wide and greater than 24 inches deep. Provide a clear floor space of at least 36 inches by 48 inches in front of the urinal. §§ 4.1.3(11), 4.18.3, 4.2.4.2 & Fig. 4(e).
(2) The toilet stall is 41 1/2 inches wide and 69 1/2 inches deep, there are no grab bars in the stall, the toilet paper dispenser is 42 inches from the back wall, and the centerline of the toilet is 21 inches from the side wall. Provide a "standard" accessible toilet stall, which is at least 60 inches wide and 59 inches deep (at least 56 inches if the water closet is wall mounted) 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. §§ 4.13, 4.16, 4.17 & Fig. 30(a), 4.22.4, 4.22.7, 4.26, 4.27.
(3) The lavatory has twist-type faucets. Replace the faucet hardware with hardware that does not require tight pinching, grasping or twisting of the wrist to operate. §§ 4.1.3(11), 4.22.6, 4.19.5, 4.27.4.
(4) The lavatory is mounted in a vanity that does not conform to the Standards. Provide a lavatory with a clear floor space of 30 by 48 inches and knee and toe clearances to allow a front approach. §§ 4.1.3(11), 4.22.6, 4.19.1, 4.19.2, 4.19.3, 4.19.4.
(5) The coat hook in the toilet stall is located 68 inches above the floor. Provide a hook that is no more than 54 inches above the finish floor for a side reach or, if that is not available, 48 inches above the finish floor for a forward reach. §§ 4.1.3(12)(a), 4.25.3, 4.2.5, 4.2.6.
(6) The room designation sign is mounted on the entrance door and does not otherwise comply with the Standards. Provide a sign, using raised letters and Braille, on the wall adjacent to the latch side of the door so that the centerline of the sign is 60 inches above the finish floor and a person can approach within 3 inches of signage without encountering protruding objects or standing within the swing of a door. §§ 4.1.3(16)(a), 4.30.1, 4.30.4, 4.30.5, 4.30.6.
d. Women's Toilet Room
(1) The toilet stall is 40 1/2 inches wide and 69 1/2 inches deep, there are no grab bars in the stall, the toilet paper dispenser is 39 inches from the back wall and 28 inches above the surface of the floor, and the centerline of the toilet is 19 1/2 inches from the side wall. Provide a "standard" accessible toilet stall, which is at least 60 inches wide and 59 inches deep (at least 56 inches if the water closet is wall mounted) 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. §§ 4.13, 4.16, 4.17 & Fig. 30(a), 4.22.4, 4.22.7, 4.26, 4.27.
(2) The lavatory has twist-type faucets. Replace the faucet hardware with hardware that does not require tight pinching, grasping or twisting of the wrist to operate. §§ 4.1.3(11), 4.22.6, 4.19.5, 4.27.4.
(3) The lavatory is mounted in a vanity that does not conform to the Standards. Provide a lavatory with a clear floor space of 30 by 48 inches and knee and toe clearances to allow a front approach. §§ 4.1.3(11), 4.22.6, 4.19.1, 4.19.2, 4.19.3, 4.19.4.
(4) The coat hook in the toilet stall is located 68 inches above the floor. Provide a hook that is no more than 54 inches above the finish floor for a side reach or, if that is not available, 48 inches above the finish floor for a forward reach. §§ 4.1.3(12)(a), 4.25.3, 4.2.5, 4.2.6.
(5) The room designation sign is mounted on the entrance door and does not otherwise comply with the Standards. Provide a sign, using raised letters and Braille, on the wall adjacent to the latch side of the door so that the centerline of the sign is 60 inches above the finish floor and a person can approach within 3 inches of signage without encountering protruding objects or standing within the swing of a door. §§ 4.1.3(16)(a), 4.30.1, 4.30.4, 4.30.5, 4.30.6.
In order to ensure that the following spaces in City facilities, for which alterations commenced after January 26, 1992, are readily accessible to and usable by individuals with disabilities, the City will take the following actions.
18. The City shall complete the following modifications to the PZK Civic Center within six months of the effective date of this Agreement:
a. The front entrance ramp has no edge protection. Install edge protection along the outside edges of the front entrance ramp that complies with the Standards. §§ 4.1.2(1), 4.3.7, 4.8.7 & Fig. 17.
b. There is a 1 inch change in level at the threshold of the rear entrance door. Alter the threshold so that it is no greater than ½ inch and is beveled with a slope no greater than 1:2. §§ 4.1.3(7)(a), 4.13.8, 4.5.2, 4.8.
c. Women's Toilet Room
(1) The designated accessible toilet stall is 68 1/2 inches by 48 inches. Provide a "standard" accessible toilet stall, which is at least 60 inches wide and 59 inches deep (at least 56 inches if the water closet is wall mounted) 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. §§ 4.13, 4.16, 4.17 & Fig. 30(a), 4.22.4, 4.22.7, 4.26, 4.27.
(2) The lavatories have twist-type faucets. Replace at least one set of faucet hardware with hardware that does not require tight pinching, grasping or twisting of the wrist to operate. §§ 4.1.3(11), 4.22.6, 4.19.5, 4.27.4.
(3) The hot water and drain pipes beneath the lavatories are not insulated or configured to protect against contact. Insulate the hot water and drain pipes consistent with the Standards. §§ 4.1.3(11), 4.22.6, 4.19.4.
(4) The toilet room does not have the required signage. Provide a sign, using raised letters and Braille, on the wall adjacent to the latch side of the door so that the centerline of the sign is 60 inches above the finish floor and a person can approach within 3 inches of signage without encountering protruding objects or standing within the swing of a door. §§ 4.1.3(16)(a), 4.30.1, 4.30.4, 4.30.5, 4.30.6.
d. Men's Toilet Room
(1) The rim of the urinal in the men's room is 24 inches above the finish floor. Provide a urinal that has an elongated rim not more than 17 inches above the floor. §§ 4.1.3(11), 4.22.5, 4.18.2
(2) The lavatories have twist-type faucets. Replace at least one faucet with hardware with controls that can be operated with one hand and do not require tight grasping, pinching, or twisting of the wrists to operate. §§ 4.1.3(11), 4.19.5, 4.22.6, 4.27.4.
(3) The designated accessible toilet stall is 68 1/2 inches by 48 inches. Provide a "standard" accessible toilet stall, which is at least 60 inches wide and 59 inches deep (at least 56 inches if the water closet is wall mounted) 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. §§ 4.13, 4.16, 4.17 & Fig. 30(a), 4.22.4, 4.22.7, 4.26, 4.27.
(4) The toilet room does not have compliant signage. Provide a sign, using raised letters and Braille, on the wall adjacent to the latch side of the door so that the centerline of the sign is 60 inches above the finish floor and a person can approach within 3 inches of signage without encountering protruding objects or standing within the swing of a door. §§ 4.1.3(16)(a), 4.30.1, 4.30.4, 4.30.5, 4.30.6.
e. There are steps leading to the stage making it inaccessible to persons using a wheelchair. Establish a procedure for providing access to the stage or install a ramp or platform lift in compliance with the Standards. §§ 4.33.5, 4.3.8, 4.8, 4.11. Any procedure shall not require lifting or carrying persons with mobility impairments or require them to traverse unnecessary or extreme distances, and the procedure must be submitted to the Department for review prior to implementation.
19. The City shall complete the following modifications to the Park Avenue Baseball and Soccer Field or shall submit building plans for a new facility to the Department within six months of the effective date of this Agreement:
a. Women's Toilet Room
(1) The designated accessible toilet stall is 88 inches by 45 1/2 inches, the door swings into the stall, and there are no grab bars in the stall. Provide at least one "standard" accessible toilet stall at least 60 inches wide and 59 inches deep (at least 56 if the water closet is wall mounted) such that all of the stall's elements, including the toilet, size and arrangement, toe clearances, doors and hardware, grab bars, and dispensers and controls, comply with the Standards. §§ 4.1.3(11), 4.22.4, 4.13, 4.16, 4.17, Figure 30, 4.26, 4.27.
(2) The toilet room identification sign is mounted in the wrong location and does not have raised letters or Braille. Provide a sign, using raised letters and Braille, on the wall adjacent to the latch side of the door so that the centerline of the sign is 60 inches above the finish floor and a person can approach within 3 inches of signage without encountering protruding objects or standing within the swing of a door. §§ 4.1.3(16)(a), 4.30.1, 4.30.4, 4.30.5, 4.30.6.
b. Men's Toilet Room
(1) The route into the toilet room is 34 inches wide. Provide an accessible route into the toilet room that is at least 36 inches wide. §§ 4.1.2(2), 4.3.3 & Fig. 7(b).
(2) The designated accessible toilet stall is 88 inches by 47 inches, the door swings into the stall, and there are no grab bars in the stall. Provide a toilet stall that is at least 60 inches wide and 59 inches deep (at least 56 inches if the water closet is wall mounted.) such that all of the stall's elements, including the toilet, size and arrangement, toe clearances, doors and hardware, grab bars, and dispensers and controls, comply with the Standards. §§ 4.1.3(11), 4.22.4, 4.13, 4.16, 4.17, Figure 30, 4.26, 4.27.
(3) Partitions intrude into the clear floor space in front of the urinal so that it is 25 1/2 inches wide. Provide a clear floor space of at least 30 inches by 48 inches in front of the urinal. §§ 4.1.3(11), 4.18.3, 4.2.4.2 & Fig. 4(d).
(4) The toilet room does not have the required signage. Provide a sign, using raised letters and Braille, on the wall adjacent to the latch side of the door so that the centerline of the sign is 60 inches above the finish floor and a person can approach within 3 inches of signage without encountering protruding objects or standing within the swing of a door. §§ 4.1.3(16)(a), 4.30.1, 4.30.4, 4.30.5, 4.30.6.
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, is readily accessible to and usable by persons with disabilities, the City will take the following actions:
20. The City shall complete the following modifications to the City Hall within six months of the effective date of this Agreement, unless otherwise provided:
a. There are 28 designated accessible parking spaces at the front and side of the City Hall building, and there is one designated accessible parking space. Provide an additional accessible parking spaces as required by the Standards with appropriate signage, one of which must be a van accessible space with a 96 inch wide access aisle and a "van accessible" sign mounted under the international symbol of accessibility such that the signage cannot be obscured by a vehicle parked in the space. §§ 4.1.2(5), 4.6.3, 4.6.4 & Fig. 9.
b. Where the parking lot surface meets the sidewalk there is a change in level of 1 1/2 inches and no curb ramp is provided. Provide an accessible route from the accessible parking spaces to the designated accessible entrances that includes a curb ramp from the accessible parking to the sidewalk. §§ 4.1.2(1), 4.3.8, 4.7.
c. The handrails on the entrance ramp from the side parking lot to City Hall do not extend beyond the ends of the ramp, there is a change in level of 1 1/2 inches where the top run meets the top level landing, the bottom run of the ramp has a slope of 1:7, and the top run has a slope of 1:5 (rise:run), both of which exceed the maximum allowable 1:12 slope for a ramp, and the level landing between the ramp runs is 24 inches in length. Install a sign at the bottom of the ramp and at the front of the building, using the international symbol of accessibility, to direct persons who have business in City Hall to the accessible entrance to the City Council Chambers. Include a telephone number on the sign and the name of a person to be contacted for receipt of services normally provided in the City Hall in the City Council Chambers. Install a telephone in the City Council Chambers for this purpose. §§ 4.1.2.7(c), 4.30.7.
d. The entrance door and all of the interior doors have twist-type hardware. Replace the door knobs with hardware that can be operated with one hand and does not require tight grasping, pinching, or twisting of the wrist to operate. §§ 4.1.3(7)(a) & (b), 4.13.9.
21. The City shall complete the following modifications to the City Council Chambers & Municipal Court Building within six months of the effective date of this agreement:
a. The front entrance ramp does not have handrails that comply with the Standards and does not have edge protection. Install edge protection and handrails that comply with the Standards. §§ 4.1.2(1), 4.3.2, 4.3.8, 4.8.5, 4.8.7 & Fig. 17, 4.26.
b. Women's Toilet Room
(1) The mirror in is mounted with the bottom edge of the reflecting surface 49 inches above the finish floor. Provide a mirror with the bottom edge of the reflecting surface no higher than 40 inches above the finish floor. §§ 4.1.3(11), 4.1.3(11), 4.19.6, 4.22.6.
(2) The lavatory has twist-type faucets, and the hot water and drain pipes under the lavatory are not insulated or otherwise configured to protect against contact. Replace the faucet with hardware that does not require tight pinching, grasping or twisting of the wrist to operate, and install insulation on each set of pipes. §§ 4.1.3(11), 4.22.6, 4.19.4, 4.19.5, 4.27.4.
(3) The centerline of the toilet is 21 inches from the side wall. Reposition the toilet so that it is exactly 18 inches from the side wall. §§ 4.1.3, 4.22.4, 4.16.2 & Fig. 28.
(4) The side grab bar extends 25 1/2 inches from the back wall and there is no rear grab bar. Install a side grab bar that is at least 40 inches long, is positioned so that it begins no more than 12 inches from the back wall, and it extends at least 52 inches from the back wall. Install a rear grab bar that is at least 36 inches long with the end mounted at least 12 inches from the centerline of the toilet, i.e., no more than 6 inches from the side wall. §§ 4.1.3(11), 4.22.4, 4.16.4 & Fig.29.
(5) The toilet paper dispenser is mounted above the side grab bar and 50 inches from the back wall. Remount the dispenser so that it is within reach, below the side grab bar, and at least 19 inches to the centerline of the roll above the finish floor. §§ 4.1.3(11), 4.22.4, 4.16.6 & Figure 29(b).
(6) The room identification sign is mounted on the door to the toilet room and does not otherwise meet the Standards . Provide signage, using raised letters and Braille, on the wall adjacent to the latch side of the toilet room entrance door with the centerline 60 inches above the surface of the floor and a person can approach within three inches of the sign without encountering protruding objects or standing within the swing of the door. §§ 4.1.3(16)(a), 4.30.1, 4.30.4, 4.30.5, 4.30.6.
c. Men's Toilet Room
(1) The highest operable part of the paper towel dispenser is 56 inches above the finish floor. Provide a dispenser so that the highest operable part is within the reach ranges of a person who uses a wheelchair; i.e., no more than 54 inches above the finish floor for a side reach or, if that is not available, 48 inches above the finish floor for a forward reach. §§ 4.1.3(11), 4.22.7, 4.27.3, 4.2.6, 4.2.5.
(2) The toilet paper dispenser is mounted above the side grab bar and 51 1/2 inches from the back wall. Provide a toilet paper dispenser that is within reach, mounted below the side grab bar, at least 19 inches above the finish floor to the centerline of the roll. §§ 4.1.3(11), 4.22.4, 4.16.6 & Fig. 29(b).
(3) The side grab bar extends 25 1/2 inches from the back wall and there is no rear grab bar. Install a side grab bar that is at least 40 inches long, is positioned so that it begins no more than 12 inches from the back wall, and it extends at least 52 inches from the back wall. Install a rear grab bar that is at least 36 inches long with the end mounted at least 12 inches from the centerline of the toilet, i.e., no more than 6 inches from the side wall. §§ 4.1.3(11), 4.22.4, 4.17.3 & Fig. 30(a).
(4) The bottom edge of the reflecting surface of the mirror is 49 inches above the finish floor. Provide a mirror that is mounted with the bottom edge of the reflecting surface no higher than 40 inches above the finish floor. §§ 4.1.3(11), 4.19.6, 4.22.6.
(5) The lavatory has twist-type faucets, and the hot water and drain pipes under the lavatory are not insulated or otherwise configured to protect against contact. Replace the faucet with hardware that does not require tight pinching, grasping or twisting of the wrist to operate, and install insulation on each set of pipes. §§ 4.1.3(11), 4.22.6, 4.19.4, 4.19.5, 4.27.4.
(6) The room identification sign is mounted on the door to the toilet room and does not otherwise meet the Standards . Provide signage, using raised letters and Braille, on the wall adjacent to the latch side of the toilet room entrance door with the centerline 60 inches above the surface of the floor and a person can approach within three inches of the sign without encountering protruding objects or standing within the swing of the door. §§ 4.1.3(16)(a), 4.30.1, 4.30.4, 4.30.5, 4.30.6.
d. The doors throughout this building have knob hardware. Replace the door handles with hardware that is easy to grasp with one hand and does not require tight grasping, pinching, or twisting of the wrist to operate. §§ 4.1.3(7)(b), 4.13.9.
e. The podium for the Council and the Judge's bench is accessible only by steps. Establish a procedure for providing an alternative, accessible area or install a ramp or platform lift to the podium in compliance with the Standards. §§ 4.8, 4.11. Any procedure shall not require lifting or carrying persons with mobility impairments or require them to traverse unnecessary or extreme distances, and the procedure must be submitted to the Department for review prior to implementation.
22. The City shall complete the following modifications to Senior Citizens Center within nine months of the effective date of this Agreement:
a. The gripping surface of the handrails on the ramp at the designated accessible entrance does not comply with the Standards, and the handrails do not extend 12 inches beyond the top and bottom of the ramp. Provide handrails for the ramp at the designated accessible entrance that have compliant gripping surfaces, that extend 12 inches beyond the top and bottom of the ramp, and that have ends that are rounded or that return smoothly to the floor or post. §§ 4.1.3(1), 4.3.7, 4.8.1, 4.8.5, 4.26.1, 4.26.2 & Fig. 39.
b. The building entrance and interior doors have twist-type hardware. Replace the door knobs with hardware that does not require tight pinching, tight grasping, or twisting of the wrist to operate. §§ 4.1.7, 4.13.9.
c. Women's Toilet Room
(1) The hot water and drain pipes under the lavatory are not insulated or otherwise configured to protect against contact. Install insulation on both sets of pipes under the lavatory. §§ 4.1.3(11), 4.19.4.
(2) The mirror is mounted with the bottom edge of the reflecting surface 49 1/2 inches above the finish floor. Provide a mirror with the bottom edge of the reflecting surface no higher than 40 inches above the finish floor. §§ 4.1.3(11), 4.1.3(11), 4.19.6, 4.22.6.
(3) The coat hook in the designated accessible toilet stall is 69 inches above the finish floor. Provide a coat hook that is 54 inches above the finish floor for a side reach or, if that is not available, 48 inches above the finish floor for a forward reach. §§ 4.1.3(11), 4.1.3(12), 4.25.3, 4.2.5, 4.2.6.
(4) The designated accessible toilet stall is 34 1/2 inches by 84 inches and it has no rear grab bar. Provide a "standard" accessible toilet stall, which is at least 60 inches wide and 59 inches deep (at least 56 inches if the water closet is wall mounted) 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. §§ 4.13, 4.16, 4.17 & Fig. 30(a), 4.22.4, 4.22.7, 4.26, 4.27.
(5) The room designation sign is mounted above the entrance door and does not otherwise comply with the Standards. Provide a sign, using raised letters and Braille, on the wall adjacent to the latch side of the door so that the centerline of the sign is 60 inches above the finish floor and a person can approach within 3 inches of signage without encountering protruding objects or standing within the swing of a door. §§ 4.1.3(16)(a), 4.30.1, 4.30.4, 4.30.5, 4.30.6.
d. Men's Toilet Room
(1) There is a privacy screen that is fixed to the floor 29 1/2 inches from the face of the door that intrudes into the accessible route into the toilet room. Remove the privacy screen or otherwise provide an accessible route into the toilet room. §§ 4.1.3(11), 4.1.3(1), 4.3.2(3), 4.3.3 & Fig.7(a) & (b).
(2) The designated accessible stall is 34 1/2 inches by 71 1/2 inches. Provide a "standard" accessible toilet stall, which is at least 60 inches wide and 59 inches deep (at least 56 inches if the water closet is wall mounted) 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. §§ 4.1.3(11), 4.13, 4.16, 4.17 & Fig. 30(a), (a-1), & (c), 4.22.4, 4.22.7, 4.26, 4.27.
(3) There is no rear grab bar in the designated accessible stall. Install a rear grab bar that is at least 36 inches long with the end mounted at least 12 inches from the centerline of the toilet, i.e., no more than 6 inches from the side wall. §§ 4.1.3(11), 4.22.4, 4.17.6, 4.26 & Fig.30.
(4) The privacy screen extends into the route to the urinal so that the route between the privacy screen and the toilet stall is 26 1/2 inches wide. Remove the privacy screen or otherwise provide an accessible route to the urinal. §§ 4.1.3(11), 4.1.3(1), 4.3.2(3), 4.3.3 & Fig.7(a) & (b).
(5) The rim of the urinal in the men's toilet room is 24 inches above the finish floor. Provide a urinal that has a rim no higher than 17 inches above the finish floor. §§ 4.1.3(11), 4.18.2.
(6) The coat hook in the designated accessible toilet stall is 70 1/2 inches above the finish floor. Provide a coat hook that is not more than 54 inches above the finish floor for a side reach or, if that is not available,48 inches above the finish floor for a forward reach. §§ 4.1.3(12)(a), 4.25.3, 4.2.5, 4.2.6.
(7) The hot water and drain pipes under the lavatory are not insulated or otherwise configured to protect against contact. Install insulation on both sets of pipes under the lavatory. § 4.1.3(11), 4.22.6, 4.19.4.
(8) The mirror is mounted so that the reflecting surface is 49 1/2 inches above the finish floor. Provide a mirror in each room mounted with the bottom of the reflecting surface no higher than 40 inches above the finish floor. §§ 4.1.3(11), 4.22.6, 4.19.6.
(9) The room designation sign is mounted above the entrance door and does not otherwise comply with the Standards. Provide a sign, using raised letters and Braille, on the wall adjacent to the latch side of the door so that the centerline of the sign is 60 inches above the finish floor and a person can approach within 3 inches of the signage without encountering protruding objects or standing within the swing of a door. §§ 4.1.3(16)(a), 4.30.1, 4.30.4, 4.30.5, 4.30.6.
23. The City shall complete the following modifications to Garret Park or shall submit building plans for a new facility to the Department within nine months of the effective date of this Agreement:
a. Men's Toilet Room
(1) The rim of the urinal is 25 inches above the finish floor. Provide a urinal with an elongated rim no more than 17 inches above the finish floor. §§ 4.1.3(11), 4.22.5, 4.18.2, 4.18.4.
(2) The designated accessible stall is 46 inches by 79 inches, has no grab-bars, and the stall door swings into the clear floor space at the toilet. Provide a "standard" accessible toilet stall that is at least 60 inches wide and at least 59 inches deep (at least 56 inches if the water closet is wall mounted) such that all of the stall's elements, including entry door, stall door hardware, water closet, size and arrangement, toe clearances, grab bars, controls and dispensers comply with the Standards. §§ 4.1.3(11), 4.13, 4.16, 4.17 & Fig. 30(a), (a-1), & (c), 4.22.4, 4.22.7, 4.26, 4.27.
(3) Partitions intrude into the clear floor space in front of the urinals so that it is 22 inches wide in front of one of the urinals and 28 1/2 inches wide in front of the other. Provide a clear floor space of at least 30 inches by 48 inches in front of at least one of the urinals. §§ 4.1.3(11), 4.18.3, 4.2.4.2 & Fig. 4(d).
(4) The toilet room does not have the required signage. Provide signage, using raised letters and Braille, on the wall adjacent to the latch side of the toilet room entrance door with the centerline 60 inches above the surface of the floor and a person can approach within three inches of the sign without encountering protruding objects or standing within the swing of the door. §§ 4.1.3(16)(a), 4.30.1, 4.30.4, 4.30.5, 4.30.6.
b. Women's Toilet Room
(1) The designated accessible stall is 46 1/2 inches by 79 inches and has no grab bars. Provide a "standard" accessible toilet stall that is at least 60 inches wide and at least 59 inches deep (at least 56 inches if the water closet is wall mounted) such that all of the stall's elements, including entry door, stall door hardware, water closet, size and arrangement, toe clearances, grab bars, controls and dispensers comply with the Standards. §§ 4.1.3(11), 4.13, 4.16, 4.17, 4.22.4, 4.25, 4.26, 4.27 & Fig.30.
(2) The centerline of the toilet is 25 inches from the side wall. Reposition the toilet so that the centerline is 18 inches from the side wall. §§ 4.1.3(11), 4.22.4, 4.17.3, & Fig. 30(a).
(3) The toilet room does not have the required signage. Provide signage, using raised letters and Braille, on the wall adjacent to the latch side of the toilet room entrance door with the centerline 60 inches above the surface of the floor and a person can approach within three inches of the sign without encountering protruding objects or standing within the swing of the door. §§ 4.1.3(16)(a), 4.30.1, 4.30.4, 4.30.5, 4.30.6.
24. The City shall complete the following modifications to Park Avenue Baseball and Soccer Field within nine months of the effective date of this Agreement:
a. There is no accessible route from parking to the playground. Establish an accessible route from parking to the playground that is firm, stable, and slip-resistant and otherwise complies with the Standards. §§ 4.1.2(2), 4.3, 4.5.
b. There is no designated accessible parking space. Provide the number of accessible parking spaces required by the Standards with appropriate signage, and provide the required number of van accessible spaces with a 96 inch wide access aisle and a "van accessible" sign mounted under the international symbol of accessibility such that the signage cannot be obscured by a vehicle parked in the space. §§ 4.1.2(5), 4.6.3, 4.6.4, Fig.9.
25. The City shall complete the following modifications to the Municipal Pool or shall submit building plans for a new facility to the Department within one year of the effective date of this Agreement:
a. The top of the service counter is 39 1/2 inches above the finish floor. Provide a counter that is at least 36 inches wide and no more than 36 inches high; or provide an auxiliary counter with a maximum height of 36 inches; or provide equivalent facilitation; e.g., by offering those services at an accessible location for individuals who use wheelchairs. § 7.2(2).
b. Women's Shower Room
(1) The shower area has a four inch curb and fixed shower heads. Provide shower space so that the curb is no higher than 1/2 inch and there is a shower spray unit with a hose at least 60 inches long that can be used as a fixed shower head and as a hand-held shower. §§ 4.1.3(11), 4.23.8, 4.21.6, 4.21.7.
(2) The soap dispenser is mounted so that the control is 62 inches above the top surface of the floor. Reposition the dispenser so that its highest operable part is within the reach ranges of a person who uses a wheelchair. §§ 4.1.3(11), 4.22.7, 4.27.3, 4.2.5, 4.2.6.
(3) The highest operable part of the paper towel dispenser is 53 inches above the finish floor and requires a forward reach from a wheelchair to operate. Reposition the dispenser so that the highest operable part is within the reach ranges of a person who uses a wheelchair. §§ 4.1.3(11), 4.22.7, 4.27.3, 4.2.6.
(4) The designated accessible stall is 43 1/2 inches by 64 inches, has no grab-bars, the centerline of the toilet is 15 inches from the side wall, and the toilet paper dispenser is mounted on the wall that is furthest from the toilet. Provide a "standard" accessible toilet stall that is at least 60 inches wide and at least 59 inches deep (at least 56 inches if the water closet is wall mounted) such that all of the stall's elements, including entry door, stall door hardware, water closet, size and arrangement, toe clearances, grab bars, controls and dispensers comply with the Standards. §§ 4.1.3(11), 4.13, 4.16, 4.17 & Fig. 30(a), (a-1), & (c), 4.22.4, 4.22.7, 4.26, 4.27.
c. Men's Shower Room
(1) The shower area has a four inch curb and fixed shower heads. Provide shower space so that the curb is no higher than 1/2 inch and there is a shower spray unit with a hose at least 60 inches long that can be used as a fixed shower head and as a hand-held shower. §§ 4.1.3(11), 4.23.8, 4.21.6, 4.21.7.
(2) The soap dispenser is mounted so that the control is located 53 inches above the finish floor and requires a forward reach from a wheelchair to operate. Reposition the dispenser so that its highest operable part is within the reach ranges of a person who uses a wheelchair. §§ 4.1.3(11), 4.22.7, 4.27.3, 4.2.5, 4.2.6.
(3) The designated accessible stall is 45 1/2 inches by 64 inches, has no grab-bars, the toilet paper dispenser is mounted 38 inches from the back wall, and the centerline of the toilet is 14 inches from the side wall. Provide a "standard" accessible toilet stall that is at least 60 inches wide and at least 59 inches deep (at least 56 inches if the water closet is wall mounted) such that all of the stall's elements, including entry door, stall door hardware, water closet, size and arrangement, toe clearances, grab bars, controls and dispensers comply with the Standards. §§ 4.1.3(11), 4.13, 4.16, 4.17 & Fig. 30(a), (a-1), & (c), 4.22.4, 4.22.7, 4.26, 4.27.
(4) The rim of the urinal is 26 inches above the finish floor. Provide a urinal with an elongated rim no more than 17 inches above the finish floor. §§ 4.1.3(11), 4.22.5, 4.18.2, 4.18.4.
(5) The highest operable part of the paper towel dispenser is 58 inches above the finish floor and requires a forward reach from a wheelchair to operate. Reposition the dispenser so that the highest operable part is within the reach ranges of a person who uses a wheelchair. §§ 4.1.3(11), 4.22.7, 4.27.3, 4.2.6.
d. The spout outlet of the drinking fountain is located 38 inches above the finish floor. Install a drinking fountain with a spout outlet no higher than 36 inches above the finish floor or provide a water cooler in an accessible location with cups that dispense within the reach ranges of persons who use wheelchairs. §§ 4.1.3(10), 4.15.2.
26. The City shall complete the following modifications to the Fire Station within nine months of the effective date of this Agreement:
a. There is a 1½ inch change in level at the threshold of the front entrance door. Alter the threshold so that it is no greater than ½ inch and is beveled with a slope no greater than 1:2. §§ 4.1.3(7)(a), 4.13.8, 4.5.2, 4.8.
b. Men's and Women's Toilet Rooms
(1) The entrance doors to the toilet rooms swing into the clear floor space at the lavatories, there is insufficient clear floor space at the lavatories, and there is insufficient maneuvering clearance at the toilet room doors. Alter these areas to meet the clear floor space and maneuvering clearance requirements of the Standards. §§ 4.1.3(11), 4.22.3, 4.2, 4.3, 4.19.3.
(2) The bottom edges of the reflecting surfaces of the mirrors are 42 inches above the finish floors. Provide mirrors that are mounted with the bottom edges of the reflecting surfaces no higher than 40 inches above the finish floor. §§ 4.1.3(11), 4.19.6.
(3) The coat hooks on the doors are 67 1/2 inches above the finish floor. Provide coat hooks that are not more than above the finish floor for a side reach or, if that is not available, 48 inches above the finish floor for a front reach. §§ 4.1.3(11), 4.25.3, 4.2.6.
(4) There are no rear grab bars at the toilets. Provide rear grab bars that are at least 36 inches long with the ends closer to the side walls mounted at least 12 inches from the centerlines of the toilets, i.e., no more than 6 inches from the side walls. §§ 4.1.3(11), 4.22.4, 4.16.4 & Fig.29(a).
(5) The room designation signs are mounted on the entrance doors and do not otherwise comply with the Standards. Provide signs, using raised letters and Braille, on the walls adjacent to the latch sides of the doors so that the centerlines of the signs are 60 inches above the finish floor and a person can approach within 3 inches of the signage without encountering protruding objects or standing within the swing of a door. §§ 4.1.3(16)(a), 4.30.1, 4.30.4, 4.30.5, 4.30.6.
c. The spout of the drinking fountain is 39 inches above the finish floor. Provide a fountain so that the spout is no higher than 36 inches above the finish floor, or install cups next to the existing fountain within the reach range requirements of the Standards. §§ 4.15.2, 4.27.3, 4.2.5, 4.2.6.
IMPLEMENTATION AND ENFORCEMENT
27. Except as otherwise specified in this Agreement, at 90 and 180 days after the effective date of this Agreement, and thereafter at yearly anniversaries of the effective date, the City will submit written reports to the Department summarizing the actions the City has taken pursuant to this Agreement. Reports will include photographs, architectural plans, notices published in the newspapers, copies of adopted policies, and proof of efforts to secure funding/assistance for structural renovations.
28. If at any time the City desires to modify any portion of this Agreement because of changed conditions making performance impossible or impractical or for any other reason, it will promptly notify the Department in writing, setting forth the facts and circumstances thought to justify modification and the substance of the proposed modification. Until there is written Agreement by the Department to the proposed modification, the proposed modification will not take effect. These actions must receive the prior written approval of the Department, which approval shall not be unreasonably withheld or delayed.
29. The Department may review compliance with this Agreement at any time. If the Department believes that this Agreement or any portion of it has been violated, it will so notify the City in writing and it will attempt to resolve the issue or issues in good faith. If the Department is unable to reach a satisfactory resolution of the issue or issues raised within 30 days of the date it provides notice to the City, it may institute a civil action in federal district court directly to enforce title II or to enforce the terms of this Agreement, or it may initiate appropriate steps to enforce § 504 of the Rehabilitation Act.
30. Failure by the Department to enforce this entire Agreement or any provision thereof with regard to any deadline or any other provision herein shall not be construed as a waiver of the Department's right to enforce other deadlines and provisions of this Agreement.
31. In the event that the City fails to comply in a timely manner with any requirement of this Agreement without obtaining a sufficient advance written agreement with the Department as a temporary modification of the relevant terms of this Agreement, the Department may file suit in an appropriate federal court to enforce the terms of the Agreement, may declare the Agreement null and void and file suit to enforce title II of the ADA, or it may initiate appropriate steps to enforce § 504 of the Rehabilitation Act.
32. This Agreement is a public document. A copy of this document or any information contained in it may be made available to any person by the City or the Department on request.
33. The effective date of this Agreement is the date of the last signature below.
34. This Agreement constitutes the entire agreement between the parties on the matters raised herein, and no other statement, promise, or agreement, either written or oral, made by either party or agents of either party, that is not contained in this written Agreement, shall be enforceable. This Agreement does not purport to remedy any other potential violations of the ADA or any other Federal law. This Agreement does not affect the City's continuing responsibility to comply with all aspects of the ADA.
35. This Agreement will remain in effect for three years from the effective date of this Agreement, or until the parties agree that full compliance with this Agreement by the City has been achieved.
36. The person signing for the City of Robertsdale represents that he is authorized to bind the City to this Agreement.
For the City of Robertsdale:
CHARLES MURPHY
Mayor
Robertsdale, Alabama
________________________
Post Office Box 429
Robertsdale, Albama 36567
Date __10/31/01___
RALPH F. BOYD, JR.
Assistant Attorney General
Civil Rights Division
By:__________________________
JOHN L. WODATCH, Chief
SUSAN BUCKINGHAM REILLY, Deputy Chief
Disability Rights Section
Civil Rights Division
U.S. Department of Justice
P.O. Box 66738
Washington, DC 20035-6738
Date ________________
Return to Project Civic Access
November 16, 2001