Attachment J

Altered Facilities

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

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

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

A. Parking

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

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

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

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

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

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

B. Offices and Counters

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

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

C. Drinking Fountains

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

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

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

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

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

D. Convention Center Toilet Rooms

1) Grand Lobby South Women’s Toilet Room

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

E. Cannon Center for the Performing Arts

1) Entranceway Doors

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

2) Ramps

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

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

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

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

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

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

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

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

a) Single User Toilet Rooms

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

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

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

A. South/North Parking Lot

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

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

B. All entrances into the Pyramid

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

C. Lower Level Telephone

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

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

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

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

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

2) Designated accessible standard toilet stall:

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

3) Designated accessible ambulatory toilet stall:

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

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

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

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

2) Designated accessible standard toilet stall:

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

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

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

3) Designated accessible ambulatory toilet stall:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

2) Designated accessible standard toilet stall:

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

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

L. Mezzanine Level near Sections 147 and 121

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

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

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

2) Designated accessible standard toilet stall:

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

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

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

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

3) Designated accessible ambulatory stall:

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

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

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

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

2) Designated accessible standard toilet stall:

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

b) The side grab bar at the toilet is inaccessibl