Existing Facilities

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

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

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

A. Council Chambers

1) The Council Chambers containing 401 seats is inaccessible because the wheelchair seating area is less than 33 inches wide. Provide 6 wheelchair seating areas, each with a minimum clear ground or floor space of 66 inches wide by 48 inches deep for forward or rear access, or 66 inches wide by 60 inches deep for side access. Ensure that the ground or floor at all wheelchair locations is level, firm, stable, and slip resistant; that wheelchair seating areas are an integral part of the fixed seating plan and are located so as to provide people with physical disabilities a choice of lines of sight comparable to those available for members of the general public; that wheelchair seating areas adjoin an accessible route that also serves as a means of egress in case of emergency; and that at least one fixed companion seat is provided next to each wheelchair seating area. Standards §§ 4.1.3(19)(a), 4.5, 4.33.

B. Accessible Routes

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

2) The route from level 1B to the stairway leading to the first floor has a low overhead clearance and presents a hazard for those that are blind or have low vision. Provide an accessible route at this location such that no objects with their bottom leading edges measuring between 27 inches and 80 inches above the finished floor protrude more than 4 inches into walks, halls, corridors, passageways, or aisles. Standards § 4.4.

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

C. Drinking Fountains

1) Although 2 drinking fountains are provided on level 1B, there is no accessible drinking fountain because the spout heights of both fountains is 42 inches high, and there is no forward approach knee space depth. Provide at least one drinking fountain with a spout height no higher than 36 inches, measured from the finished floor or ground surface to the spout outlet; and a spout located at the front of the unit that directs the water flow in a trajectory that is nearly parallel to the front of the unit and is positioned so the flow of water is within 3 inches of the front edge of the fountain and at least 4 inches high. Ensure that fountain controls are operable with one hand, require 5 lbf or less to operate without tight grasping, pinching, or twisting of the wrist; and are front mounted or side mounted near the front edge. Additionally, provide a drinking fountain that is accessible to people who have difficulty bending or stooping. This can be accommodated by the use of a “hi-lo” fountain; by providing one fountain accessible to those who use wheelchairs and one fountain at a standard height convenient for those who have difficulty bending; by providing a fountain accessible to people who use wheelchairs and a cup dispenser; or by such other means as would achieve the required accessibility for each group of people. Standards §§ 4.15, 4.27.4, Fig. 27.

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

3) Although 2 drinking fountains are provided on the first floor, there is no accessible drinking fountain because the spout height on the existing fountains is 37 inches above the finished floor, and there is no fountain provided for persons who have trouble bending or stooping. Provide at least one drinking fountain with a spout height no higher than 36 inches, measured from the finished floor or ground surface to the spout outlet; and a spout located at the front of the unit that directs the water flow in a trajectory that is nearly parallel to the front of the unit and is positioned so the flow of water is within 3 inches of the front edge of the fountain and at least 4 inches high. Ensure that fountain controls are operable with one hand, require 5 lbf or less to operate without tight grasping, pinching, or twisting of the wrist; and are front mounted or side mounted near the front edge. Additionally, provide a drinking fountain that is accessible to people who have difficulty bending or stooping. This can be accommodated by the use of a “hi-lo” fountain; by providing one fountain accessible to those who use wheelchairs and one fountain at a standard height convenient for those who have difficulty bending; by providing a fountain accessible to people who use wheelchairs and a cup dispenser; or by such other means as would achieve the required accessibility for each group of people. Standards §§ 4.15, 4.27.4, Fig. 27.

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

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

6) Although drinking fountains are provided on the 3^rd, 4^th, 5^th, and 6^th floors , there is no drinking fountain provided for people who have difficulty bending or stooping. Provide a drinking fountain that is accessible to people who have difficulty bending or stooping. This can be accommodated by the use of a “hi-lo” fountain; by providing one fountain accessible to those who use wheelchairs and one fountain at a standard height convenient for those who have difficulty bending; by providing a fountain accessible to people who use wheelchairs and a cup dispenser, or by such other means as would achieve the required accessibility for each group of people. Standards § 4.1.3(10)(a).

D. Offices and Counters

1) Counters

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

b) The Employment Applications Counter at the Personnel Division (Room 1B33) is inaccessible because the counter is mounted 41 inches above the mounted floor. Provide a counter on an accessible route such that a portion of the counter is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary counter with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, a clip board made available to the public, or other means. Standards §§ 7.2(2), 4.3.

c) The Employment Application Counter at the Personnel Division is inaccessible because the counter is a protruding object. Provide a circulation path at this location such that no objects with their bottom leading edges measuring between 27 inches and 80 inches above the finished floor protrude more than 4 inches into walks, halls, corridors, passageways, or aisles. Free-standing objects mounted on posts or pylons may overhang 12 inches maximum from 27 inches to 80 inches above the ground or finished floor. Standards § 4.4.

d) The Executive Division Counter at the Public Services Division (Room 200) is inaccessible because the counter is mounted 39 inches above the finished floor. Provide a counter on an accessible route such that a portion of the counter is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary counter with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, a clip board made available to the public, or other means. Standards §§ 7.2(2), 4.3.

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

f) The Payroll Counter at the Finance and Administration Division (Room 354) is inaccessible because it is mounted 42 inches above the finished floor. Provide a counter on an accessible route such that a portion of the counter is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary counter with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, a clip board made available to the public, or other means. Standards §§ 7.2(2), 4.3.

g) The Comptroller Accounting Counter at Finance and Administration Division (Room 348) is inaccessible because the counter is mounted 41 inches above the finished floor. Provide a counter on an accessible route such that a portion of the counter is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary counter with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, a clip board made available to the public, or other means. Standards §§ 7.2(2), 4.3.

h) The City Attorney’s Office Counter at the Law Division (Room 336) is inaccessible because it is mounted 42.5 inches above the finished floor. Provide a counter on an accessible route such that a portion of the counter is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary counter with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, a clip board made available to the public, or other means. Standards §§ 7.2(2), 4.3.

i) The Executive Office Counter at the Legislative Division (Room 514) is inaccessible because the counter is mounted 42.5 inches above the finished floor. Provide a counter on an accessible route such that a portion of the counter is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary counter with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, a clip board made available to the public, or other means. Standards §§ 7.2(2), 4.3.

j) The Building Design and Construction Counter at the Engineering Division is inaccessible because the counter is mounted 43 inches above the finished floor. Provide a counter on an accessible route such that a portion of the counter is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary counter with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, a clip board made available to the public, or other means. Standards §§ 7.2(2), 4.3.

k) The Receptionist’s Counter at the Office of the Mayor (7^th floor) is inaccessible because the counter is mounted 41 inches above the finished floor. Provide a counter on an accessible route such that a portion of the counter is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary counter with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, a clip board made available to the public, or other means. Standards §§ 7.2(2), 4.3.

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

3) The door to the Office of Planning and Development (Room 468), which is accessed from the latch side of the door, is inaccessible because it has less than 18 inches of maneuvering clearance. On the pull side of the door, provide a path of travel at least 48 inches wide for a side approach and at least 24 inches of clear maneuvering space adjacent to the latch side of the door. Standards § 4.13.6, Fig. 25(c).

E. Toilet Rooms

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

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

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

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

c) The lavatory is inaccessible because it does not provide 29 inches of knee height clearance. Provide a lavatory with the top of its rim or counter 34 inches or less above the finished floor; the bottom edge of the apron at least 29 inches above the finished floor; and knee and toe clearances that comply with Fig. 31. Standards § 4.19.2, Fig. 31.

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

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

f) The toilet paper dispenser is inaccessible because it is not located under the side grab bar. Provide a toilet paper dispenser that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

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

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

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

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

b) The toilet is inaccessible because its centerline measures 16.5 inches from the side wall. Provide a toilet with a centerline that measures 18 inches from the near side wall. Standards § 4.17.3, Fig. 30.

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

d) The toilet paper dispenser is inaccessible because it is not mounted under the side grab bar. Provide a toilet paper dispenser that is mounted with its top at least 1½ inches under the side grab bar and 36 inches or less from the rear wall and is centered at least 19 inches above the finished floor. Standards § 4.17.3, Fig. 30(d).

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

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

5) 3^rd Floor Unisex Toilet Room

6) Men and Women’s Toilet Rooms with Stalls – 3^rd, 4^th, 5^th, and 6^th Floors: On each of these floors, the following inaccessible features were found throughout all of these toilet rooms with stalls. The City may make all of these toilet rooms accessible. Alternatively, the City may make toilet rooms on every other floor accessible and provide accessible directional signage with the International Symbol of Accessibility at inaccessible toilet rooms indicating the location of the nearest accessible toilet room, and provide accessible signage with the International Symbol of Accessibility at all accessible toilet rooms. Standards §§ 4.1.2(7)(d), 4.1.6(3)(e)(iii), 4.30.1, 4.30.2, 4.30.3, 4.30.5, 4.30.7.

a) The toilet room sign for the Men’s and Women’s Toilet Rooms with Stalls on the 3^rd, 4^th, 5^th and 6^th floors does not display the International Sign of Accessibility. Provide a toilet room sign with the International Symbol of Accessibility and raised and Braille characters mounted on the wall adjacent to the latch side of the door with the centerline of the sign 60 inches above the finished floor and situated such that a person can approach within 3 inches of the sign without encountering an obstruction or standing within a door swing. Standards §§ 4.1.2(7)(d), 4.30.1, 4.30.4, 4.30.5, 4.30.6, 4.30.7.

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

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

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

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

f) The seat cover dispenser is inaccessible because the controls are mounted at 55 inches above the finished floor with a required 24 inch reach over the toilet. Provide a seat cover dispenser such that the controls comply with Fig. 5 for a forward reach or with Fig. 6 for a side reach and such that it is accompanied by clear floor space of 30 by 48 inches that allows a forward or parallel approach, respectively, by a person using a wheelchair. Standards §§ 4.27.2, 4.27.3, 4.2.4, 4.2.5, 4.2.6.

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

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

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

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

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

A. Parking

1) The parking lot is inaccessible because there is no access aisle. At each standard accessible space, provide an access aisle at least 60 inches wide. At each van accessible space, provide an access aisles at least 96 inches wide. Ensure that all access aisles are flat and level, with slopes and cross-slopes not exceeding 1:50 in all directions, and that their surfaces are firm, stable, and slip-resistant. Standards §§ 4.1.2(5), 4.6.3, Fig. 9.

2) The parking reserved for persons with disabilities lacks appropriate signage. At all spaces designated as reserved for persons with disabilities, provide vertical signs with the International Symbol of Accessibility located such that they cannot be obstructed by parked vehicles. At van accessible spaces, provide an additional “Van-Accessible” sign located below the International Symbol of Accessibility. Standards §§ 4.6.4, 4.30.7(1).

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

B. Counter

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

C. Drinking Fountain

1) The drinking fountain has a spout that is 38 inches above the finished floor. Provide a fountain that has a spout height no higher than 36 inches, measured from the finished floor or ground surface to the spout outlet, and that otherwise complies with the Standards. Standards §§ 4.15, 4.27.4, Fig. 27.

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

A. Parking

1) Although the parking lot has a total of 75 parking spaces of which 5 are designated as standard accessible spaces, none are designated as being van-accessible. On the shortest accessible route to the accessible entrance, provide 1 van accessible space designated as reserved for people with disabilities. Ensure that van accessible spaces are a minimum of 96 inches wide and served by access aisles at least 96 inches wide. At all spaces designated as reserved for persons with disabilities, provide vertical signs with the International Symbol of Accessibility located such that they cannot be obstructed by parked vehicles. At van accessible spaces, provide an additional “Van-Accessible” sign located below the International Symbol of Accessibility. Ensure that all spaces and access aisles for persons with disabilities are flat and level, with slopes and cross-slopes not exceeding 1:50 in all directions, and that their surfaces are firm, stable, and slip-resistant. Standards §§ 4.1.2(5), 4.6, 4.30.7(1).

3) The parking lot is inaccessible because there are no access aisles. At each standard accessible space, provide an access aisle at least 60 inches wide. At each van accessible space, provide an access aisles at least 96 inches wide. Ensure that all access aisles are flat and level, with slopes and cross-slopes not exceeding 1:50 in all directions, and that their surfaces are firm, stable, and slip-resistant. Standards §§ 4.1.2(5), 4.6.3, Fig. 9.

B. West End Exterior Entrance

1) The west end exterior entrance inaccessible because there is an unbeveled ½ inch threshold. Provide a door with a threshold no greater than ¼ inch, or between ¼ inch and ½ inch and beveled with a slope no greater than 1:2. Standards §§ 4.13.8, 4.5.2.

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

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

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

D. East End Exterior Entrance and Doors

2) The route from the East End Exterior Entrance and Doors is inaccessible because the ashtray is a protruding object that is not detectable to a blind person using a cane. Provide an accessible route at this location such that no objects with their bottom leading edges measuring between 27 inches and 80 inches above the finished floor protrude more than 4 inches into walks, halls, corridors, passageways, or aisles. Free-standing objects mounted on posts or pylons may overhang 12 inches maximum from 27 inches to 80 inches above the ground or finished floor. Standards § 4.4.

E. North End Entrance and Doors

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

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

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

G. Ramp to Ground Level Multi-purpose Room

1) The ramp is inaccessible because the handrails are 32¼” in height, the extensions are less than 12 inches from the ground surface, no extensions are provided for the inside handrails, and the handrails are 2¼” from the wall. Provide handrails that are between 1¼ inches and 1½ inches in diameter with a continuous gripping surface along both sides of the ramp, extending at least 12 inches beyond the top and bottom of the ramp parallel with the ground surface. Ensure that handrails are mounted between 34 inches and 38 inches above the ramp surface and 1½ inches from the wall, with ends rounded or returned smoothly to the floor, wall, or post, and that they do not rotate within their fittings. Standards § 4.8.5.

H. Toilet rooms: the City may make all of the following toilet rooms accessible to people with disabilities. Alternatively, the City may make one set of toilet rooms accessible or create an accessible unisex toilet room, with accessible directional signage with the International Symbol of Accessibility at inaccessible toilet rooms indicating the location of the nearest accessible toilet room, and accessible signage with the International Symbol of Accessibility at all accessible toilet rooms. Standards §§ 4.1.2(7)(d), 4.1.6(3)(e)(iii), 4.30.1, 4.30.2, 4.30.3, 4.30.5, 4.30.7.

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

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

b) The door to the men’s 1^st floor west side toilet room is inaccessible because it is only 29" wide. Provide a door with a clear opening at least 32 inches wide when measured from the face of the door to the opposite stop when the door is opened 90 degrees and with hardware usable with one hand and without tight grasping, pinching, or twisting of the wrist. Lever-operated, push-type, and U-shaped handles are acceptable designs. Standards §§ 4.13.5, 4.13.9.

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

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

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

f) The route within the toilet room is inaccessible because the door closer hangs into the door clear opening at 70 inches and is a protruding object that is not detectable to a blind person using a cane. Provide an accessible route at this location such that no objects with their bottom leading edges measuring between 27 inches and 80 inches above the finished floor protrude more than 4 inches into walks, halls, corridors, passageways, or aisles. Free-standing objects mounted on posts or pylons may overhang 12 inches maximum from 27 inches to 80 inches above the ground or finished floor. Standards § 4.4.

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

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

b) The door to the women’s 1^st floor west side toilet room is inaccessible because it is only 30 inches wide. Provide a door with a clear opening at least 32 inches wide when measured from the face of the door to the opposite stop when the door is opened 90 degrees and with hardware usable with one hand and without tight grasping, pinching, or twisting of the wrist. Lever-operated, push-type, and U-shaped handles are acceptable designs. Standards §§ 4.13.5, 4.13.9.

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

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

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

f) The toilet seat cover dispensers are inaccessible because it is mounted 61 inches above the finished floor. Provide toilet seat covers with mechanical controls, if any, that can be operated with 5 lbf or less and that can be used with one hand and without tight grasping, pinching, or twisting of the wrist (lever-operated, push-type, and electronically controlled mechanisms are examples of acceptable designs). Ensure that the controls are a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that it is accompanied by clear floor space of 30 by 48 inches that allows a forward or parallel approach by a person using a wheelchair. Standards §§ 4.27.2, 4.27.3, 4.27.4, 4.2.4, 4.2.5, 4.2.6.

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

h) The route within the toilet room is inaccessible because the door closer hangs into the door clear opening at 70 inches and is not detectable to a blind person using a cane. Provide an accessible route at this location such that no objects with their bottom leading edges measuring between 27 inches and 80 inches above the finished floor protrude more than 4 inches into walks, halls, corridors, passageways, or aisles. Free-standing objects mounted on posts or pylons may overhang 12 inches maximum from 27 inches to 80 inches above the ground or finished floor. Standards § 4.4.

i) The route from the counter to the toilet stall is inaccessible because it is only 21 inches wide. Provide at least one accessible route within the boundary of the site connecting these elements that, to the maximum extent feasible, coincides with the route for the general public. The accessible route must have a minimum clear width of 36 inches, or a minimum clear width of 42 inches if there is a turn around an obstruction less than 48 inches wide; have passing spaces at least 60 inches by 60 inches at least every 200 feet; have a minimum clear headroom of 80 inches; have a surface that is firm, stable, and slip resistant; have, in the absence of a curb ramp, ramp, elevator, or platform lift, no level changes in excess of ½ inch vertically; and have a running slope of less than 1:20 (5%) (or have been constructed as a fully accessible ramp) and a cross slope of less than 1:50 (2%). Standards §§ 4.3, 4.5, Fig. 7.

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

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

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

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

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

d) The door to the men’s second floor toilet room with stalls is inaccessible because there is a 1¼ inch threshold. Provide a door with a threshold no greater than ¼ inch, or between ¼ inch and ½ inch and beveled with a slope no greater than 1:2. Standards §§ 4.13.8, 4.5.2.

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

f) The paper towel dispenser is inaccessible because the controls are mounted at 57 inches above the finished floor. Provide a paper towel dispenser with the controls a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that is accompanied by clear floor space of 30 by 48 inches that allows a forward or parallel approach by a person using a wheelchair. Standards §§ 4.27.2, 4.27.3, 4.2.4, 4.2.5, 4.2.6.

g) The lavatory is inaccessible because the bottom edge of the apron is 27½ inches above the finished floor. Provide a lavatory with the top of its rim or counter 34 inches or less above the finished floor; the bottom edge of the apron at least 29 inches above the finished floor; and knee and toe clearances that comply with Fig. 31. Standards § 4.19.2, Fig. 31.

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

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

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