1. 100 North Main Building – Inspectional Services, Police Claims. The City represents that it plans to move its Police Department services to another location within 12 months and its City Offices of Claims services to another location within 24 months of the effective date of this Agreement. Within three months of the effective date of this Agreement, the City will implement and report to the Department its written plan regarding how the program, activity, or service will be made accessible to persons with disabilities. (Existing Facility.)

A. Parking

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

2) The van accessible parking space is inaccessible because the vertical clearance provided is only 90 inches. Provide a minimum vertical clearance of 98 inches at designated van accessible parking spaces and along at least one vehicle access route to such spaces from site entrances and exits. Standards §§ 4.1.2(5)(b), 4.6.5.

3) The parking lot is inaccessible because two spaces lack 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. Elevators

1) Elevators to all Parking Levels

a) The elevator is inaccessible because the call buttons are centered at 52 inches above the finished floor and lack visual signals indicating that a call has been registered or answered. Provide hall (lobby) call buttons with visual signals indicating when each call is registered and when each call is answered. Ensure that the call buttons are centered at 42 inches above the finished floor, a minimum of ¾ inch in the smallest dimension, with the button designating the up direction on top; that the call buttons are raised or flush; and that objects mounted beneath hall call buttons do not project into the elevator lobby more than 4 inches. Standards § 4.10.3, Fig. 20.

b) The elevator is inaccessible because the hall lanterns do not signal once for up, twice for down, or do not have voice announcers. Provide hall lanterns at each hoistway entrance that emit a visible and audible signal indicating which car is answering a call. Ensure that audible signals sound once for the up direction and twice for the down direction or have verbal annunciators that say “up” or “down;” and that visible signals are mounted so that their centerline is at least 72 inches above the lobby floor, they are at least 2½ inches in the smallest dimension, and they are visible from the vicinity of the hall call button. Lanterns located in cars, visible from the vicinity of hall call buttons, and conforming to the above requirements, are acceptable. Standards § 4.10.4, Fig. 20.

c) The elevator is inaccessible because there is no hoistway signage on each floor. Provide signage at hoistway entrances with raised and Braille floor designations on both jambs such that the centerline of the characters is 60 inches above the finished floor and the characters are 2 inches high. Standards § 4.10.5, Fig. 20.

d) The elevator is inaccessible because Braille and raised characters are not provided on the left of the car control buttons; the main entry floor car control button is not designated by a raised star; the floor buttons do not have visual indicators to register a call or to show that a call has been answered; the highest button is 55 inches above the finished floor; the emergency controls are not grouped at the bottom of the panel, and the centerline of these emergency controls is more than 35 inches above the finished floor. Provide car control buttons that are at least ¾ inch in their smallest dimension and are raised or flush and that are designated by Braille and by raised standard alphabet characters for letters, arabic characters for numerals, or standard symbols. Ensure that the car control button for the main entry floor is designated by a raised star at the left of the floor designation; that all raised designations for control buttons are placed immediately to the left of the buttons to which they apply; that floor buttons are provided with visual indicators to show when each call is registered and are extinguished when each call is answered; that all floor buttons are no higher than 54 inches above the finished floor for a side approach and no more than 48 inches above the finished floor for a front approach; and that emergency controls, including the emergency alarm and emergency stop, are grouped at the bottom of the panel and have their centerlines no less than 35 inches above the finished floor. Standards § 4.10.12, Fig. 23.

e) The elevator is inaccessible because the car position does not ring as the car passes or stops on floors. Provide visual car position indicators above the car control panel or over the door to show the position of the elevator in the hoistway. Ensure that indicators emit an audible and visual signal as the car passes or stops at a floor served by the elevator, with the corresponding floor designation being illuminated; and that numerals are a minimum of ½ inch high. Standards § 4.10.13.

2) Two Banks of Lobby Elevators Serving All Floors (one bank serves the bottom 22 floors; one bank serves the top floors)

a) The elevators are inaccessible because the hallway call buttons are centered 54 inches above the finished floor. Provide hall (lobby) call buttons with visual signals indicating when each call is registered and when each call is answered. Ensure that the call buttons are centered at 42 inches above the finished floor, a minimum of ¾ inch in the smallest dimension, with the button designating the up direction on top; that the call buttons are raised or flush; and that objects mounted beneath hall call buttons do not project into the elevator lobby more than 4 inches. Standards § 4.10.3, Fig. 20.

b) The route from the lobby to the elevator hallway is inaccessible because ashtrays mounted under the call buttons protrude more than 4 inches into the route of travel and are not cane-detectable to people who 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. 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 elevator is inaccessible because the hall lanterns do not consistently signal once for up, twice for down, or have voice announcers. Provide hall lanterns at each hoistway entrance that emit a visible and audible signal indicating which car is answering a call. Ensure that audible signals sound once for the up direction and twice for the down direction or have verbal annunciators that say “up” or “down;” and that visible signals are mounted so that their centerline is at least 72 inches above the lobby floor, they are at least 2½ inches in the smallest dimension, and they are visible from the vicinity of the hall call button. Lanterns located in cars, visible from the vicinity of hall call buttons, and conforming to the above requirements, are acceptable. Standards § 4.10.4, Fig. 20.

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

e) The elevator is inaccessible because the car control buttons do not have Braille or raised characters to the left of the buttons; the main entry floor car control button is not designated by a raised star; the highest button is 66.5 inches off the floor; emergency controls are not grouped at the bottom of the panel, the buttons are recessed, and the centerline of these emergency controls is not less than 35 inches above the finished floor. Provide car control buttons that are at least ¾ inch in their smallest dimension and are raised or flush and that are designated by Braille and by raised standard alphabet characters for letters, arabic characters for numerals, or standard symbols. Ensure that the car control button for the main entry floor is designated by a raised star at the left of the floor designation; that all raised designations for control buttons are placed immediately to the left of the buttons to which they apply; that floor buttons are provided with visual indicators to show when each call is registered and are extinguished when each call is answered; that all floor buttons are no higher than 54 inches above the finished floor for a side approach and no more than 48 inches above the finished floor for a front approach; and that emergency controls, including the emergency alarm and emergency stop, are grouped at the bottom of the panel and have their centerlines no less than 35 inches above the finished floor. Standards § 4.10.12, Fig. 23.

f) The elevator is inaccessible because the car position indicator does not ring as the car passes or stops at floors. Provide visual car position indicators above the car control panel or over the door to show the position of the elevator in the hoistway. Ensure that indicators emit an audible and visual signal as the car passes or stops at a floor served by the elevator, with the corresponding floor designation being illuminated; and that numerals are a minimum of ½ inch high. Standards § 4.10.13.

C. Offices and Counters

1) Memphis Police Department - Inspectional Services (22^nd floor, room 2220 - single door near elevators)

a) The entrance door is inaccessible because the pressure required to open the door is more 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 door to the Memphis Police Department - Inspectional Services, which is accessed through a front approach, is inaccessible because it has insufficient latch space on the pull 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).

c) The door to the Memphis Police Department - Inspectional Services, which is accessed through a front approach and which has both a closer and a latch, is inaccessible because it has insufficient latch space on the push side of the door. On the push side of the door, provide maneuvering clearance at least 48 inches deep and provide a minimum of 12 inches of maneuvering clearance on the latch side of the door, or remove the closer or the latch. Standards § 4.13.6, Fig. 25(a).

2) Memphis Police Department - Inspectional Services (22^nd floor via double doors near elevator)

a) The door to Inspectional Services is inaccessible because the pressure required to open the door is more 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 door to the Inspectional Services Office, which is accessed from the latch side of the door, is inaccessible because it has inadequate maneuvering space on the push side. On the push side of the door, provide a clear path of travel for a side approach at least 42 inches wide and at least 24 inches of clear maneuvering space adjacent to the latch side of the door. Standards § 4.13.6, Fig. 25(c).

3) City Offices of Claims - Risk Management and Contract Compliance (20^th floor, room 2028)

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

c) The door to the City Offices of Claims - Risk Management and Contract Compliance, which is accessed through a front approach, is inaccessible because it has only 7.5 inches of latch space on the pull side. On the pull side of the door, provide maneuvering clearance at least 60 inches deep and provide a minimum of 18 inches (24 inches is preferred) of maneuvering clearance on the latch side of the door. Standards § 4.13.6, Fig. 25(a).

d) The door to the City Offices of Claims - Risk Management and Contract Compliance (Room 2028), which is accessed from the latch side of the door, is inaccessible because it has inadequate maneuvering space on the push side. On the push side of the door, provide a clear path of travel for a side approach at least 42 inches wide and at least 24 inches of clear maneuvering space adjacent to the latch side of the door. Standards § 4.13.6, Fig. 25(c).

e) The Risk Management and Contract Compliance Counter at the City Offices of Claims 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.

D. Drinking Fountains on 20^th and 22^nd Floors

1) Although a drinking fountain is provided on each of the 20^th and 22^nd floors, there is no accessible drinking fountain because no adequate knee clearance provided. Provide at least one drinking fountain with a spout height no higher than 36 inches, measured from the finished floor or ground surface to the spout outlet; and a spout located at the front of the unit that directs the water flow in a trajectory that is nearly parallel to the front of the unit and is positioned so the flow of water is within 3 inches of the front edge of the fountain and at least 4 inches high. Ensure that fountain controls are operable with one hand, require 5 lbf or less to operate without tight grasping, pinching, or twisting of the wrist; and are front mounted or side mounted near the front edge. Additionally, provide a drinking fountain that is accessible to people who have difficulty bending or stooping. This can be accommodated by the use of a “hi-lo” fountain; by providing one fountain accessible to those who use wheelchairs and one fountain at a standard height convenient for those who have difficulty bending; by providing a fountain accessible to people who use wheelchairs and a cup dispenser; or by such other means as would achieve the required accessibility for each group of people. Standards §§ 4.15, 4.27.4, Fig. 27.

E. Toilet Rooms on 20^th and 22^nd Floors

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

b) The doors to the Men’s and Women’s Toilet Rooms on the 20^th and 22^nd floors are inaccessible because the threshold is greater than ½ inch and unbeveled. 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.

2. Shelby County Justice Center – City courts, Memphis Police Department offices. Within three months of the effective date of this Agreement, the City will implement and report to the Department its written plan regarding how the program, activity, or service will be made accessible to persons with disabilities. (Existing Facility.)

A. Signage

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

B. Counters

1) The Cashier’s Counter at City Court Clerk’s Office on the basement level is inaccessible because the counter is mounted 41.5 inches high. Provide a counter on an accessible route such that a portion of the counter is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary counter with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, a clip board made available to the public, or other means. Standards §§ 7.2(2), 4.3.

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

3) The Front Counter at the Memphis Police Department Lobby on the 12^th floor is inaccessible because the counter is mounted 40 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.

4) The Executive Director’s Reception Counter at the Executive Director’s Office of the Memphis Police Department on the 12^th floor is inaccessible because the counter is mounted 41 inches high. Provide a counter on an accessible route such that a portion of the counter is at least 36 inches wide and no more than 36 inches above the finished floor, or provide an auxiliary counter with a maximum height of 36 inches in close proximity to the main counter, or provide equivalent facilitation. Equivalent facilitation may be provided in the form of a folding shelf attached to the main counter, an auxiliary table nearby, a clip board made available to the public, or other means. Standards §§ 7.2(2), 4.3.

C. Courtrooms

1) Division I

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

b) The Division I Courtroom containing 90 seats is inaccessible because insufficient wheelchair accessible seating is provided. Provide 4 wheelchair seating areas, each with a minimum clear ground or floor space of 66 inches wide by 48 inches deep for forward or rear access, or 66 inches wide by 60 inches deep for side access. Ensure that the ground or floor at all wheelchair locations is level, firm, stable, and slip resistant; that wheelchair seating areas are an integral part of the fixed seating plan and are located so as to provide people with physical disabilities a choice of lines of sight comparable to those available for members of the general public; that wheelchair seating areas adjoin an accessible route that also serves as a means of egress in case of emergency; and that at least one fixed companion seat is provided next to each wheelchair seating area. Standards §§ 4.1.3(19)(a), 4.5, 4.33.

2) Division II

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

b) The Division II Courtroom containing 90 seats is inaccessible because there is insufficient seating provided for persons using wheelchairs. Provide 4 wheelchair seating areas, each with a minimum clear ground or floor space of 66 inches wide by 48 inches deep for forward or rear access, or 66 inches wide by 60 inches deep for side access. Ensure that the ground or floor at all wheelchair locations is level, firm, stable, and slip resistant; that wheelchair seating areas are an integral part of the fixed seating plan and are located so as to provide people with physical disabilities a choice of lines of sight comparable to those available for members of the general public; that wheelchair seating areas adjoin an accessible route that also serves as a means of egress in case of emergency; and that at least one fixed companion seat is provided next to each wheelchair seating area. Standards §§ 4.1.3(19)(a), 4.5, 4.33.

3) Division III

a) The Division III Courtroom is inaccessible to people with hearing impairments because although there are 50 or more fixed seats, there is no assistive listening system. Provide a permanently installed assistive listening system serving the fixed seating. Ensure that the seating served by the system is located within a 50 foot viewing distance of the stage or playing area and has a complete view of the stage or playing area. Provide 3 receivers for use by the general public and signage indicating their availability. 28 C.F.R. § 35.160; Standards §§ 4.30, 4.33.

b) The Division III Courtroom containing 75 seats is inaccessible because there is insufficient accessible seating provided for persons using wheelchairs. Provide 4 wheelchair seating areas, each with a minimum clear ground or floor space of 66 inches wide by 48 inches deep for forward or rear access, or 66 inches wide by 60 inches deep for side access. Ensure that the ground or floor at all wheelchair locations is level, firm, stable, and slip resistant; that wheelchair seating areas are an integral part of the fixed seating plan and are located so as to provide people with physical disabilities a choice of lines of sight comparable to those available for members of the general public; that wheelchair seating areas adjoin an accessible route that also serves as a means of egress in case of emergency; and that at least one fixed companion seat is provided next to each wheelchair seating area. Standards §§ 4.1.3(19)(a), 4.5, 4.33.

D. Drinking Fountains:

1) Near Division I Courtroom on the Basement Level:

a) The drinking fountain is inaccessible because the spout height is 40 inches above the finished floor. Provide at least one drinking fountain with a spout height no higher than 36 inches, measured from the finished floor or ground surface to the spout outlet; and a spout located at the front of the unit that directs the water flow in a trajectory that is nearly parallel to the front of the unit and is positioned so the flow of water is within 3 inches of the front edge of the fountain and at least 4 inches high. Ensure that fountain controls are operable with one hand, require 5 lbf or less to operate without tight grasping, pinching, or twisting of the wrist; and are front mounted or side mounted near the front edge. Standards §§ 4.15, 4.27.4, Fig. 27.

b) The route near drinking fountain is inaccessible because the fountain is not detectable to a blind person using a cane. Provide an accessible route at this location such that there are no objects protruding more than 4 inches into the circulation path with their leading edges at a height between 27 and 80 inches above the finished floor and without cane detectable barriers. Standards § 4.4.

2) Between toilet rooms in the Basement Level:

a) The drinking fountain is inaccessible because the spout height is 39 inches above the finished floor. Provide at least one drinking fountain with a spout height no higher than 36 inches, measured from the finished floor or ground surface to the spout outlet; and a spout located at the front of the unit that directs the water flow in a trajectory that is nearly parallel to the front of the unit and is positioned so the flow of water is within 3 inches of the front edge of the fountain and at least 4 inches high. Ensure that fountain controls are operable with one hand, require 5 lbf or less to operate without tight grasping, pinching, or twisting of the wrist; and are front mounted or side mounted near the front edge. Standards §§ 4.15, 4.27.4, Fig. 27.

3) Memphis Police Department office on the 12^th floor:

a) Although 3 drinking fountains are provided, there is no accessible drinking fountain because the spout heights range in height from 38 to 40 inches above the finished floor. Provide at least one drinking fountain with a spout height no higher than 36 inches, measured from the finished floor or ground surface to the spout outlet; and a spout located at the front of the unit that directs the water flow in a trajectory that is nearly parallel to the front of the unit and is positioned so the flow of water is within 3 inches of the front edge of the fountain and at least 4 inches high. Ensure that fountain controls are operable with one hand, require 5 lbf or less to operate without tight grasping, pinching, or twisting of the wrist; and are front mounted or side mounted near the front edge. Standards §§ 4.15, 4.27.4, Fig. 27.

E. Toilet Rooms

1) Basement Level Men’s Toilet Room with Stalls

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

b) Although the facility contains an emergency alarm system, the alarm system is inaccessible because no visual alarm is provided. 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.

c) The soap dispenser is inaccessible because the controls are mounted at 60 inches above the finished floor with a required 24 inch reach over an obstruction. Provide a soap dispenser such that the controls comply with Fig. 5 for a forward reach or with Fig. 6 for a side reach and such that it is accompanied by clear floor space of 30 by 48 inches that allows a forward or parallel approach, respectively, by a person using a wheelchair. Standards §§ 4.27.2, 4.27.3, 4.2.4, 4.2.5, 4.2.6.

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

e) 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.

f) 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.

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

2) Basement Level Women’s Toilet Room with Stalls

b) Although the facility contains an emergency alarm system, the alarm system is inaccessible because no visual alarm has been provided. 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.

c) The soap dispenser is inaccessible because the controls are mounted at 60 inches above the finished floor with a required reach of 24 inches over an obstruction. Provide a soap dispenser such that the controls comply with Fig. 5 for a forward reach or with Fig. 6 for a side reach and such that it is accompanied by clear floor space of 30 by 48 inches that allows a forward or parallel approach, respectively, by a person using a wheelchair. Standards §§ 4.27.2, 4.27.3, 4.2.4, 4.2.5, 4.2.6.

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

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

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

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

3) 12^th Floor (Memphis Police Department) Men’s Toilet Room with Stalls

a) The signage provided is inaccessible because it does not display the International Sign of Accessibility, nor does it have Braille orraised characters. Provide a toilet room sign with the International Symbol of Accessibility and raised and Braille characters mounted on the wall adjacent to the latch side of the door with the centerline of the sign 60 inches above the finished floor and situated such that a person can approach within 3 inches of the sign without encountering an obstruction or standing within a door swing. Standards §§ 4.1.2(7)(d), 4.30.1, 4.30.4, 4.30.5, 4.30.6, 4.30.7.

b) The entrance to the Men’s Toilet Room with Stalls is inaccessible because the vestibule between doors is only 24 inches deep. Provide an accessible entrance to this room such that the space between any two doors in series is at least 48 inches plus the width of any door swinging into the space. Ensure that doors in series swing either in the same direction or away from the space between the doors. Standards § 4.13.7, Fig. 26.

c) Although an audible alarm is provided in this facility, there is no visual alarm appliance in the toilet room. Provide a visual alarm appliance in the toilet room. Standards §§ 4.28.1, 4.28.3.

d) The soap dispenser is inaccessible because the controls are mounted at 58 inches above the finished floor with a required 24 inch reach over an obstruction. Provide a soap dispenser such that the controls comply with Fig. 5 for a forward reach or with Fig. 6 for a side reach and such that it is accompanied by clear floor space of 30 by 48 inches that allows a forward or parallel approach, respectively, by a person using a wheelchair. Standards §§ 4.27.2, 4.27.3, 4.2.4, 4.2.5, 4.2.6.

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

f) The door to the accessible stall is 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.

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.

4) 12^th Floor (Memphis Police Department) Women’s Toilet Room with Stalls

a) The signage provided is inaccessible because it does not display the International Sign of Accessibility, nor does it have Braille or raised characters. Provide a toilet room sign with the International Symbol of Accessibility and raised and Braille characters mounted on the wall adjacent to the latch side of the door with the centerline of the sign 60 inches above the finished floor and situated such that a person can approach within 3 inches of the sign without encountering an obstruction or standing within a door swing. Standards §§ 4.1.2(7)(d), 4.30.1, 4.30.4, 4.30.5, 4.30.6, 4.30.7.

b) The entrance to the Women’s Toilet Room with Stalls is inaccessible because the vestibule area is only 24 inches deep. Provide an accessible entrance to the Women’s Toilet Room with Stalls at the Memphis Police Department (12^th floor), such that the space between any two doors in series is at least 48 inches plus the width of any door swinging into the space. Ensure that doors in series swing either in the same direction or away from the space between the doors. Standards § 4.13.7, Fig. 26.

c) The toilet room door swings into the required clear floor space at the paper towel dispenser. Ensure that no door swings into the required clear floor space at any accessible fixture. Standards § 4.22.2.

d) Although the facility contains an emergency alarm system, the alarm system is inaccessible because no visual alarm has been provided in the Women’s Toilet Room with Stalls. 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.

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

f) 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.

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

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.

3. Sexual Assault Resource Center. Within 12 months of the effective date of this Agreement, the City or the Lessor will complete the following modifications: (New construction)

A. Parking:

1) 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.

2) The van accessible parking reserved for persons with disabilities lacks the appropriate signage. At van accessible spaces, provide a “Van-Accessible” sign located below the International Symbol of Accessibility such that the sign cannot be obstructed by vehicles parked in the space. Standards §§ 4.1.2(5), 4.6.4, 4.30.7(1).

B. Drinking fountain: Although 1 drinking fountain is provided, there is no accessible drinking fountain because the water height is not at least four inches high, the control requires a pressure of 15 pounds to operate, and there is not at least 27 inches knee space height. In addition, there is no access for people who have trouble bending or stooping. Provide at least one drinking fountain with a spout height no higher than 36 inches, measured from the finished floor or ground surface to the spout outlet; and a spout located at the front of the unit that directs the water flow in a trajectory that is nearly parallel to the front of the unit and is positioned so the flow of water is within 3 inches of the front edge of the fountain and at least 4 inches high. Ensure that fountain controls are operable with one hand, require 5 lbf or less to operate without tight grasping, pinching, or twisting of the wrist; and are front mounted or side mounted near the front edge. Additionally, provide a drinking fountain that is accessible to people who have difficulty bending or stooping. This can be accommodated by the use of a “hi-lo” fountain; by providing one fountain accessible to those who use wheelchairs and one fountain at a standard height convenient for those who have difficulty bending; by providing a fountain accessible to people who use wheelchairs and a cup dispenser; or by such other means as would achieve the required accessibility for each group of people. Standards §§ 4.1.3(10), 4.15, 4.27.4, Fig. 27.

C. Men and Women’s Toilet Rooms with Stalls:

1) The toilet room sign for each toilet room is mounted with its centerline at 66.5 inches above the finished floor. Provide a toilet room sign in each toilet room with raised and Braille characters mounted on the wall adjacent to the latch side of the door with the centerline of the sign 60 inches above the finished floor and situated such that a person can approach within 3 inches of the sign without encountering an obstruction or standing within a door swing. Standards §§ 4.1.2(7)(d), 4.30.1, 4.30.4, 4.30.5, 4.30.6.

2) The toilet room door to each toilet room is inaccessible because the pressure required to open the door is 12 pounds for the women’s toilet room and 10 pounds for the men’s toilet room. Provide a door to each toilet room that requires no more than 5 pounds of force to open. Standards §§ 4.1.3(7)(b), 4.13.11(2)(b).

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

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

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