PROJECT CIVIC ACCESS AGREEMENT BETWEEN
THE UNITED STATES OF AMERICA,
PRINCE GEORGE’S COUNTY, MARYLAND,
THE MARYLAND-NATIONAL CAPITAL PARK AND PLANNING COMMISSION
UNDER THE AMERICANS WITH DISABILITIES ACT
The United States Department of Justice (Department) initiated this matter as a voluntary compliance review of Prince George’s County, Maryland, a body corporate and politic (County) and the Maryland-National Capital Park and Planning Commission (Commission) under title II of the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. §§ 12131-12134, and the Department’s implementing regulation, 28 C.F.R. Part 35. Because the County receives financial assistance from the Department of Justice, the review was also conducted under the authority of section 504 of the Rehabilitation Act of 1973, 29 U.S.C. § 794, and the Department’s implementing regulation, 28 C.F.R. Part 42, Subpart G. The County was selected for this compliance review because there are a large number of people with disabilities who reside in the County, not because of any title II complaint against the County or any evidence of discrimination.
The review was conducted by the Disability Rights Section of the Department’s Civil Rights Division and focused on the County’s compliance with the following title II requirements:
C to conduct a self-evaluation of its services, policies, and practices by July 26, 1992, and make modifications necessary to comply with the Department’s title II regulation, 28 C.F.R. § 35.105;
C to notify applicants, participants, beneficiaries, and other interested persons of their rights and the County’s obligations under title II and the Department’s regulation, 28 C.F.R. § 35.106;
C to designate a responsible employee to coordinate its efforts to comply with and carry out the County’s ADA responsibilities, 28 C.F.R. § 35.107(a);
C to establish a grievance procedure for resolving complaints of violations of title II, 28 C.F.R. § 35.107(b);
C to operate each program, service, or activity so that, when viewed in its entirety, it is readily accessible to and usable by individuals with disabilities, 28 C.F.R. § 35.150, by:
C delivery of services, programs, or activities in alternate ways, including, for example, redesign of equipment, reassignment of services, assignment of aides, home visits, or other methods of compliance or, if these methods are not effective in making the programs accessible,
C physical changes to buildings (required to have been made by January 26, 1995), in accordance with the Department’s title II regulation, 28 C.F.R. § 35.151, and the ADA Standards for Accessible Design (Standards), 28 C.F.R. pt. 36, App. A, or the Uniform Federal Accessibility Standards (UFAS), 41 C.F.R. § 101-19.6, App. A.
C to ensure that facilities for which construction or alteration was begun after January 26, 1992, are readily accessible to and usable by people with disabilities, in accordance with 1) the Department’s title II regulation and 2) the Standards or UFAS, 28 C.F.R. § 35.151;
C to ensure that communications with applicants, participants, and members of the public with disabilities are as effective as communications with others, including furnishing auxiliary aids and services when necessary, 28 C.F.R. § 35.160;
C to provide direct access via TTY (text telephone) or computer-to-telephone emergency services, including 9-1-1 services, for persons who use TTY’s and computer modems, 28 C.F.R. § 35.162;
C to provide information for interested persons with disabilities concerning the existence and location of the County’s accessible services, activities, and facilities, 28 C.F.R. § 35.163(a); and
C to provide signage at all inaccessible entrances to each of its facilities, directing users to an accessible entrance or to information about accessible facilities, 28 C.F.R. § 35.163(b).
As part of its compliance review, the Department reviewed the following facilities, which – because construction or alterations commenced after January 26, 1992 – must comply with the ADA’s new construction or alterations requirements: Bunker Hill Fire Station, County Police Department (Eastover Police Station), DPW&T Trip Center, Hyattsville District Court, Cheverly Health Center, Upper Marlboro Library, County Correctional Facility, Largo Government
Center, Hyattsville Branch Library, and County Services Building.
The Department’s program access review covered those of the County’s programs, services, and activities that operate in the following facilities: Prince George’s County Courthouse, Clinton Police Station, D. Leonard Dyer Regional Health Center, Harriet L. Hunter Senior Center, Laurel Library Branch, Prince George’s House, Clinton Library, Beltsville Fire Station #41, Department of Public Works and Transportation (Marburger Building), Cora B. Wood Senior Center, Police Services Complex, Police District II, New Carrollton Library, Spauldings Branch Library, County Administration Building, RMS Building, Hyattsville Justice Center Complex, District 1 Police Station, Central Communications Facility, Hillcrest Heights Branch Public Library, Beltsville Library Branch, Beltsville Police Station, Glenarden Branch Library, Fairmount Heights Branch Library, 9400 Peppercorn Place, County Health Department (1701 McCormick Drive, Largo), Women’s Wellness Center, Prince George’s County Office of the Sheriff, Laurel Health Department, County Health Department (1801 McCormick Drive, Largo), and Prince George’s County Health Department WIC Program.
The Department reviewed the County’s policies and procedures regarding emergency management and disaster prevention, and sidewalk maintenance to evaluate whether persons with disabilities have an equal opportunity to utilize these programs.
The Department reviewed the following recreational facilities that are located in the County and owned and operated by the Commission: R.M. Watkins Regional Park, Louise F. Cosca Regional Park, Fairland Aquatic Center, Fairland Athletic Complex, Fairland Regional Park Stormwater Demonstration Building, and Fairland Regional Park. The Department did not review any other facilities owned or operated by the Commission; nor did the Department review any policies or procedures of the Maryland-National Capital Park and Planning Commission.
1. The ADA applies to the County because it is a “public entity” as defined by title II. 42 U.S.C. § 12131(1).
2. The Department is authorized under 28 C.F.R. Part 35, Subpart F, to determine the compliance of the County with title II of the ADA and the Department's title II implementing regulation, to issue findings, and, where appropriate, to negotiate and secure voluntary compliance agreements. Furthermore, the Attorney General is authorized, under 42 U.S.C. § 12133, to bring a civil action enforcing title II of the ADA should the Department fail to secure voluntary compliance pursuant to Subpart F.
3. The Department is authorized under 28 C.F.R. Part 42, Subpart G, to determine the County’s compliance with section 504 of the Rehabilitation Act of 1973, to issue findings, and, where appropriate, to negotiate and secure voluntary compliance agreements. Furthermore, the Attorney General is authorized, under 29 U.S.C. § 794 and 28 C.F.R. §§ 42.530 and 42.108-110, to suspend or terminate financial assistance to the County provided by the Department of Justice should the Department fail to secure voluntary compliance pursuant to Subpart G or to bring a civil suit to enforce the rights of the United States under applicable federal, state, or local law.
4. The parties to this Agreement are the United States of America; Prince George’s County, Maryland; and the Maryland-National Capital Park and Planning Commission.
5. In order to better serve persons with disabilities who reside in this County, highlight access for persons with disabilities as a priority of this County's governance, and avoid the burdens and expenses of an investigation and possible litigation, the parties enter into this Agreement.
6. In consideration of, and consistent with, the terms of this Agreement, the Attorney General agrees to refrain from filing a civil suit in this matter regarding all matters contained within this Agreement, except as provided in the section entitled “Implementation and Enforcement.” The parties’ expectation is that, once the actions set forth in this Agreement have been taken, the facilities surveyed by the Department will be in compliance with the architectural requirements of title II of the ADA.
ACTIONS TAKEN BY PRINCE GEORGE’S COUNTY
7. Prince George’s County established a Commission for Persons with Disabilities in 1985.
8. The County was a recipient of the National Association of Counties Award in 1998 for the County’s Disability Awareness Training for its Public Safety Personnel, and educates its student police officers on the rights of citizens with disabilities.
9. The County has an ADA Coordinator as well as an ADA Coordinator for each department, agency or office. An annual report is provided to the County’s Chief Administrative Officer and includes information regarding reasonable accommodation requests, the outcome of the requests, grievances, and a description of any auxiliary aids provided to assist a person with a disability to participate in County programs, services, and activities. The County ADA Coordinator meets with departmental ADA coordinators to discuss interdepartmental issues.
10. The County and its individual departments and agencies conducted a self-evaluation survey between August 1, 1992 and January 1993, and prepared a subsequent Correction Plan describing the steps each department would take to ensure that citizens with disabilities would have access to all County services, programs and activities.
11. The County developed a formal transition plan dated June 23, 1993, and implemented an action plan for barrier removal. Several items identified in that plan have already been completed and include (but are not limited to) the following:
A. the construction of accessible toilet rooms at several County facilities;
B. the construction or modification of accessible parking, curb cuts and ramps at several County facilities; and
C. the replacement of inaccessible faucets, door handles and door closures in several County offices.
12. The County is currently expanding the availability of TTY’s throughout the County government. It also relies on the use of the Maryland Relay System and the County relay system, and every departmental ADA coordinator have been trained in relay services usage.
13. 9-1-1 Telephone Emergency Services have been expanded and enhanced based on the recommendations of an advisory committee made up of citizens who are deaf, public safety staff representatives and the Individuals with Disabilities Division. Each 9-1-1 call station is equipped with a TTY or computer equivalent.
14. On a yearly basis, the County Department of Public Works and Transportation has been removing and replacing many sidewalks and curb cuts, and installing new, accessible curb cuts. For the last twelve years, approximately 2.5 million dollars has been spent on this endeavor.
15. The County has adopted an employment policy that prohibits discrimination based on disability and provides for reasonable accommodation for job applicants and employees.
16. ADA awareness and training are incorporated into the curriculum of a variety of courses offered by the Office of Personnel Training Institute.
17. The County’s Website includes a section on “Emergency Planning for People with Special Needs.”
18. Within four months of the effective date of this Agreement, the County will adopt the attached Notice (Attachment A); distribute it to all agency heads; publish the Notice in a local newspaper of general circulation serving the County; post the Notice on its Internet Home Page; and post copies in conspicuous locations in its public buildings. It will refresh the posted copies, and update the contact information contained on the Notice, as necessary, for the life of this Agreement. Copies will also be provided to any person upon request.
19. Within four months of the effective date of this Agreement, and on yearly anniversaries of this Agreement until it expires, the County will implement and report to the Department its written procedures for providing information for interested persons with disabilities concerning the existence and location of the County’s accessible programs, services, and activities.
GENERAL EFFECTIVE COMMUNICATION PROVISIONS
20. Within three months of the effective date of this Agreement, the County will identify sources of qualified sign language and oral interpreters, real-time transcription services, and vendors that can put documents in Braille, and will implement and report to the Department its written procedures, with time frames, for fulfilling requests from the public for sign language or oral interpreters, real-time transcription services, and documents in alternate formats (Braille, large print, cassette tapes, etc.).
21. The County will take steps to ensure that all appropriate employees are trained and practiced in using the Maryland Relay Service to make and receive calls.
22. Within three months of the effective date of this Agreement, the County will develop procedures for answering 9-1-1 calls that include training all call takers to use a TTY to take 9-1-1 calls, to recognize a “silent” open line as a potential TTY call and respond by TTY, and to ensure that TTY calls are answered as quickly as other calls received.
23. The County will monitor its incoming 9-1-1 TTY calls to ensure they are answered as quickly and accurately as other calls received.
24. The County will incorporate correct TTY call-taking procedures into 9-1-1 call takers’ performance evaluations and will amend its personnel policies to include written disciplinary procedures for call takers who fail to perform TTY call-taking consistent with the training and procedures. The County will implement and report to the Department its evaluation and procedures within three months of the effective date of this Agreement.
LAW ENFORCEMENT AND EFFECTIVE COMMUNICATION
25. Within twelve months of the effective date of this Agreement, the County will adapt for its own use and implement the Prince George’s County Sheriff’s Office and Police Department’s Policy Statement on Effective Communication with People Who are Deaf or Hard of Hearing [Attachment C] and distribute to all sheriff and police department officers the Guide for Law Enforcement Officers When in Contact with People Who are Deaf or Hard of Hearing [Attachment D].
26. Within eighteen months of the effective date of this Agreement, the County will contract with one or more local qualified oral/sign language interpreter agencies to ensure that the interpreting services will be available on a priority basis, twenty-four hours per day, seven days a week, to its police stations and sheriff department or make other appropriate arrangements (such as contracting directly with or hiring qualified interpreters).
27. Within eighteen months of the effective date of this Agreement, the County will ensure that each police station and sheriff’s department or substation and each jail, detention or correctional facility is equipped with a working TTY to enable persons who are deaf, hard of hearing, or who have speech impairments to make outgoing telephone calls. Where inmate telephone calls are time-limited, the County will adopt policies permitting inmates who use TTY’s a longer period of time to make those calls, due to the slower nature of TTY communications compared with voice communications.
28. This Agreement does not address the accessibility of voting equipment or voting systems, including polling place accessibility, or any modifications to polling-related policies and procedures that may be necessary to ensure access for persons with disabilities.
EMERGENCY MANAGEMENT PROCEDURES AND POLICIES
29. If the County contracts with another entity, such as the American Red Cross or another local government, to provide its emergency preparedness plans and emergency response services, the County will ensure that the other entity complies with the following provisions on its behalf.
30. Within twelve months of the effective date of this Agreement, the County will implement and report to the Department its written procedures that ensure that it regularly solicits and incorporates input from persons with a variety of disabilities and those who serve them regarding all phases of its emergency management plan (preparation, notification, response, and clean up).
31. Within twelve months of the effective date of this Agreement, the County will implement and report to the Department its written procedures that ensure that its community evacuation plans enable those who have mobility impairments, vision impairments, hearing impairments, cognitive disabilities, mental illness, or other disabilities to safely self-evacuate or be evacuated by others. Some communities are instituting voluntary, confidential registries of persons with disabilities who may need individualized evacuation assistance or notification. If the County adopts or maintains such a registry, its report to the Department will discuss its procedures for ensuring voluntariness, appropriate confidentiality controls, and how the registry will be kept updated, as well as its outreach plan to inform persons with disabilities of its availability. Whether or not a registry is used, the County plan should address accessible transportation needs for persons with disabilities.
32. Within three months of the effective date of this Agreement, the County will implement and report to the Department its written procedures that ensure that if its emergency warning systems use sirens or other audible alerts, it will also provide ways to inform persons with hearing impairments of an impending disaster. The use of auto-dialed TTY messages to pre-registered individuals who are deaf or hard of hearing, text messaging, e-mails, open-captioning on local TV stations and other innovative uses of technology may be incorporated into such procedures, as well as lower-tech options such as dispatching qualified sign language interpreters to assist with emergency TV broadcasts.
33. Within two years of the effective date of this Agreement, the County will implement and report to the Department its written procedures that ensure that at least one emergency shelter has a back-up generator and a way to keep medications refrigerated (such as a refrigerator or a cooler with ice). Such shelter(s) will be made available to persons whose disabilities require access to electricity and refrigeration, for example, for using life-sustaining medical devices, providing power to motorized wheelchairs, and preserving certain medications, such as insulin, that require refrigeration. The written procedures will include a plan for notifying persons of the location of such shelter(s).
34. Within three months of the effective date of this Agreement, the County will implement and report to the Department its written procedures that ensure that persons who use service animals are not separated from their service animals when sheltering during an emergency, even if pets are normally prohibited in shelters. The procedures will not unnecessarily segregate persons who use service animals from others but may take into account the potential presence of persons who, for safety or health reasons, should not be in contact with certain types of animals.
35. Some of the of the County’s emergency shelters may be owned or operated by other public entities subject to title II or by public accommodations subject to title III and, as such, are subject to the obligation to provide program access or remove barriers to accessibility under the ADA. This Agreement does not limit such future enforcement action against the owners or operators of these facilities by any person or entity, including the Department.
36. Within three months of the effective date of this Agreement and until all emergency shelters have accessible parking, exterior routes, entrances, interior routes to the shelter area, and toilet rooms serving the shelter area, the County will identify and widely publicize to the public and to persons with disabilities and the organizations that serve them the most accessible emergency shelters.
37. To the extent that the County provides opportunities for post-emergency temporary housing to its residents, within 3 months of the effective date of this Agreement, it will develop, implement, and report to the Department its plans for providing equivalent opportunities for accessible post-emergency temporary housing to persons with disabilities. Within one year of the effective date of this Agreement, the County will ensure that information it makes available regarding temporary housing includes information on accessible housing (such as accessible hotel rooms within the community or in nearby communities) that could be used if people with disabilities cannot immediately return home after a disaster if, for instance, necessary accessible features such as ramps or electrical systems have been compromised.
38. Within three months of the effective date of this Agreement, the County will identify all existing records of streets, roads, and highways that have been constructed or altered since January 26, 1992. Paving, repaving, or resurfacing a street, road, or highway is considered an alteration for the purposes of this Agreement. Filling a pothole is not considered an alteration for the purposes of this Agreement. Within three years of the effective date of this Agreement, the County will provide curb ramps or other sloped areas complying with the Standards or UFAS at all intersections of the streets, roads, and highways identified under this paragraph having curbs or other barriers to entry from a street level pedestrian walkway.
39. Beginning no later than three months after the effective date of this Agreement, the County will provide curb ramps or other sloped areas complying with the Standards or UFAS at any intersection having curbs or other barriers to entry from a street level pedestrian walkway, whenever a new street, road, or highway is constructed or altered.
40. Within three months of the effective date of this Agreement, the County will identify all existing records of street level pedestrian walkways that have been constructed or altered since January 26, 1992. Paving, repaving, or resurfacing a walkway is considered an alteration for the purposes of this Agreement. Within three years of the effective date of this Agreement, the County will provide curb ramps or other sloped areas complying with the Standards or UFAS at all places where a street level pedestrian walkway identified under this paragraph intersects with a street, road, or highway.
41. Beginning no later than three months after the effective date of this Agreement, the County will provide curb ramps or other sloped areas complying with the Standards or UFAS at all newly constructed or altered pedestrian walkways where they intersect a street, road, or highway.
WEB-BASED SERVICES AND PROGRAMS
42. Within 1 month of the effective date of this Agreement, and on subsequent anniversaries of the effective date of this Agreement, the County will distribute to all persons – employees and contractors – who design, develop, maintain, or otherwise have responsibility for content and format of its website(s) or third party websites used by the County (Internet Personnel) the technical assistance document, “Accessibility of State and Local Government Websites to People with Disabilities,” which is Attachment H to this Agreement (it is also available at www.ada.gov/websites2.htm).
43. Within three months of the effective date of this Agreement, and throughout the life of the Agreement, the County will do the following:
A. Establish, implement, and post online a policy that its web pages will be accessible and create a process for implementation;
B. Ensure that all new and modified web pages and content are accessible;
C. Develop and implement a plan for making existing web content more accessible;
D. Provide a way for online visitors to request accessible information or services by posting a telephone number or e-mail address on its home page; and
E. Periodically (at least annually) enlist people with disabilities to test its pages for ease of use.
PHYSICAL CHANGES TO FACILITIES
44. The elements or features of the County’s facilities that do not comply with the Standards, including those listed in Attachments I, J, K, and L prevent some persons with disabilities from fully and equally enjoying the County’s services, programs, or activities and constitute discrimination on the basis of disability within the meaning of 42 U.S.C. § 12132 and 28 C.F.R. §§ 35.149 and 35.150. This Agreement shall not be construed as an admission of liability or discrimination by the County.
45. The County will comply with the cited provisions of the Standards when taking the actions required by this Agreement.
46. Within two years of the effective date of this Agreement, the County will install 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.
47. Newly Constructed Facilities: In order to ensure that the following spaces and elements in County facilities, for which construction was commenced after January 26, 1992, are readily accessible to and usable by persons with disabilities, the County will take the actions listed in Attachment I.
48. Altered Facilities: In order to ensure that the following spaces and elements in County facilities, for which alterations commenced after January 26, 1992, are readily accessible to and usable by persons with disabilities, the County will take the actions listed in Attachment J.
49. Program Access in County Existing Facilities: In order to ensure that each of the County’s programs, services, and activities operating at a facility that is the subject of this Agreement, when viewed in its entirety, is readily accessible to and usable by persons with mobility impairments, the County will take the actions listed in Attachment K.
50. Access to County Programs Housed in Others’ Facilities: In order to ensure that the County’s programs, services, and activities that are the subject of this Agreement and that are operated by the County at facilities owned or controlled by other entities, when viewed in its entirety, are readily accessible to and usable by persons with mobility impairments, the County will take the actions listed in Attachment L in accordance with its lease agreements.
51. Access to Recreational Facilities Located in the County but Owned and Operated by the Maryland-National Capital Park and Planning Commission: In order to ensure that recreational facilities are readily accessible to and usable by persons with disabilities, the Maryland-National Capital Park and Planning Commission will take the actions listed in Attachment M. The Commission’s obligations under this Agreement are limited solely to performing those actions listed in Attachment M.
52. Except as otherwise specified in this Agreement, at yearly anniversaries of the effective date of this Agreement until it expires, the County will submit written reports to the Department summarizing the actions the County has taken pursuant to this Agreement. Reports will include detailed photographs showing measurements, architectural plans, work orders, notices published in the newspaper, copies of adopted policies, and proof of efforts to secure funding/assistance for structural renovations or equipment.
53. Throughout the life of this Agreement, consistent with 28 C.F.R. § 35.133(a), the County will maintain the accessibility of its programs, activities, services, facilities, and equipment, and will take whatever actions are necessary (such as routine testing of accessibility equipment and routine accessibility audits of its programs and facilities) to do so. This provision does not prohibit isolated or temporary interruptions in service or access due to maintenance or repairs. 28 C.F.R. § 35.133(b).
54. Within one year of the effective date of this Agreement, the County will develop or procure a two-hour training program on the requirements of the ADA and appropriate ways of serving persons with disabilities. The County will use the ADA technical assistance materials developed by the Department and will consult with interested persons, including individuals with disabilities, in developing or procuring the ADA training program.
55. Within eighteen months of the effective date of this Agreement, the County will deliver its training program to all County employees who have direct contact with members of the public. At the end of that period, the County will submit a copy of its training curriculum and materials to the Department, along with a list of employees trained and the name, title, and address of the trainer.
IMPLEMENTATION AND ENFORCEMENT
56. If at any time the County or Commission desire to modify any portion of this Agreement because of changed conditions making performance impossible or impractical or for any other reason, it will promptly notify the Department in writing, setting forth the facts and circumstances thought to justify modification and the substance of the proposed modification. Until there is written Agreement by the Department to the proposed modification, the proposed modification will not take effect. These actions must receive the prior written approval of the Department, which approval will not be unreasonably withheld or delayed. Nothing in this Agreement requires the County or Commission to violate its current procurement regulations.
57. The Department may review compliance with this Agreement at any time. If the Department believes that the County or Commission has failed to comply in a timely manner with any requirement of this Agreement without obtaining sufficient advance written agreement with the Department for a modification of the relevant terms, the Department will so notify the County or Commission in writing and it will attempt to resolve the issue or issues in good faith. If the Department is unable to reach a satisfactory resolution of the issue or issues raised within 30 days of the date it provides notice to the County or Commission, it may institute a civil action in federal district court to enforce the terms of this Agreement, or it may initiate appropriate steps to enforce title II and section 504 of the Rehabilitation Act.
58. For purposes of the immediately preceding paragraph, it is a violation of this Agreement for the County or Commission to fail to comply in a timely manner with any of its requirements without obtaining sufficient advance written agreement with the Department for an extension of the relevant time frame imposed by the Agreement.
59. Failure by the Department to enforce this entire Agreement or any provision thereof with regard to any deadline or any other provision herein will not be construed as a waiver of the Department's right to enforce other deadlines and provisions of this Agreement.
60. This Agreement is a public document. A copy of this document or any information contained in it will be made available to any person by the County or the Department on request.
61. This Agreement constitutes the entire agreement between the parties on the matters raised herein, and no other statement, promise, or agreement, either written or oral, made by either party or agents of either party, that is not contained in this written Agreement (including its Attachments, which are hereby incorporated by reference), will be enforceable. This Agreement does not purport to remedy any other potential violations of the ADA or any other federal law. This Agreement does not affect the County’s continuing responsibility to comply with all aspects of the ADA and section 504 of the Rehabilitation Act.
62. This Agreement will remain in effect for four years.
63. The person signing for the County represents that he or she is authorized to bind the County to this Agreement.
64. The person signing for the Commission represents that he or she is authorized to bind the Commission to this Agreement.
65. The effective date of this Agreement is the date of the last signature below.
For Prince George’s County, Maryland:
DR. JACQUELINE F. BROWN,
Chief Administrative Officer
Prince George’s County
County Administration Building
14741 Governor Oden Bowie Drive
Upper Marlboro, MD 20772
For the United States:
BRADLEY J. SCHLOZMAN
Acting Assistant Attorney General
JOHN L. WODATCH, Chief
JEANINE WORDEN, Deputy Chief
MARY LOU MOBLEY, Senior Counsel
ELIZABETH BACON, Supervisory Attorney
SUSAN G. QUINN, Investigator
MICHELE ANTONIO MALLOZZI, Architect
U.S. Department of Justice
Civil Rights Division
950 Pennsylvania Avenue, N.W.
Disability Rights Section - NYA
Washington, DC 20530
For The Maryland-National Capital
Park and Planning Commission:
By: ____________________________ Attest:
TRUDYE MORGAN JOHNSON,
Executive Director ___________________________
The Maryland-National Capital Patricia Colihan Barney,
Park and Planning Commission Secretary-Treasurer
Department of Parks and Recreation The Maryland-National Capital
6611 Kenilworth Avenue Park and Planning Commission
Riverdale, Maryland 20737