Attachment J – Alterations

Please Note: Paragraph 37 of the Settlement Agreement requires that within 12 months of the effective date of this Agreement, the County will provide signage as necessary to comply with 28 C.F.R. § 35.163(b), after having surveyed all facilities that are the subject of this Agreement for the purpose of identifying those that have multiple entrances not all of which are accessible.

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

1. Within 24 months of the effective date of the Agreement, the County will complete the following modifications to the County Courthouse – Duluth, 100 North 5^th Ave West, Duluth, MN:

a. It is noted that most of the County Courthouse – Duluth was constructed before, and has not been altered since, the effective date of the ADA. The Civil Service Personnel offices, as well as the Law Department’s 5^th floor offices, were altered since the effective date of the ADA.

b. Parking lot

i. The parking reserved for persons with disabilities is inaccessible because six out of the seven standard access aisles have a width of only 50 inches. Provide designated accessible parking spaces that are a minimum of 96 inches wide and served by access aisles at least 60 inches wide. An access aisle may be shared by two accessible parking spaces. Standards §§ 4.1.2(5), 4.1.6(1)(b), 4.6.3, Fig.9.

ii. The signage designating parking as reserved for persons with disabilities is too low. At each space designated as reserved for persons with disabilities, provide a vertical sign with the International Symbol of Accessibility located such that it cannot be obstructed by vehicles parked in the space. Standards §§ 4.1.2(5), 4.1.6(1)(b), 4.6.4, 4.30.7(1).

iii. The van accessible parking space is inaccessible because the multi-floor garage has a vertical clearance of 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. If a van-accessible space is provided at an alternate location, ensure that this space is on the closest possible accessible route of travel, and provide signage directing persons with disabilities to this parking space location. Standards §§ 4.1.2(5)(b), 4.1.6(1)(b), 4.6.5.

c. Routes of travel throughout Courthouse

i. Change machine on the ground floor – The route from the ground level entrance to the stairway is inaccessible because the wall-mounted change dispenser protrudes into the route and is not be 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 §§ 4.1.2(3), 4.1.6(1)(b), 4.4.

ii. Tunnel to City Hall – The tunnel route from the County Courthouse to Duluth City Hall has a slope ranging from 5.5 to 6.3 degrees, is more than 100 feet long without level landings at the top, bottom, or center, and has no handrails. Provide signage directing people with disabilities to the nearest accessible route of travel to the Duluth City Hall. Standards §§ 4.1.3(8), 4.1.6(1)(b), 4.13, 4.30.

iii. Civil Service Personnel Offices – The route from the lower level to the upper level of the Civil Service Personnel offices is inaccessible because the upper level is accessed only via a stairway. The County will continue to provide services upon request to the general public at the accessible lower level of the Civil Service Personnel offices.

d. Signage – Many permanent room signs throughout the Courthouse are inaccessible because they lack raised and Braille 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 §§ 4.1.2(7), 4.1.6(1)(b), 4.30.1, 4.30.4, 4.30.5, 4.30.6.

e. Pay Telephones – The pay telephone on the 1^st floor has its highest operable part at 55 inches above the finished floor, and does not have appropriate signage. Provide an accessible telephone at this location with a clear floor space of at least 30 inches by 48 inches that allows either a forward or parallel approach by a person using a wheelchair such that bases, enclosures, and fixed seats do not impede approaches to the telephone; with the highest operable part of the telephone mounted no more than 48 inches above the floor for a front approach or no more than 54 inches above the floor for a side approach; that is hearing aid compatible and has a volume control mechanism; with telephone books, if provided, located between 15 and 48 inches above the finished floor for a front approach or between 9 and 54 inches above the finished floor for a side approach; with a cord of at least 29 inches long from the telephone to the handset; and with signage that complies with the Standards. Standards §§ 4.1.3(17), 4.1.6(1)(b), 4.31, 4.30.7(2).

f. Elevators

i. 2^nd Street Side – The elevator is inaccessible because it does not signal twice for down, and hoistway signs are centered at 43 inches above the finished floor. 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. 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 §§ 4.1.3(5), 4.1.6(1)(b), 4.10, Figs. 20, 21.

ii. 1^st Street Side – The elevator bank is inaccessible because hoistway signs are centered at 43 inches above the finished 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 §§ 4.1.3(5), 4.1.6(1)(b), 4.10, Figs. 20, 21.

g. Drinking Fountains

i. Ground floor – Although an accessible drinking fountain is provided, 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), 4.1.6(1)(b).

h. Offices and Counters

i. Property Management Office, Room 50, Mezzanine Level – The entrance door is inaccessible because the pressure required to open the door is 7 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards §§ 4.1.3(7)(b), 4.1.6(1)(b), 4.13.11(2)(b).

ii. Sheriff’s Office, Rooms 103 / 105, 1^st Floor –

(1) The entrance door is inaccessible because the pressure required to open the door is 10 pounds, and knob hardware is used. Provide a door that requires no more than 5 pounds of force to open, and 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), 4.1.6(1)(b), 4.13.9, 4.13.11(2)(b).

(2) The information counter at the Sheriff’s Office is inaccessible because its surface is 42 ½ 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 §§ 4.1.1(2), 4.1.6(1)(b), 7.2(2), 4.1.3(1), 4.3.

iii. Moving Violations Office, Room 109, 1^st Floor – The entrance door 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 §§ 4.1.3(7)(b), 4.1.6(1)(b), 4.13.11(2)(b).

iv. County Auditor Accounting Division Office, Room 201, 2^nd Floor – The information counter at the County Auditor Accounting Division Office is inaccessible because its surface is 40 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 §§ 4.1.1(2), 4.1.6(1)(b), 7.2(2), 4.1.3(1), 4.3.

v. County Administrator Office, Room 202, 2^nd Floor – The information counter at the County Administrator Office is inaccessible because its surface is 40 ½ 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 §§ 4.1.1(2), 4.1.6(1)(b), 7.2(2), 4.1.3(1), 4.3.

vi. County Assessor’s Office, Room 212, 2^nd Floor – The information counter at the County Assessor’s Office is inaccessible because its surface is 48 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 §§ 4.1.1(2), 4.1.6(1)(b), 7.2(2), 4.1.3(1), 4.3.

vii. County Auditor Services Office, Room 214, 2^nd Floor – The information counter at the County Auditor Services Office is inaccessible because its surface is 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 §§ 4.1.1(2), 4.1.6(1)(b), 7.2(2), 4.1.3(1), 4.3.

viii. County Attorney’s Office, 5^th floor – The information counter at the County Attorney's Office is inaccessible because its surface is 40 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 §§ 4.1.1(2), 4.1.6(1)(b), 7.2(2), 4.1.3(1), 4.3.

i. Courtrooms and Assembly Areas

i. Arraignment Courtroom – 1^st Floor (existing element)

(1) The door to the arraignment courtroom is inaccessible because a single leaf has an opening width of only 25 inches, and it has knob hardware. 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. In addition, 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. Alternatively, an automatic door opener may be used. Standards §§ 4.1.3(7)(b), 4.13.5 and Fig. 24, 4.13.9.

(2) The route to the defendant area is inaccessible because the gate is only 30 inches wide. Provide an accessible route to the defendant area with a minimum clear width of 36 inches, except at doors and gates, where the width may decrease to 32 inches. Standards §§ 4.1.3(1), 4.3.3, 4.13.5.

(3) The arraignment courtroom containing fixed seating for 45 individuals is inaccessible because it has no wheelchair seating areas. Provide at least 2 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.

ii. County Board Room – Room 200, 2^nd Floor (existing element)

(1) The door to the County Board Room is inaccessible because a single leaf has an opening width of only 25 inches, and it has knob hardware. 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. In addition, 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. Alternatively, an automatic door opener may be used, or the doors will be propped open during sessions. Standards §§ 4.1.3(7)(b), 4.13.5 and Fig. 24, 4.13.9.

(2) The County Board Room containing bench seating for approximately 72 individuals is inaccessible because it has no wheelchair seating areas. Provide at least 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.

iii. County Commissioners Conference Room – 2^nd Floor (existing element)

(1) The entrance door 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.

iv. Juvenile Court (Courtroom # 2) – 3^rd Floor (existing element)

(1) The door to Courtroom # 2 (3^rd floor) is inaccessible because a single leaf has an opening width of only 25 inches, and it has knob hardware. 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. In addition, 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. Alternatively, an automatic door opener may be used or a different, accessible route may be used. Standards §§ 4.1.3(7)(b), 4.13.5 and Fig. 24, 4.13.9.

v. Other Courtrooms – the County shall select and make two out of the following courtrooms, including entrance doors, jury deliberation rooms, and jury toilet rooms, accessible to persons with disabilities: courtrooms #1, 2, and 3 on the first floor; probation courtroom on the 3^rd floor; and courtrooms #1, 2, 3, and 4 on the 4^th floor. At least one courtroom to be made accessible shall include a jury deliberation room and jury toilet rooms. For these courtrooms not selected to be made accessible, the County shall begin to provide court proceedings at an accessible courtroom upon request by persons with disabilities (including parties to a suit, attorneys, witnesses, spectators, and other interested parties). In the event that these courtrooms not selected to be made accessible are modified in the future, each modified courtrooms and associated jury rooms and toilet rooms shall be made accessible.

(1) Courtroom # 1 – 1^st Floor (existing element)

(a) The door to Courtroom # 1 (1^st floor) is inaccessible because a single leaf has an opening width of only 29 inches, and it has knob hardware. 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. In addition, 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. Alternatively, an automatic door opener may be used. Standards §§ 4.1.3(7)(b), 4.13.5 and Fig. 24, 4.13.9.

(b) The jury box is inaccessible because there are steps leading to this area. Provide a ramp or platform lift in compliance with the Standards or establish a procedure for providing access to this area. Any procedure shall not require lifting or carrying persons with mobility impairments or require them to traverse unnecessary or extreme distances. Standards §§ 4.33.5, 4.3.8, 4.8, 4.11.

(c) Courtroom # 1 containing bench seating for approximately 45 individuals is inaccessible because it has no wheelchair seating areas. Provide at least 2 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) The route to the jury room is inaccessible because the doorway is only 29 inches wide. In addition, the door contains knob hardware. Provide an accessible route to the jury room with a minimum clear width of 36 inches, except at doors, where the width may decrease to 32 inches. In addition, 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 §§ 4.1.3(1), 4.1.3(7)(b), 4.3.3, 4.13.5, 4.13.9.

(e) Jury room men’s and women’s single-user toilet rooms – these single user toilet rooms contain a number of inaccessible elements and is not accessible to people with disabilities. Provide an accessible toilet room for each gender such that all of the room’s elements, including signage, door, door hardware, clear floor space, water closet, urinal (if provided), grab bars, lavatory, mirror, controls, and dispensers, comply with the Standards. Standards §§ 4.1.3(11), 4.22, 4.13, 4.16, 4.18, 4.19, 4.26, 4.27, 4.30, Figs. 28, 29.

(2) Courtroom # 2 – 1^st Floor (existing element)

(a) The door to Courtroom # 2 (1^st floor) is inaccessible because a single leaf has an opening width of only 25 inches, and it has knob hardware. 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. In addition, 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. Alternatively, an automatic door opener may be used. Standards §§ 4.1.3(7)(b), 4.13.5 and Fig. 24, 4.13.9.

(c) Courtroom # 2 containing fixed seating for 50 individuals is inaccessible because it has no wheelchair seating areas. Provide at least 2 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) Courtroom # 3 – 1^st Floor (existing element)

(a) The door to Courtroom # 3 (1^st floor) is inaccessible because a single leaf has an opening width of only 25 inches, and it has knob hardware. 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. In addition, 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. Alternatively, an automatic door opener may be used. Standards §§ 4.1.3(7)(b), 4.13.5 and Fig. 24, 4.13.9.

(4) Probation Court – 3^rd floor (existing element)

(a) The door to the Probation Court is inaccessible because a single door leaf has an opening width of only 28 inches, and it has knob hardware. 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. In addition, 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. Alternatively, an automatic door opener may be used. Standards §§ 4.1.3(7)(b), 4.13.5 and Fig. 24, 4.13.9.

(b) The door to the jury deliberation room 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 Probation Court containing bench seating for approximately 50 individuals is inaccessible because it has no wheelchair seating areas. Provide at least 2 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.

(5) Courtrooms # 1 and # 4 – 4^th Floor (existing element)

(a) The doors to Courtrooms # 1 and # 4 (4^th floor) are inaccessible because a single leaf has an opening width of only 25 inches, and the doors have knob hardware. Provide a door to each of these courtrooms with a clear opening of 32 inches with the door open 90 degrees, measured between the face of the door and the opposite stop. In addition, 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. Alternatively, an automatic door opener may be used. Standards §§ 4.1.3(7)(b), 4.13.5 and Fig. 24, 4.13.9.

(b) The jury boxes are inaccessible because there are steps leading to these areas. Provide a ramp or platform lift in compliance with the Standards or establish a procedure for providing access to this area. Any procedure shall not require lifting or carrying persons with mobility impairments or require them to traverse unnecessary or extreme distances. Standards §§ 4.33.5, 4.3.8, 4.8, 4.11.

(c) Courtrooms # 1 and # 4 jury room men’s and women’s single-user toilet rooms – these single user toilet rooms contain a number of inaccessible elements and is not accessible to people with disabilities. Provide an accessible toilet room for each courtroom such that all of the room’s elements, including signage, door, door hardware, clear floor space, water closet, urinal (if provided), grab bars, lavatory, mirror, controls, and dispensers, comply with the Standards. Standards §§ 4.1.3(11), 4.22, 4.13, 4.16, 4.18, 4.19, 4.26, 4.27, 4.30, Figs. 28, 29.

(6) Courtrooms # 2 and # 3 – 4^th Floor (existing elements)

(a) The doors to Courtrooms # 2 and # 3 (4^th floor) are inaccessible because a single leaf has an opening width of only 25 inches, and these doors have knob hardware. Provide a door to each of these courtrooms with a clear opening of 32 inches with the door open 90 degrees, measured between the face of the door and the opposite stop. In addition, 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. Alternatively, an automatic door opener may be used. Standards §§ 4.1.3(7)(b), 4.13.5 and Fig. 24, 4.13.9.

(b) Both courtrooms containing bench seating for approximately 40 individuals each are inaccessible because they have no wheelchair seating areas. Provide at least 2 wheelchair seating areas in each courtroom, 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.

(c) Courtrooms # 2 and # 3 jury room men’s and women’s single-user toilet rooms – these single user toilet rooms contain a number of inaccessible elements and is not accessible to people with disabilities. Provide an accessible toilet room for each courtroom such that all of the room’s elements, including signage, door, door hardware, clear floor space, water closet, urinal (if provided), grab bars, lavatory, mirror, controls, and dispensers, comply with the Standards. Standards §§ 4.1.3(11), 4.22, 4.13, 4.16, 4.18, 4.19, 4.26, 4.27, 4.30, Figs. 28, 29.

j. Law Library – 5^th Floor – The book stacks are inaccessible because the space between stacks is only 30 inches. The County will continue to provide access, including having staff provide assistance upon request.

k. Holding cells area on the 1st floor

i. Toilet facilities – The toilet areas of the holding cells contain a number of inaccessible elements and are not accessible to people with disabilities. Provide an accessible holding cell and toilet area such that all of the room’s elements, including door, clear floor space, water closet, urinal (if provided), grab bars, lavatory, mirror, controls, and dispensers, comply with the Standards. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22, 4.13, 4.16, 4.18, 4.19, 4.26, 4.27, 4.30, Figs. 28, 29.^[1]

l. Toilet Rooms with Stalls

i. Ground Floor Men’s and Women’s Toilet Rooms with Stalls

(1) These toilet rooms are inaccessible. 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.

ii. 1^st Floor Men’s Toilet Room with Stalls

(1) The toilet room sign is mounted on the door and has a centerline at 56 inches above the finished floor. Provide a toilet room sign with the International Symbol of Accessibility and raised and Braille characters. The sign shall be mounted on the wall adjacent to the latch side of the door with the centerline of the sign at 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), 4.1.6(1)(b), 4.30.1, 4.30.4, 4.30.5, 4.30.6, 4.30.7.

(2) The entrance door, which is accessed through a front approach, is inaccessible because it has only 8 inches of clearance 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. Alternatively, provide an automatic door opener at this location. Standards §§ 4.1.3(7)(b), 4.1.6(1)(b), 4.13.6, Fig. 25(a).

(3) 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 §§ 4.1.3(11), 4.1.6(1)(b), 4.22.6, 4.19.6.

(4) 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 §§ 4.1.3(11), 4.1.6(1)(b), 4.22.6, 4.19.4.

(5) No accessible coat hook has been provided. Provide a coat hook at a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that is accompanied by clear floor space of 30 by 48 inches that allows a forward or parallel approach by a person using a wheelchair. Standards §§ 4.1.3(12)(a), 4.1.6(1)(b), 4.25.2, 4.25.3, 4.2.4, 4.2.5, 4.2.6.

(6) The side grab bar at the toilet is inaccessible because its length is 32 inches. Provide a side grab bar that is at least 40 inches in overall length, with the far end mounted at least 52 inches from the rear wall and the closer end 12 inches or less from the rear wall. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.4, 4.17.6, Figs. 30(a), (d).

iii. 1^st Floor Women’s Toilet Room with Stalls

(1) Signage – The toilet room sign is mounted on the door and has a centerline at 57 inches above the finished floor. Provide a toilet room sign with the International Symbol of Accessibility and raised and Braille characters. The sign shall be mounted on the wall adjacent to the latch side of the door with the centerline of the sign at 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), 4.1.6(1)(b), 4.30.1, 4.30.4, 4.30.5, 4.30.6, 4.30.7.

(2) 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 §§ 4.1.3(11), 4.1.6(1)(b), 4.22.6, 4.19.4.

(3) The toilet is inaccessible because there is insufficient clear floor space. Provide clear floor space that complies with Fig. 30 at the toilet. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.4, 4.17.3, Fig. 30.

(4) 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 §§ 4.1.3(12)(a), 4.1.6(1)(b), 4.25.2, 4.25.3, 4.2.4, 4.2.5, 4.2.6.

(5) The side grab bar at the toilet is inaccessible because its length is 32 inches. Provide a side grab bar that is at least 40 inches in overall length, with the far end mounted at least 52 inches from the rear wall and the closer end 12 inches or less from the rear wall. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.4, 4.17.6, Figs. 30(a), (d).

(6) The rear grab bar at the toilet is inaccessible because its length is 32 inches. Provide a rear grab bar that is at least 36 inches in overall length with the closer end no more than 6 inches from the side wall. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.4, 4.17.6, Fig. 30.

iv. 2^nd Floor Women’s Toilet Room with Stalls

(1) This toilet room is inaccessible. 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.

v. 3^rd Floor Men’s Toilet Room with Stalls

(1) The route through the toilet room is inaccessible because the wall-mounted paper towel dispenser protrudes into the route and would not be 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 §§ 4.1.2(3), 4.1.6(1)(b), 4.4.

vi. 3^rd Floor Women’s Toilet Room with Stalls

vii. 4^th Floor Men’s and Women’s Toilet Rooms with Stalls

viii. 5^th Floor Men’s and Women’s Toilet Rooms with Stalls

2. Within 24 months of the effective date of the Agreement, the County will complete the following modifications to The Depot, 506 West Michigan St., Duluth, MN:

a. Although the Depot is leased out to the St. Louis County Heritage and Arts Center, the County continues to pay for improvements and maintenance of the exterior areas and all common areas (including public toilet rooms) of the facility. The Playhouse, classrooms, and museum are leased to and operated by private organizations. It is further noted that the Playhouse and dressing room areas have not been altered since the effective date of the Americans with Disabilities Act.

b. External route to Playhouse backstage: This entrance is inaccessible because there is a two inch change in level at the threshold to the door with broken, sloped pavement within the doorway’s required maneuvering clearance. 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. In addition, provide a door so that the floor or ground area within the required clearances is level and clear. Standards §§ 4.1.3(7)(a), 4.1.6(1)(b), 4.13.6, 4.13.8, 4.5.2, Fig. 25.

c. Ramp from Playhouse to Museum – The ramp is inaccessible because the handrails do not have 12 inch extensions at the top and bottom of the ramp. 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, with ends rounded or returned smoothly to the floor, wall, or post, and that they do not rotate within their fittings. Standards §§ 4.1.2(1), 4.1.2(2), 4.1.6(1)(b), 4.8.5.

d. 1^st floor drinking fountain – Although an accessible drinking fountain is provided, 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), 4.1.6(1)(b).

e. Playhouse (existing element): the County shall make the following modifications within the time frame set forth above. Alternatively, within three months of the effective date of the Agreement, the County will implement and report to the Department its written plan regarding how the program, activity, or service provided at the Playhouse, including dressing rooms and associated toilet and shower rooms, will be made accessible to persons with disabilities:

i. Wheelchair seating areas – The Playhouse containing 280 seats is inaccessible because it only has 2 wheelchair seating areas, these areas are 24 inches deep and 54 inches wide, and they are not on an accessible route of travel from the entrance. 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 admission prices and 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.

ii. Dressing Room Men’s and Women’s Toilet Rooms with Stalls and Showers (existing elements)

(1) These toilet rooms contain a number of inaccessible elements and are not accessible to people with disabilities. Provide an accessible toilet room(s) 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.

(2) The showers contain a number of inaccessible elements and are not accessible to people with disabilities. Provide a shower in each room that is exactly 36 inches wide and 36 inches deep with a 48 inch long and 36 inch wide clear floor space alongside the shower opening, and an L-shaped shower seat mounted on the wall opposite the controls and extending the full depth of the stall; OR a shower that is at least 30 inches deep and 60 inches wide with no curb or threshold and with a 36 inch deep and 60 inch wide clear floor space at the shower opening. Ensure that the shower has grab bars, controls, a shower spray unit, and a seat, curb, and enclosure, if provided, that comply fully with the Standards and with Figs. 35, 36, and 37, as applicable. Standards § 4.21, Figs. 35, 36, 37.

f. Toilet Rooms with Stalls

i. 1^st Floor Men’s and Women’s Toilet Rooms with Stalls

ii. 3^rd Floor Men’s Toilet Room with Stalls

(1) The toilet room sign is mounted on the door. Provide a toilet room sign with the International Symbol of Accessibility and raised and Braille characters. The sign shall be mounted on the wall adjacent to the latch side of the door with the centerline of the sign at 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), 4.1.6(1)(b), 4.30.1, 4.30.4, 4.30.5, 4.30.6, 4.30.7.

(2) The baby changing unit is inaccessible because the controls are mounted at 56 inches above the finished floor. Provide a baby change unit with the controls a maximum height above the finished floor of 48 inches for a forward approach or 54 inches for a side approach and that is accompanied by clear floor space of 30 by 48 inches that allows a forward or parallel approach by a person using a wheelchair. Standards §§ 4.1.3(13), 4.1.6(1)(b), 4.27.2, 4.27.3, 4.2.4, 4.2.5, 4.2.6.

iii. 3^rd Floor Women’s Toilet Room with Stalls

(2) The baby changing station is inaccessible because the controls are mounted over an obstruction – i.e., the weight scale. Provide a baby change station 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 §§ 4.1.3(13), 4.1.6(1)(b), 4.27.2, 4.27.3, 4.2.4, 4.2.5, 4.2.6.

(4) The toilet is inaccessible because its centerline is 19 inches from the side wall. Provide a toilet with a centerline that is 18 inches from the near side wall. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.4, 4.17.3, Fig. 30.

3. Within 24 months of the effective date of the Agreement unless otherwise indicated, the County will complete the following modifications to the Chris Jensen Health and Rehabilitation Center, 2501 Rice Lake Road, Duluth, MN

a. It is noted that most of the Chris Jensen Health and Rehabilitation Center was constructed before, and has not been altered since, the effective date of the ADA. Portions of the Willow area was altered after the ADA’s effective date – specifically, the eating, nurses, medical, and staff areas. The resident’s rooms and attached toilet rooms were not altered since the effective date of the ADA, except for carpeting and painting.

b. Parking Lots

i. Lower level parking lot – Although the parking lot has a total of 75 parking spaces, an inadequate number are designated as reserved for people with disabilities. The two designated accessible parking spaces do not have access aisles, and signage can be obstructed by a vehicle parked in these spaces. In addition, no parking space is designated as being van-accessible. On the shortest accessible route to the accessible entrance, provide 1 van accessible space and 2 standard spaces designated as reserved for people with disabilities. Standard accessible spaces shall be a minimum of 96 inches wide and served by access aisles at least 60 inches wide. Van accessible spaces shall be a minimum of 96 inches wide and served by access aisles at least 96 inches wide. All spaces designated as reserved for people with disabilities shall have vertical signs with the International Symbol of Accessibility located such that they cannot be obstructed by parked vehicles. Van accessible spaces shall have an additional “Van-Accessible” sign located below the International Symbol of Accessibility. Standards §§ 4.1.2(5), 4.1.6(1)(b), 4.6, 4.30.7(1).

ii. Upper level parking lot – Although the parking lot has approximately 100 parking spaces, the five spaces designated as reserved for people with disabilities do not have access aisles, and signage can be obstructed by a vehicle parked in these spaces. In addition, no parking space is designated as being van-accessible. On the shortest accessible route to the accessible entrance, provide 1 van accessible space and 4 standard spaces designated as reserved for people with disabilities. Standard accessible spaces shall be a minimum of 96 inches wide and served by access aisles at least 60 inches wide. Van accessible spaces shall be a minimum of 96 inches wide and served by access aisles at least 96 inches wide. All spaces designated as reserved for people with disabilities shall have vertical signs with the International Symbol of Accessibility located such that they cannot be obstructed by parked vehicles. Van accessible spaces shall have an additional “Van-Accessible” sign located below the International Symbol of Accessibility. Standards §§ 4.1.2(5), 4.1.6(1)(b), 4.6, 4.30.7(1).

c. Routes of travel throughout the Chris Jensen facility

i. 1^st and 2^nd floor “comment boxes” – The routes near the central elevators on the 1^st and 2^nd floors are inaccessible because the wall-mounted “comment boxes” protrude into the routes and would not be detectable to a blind person using a cane. Provide an accessible route at these locations 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.

ii. Birch area courtyard – there is a 2 inch step near the courtyard entrance to the Birch area cafeteria. 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.

d. Central elevator bank (two elevators)

i. The elevator bank is inaccessible because the hall call buttons are centered at 40 inches above the finished floor. Ensure that the call buttons are centered at 42 inches above the finished floor. Standards §§ 4.1.3(5), 4.1.6(1)(b), 4.10.3, Fig. 20.

ii. The elevator bank is inaccessible because hoistway signage is provided on only one door jamb. 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 §§ 4.1.3(5), 4.1.6(1)(b), 4.10.5, Fig. 20.

iii. The elevator bank is inaccessible because the main entry floor button on the car control panel is not designated by a raised star. Ensure that the car control button for the main entry floor is designated by a raised star at the left of the floor designation. Standards §§ 4.1.3(5), 4.1.6(1)(b), 4.10.12, Fig. 23.

iv. The elevator bank is inaccessible because the car position does not ring as the car passes or stops on floors. 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. Standards §§ 4.1.3(5), 4.1.6(1)(b), 4.10.13.

v. The elevator is inaccessible because, although emergency communications are provided, the system is not identified by raised symbol and lettering, the control box door is not operable without tight grasping or pinching, and the system does not work without voice communication. Provide a two-way communication system such that it does not require voice communication, the highest operable part is a maximum of 48 inches above the finished floor of the car, and it is identified by a raised symbol and lettering located adjacent to the device. If the system uses a handset, ensure that the length of the cord from the panel to the handset is at least 29 inches. If the system is located in a closed compartment, ensure that the compartment door hardware operates without tight grasping, pinching or twisting of the wrist. Standards §§ 4.1.3(5), 4.1.6(1)(b), 4.10.14.

e. Ground level and 2^nd floor drinking fountains – these wall-mounted drinking fountains are inaccessible because their knee space is 25 inches high, and there is no access for people who have trouble bending or stooping. Provide a drinking fountain with clear knee space between the bottom of the apron and the finished floor or ground of at least 27 inches high, 30 inches wide, and 17 to 19 inches deep; and a minimum clear floor space of 30 inches by 48 inches to allow a person in a wheelchair to approach the unit facing forward. Alternatively, a cup dispenser may be used. In addition, provide a drinking fountain that is accessible to people who have difficulty bending or stooping. This can be accommodated by the use of a “hi-lo” fountain; by providing one fountain accessible to those who use wheelchairs and one fountain at a standard height convenient for those who have difficulty bending; by providing a fountain accessible to people who use wheelchairs and a cup dispenser, or by such other means as would achieve the required accessibility for each group of people. Standards §§ 4.1.3(10), 4.1.6(1)(b), 4.15.5(1), Figs. 27(a), (b).

f. Willow area unisex single-user visitors toilet room (altered element)

i. The toilet room sign is inaccessible. Provide a toilet room sign with the International Symbol of Accessibility and raised and Braille characters. The sign shall be mounted on the wall adjacent to the latch side of the door with the centerline of the sign at 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), 4.1.6(1)(b), 4.30.1, 4.30.4, 4.30.5, 4.30.6, 4.30.7.

ii. The toilet room entrance door is inaccessible because the pressure required to open the door is greater than 5 pounds. Provide a door that requires no more than 5 pounds of force to open. Standards §§ 4.1.3(7)(b), 4.1.6(1)(b), 4.13.11(2)(b).

iii. 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 §§ 4.1.3(14), 4.1.6(1)(b), 4.28.1, 4.28.3.

iv. 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 §§ 4.1.3(11), 4.1.6(1)(b), 4.22.6, 4.19.6.

v. The soap dispenser is inaccessible because the controls are mounted at 51 inches above the finished floor and a forward reach is required. 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 §§ 4.1.3(13), 4.1.6(1)(b), 4.27.2, 4.27.3, 4.2.4, 4.2.5, 4.2.6.

vi. The paper towel dispenser is inaccessible because the controls are mounted at 61 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 §§ 4.1.3(13), 4.1.6(1)(b), 4.27.2, 4.27.3, 4.2.4, 4.2.5, 4.2.6.

vii. 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 §§ 4.1.3(11), 4.1.6(1)(b), 4.22.6, 4.19.4.

viii. The toilet is inaccessible because its height to the top of the seat is 15 ½ inches from the finished floor, its centerline is 19 inches from the near side wall, the toilet paper dispenser is 40 inches from the rear wall, its flush control is on the closed end, and there are no accessible grab bars. Provide a toilet with a centerline that is 18 inches from the near side wall; a seat that is between17 and 19 inches above the finished floor; clear floor space at the toilet that complies with Fig. 28; and a flush control mounted on the “open” side of the toilet’s clear floor space. Provide a toilet paper dispenser that is mounted within reach, with its top at least 1½ inches under the side grab bar, and centered at least 19 inches above the finished floor. 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, and a side grab bar that is at least 42 inches in overall length, with the far end mounted at least 54 inches from the rear wall and the closer end 12 inches or less from the rear wall. Ensure that the grab bars are mounted 33 to 36 inches above the finished floor; with a diameter between 1¼ and 1½ inches; with 1½ inches between the grab bars and the wall; and at least 1½ inches between the grab bars and any other object, such as a toilet paper dispenser or a toilet seat cover dispenser. Standards §§ 4.1.3(11), 4.1.6(1)(b), 4.22.4, 4.16.2, 4.16.3, 4.16.4, 4.16.5, 4.16.6, 4.26.2, Figs. 28, 29.

g. Typical Resident’s Areas