Wheat_Ridge_ADA_Compliance_Transition_Plan.pdf

UPDATED

February 2019

Americans with Disabilities Act Transition Plan

City of Wheat Ridge | ADA Transition Plan

ORIGINAL PLAN PREPARED IN 2017

This publication has been prepared by Alfred Benesch & Company in partnership with the City of Wheat Ridge.

All information contained herein is expressly prepared for the sole use of the City of Wheat Ridge. Should any portion of this publication be duplicated elsewhere, we request appropriate attribution for such usage.

ACKNOWLEDGEMENTS

Many individuals were involved with the development of the ADA Transition Plan and other accessibility improvements within Wheat Ridge. The active participation of City staff from the Public Works and Engineering Divisions, the City Council and Leadership, and other stakeholders within the community indicates the level of engagement and commitment to improving accessibility in our Community. This assignment could not have been completed without the efforts and cooperation from these the following:

City of Wheat Ridge City Council

City of Wheat Ridge Public Works Department – Engineering Division

Prepared By:

Alfred Benesch & Company

TABLE OF CONTENTS

EXECUTIVE SUMMARY� 1

TRANSITION PLAN� 2

3.1 Design Standards� 4

3.2 Accessibility Practices� 5

3.3 Program Access and Effective Alternative Communication� 5

6.1 Programmatic Accessibility� 8

6.2 Physical Accessibility� 8

7. Transition Plan Implementation� 11

7.1 Goals for the Program� 11

7.2 Prioritization of Barriers� 11

7.3 Strategies to Improve Accessibility� 12

7.4 Implementation Schedule� 13

7.5 Implementation Strategy� 13

7.6 Funding� 15

8. Public Information Sharing & Grievance Procedure� 16

8.1 Public Information Sharing� 16

8.2 Grievance Procedure� 17

9. Monitoring Progress & Updating Plan� 17

APPENDIX A – GLOSSARY OF TERMS� 19

APPENDIX B – CITY POLICY REDARDING THE ADA� 22

APPENDIX C – ADA DESIGN & CONSTRUCTION EXCEPTION FORM� 24

APPENDIX D – ADA COORDINATOR CONTACT INFORMATION� 26

APPENDIX E – PUBLIC OUTREACH MATERIALS AND RESULTS� 28

APPENDIX F – INTERNAL STAFF QUESTIONAIRE AND RESULTS� 54

APPENDIX G – AREA OF PUBLIC FACILITIES ASSESSED� 74

APPENDIX H – OVERVIEW OF ASSESSMENT OF ATTRIBUTES/

PARAMETERS� 76

APPENDIX I – ASSESSMENT FINDINGS� 79

APPENDIX J – BARRIER REMOVAL SCHEDULES & BUDGETS� 82

APPENDIX K – FUTURE TRAINING PROGRAM� 84

APPENDIX L – GRIEVANCE PROCEDURE & FORM� 87

APPENDIX M – SUMMARY OF REMEDIATION WORK COMPLETED� 92

APPENDICES

City of Wheat Ridge | ADA Transition Plan | 1

EXECUTIVE SUMMARY

While the City has been improving accessibility within their corporate limits for years, in 2016, the City’s Engineering Division continued the process of developing a published ADA Transition Plan. The purpose of this Plan is to provide formal guidelines and goals to improve accessibility throughout the City’s transportation network, and serve as a means of formal documentation of the procedures and progress already taken place in accordance with Title II of the Americans with Disabilities Act (ADA). Enacted in 1990, the ADA mandates equal opportunity for individuals with disabilities.

The current self-evaluation focused on pedestrian facilities within the City’s transportation network maintained by the Engineering Division.

These facilities include curb ramps and pedestrian pushbuttons within the public right-of-way (ROW) throughout the City. In 2017, the City anticipates beginning the process to assess sidewalk accessibility within the public ROW.

In conjunction with the sidewalk assessment efforts, the City will also update their GIS database to document those pedestrian facilities with improved accessibility based upon work performed since the last assessment. The past and anticipated future evaluations will provide a basis for a more robust assessment of accessibility in and along City facilities; allow for planning and prioritizing removal of barriers; and develop a road map for any remaining assessments needed. This Transition Plan addresses proposed timelines and anticipated costs associated with the removal of barriers and completing the remaining assessments.

Along with the assessment of pedestrian facilities in the City’s transportation network, the self-evaluation also reviewed the Engineering Division’s programs, procedures, and policies. This process included meetings with different department staff and disseminating an internal staff questionnaire.

Public outreach and involvement was also a conducted consisting of public meetings, user surveys, and an online website.

This Transition Plan is a living document intended to be regularly monitored and updated. Updated versions will incorporate future findings from the actions identified above as well as advancements made towards improving accessibility, implementation of the Plan, and progress towards identified goals.

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1. Overview The purpose of this Transition Plan is to provide guidance to improve accessibility to the City of Wheat Ridge’s transportation network in accordance to Title II of the Americans with Disabilities Act (ADA). The ADA requires a public entity to modify its policies, practices, or procedures, within reason, to avoid discrimination against people with disabilities. This Plan will assist the City’s Engineering Division to identify both physical and non-physical barriers to accessibility and to develop solutions to increase the opportunity of accessibility to all individuals. The main components included:

• Performing a self-evaluation of the City’s current practices, guidelines, standards, policies, and/or procedures or recommended for future use to minimize or eliminate barriers to accessibility within the City of Wheat Ridge public ROW.

• Designating the Department’s ADA Coordinator and their role and responsibilities.

accessibility issues.

This Plan describes the process the City used to perform a self-evaluation and provides recommendations and goals identified as a result of the self-evaluation. The Plan also addresses training provided regarding guidelines, standards, policies, procedures, and/or practices to minimize or eliminate barriers to access within the City.

The City of Wheat Ridge elected officials and staff believe promoting an accessible environment for all persons is essential to good customer service and in line with the quality of life that its residents desire.

The Plan is a living document, subject to review and update periodically.

2. Federal, State, and City Legal Accessibility Requirements

The Americans with Disabilities Act (ADA), enacted on July 26, 1990, is a civil rights law prohibiting discrimination against individuals on the basis of disability.

The ADA consists of five titles outlining protections in the following areas:

TRANSITION PLAN

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Title II of ADA pertains to the programs, activities, and services public entities provide and extend the application of the ADA to include those provided by all state and local government entities. Title II regulations expand upon the general prohibitions of discrimination established under Section 504 of the Rehabilitation Act of 1973. As such, policies, practices, and programs, must comply with the appropriate sections of the ADA.

The ADA requires the City operate their programs so that, when viewed in their entirety, the programs are accessible to and useable by individuals with disabilities. This includes making reasonable modifications in policies, practices, and procedures that deny equal access to individuals with disabilities unless it would result in a fundamental alteration in the program. The City can provide services or benefits to individuals with disabilities through programs that are separate or different such that the separate or different measures are necessary to ensure that benefits and services are equally effective.

A large part of the effectiveness of increasing accessibility and complying with the ADA is taking appropriate steps to ensure that communications with persons with disabilities are as effective as communications with others. This also includes establishing a grievance procedure to provide prompt and equitable resolution of complaints.

Title II of ADA, 28 CFR. Part 35 Sec. 35.105 and Sec. 35.150 requires agencies to conduct a self-evaluation of its facilities, policies, practices, and programs and develop a Transition Plan to outline how reasonable accessibility improvements for individuals, when needed, will be addressed. This Plan includes the findings of the self-evaluation and addresses areas of potential improvement as they pertain to public ROW within and maintained by the City. This Plan also identifies alternative methods of service delivery permissible under 28 CFR Part 35. l 50(a) and (b ).

Once a Transition Plan is developed, it must be submitted for public review before final approval and adoption. At a minimum, a Transition Plan shall include the following elements:

While the ADA requires agencies to reasonably modify its policies, procedures, and facilities to avoid discrimination towards persons with a disability, it is not required to remove all barriers in all situations. The ADA does not require the City to undertake any action that would fundamentally alter the intent of a program or activity, create a hazardous condition, or result in an undue financial burden.

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The ADA Standards and Specifications described in this section are intended to apply to all construction of city streets and the transportation network within the City of Wheat Ridge required to adhere to City requirements under the Engineering Division’s jurisdiction. Pedestrian facilities within the City’s parks and trails network adhere to the Parks and Recreation Department’s standards.

Currently the City utilizes the Americans with Disabilities Act Accessibility Guidelines (ADAAG) and portions of the 2011 Proposed Guidelines for Pedestrian Facilities in the Public Right-of-Way (PROWAG) as the basis for transportation facilities. The City maintains standard construction details for transportation facilities intended to provide accessibility within the transportation network. Additionally, the City utilizes Colorado Department of Transportation requirements for some projects.

For public ROW adjacent to private property, the Streetscape Design Manual was adopted by City Council on March 28, 2011, through Ordinance 1481. This document establishes streetscape design requirements (such as sidewalks and street trees).

The City’s Engineering Standard Construction Details are available at:

http://www.ci.wheatridge.co.us/71/Standard-Construction-Details

CDOT standards are available at:

https://www.codot.gov/business/designsupport/standard-plans/2012-m-standards-plans/2012-m-standards-pdfs/

The Streetscape Design Manual is available at:

http://www.ci.wheatridge.co.us/431/Guiding-Documents

In an effort to account for construction tolerances and to avoid exceeding listed thresholds, designers and construction crews shall target specified slopes and dimensions below the maximum or above the minimum requirements stated in these standards while maintaining positive drainage to the maximum extent possible.

In alterations to existing facilities, where compliance with applicable standards and specifications is technically infeasible or result in undue burden, the alteration shall conform to standards to the maximum extent possible.

Such exceptions shall be documented on the ADA Design and Construction Exception Form contained in Appendix C and submitted to the ADA Coordinator for documentation.

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All future enactments and revisions to legally applicable Federal, State, or City accessibility codes, standards or guidelines, shall be incorporated into these ADA Codes and Standards to the extent that such enactments or revisions exceed the requirements contained herein. Nevertheless, such enactments or revisions shall not decrease any requirement as contained herein.

3.2 Accessibility Practices

The City strives to improve accessibility by leveraging many of its existing and programs. While most of these programs listed below are not intended to specifically address accessibility, they often result in accessibility upgrades or improvements to some extent. These programs include the following:

Section 7 further explains the implementation and scope of these programs as they relate to accessibility improvements.

The City’s goal is to provide an accessible route throughout the transportation network whenever possible. This does not require the City to construct sidewalk where it does not currently exist or remove physical barriers to all existing pedestrian facilities as long as they provide and identify an accessible route to individuals with disabilities, however, the City is working towards improving connectivity and accessibility. Under this concept, the City may choose not to install curb ramps or sidewalks at some locations (or to install them as a lower priority later), as long as a reasonable path of travel is available even without those pedestrian facilities. Installing new sidewalk within residential areas which do not have existing sidewalks is the responsibility of the property owners.

3.3 Program Access and Effective Alternative Communication

The City makes every effort to provide access to its programs for all citizens.

Beyond physical access, this includes program access. In order to effectively communicate with individuals with disabilities, the City provides alternative effective communication methods to its staff members and the public when requested and possible. The following statement is currently included in all City Council Meeting agendas and will be included in public notifications from the Engineering Division:

“Individuals with disabilities are encouraged to participate in all public meetings sponsored by the City of Wheat Ridge. Contact the Public Information Officer at least one week in advance of a meeting if you are interested in participating and need inclusion assistance.”

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The ADA does not require the City to undertake any action that would result in a fundamental alteration in the intent of its program or activity, would create a hazardous condition, or would represent an undue financial and administrative burden. If such a situation should arise, the City will make sure proper documentation is provided as outlined in the ADA and explore potential accommodations that may be appropriate for providing program accessibility in lieu of making actual physical changes in an effort to make their programs and services as accessible as possible.

The majority of the programs the Engineering Division are involved with are Public Meetings. Public Meetings are typically conducted as close to the specific project’s location as possible in an accessible facility.

Accommodations and alternative forms of effective communication are made available to the public upon request.

4. ADA Coordinator Role & Responsibilities The ADA requires public entities with fifty (50) or more employees to designate one or more individuals as responsible employees for monitoring compliance with and investigating potential violations of the ADA. This individual(s) is the primary point of contact for individuals with disabilities to:

• Request auxiliary aids and services, policy modifications, and other accommodations;

• File a complaint with the City regarding accessibility to City programs, activities and services; and/or

• Address ADA concerns from the general public and from other departments and employees of the public entity.

In addition to providing public service, an ADA Coordinator is a valuable resource for City as well. They provide a specifiic contact person knowledgeable with the ADA to answer questions and provide support. The ADA Coordinator also provides consistent feedback on reasonable accommodations, undue burden decisions, and potential accessibility measures.

The ADA does not require the City to undertake any action that would result in a fundamental alteration in the intent or nature of its program or activity, would create a hazardous condition, or would represent an undue burden.

Undue burden means significant difficulty or expense when considering the nature and cost of the accommodation in relation to the size, resources, and facility of the specific operation. Undue burden is determined on a case-by-case basis and shall include concurrence of the ADA Coordinator and must be accompanied by a statement citing the reasons for reaching the conclusion. The determination that undue burdens would result must be based on an evaluation of all resources available for use in the programs.

The Engineering Division currently has a Department ADA Coordinator to serve in this role. A Departmental ADA Coordinator system is anticipated to be implemented in the future to address the needs of employees and

City of Wheat Ridge | ADA Transition Plan | 7 citizens with disabilities for the programs and facilities each department is responsible for within the City. A single ADA Coordinator may be designated in the future for the entire City with each Department ADA Coordinator handling their respective departments. If implemented, this system will identify a Departmental ADA Coordinator within each department who will collaborate with the City’s ADA Coordinator regarding the needs of their department and the programs their department is responsible to manage. The benefit of having a Departmental ADA Coordinator for each department is it provides a subject matter expert and someone with knowledge of department operations and budgets for the ADA Coordinator to work. The City’s ADA Coordinator, or designee, will follow-up with each Departmental ADA Coordinator to coordinate the implementation of plans, programs, policies and procedures and to determine any undue burden specific to that department.

Appendix D identifies the office, address, and telephone number of the Engineering Division’s ADA Coordinator.

5. Public Involvement The City provided several opportunities to receive and encourage the public, advocacy groups, and other stakeholders to provide input and identify areas of concern during the development of this Plan.

The City utilized several different methods of public outreach and involvement including public meeting and open houses, informational handouts, online surveys, and press releases. A Transition Plan webpage was also provided within the City’s website specifically intended for providing updates and soliciting input.

A public open house was held at the Wheat Ridge Recreation Center, a fully accessible facility, on October 5, 2015. Notifications for the event were disseminated on multiple platforms including the City’s webpage, social media outlets, a press release, and flyers to various City facilities and community living centers. The public open house was for both the ADA Transition Plan and the Bicycle & Pedestrian Master Plan Update projects in an effort to increase public turn out and because of the synergies between the two projects. The open house provided an opportunity for interested parties to visit with the Plan development team, provide input on areas of concern, and a handout regarding the Plan’s goals and objectives.

Another method of soliciting input for the Transition Plan was through a public survey made available in a variety of formats (paper, online, audio, etc.). The purpose of this survey was to help identify specific accessibility issues as well as potential areas of improvement throughout the City overall.

Input received from the survey and meetings was evaluated and included in the Transition Plan.

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A second public open house was held at the same Wheat Ridge Recreation Center, on July 19, 2017. Notifications for the event were disseminated on multiple platforms including the City’s webpage, social media outlets, a press release, and bi-lingual flyers. The open house included a presentation of the Transition Plan draft and findings from the self-evaluation. The open house also provided an opportunity for interested parties to visit with the Plan development team and provide input on the draft Transition Plan.

A draft version of the Plan was made available to the public through the project webpage for a period of 30 days. Feedback received was evaluated and the Plan modified as deemed appropriate by the Plan development team.

Appendix E shows the different forms of public involvement used during the development of the Transition Plan described in this section.

6. Self-Evaluation There are two kinds of accessibility, program accessibility and physical accessibility. The City must provide both types of accessibility in order to be free of discrimination. In addition to physical access, programmatic accessibility also includes all of the policies, practices, and procedures allowing people with disabilities an equally effective opportunity to participate in programs and services. Physical accessibility requires a facility provide for an accessible path free of barriers.

6.1 Programmatic Accessibility

The ADA requires the City to evaluate current policies and practices to identify and correct any barriers inconsistent with the intent of the law. Representatives from the Engineering Division have examined current practices and policies related to the ADA, and identified gaps in information or training to address in the Transition Plan. To further refine and understand accessibility issues needing to be addressed, the City administered a questionnaire to department staff in order to provide information on the following:

services, and

• Encounters with physical obstructions and staff disabilities.

A sample of the questionnaire and an overview of the responses are in Appendix F.

6.2 Physical Accessibility

The Engineering Division is responsible for maintaining the City’s transportation network defined as all roadways, sidewalks, on-system shared-use trails, curb ramps, bridges, and other pathways designated for public transportation within City limits and owned by the City. This Plan intends to address accessibility

City of Wheat Ridge | ADA Transition Plan | 9 adjacent to or crossing roadways and bridges and accessibility on facilities designated for shared-use or non-vehicular public transportation. The transportation network does not include facilities maintained by or owned by other agencies or private entities within the jurisdictional boundaries of the City.

An example of this are curb ramps along State highways are addressed as part of CDOT’s ADA Transition Plan and will not directly be the City’s responsibility.

The ADA requires the City to address accessibility across all public facilities under the jurisdiction of the City. For the purpose of this Transition Plan, the Engineering Division focused on the following categories within the public ROW:

• Pedestrian Pushbuttons

Accessibility issues related to other City facilities will be addressed under a separate plan(s).

6.2.1 Method for Evaluations, Data Collection, and Processing As part of the self-evaluation, the City outlined a comprehensive evaluation strategy consisting of physical review and measurement of curb ramps and sidewalks and other pedestrian transportation assets adjacent to or crossing roadways and bridges. At the time of this Plan, the City has evaluated curb ramps and pedestrian pushbuttons and are implementing the evaluation strategy for sidewalks.

These evaluations are based on the 2011 Proposed Guidelines for Pedestrian Facilities in the Public Right-of-Way (PROWAG) published by the United States Access Board. The PROWAG document has not been adopted or approved.

PROWAG is recognized as a best practice and has been recommended for use by the Federal Highway Administration (FHWA). Compliance or non‐ compliance as noted herein, is in reference to PROWAG, assuming it is the standard by which accessibility should be measured.

The City cataloged all existing curb ramps and pedestrian pushbuttons utilizing their Geographic Information System (GIS) database. In 2015 and 2016 the City performed field evaluations and documented a variety of attributes for these assets to determine compliancy. The attributes evaluated generally include the following:

• Curb ramp configuration, geometry, grades, vertical discontinuities, and condition

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The City updated its GIS database to include the sidewalk network and evaluated segments for compliancy. The attributes that were evaluated included the following:

compliant driveway crossings

In addition to these attributes, any curb ramps, pedestrian signals or sidewalks within the City belonging to CDOT or other agencies were identified.

To be compliant under PROWAG, these features must satisfy established criteria specific to each asset type and purpose. If one criteria of an asset is non-compliant, the asset technically does not meet accessibility requirements even though it may be substantially compliant. Appendix G provides information related to the assets surveyed. This information is maintained in the City’s GIS database for easy reference and query for internal staff. It should be noted, all information related to the findings is based upon the self-evaluation performed in 2015 and 2016 for curb ramps and pedestrian pushbuttons and in 2017 for sidewalks.

6.2.2 Overview of Findings

The City has approximately 1,707 locations under their jurisdiction with curb ramps present and constructed to old or non-compliant standards. These locations, while not fully compliant, provide some degree of accessibility. Based upon the self-evaluation field survey, approximately 3% of the curb ramp locations were fully compliant and provided compliant accessibility. Approximately 1,354 locations did not have an acceptable detectable warning panel present. The most prevalent issues with non-compliant curb ramps included improper landing slopes and/or dimensions (80%); improper cross slope or geometry along the ramp or at the curb drop (52%); and/or running slope of the ramp (63%).

Based on the self-assessment, the City has approximately 153 locations with pedestrian pushbuttons under their jurisdiction throughout the transportation network. Based on the self-assessment, only 10% of the pushbuttons meet accessibility requirements (excluding audible features and distance from curb ramp not previously required under PROWAG or ADAAG). The most prevalent issues encountered on non-compliant pushbuttons included improper mounting height, improper location (distance) relative to the curb, and/or no clear space along the travel path. These issues either singularly or in combination were present on approximately 68% of the segments assessed. Approximately 118 pushbutton locations were not equipped with audible features1. Currently, audible features are not mandates at all pedestrian signals and should be evaluated on a case-by-case basis.

1 MUTCD, ADAAG, or PROWAG did not require pedestrian signals/pushbuttons be audible prior to 2012. Upgrading the controller, software, or replacing the pedestrian signal heads may require updating the pedestrian signals to include audible features.

Curb Ramp Findings

Fully Compliant

Landing Space Issues

Ramp Cross Slope

Ramp Running Slope

80%63%

3%

52%

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Based on the self-assessment, the City has approximately 162 locations with pedestrian signals under their jurisdiction throughout the transportation network. Of the 162 locations, 9 did not have pedestrian pushbuttons present. Based on the self-assessment, approximately 72% of the pedestrian signals were not equipped with audible features.

It should be noted for locations with non-compliant curb ramp, pedestrian pushbuttons and/or pedestrian signals, an accessible route may exist within reasonable proximity to some of these locations.

At the time of this plan, it is estimated that the city has approximately 156 miles of sidewalk and all were analyzed for ADA accessibility. Of these 2,116 sidewalk segments evaluated, approximately 11% were compliant for the attributes assessed. Approximately 1,886 segments had accessibility issues. The most prevalent issues with non-compliant sidewalk included improper width (26%);

improper cross slope (11%) or a combination of width and cross slope (51%).

Appendix I provides a summary of curb ramps, pedestrian pushbuttons, and sidewalk findings.

7. Transition Plan Implementation

7.1 Goals for the Program

The overall goal of the Transition Plan is to improve accessibility to the programs, activities, and services provided by the Engineering Division. In order to achieve this goal, the City prioritized the list of identified barriers, identified potential strategies and methods to remove barriers within fiscal constraints, and provided additional guidance to City staff and the public on the requirements of the ADA and the City’s approach to improve accessibility. The City also developed a realistic schedule based on estimated available budget for the removal of barriers and identified potential funding sources and opportunities to remove identified barriers.

7.2 Prioritization of Barriers

Currently, the City primarily addresses identified accessibility issues on a case-by-case basis as determined by the department responsible for the facility and based on available resources. The Engineering Division assesses and updates curb ramps as necessary adjacent to street segments included in their annual Street Resurfacing Project.

Due to differing levels of severity regarding impacts to accessibility and fiscal constraints, the City developed a system to classify, prioritize and schedule implementation of accessibility improvements and barrier removal. This system consists of proximity to public facilities and public transit, level of use by the public, severity of barriers, geographic distribution, and cost.

Considering these factors, along with due consideration of the often conflicting nature of these challenges, the City anticipates utilizing the following criteria to assist staff in prioritizing implementation of accessibility improvements.

Sidewalk Findings

0.1%

25.6%52%

11.2%

10.9%

Compliant

Width Only

Cross Slope Only

Combination of Issues

Running Slope Only (not visible)

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1. Locations where adjacent roadway or infrastructure improvements are taking place.

2. Locations in close proximity to public facilities and high pedestrian traffic areas such as schools, hospitals, City owned facilities, churches, and group living communities.

3. Locations having a higher degree of non-compliance or more significant barriers to accessibility.

4. All other locations not listed above as funding and resources are available.

The Intersection Prioritization Tool provided through the link and available from the Traffic Operations Division was recreated from National Cooperative Highway Research Program (NCHRP) 3-62 research. The worksheets are a product of NCHRP 3-62 and are published in the Transportation Research Record, Journal of the Transportation Research Board, No. 1982, pp. 13-20, entitled “Development of an Intersection Prioritization Tool for Accessible Pedestrian Signal Installation”. The Intersection Prioritization Tool consists of two worksheets.

To prioritize installing accessible pedestrian signals, the City will analyze traffic volumes, current traffic-signal patterns and the complexity of the intersection’s geometry. The City will utilize the Intersection Prioritization Tool criteria created by the National Cooperative Highway Research Program (NCHRP) 3-62 research and the Manual on Uniform Traffic Control Devices to evaluate and prioritize each intersection under consideration, including new traffic signal installations. The Intersection Prioritization Tool provides a method of scoring individual crossings for relative crossing difficulty to visually impaired individuals. This provides a method to compare crossings for priority for installation of accessible pedestrian signals.The worksheets and detailed instructions on completing the worksheets are located at http://www.apsguide.org/appendix_d.cfm.

While the City intends to use these criteria as a guide for prioritization, project level decisions to improve accessibility or modify existing pedestrian facilities will be based on a variety other contributing factors including efficiency of construction efforts and budget, upcoming infrastructure projects which may impact pedestrian facilities, program and master planning input, etc.

Locations identified from the grievance process will be addressed and prioritized on a case-by-case basis.

7.3 Strategies to Improve Accessibility

Implementing physical changes to the City’s infrastructure will take time and resources to properly plan, design, and upgrade existing facilities and remove identified barriers. Beyond targeted barrier removal projects, the City incorporates improving accessibility on capital improvement projects. These projects, both public and private, currently require ADA compliance and review by City staff or designated representatives.

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Additionally, the City plans to include annual budgetary allotments for projects targeting accessibility on top of what is currently programmed, with emphasis given to the removal of barriers based on the Transition Plan priorities. Where access cannot immediately be provided, interim measures will be explored and potentially implemented in order to provide programmatic access to persons with disabilities to the extent feasible pending the remediation of physical barriers.

Recently, the City completed its Bicycle & Pedestrian Master Plan Update.

This effort helped identify specific locations and corridors throughout the City where the public desires increased connectivity. This update will afford the City the benefit of improving accessibility in these highly desired locations during the implementation of the improvements identified. Improving accessibility and potentially expanding the pedestrian facilities network may be done in coordination with the guidance of this master plan.

7.4 Implementation Schedule

The City plans to address and remove barriers to accessibility based upon the priorities outlined in this Transition Plan systematically based on established program priorities and standard City processes and procedures.

The City reserves the right to modify barrier removal priorities in order to allow flexibility in addressing reasonable accommodations for persons with disabilities, community requests, changes in City programs or facility usage, funding availability and constraints, and opportunities with similar capital improvement projects.

For the development of this Transition Plan, the City based programming costs of the different project components on a per ramp, per linear foot of curb and gutter, per square foot of sidewalk, and per each pedestrian pushbutton and signal basis. These programming costs include an allowance for different elements typically associated with the specific improvements and severity of non-compliance. Examples of these components include additional adjacent sidewalk or curb and gutter required to construct curb ramp, retaining walls, landscaping, pavement patching, and ROW. The estimated programming costs also include contingencies for engineering design, construction and surveying. Because of the unknown nature of future capital improvement program projects and budgets, private development and re-development, federal grants, and general operating budgets; the City cannot accurately predict available future annual spending towards improving accessibility. Estimated costs and potential timelines to address the findings of the self-evaluation are provided in Appendix J.

7.5 Implementation Strategy

In general, accessibility improvements along the transportation network addressing curb ramps and sidewalks occur as part of contracted construction projects and activities. The City has legal authority to require

City of Wheat Ridge | ADA Transition Plan | 14 new sidewalks and accessible ramps being constructed or existing facilities with a demonstrated need within the public ROW meet current accessibility requirements.

It is anticipated the majority of the accessibility improvement will be performed in conjunction with other projects and activities occurring within the City. The following illustrates the most anticipated efforts and how each may improve accessibility:

New Construction Projects: Work involving constructing new pedestrian or transportation features in locations within current or future public ROW shall provide accessible features in the project that meet current ADA design standards.

New Improvements Projects: Work involving improving existing public ROW transportation features will provide new or necessary upgrades to existing accessible features in the project area to meet current ADA design standards. Such projects may include road widenings as part of the Capital Improvement Program with associated sidewalk improvements or connectivity projects identified in the Bicycle & Pedestrian Master Plan Update.

Major Maintenance and Rehabilitation Projects: Work involving any alteration or major maintenance activity performed on transportation assets in the existing public ROW shall provide or upgrade accessible features in, or immediately adjacent to, the project to meet current ADA design standards to the extent feasible. Such projects shall include any project requiring pavement reconstruction, major pavement rehabilitation, sidewalk improvements, or the reconstruction of accessibility facilities caused by private permittees. Minor or routine maintenance activities (patching, sealing, etc.) will include accessibility improvements when required by the ADA or when such improvements are consistent with the scope of the activity being performed.

Routine Maintenance & Repair Projects: Work that is limited to specifically repairing spot areas in the public ROW directly affecting accessibility shall provide new or necessary upgrades to impacted existing accessible features to meet current ADA design standards.

Training & Education Projects: The City may provide training, formal or informal, to staff, contractors, engineers, developers, partners, and the general public as deemed appropriate for the purpose of educating and training individuals and entities on ADA requirements, construction standards and processes, and City expectations for projects within the transportation network.

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7.6 Funding

Funding is an important component for improving accessibility within the transportation network. The City endeavors to responsibly fund efforts to improve accessibility whenever practical. It is anticipated funding for improvements and mechanisms for project delivery may come from the following sources:

(STIP), Highway Safety Improvement Program (HSIP), Safe Routes To Schools (SRTS), Congestion Mitigation and Air Quality Improvement (CMAQ), Surface Transportation Program (STP), Colorado Office of Transportation Safety (OTS) grants, Centers for Disease Control and Prevention (CDC), Community Development Block Grant (CDBG), Road Diet Projects, Multi-Modal Transportation Programs, Transportation Enhancement Activities (TEA), Transportation Alternatives (TA), Railway-Highway Crossing Program (RHC), and other pedestrian, mobility, development grants

General Fund)

• Creation of Taxing Districts - Tax Increment Financing District (TIF), Community Improvement District (CID), Tax Allocation District (TAD)

• Adoption of Fees to fund an Enterprise associated with Accessibility

The ADA does not require the City to undertake any action that would result in a fundamental alteration in the intent of its program or activity, would create a hazardous condition, or would represent an undue financial and administrative burden. This determination shall include concurrence of the ADA Coordinator and must be accompanied by a statement citing the reasons for reaching the conclusion. The determination that undue burdens would result must be based on an evaluation of all resources available for use in the programs.

The following outlines the anticipated process for addressing accessibility barriers within the City’s transportation system:

Coordinated/Included with another Project(s):

1. Annually review planned projects and compare project locations to locations of known accessibility issues.

2. Review project areas to identify or confirm and quantify accessibility barriers.

3. Identify available funding to allocate towards accessibility improvements.

2 NOTE: Many of these programs or types of programs are competitive type grants, therefore, agencies aren’t guaranteed to receive these funds. The City will need to monitor these programs and decide whether to pursue the funds.

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4. Develop necessary Contract Document changes to incorporate proposed improvements into the overall project.

5. Inspect constructed improvements and document resolution of accessibility barrier(s).

Standalone Project(s):

1. Review documented accessibility barriers and identify locations without undue burdens to target, consistent with the Plan priorities, construction economics and other environmental factors, and available funding.

proposed improvements into the overall project.

4. Inspect constructed improvements and document resolution of accessibility barrier(s).

Prior to initiating the formal development of the Transition Plan, the City commenced efforts to improve accessibility. These efforts are ongoing and will be re-focused as needed to maintain consistency with the vision of the Plan.

In an effort to provide a better understanding of the ADA and its requirements, the City is developing and will be providing two different ADA training measures. The first training measure will address City specific items such as the Departmental ADA Coordinator, requirements and best practices for public meetings, standardized language for public outreach and correspondence, and ADA support provided by the City. The second training measure will address issues more technical in nature such as current ADA standards and specifications; requirements for providing an accessible route; reasonable accommodations; and the design, construction, maintenance, and inspection of accessible improvements. The measures provided may focus on a combination of these elements or single elements depending on the intended specific purpose or audience. Additional details of the anticipated training program are provided in Appendix K.

8. Public Information Sharing & Grievance Procedure

8.1 Public Information Sharing

The City makes information available to all applicants, participants, beneficiaries, and interested persons regarding the provisions of the ADA and its applicability to the services, programs or activities of the City.

The City is committed to sharing information with the public regarding efforts to improve accessibility throughout the City. Information sharing occurs mostly through contact with the ADA Coordinator, the City’s webpage, press releases and other public notifications, and other typical public outreach methodologies.

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The Transition Plan will continuously be available by contacting the ADA Coordinator or on the City’s website http://co-wheatridge3.civicplus.

com/1543/ADA-Transition-Plan.

8.2 Grievance Procedure

The City of Wheat Ridge has a formal grievance procedure in place to provide citizens with a way to file complaints regarding accessibility and a documented method for the City to handle complaints. Appendix L identifies the City’s grievance procedure and responsibilities towards filing, investigating, and initiating a response and the complaint form.

In the event available funds are insufficient for responding to grievances that request barrier removal or structural modifications, improvements will be prioritized and scheduled, as resources are available.

9. Monitoring Progress & Updating Plan The ADA Transition Plan is a living document. The City will review the ADA Transition Plan every two years or as needed and update it as deemed appropriate to address progress towards improving accessibility and provide for any Plan modifications. The Department ADA Coordinator and appropriate staff will review the Plan to identify updates and incorporate new information pertaining to accessibility and the ADA into the Plan.

Public comments or suggestions received will be incorporated as deemed appropriate.

City staff or representatives will monitor barrier removal and remediation periodically in the field. Their goal is to ensure alterations and newly constructed facilities meet ADA Codes and City Standards. City ADA guidelines will be made available to contractors prior to performing any work. Field inspections may be performed both during and after work is performed.

As new facilities are constructed or re-constructed such as curb ramps, sidewalks, or pedestrian pushbuttons and signals; the Engineering Division will update their GIS database to reflect these improvements.

Updating the GIS database will allow the City to monitor accessibility in specific areas, as well as the City’s overall transportation network.

The GIS database can also be used to re-prioritize and allocate budget appropriately. The database is intended to be a tool to assist the City with accessibility improvements and not the sole method for determining accessibility improvement projects. The Department ADA Coordinator will be available to the general public to provide updated monitoring and status reports upon request.

Appendix A Glossary of Terms

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Appendix A – GLOSSARY OF TERMS Accessible Pedestrian Signal – An integrated device that communicates information about the pedestrian walk phases in non-visual formats.

Accessible Route – a continuous, unobstructed path connecting all accessible elements and spaces including public transportation facilities, parking access aisles, curb ramps, crosswalks at vehicular ways, walks, ramps and lifts.

ABA – means and refers to the Architectural Barriers of 1968 which requires facilities designed, built, altered, or leased with funds supplied by the United States Federal Government be accessible to the public.

ADA – means and refers to the Americans with Disabilities Act as contained and explained in Title 42, Chapter 126 of the United States Code.

ADAAG – Americans with Disabilities Act Accessibility Guidelines, codified at Appendix A to 28 Code of Federal Regulations Part 36 and at Appendix A to 49 Code of Federal Regulations part 37.

Auxiliary Aids and Services – services and devices promoting effective communication or allowing access to goods and services as defined by Titles II and III of the ADA.

Complaint – a claimed violation of the ADA.

Curb Ramp – a short ramp cutting through a curb or built up to it.

Detectable Warning – truncated domes, typically pre-fabricated and installed or stamped into a walkway, providing a tactile surface at the transition from a curb and the street or other hazardous vehicular crossings, assisting pedestrians with vision disabilities in determining when they enter the street.

Disability – a physical or mental impairment substantially limiting one or more of the major life activities of an individual as defined by the ADA.

Facility – All or any portion of buildings, improvements, elements, and pedestrian or vehicular routes located on a site or in a public right-of-way.

Impairment – any physiological disorder, or condition, cosmetic disfigurement, or anatomical loss affecting one or more body systems or any mental or psychological disorder, such as mental retardation, organic brain syndrome, emotional or mental illness, and specific learning disabilities.

Pedestrian Rights-of-Way (PROW) – sidewalks,…