The Americans with Disabilities Act (ADA) is a comprehensive federal civil rights statute enacted in 1990. Comprised of five major parts, or “titles,” the ADA’s stated purpose was to provide a “clear and comprehensive national mandate for the elimination of discrimination against individuals with disabilities.” It is estimated by the U.S. Census Bureau that over 50 million U.S. residents have a disability, and over 50% of senior citizens age 65 or older have a disability.
Title II requires that all public entities with more than 50 employees perform a self-evaluation, prepare a transition plan, and make the plan available for three years. While the City has always sought to comply with the requirements of the ADA legislation, in 2017 cities across Tennessee were required to formally commit to TDOT to prepare a comprehensive Self-Evaluation & Transition Plan. Failure to do so, would make a city ineligible for federal and state road funding assistance.
The City of Brentwood has completed this self-evaluation of all City facilities inside and outside of the public right-of-way (ROW), including programs and procedures, and prepared a Transition Plan that outlines the necessary steps to be fully compliant. The plan is attached for your review. Please note that it is split into multiple files due to the size of the document. The individual files include the main narrative and four separate appendices.
The goal of the plan is to ensure that all residents and visitors are able to access all services, programs, and activities. The City will promptly investigate any formal grievance filed according to the approved grievance procedures. Additionally, the City will include annual budgetary allotments to make required improvements that will eventually make the various facilities fully accessible, with emphasis given to the improvements that most impact the ability of persons with disabilities to access facilities or programs. Where access cannot be provided, alternate means to provide the same opportunities to persons with disabilities will be provided.
In performing this self-evaluation, all means of pedestrian traffic within the City’s right-of-way (ROW), including sidewalks, crosswalks, and curb ramps were evaluated and documented. Areas open to the public were assessed at the following City facilities:
- Park Facilities (Multiple Facilities City-wide)
- Ravenswood Mansion
- Safety Center East (Public Accessible areas only)
- Service Center (Public Accessible areas only)
- Fire Station No. 2 (Public Accessible areas only)
- Cool Springs House
- City Hall (Public Accessible areas only)
- John P. Holt Brentwood Library
Areas of these facilities open to the public generally include parking lots, walks, park amenities, and areas within buildings that are not restricted to employees. Some buildings or areas of certain buildings have infrequent public access and were evaluated under the same guidelines.
In addition to City facilities, the self-evaluation reviewed existing City policies and procedures within each department. A survey questionnaire was distributed to each department and followed by interviews or other data gathering if needed to better understand the responses or the operation of each department. Key items reviewed within each department included ADA-specific training of employees, potential obstacles to accessibility and accommodation of persons with disabilities, review of publications produced by each department, and staff suggestions to help them accommodate persons with disabilities. Following this review, recommendations were made to improve accessibility of programs for each department. A copy of the survey responses is included in Appendix C.
It is the goal of the City to make facilities for all services, programs and activities fully accessible within 10 years, however this will be largely dependent on several economic factors and any future changes to the ADA Accessibility Guidelines (ADAAG) or other unforeseen requirements. The City has committed to provide training for staff on the requirements of the ADA and to make accommodations for employees with disabilities, many of which can be done without costly architectural renovations. The Transition Plan will be reviewed and updated periodically to ensure the City is fully compliant with current ADAAG standards.
During preparation of the plan staff solicited feedback from the public through various social media outlets as well as by posting the draft plan on the City's website prior to formal presentation to the Commission. Feedback received to-date is included in Appendix D. Future feedback will be included in future revisions to the plan.
The results of the self-evaluation identified a number of barriers at City facilities, in and out of the right-of-way. The estimated cost to correct the deficiencies outside of the right-of-way is $59,750. The total cost to correct the deficiencies noted within the right-of-way is $1,777,000. The degree to which these barriers limited accessibility and their priority for corrective action was subjectively categorized as “high”, “medium”, or “low.” “High” priority included barriers that effectively prohibited access to a facility, present a safety hazard, or are in an area of high pedestrian traffic.
All improvements were further categorized into 10 one-year phasing programs to spread out the cost for implementation and address the most serious deficiencies at the most used areas of the city. The actual implementation schedule, budgeting, and prioritization will be determined by administration and is likely to be impacted by any complaints/grievances received, new regulations and requirements, and availability of funding. Each year going forward, the actual funding amount will be discussed and approved as part of the annual Capital Improvement Program (CIP) process.
Staff is hereby requesting the Commission adopt the attached plan for submission to TDOT in accordance with its requirements.
Please direct any questions to Mike Harris, Director of Engineering. |