THE NATIONAL ACADEMIES
National Academy of Sciences
National Cooperative Highway Research Program
NCHRP PROJECT NUMBER 20-7 (232)
ADA Transition Plans:
A Guide to Best Management Practices
May 2009
Jacobs Engineering Group
Baltimore, MD
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TABLE OF CONTENTS
Page
I INTRODUCTION......................................................................................................................................................... 1
Background ............................................................................................................................................................. 1
Applicability to State Departments of Transportation .............................................................................................. 1
Purpose of This Guide ............................................................................................................................................ 1
Focus ...................................................................................................................................................................... 2
Methodology ........................................................................................................................................................... 2
Contents of This Guide ........................................................................................................................................... 2
II STEPS to Compliance ................................................................................................................................................ 2
Overview ................................................................................................................................................................. 2
Step 1 - Designating an ADA Coordinator .............................................................................................................. 3
Step 2 - Providing Notice About the ADA Requirements ........................................................................................ 3
Step 3 - Establishing a Grievance Procedure ......................................................................................................... 3
Step 4 - Development of Internal Standards, Specifications, and Design Details ................................................... 4
Step 5 - The ADA Transition Plan ........................................................................................................................... 4
Step 6 - Schedule and Budget for Improvements ................................................................................................... 6
Step 7 - Monitoring the Progress ............................................................................................................................ 7
Conclusion to the Process ...................................................................................................................................... 7
III FINDINGS and Best Practices of State DOTs ........................................................................................................... 7
Overview ................................................................................................................................................................. 7
Administrative Tasks ............................................................................................................................................... 7
Self-Evaluation Phase ........................................................................................................................................... 10
Implementation ..................................................................................................................................................... 12
Sample Transition Plan Outline ............................................................................................................................ 15
Public Involvement ................................................................................................................................................ 16
Coordination With Other Agencies ........................................................................................................................ 17
IV CONCLUSION ......................................................................................................................................................... 18
V FURTHER REFERENCE ........................................................................................................................................ 18
VI ATTACHMENTS ..................................................................................................................................................... 19
List of ADA Contacts by State ............................................................................................................................... 19
Questionnaire........................................................................................................................................................ 32
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I INTRODUCTION
BACKGROUND
The Americans with Disabilities Act (ADA) of 1990 is a civil rights statute (hereinafter referred to as the Act)
that prohibits discrimination against people who have disabilities. There are five separate Titles (sections) of
the Act relating to different aspects of potential discrimination. Title II of the Act specifically addresses the
subject of making public services and public transportation accessible to those with disabilities. With the
advent of the Act, designing and constructing facilities for public use that are not accessible by people with
disabilities constitutes discrimination.
The Act applies to all facilities, including both facilities built before and after 1990. As a necessary step to a
program access plan to provide accessibility under the ADA, state and local government, public entities or
agencies are required to perform self-evaluations of their current facilities, relative the accessibility
requirements of the ADA. The agencies are then required to develop a Program Access Plan, which can be
called a Transition Plan, to address any deficiencies. The Plan is intended to achieve the following:
(1) identify physical obstacles that limit the accessibility of facilities to individuals with disabilities,
(2) describe the methods to be used to make the facilities accessible,
(3) provide a schedule for making the access modifications, and
(4) identify the public officials responsible for implementation of the Transition Plan.
The Plan is required to be updated periodically until all accessibility barriers are removed.
APPLICABILITY TO STATE DEPARTMENTS OF TRANSPORTATION
The requirements of the ADA apply to all public entities or agencies, no matter the size. The transition plan
formal procedures as outlined in 28 C.F.R. section 35.150 only govern those public entities with more than 50
employees. The obligation to have some planning method to make facilities ADA-accessible is required for all
public entities. This includes State Departments of Transportation (hereinafter referred to as Departments) and
the extensive public transportation systems that they manage. The development or updating of a Transition
Plan is now an ongoing activity or a goal at many Departments. A principal challenge of this activity to the
Departments, as opposed to other government agencies that manage public facilities, is the need to cope with
the overall size and geographic extent of the public facilities that a Department of Transportation manages.
These public facilities can involve thousands of miles of public rights-of-way.
PURPOSE OF THIS GUIDE
The purpose of this guidance document is to ensure that good ideas, helpful information, and successful
practices concerning the development and updating of Transition Plans are recognized, recorded, and shared
among Departments of Transportation.
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FOCUS
ADA Transition Plans are required from all Departments to cover all facilities under their control. This includes
rights-of-way, but also the buildings that may be owned by the Department such as district offices, welcome
centers, rest stops, airport terminals, and other types of buildings associated with transportation activities. The
focus of this report is solely on Department managed pedestrian facilities in public rights-of-way. This typically
includes sidewalks, pedestrian paths, curb ramps, street crossings, driveway crossings, crosswalks, median
crossings, public transit stops, and pedestrian activated signal systems. The accessibility of pedestrian
facilities in the public right-of-way is only one aspect for providing equal access to state government programs,
services, and activities – but it is an aspect that affects many citizens in their daily activities.
METHODOLOGY
The material in this report is based on information obtained through Department websites, questionnaires filled
out by some Departments, and telephone interviews with the ADA coordinator or other contacts at some
Departments as well as input from guidance documents from the Federal Highway Administration (FHWA), the
Department of Justice (DOJ), and the US Access Board. All contacts were made with the understanding that
individual state status, progress, or data would not be reported or compared, but that any information obtained
would be used in an effort to help other Departments comply with the development and updating of their own
Transition Plans.
CONTENTS OF THIS GUIDE
This report presents the issues that Departments have to deal with in the development and updating of their
ADA Transition Plans. It then describes, using anecdotal information, the roadblocks encountered in dealing
with these issues and the methods that Departments across the country have developed to make progress.
II STEPS TO COMPLIANCE
OVERVIEW
The ideal scenario for meeting the requirements of the Act with regard to the accessibility of facilities in the
public right-of-way would involve the following steps:
(1) designating an ADA Coordinator,
(2) providing notice to the public about ADA requirements,
(3) establishing a grievance procedure,
(4) developing internal design standards, specifications, and details,
(5) assigning personnel for the development of a Transition Plan and completing it,
(6) approving a schedule and budget for the Transition Plan, and
(7) monitoring the progress on the implementation of the Transition Plan.
The following is an expansion on each of the requirements for this ideal scenario.
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STEP 1 - DESIGNATING AN ADA COORDINATOR
Each Department must designate at least one responsible employee to coordinate ADA compliance. The
benefits of having an ADA Coordinator are that:
It makes it easier for members of the public to identify someone to help them with
questions and concerns about disability discrimination,
It provides a single source of information so questions by the Department staff and from
outside the Department can be answered quickly and consistently, and
It provides an individual who can focus on and who can be instrumental in moving
compliance plans forward.
The person who is appointed to this position must be familiar with the Department’s operation, trained in the
requirements of the ADA and other laws pertaining to discrimination, and able to deal effectively with local
governments, advocacy groups, and the public. It is assumed that the coordinator is given sufficient time free
of other responsibilities to carryout the Coordinator’s functions. Possible locations for the position within a
Department are the Office of the Commissioner, the Civil Rights Office, the Legal Department, the Planning
Department, or the Public Involvement Department.
STEP 2 - PROVIDING NOTICE ABOUT THE ADA REQUIREMENTS
A Department must provide public notice about the rights of the public under the ADA and the responsibility of
the Department under the ADA. Providing notice is not a one time requirement, but a continuing responsibility.
The audience of those who may have an interest in accessibility on Department facilities might include a large
number of individual citizens that would be not be readily identifiable. Groups that are likely to include the
target audience include public transit users and advocacy groups. A Department has the responsibility to
determine the most effective way to provide notice. A notice on a Department website lends itself to both the
requirement for wide notice and the requirement for continuing notice. The website must in itself be
accessible. The Department of Justice has provided a model that could be followed by Departments on their
website. See “Notice under the Americans with Disabilities Act” on their web page,
http://www.ada.gov/pcatoolkit/chap2toolkit.htm, for more information.
Public Outreach Programs The opportunity for the disabled community and other interested parties
to participate in developing the Transition Plan is an integral part of the process. The dissemination of
information and requests for comments can take place through awareness days, newsletters, and
websites. The ability to comment must be linked with public access to information databases.
Possible sources of input to the Transition Plan are activists, advocacy groups, general citizens,
organizations that support the rights of the disabled, elected officials, other agencies, a Governor’s
Committee on People with Disabilities or other such body, or a state ombudsman. Comments can be
obtained through comment forms at meetings, transcriptions of meetings, a dedicated hotline, an e-
mail address, or a postal address.
STEP 3 - ESTABLISHING A GRIEVANCE PROCEDURE
A Department is required to adopt and publish procedures for resolving grievances arising under Title II of the
ADA. The procedures are intended to set out a system for resolving complaints of disability discrimination in a
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prompt and fair manner. Complaints would typically be directed to the Department’s Office of Civil Rights. It is
generally thought that filing a complaint with a Department is an appropriate first step, in that it provides an
opportunity to resolve a local issue at the local level. However, the exhaustion of a Department’s grievance
procedure is not a prerequisite to filing a complaint with either a federal agency or a court. The Department of
Justice has provided a model for Departments to follow. See “Grievance Procedure under the Americans with
Disabilities Act” at http://www.ada.gov/pcatoolkit/noticetoolkit.pdf for more information.
STEP 4 - DEVELOPMENT OF INTERNAL STANDARDS, SPECIFICATIONS, AND DESIGN DETAILS
The Architectural and Transportation Barrier Compliance Board (alternatively called the Access Board) has
developed accessibility guidelines for pedestrian facilities in the public right-of-way. The Federal Highway
Administration has recognized these as its currently recommended best practices. A Department can adopt
these accessibility guidelines into their own system of standards, specifications, and design details with
modifications to meet local conditions. Development of design standards and design details within the
Department allows for consistency in the application of ADA requirements for new facilities. See
http://www.access-board.gov/prowac/guide/PROWGuide.htm for more information
STEP 5 - THE ADA TRANSITION PLAN
The Transition Plan (hereinafter referred to as the Plan) should consist of the following elements:
1. A List of Physical Barriers in the Department’s Facilities that Limit Accessibility of Individuals with
Disabilities (the Self-Evaluation),
2. A Detailed Description of the Methods to Remove these Barriers and Make the Facilities Accessible,
3. A Schedule for Taking the Necessary Steps,
4. The Name of the Official Responsible for Implementation,
5. A Schedule for Providing Curb Ramps, and
6. A Record of the Opportunity Given to the Disability Community and Other Interested Parties to
Participate in the Development of the Plan.
Periodic updates to the Transition Plan are required in order to ensure on-going compliance. Some of these
key steps are described further below.
The Self-Evaluation The first task involved in preparing an ADA Transition Plan is conducting an
inventory of existing physical barriers in the facilities operated by the Department and listing all the
barriers that limit accessibility. This is often referred to as the self-evaluation process. Possible
inventory approaches are on-ground surveys, windshield surveys, aerial photo studies, or drawing
reviews. Deficiencies very likely to be found in an inventory of facilities are:
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SELF-EVALUATION CHECKLIST
ISSUE
POSSIBLE BARRIERS
Sidewalk and Pathway Clear Width
Narrow, Below Guidelines
Sidewalk and Pathway Cross Slope
Steepness, Irregularity, Variability, Warping
Landings Along Sidewalks and
Pathways
Less Than 4 feet by 4 feet
Sidewalk and Pathway Grade
Steepness, Angle Points
Materials and Finishes
Deterioration of Surfaces, Deterioration of Markings,
Appropriateness of material (ex. Cobblestones)
Gratings
Grating Type, Grate Opening Orientation
Discontinuities
Missing Sections, Gaps, Drops, Steps
Detectable Warning System
Missing, Inappropriate Materials, Inadequate Size, Wrong
Location
Obstructions
Signs, Mail Boxes, Fire Hydrants, Benches, Telephones,
Traffic Signal Poles, Traffic Signal Controller Boxes,
Newspaper Boxes, Drainage Structures, Tree Grates,
Pole Mounted Objects, Standing Water, Snow or Ice
Traffic Signal Systems
Lack of Provision for the Visually Impaired such as APS,
Inadequate Time Allowed, Inoperable Buttons,
Inaccessible Buttons
Curb Ramp
Missing, Doesn’t Fall within Marked Crosswalk, Doesn’t
Conform to Guidelines
Curb Ramp Flares
Missing Where Required, Too Steep
Standards set for each of these issues can be found in the US Architectural and Transportation Barriers
Compliance Board’s Accessible Rights-of-Way: A Design Guide, Chapter 3 “Best Practices in Accessible
Rights-of-Way Design and Construction”. Refer to their website at http://www.access-
board.gov/prowac/guide/PROWGuide.htm for more information.
The information developed through the inventory process has to be quantified and presented as a baseline so
that progress can be monitored and measured. The inventory information can be presented in a variety of
ways including Aerial Photos, a Database or Spreadsheet, Marked Up Drawings, or a Geographic Information
System (GIS).
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Self-evaluation also takes place after the Transition Plan is complete. Periodic reviews and updates to the
Plan must be conducted to ensure ongoing compliance with ADA requirements. Self-evaluation activities
would then consist of reviewing the Plan to determine the level of compliance, and determine if any additional
areas of upgrade are needed. If deficiencies are found, these are catalogued and the Transition Plan updated
to detail how and when the barriers to pedestrian access would be removed.
STEP 6 - SCHEDULE AND BUDGET FOR IMPROVEMENTS
The Transition Plan should include a schedule of improvements to upgrade accessibility in each year following
the Transition Plan. Remediation work can be presented for an independent remediation program or as an
integral part of regularly scheduled maintenance and improvements project such as Resurfacing Projects,
Roadway Rehabilitation and Reconstruction Projects, and Signal System Installation Projects. All new projects,
regardless of funding sources, would include pedestrian elements that are consistent with the ADA guidelines.
Funding Sources The most immediate source of funds for remediation efforts is the incorporation of
improvements into existing programmed remediation projects, incorporation into programmed
signalization projects, and incorporation into programmed maintenance work. An accessibility
improvement program could be developed as a stand alone project through the Transportation
Improvement Program. Potential sources of funding for accessibility improvements also include the
following:
o Congestion Mitigation/Air Quality Program,
o Highway Safety Improvement Program,
o National Highway System Improvements Program,
o Railway – Highway Crossing Program,
o Recreational Trail Program,
o Safe Routes to School Program,
o State and Community Traffic Safety Program,
o Surface Transportation Program,
o Transportation Enhancement Activities Program.
Additional federal funding sources for different elements of pedestrian projects and programs can be found at
http://www.fhwa.dot.gov/civilrights/ada_qa.htm#q30.
Prioritization The prioritization of improvements that may not be included in an existing programmed
project can be based on a number of factors. Generally, priority should be given to transportation
facilities, public places, and places of employment. Other factors to consider when prioritizing
improvements may include:
o Citizen requests or complaints regarding inaccessible locations,
o Pedestrian level of service,
o Population density,
o Presence of a disabled population,
o Cost
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STEP 7 – MONITORING THE PROGRESS
In order to be effective, the Transition Plan needs to be utilized in yearly planning of projects and funding
decisions, and also needs to be periodically reviewed for compliance and validity. The Transition Plan should
be viewed as a “living document” and updated regularly to reflect changes in real world conditions and to
address any possible new areas of noncompliance. Changes to a sidewalk such as the installation of a
newspaper vending machine, or the relocation of a light pole, can create new access problems that were not
evident when the plan was drafted. Regular updates to the plan will also result in monitoring compliance and
the effectiveness of priorities set in the Plan itself.
CONCLUSION TO THE PROCESS
The ideal conclusion to the Transition Plan process is the elimination of the barriers listed in the Transition
Plan and the acceptance of the requirements of the Act as an everyday reality in all future work going forward.
Due to the magnitude of the task and the other priorities that a Department faces, the ideal scenario has not
universally played out. Although the majority of Departments contacted had some form of inventory or
Transition Plan completed, many of the Departments reported that they were either just beginning the process
or didn’t have firm plans for preparing a Transition Plan.
The following sections of this Guide discuss best practices and decisions that Departments have utilized in
dealing with implementation issues and the methods that they have used to make progress. In addition to
presenting anecdotal evidence from the states in Best Practices, the following sections present “keys to
success”. These are called out to help Departments as they are undertaking the ADA tasks associated with
drafting and updating a Transition Plan.
III FINDINGS AND BEST PRACTICES OF STATE DOTS
OVERVIEW
Each of the fifty state Departments of Transportation as well as those in Puerto Rico and the District of
Columbia were included in this study to gather information on Best Practices used among the states for
completing tasks associated with ADA requirements. All Departments have web sites available for review. A
questionnaire was developed to facilitate the information gathering process from the Departments. This
questionnaire was e-mailed to each of the Departments. The questionnaire was followed up with a telephone
survey to aid in the information exchange. Of the 52 Departments contacted, 20% completed the
questionnaire, 44% were contacted by phone for discussion but with no formal survey completed, and 13%
were not successfully contacted. The remaining 23% of the Departments have indicated that the questionnaire
will be forthcoming, but as of the date of this report, their completed questionnaires have not been received.
The questionnaire is included as an attachment.
ADMINISTRATIVE TASKS
Departments were found to vary greatly in their responsibilities, their structure, and the nature of the facilities
that they manage. Nevertheless, they all have the responsibility of establishing a basic program to meet the
administrative requirements of the ADA. The basic administrative requirements of this program are:
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(1) Designating an ADA Coordinator,
(2) Giving notice about the ADA requirements, and
(3) Establishing a grievance procedure.
The Coordinator: Section 504 of the Rehabilitation Act of 1973 presented many similar requirements
to those found in the ADA and has been around longer than the ADA. If there was an individual who
had responsibility for carrying out the requirements of Section 504, this individual provided a logical
selection for the duties of ADA Coordinator. In many states, an ADA coordinator has been appointed
as a part-time or in some cases a full-time position. In a few states, an ADA coordinator has only been
appointed within the past two years. The background of these staff members varies greatly. Many of
the staff members in these positions have backgrounds that do not match the technical requirements
that are needed to successfully complete the activities required to comply with ADA. This presents a
roadblock for the agencies at the outset of the process and can lead to delays in compliance.
The Coordinator may report to the Human Resources Department or to a Civil Rights Department.
The direction to the process provided by an ADA coordinator generally correlates with the successful
drafting and implementation of the Transition Plan.
Whether there is a staff of one or an entire ADA task force, training was also cited by various
Departments as an important tool for ensuring compliance with ADA requirements and completion of
ADA Transition Plans. Many Departments have staff that has participated in some form of ADA
training from the Federal Highway Administration, the US Access Board, or other agencies. Several
other Departments are requiring that all personnel within the DOT receive training. Educating
Department staff in the requirements of Title II of the ADA results in better flow of information
regarding non-compliant rights-of-way and can creates a “buy-in” to the process by all staff.
Giving Notice of ADA Requirements: As described above, Departments are required to give notice
to the public on information regarding public accessibility and compliance with ADA. A Department’s
web site is generally the first resource for the public to seek out information about pedestrian
accessibility in the public right-of-way. There are a wide range of approaches to providing website
KEY TO SUCCESS
Providing dedicated, trained staff within the Department for ADA compliance has a high
correlation with successful drafting and implementation of Transition Plans, Self-evaluations,
and Transition Plan updates.
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information about ADA requirements among the Departments - varying from a webpage devoted
exclusively to the subject, to a link on the main web page, to passive discussion of the issue
submerged in other topics.
By providing this information on-line, the Department widens the accessibility of the information and
allows for education of the general public and facilitates the exchange of information with the disabled
community. Utilizing the Department’s web page can provide a one stop portal for issues related to
ADA compliance, including pedestrian accessibility on Department rights-of-way, Transition Plan
status and methodologies for filing complaints. Many Departments home pages have links to the
“ADA/Accessibility Program”. Other websites mention the ADA only passively as part of other
discussions. More commonly, the ADA is mentioned, but not highlighted, under statewide pedestrian
and bicycle plans, policies, programs, and planning guidance.
The best practice for notification is to provide a clear and exclusive reference to the ADA requirements
on the Department’s webpage in order to best address the notification requirement.
Other forms of notice that Departments utilize include public meetings. Meetings should be targeted
to the pedestrian community and specifically to the disabled pedestrian community. Mailings and
information regarding meetings can be distributed to this targeted community with the help of
advocacy groups for the disabled.
Grievance Procedure: As a regulatory requirement of ADA, the Department must adopt and publish
a grievance procedure providing for prompt and equitable resolution of complaints alleging any action
that would be prohibited under Title II. In addition to the regulatory requirement of including the
grievance procedure in the Transition Plan, it is also good practice to include this detailed information
on the Department’s website. The grievance procedure should make methods clear for any member
KEY TO SUCCESS
Provide a website with links to the various components of the ADA Transition Plan such as
policies, compliance planning for construction and retrofits, opportunities for public
participation, links to the ADA advisory committee, grievance procedures, and the schedule for
implementation of the program.
KEY TO SUCCESS
One state found that public meetings on the newly completed inventory were better attended
when they were coupled with another meeting geared toward the disabled community – such
as linking the meeting with a regularly scheduled meeting of the Statewide or Local
Commission on Disabilities.
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of the public wishing to inform the Department of potential hindrances to public access along
pedestrian rights-of-way. Exchange of this information is a critical step in addressing potential ADA
noncompliance and preventing the escalation of the grievance to a formal civil complaint.
Department approaches to this responsibility vary from simply adopting the state grievance procedure,
to developing unique approaches for the Department itself.
SELF-EVALUATION PHASE
As the initial step in the Transition Plan, Departments are required to conduct an inventory of their facilities to
determine if they are accessible by persons with disabilities. This stage is often referred to as the self-
evaluation phase. This section discusses how agencies have undertaken or are planning to undertake this
assignment.
The Inventory: Many Departments reported the completion of the inventory during the self-evaluation
as being the biggest and most daunting task of the Transition Plan process. Lack of budget and
(associated) lack of staffing often make this task extremely challenging to complete. Budgetary
constraints as well as management decisions on staffing and support of ADA programs are a major
factor in each Department’s ability to complete the tasks associated with updating the Transition Plan.
As a result, many states report being stalled in the inventory phase, either awaiting the completion of
self-evaluation activities or unable to take the data collected and develop priorities for upgrades.
Ideally, dedicated funding and staffing would be planned out through the completion of the Transition
Plan prior to starting any self-evaluation activities.
Several states have adopted a two pronged approach to Transition Plan development due to the level
of effort required to fully inventory state rights-of-way, by creating two separate plans; one for buildings
and one for rights-of-way. This allows the compliance effort for buildings and other public facilities to
proceed without being held up during completion of state wide inventory of rights-of-way. Other
states have prioritized the inventory and are approaching the task in stages. These Departments have
completed part of the inventory to include highly used areas such as urban areas with high pedestrian
traffic, and areas near facilities that are commonly used by pedestrians with disabilities, such as a
school for the blind. This allows for the Department to move forward with updating the Transition Plan
KEY TO SUCCESS
Making the grievance procedure as straightforward as possible for the public can facilitate
information exchange regarding non-compliant sites, and can help the Department avoid
escalation of grievance issues. By allowing the public to choose any method of filing a
grievance, from writing a formal complaint to the ombudsman, filing a complaint electronically
through the website, contacting any Department business office, or calling a toll free number,
the Department ensures a better exchange of information.
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to address these high traffic areas, and the Department can then complete the inventory of remaining
rights-of- way as time and resources allow.
Other states have utilized the organization of the Department into regions or districts as a logical way
of dividing the inventory process, with each District responsible for self-evaluation activities and
development of an individual Transition Plan covering their geographic area. Where the inventory
process has been divided up, states continue to maintain a central location of inventory data to allow
for access by the public and other offices within the state.
Inventory also requires an assessment of who is responsible for the facilities’ compliance. Many
states reported that determining who was responsible for compliance was often difficult and can stall
the inventory process, since it is unclear what should be included in the self-evaluation. Sidewalks on
state roads within municipalities were cited as sometimes problematic, as were public transit facilities
that were owned by the DOT but operated by others. Some Departments turn over ownership of
sidewalks to municipalities upon completion of construction. In cases where responsibility for
compliance is in question, it is critical that the municipality and the Department be in close contact to
allow for resolution. Departments have reported grievances being filed with no clear idea of who is
responsible for upgrading the facility, leading to delay in addressing the nonconformity.
Making the Information Available: The most common method of storing the data gathered during
the inventory process is quickly becoming the utilization of GIS. Some states have held outreach
meetings with data displays on which the public can view street level detail of public access issues
along state rights-of-way. GIS enables linking real photos of the site with a general mapping tool and
engineering data. Providing this type of street level information to the members of the public greatly
enhances the readability of the information, and can create a more productive information exchange.
Establishing a Baseline: The main goal of the Self-evaluation phase is to provide a baseline of what
facilities under the Department’s responsibility are noncompliant with ADA standards. Comparisons to
the initial self-evaluation will provide evidence of a Department’s good faith in efforts to comply with
ADA requirements.
KEY TO SUCCESS
When staffing or funding for inventory efforts is a challenge, many Departments get creative –
several states have reported using summer interns for self-evaluation activities on public rights
–of-way. Others prioritize the inventory process by looking at high pedestrian areas first. In
this way, even if a complete inventory cannot be undertaken, those areas that will be most
utilized (such as urban intersections) are addressed.
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IMPLEMENTATION
When the self-evaluation is completed and the Department has an inventory of where structural modifications
are required to achieve accessibility, the Department must plan for the removal of these barriers. A Transition
Plan must contain at a minimum:
(1) a list of the physical barriers that limit the accessibility of services to individuals with disabilities (the
inventory),
(2) a detailed outline of the methods to be used to remove these barriers and make the facilities
accessible,
(3) a schedule for taking the necessary steps to achieve compliance, and
(4) the name of the official responsible for the plan’s implementation.
Curb Ramp Deficiencies: Curb Ramps are a small but vitally important part of making sidewalks,
street crossings, and the other pedestrian routes that make the public right-of-way accessible to
people with disabilities. They receive special consideration in the Transition Plan with a separate
schedule for the remediation of curb ramp issues. The primary issue with curb ramps in many
Departments is how to proceed with rectifying a large, long term problem in a logical manner.
The following table provides an example from one Department of how to prioritize removal of accessibility
barriers. The Table uses a ranking system (priority) based on variables (Situation) that include location,
degree of utilization and degree of non compliance.
KEY TO SUCCESS
A very detailed approach for setting priorities for dealing with curb ramps (or other non
conformities) can help with successful implementation of the Plan. Criteria can include both
physical characteristics and location considerations. Making use of such a specific criteria
presupposes that sufficient detail has been gathered in the self-evaluation phase so that the
curb ramps can be accurately characterized.
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PRIORITY
SITUATION
Highest
1A
Existing Curb Ramp with Running Slope Greater than 12% and Location
near a Hospital, School, Transit Stop, Government Building, or Similar
Facility
1B
No Curb Ramp where Sidewalk or Pedestrian Path Exists and Location
near a Hospital, School, Transit Stop, Government Building, or Similar
Facility
2A
An Existing Curb Ramp with a Running Slope Greater than 12% (Not
Located near a Hospital or Similar Facility)
2B
No curb ramp where a Sidewalk or Pedestrian Path Exists (Not Located
near a Hospital or Similar Facility)
3
No Curb Ramp where a Striped Crosswalk exists
4
One Curb Ramp per Corner and Another is Needed to Serve the Other
Crossing Direction
5A
An Existing Curb Ramp with either a Running Slope Greater than 1 to 12
or an Insufficient Landing
5B
An Existing Curb Ramp with Obstructions in the Ramp or the Landing
5C
An Existing Curb Ramp with any of the Following Conditions:
o A Cross Slope Greater than 3%
o A Width Less Than 36 Inches
o No Flush Transition or a Median or Island Crossings that are
Inaccessible
5D
An Existing Curb Ramp with Returned Curbs where Pedestrian Travel
Across the Curb is not Permitted
5E
An Existing Diagonal Curb Ramp without the 48 Inch Extension in the
Crosswalk
5F
An Existing Curb Ramp without Truncated Dome Texture Contrast or
without Color Contrast
Lowest
The Pedestrian Push Button is not Accessible from the Sidewalk or from
the Ramp
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Schedule: Setting priorities for the implementation of upgrades is a requirement. Transition Plans
should include a year by year schedule of upgrades. Many Departments will prioritize projects based
on level of anticipated use rather than the degree of non-compliance. Curb ramps or intersections that
may be near facilities for the disabled, are generally given priority for upgrade. However, oftentimes it
is difficult for Departments to know themselves which intersections are most utilized by persons with
disabilities.
Funding: The funding for implementation of the Transition Plan can come from several sources, as
discussed earlier in this report and in the FHWA guidance found at
http://www.fhwa.dot.gov/civilrights/ada_qa.htm#q30. Lack of funding and staffing were cited as the
most common roadblocks to completing the inventory and the Transition Plan. In Departments where
dedicated funding and staffing is not in place, Transition Plans are generally not completed. In the
longer term, this may lead to civil suits and expensive litigation for Departments. Establishing a well
developed Transition Plan can be viewed as a capital planning tool and will allow for better
Departmental control over the compliance process.
The funding of the upgrades found in the Transition Plan is also a consideration, since ADA
compliance activities do not stop with the successful completion of the Transition Plan, or the update
of a Transition Plan. The improvements therein must be funded and undertaken as well. Accessibility
improvements are generally incorporated into existing improvement projects. In some cases
Departments have provided special projects that specifically address pedestrian access requirements.
KEY TO SUCCESS
Working closely with advocacy groups to set the schedule for implementation and prioritization
can be extremely beneficial. These groups can help bring information from the public to the
Departments so that money can be best spent on those areas that will serve to benefit the
most people.
KEY TO SUCCESS
One state’s approach to prioritization uses a GIS database that contains information regarding
compliant and non-compliant elements. This GIS information is then displayed along with
locations of pedestrian incidents, feedback from the community or local jurisdiction, locations of
government facilities, locations of public facilities and mass transit stops. Each of these
elements were assigned a value and ranked for priority.
Page 15
Lines of Responsibility: A management structure for the implementation of the Transition Plan is
extremely important in order to fully complete all tasks that are associated with the Plan.
SAMPLE TRANSITION PLAN OUTLINE
Among the states that have not yet completed a Transition Plan, staff members asked if a generic Transition
Plan format is available. In many regions, FHWA provides a sample plan to help Departments facilitate the
process. Although there are mandates for content, there are no requirements for format of the Transition Plan.
KEY TO SUCCESS
Length and level of detail of Transition Plans varies greatly among the states. For example,
one state provides a succinct one and a half page of narrative on rights-of-way and the
prioritization criteria, incorporating the inventory by reference. Other states have a Transition
Plan that provides pages and pages of actual inventory with priorities and proposals for each
individual site. At the outset of the process, a Department should make a determination as to
what level of detail will be included in the Plan and the content that will be the most beneficial
to them in implementing ADA
KEY TO SUCCESS
Beyond simply designating an ADA Coordinator, many Departments have a designated
Transition Plan manger, as well. While the ADA Coordinator may be involved in public
outreach and oversight of ADA compliance, the Transition Plan manager may be better
equipped to handle the technical aspects related to the self-evaluation activities and Transition
Plan updates.
Page 16
The following is a sample of one possible outline for Transition Plans.
SECTION
CONTENTS
I SELF-EVALUATION :
A list of physical barriers in the department’s facilities that limit
accessibility of individuals with disabilities. This may take the form
of an Excel spreadsheet or GIS files incorporated by reference,
or can be worked into a narrative list to be embedded in the text
of the Transition Plan.
II CORRECTION PROGRAM:
A detailed description of the methods to remove these barriers
and make the facilities accessible.
III IMPLEMENTATION SCHEDULE:
A schedule for taking the necessary steps.
IV PROGRAM RESPONSIBIL ITY:
The name of the official responsible for implementation. This
should include the name of the department ADA coordinator, as
well as a transition plan team (if there is one), or the regional
coordinators, if the inventory and transition plans area is divided
by region or district.
V CURB RAMP CORRECTION PROGRAM:
A schedule for providing curb ramps.
VI PUBLIC INVOLVEMENT RECORD:
Record of the opportunity given to the disability community and
other interested parties to participate in the development of the
Plan.
ATTACHMENTS
PUBLIC INVOLVEMENT
The Department is required to provide an opportunity for people outside of the agency, people with disabilities,
and other interested individuals and organizations to review and comment on the Transition Plan. This section
presents some of the approaches agencies have used to provide this opportunity.
The Dissemination of Information: Although all Departments now have websites, very few have the
Transition Plan available for public review. This represents a missed opportunity as an avenue for
information dissemination. In addition to providing information for the public at large, the targeted
distribution of information should also be undertaken. Advisory groups that may have worked with the
Department during the development of the Plan and the prioritization of the upgrades would receive
the information. Advocacy groups that work with the disabled community, as well as any individuals
with disabilities that may have participated in Plan development in some way (ex. through grievance
filings, through hotlines or through previous public meetings), would also be interested in reviewing the
plan.
Page 17
COORDINATION WITH OTHER AGENCIES
Coordination among transit agencies can be a helpful step in creating a Transition Plan that is concise and
effective in addressing upgrades.
Public Transit: There are many states where Departments are not only responsible for pedestrian
access along public rights-of-way but also for pedestrian access to other transit facilities.
Departments of Transportation also frequently have responsibility for public transit such as
responsibility for airports, ferry systems, light rail systems and bus terminals. Each of these presents
unique compliance issues. All facilities need to be included in the Department’s Transition Plan.
KEY TO SUCCESS
Seeking the involvement of Advocacy groups and the disabled public early in the process can
lead to better success in dealing with non-compliance areas. This early coordination can
provide valuable information to the Department from people who most use the pedestrian
facilities and provides and opportunity for the concerns that are most important to the advocacy
groups and the public to be addressed more effectively. These groups know best where
problem areas are and their input can provide valuable insight to Departments that are trying to
set priorities for upgrades.
KEY TO SUCCESS
Creation of a regional working group for ADA compliance issues was cited by several states in
the east as being a helpful practice in completing tasks related to the Transition Plan. These
interstate groups are made up of an ADA coordinator as well as other members of
Departments and FHWA. The meetings provide a forum for exchange of ideas and any Best
Management practices. The groups exchange ideas in their approach to developing inventories
and updating Transition Plans. Regional grouping also enables common challenges among
the states to be more effectively addressed. Densely urbanized areas in the Northeast, with
miles of urban sidewalks interspersed with public transit have different pedestrian issues than
newer cities in the Southwest. For example, Washington State deals with an entirely different
pedestrian issue in managing the nations’ largest ferry system. Creating regional work groups
can facilitate discussion of common regional problems.
Page 18
Adjacent Jurisdictions: Where facilities owned and operated by the Department abut facilities owned
by others, such as a municipality, responsibility for ADA compliance should be coordinated. For
example group meetings with ADA coordinators throughout the state have been cited by some states
as valuable in avoiding conflict among adjacent jurisdictions. In one phone interview with a
Department ADA Coordinator, the coordinator explained that one of his priorities for the upcoming
year was to create a master list for the state of all ADA Coordinators at the municipal and state level to
facilitate statewide interagency coordination. Taking this one step further, many Departments in the
northeast participate in a civil rights working group among the states. This group addresses Title II
compliance as one of its tasks
IV CONCLUSION
The purpose of this document is to ensure that good ideas, helpful information, and successful practices
concerning the development and updating of Program Access Plans or Transition Plans are recognized,
recorded, and shared among Departments of Transportation.
The ideal conclusion to this process is the elimination of the barriers and the acceptance of the requirements
of the ADA as an everyday reality in all future work going forward. Due to the magnitude of the task and the
other priorities that a Department faces, the ideal scenario has not universally played out. Although the
majority of Departments contacted had some form of inventory or Transition Plan completed, many of the
Departments reported that they were either just beginning the process or didn’t have firm plans for preparing a
Transition Plan.
By highlighting some of the issues and the methods used to address issues that the Departments face when
developing and updating their ADA Transition Plans it is desired that going forward all Departments can make
significant progress towards improving access to the facilities they manage. This document presents ideal
scenarios and some of the best practices of Departments across the country. It is recognized that each
Department or responsible agency will have to tailor an approach to developing, updating and implementing a
Transition Plan based upon their own needs and available resources and that the level of detail and content of
the Plan will vary and be presented in a format that will be the most beneficial to them in implementing ADA.
V FURTHER REFERENCE
There are many guidance documents available on the internet with helpful information to assist in completing
and updating ADA Transition Plans. Some of those more frequently cited by Departments include the
following:
FEDERAL HIGHWAY ADMINISTRATION OFFICE OF CIVIL RIGHTS QUESTIONS AND ANSWERS ABOUT ADA AND
SECTION 504, January 2008. Available, [ retrieved December 2008]
http://www.fhwa.dot.gov/civilrights/ada_qa.htm
U.S. DEPARTMENT OF JUSTICE ADA BEST PRACTICES TOOLKIT FOR STATE AND LOCAL GOVERNMENTS June
2008. Available, [retrieved December 2008] http://www.ada.gov/pcatoolkit/toolkitmain.htm .
UNITED STATE DEPARTMENT OF JUSTICE, THE AMERICANS WITH DISABILITIES ACT, TITLE II TECHNICAL
ASSISTANCE MANUAL, COVERING STATE AND LOCAL GOVERNMENT PROGRAMS AND SERVICES, November
1993. Available, [ retreived December 2008] http://www.ada.gov/taman2.html
Page 19
PUBLIC RIGHTS-OF-WAY ACCESS ADVISORY COMMITTEE and ITE Publication Special Report: ACCESSIBLE
PUBLIC RIGHTS-OF-WAY, PLANNING AND DESIGNING FOR ALTERNATIONS. Available, [ retreived December
2008 ] http://access-board.gov/prowac/alterations/guide.htm
US ACCESS BOARD, REVISED GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY. November 2005.
Available, [ retreived December 2008] http://www.access-board.gov/PROWAC/draft.htm
FHWA DESIGNING SIDEWALKS AND TRAILS FOR ACCESS PART 2. Available, [ retreived December 2008]
http://www.fhwa.dot.gov/environment/sidewalk2 .
KRW INCORPORATED, ADA TRANSPORTATION ACCESSIBILITY REFERENCE GUIDE, Project Action, National
Easter Seal Society, and U.S. Architectural and Transportation Barriers Compliance Board, March 1993.
Many Departments cited recent training from FHWA as being helpful in understanding the issues surrounding
ADA Transition Plan compliance. The FHWA training documents are often used as reference documents
during the updating of a Transition Plan.
Statutes and Regulations: The Department’s Title II regulations for state and local governments are found at
Title 28, Code of Federal Regulations, Part 35 (abbreviated as 28 CFR pt. 35. The ADA Standards for
Accessible Design are located in Appendix A of Title 28, Code of Federal Regulations, Part 36 (abbreviated as
28 CFR pt. 36 app. A). Those regulations, the statute, and many helpful technical assistance documents are
located on the ADA internet Home Page at http://www.ada.gov and on the ADA technical assistance CD-ROM
available without cost from the toll-free ADA Information Line at 1-800-514-0301 (voice) and 1-800-514-0383
(TTY).
VI ATTACHMENTS
LIST OF ADA CONTACTS BY STATE
State
ADA Coordinator
Contact
(if different than ADA coordinator)
Alabama
Byron Browning
Assistant ADA Coordinator
Alabama Department of Transportation
1409 Coliseum Boulevard
Montgomery, AL 36110
334-242-6942
Page 20
State
ADA Coordinator
Contact
(if different than ADA coordinator)
Alaska
Jon Dunham
Civil Rights Office Manager
2200 East 42nd Avenue
PO Box 196900
Anchorage AK 99519-6900
907-269-0851
[email protected]ate.ak.us
Arizona
Edward Edison
Civil Rights Administrator
Arizona Department of Transportation
1135 N 22nd Ave, 2nd Floor
Phoenix, AZ 85009
602-712-7761
Arkansas
James Moore
Internal EEO Coordinator
Arkansas State Highway &
Transportation Department
10324 Interstate 30
Little Rock, Arkansas 72209
501-569-2299
james.moore@arkansashighways.com
California
Alex Morales III
ADA/504 Coordinator
California Department of Transportation
Civil Rights Program
1823 14th Street
MS 79
Sacramento CA 95814
916-324-8764
.
Jerry Champa is the lead for the
Transition Plan effort
California Department of Transportation
Civil Rights Program
1823 14th Street
MS 79
Sacramento CA 95814
916-324-8764
jerry_cham[email protected]]
Page 21
State
ADA Coordinator
Contact
(if different than ADA coordinator)
Colorado
Benjamin Cordova
ADA Coordinator
Colorado Department of Transportation
Center for Equal Opportunity
4201 East Arkansas Avenue, Room 200
Denver, Colorado 80222
303-757-9594
benjamin.cordova@dot.state.co.us
Connecticut
John F. Carey
Transportation Division Chief
Connecticut Department of
Transportation
2800 Berlin Turnpike
P.O. Box 317546
Newington, CT 06131-7546
860-594-2710
Delaware
Linda M. Osiecki, M.E., P.E.
Program Manager, Quality Section
Delaware Department of Transportation
800 Bay Road
P.O. Box 778
Dover, DE 19903
302-760-2342
District of
Columbia
Brett Rouiller
ADA/504 Coordinator
District of Columbia Department of
Transportation
2000 14th Street, NW
5th Floor
Washington, DC 20009
202-497- 4722
Page 22
State
ADA Coordinator
Contact
(if different than ADA coordinator)
Florida
Dean Perkins
ADA Coordinator
Florida Department of Transportation
Haydon Burns Building
605 Suwannee Street
Tallahassee, Florida 32399-0450
850-414-4359
[email protected].fl.us
Georgia
Ulander Gervais
Title VI/Environmental Justice Specialist
Georgia Department of Transportation
Office of Equal Opportunity
2 Capitol Square
Atlanta, Georgia 30334
404-463-6928
[email protected]ate.ga.us
Hawaii
Benjamin Gorospe
ADA Coordinator
Hawaii Department of Transportation
Office of Civil Rights
869 Punchbowl Street #112
Honolulu, Hawaii 96813
808-587-7584
benjamingGorospe@hawaii.gov
Idaho
Karen Sparkman
Director, Civil Rights Section
Idaho Transportation Department
P. O. Box 7129
Boise, ID 83707-1129
208-334-8852
karen.sparkm[email protected]
Page 23
State
ADA Coordinator
Contact
(if different than ADA coordinator)
Illinois
David Dailey
ADA Specialist
Bureau of Civil Rights
2300 South Dirksen Parkway, Room 317
Springfield, IL 62764
217-557-5900
Indiana
Christine D. Cde Baca
Title VI/ADA Administrator
100 North Senate, Room N750
Indianapolis, IN 46204
317-234-6142
Iowa
Roger E. Bierbaum
Director, Office of Contracts
Highway Division
Iowa Department of Transportation
800 Lincoln Way
Ames, IA 50010
515-239-1414
roger.bierbaum@dot.iowa.gov
Kansas
Mike Smith
Internal Civil Rights/ADA Coordinator
Kansas Department of Transportation
Eisenhower State Office Building
700 SW Harrison
Topeka, Kansas 66603
785-296-2279
eeooffice@ksdot.org
Kentucky
Kathy Marshall
Office of Human Resources
Kentucky Transportation Cabinet
200 Mero Street
Frankfort, KY 40601
502-564-4610
KathyN.Marshall@ky.gov
Page 24
State
ADA Coordinator
Contact
(if different than ADA coordinator)
Louisiana
Candy Cardwell
Human Resources Analyst
Human Resources Section
Louisiana Department of Transportation
and Development
P.O. Box 94245
Baton Rouge, LA 70804-9245
225-379-1241
candycardwell@dotd.louisiana.gov
Maine
GiGi Ottmann-Deeves
Maine Department of Transportation
16 State House Station
Augusta, ME 04333
207-624-3036
gigi.ottmann-[email protected]v
Maryland
Linda I. Singer
ADA Title II Coordinator, Legislative
Manager
Office of Policy and Research
Maryland State Highway Administration
707 North Calvert Street
Baltimore MD 21202
410-545-0362
Massachusetts
David Phaneuf
ADA Coordinator
Massachusetts Highway Department
State Transportation Building
10 Park Plaza, Room 3170
Boston, MA 02116
617-973-7722
Angela Rootekoff
Office of Civil Rights
State Transportation Building
10 Park Plaza, Room 3170
Boston, MA 02116
617-973-7025
angela.rootekof[email protected]a.us
Michigan
Tony Kratofil
Bay Region Engineer
55 E. Morley Dr.
Saginaw, MI 48601
989-754-0878
Page 25
State
ADA Coordinator
Contact
(if different than ADA coordinator)
Minnesota
Bruce Latu
Minnesota Department of Transportation
395 John Ireland Boulevard
St. Paul, MN 55155-1899
651-291-1016
Mississippi
Carolyn Bell
Civil Rights Manager
Mississippi Department of Transportation
401 North West Street
Jackson, MS 39201
601-359-7466
Missouri
Lester Woods
External Civil Rights Administrator
Missouri Department of Transportation
1617 Missouri Boulevard
Jefferson City, MO 65109
573-751-2859
lester.woodsJr@modot.mo.gov
Stefan Denson
Missouri Department of Transportation
1617 Missouri Boulevard
Jefferson City, MO 65109
573-751-1355
stefan.denson@modot.mo.gov
Montana
Alice Flesch, Program Manager
Montana Department of Transportation
2701 Prospect Avenue
PO Box 201001
Helena, MT 59620-1001
406-444-9229
aflesch@mt.gov
Nebraska
Jim Knott
Director, Roadway Design Division
Nebraska Department of Roads
Roadway Design
1500 Highway 2
PO Box 94759
Lincoln, NE 68509-4759
402-479-4601
Page 26
State
ADA Coordinator
Contact
(if different than ADA coordinator)
Nevada
Dennis Coyle
ADA/504 Coordinator
Nevada Department of Transportation
1263 South Stewart Street
Carson City, NV 89712
775-888-7598
New
Hampshire
David Chandler
New Hampshire Department of
Transportation
7 Hazen Drive
P.O. Box 483
Concord, NH 03302-0483
603-271-2467
[email protected].nh.us
New Jersey
Chrystal Section-Williams
Title VI Analyst
Division of Civil Rights & Affirmative
Action
New Jersey Department of
Transportation
1035 Parkway Avenue
Trenton, NJ 08618
609-530-2939
chrystal.section-williams@dot.state.nj.us
Paul Thomas
ADA Transition Plan Manager
New Jersey Department of Transportation
1035 Parkway Avenue
Trenton, NJ 08618
paul.thom[email protected]
New Mexico
Jose Ortiz
ADA Coordinator
New Mexico State Transportation
Department
Aspen Plaza1596 Pacheco Street
Santa Fe, NM 87505
505-827-1648
jose.o[email protected].us
Page 27
State
ADA Coordinator
Contact
(if different than ADA coordinator)
New York
David Perez
Compliance Specialist II
New York State Department of
Transportation
Office of Audits and Risk Management
Services
Civil Rights Bureau, Pod 62
50 Wolf Road
Albany, New York 12232
North Carolina
Walt Thompson
Director, Productivity Services
North Carolina Department of
Transportation
1517 Mail Service Center
Raleigh, NC 27699-1517
919-733-2083
[email protected].nc.us
North Dakota
Mark S. Gaydos, P.E.
North Dakota Department of
Transportation
Design Division
608 East Boulevard Avenue
Bismarck, ND 58505-0700
701-328-4417
mgaydos@nd.gov
Roger Weigel
North Dakota Department of
Transportation
Design Division
608 East Boulevard Avenue
Bismarck, ND 58505-0700
701-328-4403
Ohio
Kimberly Watson
EEO Program Administrator
Office of Chief Legal Counsel
Civil Rights Unit
Ohio Department of Transportation
Central Office
1980 West Broad Street
Columbus, OH 43223
614-728-9245
[email protected]ate.oh.us
Page 28
State
ADA Coordinator
Contact
(if different than ADA coordinator)
Oklahoma
Glenn Brooks
Title VI Coordinator
Oklahoma Department of Transportation
200 N. E. 21st Street, Room 1-B4
Oklahoma City, OK 73105
405-521-4139
[email protected]ladot.state.ok.us.
Oregon
Martha Smith
EEO/Affirmative Action/ADA Coordinator
Oregon Department of Transportation
Office of Civil Rights/Human Resources
104 Transportation Building
355 Capitol Street NE
Salem, OR 97301
503-373-7093
martha.sm[email protected]
Pennsylvania
Chris Drda
Chief, Consultant Agreement Section
Bureau of Design
Pennsylvania Department of
Transportation
400 North Street
Keystone Building, 7th Floor
Harrisburg, PA 17120
717-783-9309
Puerto Rico
Ana Olivencia
ao[email protected]p.gov.pt
Page 29
State
ADA Coordinator
Contact
(if different than ADA coordinator)
Rhode Island
Michael Penn
Senior Civil Engineer
Rhode Island Department of
Transportation
Two Capitol Hill
Providence, RI 02903
401-222-2023 x4050
South Carolina
Natalie Moore
ADA Coordinator
South Carolina Department of
Transportation
955 Park Street
Columbia, SC 29201
803-737-1347
adacoordinator@scdot.org
South Dakota
June Hansen
Civil Rights Compliance Officer
South Dakota Department of
Transportation
700 East Broadway Avenue
Pierre, SD 57501
605-773-3540
june.hansen@state.sd.us
Tennessee
Margaret Mahler
ADA Coordinator
Tennessee Department of Transportation
Suite 400 – James K. Polk Building
505 Deaderick Street
Nashville, TN 37243
615-741-4984
margaret.z.m[email protected]
Texas
Jesse W. Ball Jr.
Civil Rights Director
Texas Department of Transportation
Office of Civil Rights
125 East 11th Street
Austin, TX 78701-2483
512-475-3117
Page 30
State
ADA Coordinator
Contact
(if different than ADA coordinator)
Utah
Warren Grames
Risk Manager
Utah Department of Transportation
4501 South 2700 West
4th Floor
Salt Lake City, UT 84114-8430
801-965-4272
Ming Jiang
Pedestrian Safety Engineer
Utah Department of Transportation
4501 South 2700 West
4th Floor
Salt Lake City, UT 84114-8430
801-965-4427
Vermont
Lori Valburn
Director of Civil Rights Programs
Vermont Agency of Transportation
National Life Building - Drawer 33
Montpelier, VT 05633
802-828-5561
lori.valburn@state.vt.us
Virginia
Alexis Thornton-Crump
SPHR, Certified Mediator
Assistant Division Administrator
Civil Rights Division
Virginia Department of Transportation
1401 East Broad Street,
Richmond, VA 23219
804-786-4414
[email protected]ginia.gov
Freddie Jones
Virginia Department of Transportation
1401 East Broad Street,
Richmond, VA 23219
804-786-4552
[email protected]irginia.gov
Washington
Kathryn LePome
ADA Coordinator
Washington State Department of
Transportation
Office of Equal Opportunity
P.O. Box 47314
Olympia, WA 98504
360-705-7097
lepomek@wsdot.wa.gov
Page 31
State
ADA Coordinator
Contact
(if different than ADA coordinator)
West Virginia
Ray Lewis, P.E.
Traffic Research and Special Projects
Engineer
West Virginia Division of Highways
Traffic Engineering
Division1900
Kanawha Boulevard East,
Building Five
Charleston, WV 25305
304-558-3063
Wisconsin
Title VI Coordinator
Civil Rights and Compliance Section
Bureau of Equity and Environmental
Services
Wisconsin Department of Transportation
4802 Sheboygan Avenue, Room 451
Madison, WI 53705
608-266-0208
[email protected].wi.us
Michele Carter and Ronald Ulvog
Facilities Maintenance Personnel
4802 Sheboygan Avenue, Room 451
Madison, WI 53705
608-266-0208
608-266-5359
michele.carter@dot.state.wi.us
ronald.ulvog@dot.dtate.wi.us
Wyoming
Lonny Pfau
Human Resources Manager
Wyoming Department of Transportation
5300 Bishop Boulevard
Cheyenne, WY 82009
307-777-4103
[email protected]te.wy.us
Kent Lambert
Wyoming Department of Transportation
5300 Bishop Boulevard
Cheyenne, WY 82009
kent.lam[email protected]y.us
Page 32
QUESTIONNAIRE
QUESTIONNAIRE FOR DEPARTMENTS OF TRANSPORTATION
DEVELOPMENT OF A BEST PRACTICES GUIDE
TO UPDATE ADA TRANSITION PLANS
NCHRP PROJECT NUMBER 20-7 (232)
The Americans with Disabilities Act (ADA) and other federal statutes place responsibility
on state departments of transportation to meet accessibility requirements for
pedestrians. These requirements include a self-evaluation study to see where the
agency’s facilities stand with regard to accessibility and a transition plan to provide the
needed accessibility improvements. An interview process with state departments of
transportation is being carried out as part of a study called “Development of a Best
Practices Guide to Update ADA Transition Plans”. The study is being sponsored by the
National Cooperative Highway Research Program; Jacobs Edwards and Kelcey is under
contract to conduct interviews and prepare a report. The overall goal of the study is to
ensure that good information, good ideas, and good practices concerning transition
plans for pedestrian accessibility programs are recognized, recorded, and shared.
There are three parts to the questionnaire: (1) the determination of some background
information, (2) a discussion of self-evaluation studies that are used to define needed
accessibility improvements, and (3) a discussion of transition plans that are used to carry
out the improvements needed to bring facilities in line with accessibility standards.
Agency
Contact Person
Title
Telephone Number
E-Mail Address
Date of Discussion
What are your responsibilities?
ADA Coordinator?
Title II Coordinator?
Section 504 Coordinator?
Page 33
Self-Evaluation Plan Manager?
ADA Transition Plan Manager?
Other?
I BACKGROUND
Agencies vary greatly in their responsibilities and their structure and in the nature of the
facilities that they manage. This section is intended to provide some context to help
understand agency planning for accessibility.
1. Agency Responsibilities
The goal of this section is to determine the range of resources that the agency is
responsible for. This range can vary widely between agencies. This study concerns
itself only with highway rights-of-ways but the overall context of the agency’s
responsibilities needs to be understood.
What types of resources is your agency
responsible for?
Highways?
Rest Areas?
Welcome Areas?
Scenic Overlooks?
Recreation Areas?
Office Buildings?
Maintenance Facilities?
Bus Transit Systems?
Bus Stops?
Van Transit Systems?
Rail Transit systems
Public Safety Facilities?
Page 34
Railways?
Ferries?
Airports?
Ports and Harbors?
Pipelines?
Waterways?
Anything else?
2. The ADA Compliance Role Within the Agency
Transportation Agencies vary widely in how they integrate the ADA compliance
responsibility into their organization. The goal of this section is to understand how the
agency assigns the responsibility for ADA compliance.
Where does the ADA Coordinator role fall
within your Agency?
Office of the Commissioner?
Civil Rights Office?
Legal Department?
Public Affairs Department?
Pubic Involvement Department?
Programs Department?
Planning Department?
Design Department?
Right-of-way Department?
Maintenance Department?
Other?
Page 35
3. Document Development
Agencies vary in their progress on formal document development. The goal of this
section is to determine where the agency stands in this process.
Does your agency have a joint self-
evaluation and transition plan?
Where can it be seen?
Is it updated periodically?
Does you agency have a separate self-
evaluation plan?
Does you agency have a separate
transition plan?
Are either of these documents in progress?
4. Compliance Complaints and Suits
The demand for pedestrian accessibility varies based on the nature of the area served.
The goal of this section to understand the nature of the demand for pedestrian
accessibility improvements.
Do you receive complaints about
pedestrian accessibility?
How many?
What are the usual subjects of complaints?
Have you been sued?
Have you entered into any settlements?
Is there an activist community or
organization that focuses on this subject?
Page 36
II SELF-EVALUATION PLAN
The State Department of Transportation is required to conduct a self-evaluation of its
facilities to determine if these facilities are accessible to persons with disabilities. This
can be a massive undertaking. This section is a discussion about how agencies have
undertaken or are planning to undertake this assignment.
1. Inventory of Facilities
The goal of this section is to determine the approach the agency has taken to perform
inventory work.
What is the magnitude of the inventory
challenge?
Roadway miles?
Person hours?
Crew hours?
Months of duration?
What is your initial information base?
Aerial Photography Library?
Map Library?
Drawings?
Field Survey?
Computer Database?
What is your approach to doing inventory
work?
Windshield survey?
On ground survey?
Photo studies?
What is the extent of inventory work?
All pedestrian facilities?
Page 37
Only pedestrian facilities deemed of
concern by the agency?
Only pedestrian facilities in key areas?
Only pedestrian facilities that support a
public service function?
Only pedestrian facilities where complaints
have been received or concerns have
been raised?
Other selection criteria?
What inventory tools have you found
useful?
GPS?
Photography?
GIS Mapping?
Computer Database?
2. Identification of Deficiencies
The goal of this section is to discuss what facilities the agency is typically dealing with
and what some of the common deficiencies are.
What types of facilities are you dealing
with?
Sidewalks?
Curb Ramps?
Curb Cuts?
Driveway Crossings?
Crosswalks?
Ramps?
Medians?
Bus Stops?
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Bike Paths?
Other?
What types of deficiency issues are you
finding?
Clear Width and Other Dimensions?
(Narrow, Below Guidelines)
Grade?
(Steepness, Angle Points)
Cross Slope?
(Steepness, Irregularity, Variability)
Materials and Finishes?
(Deterioration, Inappropriateness)
Discontinuities?
(Missing Sections, Gaps, Drops)
Obstructions?
(Signs, Lights, Mail Boxes, Fire Hydrants,
Newspaper Boxes, Drainage Structures,
Standing Water)
Detectable Warning Systems?
(Missing, Inappropriate Materials,
Inadequate Size, Wrong Location)
Traffic Signal Systems?
(Inadequate Time Allowed, Inaccessible
Buttons, Inoperable Buttons, Lack of
Visually Impaired Provisions)
Lighting?
(Missing, Not Operating, Inadequate
Levels)
Maintenance and Services?
(Snow Removal, Debris Clean Up, Trash
Cans, Recyclable Material Bins)
Access Through Work Zones?
Other?
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3. Validation of Selections
The agency is required to provide an opportunity for people with disabilities and other
interested individuals and organizations to review and comment on the self-evaluation of
facilities. The goal of this section is to determine the approaches used to provide this
opportunity.
Is there an Advisory Group?
How do they function?
Periodic meetings?
Field visits?
Other?
Is there input from activists or
organizations?
Is there input from other agencies?
Is there input from elected officials?
Is there a Community Outreach Effort?
Are there local public meetings about
inventory results?
Are these independent meetings or
piggybacked on other community
meetings?
What means of disseminating information
are being used?
Awareness days?
Newsletters?
Website?
Public Access to Databases?
What means of receiving input are there?
Comment forms at meetings?
Hotline?
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Published e-mail address?
Published mail in address?
Transcriptions of meetings?
Staff memoranda concerning meeting
comments?
Are provisions made to accommodate the
hearing impaired and the visually
impaired?
Is there a list of interested parties
maintained?
Other thoughts?
4. Establishment of a Baseline
There is a need to create a baseline of information to identify needs and have the ability
to document progress. The goal of this section is to investigate how the agency
accomplishes this.
Is the self-evaluation study added on to
some existing database?
What is the nature of that database?
Is the self-evaluation study a stand alone
database?
Is a GIS database used?
Is a spread sheet approach used?
What are the sorting categories?
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III TRANSITION PLAN
The agency must prepare a Transition Plan that identifies deficiencies, develops a
method to make facilities accessible, provides a schedule for making the required
access modifications, and designates a public official responsible for the Transition Plan.
This section is a discussion about how agencies have undertaken or are planning to
undertake this assignment.
1. Designs and Cost Estimates for Improvements
The improvements needed to correct deficiencies have to be defined through a design
and cost estimating process. The goal of this section is to discuss the agency approach
to doing this.
What design standards do you use?
ADA Accessibility Guidelines?
Uniform Federal Accessibility Standards?
Your own standards?
Have your standards been reviewed with
regard to accessibility issues?
Do you have in house design capability
with regard to accessibility issues?
Are design consultants needed?
What cost estimating resources do you rely
on for accessibility improvements?
What escalation factors are you applying to
accessibility improvements?
2. Prioritization of Improvements
A priority ranking for approaching the defined improvements has to be worked out so
that an effective schedule can be established. The goal of this section is to discuss the
methods used to rank the improvements in order of priority.
What is the approach to prioritizing
improvements?
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Population density in the area?
Significant disabled population within the
area?
Proximity to key locations?
Government offices?
Schools?
Hospitals?
Places of employment?
Shopping areas?
The severity of the deficiency?
Is a review of complaints a factor?
Is public demand a factor?
What are the sources of public demand?
Is compatibility with the available budget a
factor?
How are the available budget and the
improvement needs matched?
3. Management Approach to Implementation
The goal of this section is to explore how the agency manages the development of the
transition plan and carrying out the improvements. The development of the plan may be
a one time rather intense effort but the tracking of the implementation of the
improvements will be a less intense long time assignment.
Who is the public official responsible for
the implementation of the Transition Plan?
Who Is the ADA Transition Plan Manager?
Is there an internal committee that
provides input into the Transition Plan
process?
Has any staff been assigned to the
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Transition Plan Process?
How many?
In what capacity?
In what department does the responsibility
for the Transition Plan reside?
What training courses about accessibility
has the staff gone through?
What reference works about accessibility
do you find useful?
Who has responsibility for transition plan
updates?
Have any consultants been contracted
relative to Transition Plan work?
4. Funding Mechanisms
There is no specific funding mechanism related to the improvement of accessibility
deficiencies. Funding might come from many different sources. The goal of this section
is to explore the funding experience of the agency.
Have accessibility improvements been
incorporation into existing programmed
projects?
Has any cost differential been recognized?
Have accessibility improvement been
incorporated into any existing maintenance
programs?
Has any cost differential been recognized?
Have stand alone accessibility
improvements projects been processed
through the Transportation Improvements
Program?
Have you had any instances where an
accessibility improvement was found to be
“unduly burdensome”?
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What sources have resulted in some
funding for accessibility improvement
programs?
National Highway System Program?
Surface Transportation Program?
Highway Safety Improvements Program?
Railway–Highway Crossing Program?
Transportation Enhancements Activities
Program?
Congestion Mitigation/Air Quality
Program?
Recreational Trails Program?
State and Community Traffic Safety
Program?
Safe Routes to School Program?
Other Programs?
Have accessibility improvements been
included in developer impact fees?
5. Scheduling and Budgeting
Schedules and budgets are the tools of implementation. The goal of this section is to
determine how the agency is scheduling and budgeting for accessibility improvements.
Is there an overall completion target date?
Are there milestone dates?
Is there a separate Curb Ramp Installation
Schedule?
Is there a budget line item for accessibility
improvements programs?
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6. Coordination with Other Agencies
Other agencies have authority over pedestrian facilities and have an interest in
accessibility. The goal of this section is to explore the exchange of information and the
handling of interfaces with other agencies.
Are there local government pedestrian
master plans that are used as input and
guidance?
Are there local government transition plans
fro accessibility improvements that are
used as input and guidance?
How is the interface between agency
sidewalks and local sidewalks handled?
Who has authority over bus stops?
How is the interface between sidewalks
and bus stops handled?
What other agencies – transit authorities,
airport authorities, turnpike authorities –
have jurisdiction over pedestrian facilities?
Do you receive input from any social
service agencies?
7. Promulgation and Feedback
The goal of this section is to __________
8. Updating of Database
The goal of this section is to ________
