Starting out as a city’s ADA Coordinator is exciting and daunting. The role itself is mandated by the Americans with Disabilities Act (ADA) so you have the overview of your role laid out for you, but how does it play out in the day to day of your job?
Under Title II of the ADA, the key requirements for a city are:
· Appoint an ADA Coordinator
· Provide Public Notice
· Adopt a Grievance Procedure
· Conduct a Self-Evaluation
· Develop a Transition Plan
There are resources for creating public notices and grievance procedures if they haven’t already been created by a predecessor. The next step, however, isn’t as clear cut. How do you update a self-evaluation or transition plan (if you’re lucky enough to have one from the last decade)? What about if your city’s self-evaluation and transition plan is a historical document created in the 1990’s and never thought of again. Where do you begin? How do you take on this monumental task, especially if your city doesn’t have the resources to hire consultants?
This is where I found myself when I began my journey as an ADA Coordinator. Our city had an out-of-date plan with little resources to devote to it. I am in the midst of the project and want to share a little about my process so far in case it can save you a little bit of time. Disclaimer: there are likely steps or ideas in between that I have missed or could have done better!
Phase 1: Project Initiation, Management, and On-Going Communication
· Create a group of internal ADA liaisons. Make a list of every department and division in your city and reach out to department heads or talk to your boss about who to contact. Having a contact person for each department in your city will help you beyond this project. I meet with this group regularly.
- Tip! Check with your ADA liaisons to learn if any major projects or funding will be going towards improvements to facilities or parks, your city’s website, or anything else this project touches on. Our Facilities team started working with consultants to complete a building conditions assessment so I was able to piggyback onto their project and send the group the ADA Checklist for Existing Facilities for them to complete with no cost and little time needed from me.
· Create a timeline for the project. You do not have to cram this process into one year. You can work on it over a year or two (unless you have an expedited timeline because of a settlement agreement). Also consider who will be the internal and external stakeholders for each phase.
- To plan for each phase, I thought of it as:
- an internal evaluation of city and department policies and procedures (utilizing the ADA liaisons for data collection) followed by
- a physical evaluation of parks, golf facilities, and city facilities.
- Present this timeline to people in your organization from the top down. Present it to the department heads first to answer all questions and get buy in. This will also help fill any liaison gaps that you may have for departments because you will need full participation from all departments.
- Next, present the timeline to your ADA liaison group and any other stakeholders that may be involved with the project. I presented the timeline to our City’s Accessibility and Disability Commission as well.
· Create a website for the project. I did this a little bit into the project rather than at the beginning which worked out fine, but it may have been nice to have it from the start. You can keep any interested stakeholders informed of the process itself, where you are in the process, and any upcoming opportunities for public engagement. Check out my SETP webpage for how I broke up the project phases.
· Gather resources and do your research. The New England ADA Center Action Guide has Self-Evaluation Forms that take you through the process of conducting a self-evaluation and developing a transition plan. Their forms can be edited to fit your city. I reached out to ADA Coordinators who recently completed their plans. Most of the time, this led me back the ADA Action Guide.
- Familiarize yourself with the surveys you will use. Go through and make sure you understand the question and what data it is collecting. This will be helpful for when you delegate data collection to the ADA liaisons.
Phase 2: Policy and Program Evaluation
· Roll out policy and procedure surveys. Use your ADA Liaison meeting to go over each question in the survey and delegate data collection to the liaisons. I recorded and posted these meetings in a Microsoft Teams channel so people could reference the video to understand the survey. This was helpful for anyone unable to attend the initial meeting. I gave them three weeks to collect the data and send it to me. I used this method for Departments and Programs (and program accessibility), General Nondiscrimination, Web Accessibility, and Effective Communication.
- Departments and Programs Survey: Have departments list City-sponsored services, programs, or activities they oversee. Any departments that have programs should fill out a program accessibility survey about the program. If much of the information about a department’s programs is redundant, they can fill out one survey making note of any key differences. Make sure to include the locations of where these programs happen. This will create a priority list for your facilities evaluation.
- Tip! Create a concrete definition of what a program is in relation to this process, so they know the range of items to include. Mine was any program, service, or activity that the public interfaces with (including digitally).
- I used a Program Accessibility survey from a California ADA Coordinator rather than the ADA Action Guide survey for more detailed information about program procedures.
- General Nondiscrimination, Web Accessibility, and Effective Communication: Pull any relevant policies and procedures your city has for these areas of consideration ahead of time so you can share those during the ADA liaison meeting. It is helpful for the liaisons to know and be able to reference the overarching policies in place.
· Analyze the data. Once the data for each area of consideration is submitted, review all responses, and identify trends and areas of improvement for your city. This information helps shape recommendations for your report as well as items for you to work on in the city. My analysis led me to work on policies we were missing, build trainings specific to gap areas, and create an effective communications procedure manual for our staff directly interfacing with the public and their requests. This data helped open conversations with departments about where their teams are in terms of accessibility and helped shape discussions about short- and long-term accessibility planning.
- Tip! If I could do this part again, I would build digital surveys so I could word all questions in plain language and have a better opportunity to assess the data through data collection software rather than manually.
Phase 3: Parks Evaluations (this is my current phase)
· Gather resources: Take the time to go through the ADA Checklist for Existing Facilities and the Play Areas and Miscellaneous checklists. For parks specifically, I used Priorities 1, 3, and 4 from the full ADA checklist as well as the Play Areas and Miscellaneous.
- The U.S. Access Board Accessibility Animations were helpful to understand some of the requirements.
- Priority 2 is for access to goods and services inside facilities and none of our parks had this.
- In Priority 4, I only used the drinking fountain questions.
- In Miscellaneous, I only used the areas of sports activities and team or player seating.
- I borrowed ArcGIS surveys from a project manager in North Carolina that helped shape my data collection efforts for this project.
- I created a plain language version of the Play Areas checklist that I am happy to share with you if your city uses ArcGIS. I used the Play Areas checklist as well as the US Access Board’s A Summary of Accessibility Guidelines for Play Areas. This is the golden resource for surveying play areas in parks.
- You will need a door pressure gauge, a digital level, and a tape measure (that goes to at least 20 feet). You will also need an iPad or tablet if you collect this data digitally. This is important too for taking reference photos of barriers and issues (or good examples to highlight in your report)!
- Tip! Work with an intern to gather this data. Find out if your department or your city’s Parks department can provide you with an intern or check with any local colleges or universities about partnering with a professor for this project. It is easier for collection and safer to work in pairs.
· Gather internal information: Work with your Parks department ADA liaison (and asset manager) to gather information about your city’s parks, including:
- how many parks your city has,
- what amenities each park has (especially play areas), and
- square footage of play areas.
· Assess the parks: Map your routes out prior to going out to the park. I mapped mine out one or two days in advance to be able to monitor and adjust as necessary. Go as early as possible to beat the heat and create a plan that works best for you and your team. We did about 5 hours a day for 4 days each week from 8 AM to 1 PM.
· Engage the public: It is important to get public feedback about what to prioritize for barrier removal and inclusion in parks. I am holding in person engagement workshops and have a digital survey as well. I will use these workshops to demonstrate what inclusion and access can be in parks through images of good examples. We will talk through the examples and the lived experiences of those in attendance to guide the small group conversations.
· Prepare the report: We will create a report outlining the data collected from all 79 City-owned parks and will provide recommendations based on the data and feedback from the public. I searched for many different park department transition plans to pick and choose what elements of each report would work for our report. This report will be given to the Parks division leadership for their long-range planning. It will be sent out to all participants of the workshops and available on our SETP webpage. It will also be included as a section in the much larger Citywide Self-Evaluation and Transition Plan report.
Below is a rough outline of the upcoming stages of the project. Stay tuned for a follow up post about my experiences with these phases and updated content about the rest of the parks project!
Phase 4: Facility Evaluations
The facility evaluations involve the assessment and inventory of ADA barriers within the City’s facilities where the public accesses City programs and services. The evaluation involves the following tasks:
- Conducting ADA facility evaluations and preparing barrier reports;
- Identify ADA barrier removal actions; and
- Involving the public and Accessibility and Disability Commission in identifying issues and drafting barrier removal priorities.
Phase 5: Prepare the ADA Self-Evaluation and Transition Plan
During the final phase, the comprehensive ADA Self-Evaluation and Transition Plan will be developed. The ADA departmental liaison group will review the draft plan and provide comments before distributing the public review draft plan.
The plan will be posted to the City website for public review and public engagement sessions will be scheduled. It is anticipated that the Plan will be available for review in Winter 2023/Spring 2024.
If you have questions or comments about this project or post, Ashley Lichtle, at ADA@slcgov.com.
Ashley Lichtle, MPA, ADAC, is the ADA Coordinator for Salt Lake City, Utah. Ashley works closely with all City departments and divisions to identify and address barriers to access throughout the city and manages ADA requests from constituents. She also serves as the board manager for the City’s Accessibility and Disability Commission. This Commission was formalized in 2022 and is made up of 15 members who represent a diverse range of disability community perspectives and experiences. The Commission’s first formal recommendation of a Closed Captioning Requirement for Businesses in Salt Lake City was signed into law in March 2023. She serves on the Rocky Mountain ADA Center Advisory Committee and the Coalition of Municipal Offices for People with Disabilities. Prior to her work in Salt Lake City, Ashley worked in disability advocacy for Arkansas’s UCEDD, Partners for Inclusive Communities, where she trained state agencies and non-profits on how to provide equal access to and inclusion for people with disabilities.