CC Resolution No. 8805
RESOLUTION NO. 8805
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
CUPERTINO ESTABLISHING AND AMERICANS WITH
DISABILITIES ACT TRANSITION PLAN - FACILITIES
WHEREAS, the 1990 Americans With Disabilities ACT (ADA) mandated state
and local facilities be accessible and usable for the disables; and
WHEREAS, the ADA further requires a transition plan that removes any barrier.;
to that goal; and
WHEREAS, the has been presented to the City Council part one of the transition
plan which surveys the physical barriers identified in City facilities;
NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of
Cupertino approve the City of Cupertino Americans With Disabilities Act Transition
Plan 1992, attached hereto and made part hereofby reference.
PASSED AND ADOPTED at a regular meeting of the City Council of the City of
Cupertino this 7 th day of December , 1992 by the following vote:
Vote Members of the City Council
i\'I'ES: Dean, Goldman, Koppel, Sorensen, Szabo
NOES: None
ABSENT: None
ABSTAIN: None
ATTEST: APPROVED:
Isl Dorothy Cornelius
Isl Nick Szabo
Mayor, City of Cupertino
City Clerk
~
CITY OF CUPERTINO
AMERICANS WITH DISABILITIES ACT
TRANSITION PLAN
1992
A special thanks to the citizens on the ADA Advisory Committee: Martin Bishop,
Sally Brennan, Dan Fiduccia, Carol McDowell and Linda Walker
Table of Contents
Page
I. Introduction 1
II. ADA Standards for Facility Accessibility 3
ill. Survey of City of Cupertino Building Facilities 6
IV. ADA Standards for Park Accessibility 13
V. Survey of City of Cupertino Parks 15
VI. ADA Standards for Signage and Symbols 19
VII. Survey of City of Cupertino Streets and Sidewalks 20
VIII. Complaint Procedure 22
IX. Disability Discrimination and Employee Complaint Policy 25
INTRODUCTION
This transition plan has been developed to comply with the 1990 Americans with
Disabilities Act (ADA) which prohibits discrimination against persons with disabilities,
Title II, Subpart D, Section 35.150(d) requires governmental entities to make all public
facilities accessible and usable. In the event that structural changes to the facilities will be
undertaken to achieve "program accessibility", a transition plan setting forth the steps
necessary for such changes is required.
The transition plan should:
1. IdentifY the physical barriers that limit accessibility to programs and
services for people with disabilities.
2. Outline of methods to be used in removing barriers and making facilities
accessible.
3. Schedule the necessary steps to achieve accessibility by January
1995.
4. Name the official responsible for implementing the Transition Plan.
5. Be available for public inspection for a minimum of three years.
The Act requires structural changes to existing City facilities needed to remove
architectural and commumcation barriers which are "readily achievable" are to be
completed as expeditiously as possible. All barriers are to be removed by January, 1995.
The plan's priority for removal of barriers is based on the following:
1. Access trom sidewalks, parking and bus stops to City building entrances
including curb ramps, entrance ramps, widening entrances and
providing accessible parking spaces.
2. Sidewalk curb ramps.
3. Access to City buildings and facilities where services and programs are
provided to the public.
4. Access to restrooms facilities including widening doors, accessible signage,
widening stalls and correcting heights of dispensers, grab bars and toilets.
S. Access to drinking fountains.
6. Access to public telephones.
7. Provision of Telecommunication Devices for the Deaf (T.D.D.) and
Assistive Listening Devices.
8. Visual and audible fire alarms.
9. Signage including access logos, brai1le and directional signs
The preceding criteria was applied to the City's eight buildings and 14 parks. The highest
priority was given to those facilities that serve the greatest number of people, especially
Memorial Park, Quinlan Center and City Hall.
BuildiDlls
fm
City Hall
Quinlan Center
Senior Community Center
Monta Vista Recreation Center
McClellan Ranch
Service Center
Sports Center
Blue Pheasant
Memorial
Portal
Somerset
Varian
Monta Vista
McClellan
Linda Vista
Three Oaks
Jollyman
W¡\son
Hoover
Fremont-Older
Blackberry Farm Golf Course
Blackberry Farm Picnic Area
Bathrooms
Number accessible
Stalls
Doors to staIls
Grab bars
Hardware
Door closures
Opening force
Toilets
Urinals
Sinks
Controls & dispensers
(towels, soap, etc.)
Signage
Fire a1anns
ADA Standards for Facilities Accessibility
Based on ADA Accessibility Guidelines
for Buildings and Facilities
Minimum of one
36" X 69"
3Z" minimum clear width
34" for side approach
33" above floor; 1 IIZ"clear from wall
(33" to 36" if toilet is tank type)
Must not require tight grasping or
twisting of wrist
3 second minimum sweep from 70 open
5 lbs. maximum
17" - 19" to top of seat
One minimum wall hung or staIl type with elongated run
17" maximum to rim
Clear floor space 30" X 48" minimum
Flush controls - 44" maximum
Wrap exposed pipes. Faucets lever; push or electric type
mirrors at least one 40" to bottom
40" above finished floor
Access logo/geometric symbol for all
Visual (strobe) and audio a1anns to be placed where deaf
people will see them, eSpecially if they are alone.
Standards (Continued)
Assembly Areas (Council Chambers & Soorts Center):
Fixed seating
Two fixed seats are required to be aisle seats with
removable, folding or no arm rests and adequately
identified
Spaces for wheelchairs
Clear floor space 30" X 48" spaces - four required
for council chamber
Assisted listeuing systems
in council chambers
and Cupertino Room
Required fixed seating areas with a capacity greater than
50 and in assembly areas with existing audio systems
Notify patrons of availability by signs Cupertino Room
of Quinlan Center and council chamber
Main Entrances:
Rises greater than 6"
Lift or ramp required smooth surfaces especially at
threshold
Signage
Directional access logo Braille
Doors
One leaf or two leaf door accessible
Three second minimum sweep hardware must not
require tight grasping or twisting threshold - 1/2"
clearance
Handrails
30" - 34" in height
Stairs
No open risers except where also served by elevator
1 112" clearance to wall continupus, no interrupting posts
Standards (Continued)
Parkin!! Lots:
Number of spaces
One handicapped space for every 25 spaces. Minimum
of one van space and one in every eight spaces for van
unloading area provided at side of designated space cwb
cuts or ramps from lot to main entrance.
Size for van parking 9' X IS'
Si2nal!e:
Directional
Indication direction to accessible features
Indicating bathrooms and toilet stalls which are
accessible.
Directional signs in Braille
Fire a1arms
Visual and audible a1arms
Interior doors
Five Ibs. maximum opening force except for fire door.
Pay phones
4S" to coin slot, 27" clearance below phone,
cord length 29" long
Drinking fountain
9" from ground clearance for feet
27" to bottom of fpunlain pan
36" maximum to bubbler
30" X 4S" floor space
Must be approachable straight on
Architectural Barriers to Access for People with Disabilities
Survey of City of Cupertino Building Facilities
The following Facilities Report for ADA constitutes the identification of the physical
barriers in city buildings that limit accessibility to programs and services for people with
disabilities.
This report also includes estimated costs and the fiscal year recommended for the
modifications to be made.
That facilities are accessible can be communicated by the effective use of the access logo.
Further communication about accessibility is planned for the Cupertino Scene.
FACannES REPORT FOR ADA
BUILDING CATEGORY NOTE COST DATE
City Hall
Parking Signs: $ 25.00 93-94
Directional
Tow-away (6) 60.00
Entrances Automate front door 1,000.00 93-94
Bevel thresholds (4) 600.00
Access logo 25.00
Interior Routes Adjust door closures 28.00 92-93
Restrooms Replace sink faucets 175.00 93-94
Install full length mirror (4) 260.00
Council Chamber:
Assembly Area Moditÿ arms of two seats 300.00 94-95
Create space for four
wheelcbairs by removing
four seats
Purchase assistive listening
device 500.00 94-95
Telephones Purchase T.D.D. place 800.00 93-94
with receptionist
Signage To identify access
throughout 1000.00 93-94
Buzzers for lower level 150.00 93-94
recreation area
Rounded Subtotal (or City Hall: 54,000.00
Quinlan Center
Parking Add two disabled parking stalls 60.00 93-94
Tow-away signs (6) 60.00 93-94
Directional signs (3) 75.00 93-94
Entrances Automate front doors (2) 3000.00 93-94
Add access logo to front door 25.00 93-94
BUlLDlNG CATEGORY oom OOSI DATE
Quinlan (continued)
Interior Routes Adjust door closure to 5 lbs. 28.00 92·93
or less opening force
Telephones Purcbase T.D.D. 800.00 93·94
Assembly Areas Assistive Listening Device 500.00 94·95
for Cupertino Room
Fin: Alarm Add visual strobe 500.00 94-95
Rounded Subtotal for QuiDlan Ceuter 54,000.00
Senior Center
Parking Access logo 25.00 92-93
Exterior Routes ModifY patio picnic tables for
wheelchair access(2) 52.00 92-93
Widen door from patio to
cardroom 800.00 94-95
Entrances Automate front door 1500.00 93-94
Bevel thresholds (3) 25.00 93-94
Restrooms Replace sink faucets 175.00 93-94
Wrap hot water pipes 28.00 92-93
Install fuIllengtb mirrors 260.00 92-93
Lower dispensers to 40" 56.00 92-93
Work/plan surface Purcbase four caddies on
casters to accommodate
wheelchairs 350.00 93-94
Buy two extra tall car tables 150.00 93-94
Rouuded Subtotal for Senior Center 53,400.00
BUILDING CATEGORY NOTE ~ DATE
Service Center
Parking Add one van space 52.00 93-94
Directional signs/access logo
Exterior Routes Handmil at entranœ ramp 800.00 93-94
Bevel front entrance 150.00 93-94
Automate front door 1500.00 93-94
Telephone Remount pay phone to PACBELL 92-93
48" to coin slot and add
29" cord
Rounded Subtotal for Service Center 52,soo.00
Monta Vista Recreation Center
Parking "Tow-away" signs 60.00 93-94
Stripe for van staIl 52.00
Exterior Routes Hard pack route to bleachers 1200.00 94-95
Handrails along including ramps 1500.00 94-95
Directional access signs 150.00 93-94
Entrances Door closures adjusted 28.00 92-93
Opening force for doors adjusted 28.00 92-93
Restrooms Acx:ess logos 25.00 93-94
Grab bars reinstalled 65.00 93-94
Wrap exposed pipes 26.00 92-93
Replace sink fàuœts (4) 500.00 93-94
Install full length mirrors 520.00 92-93
Lower dispensers 104.00 92-93
Signagc Needed everywhere 500.00 93-94
Audiolvisual fire alarms 1000.00 94-95
Rounded Subtotal for Mouta VIsta Center $6,000.00
BUILDING CATEGORY NOTE !X!SI DATE
Sports Center
Parking Add two accessible parking
spaces 104.00 93·94
Relocate van space on flat
surface 52.00 93-94
Curbcut at accessible parking
spaces 750.00 93-94
Exterior Routes Pathway from Stevens Creek
to lower level on cast ofbldg. 1250.00 94-95
Directional signs 150.00 93-94
Wheelchair lift to front door 10,000.00 93·94
Handrail at front entrance 800.00 93·94
Entrances Automate front door 1250.00 93-94
Bevel thresholds (2) 300.00 93-94 ,
Drinking
Fountain Properly mountccl (2) 2000.00 93·94
(one inside-one outside)
Interior Routes ·Elevator 30,000.00
Doors
Hardware (5) 500.00 93·94
Thresholds beveled (3) 450.00 93·94
Adjust opening force 26.00 93-94
Restrooms Door clearance requites
removal of modesty screen 56.00 94-95
Reconfigure toilet stalls 756.00 94·95
1nsta11 correct urinal 350.00 94·95
Wheelchair clearance
under sink 750.00 94-95
Replaa: faucets 600.00 94-95
Wrap exposed pipes 310.00 94-95
1nsta11 full length mirrors 560.00 94-95
Lower dispensers to 40" 250.00 94-95
Access logo 25.00 94-95
Telephones Replaa: at correct height PACBELL 92-93
.The future of the Sports Center is subject to a master plan that has not yet been completed. Before a
sum as large as that for the elevator is expended, the size of the facility and its program uses arc needed.
Lower level access is possible without the elevator.
BUlLDING CATEGORY NOTE COST DATE
Sports Center (continued)
Signage Access logos & braille 300.00 94-95
Visual fire a1ann 300.00 94-95
Rounded Subtotal for Sports Center 552,000.00
Blue Pheasant Building·
Parking 6 accessible spaces required
including one van space 300.00 94-95
Directional signs 50.00 94-95
Exterior Routes Ramp tp pro-shop replaced
at correct slope and texture 18,000.00 94-95
Handrails 2000.00 94-95
Thresholds to outdoor ,
restrooms 450.00 93-94
Entrances Wheelcbair lift at front door 10,000.00 94-95
Automate front door 1500.00 93-94
Bevel threshold 150.00 93-94
Handrails 1500.00 93-94
Widen lower outside doorway 5000.00 94-95
Drinking
Fountain Replace at pro-shop 1000.00 94-95
Restrooms (Inside
&Outside) Reconfigure stalls 2400.00 94-95
Install grab bars 85,00 94-95
Replace urinals 700.00 94-95
Replace with accessible sinks 1000.00 94-95
Wrap exposed pipes 104.00 94-95
Change faucets 704.00 94-95
Install full length mirrors 660,00 94-95
LPwer dispensers 78.00 94-95
Widen exterior doors (2) in
outside restrooms 1132.00 94-95
Telephones Locate pay phones at
correct height PACBELL 92-93
Ronnded Subtotal for Blue Pheasant 546,813.00
·The restaurant portion is leased for operation. Renegotiations for the restaurant will address whose
obligation it is to make the required modifications before the January, 95 deadline.
BUILDING CATEGORY NOTE gm DATE
Blackberry Farm
Exterior Routes Ramp to pump room 500.00 94-95
Ramp & fence reconfigurations 1500.00 94-95
to 2nd pool to include
port-a-potties
Ramps on creek crossing (2) 1500.00 93-94
Telephone Relocate to flat grade PACBELL 94-95
Fire Alarms V1SU8I and audio (10) 100.00 94-95
Restrooms Reconfigure stalls 2400.00 94-95
Install grab bars 85.00 94-95
Install urinal 350.00 94-95
Wrap exposed pipes 104.00 94-95
Install fu1llength mirrors 660.00 94-95
Lower dispensers 104.00 94-95
Reconfigure Woman's Dressing
room 450.00 94-95
Shower outside
Stalls Remove screen 208.00 94-95
Lower & modify faucets 450.00 94-95
Showerhead outdoors at
2nd pool 150.00 94-95
Pools Lifts for pools (2) 7000.00 94-95
Drinking
Fountain RepIaa: (2) 2000.00 94-95
Rounded Subtota1 for Blackberry Farm 518,000.00
ESTIMATED FOR ALL BUILDINGS $136,700.00
ADA Standards for Park Accessibility
Parkinll Lots
Number
One bandicapped space per 25 spaces with a
minimum requirement of one
One in every eight spaces, but not less than one,
aa:essible van space (96" minimum width)
Signs
International symbol for access
Signage for van space
Geometric symbols for bathrooms
Exterior Routes
RequiIed from buildings to transportation stops,
parking and sidewalks
Trees
Pruned to 72" above ground
Texture
Stable, firm and slip resistant
Width
36" minimum
48" minimum for sidewalks
Cbange in levels
Greater than 112" requires bevel with ratio of
1:2; or ramp with ratio ofl:12
Picnic Tables
Modifications to a minimum of one table to allow
a wheelchair to use facing forward
Standards (Continued)
Bathrooms
Number accessible
Minimum of one
Stalls
36" X 69"
Doors to stalls
32" minimum clear width
34" for side approach
Grab bars
33" above floor 1 112" clear from wall
(to 36" above floor if tank type toilet)
Hardware
Must not require tight grasping or twisting of
wrist
Door closures
3 second minimum sweep from 70 open
Opening force
S lbs. maximum
Toilets
17" - 19" to top of seat
Urinals
One minimum; wall hung or stall type with
elongated rim 17" maximum to rim 30" X 48"
of clear floor space
Flush controls - 44" maximum
Pay phones
Maximum of 48" to coin slot
27" clearance to fountain pan
36" maximum to bubbler
30" X 48" floor space
Must be approachable straight on
Drinking Fountains
9" clearance from ground for feet
27" from ground to fountain pan
36" maximum to bubbler
30" X 48" floor space
Must be approachable straight on
Barriers to Access for People with Disabilities
Survey of City of Cupertino Parks
The following Facilities Report for ADA constitutes the identification of the physical
barriers in parks that limit accessibility to programs and services for people with
disabilities.
This report also includes estimated costs and the fiscal year recommended for
modifications to be made.
Communication regarding the accessibility of pads are planned for the Cupertino Scene.
Park Report for ADA
PARK CATEGORY NOTE ~ DATE
Memorial Bathroom Lower dispensers 56.00 93-94
Grab bars 65.00 93-94
Programs Tennis viewing for wheelchairs 750.00 94-95
Drinking
Fountains Install two 2924.00 93·94
Signs Access logo 250.00 93-94
Picnic Tables Moditÿ two 104.00 93-94
Pathways Smooth and widen 600.00 ongoing
Telephone Request pay phone outside
Senior Center 92-93
McClellan Ranch Drinking
Fountain Install one 1982.00 93-94
Parking Paint van stall 52.00 93-94
Picnic Table Moditÿ one 52.00 93-94
Bathrooms Install mirror 260.00 94-95 ,
Wrap pipes 28.00 94-95
Reconfigure stalls 700.00 94-95
Bevel entrance 600.00 94-95
Grab bars installed 65.00 94·95
Replace urinal 350.00 94-95
Replace sink fauœts 175.00 94-95
Lower dispensers 56.00 94-95
Signs Directional 25.00 94-95
Access logos 25.00 94-95
Restroom designations 150.00 94-95
Pathways Harden surface of trails 1200.00
Telephone Request installation of pay phone 92-93
Monta Vista Picnic Tables Moditÿ one 52.00 93-94
Parking Paint van stall 52.00 93-94
Linda Vista Topography This padt is located on a hillside.
Its nature prohibits slopes which
meet ADA standards and as such
is exempted from regrading.
Signs Access logo 100.00 93-94
Drinking
Fountain Install one 1982.00 93-94
Bathrooms Remove modesty screen at
entrance 500.00 94-95
PARK CATEGORY NOTE OOSI DATE
Portal
Topography The slopes of the pathway are
not to standard due to the quick
rise to the back of the park.
Re-grading will be required one day Undeternúned
Signs Access logos 100.00
Bathrooms Remove screening at entrance 500.00 94-95
Grab ban 65.00 94-95
Lower dispensers 56.00 94-95
Install minor 260.00 94-95
Wrap pipes 28.00 92-93
Recon1igure stalls 700.00 94-95
Replace sink faucets 175.00 94-95
Picnic Tables MPdify one 52.00 93-94
Drinking
Fountain Install one 1982.00 93-94
Somerset Topography The slope of the pathways
are not to standard due to the
rise to the back of the park
Picnic Tables MPdify one 52.00 93-94
Varian Drinking
Fountain Install one 1982.00
Picnic Tables MPdify one 52.00 93-94
Signs Tow-away
Wilson Signs Directional to accessible
entrance 150.00 93-94
Drinking
Fountain Install two 3132.00 93-94
Picnic Tables MPdify one 52.00 93-94
Jollyman Picnic Tables Modify one 52.00 93-94
Parking Both lots - stripe for van stall 104.00 93-94
Steps V1SU8l striping 28.00 92-93
Signs Access logo 150.00 93-94
Club cut SE parking area
Three Oaks Drinking
Fountain Install one 1932.00 93-94
Picnic Tables MPdify one 52.00 93-94
Parking signs Install 77.00
Club cut Modify slope & traction
Hoover Picnic Table MPdify one 52.00 93-94
Rounded Total Costs: 25,000.00
o·
ADA Standards for Signage and Symbols
Letters and numbers width to height ratio of3:5
Minimum character height of 3"
Letters and numbers shall be raised 1/32" and be accompanied by Braille at a height of at
least 5/8" and no higher than 2"
Characters and background of signs shall be non-glare and in contrast with each other
Permanent signs placed adjacent to latch side of door no higher than 60" above the
finished floor
Symbols of Accessibility
Facilities and elements which are accessible should be identified with international symbol
of accessibility
Telephones should be separately identified if:
Volume controlled
Text telephone
Assistive listening systems need to be identified
It has not yet been determined by the Department of Justice whether or not a closed
captioned system must be used with The City Channel. The costs range rrom $15,000 to
$35,000 depending on quality. Additionally, a stenographer would be required at all
telecasted meetings at an approximate cost of$100.00 per hour.
Signage needs have been identified in the previous surveys offacilities and parks.
Barriers to Access for People with Disabilities
Survey of City of Cupertino Streets and Sidewalks
The following projects were identified during the public hearings held in July, 1992, It
should be noted that public consensus that the City of Cupertino's streets and sidewalks
are remarkably accessible due to an active program for curb ramps and maintenance.
PROJECT ~ DATE
Complete sidewalk along
Bubb Road Grant will fund 93-94
Flatten sidewalk Ongoing program
Straighten sidewalks on Council must decide to remove
Stevens Creek Blvd. between the street trees or buy right-of-way,
Stelling and De Anza The sidewalk itself would be
approximately $7 per sq. foot.
Audible traffic light at
Bandley and Stevens Creek $ 1,000.00 93-94
Flashing caution light at
Saich and Stevens Creek 6,000.00 93-94
Install sidewalk and curb 93-94
ramps at bus stop on Wolfe Rd.
at Hewlett Packard entrance 2,600.00
Cwb ramps to walkway on 280lWolfe
overpass 4,000.00 93-94
Sidewalk on De Anza near Stevens Already scheduled 93-94
Creek (by PWV Bank)
KirwinlMcCleUan - curb ramps 2,000,00 93-94
Sears driveway on Stevens Creek needs 93-94
a slope correction
WheatonIPortaI - curb ramps 2,000,00 93-94
Rounded Total of Streets and Sidewalk Projects S 17.600
COMP~PROCEDURE
In February, 1992 the City Council adopted a resolution that established a Disability
Discrimination Policy which, among other things, established a procedure for investigating
and resolving internal disability discrimination complaints related to employment practices.
The entire policy follows as Exhibit A
Adoption of this transition plan establishes a similar complaint procedure for any
individual that believes they have been subjected to unlawful discrimination on the basis of
disability by the City of Cupertino, its employee(s), services or programs.
CITY OF CUPERTINO
ADA COMPLAINT PROCEDURE
POLICY
Any individual who believes that they have been subjected to unlawful discrimination on
the basis of disability by the City of Cupertino, its employee(s), service or program may
file a complaint.
A complaint is a formal expression of dissatisfaction with an employee, policy, service or
program provided by the City of Cupertino regarding access or discrimination on the basis
of disability as defined in the Americans with Disabilities Act of 1990.
PROCEDURE
I. Any individual who believes he or she has been discriminated against on the basis of
disability including being denied access to facilities and programs, may make a '
written complaint as soon as possible after the incident. In order to facilitate the
investigation, the complainant is encouraged to submit the complaint within 30 days
of the alleged incident(s).
In all cases, complaints must be received in writing and include the location and date
the alleged incident occurred. All complaints should be sent to the Assistant to the
City Manager's office, City Hall, 10300 Torre Ave., Cupertino, 95014, for
resolution. A written record of the complaint and the action taken will be maintained
by the City. A decision by the Assistant to the City Manager will be rendered in
writing within 30 working days. For additional information or assistance, call (408)
252-4505 (voice) or (TDD). Copies of this policy are available in
large print.
2, The complaint shall include:
a description of the alleged discriminating activity, policy, program or service;
dates(s), tirne(s) and location(s) ofincidents(s);
name( s), of witnesses, if any;
complainant's address and telephone number;
copies of documents; and
remedy desired.
3. Upon receipt of a complaint, the Assistant to the City Manager ( or designee) shall
cause an investigation of all charges to be made. The investigation shall include
interviews with: (a) the complainant; (b) the person(s) responsible for the activity,
policy, program or service engaged in the alleged incident; and (c) any other person
believed to have relevant knowledge concerning the complaint.
4. Upon completion of the investigation, the Assistant to the City Manager (or
designee) shall review factual information gathered through the investigation to
determine whether the alleged complaint constitutes discrimination, giving
consideration to all factual information, the totality of the circumstances, including
the nature of the activity, program or services and the context in which the alleged
incidents occurred.
5. The Assistant to the City Manager shall then prepare a written report stating the
results of the investigation and the determination as to the action(s) to be taken, if
any. The results of the investigation and recommendation(s) shall be conveyed to
appropriate persons, including the complainant and the person( s) responsible for the
alleged activity, policy, program or service engaged in the incident. The decision of
the Assistant to the City Manager is final.
6. The complainant's right to a prompt and equitable resolution of the complaint will
not be impaired by the complainant's pursuit of other remedies, such as the filing of a
complaint within the Department ofJustice or other appropriate federal agency, or
the filing of a suit in state or federal court. Complaints to any federal agency must lie
within 180 days of the alleged discrimination.
J
Disability Discrimination Policy
And Complaint Procedure
I. PURPOSE
The purpose of this policy is:
to prohibit and eliminate any discrimination in employment against a qualified
individual with a disability;
to define what constitutes "disability";
to define who is a "qualified individual with a disability'"
to define discrimination on the basis of disability; and
to establish a procedure for investigating and resolving internal disability
discrimination complaints.
II, POLICY
Discrimination on the basis of disability against an applicant or an employee who is a
qualified individual with a disability, by a supervisor, management employee, or
coworker is not condoned and will not be tolerated. This policy applies to the job
application process and to all terms and conditions of employment including, but not
limited to, hiring, placement, promotion, disciplinary action, layoff, recall, transfer,
leave of absence, compensation and training.
All complaints of discrimination on the basis of disability will be promptly and
objectively investigated.
Disciplinary action up to and including termination will be instituted for behavior in
the definition of discrimination on the basis of disability set forth below.
Any retaliation against a person for filing a discrimination charge or making a
discrimination-complaint is prohibited, even if the complaint is not upheld.
ill. DEFINITIONS
A. Disability
"Disability" is: (1) a physical or mental impairment that substantially limits one or
more major life activity; or (2) having a record of such an impairment; or (3) being
regarded as having such an impairment. .
Disability Discrimination Policy and Complaint Procedure
Page 2
1. Physical or Mental Impairments
Physical or mental impairments include, but are not limited to: vision, speech
and hearing impairments; emotional disturbance and mental illness; seizure
disorders; mental retardation; orthopedic and neuromotor disabilities; learning
disabilities; diabetes; heart disease; nervous conditions; cancer; asthma;
Hepatitis B; my infection; and drug addiction if the addict has successfully
completed or is participating in a rehabilitation program and no longer uses
illegal drugs.
The following conditions are not physical or mental impairments:
transvestitism; illegal drug use; homosexuality and bisexuality; compulsive
gambling, kleptomania; pyromania; pedophilia; exhibitionism; and voyeurism;
pregnancy; height; weight; eye color; hair color; left-handedness; proverty; lack
of education; a prison record; and poor judgment or quick temper if not
symptoms of a mental or physiological disorder.
2. Substantial Limitation of Major Life Activities
An individual is disabled ifhe or she has a physical or mental impairment that
(a) renders him or her unable to perform a major life activity, or that (b)
substantially limits the condition, manner or duration under which he or she can
perform a particular major life activity in comparison to other people.
Major life activities are functions such as caring for oneself, performing manual
tasks, walking, seeing, hearing, speaking, breathing, learning and working.
In determining whether physical or mental impairment substantially limits the
condition, manner or duration under which an individual can perform a
particular major life activity in comparison to other people, the following
factors sha1l be considered:
a. the nature and severity of the impairment;
b. the duration or expected duration of the impairment; and
c. the permanent or long-term impact (or expected impact) of or resulting &om
the impairment.
Disability Discrimination Policy and Complaint Procedure
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In determining whether a physical or mental impairment substantially limits an
individual with respect to the major life activity of "working, " the following
factors should be considered:
a. the geographical area to which the individual has reasonable access;
b. the job trom which the individual has been disqualified because of an
impairment and the number and types of jobs within that geographical area
utilizing similar training, knowledge, skills or abilities trom which the
individual is also disqualified because of the impairment; and/or
c. the number and types of other jobs within that geographical area not
utilizing similar training, knowledge, skills or abilities (to the job trom
which disqualified) trom which the individual is also disqualified because '
of the impairment (broad range of jobs in various classes).
3. Having a Record of Impairment
An individual is disabled ifhe or she has a history of having an impairment that
substantially limits the peñormance of a major life activity; or has been
diagnosed, correctly or incorrectly, as having such an impairment.
4. Regarded as Having a Disability
An individual is disabled if he or she is treated or perceived as having an
impairment that substantially limits major life activities, although no such
impairment exists.
B. Qualified Individual with a Disability
A "qualified individual with a disability" is a person who (1) satisfies the
job related requirements for the position, and (2) can peñorm the "essential
functions" of the position despite their disability, or who (3) with
"reasonable accommodation" can perform the essential functions of the
position.
Disability Discrimination Policy and Complaint Procedure
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1. Satisfied Job-Related Requirements
The first step is to determine whether the disabled individual satisfied the job-
related requirements of the position. SatisfYing the job-related requirements of
the position means that the disabled individual possesses the appropriate
educational background, employment experience, skills, and license required for
the position.
2. Essential Factors
The second step is to determine whether the individual can perform the essential
functions of the position despite their disability. Essential functions are the
fundamental duties of a position. Marginal or peripheral functions of a position
are not essential functions.
A function may be essential because:
a. the reason the position exists is to perform that function;
b. of the limited number of employees available among whom the
performance of that job function can be distributed; and
c. it is highly specialized and requires specific expertise or skill to
perform.
The following factors shall be considered in determining whether a function is
essential: the agency's judgment as to which functions are essential; written job
descriptions; the amount of time spent on the job performing the function; the
consequences of not requiring the performance of the function; the terms of a
collective bargaining agreement or MOU; and the work experience of past and
present incumbents in the position.
3. Accommodation
If the individual cannot perform the essential functions despite their disability,
the third step is to determine whether reasonable accommodation would enable
the individual to perform the essential functions of the position.
Disability Discrimination Policy and Complaint Procedure
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Accommodation is any change in the work environment or in the way things are
customarily done that enables a disabled individual to enjoy equal employment
opportunities. Accommodation means modification or adjustments:
a. to a job application process to enable an individual with a disability to be
considered for the position;
b. to the work environment in which a position is performed so that a disabled
person can perform the essential functions of the position; and
c. that enable disabled individuals to enjoy equal benefits and privileges of
employment as other similarly situated employees without disabilities enjoy.
Accommodations includes making existing facilities and equipment used by
employees readily accessible to and usable by individuals with disabilities.
Accommodation applies to:
*
all employment decisions and to the job application process;
*
all services and programs provided in connection with employment;
*
non-work facilities provided by the agency to all employees; and
*
known disabilities only.
Accommodation is not required if:
*
it eliminates essential functions of a position ftom the disabled individual's
job; or
*
adjustments or modifications requested are primarily for the benefit of the
disabled individual.
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4. Undue Hardship
Agency will not provide an accommodation that imposes an "undue hardship"
on the operation of the agency's business. Undue hardship means significant
difficulty or expense incurred in the provision of accommodation. Undue
hardship includes but is not limited to financial difficulty. Undue hardship refers
to any accommodation that would be unduly costly, extensive, substantial or
disruptive, or that would fundamentally alter the nature or operation of the
business.
Whether a particular accommodation will impose an undue hardship is
detennined on a case-by-case basis. The following factors will be considered in
determining whether an accommodation would create an undue hardship: the
nature and cost of the accommodation; the financial resources of the agency;
the number of employees; and the type of operations of the agency, including ,
the composition and functions of its workforce.
5. Determining the Appropriate Accommodation
If a qualified individual with a disability requests the provision of a reasonable
accommodation, the agency shall engage in an informal, interactive process
with the disabled person which identifies the precise limitations resulting £Tom
the disability and the potential accommodations that could overcome those
limitations.
The accommodation process shall generally involve five steps. First, the agency
shall analyze the particular job at issue and determine its purpose and essential
functions. Second, the agency shall consult with the disabled individual to
ascertain the precise job-related limitations imposed by the individual's
disability. Third, the agency shall consult with the disabled individual to identify
potential accommodations. Fourth, the agency shall assess the effectiveness of
each potential accommodation with regard to enabling the individual to perform
the essential functions of the position. Finally, the agency shall consider the
preference of the individual to be accommodated and select and implement the
accommodation that is not appropriate for both the employee and the agency.
Disability Discrimination Policy and Complaint Procedure
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C. Discrimination on the Basis of Disability
Discrimination on the basis of disability means:
to limit, segregate, or classify a job applicant or employee in a way that
may adversely affect opportunities or status because of the applicant's or
employee's disability;
to participate in a contract which could subject an applicant or employee
with a disability to discrimination;
to use any standards, criteria or method of administration which could have
the effect of discriminating on the basis of disability;
to deny equal jobs or benefits because of a disability;
to fail to make reasonable accommodations to known physical or mental
limitations of an otherwise qualified individual unless it can be shown that
the accommodation would impose an undue hardship;
to use a selection criteria which exclude disabled person unless the criteria
is job-related and consistent with business necessity; and
to fail to use employment tests in a manner that ensures that the test results
accurately reflect the applicant's or employee's skills or aptitude for a
particular job.
IV. Complaint
I. A job applicant or employee who believes he or she has been discriminated
against on the basis of disability may make a written complaint as soon as
possible after the incident to: (a) comp1ainant's immediate supervisor; (b)
comp1ainant's department head; or (c) the Assistant to the City Manager who
has been designated to coordinate agency's efforts to comply with federal and
state laws concerning employment discrimination on the basis of disability.
In order to faci1itate the investigation, the complainant is encouraged to submit
the complaint within 30 days of the alleged incident(s). Where reasonable
circumstances prevent the filing of the complaint within this time period,
complaints received after this time period may be accepted.
Disability Discrimination Policy and Complaint Procedure
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2. The complaint shall include:
* a description of the offending behavior( s) or violations;
* date(s), time(s) and location(s) ofincident(s);
* name( s) of alleged offender( s);
* name(s) of witnesses, if any; and
* remedy desired.
3. Complainant's immediate supervisor or department head shall refer all
complaints received to the Assistant to the City Manager,
4. Upon receipt of a complaint, the Assistant to the City Manager shall
investigate all charges. The investigation shall include interviews with:
(a) the complainant; (b) the person(s) allegedly engaged in discrimination,
and (c) any other person believed to have relevant knowledge concerning
the complaint.
5. Upon completion of the investigation, the Assistant to the City Manager
shall review the information gathered through the investigation to
determine whether the alleged conduct constitùtes discrimination, giving
consideration to all factual information, the totality of the circumstances,
including the nature of the alleged discriminatory conduct and the context
in which the alleged incidents occurred.
6. The Assistant to the City Manager shall then prepare a written report
setting forth the results of the investigation and the determination as to
whether discrimination occurred. The results of the investigation shall be
conveyed to appropriate persons including to the complainant, the
person(s) allegedly engaged in discrimination, the supervisor, and the
department head.
7. If it is determined that discrimination occurred, swift and appropriate
disciplinary action will be commensurate with the severity and/or rrequency
of the offense.
8. Reasonable steps shall be taken to protect the victim and other potential
victims rrom further discrimination.
Disability Discrimination Policy and Complaint Procedure
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9. Reasonable steps shall be taken to protect the victim fÌ'om retaliation as a
result of communicating the complaint.