ADA transition plan: What you need to know now
Every agency must document its intent to meet the Americans with Disabilities Act (ADA) requirements—and developing a transition plan based on self-evaluation is the way to do it. Workshop presenters at the City Engineers Association of Minnesota annual meeting in January offered perspectives from three levels of government—state, county, and city—to help all agencies meet both the requirements and spirit of the law.
Why create a transition plan?
Lynnette Geschwind, ADA Title II coordinator for the Minnesota Department of Transportation (MnDOT), provided the state perspective. MnDOT's self-evaluation and transition planning process is based on the idea that "any public entity must make all of its facilities accessible," she said. She defined the two parts of an evaluation and transition plan: The self-evaluation portion consists of an inventory of programs, services, and activities to determine which ones are accessible. The transition plan identifies corrections that need to be made. "In Minnesota, we're all behind on transition plan requirements—but we are under way," she said.
Why do the plan? Beyond being an ADA requirement, Geschwind said the transition plan provides a better understanding of your system. It creates the opportunity to get input from the disabled community at the program level. And, it helps agencies develop investment priorities. Having early input about where improvements are needed is very useful information to have before projects are budgeted and implementation begins, she said.
What steps should be taken to create a transition plan? After identifying the existing facilities, programs, and services that limit access, Geschwind advised these steps:
- Describe the methods to be used to make them accessible.
- Specify a schedule by prioritizing the needs of persons with disabilities—which also means being willing to interrupt the schedule when an issue or complaint is raised by an individual with a disability.
- Identify the official response for seeing that the plan is implemented. "The ADA coordinator has oversight for general compliance in your jurisdiction," she said.
MnDOT's transition plan timeline began in July and August of 2009 when the plan was written and put out for public comment. The written transition plan was then revised in April 2010. Curb ramp and pedestrian bridge inventories were done in the summer of 2011; the sidewalk inventory is not yet finished but is expected to be complete in summer of 2012.
The transition plan has led to a number of positive outcomes within MnDOT, Geschwind said. For example, major revisions to the accessibility design have occurred; an investment program was developed; the internal advisory structure was revamped to organize staff around the initiative; the transition plan was published; and a training plan has been developed.
There are some ongoing challenges, according to Geschwind. "This isn't a plan you write once and then it's done," she said.
The current version of MnDOT's ADA transition plan, an outline of how it's being revised to comply with this important statute, and other ADA resources are available online.
'The right thing to do': a county perspective
Pete Lemke provided a county perspective on ADA transition planning by sharing how Hennepin County ensures that its transportation system is accessible to all.
In 2010, in response to a complaint that Hennepin County didn't have a transition plan for public right-of-way, the county took steps toward compliance. First, it did a self-evaluation in conjunction with a Complete Streets Inventory. This provided a summary of sidewalks, ramps, and truncated domes, along with other elements such as travel lanes, trails, crosswalks, and sidewalks. In addition, the transportation department evaluates portions of its pedestrian infrastructure each year as part of its annual pedestrian curb ramp projects, and it has developed a working plan for the installation and management of accessible pedestrian signals. Based on this information, a transition plan is being developed, with approval expected in 2012.
Hennepin County also worked on communication issues to ensure open exchange of information and ideas surrounding its transition plan. In 2011, four open houses were held to engage the public on ADA issues. "These were very successful," Lemke said. The county also has a formal grievance procedure, but "we're also open to resolve conflicts in a less formal way," he said. He summed up with this: "Why provide access to all? Because it's the right thing to do."
A city view of ADA
Mark Ray provided a city perspective on transition planning by describing how the City of Golden Valley did a self-evaluation and inventory and adopted a transition plan in December 2011. Ray said the ADA transition plan supports access to mass transit and aids transportation system maintenance as well as grant applications.
"The goal of our transportation system is access for everyone; the methods depend on your agency," Ray said. "The transition plan says you'll take these steps and use these methods to meet these requirements." After doing inventories, Golden Valley created a document that was just 12 pages long but with an appendix that will be updated as things change within the city.
Golden Valley's transition plan consists of an introduction that describes legal requirements the document fulfills, policy goals, and implementation process. The body of the document contains definitions, describes when upgrades are required, outlines project implementation including the request process, and explains the grievance process (and uses a complaint form that was already available). The document also includes an ADA compliance statement and identifies design guidelines. Answers to frequently asked questions, resources (agency listings and links to websites), and an appendix round out the document.
The appendix lists priority areas, the city's capital improvement plan, public sidewalk and trail policy, the grievance process, and Public Rights-Of-Way Accessibility Guidelines (PROWAG) design guidelines.
"The introduction explains why, the body of the document describes where (projects) and how (requirements), and the appendix outlines when," Ray said.
—Jeanne Engelmann, LTAP freelancer