ADA Guide for Small Towns

Americans with Disabilities Act
ADA Guide for Small Towns
A guide for small local governments
including towns, townships, and rural counties.
U.S. Department of Justice
Civil Rights Division
Disability Rights Section

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Reproduction
Reproduction of this document is encouraged.
Additional copies of this publication may be obtained
by calling the ADA Information Line at
800-514-0301 (voice), 800-514-0383 (TTY) or by
visiting the Department’s ADA Home Page on the
World Wide Web (www.usdoj.gov/crt/ada/
adahom1.htm).
first printing, April 2000

Introduction 	1
Part One -- The ADA’s Requirements for Small Towns 	1
1. Existing Facilities: Program Accessibility 	2
Example -- Annual town meeting
Example -- Historic Town Library
Example -- Historic House Museum
Example -- Town Police Station
Example -- Providing accessible temporary facilities
Example -- Specialized programs
Example -- Sign directs to accessible rest rooms
Example -- Alterations comply with ADA Standards
2. New Construction, Alterations, and Additions 	5
3. Maintenance of Accessible Features 	7
Example -- Maintaining a lift or accessible feature
Example -- Removing snow and ice to permit program accessibility
4. Effective Communication 	7
Example -- Auxiliary Aids and Sign Language Interpreters at Annual Town Meeting
5. Policies, Practices, and Procedures 	9
Example -- Photo identification policies
6. Processes for Complying with the ADA 	10
Provide Public Notice about ADA Requirements
Other Obligations for larger towns with 50 or more employees
Designate an individual to coordinate ADA compliance
Develop a transition plan
Develop a grievance procedure
Part Two --
Typical Issues: Program Accessibility and Effective Communication 	12
A 	Accessible Parking 	12
B 	Accessible Route 	14
C 	Accessible Entrance 	14
D 	Curb Ramps at Intersections 	15
E 	Alternate Services 	16
F 	Library Services 	16
G 	Parks and Recreation Programs 	17
H 	Accessible Print Material 	17
I 	Police Services 	18
J 	Calling 9-1-1 and Other Emergency Services 	18
K 	Temporary Events 	18
Part Three -- Resources 	20
Table of Contents
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1
Introduction
A ramp located next to the stairs to this
town hall provides an accessible entrance.
1
The term “towns” is used in this publication to
refer to all small local governments, towns, and
townships. Please remember that title II applies to all
State and local government entities, regardless of size,
including State governments, local governments,
special government entities such as transportation
authorities, school districts, water districts, and other
special purpose districts.
The Americans with Disabilities Act gives civil rights protections to individuals with disabili-
ties similar to those provided to individuals on the basis of race, color, sex, national origin,
age, and religion. It guarantees equal opportunity for individuals with disabilities in employ-
ment, transportation, State and local government services, telecommunications, and in the
goods and services provided by businesses.
Small towns offer a variety of essential programs and services
that are fundamental to the public and to everyday American
life. Although the range of services offered by small towns
varies, it is essential that people with disabilities have the
opportunity to participate in the programs and services that
towns offer. Applying for a building permit or business
license, playing ball in the local park, marching in the Memo-
rial Day parade, attending an annual street festival or a town
meeting, or calling 9-1-1 for emergency police, fire, or rescue
all are typical town programs, activities or services covered by
the Americans with Disabilities Act or ADA.
The ADA gives people with disabilities an equal opportunity to participate in the main-
stream of public life offered to all Americans. This guide presents an informal overview of
some basic ADA requirements and provides cost-effective tips on how small towns can
comply with the ADA.
Title II of the ADA applies to State and local govern-
ments, including towns and townships, school districts,
water districts, special purpose districts, and other small
local governments and instrumentalities. It prohibits
discrimination on the basis of disability in all services,
programs, and activities provided by towns 1
. 	Thus,
people with disabilities must have an equal opportunity
to participate in and benefit from a town’s services,
programs, and activities. To accomplish this, the ADA
sets requirements for town facilities, new construction
and alterations, communications with the public, and
policies and procedures governing town programs,
services, and activities.
Part One: The ADA’s Requirements for Small Towns
Introduction

2
Library staff provide curbside services
because the library facility
cannot be made accessible.
Physical modifications to provide program
accessibility included parking spaces, the public
toilet facility and an accessible route
to the ocean overlook.
Program Accessibility
1. Existing Facilities:
Program Accessibility
When programs, services, or activities are
located in facilities that existed prior to
January 26, 1992, the effective date of title
II of the ADA, towns must make sure that
they are also available to persons with
disabilities, unless to do so would funda-
mentally alter a program, service, or activity
or result in undue financial or administra-
tive burdens (see page 8). This requirement
is called program accessibility. When a
service, program, or activity is located in a
building that is not accessible, a small town
can achieve program accessibility in several
ways. It can:
• relocate the program or activity to an
accessible facility,
• provide the activity, service, or benefit in
another manner that meets ADA
requirements, or
• make modifications to the building or
facility itself to provide accessibility.
Thus, to achieve program accessibility, a
small town need not make every existing
facility accessible. It can relocate some
programs to accessible facilities and modify
other facilities, avoiding expensive physical
modifications of all town facilities.
Example
A town holds its annual town meeting in an
inaccessible location, the second floor of the
two-story town hall that has no elevator. The
town council considers installing an elevator
in the building as well as replacing the
existing town hall with a new, fully accessible
building, but determines that the town’s
limited financial resources will not allow
either of these approaches. Instead, the town
officials decide to hold the town meetings, as
well as other public meetings where large
numbers of the public are expected to attend,
in the accessible auditorium of its local high
school. The town officials also decide to
move smaller meetings, which are periodically
held on the second floor of the town hall, to
the school auditorium, when they receive a
request within 24 hours of a meeting.
Example
The town library is a historic structure that is
listed on the State historic register. The two
entrances to the facility each have four steps
and no accessible entrance is provided. The
town consults with an architect to determine
if an accessible entrance can be provided and
is told that a ramp or lift cannot be added to
either entrance without a significant change
to the exterior of the building. After
reviewing the ADA requirements, the town
learns that qualified historic
buildings and facilities are not
required to take any action
that would threaten or
destroy the historic

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Example
The town’s police station has one step at the
public entrance and there is no accessible
entrance available. After considering its
options for providing program accessibility,
the town decides to modify the facility to
provide access rather than relocate the police
programs or services. After review of the
programs and services provided at the station,
the town determines that the public entrance,
lobby, and service counter need to be
accessible to provide program accessibility.
Therefore, alterations are limited to those
items necessary to achieve program
accessibility. In this case, it includes
providing a van-accessible parking space in
the parking lot, an accessible route from the
parking space to the modified public
entrance, and an accessible service counter
inside the police station.
A town chose to alter its police station rather
than move its programs and services to another
accessible location.
Program Accessibility
Example (continued)
significance of a historic property. The State
historic preservation office is consulted and it
determines that the exterior cannot be
modified. Because physical modifications to
the entrances cannot be made, the town
changes its policies and provides access to the
library services in an “alternate manner” upon
request. Library staff are trained to take
requests over the telephone, to look up
information for individuals with disabilities
who cannot use the library, to provide
information over the telephone, and to
provide curbside service for books and library
publications or to mail items to individuals
upon request. Library staff may also meet
with an individual in another accessible
location when the telephone service is not
effective. The library publicizes a telephone
number for requesting these alternate services
in its publications and announcements.
Example
A town-operated two story historic house
museum, which dates from 1885, provides
exhibition and instructional programs for the
public. The focus of the program is the
exhibition of a typical 19th century Victorian
house.
The self-evaluation determines that the
house is not accessible. After considering the
options for providing access to the programs
and services, the town decides that it is not
possible to move the museum programs to
other accessible locations because the historic
house itself is a critical part of the historic
house program. The town develops plans to
alter the facility to provide physical access to
the first floor. These alterations are planned
in compliance with the historic preservation
requirements of the ADA Standards.
After reviewing the alterations with the
State historic preservation office, the town
determines that the second floor cannot be
made accessible without threatening the
unique features and historic significance of
the house. Because the town must consider
alternatives to structural changes in these
instances, the town establishes a policy to
locate all temporary programs on the first
floor. In addition, the town documents the
second floor spaces and content using video
or other innovative solutions and provides an
accessible viewing area on the first floor.
When a town becomes aware that a program
is not accessible and plans to alter a facility
to provide access, it may be necessary to
temporarily relocate a program, service, or
activity to a temporary accessible location or
to temporarily offer the service in an alter-
nate manner.

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Program Accessibility
This temporary solution assures that the
service, program, or activity is accessible
during the time the alterations are planned
and being implemented.
Example
The public toilet facilities at the town
recreation area are not accessible. After
consideration of whether to modify the
facilities or to relocate the programs held at
the recreation area, the town decides to alter
the toilet facilities and the walkway leading to
them. While the fundraising is done,
alterations planned, and the work completed,
the town provides temporary portable toilet
facilities that are accessible.
When choosing a method of providing
program access, a public entity must give
priority to the one that results in the most
integrated setting appropriate to encourage
interaction among all users, including
individuals with disabilities. In addition, a
town may offer additional activities or
services so an individual with a disability can
more fully participate in, or benefit from, a
program, service, or activity. However,
when such special activities or services are
provided for people with disabilities, the
town must permit a person with a disability
to choose to participate in services, pro-
grams, or activities that are not different or
separate.
Example
The local town pool provides a swimming
program for people with disabilities that
includes additional staff who provide
individualized instruction. A person with a
disability participates in the program. The
person applies to attend group swimming
lessons that are open to the public even
though these lessons do not provide
specialized instruction. The town must
permit the individual with a disability to
participate unless doing so would
fundamentally alter the program.
Because program accessibility may be
provided in an accessible part of a facility
when the remainder of the facility is not
accessible, the public must be informed of
the location of accessible features. Signs
should direct the public to the location of
accessible elements and spaces, including the
location of accessible parking, the accessible
entrance to a facility, and accessible toilet
rooms. In addition, a town may issue a
brochure or pamphlet with a map indicating
the town’s accessible features.
Example
A town hall has two sets of public toilet
rooms. One set has been altered and is
accessible, and the other set is not accessible.
The town installs signage at the inaccessible
toilet rooms directing people to the accessible
toilet rooms.
Sign at an inaccessible entrance
provides directions to the nearest
accessible entrance.
Towns making modifications to a building
or facility to provide program accessibility
must comply with the ADA Standards for
Accessible Design (ADA Standards) or the
Uniform Federal Accessibility Standards
(UFAS).
Example
The town outdoor recreation area has a ball
field, parking lot, and a building with public
toilets. Town officials note that the parking
lot does not have accessible parking spaces
and the toilet facilities are not accessible. The
town decides to provide accessible parking
spaces in the part of the lot closest to the
route to the ball field by restriping that
section of the parking lot, installing signage
designating the accessible parking spaces, and

5
Public toilets at a park
were built to comply with the new
construction requirements
of the ADA Standards.
New Construction, Alterations and Additions
Example (continued)
2. New Construction and
Alterations
Alterations done to provide program
accessibility must comply
with the ADA Standards.
in the future the ADA Standards will
become the only design standard under the
ADA. Because ADA requirements for new
construction and alterations do change from
time to time, towns should become familiar
with any new design and construction
requirements before a project starts (see
Resources for free information sources).
Alterations and Additions
When a building or facility is renovated or
altered or added to for any purpose, the
alterations or additions must comply with
the ADA Standards. In general, the alter-
ation provisions are the same as the new
construction requirements except that
deviations are permitted when it is not
technically feasible to comply. Additions are
considered an alteration but the addition
must follow the new construction require-
ments. When existing structural and other
conditions make it impossible to meet all
the alteration requirements of the ADA
Standards, then they should be followed to
the greatest extent possible.
by making sure the accessible parking spaces
are on an accessible route to the recreation
area. The town also modifies the toilet
facilities to make them accessible. All
alterations are done in compliance with the
ADA Standards and signs are provided to
identify the accessible toilet facilities.
New Construction
ADA requirements for new construction
have been in effect since January 1992.
New buildings and facilities must comply
with the new construction provisions of the
ADA Standards for Accessible Design
(without the elevator exemption) or the
Uniform Federal Accessibility Standards
(UFAS). This requirement includes facilities
that are open to the public and those that
are for use by employees.
The ADA Standards for Accessible Design
(ADA Standards) were first issued in 1991
and have been selected as the ADA design
standard by many towns. Although towns
now have the option to choose either the
ADA Standards or the UFAS, it is likely that

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Alterations
Alterations to existing town buildings
follow the alteration requirements
of the ADA Standards.
Basic Requirements for Alterations:
• Any alteration that affects the usability
of a building or facility must comply
with the requirements of the ADA
Standards unless technically infeasible to
do so. Alterations can be as limited as
the replacement of a fixture or element,
such as a lavatory, toilet, or piece of door
hardware.
• When an element is replaced, the new
element must comply with the ADA
Standards if the minimum requirements
for accessibility under the ADA have not
already been met.
• When a town alters an area of a facility
that contains a primary function area,
the town has an additional obligation.
The town is also responsible for making
the path of travel to the altered area
(room or wing), as well as the toilet
rooms, drinking fountains, and public
telephones serving the altered area
accessible. Primary function areas are
those areas of a building that include the
primary spaces for which the building
was constructed (for example, offices or
meeting areas in a town hall, locker
rooms in an athletic facility, or
classrooms in a school or training
center). The amount of money the
town must spend to provide an
accessible path of travel is limited to
20% of the overall cost of the
alterations. If the path of travel
alterations can be done for less than the
20% limit, then only that expenditure is
required. If all the required accessible
features are already provided then no
additional expenditure is needed.
• When a qualified historic facility is
altered, an exception to the alteration
requirements of the ADA Standards may
be used if the alteration threatens to
destroy the historic significance of the
building or facility. In these situations,
special provisions in the Standards may
be used for the element or space that
would be threatened. In almost all
situations, accessible design can be used
without significantly impairing the
historic features of the facility.
• The ADA Standards have specific
requirements for additions. Additions,
which include an expansion, extension
or increase of the gross floor area of a
building or facility, are considered an
alteration to a facility but the area that is
added must comply with the new
construction requirements. Each
addition that affects or could affect the
usability of an area containing a primary
function area must meet the path of
travel requirements (see above).

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3. Maintenance of
Accessible Features
A lift provides access to the programs and
services held in this town library.
If the lift is out of service, alternate
services are provided in an accessible
location until the lift is repaired.
Clearing snow from accessible parking
spaces and the accessible route may be
essential to provide access to programs,
services, or activities.
Example
A town building that was built before the
ADA went into effect has a lift that provides
access from inside the building to the library.
The town must maintain the lift in working
condition to assure that the public has access
to the library programs. If the lift is out of
order, repairs must be made in a timely
fashion. Until the repairs are made, the town
should provide alternate service for wheelchair
users and others with disabilities who can no
longer gain access to the library. These
services may include retrieval of library
materials by staff who will meet with an
individual in an accessible location.
Example
When weather conditions such as snow and
ice limit or prevent access to services,
programs, and activities, a town that houses
programs in an accessible facility will have to
maintain access to ensure that those programs
are accessible. Maintenance of accessible
features would include the removal of snow
from accessible parking spaces, parking space
access aisles, the accessible route to the
accessible entrance, and accessible entrances.
Although temporary interruptions in services
due to bad weather are expected, alternate
services should be provided if snow and ice
cannot be cleared in a timely manner.
4. Effective Communication
Maintenance of Accessible Features
Towns must maintain in operable working
condition those features that are necessary to
provide access to services, programs, and
activities -- including elevators and lifts,
curb ramps at intersections, accessible
parking spaces, ramps to building or facility
entrances, door hardware, and accessible
toilet facilities. Isolated or temporary
interruptions in service or access are permit-
ted for maintenance or repairs.
Towns must take appropriate steps to ensure
that communications with members of the
public, job applicants, and participants with
disabilities are as effective as communica-
tions with others unless it is an undue
financial or administrative burden to do so
or it would result in a fundamental alter-
ation (see page 8) in the nature of its pro-
gram or activity.
Achieving effective communication often
requires that towns provide auxiliary aids
and services. Examples of auxiliary aids and

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Effective Communication
A sign language interpreter is one type
of auxiliary aid or service
that may be requested.
services include qualified sign language
interpreters, assistive listening devices, open
and closed captioning, notetakers, written
materials, telephone handset devices, quali-
fied readers, taped texts, audio recordings,
Brailled materials, materials on computer
disk, and large print materials.
Towns must provide appropriate auxiliary
aids and services where they are necessary to
achieve an equal opportunity to participate
in, and enjoy the benefits of, a service,
program, or activity conducted by or for the
town. The town must give primary consid-
eration to the type of auxiliary aid requested
by a person with a disability. However, the
town may provide a different type of aid if it
can show that it is an effective means of
communication.
Example
A town prepares to hold its annual town
meeting in the high school gymnasium. A
request is made through the meeting
coordinator for real time captioning to be
provided for a person who is deaf. Real time
captioning displays the spoken content from a
meeting or a speech on a large television
screen as text. The town gives primary
consideration to the request but after
discussing alternatives for providing effective
communication with the individual who
made the request, the town learns that the
individual is fluent in American Sign
Language (ASL). The town offers to provide
a qualified ASL sign language interpreter for
the town meeting because it has determined
from discussions with the individual that the
interpreter can provide effective
communication.
Determination of an undue financial burden
or a fundamental alteration can only be
made by the head of the town government
or his or her designee and must be accompa-
nied by a written statement of the reasons
for reaching that conclusion. The determi-
nation of an undue burden must be based
on all resources available for use in the
program, service, or activity. When it is not
possible to provide a particular type of
auxiliary aid to achieve effective communi-
cation due to an undue burden or funda-
mental alteration, the town must take any
other action that would not result in such
burdens or fundamental alteration, but
would nevertheless ensure that individuals
with disabilities receive the benefits and
services of the program or activity.
If a town communicates with applicants and
beneficiaries by telephone, it should ensure
that an effective telecommunication system
such as communication using the relay
system or a TTY (or TDD) be used to
communicate with individuals who are deaf,
hard-of-hearing or who have speech disabili-
ties. A TTY has a keyboard and visual
display for non-verbal communication with
another TTY user or a relay system operator.
The relay system is provided in each State
and permits telephone communication
between voice handsets and individuals
using a TTY.
A town can choose to provide a TTY with-
out significant expense. Some towns have
decided to install a portable TTY next to a
public pay telephone and to anchor the
portable unit to a shelf. Electrical connec-
tions are enclosed to protect against acciden-
tal disconnection of power.

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A portable TTY mounted on a shelf located
next to a pay telephone can provide
a low-cost TTY solution.
Effective Communication and Policies, Practices and Procedures
Requirements for effective communications
also apply to “telephone emergency services”
that provide a basic emergency service, such
as police, fire, and ambulance, that are
provided by public safety agencies, including
9-1-1 (or, in some cases, seven-digit) sys-
tems. Direct, equal access must be provided
to all services included in the system, in-
cluding services such as emergency poison
control information. Where direct access is
provided to callers, direct access by TTY
users means the telephone emergency service
cannot use a relay system or transfer all TTY
calls to one operator while other callers have
access to all available operators (for more
information, see the Department’s publica-
tion, Access for 9-1-1 and Telephone Emer-
gency Services Under the Americans with
Disabilities Act).
5. Policies, Practices,
and Procedures
Towns must make reasonable modifications
to policies, practices, and procedures to
avoid discrimination against individuals
with disabilities. While this requirement
applies to all policies, practices, and proce-
dures of the town, the town does not have
to make modifications that would result in a
fundamental alteration in the program,
service, or activity or result in a direct threat
to the health or safety of others. A direct
threat is a significant risk that cannot be
eliminated or reduced to an acceptable level
by the town’s modification of its policies,
practices, or procedures, or by the provision
of auxiliary aids or services. The public
entity’s determination that a person poses a
direct threat to the health or safety of others
may not be based on generalizations or
stereotypes about the effects of a particular
disability (see The ADA Title II Technical
Assistance Manual).
The self-evaluation typically includes a
review of polices, practices, and procedures
(see page 10, Processes for Complying with
the ADA). Periodic review after the self-
evaluation may be done to maintain compli-
ance with the ADA. A town can choose
how it wants to conduct a review of policies
and practices that govern the administration
of the town’s programs, activities, and
services. Towns that have already done a
self-evaluation do not have to do another
one.
Review of policies, practices, and procedures
also applies to telephone emergency services,
such as 9-1-1, where policies must ensure
direct access to individuals who use TTY’s
and computer modems.

10
Processes for Complying with the ADA
Example
A town pool requires that adults provide
photo identification to verify residency before
using the pool or participating in pool
programs. During review of town policies,
practices, and procedures, the town
determines that the pool identification policy,
which requires that a driver’s license with a
photo be presented to gain admission, may
discriminate against people with disabilities
who may not have a driver’s license. The
town changes its policy to permit other forms
of identification to verify residency.
6. Processes for Complying
with the ADA
A mother with her service animal leads her
children to the town pool. Policies and
procedures that restrict or prohibit service
animals may violate the ADA.
An emergency call box located in a rural
area is mounted in an accessible location
and can be used with or without speech to
provide effective communication.
Any policies, practices, or procedures that
may limit or exclude individuals with
disabilities must be reasonably modified,
unless doing so would result in a fundamen-
tal alteration in the nature of the service,
program, or activity. The self-evaluation
should identify changes to policies to be
implemented. It should also identify any
discriminatory policies, practices, and
procedures that cannot be reasonably
changed without resulting in a fundamental
alteration.
The self-evaluation also identifies problems
with the accessibility of facilities and estab-
lishes recommendations for providing
program accessibility (which may include
relocation to an accessible facility). It may
also suggest short-term and long-term
strategies to provide access to people with
disabilities.
Towns that have not already conducted a
self-evaluation or updated a previous self-
evaluation conducted under Section 504 of
the Rehabilitation Act must do so. The self-
evaluation is a review of all town services,
programs, and activities to identify any
physical barriers or policies, practices, or
procedures that may limit or exclude partici-
pation by people with disabilities. The self-
evaluation includes permanent, temporary,
and periodic services, programs, and activi-
ties. Each town should look at what ser-
vices, programs, or activities are offered and
in what location.

11
Towns that completed a self-evaluation to
comply with section 504 of the Rehabilita-
tion Act only have to bring the 504 self-
evaluation up to date with ADA require-
ments by evaluating the services, programs,
and activities that have changed. However,
because considerable time has passed since
most section 504 self-evaluations were done,
it would be best to conduct a new self-
evaluation.
Provide public notice about
ADA requirements
A small town must provide notice to the
public about its ADA obligations and about
accessible facilities and services in the town.
The notice must inform the public about
the ADA’s nondiscrimination requirements.
It may also describe how the public or
employees may contact specific town offi-
cials about problems with accessibility and
the need for effective communication. The
information must be accessible to the
public, including people who have disabili-
ties that affect communication, such as
blindness, low vision, deafness, and hearing
loss. Although no specific method is re-
quired to reach the public, notice can be
provided in more than one format and by
using more than one type of media, such as
the town’s website, print, radio, or televi-
sion.
Other obligations for larger
towns with 50 or more
employees
Although the ADA only requires State and
local governments with 50 or more employ-
ees to take the following measures, towns
with less than fifty employees may want to
consider following the same or similar steps
because the process may make it easier to
comply with the ADA.
Designate an individual to
coordinate ADA compliance
Responsibilities for the ADA coordinator
may include conducting the self-evaluation
and developing the transition plan (see
below), handling requests for auxiliary aids
and services, providing information about
Installation of curb ramps is one of the items
included in the transition plan.
This type of curb ramp is used when some type
of barrier prevents pedestrians
from entering the curb ramp from the side.
Processes for Complying with the ADA
a
b
accessible programs and services, and serving
as a local resource to the town or township.
The ADA coordinator may also have re-
sponsibility for working with the mayor or
town council to ensure that new facilities or
alterations to town facilities meet ADA
requirements. In some communities, this
individual also receives complaints from the
public and works to resolve them.
Develop a transition plan
If a town with 50 or more employees de-
cides to make physical changes to achieve
program access it must develop a written
plan that identifies the modifications that
will be made. The plan should include
timelines for completing these modifica-
tions. Interested parties, including people
with disabilities and organizations represent-
ing people with disabilities, must at a
minimum have an opportunity to partici-
pate in the development of the plan by
submitting comments. A copy of the plan
and a copy of the self-evaluation must be
available for public inspection for three years
after completion.
c Develop a grievance procedure
Towns with fifty or more employees must
have an ADA grievance procedure. A griev-
ance procedure provides people who feel they
have been discriminated against because of

12


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Features of Accessible Parking Spaces for Cars
96” min. 	96” min.
2440 	2440
accessible route (min. 36-inch width)
1525
60”min.
Typical Issues - Accessible Parking
their disability, or others who feel they have
been discriminated against because they
have a friend or family member with a
disability, with a formal process to make
their complaint known to the town. This
procedure encourages prompt and equitable
resolution of the problem at the local level
without having to force individuals to file a
Federal complaint or a lawsuit.
Part Two -- Typical Issues: Program Accessibility and
Effective Communication
Accessible Parking
In new construction and in alterations, accessible parking must be provided whenever public
parking is provided. Towns may wish to add accessible parking when public parking is not
provided to provide access to facilities where programs, services, or activities are located.
Accessible parking spaces have a number of features that make it possible for people with
disabilities to get into or out of a vehicle.
Accessible Parking Spaces for Cars
Accessible parking spaces for cars have at least a 60 inch-wide access aisle located adjacent to
the designated parking space. The access aisle is just wide enough to permit a person using a
wheelchair to enter or exit the car. These parking spaces must be located on level ground and
identified with a sign mounted in front of the parking space high enough so it is visible when
a vehicle is parked.
A
Sign with the international symbol of
accessibility mounted high enough so it
can be seen while a vehicle is parked in the
space.
If the accessible route is located in front of
the space, install wheelstops or other
barriers to keep vehicles from reducing
width below 36 inches.
Access aisle of at least 60-inch width must
be level (1:50 maximum slope in all
directions), be the same length as the
adjacent parking space(s) it serves and
must connect to an accessible route to the
building. Ramps must not extend into the
access aisle.
Boundary of the access aisle must be
marked. The end may be a squared or
curved shape.
Two parking spaces may share an access
aisle.

13


@
@
€
€
À
À96” min.
2440
96” min.
2440
96” min.
2440
Three Additional Features for Van-Accessible Parking Spaces
accessible route
Typical Issues - Accessible Parking
Van-Accessible Parking Spaces
One of every eight accessible parking spaces, but always at least one, must be accessible for
vans with a side-mounted lift. If only one accessible space is provided, it must be a van-
accessible space.
Van-accessible parking spaces incorporate the same requirements as accessible parking spaces
for cars and have three additional features for vans:
• a wider access aisle (96 inch-wide) to accommodate a wheelchair lift;
• vertical clearance to accommodate van height at the van parking space, the adjacent
access aisle, and on the vehicular route to and from the van-accessible space, and
• an additional sign that identifies the parking spaces as “van accessible.”
When accessible parking spaces are added in an existing parking lot, towns must
locate the accessible spaces on the most level ground close to the accessible entrance. An
accessible route must always be provided from the accessible parking spaces to the accessible
entrance.
The ADA Standards have technical requirements for parking lots and garages but no techni-
cal requirements for the design of on-street parking.
For more information about accessible parking, see the ADA Standards and other publica-
tions listed in Part III: Resources (page 20).
Sign with “van accessible” and the international
symbol of accessibility mounted high enough so
the sign can be seen when a vehicle is parked in
the space
96-inch min. width access aisle, level (max. slope
1:50 in all directions), located beside the van
parking space
98-inch min. high clearance at van parking space,
access aisle, and on vehicular route to and from
van space

14
Accessible Route
When a walk, pathway, or pedestrian route is necessary to provide public access to
a program, service, or activity, an accessible route must be provided. An accessible
route is an unobstructed pedestrian path that connects accessible elements and
spaces such as accessible parking spaces, accessible entrances, accessible meeting
rooms, accessible toilet rooms,
etc. It can be a walkway,
hallway, part of a courtyard, or
other pedestrian space. An
accessible route must be at least
36 inches wide, have no abrupt
vertical changes in level (such as
a step), have a running slope no
more than 1:12 in most cases,
and meet other requirements
for cross slope, surface condi-
tions, vertical height, and
passing spaces. The width of an
accessible route can be as
narrow as 32 inches wide, such
as at a doorway or a narrow
section of hallway, but only for a
distance up to 24 inches long.
An accessible route connects accessible parking
(right) with the accessible entrance.
A historic town building added a ramp, walkway, and
modified an entrance to provide access.
Typical Issues - Accessible Route and Accessible Entrance
B
C Accessible Entrance
If entering a facility is necessary to participate in or benefit from a program,
service, or activity, then that facility must have an accessible entrance and the
accessible entrance must be on an accessible route. The accessible route must
connect one or more (exterior) site entry points (such as parking, a public side-
walk, or a public transportation stop) with an accessible entrance. The accessible
entrance must also connect to an interior accessible route leading to the space or
spaces where the program is located.
An accessible entrance must
have an accessible door or
doorway. If a door is provided,
there must be maneuvering
space on the pull and push sides
of the door to permit a person
using a wheelchair to open the
door and then move through
the door opening. The clear
width of the opening must be at
least 32 inches wide and acces-
sible door hardware (handle and
latch) must be provided. If a
door closer is provided, it must
be adjusted so the door will not
close too quickly.

15
Curb ramps are needed when walkways
cross a curb at an intersection. This type of
curb ramp has flared sides and must be
used when pedestrians may enter or exit
the curb ramp from the side.
Typical Issues - Accessible Entrance and Curb Ramps at Intersections
Although it is best to have the accessible
entrance be the same one used by most of
the public, existing conditions may
prevent modification of the main en-
trance resulting in use of a secondary or
side entrance as the accessible entrance. It
may also be necessary to use a secondary
entrance if only one part of the building is
accessible. Where a secondary or side
entrance provides access, signs should be
provided at inaccessible
entrances to direct the public to the
nearest accessible entrance.
32-inch min.
18-inch
min.
approach
required clear floor
space -- the size varies
depending on the
direction of approach
and door swing.
A plan view of an accessible door
Curb Ramps at Intersections
Pedestrian walkways or sidewalks that are the responsibility of the town often play a key role
in providing access to government programs and services and to the goods and services
offered to the public by private businesses. When walkways cross a curb at intersections, a
ramp or sloped surface is needed. The title II regulations set requirements for curb ramps at
intersections. Whenever a town constructs a new road and sidewalk or alters existing roads
and sidewalks, it must install curb ramps. In addition, the ADA requires that towns evaluate
its existing system of sidewalks and develop a schedule to provide curb ramps where pedes-
trian walkways cross curbs. Because a town will not be able to install curb ramps at all town
streets right away, the town’s plan for curb ramp installation should set priorities for which
streets require curb ramps. Towns must give
priority to walkways serving State and local
government offices and facilities, bus stops
and transportation services, private busi-
nesses offering goods and services to the
public, and employees, followed by walk-
ways serving residential areas.
D
Any curb ramps that are installed must
comply with the ADA Standards. In areas
with hilly terrain or other site constraints,
towns should follow the ADA Standards to
the greatest extent feasible.
To achieve or maintain program accessibil-
ity, a town should develop procedures to
allow the public to request that curb ramps
be installed at specific intersections fre-
quented by people with disabilities, includ-
ing residents, employees, or visitors.

16
Typical Issues - Alternate Services & Library Services
Alternate Services
A town can make its services, programs, or activities accessible by relocating them to an
accessible site or offering them in an alternate way that is accessible. A town should consider
the integration requirements of the ADA, which require that priority be given to measures
that will provide the service, program, or activity in the most integrated setting appropriate.
For small towns, alternate service may include meeting with an individual with a disability in
his or her home to fill out specific forms if the town office is not accessible. It may also
include curb service to pick up or deliver an item. However, in some cases alternate service is
not appropriate. If a town meeting is scheduled to be held on the second floor of a building
without an elevator and a person using a wheelchair wishes to attend the meeting, the meet-
ing should be relocated to an accessible space, unless it would result in undue financial or
administrative burdens. Making the person sit by themselves on the first floor and watch the
meeting on a television monitor or having them watch the meeting at home is not a desirable
alternative because it does not give the person with a disability an equal opportunity to
interact with officials and other participants.
Library Services
Library services are an example of programs and services offered by many towns. If a library
facility or building is not accessible, these services may be offered in a different accessible
library facility, in another accessible facility nearby, or in an alternate manner. Some towns
with only one library may prefer to modify the entrance to the library and other key ele-
ments to provide access. Others that may have a facility that is
difficult to make accessible or lack the resources to
make essential physical changes
may choose to offer the
programs and services in an
alternate accessible location.
What is important is that
the same services be avail-
able to individuals with
disabilities as are offered to
others – such as doing
research, using the card
catalog or cataloging device,
reading or reviewing items
usually held in reserve or
special collections, and An individual uses a call button to request assistance
from library staff of the bookmobile.
E
F
returning loaned items.
If a library provides program accessibility through alternate means it must have policies that
permit staff to carry out this policy. The policies must include procedures that permit the
public to make requests for the alternate location or services. In many cases, however,
providing basic physical accessibility to the library facility is preferred in meeting the obliga-
tion to provide services in the most integrated setting appropriate.

17
A town playground with an
accessible route that provides
access to a play area.
Accessible Print Material
Public documents such as town annual reports, promotional brochures, and other docu-
ments, such as tax bills, license applications and other printed information may need to be
provided in an alternate accessible format to provide effective communication for individuals
who are blind or visually impaired. Alternate formats may include materials in Braille, large
print, files on computer disk that can be used in a personal computer, or an audiotape
recording of the print document. Priority should be given to the type of format that has
been requested unless the town determines that another format is effective or that providing
the one requested would result in undue financial or administrative burdens or a fundamen-
tal alteration in the nature of the program. A town should publish a contact number for the
public to request an accessible format or other auxiliary aid or service.
Typical Issues - Parks and Recreation Programs & Accessible Print Material
G
H
Parks and Recreation Programs
A town’s recreational programs or activities, such as those offered at the town baseball or
football field or at the town pool, play an important part in the life of a community. These
programs, services, and activities are among those that the town should review as part of the
self-evaluation to determine if any physical or policy barriers exist that may keep people with
disabilities from participating. If a town decides to modify facilities to provide program
accessibility and has more than one facility available (such as when several ball fields are
provided) only some of the facilities may need to be accessible. However, when only some of
the ball fields are accessible, the scheduling policies for their use will need to accommodate
requests for accessible fields, player areas, or spectator seating (if provided).
When the facilities are built or altered,
they must comply with the ADA
Standards, which have specific technical
requirements for elements and spaces,
such as accessible parking spaces,
accessible routes, toilet facilities,
public telephones, and
spectator seating areas.
For elements and spaces
without specific techni-
cal standards, such as
ball fields or playing
areas, the town should
use the Standards as a
guide, providing a
reasonable number, but
at least one, that is
accessible and providing
an accessible route to
the area of play and the
spectator areas.

18
A police officer and a deaf person
communicate using a writing pad and pen.
Calling 9-1-1 and Other Emergency Services
Dialing 9-1-1 is the most familiar and effective way Americans have of finding help in an
emergency. The ADA requires all telephone emergency services to provide direct, equal
access to their services for people with disabilities who use a TTY.
Equal access means that TTY callers have an opportunity to obtain emergency services that is
equal to that of callers who use voice handsets. The telephone emergency services provided
for TTY callers must be handled in the same manner as those provided for individuals who
make voice calls, in terms of response time, response quality, hours of operation, and all other
features offered (e.g., automatic number identification, automatic location identification,
automatic call distribution). There must be adequate numbers of TTY’s or equipment to
answer TTY calls. If a town or township relies on another government entity to provide its
9-1-1 and telephone emergency services, it should inquire about the accessibility of the
services (for more information see Access for 9-1-1 and Telephone Emergency Services Under the
Americans with Disabilities Act).
Typical Issues - Police Services, 9-1-1 and Other Emergency Services, and Temporary Events
I
J
K
Police Services
Local police services are covered by the ADA, including investiga-
tions, interrogation, arrest, and transportation. Program
accessibility requirements apply to the services and
programs offered to the public, including those
offered at a local police station. Effective
communication requirements also apply
to communication with the public,
including individuals suspected of
criminal activity.
If a town has a police station, jail, or
holding facility, or other public police
facility, the town should include services,
programs, and activities that are offered
in these facilities in its self-evaluation.
To achieve program accessibility, it may
be possible to share some accessible
facilities with other nearby towns or government entities or to offer the service, program, or
activity in another accessible location or manner. Vehicles used to transport suspects or
prisoners should also be included in the self-evaluation. If a town does not have an accessible
vehicle available for transporting suspects or prisoners, the town should identify a source for
an accessible vehicle, such as an accessible school bus, taxi with a wheelchair lift, or an
accessible vehicle from a nearby town.
Temporary Events
The ADA applies to both temporary and permanent services, programs, or activities of a
town. Facilities and structures that are built or altered for temporary use must comply with
the ADA Standards (except for construction trailers). In addition, the policies and opera-
tions for the event must meet the nondiscrimination requirements of the ADA. When
planning temporary events such as a town festival or concert, the town should review ADA

19
When portable toilets are
provided, at least one at
each location must be
accessible.
A town fair that was planned to provide accessible
programs, services and activities.
• temporary curb ramp
added where needed to
provide an accessible
route
• booths and vendors
located on an accessible
route
• sign language
interpreters available
for selected
performances and
programs
• accessible parking,
accessible transit drop
offs and stops (if
provided) and an
accessible route from
these areas to the fair is
provided
2
Private vendors and contractors should follow the ADA title III regulations
which cover goods and services provided by private companies. For more
information, see the ADA Guide for Small Businesses.
Selected Accessible
Features of Town Fair
Typical Issues - Temporary Events
title II requirements 2 and the ADA Standards. The Standards can provide
guidance to help event planners place temporary accessible parking spaces in
appropriate locations, provide an accessible route throughout the site, and
provide other accessible features for food service, toilet facilities (including
accessible portable toilets), assembly area seating, public telephones, etc., where
such elements or facilities are provided for the public. It is very important to
consider accessibility requirements when the event is in the planning stage so
that accessible facilities can be identified and incorporated in a manner that
does not require extensive construction or last-minute modifications.
Effective communication requirements also apply to temporary events.
It may be necessary to provide qualified sign language interpreters or
other auxiliary aids and services as requested, such as print material in
a large-print format or on computer disk. A town may choose when to
provide interpreters and publicize a schedule for interpreters and other
auxiliary aids and services. 	It should also provide auxiliary aids or
services in response to individual requests, unless to do so would result
in undue financial and administrative burdens. Promotional material
for a temporary event should explain how the public can request a
particular auxiliary aid or service and be informed of when specific
auxiliary aids and services may be available.

20
Resources - Department of Justice
Part Three: 	Resources
The ADA and City Governments:
Common Problems
A 9-page publication that compiles common
problems with Title II compliance.
ADA Regulation for Title II, as printed in the Federal
Register (7/26/91)
The Department of Justice’s regulation imple-
menting title II, subtitle A, of the ADA, which
prohibits discrimination on the basis of disability
in the services, programs, and activities provided
by towns.
Title II Technical Assistance Manual (1993) and
Supplements (Spanish edition available by mail)
A 30-page manual explaining what State and local
governments must do to ensure that their services,
programs, and activities are provided to the public
in a non-discriminatory manner. Gives practical
examples.
Department of Justice ADA Mediation Program
A 8-page publication describing the Department’s
ADA mediation program including locations of
ADA mediators, and examples of successful
mediation efforts.
ADA Regulation for Title III, including the ADA
Standards for Accessible Design.
ADA Information Services
A 2-page list with the telephone numbers and
Internet addresses of Federal agencies and other
organizations that provide information and
technical assistance to the public about the ADA.
Enforcing the ADA: A Status Report from the
Department of Justice
A quarterly report providing timely information
about ADA cases and settlements, building codes
that meet ADA accessibility standards, and ADA
technical assistance activities.
Commonly Asked Questions About the ADA and
Law Enforcement
A 13-page publication explaining ADA require-
ments for ensuring that people with disabilities
receive the same law enforcement services and
protections.
Access for 9-1-1 and Telephone Emergency Services
A 10-page publication explaining the require-
ments for direct, equal access to 9-1-1 for persons
who use teletypewriters (TTYs).
ADA Guide for Small Businesses
A 15-page booklet for businesses that provide
goods and services to the public.
Department of Justice ADA Information
To help State and local governments, including small local governments, understand and comply with
the law, the Department of Justice established a technical assistance program to answer questions about
the ADA. The Department of Justice has a toll-free ADA Information Line that provides access to ADA
specialists during business hours. The ADA Information Line also provides twenty-four hours a day
access to a fax-on-demand system for technical assistance materials that permits a caller to have the
document sent to them by fax. Orders for publications sent by mail may be made twenty-four hours a
day on the Information Line’s voice mail system.
ADA Information Line -- 800-514-0301 voice and 800-514-0383 TTY
Another important source of ADA information is the Department’s ADA Home Page on the World
Wide Web. This extensive web site provides access to ADA regulations, all Department ADA technical
assistance materials, including newly-released technical assistance material, proposed changes in the ADA
regulations, and access to Freedom of Information Act materials including technical assistance letters.
The web site also provides links to other Federal agencies with ADA responsibilities.
ADA Home Page -- www.usdoj.gov/crt/ada/adahom1.htm
Selected ADA Publications available from the ADA Information Line and ADA Home Page:

21
Other Federal Agencies and Federal Grantees Providing Information
Resources - Federal Agencies & Other Organizations
Department of Transportation
Department of Transportation offers technical
assistance on ADA provisions applying to public
transportation.
ADA Assistance Line for information,
questions and complaints
888-446-4511 (voice) -- TTY: relay service
202-366-2285 (voice) -- 202-366-0153 (TTY)
Transportation - documents and questions
202-366-1656 (voice) -- TTY: use relay service
Transportation - legal questions
202-366-4011 (voice) -- TTY: use relay service
Internet address -- www.fta.dot.gov
Equal Employment Opportunity
Commission
Equal Employment Opportunity Commission
offers technical assistance on the ADA provisions
applying to employment; also provides informa-
tion on how to file ADA complaints.
Employment - questions
800-669-4000 (voice) -- 800-669-6820 (TTY)
Employment - documents
800-669-3362 (voice) -- 800-800-3302 (TTY)
Internet address -- www.eeoc.gov
Access Board
Access Board (or Architectural and Transportation
Barriers Compliance Board) offers technical
assistance on the ADA Accessibility Guidelines.
Documents and questions
800-872-2253 (voice) -- 800-993-2822 (TTY)
Electronic bulletin board -- 202-272-5448
Internet address -- www.access-board.gov
Department of Housing and Urban
Development
Fair Housing Act: for questions or publications
call Department of Housing and Urban Develop-
ment.
Fair Housing accessibility questions
202-708-2333 (voice) -- 202-708-4112 (TTY)
Fair Housing publications
800-767-7468 (voice) -- TTY: use relay service
Internet address -- www.hud.gov
Disability and Business Technical Assistance
Centers (DBTACs)
Department of Education funds ten regional
centers to provide technical assistance on the
ADA.
800-949-4232 (voice/TTY)
Internet address -- www.adata.org
Job Accommodation Network
The Job Accommodation Network (JAN) is a
free telephone consulting service offering
information and advice to employers and people
with disabilities on reasonable accommodation in
the workplace.
800-526-7234 (voice &TTY)
Internet address --
http://janweb.icdi.wvu.edu/english

The Americans with Disabilities Act authorizes the Department of Justice (the Department) to
provide technical assistance to individuals and entities that have rights or responsibilities under the
Act. This document provides informal guidance to assist you in understanding the ADA and the
Department's regulations.
This guidance document is not intended to be a final agency action, has no legally binding effect,
and may be rescinded or modified in the Department’s complete discretion, in accordance with
applicable laws. The Department’s guidance documents, including this guidance, do not establish
legally enforceable responsibilities beyond what is required by the terms of the applicable statutes,
regulations, or binding judicial precedent.