Sonoma County Junior College District ADA Self-Evaluation And .
Sonoma County Junior College District ADA Self-Evaluation and Transition PlanJune 2011INTRODUCTION . 31.01.11.21.31.41.5ADA Self-Evaluation and Transition Plan Development Process . 3Introduction . 31.1.1Overview . 31.1.2Legislative Mandate . 31.1.3Discrimination and Accessibility . 51.1.4Undue Burden . 6ADA Self-Evaluation and Transition Plan Development Requirements . 6ADA Self-Evaluation and Transition Plan Development Process . 71.3.1Introduction . 71.3.2Program Accessibility Questionnaire . 81.3.3Review of Published Rules and Regulations . 91.3.4Public Participation Process . 9Facilities Transition Plan . 9Walkways and Curb Ramps . 92.02.1Policies, Procedures, and Program Accessibility: Findings & Recommended Actions . 10Introduction . 102.1.1Overview . 102.1.2Findings and Recommended Actions. 112.2Findings and Recommended Actions—District-wide Practices, Activities, and Services 12Accessible/Adaptive Equipment . 12Customer Service . 12Notice Requirements . 13Printed Information. 16Televised and Audiovisual Public Information . 17Website . 17Public Telephones and Communication Devices . 19Training and Staffing . 20Program Eligibility and Admission . 21Public Meetings . 21Transportation. 23Tours and Trips . 23Use of Consultants for Delivering Program Services. 24Emergency Evacuation Procedures . 243.03.1Transition Plan for Sonoma County Junior College District Facilities . 26Introduction . 263.1.1Overview-Sonoma County Junior College District’s Approach . 263.1.2Evaluation/Survey Process . 263.1.3Facility Reports. 283.2Transition Plan . 28Table of ContentsPage i
Sonoma County Junior College District ADA Self-Evaluation and Transition PlanJune 20113.2.13.2.23.2.33.2.4Barrier Removal Priorities—Districtwide . 28Barrier Removal Priorities—Within a Facility . 28New Construction and Renovations . 29Time Frames for Completion . 304.04.1Exterior Routes of Travel . 32Introduction . 324.1.1Overview of the District’s Approach . 324.1.2Priorities for Path of Travel (POT) Repair, Replacement and New Construction . 324.2Transition Plan—Exterior Routes of Travel. 324.2.1General Policies and Practices . 325.0Complaint Procedures for Discrimination Based on Disability . 346.06.16.26.36.46.56.66.76.8Program Accessibility Guidelines, Standards & Resources . 47Introduction . 47Federal Accessibility Standards & Regulations & Resources . 47State of California Accessibility Standards & Regulations & Resources . 48General Disability Etiquette . 49Local, State, & National Organizations who Provide Disability Services & Information . 50Accessible Websites . 58Emergency Preparedness . 59Providing Accessible Facilities & Programs: Museums, Parks and Recreation, andSchools . 606.9Information for Specific Disabilities . 64Blind/Visual Impaired: Things to Know, Things to Do . 64Deaf/Hard of Hearing: Things to Know, Things to Do. 67Deaf/Blind (Both Deaf and Blind): Things to Know, Things to Do . 71Physical Disability/Mobility Impairment: Things to Know, Things to Do . 73Psychiatric Disabilities: Things to Know, Things to Do. 75Developmental Disabilities: Things to Know, Things to Do . 76Learning Disabilities: Things to Know, Things to Do . 78Speech Impairments: Things to Know, Things to Do . 79Multiple Chemical Sensitivity: Things to Know, Things to Do . 807.0Funding for Projects . 82Appendix A: Accessibility Definitions: . 83Appendix B: Program Accessibility Questionnaire for Program Providers . 88Appendix C - Facility Reports . 89Page ii
Sonoma County Junior College District ADA Self-Evaluation and Transition PlanTransition Plan for District FacilitiesJune 2011INTRODUCTION1.0ADA Self-Evaluation and Transition Plan Development Process1.1Introduction1.1.1 OverviewThe Americans with Disabilities Act (ADA) is a comprehensive civil rights law for persons withdisabilities in both employment and the provision of goods and services. The ADA states that itspurpose is to provide a “clear and comprehensive national mandate for the elimination ofdiscrimination against individuals with disabilities.” Congress emphasized that the ADA seeks todispel stereotypes and assumptions about disabilities and to assure equality of opportunity, fullparticipation, independent living, and economic self-sufficiency for people with disabilities.Appendix A provides definitions for terms used in this report that are found in the ADA and theADA Accessibility Guidelines (ADAAG).This ADA Self-Evaluation and Transition Plan is prepared in compliance with the requirementsset forth in Title II of the ADA. The ADA states that a public entity must reasonably modify itspolicies, practices, or procedures to avoid discrimination against people with disabilities. Thisreport will assist Sonoma County Junior College District in identifying policy, program, andphysical barriers to accessibility and in developing barrier removal solutions that will facilitatethe opportunity of access to all individuals.This report describes the process by which policies, programs, and facilities were evaluated forcompliance with the ADA; presents the findings of that evaluation; and providesrecommendations for ensuring accessibility. This part provides an overview of the requirementsand process for developing the Self-Evaluation and Transition Plan. The next two parts detailthe findings and recommended actions related to providing accessible policies, procedures, andprograms (Part 2) and those related to the District’s program for providing accessible buildingsand facilities (Part 3). Part 4 outlines Routes of Travel and Part 5 outlines the District’scomplaint procedures for disability discrimination. Part 6 describes suggested components ofthe District’s program accessibility resources and toolkit.1.1.2 Legislative MandateThe development of a transition plan is a requirement of the federal regulations implementingthe Rehabilitation Act of 1973, which require that all organizations receiving federal funds maketheir programs available without discrimination toward people with disabilities.The Act, which has become known as the “civil rights act” of persons with disabilities, statesthat:Page 3
Sonoma County Junior College District ADA Self-Evaluation and Transition PlanTransition Plan for District FacilitiesJune 2011No otherwise qualified handicapped individual in the United States shall, solely by reasonof handicap, be excluded from the participation in, be denied the benefits of, or besubjected to discrimination under any program or activity receiving federal financialassistance. (Section 504)Subsequent to the enactment of the Rehabilitation Act, Congress passed the Americans withDisabilities Act (ADA) on July 26, 1990. The Sonoma County Junior College District is obligatedto observe all requirements of Title I of the ADA in its employment practices; Title II in itspolicies, programs, and services; any parts of Titles IV and V that apply to the District, itsprograms, services, or facilities; and all requirements specified in the ADA AccessibilityGuidelines (ADAAG) that apply to facilities and other physical holdings.The Department of Justice’s Title II regulation adopts the general prohibitions of discriminationestablished under Section 504 and incorporates specific prohibitions of discrimination for theADA. Title II provides protections to individuals with disabilities that are at least equal to thoseprovided by the nondiscrimination provisions of Title V of the Rehabilitation Act.This legislative mandate, therefore, prohibits Sonoma County Junior College District from,either directly, or through contractual arrangements:Deny persons with disabilities the opportunity to participate in services, programs, oractivities that are not separate or different from those offered others, even if theDistrict offers permissibly separate or different activities.In determining the location of facilities, making selections that have the effect ofexcluding or discriminating against persons with disabilities.Title II of the ADA stipulates that public entities must identify and evaluate all programs,activities, and services and review all policies, practices, and procedures that governadministration of the programs, activities, and services for all government entities employingmore than fifty people. These administrative requirements include:Completion of a self-evaluation;Development of an ADA complaint procedure;Designation of a person who is responsible for overseeing Title II compliance; andDevelopment of a Transition Plan if the self-evaluation identifies any structuralmodifications necessary for compliance. The Transition Plan must be retained for threeyears.This report and certain documents incorporated by reference establish the ADA Self-Evaluationand Transition Plan for Sonoma County Junior College District.Page 4
Sonoma County Junior College District ADA Self-Evaluation and Transition PlanTransition Plan for District FacilitiesJune 2011In addition, the California Code of Regulations, Title 24, Part 2 mandates that all publicly fundedbuildings, structures, and related facilities shall be accessible to and usable by persons withdisabilities. These regulations, which are often referred to as Title 24, pertain to SonomaCounty Junior College District buildings and facilities that were constructed using state, District,or municipal funds or that are owned, leased, rented, contracted, or sublet by the District. Title24 regulations and standards were also incorporated in the evaluation of architectural barriersas part of Sonoma County Junior College District’s Transition Plan.1.1.3 Discrimination and AccessibilityThere are two types of accessibility: physical accessibility and program accessibility. Absence ofdiscrimination requires that both types of accessibility be provided.The ADA establishes requirements to ensure that buildings and facilities are accessible to andusable by people with disabilities. Design guidelines to achieve accessibility have beendeveloped and are maintained by the U.S. Access Board under the jurisdiction of the ADA. TheADA Accessibility Guidelines (ADAAG) covers a wide variety of facilities (including buildings andoutdoor recreation areas) and establishes minimum accessibility requirements for newconstruction and alterations to these facilities. The District may achieve physical accessibility byensuring that a facility is barrier-free and meets ADAAG technical requirements and State ofCalifornia standards, including those found in Title 24. Barriers include any obstacles thatprevent or restrict the entrance to or use of a facility.Programmatic accessibility includes physical accessibility, but also entails all policies, practices,and procedures that permit people with disabilities to participate in programs and to accessimportant information. Program accessibility requires that individuals with disabilities beprovided an equally effective opportunity to participate in or benefit from a public entity’sprograms and services.The District may achieve program accessibility by a number of methods, both structural andnon-structural:Structural methods may include altering an existing facility;Acquisition or redesign of equipment;Assignment of aides; and/orProviding services at alternate and accessible sites.When choosing a method of providing program access, the District will give priority to the onethat results in the most integrated setting appropriate to encourage interaction among allusers, including individuals with disabilities. In compliance with the requirements of the ADA,the District provides equality of opportunity but does not guarantee equality of results.Page 5
Sonoma County Junior College District ADA Self-Evaluation and Transition PlanTransition Plan for District FacilitiesJune 20111.1.4 Undue BurdenThe District does not have to take any action that it can demonstrate would result in afundamental alteration in the nature of a program or activity, would create a hazardouscondition, or would represent an undue financial and administrative burden. Thisdetermination can only be made by the ADA Coordinator, department head, or designee andmust be accompanied by a statement citing the reasons for reaching that conclusion.The determination that an undue financial burden would result must be based on an evaluationof all resources available for use in a program. For example, if a barrier removal action is judgedunduly burdensome, the District must consider other options for providing access that wouldensure that individuals with disabilities receive the benefits and services of the program oractivity.1.2ADA Self-Evaluation and Transition Plan Development RequirementsThe Self-Evaluation is the District’s assessment of its current policies, practices, and procedures.It identifies and corrects those policies and practices that are inconsistent with therequirements of Title II of the ADA. In keeping with these requirements and as part of the SelfEvaluation, Sonoma County Junior College District:Identified all its programs, activities, and services; andReviewed all the policies, practices, and procedures that govern the administration of itsprograms, activities, and services.The ADA also sets forth specific requirements for preparation of an acceptable Transition Plan.At a minimum, the elements of the plan should include:A list of the physical barriers at District facilities that limit the accessibility of itsprograms, activities, or services to individuals with disabilities;A detailed outline of the methods to be used to remove these barriers and meet thecurrent standards and accessibility regulations;A schedule for taking the steps necessary to achieve compliance with Title II of the ADA;andThe name of the individual responsible for the plan’s implementation.Page 6
Sonoma County Junior College District ADA Self-Evaluation and Transition PlanTransition Plan for District FacilitiesJune 20111.3ADA Self-Evaluation and Transition Plan Development ProcessThe process developed and implemented to complete Sonoma County Junior College District’sADA Self-Evaluation and Transition Plan included meetings with the President and ComponentAdministrators of the District; the administration of a survey to assess program and servicesaccessibility; a review of the District’s published rules and regulations; a survey by Architerra toidentify physical barriers in public facilities and pedestrian rights-of-ways, and a public meetingto obtain input from students, employees, and members of the community and to review theTransition Plan recommendations.1.3.1 IntroductionServices and programs offered by Sonoma County Junior College District, to the public, must beaccessible. Accessibility applies to all aspects of a program or service, including advertisement,orientation, eligibility, participation, testing or evaluation, physical access, provision of auxiliaryaids, and transportation.The goals of the Self-Evaluation were:1. To develop policy recommendations for the District and each of its departments,divisions, and programs;2. To ensure that the views of the disability community are included in the District’spolicies; and3. To foster ties between District staff and representatives of the disability community.The process of making District facilities and programs accessible to all individuals will be an ongoing one, and the District will continue to review accessibility issues such as resolution ofcomplaints and reasonable modifications to programs. The District will also periodicallyevaluate the success of improving access to programs by the practices and proceduresdeveloped during the Self-Evaluation process.The evaluation of the services and programs of Sonoma County Junior College District includedthe following activities:Hired a consultant (Architerra, LLP) to evaluate the physical environment and identifystructural barriers on the Santa Rosa Campus;Evaluated programs, services and activities via a survey to the college community;Prioritized improvements for increasing access and removing barriers;Developed a Transition Plan for the District.Page 7
Sonoma County Junior College District ADA Self-Evaluation and Transition PlanTransition Plan for District FacilitiesJune 20111.3.2 Program Accessibility QuestionnaireThe Self-Evaluation of Sonoma County Junior College District’s services, programs, and activitiesrequired and involved the participation of every department and division of the District.The District distributed a program accessibility questionnaire to each department/division forits staff to complete. Staff members were asked to complete a written program accessibilitysurvey, which included an inventory of all services and programs provided to the public and thelocations at which these were provided. The survey included a review of the followinginformation:A summary of the program and its purpose, the specific activities that comprise theprogram, and the nature of any advertising or program material produced;Any program or admission eligibility requirements;An overview of participation in the program, including who participates and howparticipation is facilitated;The methods used by the department to provide accessibility;Any access complaints or requests for improving access to the program;A list of facilities, or portions of facilities, used for the program and the activity thattakes place there;Program providers, including outside organizations;Transportation services;Communication, including television, audiovisual presentations and the District’swebsite;Emergency evacuation procedures;Accessible/adaptive equipment;Customer service;Notice requirements;Printed information;Public telephones and communication devices;Training and staffing;Program eligibility requirements and admission;Public meetings;Tours and trips;Use of consultants;Emergency evacuation procedures;Facilities; andSpecial events and private events on District properties.Page 8
Sonoma County Junior College District ADA Self-Evaluation and Transition PlanTransition Plan for District FacilitiesJune 20111.3.3 Review of Published Rules and RegulationsThe published policies and practices of Sonoma County Junior College District were analyzed todetermine whether services offered are and/or language used is discriminatory to people withdisabilities. Policies, when reviewed and updated, will include a review of language regardingpeople with disabilities.1.3.4 Public Participation ProcessA public involvement process assisted in the development of this Self-Evaluation and TransitionPlan in order to obtain input from the community. The District Accessibility Committeereviewed the plan and provided input for prioritization of barrier removal. A public meeting forin-person participation was held on May 16th, 2011 at the Petaluma Camus from 10:00a.m. to12:00p.m. and at the Santa Rosa Campus from 2:00p.m. to 4:00p.m.The public meeting was publicized/advertised on the web;The public meeting notice was distributed to over 2,300 disabled students via thestudent portal;The public meeting was announced to over 3,000 staff and faculty via college-wideemail distribution.1.4Facilities Transition PlanThe District conducted a survey of architectural barriers in its buildings and facilities on theSanta Rosa Campus in 2007. Only those areas open to the public were surveyed. The surveysprovide the District with an overview of the architectural barriers that prevent people withdisabilities from using its facilities and participating in its programs.1.5Walkways and Curb RampsThe survey of architectural barriers also included a review of all walkways and curb ramps. Thesurveys provide the District with an overview of the architectural barriers that prevent peoplewith disabilities from maneuvering the campus, and participating in its programs.Page 9
Sonoma County Junior College District ADA Self-Evaluation and Transition PlanTransition Plan for District FacilitiesJune 20112.0Policies, Procedures, and Program Accessibility: Findings & Recommended Actions2.1IntroductionServices and programs offered by Sonoma County Junior College District to the public must beaccessible. Accessibility applies to all aspects of a program or service, including advertisement,orientation, eligibility, participation, testing or evaluation, physical access, provision of auxiliaryaids, transportation, policies, and communication.2.1.1 OverviewThe following sections detail the review of current District-wide and unique policies, services,programs, and activities based on meetings with District staff and responses to the programaccessibility questionnaire from the following departments, divisions, and programs.Academic AffairsArts, Humanities, Behavioral & Social SciencesLiberal Arts & SciencesBusiness & Professional StudiesCareer & Technical Education & Economic DevelopmentLearning ResourcesChild DevelopmentContinuing Education & Strategic Program DevelopmentCurriculum & Educational Support ServicesEconomic Workforce DevelopmentAgriculture & Natural ResourcesFoster & Kinship Care Education ProgramHealth SciencesLanguage Arts & Academic FoundationsMedia ServicesMESALife SciencesPhysical EducationPublic SafetyBusiness ServicesBookstoreDistrict PolicePurchasing & Graphics ServicesPage 10
Sonoma County Junior College District ADA Self-Evaluation and Transition PlanTransition Plan for District FacilitiesJune 2011President’s OfficeEnvironmental Health & SafetyFacilities OperationsInformation TechnologyPublic RelationsHuman ResourcesStudent ServicesDisability ResourcesMatriculation & AssessmentScholarship & Outreach ProgramsFinancial AidAdmissions & RecordsEOPS/CarePetaluma CampusInstruction & Enrollment ManagementInstruction & Technical ServicesMedia ServicesFacilitiesBookstore2.1.2 Findings and Recommended ActionsFindings (based on the survey administered in 2007) and recommended actions are provided inSection 2.2 for District-wide programmatic accessibility barriers in the following areas:Accessible/Adaptive Equipment Customer ServiceNotice requirementsPrinted informationTelevised and audiovisual public informationWebsitePublic telephones and communication devicesTraining and staffingProgram eligibility and admissionPublic meetingsTransportation servicesTours and tripsUse of consultants for delivering program servicesEmergency evacuation proceduresFacilitiesSpecial events on District propertiesPage 11
Sonoma County Junior College District ADA Self-Evaluation and Transition PlanTransition Plan for District FacilitiesJune 20112.2Findings and Recommended Actions—District-wide Practices, Activities, and ServicesAccessible/Adaptive EquipmentSelf-Evaluation Findings:Many programs make electronic equipment available. Most of these programs report that theymake this equipment accessible to persons with disabilities, and that auxiliary aids are providedto assist persons with disabilities.Action Steps:1. Collaborate with local community organizations such as the Disability Services and LegalServices to develop and maintain a current resource list of assistive technologyequipment and sources for acquiring them.2.Establish and maintain a “Resources Toolkit” (please see section 6.0) of adaptive aidsand human resources that should be available for use by individuals participating inprograms. Include information about the availability of specific equipment and/orindividuals who are available to provide special services (e.g., ASL translation) in publicinformation materials such as brochures and the District’s website.3.Include accessibility as a criterion for purchasing decision making. Whenever possible,evaluate furniture and building materials purchases for compatibility with a wide rangeof disabilities and sensitivities. Select items that are easily adjustable or can be modifiedto accommodate a variety of physical and ergonomic needs when purchasing items suchas furniture, site furnishings, and office systems. Consultation with disabilityorganizations and persons with disabilities (Please see section 6.0 for DisabilityResources) will assist in this task.Customer ServiceSelf-Evaluation Findings:Most staff reported that they do not have eligibility requirements. Few staff reported that theycannot make procedural changes to accommodate an instructor or students with disabilities.
Sonoma County Junior College District ADA Self-Evaluation and Transition Plan Transition Plan for District Facilities June 2011 Page 3 INTRODUCTION 1.0 ADA Self-Evaluation and Transition Plan Development Process 1.1 Introduction 1.1.1 Overview . The Americans with Disabilities Act (ADA) is a comprehensive civil rights law for persons with
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