HomeMy WebLinkAboutres2021-016•
Whatcom County
COUNTY COURTHOUSE
311 Grand Avenue, Ste #105
Bellingham, WA 98225-4038
(360) 778-5010
Agenda Bill Master Report
File Number: AB2021-244
File ID:
AB2021-244
Version: 1
Status: Approved
File Created:
04/08/2021
Entered by: RMcconne@co.whatcom.wa.us
Department:
Public Works
File Type: Resolution Requiring a Public Hearing
Department
Assigned to:
Council
Final Action: 05/04/2021
Agenda Date:
05/04/2021
Enactment #: RES 2021-016
Primary Contact Email: sdraper@co.whatcom.wa.us
TITLE FOR AGENDA ITEM:
Resolution adopting the Whatcom County Americans with Disabilities Act (ADA) Transition Plan within
the Public Rights -of -Way
SUMMARY STATEMENT OR LEGAL NOTICE LANGUAGE:
See attached memo
HISTORY OF LEGISLATIVE FILE
Date: Acting Body: Action: Sent To:
04/20/2021 Council INTRODUCED FOR PUBLIC Council
HEARING
Aye: 7 Browne, Buchanan, Byrd, Donovan, Elenbaas, Frazey, and Kershner
Nay: 0
Absent: 0
05/04/2021 Council APPROVED
Aye: 6 Browne, Buchanan, Donovan, Elenbaas, Frazey, and Kershner
Nay: 0
Absent: 1 Byrd
Attachments: Agenda Bill Master Report, Staff memo, Proposed Resolution with Exhibit A
Whatcom County Page 1 Printed on 51712021
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
PROPOSED BY: Public Works - Engineering
INTRODUCTION DATE: 4/20/2021
RESOLUTION NO.2021-016
A RESOLUTION ADOPTING THE WHATCOM COUNTY AMERICANS WITH
DISABILITIES ACT (ADA) TRANSITION PLAN WITHIN PUBLIC RIGHTS -OF -WAY
WHEREAS, the Americans with Disabilities Act was enacted on July 26, 1990 and
provides comprehensive civil rights to persons with disabilities; and
WHEREAS, to satisfy the requirements of ADA Title II Part 35, Subpart D, the Whatcom
County Department of Public Works initiated the drafting of a Transition Plan to outline
modifications and efforts that must be made to correct findings of non-compliance with ADA
standards; and
WHEREAS, Title II of the ADA requires public entities to provide an opportunity to
interested parties, including individuals with disabilities or organizations representing individuals
with disabilities to participate in the development of the transition plan, and
WHEREAS, the County held an official 30-day public comment period of the draft ADA
Transition Plan and incorporated feedback from the public and interested groups into the
Whatcom County ADA Transition Plan Within Public Rights -of -Way in attached Exhibit A;
NOW, THEREFORE, BE IT RESOLVED by the Whatcom County Council that the
Whatcom County ADA Transition Plan Within Public Rights -of -Way, attached hereto as Exhibit A,
is hereby adopted.
ADOPTED this 4th day of May , 2021.
���;��t�sstsF�tFetE
� G O
G G
6
Dana. Brovyn-av'is, Cleric,df the; ouncil
'VI
` a m
APPROVEt1: A5 TO FOR'Mte'
Approved by Christopher Quinn by email/DH
Sr. Deputy Prosecuting Attorney,
Civil Division
WHATCOM COUNTY COUNCIL
WHATCOM COUNTY, WASHINGTON
,-A- A (P
Barry Buchanan, Council Chair
Exhibit A:
Whatcom County ADA Transition Plan Within Public
Rights -of -Way
This page intentionally left blank.
Whams or IT Count/
Prepared by
This page intentionally blank.
Whatcom County
311 Grand Avenue, Suite 105
Bellingham, Washington 98225
360-778-5010
www.whatcomcounty.us
COUNTY ADMINISTRATION
Jon Hutchings, Director of Public Works
Rud Browne
Todd Donovan
Tyler Byrd
Kathy Kershner-
Ben Elenbaas
Barry Buchanan
Carol Frazey
Transpo Group
12131 1 13rh Ave NE, Ste. 203
Kirkland, WA 98034
e-AN BE T
Additional copies of this document are available online at
www.whatcomcounty.us/ADATransitionPlan
This plan can be made available in an alternate format by emailing
the Human Resources Manager, ADA Coordinator, at
hr@co.whatcom.wa.us or by calling 360-778-5300, Persons who are
deaf or hard of hearing may make a request by calling the
Washington State Relay at 711.
For questions about Whatcom County's ADA Transition Plan, please
contact
Whatcom County - Department of Public Works
322 N Commercial Street, Ste 210
Bellingham, WA 98225
360-778-6200
IINTRODUCTION ............................. ............ ................... ......................... ............................. 2
. I PLAN REQUIREMENTS AND STANDARDS..........................................................................................................
2
1.2 BACKGROUND.....................................................................................................................................................
3
1.3 PLAN STRUCTURE................................................................................................................................................
3
2 SELF-ASSESSMENI...............................................................................................................4
2.1 POLICY, PRACTICES AND DESIGN STANDARDS........................................................................................4
2.1.1 Method...............................................................................................................................................................................4
2.1.2 Findings.................................................................................................................................................................................4
2.2 PHYSICAL BARRIER...............................................................................................................................................
4
2.2.1 Data Collection.............................................................................................................................................................4
2.2.2 Findings.............................................................................................................................................................................6
2.3 GIS INVENTORY DATABASE...............................................................................................................................
8
3 STAKEHOLDER ENGAGEMENT.......................................................................I................9
3.1 ENGAGEMENT METHODS..... ................................................................. ...................... ..................................
9
3.1.1 Public Meeting..............................................................................................................................................................
9
3.1.2 On -Line Survey............................................................................................................................................................9
3.1.3 Focus Group... ..................... .................. .............. ............................. .........................................................................
9
3.2 MEETING ADA STANDARDS ............................................................................................................................10
4 BARRIER REMOVAL.—
11
4.1 BARRIER REMOVAL METHODS.....................................................................................................................
1 1
4.2 BARRIER REMOVAL RECOMMENDATIONS.................................................................................................
11
5 IMPLEMENTATION ............................................................................................................
Is
5.1 APPROACH........................................................................................................................................................
15
5.2 PRIORITIZATION................................................................................................................................................15
5.2.1 Accessibility Index Score....................................................................................................................................
15
5.2.2 Location Index Score............................................................................................................................................
21
5.2.3 Barrier Removal Priorities..................................................................................................................................
22
5.3 TRANSITION PLAN COST AND SCHEDULE.................................................................................................23
5.3.1 Process............. ........................ ................ ......................................................................................................................
23
5.3.2 Planning Level Cost Estimate........................................................................................................................
23
5.3.3 Schedule........................................................................................................................................................................25
6 CURRENT PRACTICES ......................................................................................................26
6.1 OFFICIAL RESPONSIBLE........................................................................................................................................26
6.2 CURRENT FUNDING INFORMATION.....................................................................................................................26
6.3 UPDATE OF DESIGN STANDARDS AND TRAINING...........................................................................................26
6AAPS POLICY.............................................................................................................................................................26
6.5 CURRENT GRIEVANCE PROCESS................................................................................................................26
6.6 MAXIMUM EXTENT FEASIBLE DATABASE AND PROCESS............................................................................26
APPENDICES
Appendix A — Barrier Audit
Appendix B—APSPo|icy
Appendix C—Muzimum Extent Feasible Template
Appendix D — Public Involvement
Appendix E—G|6 Inventory
Appendix IF—[oxt Estimate Backup
This page intentionally blank.
ADA Transition Plan Whatcom County February 2021
Executive Summary
This Americans with Disabilities Act Self -Evaluation and Transition Plan establishes the Whatcom
County's ongoing commitment to providing equal access for all, including those with disabilities. In
developing this plan, Whatcom County has undertaken a comprehensive evaluation of its facilities and
programs within the public rights -of -way to determine what types of access barriers exist for individuals
with disabilities. This plan will be used to help guide future planning and implementation of necessary
accessibility improvements.
Both the Self -Assessment and the Transition Plan are required elements of the federally mandated ADA
Title II, which requires that government agencies provide equal access to programs and services they
offer. While the ADA applies to all aspects of government services, this document focuses on
Whatcom County Public Facilities, within public right-of-way. This includes sidewalks, curb
ramps, pedestrian pushbuttons, and other public facilities.
This document summarizes the Self -Assessment, which includes an accessibility assessment of pedestrian
facilities as well as practices and procedures which relate to them, such as curb ramp design standards. It
also contains a Transition Plan, which identifies a schedule for the removal of barriers and identifies how
the County will address requests for accommodations in a consistent manner, see section 5.3 for
schedule details.
The County's objective is to remove physical barriers associated with access to public park facilities,
building interior pathways, park trails, sidewalks and curb ramps, in association with the Transportation
Improvement Program (TIP). The County is committed to removing these barriers as soon as possible,
the county will implement a program that will remove the highest priority barriers. In addition, the
county is committed to ensuring continued ADA compliance for all capital improvement projects,
permitted development, and any other right-of-way construction projects.
ADA Transition Plan Whatcom County February 2021
}
The Americans with Disabilities Act (ADA) was
enacted on July 26, 1990 and provides
comprehensive civil rights protections to
persons with disabilities in the areas of
employment, state and local government
services, and access to public accommodations,
transportation, and telecommunications.
Counties and other government agencies are
required to have an ADA self -assessment and
transition plan when they grow beyond a
threshold of 50 employees. Accessibility
requirements extend to all public facilities. The
scope of this plan is focused on accessibility
within the public rights -of -way, selected public
buildings and parks.
There are five titles, or parts, to the ADA of
which Title II is most pertinent to travel within
the public rights -of -way and government
buildings. Title II of the ADA requires Public
Entities to make their existing "programs"
accessible "except where to do so would result
in a fundamental alteration in the nature of the
program or an undue financial and
administrative burden." Public rights -of -way,
public government buildings, and public parks all
fall within the County's programs.
This effort was initiated by Whatcom County to
satisfy the requirements of ADA Title II Part 35,
Subpart D — Program Accessibility § 35.150
(d)(3) which states:
2
The plan shall, at a minimum—
(i) Identify physical obstacles in the public
entity's facilities that limit the accessibility of
its programs or activities to individuals with
disabilities;
(ii) Describe in detail the methods that will be
used to make the facilities accessible;
(iii) Specify the schedule for taking the steps
necessary to achieve compliance with this
section and, if the time period of the
transition plan is longer than one year, identify
steps that will be taken during each year
(iv) Indicate the official responsible for
implementation of the plan.
The 2010 ADA Standards for Accessible Design
(ADAS), is the standards document in which all
federal ADA standards are collectively held.
The 2010 ADAS and regulations from the 28
CFR Part 36 replaced the 1991 ADA (ADA
Accessibility Guidelines (ADAAG)).
The Draft Guidelines for Accessible Public
Rights -of -Way was first published by the US
Access Board in 2005. The US Access Board's
Proposed Guidelines for Pedestrian Facilities in
the Public Right -of- , or PROWAG, was
published for comment in 2011. Both the 2005
and 2011 guidelines have not yet been adopted
as standards. Despite this delay, many public
entities currently use the draft PROWAG as
'best practice' for features within the public
rights -of -way and this practice has been
endorsed by the Federal Highway
Administration (FHWA) and the US Access
Board. The public right-of-way facilities
ADA Transition Plan Whatcom County February 2021
evaluated under this plan were evaluated against
the 2010 ADAS and PROWAG.
In 1995 Whatcom County Council adopted an
ADA Transition Plan and Self -Evaluation, and in
1999 an update to the ADA Transition Plan and
Self -Evaluation were adopted. The initial 1995
plan included a statement of requirements, an
implementation schedule, a survey of county
facilities, and a self -evaluation plan. The 1999
update includes the same elements as well as
transition plan notes and updated information
for facilities. The transition plans identified 23
facilities for survey and barrier removal. The
county removed all barriers identified in the
plan and update in accordance with the plan
guidelines. The previous plan and update focus
on providing access to public buildings and
specific programs, but do not provide a robust
review of the pedestrian facilities within the
public right-of-way.
The structure of this plan was organized to
closely follow federal ADA transition plan
requirements. This includes:
Chapter 2 — Self -Assessment
Documents self -assessment findings
including physical barriers as well as
practices or design standards that result in
accessibility barriers.
Chapter 3 — Stakeholder Engagement
Documents public engagement efforts.
Describes both programs and mechanisms
the County will use to remove accessibility
barriers and identifies a number of detailed
recommendations the County should
implement to remove accessibility barriers
moving forward.
Chapter 5 -- Implementation Outlines a
schedule for the transition plan, including
prioritization of projects, planning level
cost estimates and potential funding
sources.
Chapter 6 - Current Practices Provides
the County with a location to store
important and evolving plan information
such as where and how this plan should be
accessible, annual performance tracking,
identification of the official responsible and
other items that will change over time.
Rest practices were identified and incorporated
throughout the planning process beginning with
the Scope of Work.
Several associated appendix items are included
along with the plan.
Appendix A — Barrier Audit
Appendix B — APS Policy
Appendix C — Maximum Extent Feasible Template
Appendix D — Public Involvement
Appendix F — GIS Inventory
Appendix F — Cost Estimate Backup
Title II of the Americans with Disabilities Act
(ADA) requires that jurisdictions evaluate
services, programs, policies, and practices to
determine their compliance with the
nondiscrimination requirements of the ADA.
This section describes the data collection
process and resulting inventory of physical
facilities such as sidewalks and curb ramps
within the County's public rights -of -way. The
inventory and self -assessment process are
described in these sections.
Practices and design standards that meet
accessibility standards are essential to ensure
new or upgraded pedestrian facilities are
accessible and that these upgrades contribute to
the removal of accessibility barriers throughout
the County. This section summarizes a review
of County's practices and design standards for
barriers and includes major findings of this
work. Complete documentation of this work
can be found in Appendix A. The audit was
conducted in February of 2020.
Whatcom County maintains adopted design
standards for pedestrian facilities. These
standards are used for County funded projects
as well as privately designed and constructed
projects within the public right-of-way. The
Whatcom County Street Design Standards
were audited for compliance with ADA
guidelines found in the 2010 ADAS and the
Public Rights -of -Way Accessibility Guidelines
(US Access Board, 2005).
0
As a result of the standards review several
recommendations were made to update these
guidance documents to adhere to ADA
standards. The code mostly references the
RCWs regarding ADA standards, which is
appropriate to clarify legal requirements. For
many items' additional references to the
WSDOT Design Manual will provide the
necessary detail to make sure the county
standards are compliant with ADA standards.
Additionally, there were a few discrepancies
between the Whatcom County Code, Road
Standards and Standard Drawings. These
recommendations are grouped into several
categories including: Sidewalks, Crosswalks,
Curb Ramps, and Signals, these can be found in
Appendix A.
A self -assessment of all facilities within the
public right-of-way was conducted and
employed a robust data collection effort that
included 8 attributes for sidewalks, 22 attributes
for curb ramps, 17 attributes for signal
I_L..tt A 11 9 I f
pusnouccons, �r or crosswalks, i attributes for
bus stops, 14 for ADA accessible parking aisles
and stalls, and 10 attributes for barriers/hazards.
These attributes were collected in the field with
individuals trained in ADA data collection
methods. Data was collected over a four -month
period.
A qualitative assessment was also conducted for
the accessibility of the Whatcom Chief Ferry
from Gooseberry Poing to Lummi Island. This
assessment occurred in October of 2020 and
included a site visit and interviews with Ferry
operators and County staff.
ADA Transition Plan Whatcom County February 2021
Data inventory for public ROW features was
collected using mobile tablet units and other
smart devices with GIS geodatabase
information. Attributes for features in the public
ROW were collected by a consultant from July
to September 2019.
Consultant staff conducted field and data
collection under supervision to ensure
consistent and accurate measurement of
sidewalk and curb ramp measurements as well
as correct recording of information using a GIS
database.
Data collection staff were provided a tape
measure (to measure dimensions for features
such as widths of curb ramps and sidewalks),
and a smart level to efficiently and accurately
measure slopes. Data collectors used mobile
units with the Collector for ArcGIS application
installed to record the measurements and traits
of each feature.
For sidewalks, cross slopes were measured at
each end of the segment and once in the
middle. The running slope was measured at
similar locations excluding within curb ramps
and driveways, with the steepest measurement
being the one recorded. The predominant
sidewalk width was recorded for the length of
the block from one intersection to the next. In
addition, a separate database was developed to
inventory specific pedestrian access route
(PAR) barriers including:
® Horizontal and Vertical Discontinuities
® Fixed, Movable, or Protruding Objects
• Non -Compliant Driveways
For curb ramps, both existing and missing curb
ramps were identified. When measures of the
same attribute, such as flare slope (typically
each ramp has two flares), differed, the worst
measure for accessibility was recorded.
To improve the collection process for curb
ramps, an optimization method was developed
The elements of curb ramps that often create
the largest barriers when out of compliance
were first measured. If any of these
measurements were noncompliant, the data
collector stopped taking measurements of other
elements on the curb ramp. This method allows
ADA Transition Plan Whatcom County February 2021
the County to quickly identify which ramps
create larger barriers to users and would need
to be replaced without collecting data that was
deemed irrelevant if the curb ramp needed full
replacement. This helped reduce data collection
time while still providing the County with
accurate data for decision malting
The physical inventory included;
® over 53 miles of existing sidewalks, paved
shoulder walkways, paved separated
walkways
® 1091 curb ramps
® 24 signal pushbuttons
® 261 bus stops
2 accessible parking stalls
® over 1850 hazards
The attributes of each feature type were
developed using WSDOT's Field Guide for
Accessible Public Rights of Way along with the
United States Access Board's PROWAG as a
baseline, with edits based on feedback from
County staff. Appendix E and the GIS data base
show the exact location of each inventory item
surveyed and identify non -compliant facilities.
The following sections detail the primary
barriers inventoried and analyzed for ADA
compliance. The barriers found applied to
different features including curb ramps,
sidewalks, discontinuities and obstacles in
pedestrian routes, and pedestrian pushbuttons.
State and Federal regulations dictate that curb
ramps and sidewalks be ADA compliant. The
result of the inventory analysis showed that
most ADA features within the public right-of-
way are in need of improvement to meet
requirements.
2.r.2, 1 (., ido Rarnps
The data collected to evaluate curb ramp
compliance was divided into three overarching
0
categories: compliant, minor non -compliant and
major non-compliance. A ramp was found to be
compliant only if all collected features of the
ramp met the required accessibility standards.
Both non -compliant categories represent
barriers to accessibility that will require
attention such as, reconstruction or new ramps.
While compliant ramps require no modification.
The majority of the existing curb ramps were
found to be non -compliant based on current
ADA requirements. A ramp was found to be a
major non-compliance, if the ramp width was
too narrow or if the run or cross slopes were
overly steep. A ramp was found to be a minor
non-compliance if the barrier was easily
removed with maintenance, or if run or cross
slopes were only slightly steeper than standard.
Figure 2-1 shows a sample of the curb ramps
surveyed in the County and the percentage of
non -compliant to compliant curb ramps within
the County. All non -compliant curb ramps will
need to be addressed and all barriers removed,
minor and major non -compliances are used to
show the level of severity of curb ramp
barriers. Compliant, minor non -compliant, and
major non -compliant curb ramps are shown in
blue, yellow, and red, respectively.
figure 2-1 Percentage of Major and Minor Non -Compliant Curb
Ramps and Compliant Curb Ramps
ADA Transition Plan Whatcom County February 2021
2.2.2.2 >id w, alks slightly steeper than standard were considered
Most sidewalks in the Whatcom County are minor non -compliances. All non -compliant
non -compliant based on ADA requirements. sidewalk segments will need to be addressed
The most frequent reasons for non -compliant and all barriers removed, minor and major non -
sidewalk segments are: compliances are used to show the level of
severity of sidewalk barriers. Compliant, minor
® The sidewalk width is too narrow
® The cross slope of the sidewalk is too
steep
® The sidewalk has fixed/non-fixed
barriers and other discontinuities that
impede required usable pedestrian
space
® Non -compliant driveways intersect the
sidewalk
Figure 2-2 shows a sample of the sidewalks
surveyed in the County and demonstrates the
percentage of sidewalk length that is compliant
and non -compliant throughout the County.
Non -compliant sidewalks are broken into two
categories, minor and major non -compliant. For
example; a sidewalk is considered to be a major
non-compliance if the width is too narrow, or if
the cross or run slopes are overly steep. A
sidewalk segment with cross or run slopes only
Accessible Pedestrian Signals (APS) and
Pushbuttons is an integrated system that
communicates to pedestrians in a visual, audible,
and vibrotactile manner. There are 24
pushbuttons in the Whatcom County, 18 of
these pushbuttons are non-APS style and
therefore do not meet current ADA
requirements. The remaining 6 pushbuttons are
APS style but will require some modifications to
be fully compliant. There are two categories of
required upgrades, buttons that need to be
relocated and reprogramed, and non-APS
buttons that need to be replaced. Figure 2-3
shows a sample of the pedestrian pushbuttons
surveyed in the County and demonstrates the
percentage of pushbuttons in each category
throughout the County. APS style and non-APS
1►9
non -compliant, and major non -compliant
sidewalks are shown in blue, yellow, and red,
respectively.
Figure 2-2 Percentage of Major and Minor Non-Comphont
Sidewalk and Compliant Sidewalk
style pushbuttons are shown in blue and red,
respectively.
Figure 2-3 Percentage ofAPS Style and Non-APS Style
Pushbuttons
ADA Transition Plan Whatcom County February 2021
2.2.2,zl. 1/Vh atcorn Chief Ferry
The Whatcom Chief Ferry is primarily a
commuter ferry for the residents of Lummi
Island. It is also the only access point for the
island for tourists and other visitors. The ferry
makes approximately 40 round trips per day
between Gooseberry Point and Lummi Island.
The existing ferry allows for walk-on passengers
but the ferry docks have very limited pedestrian
facilities. Walk-on passengers must use the
vehicular roadways and ramps to board and
deboard the ferry. With regards to accessibility,
these roadways and ramps have several barriers
including vertical and horizontal discontinuities,
non -compliant slopes, non -compliant ramps,
and no designated pedestrian route.
Both docks have parking spaces marked as
accessible that are used sporadically. There is
also a bus stop on the Gooseberry Point side.
Restrooms are present at the Lummi Island
dock but not at the Gooseberry Point dock.
There are no dedicated pedestrian faciltities
between these features and the ferry docks and
pedestrians use the adjacent roadway pavement
to access these facilities.
As a part of the self -assessment an extensive
GIS database was created to assist with tracking
progress through barrier removal. The database
contains each attribute that was inventoried and
all data that was collected for each attribute.
The ferry itself has a small indoor passenger
area but no accessible ingress or egress point.
There are several large vertical hazards
between the loading point and the passenger
compartment.
In addition to the vehicular ferry, a passenger
only ferry is also used for several weeks in the
fall while the vehicular ferry is in dry dock for
maintenance. This boat was not assessed as part
of the self -assessment but interviews with ferry
and county staff indicate that accessibility is a
challenge with the passenger ferry as well. In
particular, ingress and egress to the ferry can be
challenging and the ferry is not able to
accommodate larger powered wheelchairs.
As of the publication of this report the County
has a preliminary design for a new ferry and is
working to obtain funding. The new ferry will
address the accessibility issues mentioned above
and will be more accessible. As these plans are
implemented, it is recommended that the
County also remove barriers at both docks to
provide a fully accessible route for pedestrians.
This database was provided to the county and
will be used and updated in the ongoing efforts
to brine the county into compliance with the
ADA standards.
ADA Transition Plan Whatcom County February 2021
Stakeholder ;
Public and stakeholder input is an essential
element in the transition plan development and
self -evaluation processes. ADA implementation
regulations require public entities to provide an
opportunity to interested persons, including
individuals with disabilities or organizations
representing individuals with disabilities, to
participate in the self -evaluation process and
development of the transition plan by
submitting comments (28 CFR 35.105(b) and 28
CFR 35.150(d)(1)). There were three primary
goals for the public outreach activities prior to
adopting the plan:
Meet Title II requirements for public
comment opportunity.
Inform the public about the County's
plan and processes regarding removal of
barriers to accessibility within the right-
of-way. Provide information to assist
interested parties to understand the
issues faced by the County, alternatives
considered and planned actions.
Obtain public comment to identify any
errors or gaps in the proposed
accessibility transition plan for the
public rights of way, specifically on
prioritization and grievance processes.
A public meeting was held at Luke's Community
and Education Center on July 30, 2019. The
meeting was widely advertised on the Whatcom
County Web Page, local radio, and to attendees
and speakers at a Whatcom County Hearing on
June 18th, 2019. Despite adequate
advertisement and public notification less than
10 members of the community were in
Pi
attendance. The objective of this event was to
reach a broad cross-section of community
members to introduce them to the plan, ask
them about barriers and gaps in the public right-
of-way, to start to define what is most
important to the public. Materials included a
large map of the County and a board defining
potential priorities. Participants were able to
use the figures to provide input on priority
infrastructure and locations. A full account of
the findings can be found in Appendix A.
With the assistance of a consultant, Whatcom
County developed a 19-question on-line survey
that was available from June 30, 2019 — August
30, 2019. The survey gathered community
feedback from over 90 community members.
The survey asked for specific feedback on
several important items related to accessibility.
Participants were asked to identify barriers they
have experienced on pedestrian facilities in the
County, as well as types of barriers, barrier
locations, and other accessibility issues. There
was a detectable difference between perceived
barriers for persons with disabilities, and those
without disabilities. Persons with disabilities
showed hospitals and park access as their
highest priorities, while those without put a
higher emphasis on community services.
Appendix A contains a detailed summary of all
comments received.
The County hosted two 90-minute focus
groups on October I st and 3rd of 2019. The
focus group meetings were offered to
interested members of the community to
review the initial comments received to date
through the open house and survey as well as
provide deeper feedback on aspects of
ADA Transition Plan Whatcom County February 2021
accessibility in the County including specific
locations, types of issues, and priorities.
The focus group was provided with a facilitation
guide as well a map of the County showing the
transit routes, a set of priorities, the
PowerPoint and flip charts. Appendix A
contains a detailed summary of all comments
received.
Per 28 CFR 35.150(d)(1), public involvement is
required as follows: A public entity shall provide
an opportunity to interested persons, including
individuals with disabilities or organizations
representing individuals with disabilities, to
participate in the development of the transition
IN
plan by submitting comments. A copy of the
transition plan shall be made available for public
inspection.
The Draft Whatcom County Transition Plan
was made available for public review and
comment for a period during the months of
March and April 2021. A link to the draft plan
was provided on the County's project website.
Title VI of the Civil Rights Act of 1964 is a
Federal statute and provides that no person
shall, on the grounds of race, color, or national
origin, be excluded from participation in, be
denied the benefits of, or be subjected to
discrimination under any program or activity
receiving Federal financial assistance. This
includes matters related to language access or
limited English proficient (LEP) persons.
ADA Transition Plan Whatcom County February 2021
4 Barrier Removal
Removal of accessibility barriers is the primary
purpose of ADA transition plans. The following
section documents the primary methods of
barrier removal the County currently has in
place. This section also provides recommended
changes to County policies, practices and design
standards to comply with state and federal
requirements related to ADA accessibility.
The County currently has a limited number of
methods to remove accessibility barriers in the
public right-of-way. Current methods of barrier
removal are indirect and are usually related to
other programs and projects conducted as part
of the Capital Improvement Plan. These
projects, when impacting existing pedestrian
facilities, will upgrade these facilities when
required. Occasionally, permitted development
will result in the reconstruction of pedestrian
facilities and removal of barriers. However,
barrier removal through this method is rare and
not consistent year-to-year.
An assessment of County policies, practices and
design standards, as documented in Chapter 2,
was conducted to understand the process that
results in barriers to accessibility. This
assessment was informed through a review of
adopted County plans, field observations,
discussions with County staff and a detailed
design audit of the County's Public Works
Standards (see Appendix D).
The recommendations included below were
developed in response to this assessment and
have been written in such a way that
recommended actions are clearly identified and
progress on each specific recommendation can
be easily tracked and updated.
Recommendation I:
Identify an official responsible for
Transition Plan implementation within
the Public Works Department
Status: Completed
As part of the transition planning process, an
individual has been identified as the official
responsible (see Section 6.1 for more
information). This position, often referred to as
the "ADA Coordinator", is one of the four
major federal requirements for every ADA
transition plan. The ADA Coordinator is
responsible for facilitating County transition
planning such as responding to grievance
requests. They also function as a central figure
for organizing the various programs and
departments within the County to maintain a
consistent approach to barrier removal and
ADA standards enforcement in multiple aspects
of County operations.
Recommendation 2:
Update County budget to include a line
item for ADA barrier removal
Status: Pending
Prioir to theil'np e.rn :rltation of this i> arl, the
County did not: Irave any bt-id et allocated or-.
renioval of harriers to accessibility within r_heir
Jurisdiction, In carder to fund the. rernoval of
ti <. Farriers identified in t.Iais plan, it is
r ecornr"Iend ed that. the County council
buc,geae tTorerr}uvc, existingtrarr barriers. ,ti pr�.��:>o sal
u
to allocate $250,000 arnr uaiy its being r evi`}wed
t,y cite C:caurary council.
ADA Transition Plan Whatcom County February 2021
Recommendation 3:
Update County design standards to
match ADA Standards
Status: Pending
County practice and design standards must
comply with federal ADA guidance. If standards
are not updated and enforced, new or
reconstructed pedestrian facilities may not be
constructed to current accessibility standards,
requiring costly revision, and increasing the
duration it will take the County to remove
accessibility barriers.
A detailed audit of County design standards
using the 2010 ADAS and Proposed Accessible
Guidelines for Pedestrian Facilities in the Public
Right -of -Way 2005 (PR®WAG) was conducted
to inform Chapter 2. This audit, which is
included in Appendix D, recommends several
specific changes to the County's Development
Standards and Standard Drawings.
Recommendation 4:
Educate County staff, consultants, and
contractors on ADA standards
Status: On -going
Transition plans are often a learning experience
for County staff, consultants, and contractors
alike since they change existing practices and
expectations. The County should use updates
to the County's design standards as an
onnnrtunity to $each and (warn ahotrt
accessibility and the barriers that those with
limited mobility or sight experience when
traveling in the County's public right-of-way.
Education can take many forms from review of
updated design standards with key individuals
such as field inspectors and contractors,
development and review of County specific
design standards or checklists with County
engineers, or training from groups that serve
those with disabilities.
Recommendation 5:
Adopt a Countywide Accessible
Pedestrian Signal (APS) policy
Status: Pending
Accessible Pedestrian Signal (APS) policies serve
as a means for cities to be consistent with ADA
requirements at traffic signals. The APS policy
covers the location and means of
communication for APS devices that
"communicate information about pedestrian
timing in nonvisual formats such as audible
tones, verbal messages, and/or vibrating
surfaces" (MUTCD). Because the City of
Bellingham Public Works staff maintain the
County's signal systems, it is recommended that
the county adopt the City of Bellingham's APS
policy. The City's APS policy is included in
Appendix B.
Recommendation 6:
Provide more accessible options for
community members to participate in
grievance process for barriers to
accessibility
Status: Pending
Public entities subject to Title 11 of the ADA are
required to adopt and publish a grievance
procedure as part of their transition plan. A
grievance process allows community members
to formally report denial of access to a County
facility, program, or activity based on disability.
Currently, The Whatcom County Code section
2.86 discusses the procedure for filing
complaints and grievances pertaining to ADA
wmnrio nra The wanly �� three-$t"� y uses u ep
process, with complaints being addressed first
by the ADA Coordinator, then the ADA
Compliance Committee, and finally, if still not
resolved, to the County Council. While this
approach is consistent with the Title II
requirements, there is an opportunity to make
the process itself more accessible. The
procedure currently requires submitting a
written complaint to the County ADA
coordinator. The County's ADA webpage
should be utilized to provide multiple options
for requesting service and filing grievances
including and accessible on-line form, and
ADA Transition Plan Whatcom County February 2021
phone, email, and in -person options for these
requests.
In addition, it is recommended that the first
step of the grievance process include
notification to the appropriate County
department. Including staff from the appropriate
department will help provide the ADA
Coordinator with the needed expertise to
address the complaint. This will also provide a
valuable feedback loop between the County
staff and the public.
Recommendation 7:
Develop a consistent and centralized
MEF documentation database
Status: Underway
Maximum extent feasible (MEF) is policy that
dictates that alterations that could affect the
usability of a facility in the public right-of-way
must be made in an accessible manner to the
maximum extent feasible. ADA Standards for
Accessible Design (2010) dictates that:
Each facility or part of a facility
altered by, on behalf of or for the
use of a public entity in a manner
that affects or could affect the
usability of the facility or part of
the facility shall, to the maximum
extent feasible, be altered in such
manner that the altered portion of
the facility is readily accessible to
and usable by individuals with
disabilities, if the alteration was
commenced after January 26,
1992.
Whatcom County should adopt a MEF
documentation process and standard template
for the documentation of maximum extent
feasible when addressing new or altered
construction. Each project to remove barriers
should be evaluated to determine if
improvements to the facility in the public right-
of-way are feasible in the engineering design
phase. Some barriers may be infeasible to
remove or may be removable only to a point.
13
Where this is the case the County should
document the reason for the variation from
accessibility standards. This documentation
should be stored in a centralized location and
be linked to the County's GIS ADA self -
assessment database and/or asset management
software to ensure consistency of data.
Consolidation of past MEF records into this
data is also recommended. A template example
has been provided in Appendix C.
Recommendation 8:
Develop performance measures and
processes to track removal of barriers
Status: Pending
The primary purpose of an ADA transition plan
is to develop a plan for removal of accessibility
barriers. In order to show progress towards
this requirement, the County should develop a
process of tracking barrier removal on a year by
year basis. It is recommended that the County
actively update the GIS ADA self -assessment
database developed for this plan, tracking how
and when ADA barriers are removed. This data
can be used to provide annual updates on
progress and demonstrate to the public as well
as federal regulators that the County is making
progress to meet Title II requirements.
Recommendation 9:
Whatcom Chief Ferry replacement and
dock improvements.
Status: Underway
The County should continue to pursue funding
to replace the existing boat with a new, more
accessible ferry.
The County should also create a plan to
remove the accessibility barriers at both dock
locations. Improvements to be considered
should include;
- Additional signing to direct pedestrians
to the pedestrian staging area
ADA Transition Plan Whatcom County February 2021
Designated and accessible pedestrian
access route between acessibile parking,
pedestrian staging area, restrooms, and
passenger area on ferry
Lighting for the pedestrian access
routes and staging areas
14
ADA Transition Plan Whatcom County February 2021
5 Implementation
Development of an implementation plan
and transition schedule included three steps
once the Countywide barrier assessment
was complete. First, all facilities with an
identified barrier were prioritized. Next, a
planning level cost estimate was developed
to provide an estimate of the financial
resources needed to remove all barriers.
Finally, a schedule was developed based on
a $250,000 annual budget for barrier
removal. This schedule will help inform
recommendations for additional funding for
barrier removal, see section 5.3.3 for
schedule details.
not meet existing sidewalks and curb ramp
standards. Each attribute collected in the
field was compared against 2010 ADAS and
PROWAG requirements as outlined in
Chapter 2.
If the facility does not meet ADA
requirements or best practices, or is
located near public destinations, points
were assigned, with the number of points
dependent on the relative importance or
proximity. Sidewalks or curb ramps with
poor compliance and several proximate
destinations received a high score and are
prioritized for removal while facilities
farther from public destinations have lower
scores, and compliant features receive a
score of zero.
To focus the County's efforts toward
Several criteria were used to establish the
facilities that pose the largest barrier within
extent to which each pedestrian facility did
the public right-of-way, an analysis of the
or did not present a barrier to accessible
accessibility of each pedestrian facility and
mobility. Tables 5-1 and 5-7 shows these
its location was completed. The result of
criteria, the threshold used to identify them
this analysis is a prioritized list of projects,
as a barrier, and the score used to indicate
with the highest benefit projects identified
the severity of each barrier relative to each
for removal first.
other. Facilities with a higher Accessibility
To complete this assessment for the public
Index Score (AIS) represent a large
accessibility barrier.
right-of-way, a multi -criteria analysis was
conducted to determine which facilities do
110
Table 5-I Sidewalk, Accessibility Index Score Volue
SIDEWALK
ACCESSIBILITY
INDEX SCORE
CRITERIA
T"HIRESHOLD SCORE
Width
< 60 inches or < 48 inches with 4
no sidewalk pull-outs
Cross Slope Issue
> 2% 1
Cross Slope Issue
> 2.4% 1
Cross Slope Issue
> 3% 2
Condition
< Average 3
Vertical Discontinuity Issue
> ''A inch and <_ '/z inch without
bevel or > /2 inch
Barriers Present >= I I
_
Vertical Discontinuity Issue
Barriers Present > 5 1
Vertical Discontinuity Issue
Barriers Present —10 1
Horizontal Discontinuity Issue
Barriers Present >= I I
1/2 inch
Horizontal Discontinuity Issue
Barriers Present > 5 I
Horizontal Discontinuity Issue
Barriers Present —10 I
Fixed Obstacles
Barriers Present >= I I
at ., w 1Iks
Fixed Obstacles
Barriers Present>=2
Fixed Obstacles
Barriers Present > 3 I
Moveable Obstacles
Barriers Present -I I
Moveable Obstacles
s,
Barriers Present>=2
Moveable Obstacles
Barriers Present>=3
Protruding Obstacles
Barriers Present -I
j�
Protruding Obstacles
Barriers Present > 2 1
i I Vlf UU11 lb' VUJLdIAI.ICJ
Barrier Present >—.J 1
Non -Compliant Driveways
Non -Compliant >2% cross -slope,
fl and/or
Barriers Present >= I I
Non -Concurrent Grade Break and/or
>8.3% Running Slope
Non -Compliant Driveways Barriers Present >=2 1
'1 Non -Compliant Driveways Barriers Present >=3 1
1 Maximum Sidewalk (AIS) Score 30
n
lip
Table 5-2 Curb Romp Accessibility Index Score Value
CURBRAMP
ACCESSIBILITY POSSIBLE
INDEX SCORE RATING CRITERIA SCORE
Ramp Width (Max
Score)
Ramp Running
Slope (Max. Score)
Ramp Cross Slope
(Max. Score)
Ramp Type (Max.
Score)
Accessible Path
Turning Space
Turning Space Turnin
Slope
Flare Slope
Receiving Ramp
Truncated Domes
(DWS)
Truncated Domes
(DWS Placement)
Truncated Domes
(DWS Depth)
Truncated Domes
(DWS Width)
Grade Break
Counter Slope
Lip
End in Crosswalk
Roadway Clear Space
TOTAL CURB RA
* 48inches
30
* 8.3% (< 15 feet), or >S% (Blended)
30
* 2%
30
Non -Compliant Type
30
No
2
None or width < full width of rarnp or length < 48 inches
5
> 2%
3
> 10%
No
2
2
No
3
Other than Back of Curb
< 2 feet
I
I
Less than Full Width of Curb Rarnp
I
Not Concurrent
2
> 5%
2
> 1/4 inch
2
No
2
< 4ft x 4ft
2
MPS ACCESSIBILITY SCORE (AIS)
30
17
Table 5-3 Signal Push Buttons Accessibility Index Score Value
SIGNAL. PUS11-1
BUTTONS
ACCESSIBILITY POSSIBLE
Curb Distance
Crosswalk Extensic
Distance
Force Less Than 51
Vibe Feedback
Button Size and Vis
Contrast
Distance of 2 Butt(
on Same Corner
Reach Depth from
Landing
Mounting Height
Tactile Arrow
Directional Arrow
Level Clear Space
Both Audible Tone
during "Walk" Cyc
and Audible Speech
d firing "Wall<" C'y
Locator Tone durir
"Don't Walk" Cycl
Braille Street Nam(
APS Style Housing
Pushbutton less than 10 feet from curb = No
2
)n
Pushbutton less than 5 feet from the extension of the crosswalk line
= No
2
)s
Pushbutton Force less than 5 pounds = No
2
Pushbutton provide vibratory feedback when pushed = No
2
ual
Pushbutton size meets minimum 2-inch diameter with visual contrast
frorn housing = No
`
Distance between pushbuttons on the same corner less than 10 feet
ns
and audible indication of WALK interval in speech = No, or distance
greater than 10 feet and indication of WALK interval in both speech
2
or tone = No
Reach depth from pushbutton to the landing is less than 10 inches =
No
2
Mounting height of pushbutton from landing area is < 42 inches or >
48 inches
2
Tactile Arrow provided = No
2
Directional arrow on pushbutton face, housing or mounting &
pushbutton with parallel orientation to crosswalk direction = No
2
Level clear space provided at pushbutton (min. 30" x 48") landing
area provided with less than a 2% cross slope in any direction = No
2
e
Audible indication of WALK interval in tone = No and Audible
indication of WALK interval in speech = No
2
g
Locator tone operates during DON'T WALK and flashing DON'T
WALK intervals = No
2
Braille correctly showing street name = No and audible indication of
street name at any time = No
2
Housing is APS Style = No
2
PUSH BUTTONS ACCESSIBILITY SCORE (AIS)
30
Toble 5-4 Parking Stall Accessibility Index Score Volue
PARKING
STALL
ACCESSIBILITY POSSIBLE
INDEX SCORE RATING CRITEMA SCORE
Stall Width
Stall Turning Slope
Stall Pavement Markii
Sign Present
Sign Height
Wheel stop or Curb
Present
Vertical Clearance
Adjacent Walkway
Width
Connected to
Access Aisle (Max,
Score)
Connected to
Accessible Path
Access Aisle Width
Access Aisle Turning
Slope
Pavement Marking
TOTAL PARKINC
If regular stall, < 96 inches. If van accessible stall, < 132 inches and
adjacent aisle is < 96 inches.
4
> 2%
4
ig
No Marking
3
No Sign
2
< 60 inches
I
No Wheel stop/Curb (and not a parallel stall)
2
< 98 inches and a van accessible parking stall
2
For parallel on -street parking with a sidewalk <= 14 feet wide
nearby, stall is not at end of block. If sidewalk is > 14 feet wide, no
access aisle provided in road parallel to stall or access aisle is < 5
feet wide.
2
No ,Access Aisle
10
Not Connected
2
< 60 inches
3
> 2%
No Hatching
3
2
STALLS ACCESSIBILITY SCORE (AIS)
30
Table .5-5 Railroad Crossing Accessibility Index Score Value
RAILROAD
CROSSING
ACCESSIBILITY POSSIBLE
INDEX SCORE RATING CRITERIA SCORE
Flange Gap > 3 inches wide 10
DWS No DWS 10
DWS Placement < 6 feet or > 15 feet from edge of nearest rail, or No DWS 10
TOTAL RAILROAD CROSSING ACCESSIBILITY SCORE (AIS) 30
Table 5-6 Crosswolk Accessibility Index Score Value
CROS' WAU(
ACCESSIBILITY
INDEX SCORE
Width I < 6 feet
RATING CRI-f'ERIA
Run Slope > 5%
Cross Slope > 2% at Stop/Yield Controlled Intersections or > 5% at other types
of crossings
TOTAL CROSSWALK ACCESSIBILITY SCORE (AIS)
POSSIBLE
SCORE
6
12
12
Ift
M
Table 5-7 Bus Stop Accessibility Index Score Value
MiS STOP
ACCESSIBILITY POSSIBLE
INDEX SCORE RATING CRITERIA SCORE
Boarding Area
Dimensions
Condition
Boarding Area Cross
Slope
Boarding Area Run
Slope
Accessible Route Slope
Shelter Cross Slope
< 5'x8' or no boarding area
8
Poor
5
> 2%
5
> 5% and not similar to roadway grade
4
> 5% and not similar to roadway grade (if separation between
boarding area and shelter)
4
> 2% (If there is a shelter)
4
ACCESSIBILITY SORE (AIS)
30
A number of popular community destinations - such as schools, transit and parks - are used to identify
high priority pedestrian facilities within the County. This is done by determining which pedestrian
facilities fall within a specified proximity of one or more of these destinations.
Pedestrian facilities within the identified proximity are assigned points based on each destination they
are close to, as shown in Table 5-8. This measure is called the Location Index Score (LIS), which
identifies high pedestrian generating overlapping areas. Ultimately the more pedestrian generators, the
higher the score.
Community Defined Destinations identified during the public outreach process consisted of general land
uses as well as specific locations that participants identified as issues. Specific locations included facilities
like sidewalks, curb ramps, crosswalks and signals that individuals had identified as barriers.
21
ADA Transition Plan Whatcom County February 2021
Table 5-8 Location Index Score Volue
LOCATION CRITERIA
Proximity to Schools
Walk -To -School Route Proximity
P arIi s
Park and Ride
Bus Stops
P SMBLE
RATING CRITERIA SCORE
Within %a -mile radius of school 5
Within '/z-mile radius of school 5
Within '/8-mile radius of park
5
Within %a -mile of park and ride 5
Within %-mile of transit stop „ 5
Within Ma -mile of signal or roundabout 1 5
F}rbaic Buddirqs i Within'/a-mile of location 5
1)u) vv i�f;at Yi f Ur a i i % Within V,-mile radius of Downtown, Urban 5
r.,,ta,rs j and Commercial Business Center Zoning
r tr.,rnaz.inity Dcfry n:a �'`i3•«3 '' 4' Within''/a-mile of location 5
�'clefinedby Stakeholder/Public En a ement')
TOTAL LOCATION INDEX SCORE (LIS) 45
Note: Community Defined Destinations to be identified based on public outreach, ADA surveys, etc. on what locations are more
important, thus giving extra weight to those community defined destinations. (To be determined)
By combining the Accessibility Index Score and
Location Index Score or Facility Use Index
Score together, a Composite Index Score was
developed. Together, these measures prioritize
barrier removal at locations where pedestrian
facilities present a barrier and where
pedestrians would be expected.
Facilities with the highest score should be
addressed first (46+ points) and represent
facilities that present a clear physical barrier and
are in high demand areas. The next levels of
priority are `high' (31-45 points) and `medium'
(16-30 points). Facilities with the lowest scores
should be address last (I to 15 points), have
minor irivi vai i Ici �, an iu are in locations is where
pedestrian demand would be expected to be
lower. These scores are relative, comparing one
facility to the other. The ranges for medium and
high priority were defined based on review of
the identified barriers and assessment of the
relative barrier they present. It should be noted
that while some barriers have a lower priority,
they still should be removed.
22
ADA Transition Plan Whatcom County February 2021
A key requirement of an ADA Transition Plan is
development of a schedule which shows how
long it will take the County to remove
accessibility barriers. Understanding the financial
resources needed to remove accessibility
barriers is essential for developing such a
schedule.
Cost estimates for each barrier were developed
to assist in determining a schedule for the
completion of the barrier removal process as a
tool to help the County plan funding for the full
removal of barriers over the coming years.
Unit costs were developed to address ADA
barriers described in Chapter 2. The unit costs
were developed using recent bid tabulations,
input from County staff, and planning level
assumptions concerning each ADA barrier type.
ADA deficiencies were totaled using their
respective unit of measurement: for example,
square yards for sidewalks, and number of
facilities for curb ramps.
To avoid overestimation of non -compliant
facilities, assumptions were made when
necessary to address the repeatability of the
unit cost and the quantities for each item. For
example, a sidewalk segment with a non-
compliant cross -slope that will require full
replacement will not also require vertical
discontinuity repair.
A final cost estimate was determined using
information from the data inventory and
calculated using current year construction
costs.
A planning level cost estimate to remove all
identified barriers was developed based on the
process described above. This overall cost
includes construction, design, mobilization, and
other construction related contingencies, but
does not include County staffing needed for
project management. Table 5-9 shows a
summary of each activity associated with barrier
removal and the applicable cost of removing the
specified amount of deficiencies.
W
ADA Transition Plan Whatcorn County February 2021
Table 5-9— Planning Level Cost Estimate Within the Public Right-of-way
1OTAL
T0'TA7"
ADA DEFICIENCY
1MPF1,0VEME:,,1T'TYPE5
QUANTITY
PRqCE
Non -Compliant Sidewalk
Reconstruct existing sidewalk or paved
135,807 SY
$19,692,029
shoulder walkway
Non -Compliant Driveway
New driveway with sidewalk
995
$2,885,500
Subtotal
$22,578,000
Non -Compliant Horizontal Discontinuity
Sidewalk crack sealing/grouting (10 LF of
120 LF
$600
sidewalk per horizontal discontinuity)
Fixed Obstacles
Relocation of obstacles including utility pole,
18
$54,000
mailbox, tree trunk, etc.
Relocation of obstacles including tree/bush
129
Moveable Obstacles
(pri-inable), message boards, parked cars,
$25,800
etc.
Protruding Obstacles
Relocation of obstacles including of
216
$108,000
bush/tree, signs, awnings etc.
Subtotal
$189,000
Curb, V'Larnqps
Missing Curb Ramps
New curb ramp
368
$2,208,000
Non -compliant ramp (running slope, cross slope, ramp
width, flare slope, lip, grade break, etc.)
Reconstruct existing ramp
674
$4,044,000
Curb Ramps without Detectable Warning Surface
(DWS) or DWS is Non -Compliant
Install/replace detectable warning surface
19
$19,600
Curb ramp at marked crosswalk does not end within
crosswalk.
Rechannelize crosswalk.
3
$3,300
Subtotal
$6,275.000
Non-APS Pushbutton and Pushbutton are Located
Incorrectly
Install new pole and pushbutton
15
$75,000
Pushbutton is non-APS but is located within Sft
crosswalk extension, I Oft from curb, compliant reach
Install new pushbutton
9
$18,000
depth, and adjacent to compliant clear space.
Subtotal
$93,000
Bus, Stops
Non -compliant bus shelter Replace Bus Shelter Pad (7.5SY per
turning space cross slope occurrence)
100 SY
$18,000
Subtotal $/8,000
Flarking
Non -compliant parking stall/parking aisle slope.
Grind surface and/or add asphalt lift,
2 EA
$4,000
.. . .... . ...... ...... ...
Subtotal
$4,000
Total
$29,157,000
Contingency @ 20%
$5,832,000
Design @ 12%
$3,499,000
Mobilization @ 8%
$2,333,000
TESC +
Traffic Control @ 12%
$3,499,000
_Construction
Management @ 20%
$5,832,000
Public Right -of -Way: TOTAL 2020 DOLLARS
$50,160,000
M
ADA Transition Plan Whatcom County February 2021
Based upon the self -evaluation, planning -level cost estimates, and existing funding programs, a
schedule for barrier removal was developed. Table 5-10 below shows barriers at each priority level as
a percentage and the total cost to remove those barriers. Highest priority barriers represent a
significant barrier to accessibility in areas with high demand for accessibility. The majority of barriers in
the high and very high priority categories are curb ramps and pedestrian pushbuttons located in high
priority locations. Lower priority barriers represent lesser barriers to accessibility in areas with lower
pedestrian demand. The barriers in the low and medium priority categories are primarily lesser barriers
to accessibility such as moveable obstacles, horizontal discontinuities and protruding obstacles. It should
be noted that while some barriers have a lower priority, they still should be removed.
Table 5-10 Public Right -of Way Barrier Removal Priontizotioi) ood Cost
Percentage 32%
45%
21%
2%
$16,133,000
$22,679,000
$10,286,000
$1,062,000
Total Cost
A plan should be developed to target removal of the highest priority barriers. The `very high' priorities
consist of 2% of the existing barriers and are estimated to cost a total of $1,062,000 to remove. By
removing the highest priority barriers first, the County is working to provide the best access to the
most needed programs, in the shortest timeframe possible. After the highest priority barriers are
removed the County should continue to remove the high priority, medium priority, and low priority
barriers. The County should create a 5-year barrier removal program with a list of projects to remove
specific barriers. The 5-year program should focus on the highest priority barriers. The purpose of the
5-year program is to make progress in barrier removal but also to provide a way to reassess the larger
plan and measure incremental progress. At the end of the 5-year program the County should reevaluate
their progress with barrier removal and the annual budget.. If progress is slower than anticipated
additional funding may be required. If progress is faster than anticipated a shorter timeline may be
achievable.
The County has proposed an annual budget of $250,000, distributed between Maintenance and
Operations ($50,000), capital improvements for barrier removal ($150,000) and project selection/design
($50,000). With the approved budget of $250,000 per year, it is anticipated that the removal of the
highest priority barriers will be completed within the first 5-year program.
25
ADA Transition Plan Whatcom County February 2021
6 Current Practices
This chapter documents key pieces of information which are critical for ongoing plan implementation.
This information is likely to change over the lifetime of the plan such as the official responsible for plan
oversight or progress report on barrier removal. This section is meant to act as a "living document"
which should be updated to represent current practices or information.
This section is updated as of: February 2020
• Official Responsible — Human Resources Manager, ADA Coordinator
® Mailing Address — 311 Grand Avenue, Bellingham, WA 98225
® Phone Number — 360-778-5300
® Email — hr@co.whatcom.wa.us
® $250,000 annual funding distributed between Maintenance and Operations ($50,000), capital
improvements for barrier removal ($150,000) and project selection/design ($50,000)
® To be Completed
to By adopting this transition plan the APS policy shown in Appendix B is adopted.
See Whatcom County Code section 2.86 and his://www.whatcomcounty.us/259/Americans-
With-Disabilities-Act-Complian
® See Appendix C
M
ADA Transition Plan Whatcom County February 2021
The plan is currently less than a year old, so it represents the most recent available data.
WA
Appendix A - Barrier Audit
Date: February 11, 2021 TG: 1.19049.00
To: David Hower, Whatcom County
From: Ryan Peterson PE, PTOE — Transpo Group
cc: James Karcher PE, Douglas Ranney PE — Whatcom County
Subject: Whatcom County ADA Accessibility Standards Review
Practices and design standards that meet accessibility standards are essential to ensure new or
upgraded pedestrian facilities are accessible and that these upgrades contribute to the removal of
accessibility barriers throughout the County.
The following Whatcom County documents were reviewed against current accessibility standards:
• Whatcom County Development Standards and Standard Drawings, October 14, 2019
• Whatcom County Code
In conversation with County staff, an approach to the standards review was developed that
included a focus on referencing other accessibility standards, rather than providing substantial
detail within Whatcom County standards. This was done for several reasons including the lack of
County resources to research changes to accessibility standards and update County standards on
a regular basis. The review of County standards relies heavily on WSDOT standards, particularly
Chapter 1510 of the WSDOT Design Manual. Where applicable, recommendations have been
made to reference this standard in leu of providing substantial detail that would be redundant with
the WSDOT Design Manual.
This memo summarizes a review of Whatcom County's policies and design standards for barriers
and includes major findings of this work. The memorandum is organized by facility type.
Sidewalks and Pathways
Whatcom County Code mentions sidewalks in various sections and provides guidance on design
relative to the different land use zones within the County. These references are not accessibility
related. Where specific design requirements are called out, they do not violate current accessibility
standards. No modifications to the County Code related to sidewalks are recommended.
Most of the design guidance for sidewalks in Whatcom County is contained in Section 508,
Roadside Features, of Whatcom County Development Standards and corresponding Standard
Plans. Sections 508.A and 508.E address sidewalks and pathways and the following modifications
are recommended:
Section 508.A, Urban Pedestrian Facilities
• Section 508.A.4 — Change the wording of this section to "Pedestrian Access Routes
(PARs) as defined by Chapter 1510 of the WSDOT Design Manual shall be provided on
one side of new and existing perimeter public roads adjoining any development which
creates, in the professional judgement of the County Engineer, the potential for significant
additional pedestrian movement and the roadway traffic has an ADT of over 400 vehicles.
This PAR shall have a firm, stable, and slip -resistant surface and may be incorporated into
the shoulder of the roadway. The PAR shall meet all applicable accessibility requirements
as shown in the WSDOT Design Manual Chapter 1510."
• Section 508.A.5 — Change the wording of this paragraph to read "Sidewalks shall be
constructed with Class 3000 cement concrete per WSDOT Standard Specifications and be
constructed per WSDOT Design Manual Sections 1510.05 — 1510.08 and corresponding
WSDOT standard plans. Construction tolerances should be accounted for during design to
insure the final constructed sidewalk meets all accessibility requirements. Sidewalks shall
be light brush finished and curing compound shall be applied to all finished concrete
12131 113th Avenue NF, Suite 2.03, Kirkland, WA 98034 1 425.821.3665 I transp a, , _ .t;0rn
surfaces per WSDOT Standard Specifications. Subgrade compaction shall meet the
requirements outlined in Section 511.E, Concrete Testing. Sidewalks in cut sections shall
be drained as shown on Standard Drawing 508.A-2."
Delete Sections 508.A.6, 508.A.7 in their entirety.
Standard Drawing 508.A-1 — Most of the information in this County standard drawing is
redundant with WSDOT Standard Plan F-30.10. It is recommended that this standard plan
be deleted and information specific to Whatcom County be incorporated into Section
508.A.5 as described above.
Section 508.13, Rural Pedestrian Facilities
• Section 508.13.1 - Change reference to walkways to "Pedestrian Access Routes (PARs) as
defined by Chapter 1510 of the WSDOT Design Manual". Change all subsequent
references to walkways in Section 508.E to "PAR"
• Section 508.13.3 — Change wording to read "Minimum PAR improvements shall consist of
a firm, stable, and slip resistant material. Material other than cement concrete and asphalt
pavement must be approved by the County Engineer. When the PAR is incorporated into
the road shoulder, the typical roadway section shall govern. PAR may be combined with
bikeway."
• Delete Section 508.13.4 in its entirety.
Driveway Approaches
Whatcom County Code contains several requirements for driveways in various sections. These
requirements are general in nature and generally identify where and when driveways are to be
installed. No specific information to accessibility is referenced in the County Code and no
modifications are recommended.
Section 508.D of Whatcom County Development Standards and associated Standard Plans
address driveway approaches. The following modifications are recommended:
• Add the following sentence to the end of Section 508.D.3.a: "When a Pedestrian Access
Route or sidewalk is present on the arterial/collector street, a Pedestrian Access Route
meeting accessibility criteria as defined in WSDOT Design Manual Chapter 1510 shall be
provided through the driveway."
Curb Ramps
References to curb ramps in the County Code are again, general in nature and do not specifically
address accessibility. No modifications are recommended.
Section 508.13 of Whatcom County Development Standards and associated standard plans
address curb ramp requirements. The following modifications are recommended:
• Section 508.G — Change wording to read "Curb ramps shall be installed at all legal
pedestrian crossings including intersections and mid -block pedestrian crossings where a
Pedestrian Access Route as defined in WSDOT Design Manual Chapter 1510 is provided
on both sides of the street and where a transition from sidewalk to pavement grade is
required. At -grade pedestrian facilities shall not require a curb ramp. Curb ramps shall be
constructed per the WSDOT Design Manual, Chapter 1510.09 and associated WSDOT
Standard Plans."
• Standard Drawings 508.13-1 through 508.G-5—These standard drawings are redundant
with WSDOT Standard Plans F-40.12, F-40.14, F-40.15, F-40.16, and F-45.10. It is
recommended that these standard plans be deleted.
Pedestrian Signals
Pedestrian signals are not addressed in either Whatcom County Code or Development Standards.
It is recommended that the following modification be made:
Add sub -section of Section 508A titled Pedestrian Signals that states: "All traffic signals
within Whatcom County, including pedestrian signals and beacons, shall be built in
accordance with City of Bellingham standards. All new traffic signals shall be constructed
in accordance with City of Bellingham design standards and standard plans. All new
pedestrian signal elements, where applicable, shall be accessible, including countdown
pedestrian signal heads and Accessible Pedestrian System (APS) pushbuttons. For
retrofits, the City of Bellingham's APS Policy shall be followed to determine the scope for
accessibility upgrades to the signal system."
Other Pedestrian Facilities
Other facilities of the pedestrian network like handrails, access ramps, and transit stops are not
mentioned in any detail within Whatcom County Code and Development Standards. The following
is a recommended modification to address this omission:
• Add sub -section of Section 508A titled Other Pedestrian Facilities that states "All other
pedestrian facilities including handrails, transit stops, access ramps, etc. shall be
constructed per WSDOT Design Manual Section 1510.15."
Appendix B - APS Policy
0 6ELL/4�
cy
v 3
GGgSHINGoo
MEMORANDUM
City of Bellingham
Public Works Department
104 W. Magnolia Street
Bellingham, WA 98225
TO: BRENT BALDWIN, PAUL REED, FREEMAN ANTHONY, JESSICA BENNETT, STEVE DAY,
CRAIG MUELLER, LARRY SCHOLTEN, SAM SHIPP
FROM: KIM BROWN
CC: CHAD SCHULHAUSER, ERIC JOHNSTON, MIKE OLINGER
SUBJECT: ACCESSIBLE PEDESTRIAN SIGNALS AND PUSHBUTTONS (APS) INSTALLATION
DATE: 30 OCTOBER 2018
Intent:
Title 11 of the Americans with Disabilities Act (ADA) requires state and local governments to
provide "effective communication" for those using or accessing public programs, services, and
activities. For pedestrians living with visual and/or hearing impairments, audible and vibrotactile
communication may be provided by means of Accessible Pedestrian Signals and Pushbuttons
(APS) at signalized intersections. These signals can provide information in an "effective" or
accessible format to assist in making signalized street crossings easier to use for all pedestrians.
Purpose:
The purpose of this policy is to establish reasonable and consistent policy for installing APS.
Policy:
The City of Bellingham will install APS under the following conditions:
• New construction: All new construction of traffic signal projects, including HAWKS and
enhanced crosswalks, requires installation of APS when pedestrian signals are installed.
• Alteration: Existing pedestrian signals shall be upgraded to APS when the signal
controller and software are altered or any individual signal or pedestrian head is
replaced.
• Citizen requests: Individuals living with disabilities or those who directly care for
individuals living with disabilities can request installation of APS at signalized
intersections, including HAWKS and enhanced crosswalks. Requests will be logged and
considered for improvement outside of a new construction or alteration project.
• In addition to the above conditions, signalized intersections will be retrofitted with APS
according to the City's ADA Transition Plan prioritization process.
Technical Requirements:
APS shall be installed in compliance with technical requirements specified in Section 4E.08
through 4E.13 of the 2009 Manual on Uniform Traffic Control Devices (MUTCD) and Section
R403 of the Proposed Guidelines for Pedestrians Facilities in the Public Right of Way (PROWAG
DRAFT 2011).
Appendix C - Maximum Extent Feasible
Project Description:
Barrier Type for MEF Evaluation
❑ New Construction Project - with proposed accessible route features requiring MEF evaluation
❑ Reconstruction Project — with existing accessible route barriers for MEF evaluation
❑ Isolated Accessible Route Barrier identified by Maintenance & Operations or public
Roadway/Accessible Route Parameters
• Roadway Classification:
• Design Speed/Posted Speed:
• Design Year ADT:
• Truck Percentage:
• Pedestrian related crash history:
• Within Urban Growth Area?:
• Facilities verified to be within right of way?:
• CRP #:
Existing Pedestrian Facilities — general description (include a summary of the proposed pedestrian
features throughout project, i.e. types of facilities, connections to existing facilities, etc.)
Pedestrian Design Standards — cover the following subjects
• Discuss the criteria that apply to the pedestrian elements on the project that will be built to the
Maximum Extent Feasible
• Include reference(s) to the appropriate PROWAG/ADA section(s) and Whatcom County Public
Works Standards [including revision date]
Alternative(s) analysis — were there alternatives considered and why were they not selected? needed for
new construction projects only
Proposal — cover the following subjects
• What features will remain that meet guidelines (Only applicable to features associated with
barriers that are being evaluated for feasibility of removal, or justification being provided per the
MEF process. For example, if an intersection has four corners and only one is altered to the MEF,
only include information about that one corner)
• What features are being built to guidelines
• What is being built to the maximum extent feasible
Justification
• Discussion of what constraints/challenges there are to meet full design level
Additional Benefits — examples include improving pedestrian connections, improved safety, better
traffic operations, etc.
Attachments Included:
Vic Map
Plan Sheet(s), description:
Feasibility /Justification Cost Estimate
Other:
Appendix D - Public Involvement
WHATCOM COUNTY
ADA TRANSITION PLAN
PUBLIC IN VOL VEMENT AND FEEDBACK
.......... __ _ . __ _ ............... __ _........... __ __ _ _.............. _ .................
PREPARED FOR: Jim Karcher and Dave Hower, Whatcom County
PREPARED BY: Jeanne Acutanza, Acutanza STS
CC: Ryan Peterson, Transpo Group
DATE: December 2, 2019 FINAL
Introduction
In developing an ADA (Americans with Disabilities Act) Transition Plan for Whatcom County, a key initial
step is outreach to people with disabilities or those who support people with disabilities. The goal of this
outreach is to gain feedback on current pedestrian facilities within the public right-of-way in Whatcom
County, specifically those not in the incorporated areas of Cities like Bellingham, that provide access to
community and government services. This draft memo outlines the community outreach process used
to support development of the ADA Transition Plan and feedback we have received to date.
This memo summarizes outreach efforts through a public meeting, survey, and more in-depth focus
groups.
Promotion and advertising for outreach
Outreach to solicit participants and encourage input at the open house, online open house, and survey
included outreach to local community service providers and advocacy groups. Specific outreach to
organizations Seiviiig anu duVUCa`ling fOf I(IQIVIQUaIS with dlSablllil2S InClUded:
• Whatcom County Main Web Page
• Whatcom County Public Works Page
• KGMI Radio
• Attendees and speakers at Whatcom County Hearing on June 18, 2019
An invitation to participate in a more in-depth focus group was solicited at the open house, through the
online survey, and personal outreach. This focus group reviewed this summary and provided comments.
Part of the focus group feedback was to seek input on ADA issues at bus stops from the school districts.
This summary includes feedback from the transportation services of the Blaine, Lynden and Bellingham
School Districts.
WHATCOM COUNTY ADA TRANSITION PLAN
OUTREACH SUMMARY
How were members of the public involved?
To garner feedback from the community, Whatcom County hosted an in -person Open House on July 30,
an online survey that was available to the public from July 30 through August 31, and two focus group
meetings for interested community members held on October 1 and 3.
Feedback for each element of outreach resulted in the identification of general and specific issues.
Community members were also asked about priorities and which issues and areas are most important to
them.
Public Meeting July 30, 2019
A community public meeting was held on July 30 at St. Luke's Community and Education Center from
5:30 p.m. to 7:30 p.m. The room is accessible using elevators and the library is centrally located in
Bellingham with good transit service. Sign language interpreters were on hand and staff engaged
members of the community to provide feedback on maps and boards. Outreach boards were provided
to help educate the public on ADA at the meeting. Images of the open house boards are provided in
Attachment A. While the meeting was broadly advertised, less than 10 people attended the public
meeting with very limited feedback. It should be noted that the City of Bellingham, located within
Whatcom County is also updating their ADA Transition Plan with their outreach activities, including an
open house, occurring roughly one month ahead of this meeting.
On -Line Survey June 30 through August 30, 2019
A 19-question survey was open from the time of the open house meeting on July 30 through August 30,
2019.
The survey was accessed 93 times and asks respondents how they travel, where they live, why they
travel in Bellingham, whether they had a disability or support someone with a disability, and whether an
accessibility issue ever prevented them from being able to participate or obtain services in Bellingham.
Questions regarding demographics were optional. The survey did not specifically ask where respondents
live but did request a ZIP code for each respondent. Of those responding to the survey, roughly one
third were located largely within the City of Bellingham ZIP codes, one third were located in ZIP codes
shared by the City and County unincorporated areas and one third were in the County and outside of
Bellingham
The survey also asked for specific feedback on the types of pedestrian facility barriers people
experience, the types of public services where access is most important for them, and specific locations
where there are barriers or other accessibility issues.
It was also possible to discern differences between the priorities of those with disabilities, those that
support people with disabilities, and those who do not have disabilities. Specifically, the top -line survey
summary suggests that those with disabilities or supporting someone with a disability clearly experience
more barriers in pedestrian facilities than those without disabilities. Those with disabilities and
supporting those with disabilities noted priority locations as hospitals and city parks, while those
without disabilities prioritized community services and hospitals slightly higher. Access to city parks was
WHATCOM COUNTY ADA TRANSITION PLAN
OUTREACH SUMMARY
notably a higher priority for those with disabilities as compared to those without disabilities or those
supporting people with disabilities.
The survey questions are provided in Attachment B. Top -line summaries breaking down respondent
types, demographics, and transportation patterns are provided in Attachment C.
Respondents reported issues at 100 locations including sidewalks, curb ramps, crosswalks at signals,
ADA parking and with access to transit. Attachment D provides a list of issues collected through the
surveys.
Focus Group Meetings October 1 and 3, 2019
t
Two focus group meetings each 90 minutes long were held on October 1 and 3 in different areas of the
County. The focus group meetings were offered to interested members of the community to review the
initial comments received to date through the open house and survey as well as provide deeper
feedback on aspects of accessibility in the County including specific locations, types of issues, and
priorities.
»st
The first meeting was held at the Whatcom County Civic Annex, 332 N. Commercial Street on Tuesday,
October 1 - 3:30 — 5 p.m. This location is located within the City of Bellingham, near transit services and
the building is accessible. In addition to a sign language interpreter, five members of the public
participated. The group included people with disabilities, people that support others with disabilities or
work on infrastructure projects.
The second meeting was held in unincorporated Whatcom County at the Whatcom County Planning and
Public Works offices at 901 W. Smith Road on Thursday, October 3 - 3:30 — 5 p.m. This location is an older
building but is accessible and transit is provided nearby. In addition to a sign language interpreters and
representative from Whatcom Transit (Janet Malley), five members of the public participated. The group
included people with disabilities, and people that support those with disabilities.
Different locations were offered to provide opportunities for broader outreach and in different areas of
the County. Whatcom County staff (Jim Karcher and David Hower), as well as members of the consultant
team (Ryan Peterson and Jeanne Acutanza) also attended.
The focus group was facilitated by County and consultant staff. A draft focus group guide is included in
Appendix E. Comments and discussion were recorded for all participants.
The focus group agenda is described below:
• Welcome and acknowledge participants and provide brief purpose of meeting
• Review Ground Rules
• Self -Introductions
WHATCOM COUNTY ADA TRANSITION PLAN
OUTREACH SUMMARY
• Discussion of the survey results and review of materials
• Workshop and in-depth discussion
This ADA transition plan is heavily reliant on public perspectives and feedback, particularly by those with
disabilities or supporting those with disabilities. This plan will be focused on identifying barriers in
pedestrian facilities in the public right-of-way and prioritizing, scheduling and identifying funding for the
removal of those barriers.
After the review of survey top -line results, the group discussed issues and comments. These comments
are transcribed from the recording and were summarized and categorized below in four areas:
1. Comments and issues on specific topics
2. Comments and issues at specific locations
3. Comments and issues that may not be addressed by the plan and
4. Priorities
General Comments and issues on specific topics
Some comments were raised related to specific issues. Where they overlapped, they were combined into
the topics below:
Additional outreach — Additional outreach at schools or with bus drivers was suggested to gain
specific feedback about students with disabilities and at facilities that serve those with
disabilities, specifically Spinal Cord Injury support groups.
Less Walking, Limited Sidewalks, and More Driving in the County — Because of the rural nature
of most of the County, a more significant portion of travel is done through driving and parking. In
some urbanizing or growth areas, sidewalks and crosswalks are not available but should be
considered. Speeds in rural, even urbanizing areas are a challenge for pedestrians, especially for
crossing roadways. The County maintains few traffic signals, and signal -controlled crosswalks are
infrequent. Because driving is an important mode of travel, the number of ADA parking spaces
and the design are essential for providing access to community services and government
buildings.
Schools — Walking to schools in the unincorporated counties can be challenging and not safe,
where there are few sidewalks, and crosswalks. Because there are limited sidewalks, curb ramps
are not a challenge. While a safe route to school programs should be part of all school plans,
many schools may not have them because walking to school is considered unsafe. There have
been cases of pedestrian fatalities near schools. If safe routes are developed, even off -road, they
should be developed as accessible, especially where there are specific programs that serve
children with disabilities. Places that might be promoting trails with uneven surfaces would not
accommodate those with disabilities.
WHATCOM COUNTY ADA TRANSITION PLAN
OUTREACH SUMMARY
Based on comments from the Focus Groups. Specific outreach to the Blaine, Lynden and
Bellingham school districts was conducted to gain feedback on how bus services work with
children with disabilities, specifically if they are picking up students at curbside from
sidewalks. Blaine School District noted their specialized school buses go door-to-door.
Bellingham also noted most students with disabilities use specialized transportation.
Growth Areas — Whatcom County has unincorporated urban growth areas, including Columbia
Valley / Kendall, Birch Bay, and Cherry Point. These areas are expected to accommodate more
active and intense land uses, potentially resulting in a greater desire for people to walk and bike.
Signals and Crosswalks — Traffic signals at intersections provide opportunities to cross roadways
safely. Whatcom County maintains relatively few traffic signals. In addition to a few signal -
controlled crosswalks, few crosswalks are crossing potentially higher speed or busy arterial roads.
Some signals in the County are maintained by other agencies, specifically WSDOT on state routes,
and require coordination to coordinate ADA improvements.
Transit — Transit service in the unincorporated County generally only operates on arterial
roadways and does not provide access on many secondary streets that serve residential areas.
Paratransit is also limited to 3/4 of a mile from established routes. Transit for many in the
disabled community is critical for mobility. Issues for transit include stops that don't have
adequate landing pads or weather protection.
Governance and Partnerships — Responsibility to improve pedestrian facilities that provide
access to services in Whatcom County are shared with many agencies, including incorporated
cities, Washington State Department of Transportation (WSDOT), Whatcom Transit Authority
(WTA), other government institutions and private businesses. Improving access seamlessly,
specifically for those with disabilities, may require coordination with different agencies.
County Parks — County Parks like Birch Bay, was not mentioned often; however, county parks
provide recreational opportunities for all. For those with disabilities, access may be inhibited
Design Practices and Model Communities — Consider communities worth emulating that have
implemented universal design. Ramps, rather than ramps and stairs, can serve as a universal
design rather than building both.
Comments and issues at specific locations
Some comments were discussed with reference to specific areas as described below:
Birch Bay Blaine - There are older populations living here, and communities should provide
sidewalks and ramps at all locations.
Hannegan Road - Transit and the park along Hannegan Road are not accessible. The grange hall
located at Smith Road / Hannegan Road is not accessible.
Lynden — Consider a roundabout and improve for accessibility.
Sudden Valley Area —The Sudden Valley area lacks safe crosswalks by the firehouse crossing Lake
Whatcom Boulevard.
Kendall Area
• Kendall Elementary and Mt Baker Library need to be improved with crosswalks and lighting.
This is a location that may serve disabled and foster kids. There are uneven sidewalks, and
WHATCOM COUNTY ADA TRANSITION PLAN
OUTREACH SUMMARY 5
the inclines do not function well. Sidewalks or crosswalks do not serve the elementary school
on SR 542/547. Students are advised not to walk to school. Sidewalks and crosswalks would
need to be coordinated with the State.
• Mt Baker Roundabout is not accessible could be better for providing safe and protected
pedestrian access for all. Provides access to the library
• Sidewalks are missing at the East Regional Community Center and connecting crosswalks
across Kendall Sumas Highway (SR 547). This community center serves a broad community,
and access for all users (not just auto) is essential.
• Kendall Trail is a high priority for the pedestrian bicycle advisory committee and could serve
the elementary school. A trail should consider accessibility for all users. A path may be good
for some users, including cyclists but not ADA.
Birch Bay/Blaine —The area serves many seniors and has mobility issues and limited sidewalks.
Northside of Lakeway Drive - There is missing sidewalk on the north side between Lowe Street
and just past Euclid.
County Wide
• Sr. Centers — Senior Centers located in Sumas, Everson, Blaine, and Lynden may not be
accessible
• Consider connecting sidewalks in higher population areas of the County. Bicycle systems are
not interconnected.
Routine Sidewalk Maintenance - Overhanging brush blocking the sidewalks should be
maintained
Comments and issues that may not be addressed by the plan
Some problems identified may not be treated as part of the Whatcom ADA Transition Plan. These are
described below:
Facilities on State Routes — Urbanizing areas are often served by State Routes like SR 542 and SR
547. Crosswalks and sidewalks are not often identified as part of a state design standard in rural
to urbanizing areas. Whatcom County would need to coordinate improvements on state routes
with WSDOT.
Transit and Paratransit — More frequent service is desirable to serve more of the County. More
paratransit that is more frequent is desirable. Transit shelters are not provided in areas where
many people wait, specifically the WinCo in Bellingham.
ADA parking —There is inadequate ADA parking at private businesses
Incorporated Areas — Within incorporated areas like Bellingham, scooters that are being
considered may create another obstacle in addition to sandwich boards on sidewalks. Businesses
on the Guide Meridian (like Starbucks) don't have good crosswalk access and signals to protect
crosswalks
WHATCOM COUNTY ADA TRANSITION PLAN
OUTREACH SUMMARY
Priorities
As a final topic, the group discussed priorities and what should be fixed first. Notes from that discussion
are provided below:
Urbanizing or growth areas — Urbanizing areas, where pedestrian activity is expected to
increase, currently lack pedestrian facilities that are adequate for all users and specifically those
with disabilities. Specific areas mentioned include Kendall, Birch Bay, and Sudden Valley.
Schools — Improving walkability to local schools and specifically addressing those with disabilities
could be a partnership with the schools to create safe routes to school.
Jurisdictional coordination — Management or maintenance of pedestrian facilities can be made
more challenging if agencies have shared jurisdiction. Coordination between agencies should be
addressed. If the State (WSDOT) has jurisdiction, but the City identifies a need for a change, there
should be mechanisms for coordination and collaboration specifically to address ADA concerns.
Additional and on -going outreach — Some mentioned the need to continue outreach and keep
the plan dynamic as new issues are raised.
WHATCOM COUNTY ADA TRANSITION PLAN
OUTREACH SUMMARY 7
ATTACHMENT A -OPEN HOUSE BOARDS
WHATCOM COUNTY ADA TRANSITION PLAN
OUTREACH SUMMARY
M"
b"
MY-
ME
4MA
0 IMMIN
INIMMEM
u
m's"7A
Now
19
x
I
0
U)
C:
A
r cd U
u ¢� b4
O
� .�
u
rl ;� "'
9
C)
a�
®
eN
Ldl
cu
CU
P-,
C�7
c°fj
crj
crj
-,q
cd
CO
c�
cu
+e�1
cu
®
0
Cn
9
u
>
m
u
IA
CL
0
N
0
CL
E
tA
W
N
u
030-
LM
co -
.
. .�E
-Ow
!
,
O> \�,» c�
� }�{
4-J
4--)
4
I
ILI r
b�.0
O
cn
4-1
cn
W
ccn
cup
. ®
ct
uj
0.
:3
b()
C�)
I-n
CIA
C3
WD
r.'
C-d
,
4-J
0
:c
ou
00
14)
ATTACHMENT B - ONLINE SURVEY
Through this brief survey, we'd like you to identify the locations and deficiencies you consider most
important.
You may also provide your contact information to receive updates or participate in a future focus
group.
* 1. First, please tell us why you travel in Whatcom County? (Check all that apply)
Live in Whatcom County Medical Appointments
Work in Whatcom County Shopping
Attend school / college Other community and social services
Recreation / Recreational Activities
Other (please specify)
* 2. Please tell us about yourself. (Check all that apply)
have a disability that impacts how I travel (please describe that disability in question 3)
I support a person with disabilities (please describe that disability in question 3)
I have no disability
I prefer not to say
1
3. If you indicated you have a disability or support someone with a disability, please select from the
following list. (Check all that apply)
Physical, mental or emotional condition that limits learning, Use a wheelchair
remembering or concentrating
Use assistive software technology such as a screen -reader
Blindness or serious difficulty seeing when wearing glasses
I Use hearing aids or hearing assistive devices
Condition that substantially limits one or more physical
activities such as walking, or climbing stairs Use a service animal
Deafness or hearing difficulty
Use a mobility device
" Other (please specify)
4. What resources do you use to find information on ADA issues? (Check all that apply)
Washington State Department of Social and Health Services (DSHS)
Washington State Department of Services for the Blind (DSB)
t
Whatcom Transit
United Blind of Whatcom County
Other (please specify)
2
6. How often do you travel in Whatcom County? (Select one)
5-7 days per week
3-4 days per week
1-2 days per week
less than weekly
7. How do you travel within Whatcom County? (Check all that apply)
( ' Drive and park
Take transit or paratransit shuttles
Wheel (use a wheelchair)
Walk with assistance like a cane or walker
Walk with a service animal
Walk
Blke
other (please specify)
i
8. If you use transit, how often do you use it in a typical week? (Select one)
4 or more days per week
2-4 days per week
1 day or less per week
less than weekly
3
10. What was the reason you could not participate? (Check all that apply)
Facility not accessible Website not accessible
Materials not provided in an alternative format Transportation or parking not available
Sign language interpreter not provided Assistive listening devices not provided
Program not accessible
Other (please specify)
11. Which of the following pedestrian facility issues are reasons you could not participate? (Check all that
apply)
Sidewalk barriers Pedestrian signal issues including access to push buttons
Curb ramp barriers ADA parking not available
Pedestrian crosswalk issues
Other (please specify)
__4
* 12.Of the six types of locations below, which one would be your HIGHEST priority? (Select one)
Government buildings that provide human services
Other government buildings
County parks
Community services
Schools and institutions
Transit facilities (examples are transit stops)
* 13. Of the six types of locations below, which one would be your SECOND HIGHEST priority? (Select one)
Government buildings that provide human services
Other government buildings
County parks
Community services
Schools and institutions
Transit facilities (examples are transit stops)
Specific Problem Areas in Whatcom County
For these open-ended questions please provide locations where you have experienced challenges
with pedestrian facilities including sidewalks, curb ramps, crosswalks, and buttons for activating
walk signals.Please note areas outside the City of Bellingham.
14. Where have you experienced challenges in Whatcom County? Please list up to three locations and the
problem. Be as specific as possible about the location and the type of barrier (sidewalk, curb ramp,
pedestrian crossings, pedestrian push buttons)
Location 1 (Street
address or cross street)
Problem 1
Location 2 (Street address,
or cross street)
Problem 2
Location 3 (Street address
or cross street)
Problem 3
X
Demographic questions
We would like to better understand the audience taking our survey. Providing information is
optional and your responses are confidential.
15. What is your age? (optional)
under 18
18 to 24
25 to 34
35 to 44
45 to 54
55 to 64
65 or older
16. How do you identify yourself? (optional)
African American/Black
Asian
Caucasian/White
Native Hawaiian/Pacific Islander
Native American
Some other race or combination of races
17. Are you of Spanish, Hispanic, or Latino origin or descent? (optional)
Yes
No
19
18. Please provide your contact information to receive updates on the plan.
Name
Email Address
Phone Number
19. Would you be willing to participate in a focus group related to the plan?
Yes
No
W
ps
rLr)
W
4�
0
0
4�
4-J
•-
�
O
�
O
E
._
ca
Q)
+,
CC
Ln
Lr)
v
d'
4-'
.
O
.-
•-
ry'
E
0
no
•01
CO.
O
m
-0
O
OV)
0
a
a
i
L
NO
• —
DC
0
SONS
0
l0
. N
00
m-0
lzt
0
4— •—
U
• —SWOO
W= C: i C: cn OV
E u
E
.C:
0.0 V)
ca r�A E v
.
> C >
._�u
._ •— „-,
ai ;�' .�
0 0
•- s-- O
W
O
O
U
C"
O
U
E
O
U
a- J
m
W
m
1-
D
O
O Q
V
1
C
• • +,)
cr M,
y�
--
u
®
F-
®
®
E
®
Uj
O:f
-J
U
2
Ln
u
J
d
®
L.LJ
�
u
J
0
M
M
V)
z
L
J
z
0
u
0
0
a
O
rn
O
DO
0
0
O
ol
0
0
O
M
O
N
0
O
0
O
nm
W
O
O
U
4--
4�
OT
D
0
C)
(m
V /
Q)
^T
V
m
`^C
'
^W
r) M
• • i
N M
'—)
T
m
®
Q
<L
W
UI
LU
cc
0
L/i
CC
uj
d
Q
D
V)
O
I
0
L,
0
O
0
0
O
0
m
N
LLJ
LU
z
d
V)
N
LU
N
O
O\l
0
0
>
N
Q
w
J
w
W
u
�-
u
Q
LLJ
u
W
®
®
c✓�
Q
0
CD
N
O
(A
uj
LLJ
LU
<
V)
0
Q
M
U.J
0
0
LLJ
n ,
W
>
>
Q)
O
4-,
N
.0
�
O
O
._
Ln
O
>
�,
ca
O
bn
O
®_0
O
O
U
m
a
Q)
_0
O
_
�
c-
a)
o
a
O
-a
>
O
>'
O
Q
�
U
>
O
�
U
`.-
ro
U
O
m
U
N
4-,
ca
0L
O
r-
j
Q
m
-
Ln
qA
Ln
cn
O
Ul
ro
Q�
>
fQ
i
z
E
Ln
Q
�tam
c- E
O
U
OC-
>
C- U
Lnn
U
-0 O
O
O 4-j
� ca
O0
•
Ail
O
O
V)
O
4--J
W
E
0
C6
U
4�
to
O
Q)
U
.>
4�
(a)
O
�
�J
O
0
0
O
`T
��J
T
Q
�
Q1
0
C�
Q
v
0 L/)
0
O
00
0
O
0
r
0
0
0
0
0
a
0
m
0
0
O
N
0
m
0
0
N
0
0
LU
z
®
w
uj
EE
of
¢
®
cr-
w
P-
of�,
�
u
LU
:D
Ul)
<
�
d
cr-I
z
¢
cr�
�
r-
V)
D
Ln
<
c�
V)
V,
r
LU
LU
M
LU
LU
CL
V)
* (1)
Z5
M
0
Ul)
0
un
Q) .4-J
.zD
m
M
(3)
4-J
Q) M
V) L/)
0-0 V)
c- c- Q)
4-j
Ul)
M
4-J C) L-
c- 0
0 (L) ca
U C)
tA
r-
0
41
-Fo
Qu
M
in
Ul)
Ln
0
u
C
ru
4-j tll
V.)
(D
CL
m
J
ID
00
LA
W
N
0
a
Q)
.(z O
. U a--)
U
1
T
O
� V
U Lo
O W
4- =
O U
-+J O
Lo
4� C)
4—
O O
N �
C� o
z
V
V)
2
u
2
�
>
<LLJ
�-
,�
V
0
z
v
®
LU
u
<
®
0
LU
cn
u
V)
uj
u
0
LU
0
0
U
m
Ln
N
N
tf�
En
0
N
O
Q\1
U
�•
O
•�
O
V
O
•
T
U
o
z
O
4-
O
U
w
v)
Q
4--J
O
X
4--J
O
y-
Oo
•,--d
VJ
O
�
V)
W
A:.
Ln
m
L
Ol
O
N
O
N
O\l
u SI
U) o
i u
C)
N
Y
t'CS
0-
U
(Y)
(D
�r
Ln
m
0
m
"C7
00
in Q)
N >
lCS
L(1
O Ln Ln
bn c-
Ln 1
T
O
U M N
U N o cn
-
• — :-, cn to
bn .�, U c
.N 00 O
.ru
O e O
O c6 },
i U U N
Obn
ca •— .� j, � �
. �-
O 4-1-0 _0 U
N _0 U N +-+ c
tn O O v N O
4-1 > — U
Q 0.0 ca
.� O v p
cn ca = - Q
•� i o > .- .v •� O
L Ln O cu N 0 Q N
o
N U =3
C-a) I p o
-I—� • O O> N U O
O ca
. _ I o cn �- c6 C
�� (7n 0- U 2, U c6 0- z Q Q I— u
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
+
Q
>
0
0
m
3
v
O
Y
Y
c
c
GA
0
c
a1
m
m
v
ns
u
7
+
j__
o
>
=
t
o
o a
ea
Vf
Y >
ate,,
U
v
v o
�e
L
o c
3
L
>
m
3
00
w
w
o N
bcA
a1
Q
O U
Y
L
L
O
E
V U
C
T
O
m
Y w
u c
m
c
3 •N
L
v-
T co
+-'
O
a1 30
H
v
>_ N
�O N
ns
ao
o
_ M
> u
3
@
c0
L bA
-
3 y
C
U
M 0
Q
`°
c
c6
E
N O
Q Y
Y
3
Y
0
C
O
sY..
N
O
Y
N
,Qj
Y =
V1 b.0
,@
Y
L
t0
o
c
L Y
D
O
C
C U
0
Q
T
O
Y Ql
c
a1 Y
�n
aJ
-0
f0
04
Y U
T
E c
ai
3
3
Q
�c
oo
v
E
>
3
�'
�
0
0
> E
Q
c
o
0
Y
3 m
c
_0
m L
o
Q
Y
V1
4- Y
aJ
M
f0 a1
T}
c
v N
Q Y
\
�a
Q
7
w tla
c
>
3
-O
w
ai
N Q
C
U
Y
y
Oa
E
y
Q
-0C
c
c
L
U a'
O
c
O
C
p N
.E
O 0)v
f6
N
to
(0
U
O
E
y.
,Ia
Y aJ
E+
Y i
m
N
3
0
3to
Y
c
3
N
3 m
of
0
3
fl
al N
�
0
v 0
U
m
,
i >
o
v
> OJ
v
O
to N
aJ
O
O
N
=
N
Y al
0
Q
— .0
C
Z
Q
Z i
Z
Z
Q
aJ
N
Y
v
Q
'O
c
c
aJ
C
(0
C
�''
N
Q
Y
O
Y
C
OU
E
Y^
c
`o
o
c
o
@ •O
°° °
rc—a
C
E
C
E
O
N
n
v E
a
O
m
-O
v
ai
0
>
0 Q
v
E m
T
(0 E
_
U
0
C N
'0 aJ
m
W
W
M
L
Y
-to
C
cm?
>
aJ
Q
E L
O
3
ns
c° 0
N
c f0
ns -0
0
is
-6
N o
'6
>
a
i% ro
C
o
E
`-'
c
c o
U 7
E
aJ
=
a1
N m
m
O
m
O w
U c
O
U
—
N o
` aJ
O
a1
a1 U
rYo o
m
v
LL
x
x
•
x
x
x
x
x
x
x
x
x
x
x
x
x
c
o
>
ai
6
"-
0
m
v
v
m
v �
O
3
o
v
E m
=
L
O_
�
L
O
o
c
a1 m
a)
>,
m
N
O
c
Q. 0
m
bD c
N
>,
O
v
L
N
N
H 3
Y
Q
>.
Q
E
m
>
0
m o
v
°
3
L
a
c
o
0
3 _
'O
0
v w
ya
v
c
c
:++ c
a
L
E
N U
y
o bn
c
m
-o
_
U
L
al
c
n�
o
N
U
4
a)
iz
3
o
3
Y o
0
aJ
v
O
++
acL
L L
>
a+
al o
N
bn
c
4=
3
c
m}
am
3 E
v
w
aJ
o_
v
U
o
fl
o
.c
m
o
> L
Q
o+
y v
3
Q
N
v
L
Y
T c
6
9
c
o z
>
m
'
E Q
a
o
3
Q
c m
o>
c
v
am >
>
ai
u
m
'O
m Y
z
ai
aJ
N
.N
o
A-2
ri
>
O m
=
j
u
U
m
m
-c
a
m
o_
an ar
c 4
m
O J
4
.N
i
c _U
7
N
'3
m
N Q) y
tlq
c
m
N
-1C 'o
(p
a1
Q m
m
N
u
v
N i
Q
O
o
O
>
a
a Y m
cea
Y
m
o
L
v
N
v
o
3 0
N
Ln
_
m
-o u
cca
o L
a
u m
N
3
v=
o
v
v
y
L
N
v
0 V
L
y
.°
`~
m
a L
QU'
c
aJ O
z
Y +'
° 3
0
o
zo
= ° u
-oo
z
z° -
y
°
O }u
a =o
c
E
Q
c
m
o
N E
:o
+U
m
u
-om
N
oo
T=
O
aJ No
4
c
m
_6 v
U
Q
N
c
>
ON
t
oo
rn
¢
m
T
v
U
>
_
c o
0
m
3
>_ E
c
m
L
E
m>
o
w—
v c E
c7
a
o
a
c E
a E
o
v
-o °
t
00 t
N
a`)
-o
>
3_
'y m
E
m
u cw
l7 =
v >
ofl
c v
ao
c
'a
ca
o
c
v
o ao
L
ou
as
>,
m
a o
o m
c=
=
a
0 c
c m
_
•E
o
vO
do
'@
-o
o
°
c .c
�n .c
m>+
3
°f)
rn
��
>
Qu
m�
c
ca
o m
o
>
-o
3 v
o°?
N=
c
cv t
a°1i Y
� NCO
o°
x°
2
v
-4muo
a
F- n
September 20, 2019 V2 Whatcom County
Facilitation Guide
Whatcom County ADA Transition
Focus Group
Tuesday, October 1, 2019 (3:30-5:OOPM) 2nd Floor Conference Room - 322 N Commercial Street
Thursday October 3, 2019 (3:30-5:OO13M) Whatcom County NW Annex
Purpose and Goals
Gain deeper insight on ADA issues in the Public Right of Way from the public and expand on a discussion
of priorities identified in the online survey.
Recruiting Members
County will recruit from survey respondents and potential other interested parties. County will provide
accommodations requested including alternative formats, sign language interpreters etc.
Agenda and Welcome
- Welcome and acknowledge/thank participants and provide brief purpose of meeting— Jim/Dave (5
Minutes)
-Ground Rules —Jeanne (5 Minutes)
- Introductions —All (10 minutes)
- Discussion of the outreach results (via PowerPoint) — Ryan (10 Minutes)
- Workshop — Jeanne and all (up to 60 minutes)
- In depth discussion of the top barrier issues and perspectives on priorities.
Purpose of the Focus Group
Today we are going to take a deeper dive with all of you on different aspects of accessibility including
different locations and types of issues. We want to ask you more about your experiences to explore
specific issues and priorities identified in the online survey and open house.
Ground Rules:
We have planned this focus group to last 90 minutes hours. During this time, we have several questions
that we would like to cover. We want everyone to take part in the discussion; however, you do not have
to respond to every question. Also, feel free to respond to what others are saying —whether you agree
or disagree. If you have been speaking a lot, wait a bit before speaking again to allow others a turn. We
are genuinely interested in your experiences with barriers to pedestrian access; therefore, there are no
right or wrong answers. If time begins to run short, it may be necessary to interrupt you in order to
complete the questions or move to the next discussion.
We will be using some graphical material, mostly charts, in the PPT you received . We will do our best to
describe them, but please feel free to ask questions.
September 20, 2019 V2 Whatcom County
We will treat your answers as confidential. We will not ask for personally identifiable information. While
we may use names during this discussion, we will replace names in the transcript after our discussion.
We also will not include your names or other personally identifiable information in any reports we write.
We ask that each of you respect the privacy of everyone in this room and not share or repeat what is
said here in any way that could identify anyone in this room.
Restrooms are down the hall on the left. Please feel free to get up from the table at any time as you
need to. We can take a break if we need to roughly at the 1-hour mark.
Introductions:
Please take a few minutes to tell us about yourself and why you are here today. What is your interest in
this project?
Survey Summary
PowerPoint to show the summary of the top -line survey results, issues and priorities.
About Transition Plans
The Transition Plan addresses potential deficiencies to improve mobility in the public right of
way including access issues along sidewalks, curb ramps, signals, and transit stops within and
adjacent to public roadways.
A transition plan will be developed after completing the public outreach process and a review
of the County's current processes for improving facilities. This plan will outline a strategy for
making improvements considering several factors such as the extent of deficiencies, identified
needs, proximity to certain facilities, requests and complaints by the community, available
budget and a realistic schedule. This focus group will be an in-depth discussion. Please, set up
you name tent or raise your hand if you would like us to repeat anything.
Materials
• Power point presentation of the outreach to date (We will read every slide)
We will spend our time considering the types of issues that people have raised and the impact those
issues have on accessing facilities that provide public and community services. Specifically, these
services include schools and institutions, parks, government buildings that provide access to community
service, other government buildings and transit
We should note that there were a relatively small number of respondents with disabilities; however, we
did reach people who support those with disabilities. This is why your responses are also important
input.
September 20, 2019 V2
Facilitator Narrative:
First any surprises in the survey?
Let's talk about the issues to barriers that have been raised to date.
Questions:
Concerns we have heard about:
Lack of ADA Parking
• Missing or discontinuous sidewalks
• Lack of crosswalks or protection from vehicles
• Short walk times for crossings
• Orientation of curb cuts
What other issues and concerns do you experience when accessing these areas?
Whatcom County
Additional probing questions for respondents.
- Which of these barriers do you experience?
- How are they problematic? How often do you experience them and how much does it impact your
travel?
- Were you surprised at the different perspectives between those with disabilities and those without as
for as barriers?
- Is this a priority or severity of one or some of these issues as compared to others?
NOTES:
September 20, 2019 V2
Whatcom County
Facilitator Narrative:
Let's talk about locations, and specifically services and resources where there may be barriers to
access. Notably from the survey, government buildings that provide public services were most noted
as priorities for having good access, specifically by those who indicated they have a disability. They
also noted schools and institutions.
Questions:
Were you surprised at the difference between perspectives for those with disabilities as compared to
those supporting people or without disabilities?
• Notably access to government buildings and schools was higher for those with disabilities
while Community Services, County Parks and transit were more critical for those supporting
people with disabilities and without disabilities?
• What services do you have trouble accessing due to barriers?
• Are there specific destinations you have trouble accessing?
What other issues and concerns do you experience?
Additional probing questions.
- Are there barriers or access issues for riding transit? Where are they?
- Which parks, schools, community services and institutions are problems to access?
NOTES:
September 20, 2019 V2
Whatcom County
Facilitator Narrative:
Part of our task in developing the ADA transition plan will be to identify what to fix first with limited
resources? It is likely our needs will outweigh our resources. Where would you invest?
Questions:
First what types of issues are most important to fix?
• Completing sidewalks
• Access to parks
• Pathways serving Transit
• Signal Timings, signal improvements and crosswalks
Where should we focus our energy?
• Schools and County Parks
• Transit pathways including sidewalks and crosswalks and curb ramps
• Improvements to make government buildings that provide community services
• Other locations?
NOTES:
Appendix E - GIS Inventory
2
M
i�
I
O
E
LL
CU
0
M,
r -,
c
0
MMO
(ou
=
E
M
•
a
0
-
0
0)
M
-c
(o
I
Vn
0
0
0-
M
I-.
LL
O
0
IB t
1$ '
IA
A
1� Y+
6
1
1 A 1
�w««d and
�I
/I
/i
I
I
/
/
I
/
q
O
U
N
L
c O
c �
O m O U
O U U)
O C: N
N E T 0 ry0ry��
L L W
U ° a O -
3 Y E cm °Co
B
W
r�
V
Ez
LVA
-0
♦
I
0
a)
o
a 0
0
0
0 a)
E m-
0 0
-C
A
4
M-
I
tl
C:
0
L)
W
'S
U
0
0
0
00
co
Q-
�p
0
CL
E
CL
0 0
0
UIP
CD
m
I
IN
A
I
0
M-1
1
0
0
�
cu
N
O
�
i
'a
U
O
o
Z
Cn) Q
00
E
O
co
cu
U
Q
O
� .
• J� `n
/ �P
2
9,
I
I
I
cu
�cu
0
U
a
O
0
U
U
Z
U
N
Q
�U
0
0
m
aV O
Ucu
Q
O
� li
2
1! 64
1
1 t
�a��ma�ad
1
q
- 9 .,fig-,...-� ♦
0 \
OB t
i
`o
U
N
U
�
c
c
:
o
Z
�
p
o
co
y
o
U
m
Cc:
.,�,
•�
Un
�=
m
o
N
U
N
c In
Q
Y
U
E
p
m
Q
O o
o m
7
(6
-C
U
u(6
-
1
\w
�
O
I a o
_ c0
�Ic
Y
Q Tf—
U,O
ft9 ¢
®Ic
s
o
,U
C`6 0
JHi^ N
J MM' ��
Appendix F - Cost Estimate Backup
!\\:
a\
\