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being into quadrants. Then I'm going to
talk about the program and policy

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portion of the requirements. uh address
public

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feedback, talk about uh how to treat
existing sites, and then talk about the

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the key deliverable, the transition
plan, and then make some comments about

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reporting that will occur between now
and when the project ends in September

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of 2026.

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All right. Can you advance it? Yeah. All
right. You might be able to work now,

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too. Right. But quickly, what is the
ADA? It became effective actually quite

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a ways back. January 26th of
1992 for the 89,000 units of local

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government across the United
States. Obviously, it prohibits

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discrimination on the basis of
disability, but it defines

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discrimination in a way that might
surprise you. It says that an existing

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site that's not accessible is
discrimination on the basis of

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disability. uh it says that programs and
policies that are not inclusive of

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people who have a disability uh rise to
the level of discrimination on the basis

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of disability. So those are all parts of
the scope here and because the scope of

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the ADA is so broad I think
appropriately so the Westcog project

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scope is broad as
well. The ADA doesn't just tell you you

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can't do certain things though it also
imposes some very affirmative mandates.

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Those two have been worked into the
scope and I'll touch on those too. Just

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a comment about things in Washington DC.
This is not a political comment. Uh we

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see this thick political approach no
matter who is elected from which party.

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There's generally when there's a
Republican elected as president, there

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are fewer civil rights staff. It's
happened every year for the last 33

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years. So we expect as much as a 50% cut
in civil rights staff, but that's not

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going to change the content. When this
has happened in the past, the content of

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settlement agreements and court
decisions has remained exactly the same.

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But we do think there will be an impact
because there will simply be fewer

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Department of Justice staff to receive
complaints and investigate complaints.

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Um, we are still seeing a continued
trend from towns and cities and special

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purpose districts of issuing RFPs for
ADA compliance. So, 33 years into the

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life of this law and agencies are still
realizing that they want to do this and

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need to do it in part because of the
changing demographic groups.

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Uh our firm is an architectural and
engineering firm but we added access

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consulting in 2008. Uh we work all over
the country and are licensed in all 50

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states and we serve just about
everybody. We are an MBE uh in

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collaboration with our partner Draft
Pros and we have about 340 nationwide.

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our accessibility practice of just the
nine of us and unique to other ADA

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consultants. Seven of the nine of us
worked in local government and I had the

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pleasure of being an

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administrator. Um so what is the quad
approach?

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So there is no way to do all 16 of the
participating uh Westco communities at

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once. We did briefly consider that, but
that was just not going to be effective.

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So, we tried to balance that by putting
you into groups of four. The scope of

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work for all 16 is the same though.
Project management, inventory

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verification, access audit, site
reports, program policy review, public

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feedback, uh transition plan, a capital
report that gives you a cost reference

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for planning purposes about direct. And
then of course interactive final

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reporting and we're going to do that on
the quad

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basis.
Um we tried to balance the quads by

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population, proximity, number of parks,
trails, and facilities. I'd say we hit a

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home run on a couple of them and maybe
missed on a couple of others. Uh but it

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is still working. Quad one started with
Darien, Reading, New Milford, and

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Norwok. Uh that's going to last roughly
September of last year through July of

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this year. Quad two is Stanford. In
fact, we have a team in Stamford this

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week, Westport, Weston, and Wilton.
That's going to run through roughly

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August of
2025. Um we do expect some overlap

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here. It went back

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Try one more forward for
me. Quad three is Bethl, Bridgewater,

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Greenwich, and New Town. And then quad
four is Danbury, Brookfield, New

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Fairfield, and Sherman. And we expect
that to take us roughly through August

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of
2026. We're also including reporting to

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Westcod on a periodic basis. And then of
course that the project

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includes I think when a lot of people
hear the Americans with Disabilities Act

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they think brick and mortar and that
certainly is a piece of it but this is

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really an important part uh programs and
policies or opportunities that each of

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the municipalities makes available to
your

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residents are also subject to the API.
So programs are defined of course as a

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thing that meets at a certain time that
I say it before and it been a certain

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location and it lasts for eight weeks.
But it's also a sidewalk that's been

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decided by a court as a program. Uh it's
also playgrounds, trails, beaches,

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campsites, public comment at one of your
board meetings. So that's why the scope

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includes evaluating your programs and
policies and talking to your staff about

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how they invite
uh analyze and fulfill requests for

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reasonable
modification. From a policy perspective,

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we'll look at things like service
animals, other powerdriven mobility

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devices, uh rental and reservation
forms, and so forth. But this is a

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really important piece. It ends up in a
separate report that

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talks about how you matched up against
the title two regulation. Uh so again, I

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think a lot of people think of brick and
mortar first when they hear ADA. You

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know, I would urge you to greenlight
this for your staff. We've had a couple

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of staff ask us, is this really a part
of the scope? And of course, it is. It's

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part of what title two requires and it's
part of uh the Westcog project.

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Community engagement is another piece.
So I'll call these two the sets of soft

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tasks involved here. You can't have a
transition plan without community

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engagement or public feedback. So this
is a really critical uh piece of this

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and as we go through and I'll use town
of reading as an example. We just did

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their community engagement March 3rd 4th
I think it was. And the point of it is

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to ask your residents who have a
disability, do you have a preference or

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priority as to the order of retrofit?
Um, and is it something that is

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meaningful to you? Because that can
influence our final recommendations to

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the town or to the city. We recognize
that each city, each municipality is

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different. So you'll get in Sherman a
different report than uh petal will and

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bridge water
will want to kind of tie your own

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citizens preferences into that. So again
I ask you to greenlight that too. We've

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had a couple of times where staff have
said is this really a part of the

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project and indeed it is. We do public
feedback in two different methods. One

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is an in-person freestanding meeting.
Since the pandemic, candidly, we I'm

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surprised if we get 10 people to show up
at an in-person meeting. These tend to

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be fairly positive in nature. Wouldn't
you agree? Yeah, I would agree. I mean,

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it's it's been a positive process for
lessian so far. There's no great same

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with us in writing. Absolutely. Really
consistent with the process with the

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public outreach. I learned a lot even
that you know I think you've warned us

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you may not get a lot of people at these
in public sessions but the feedback that

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you did get was really insightful and
invaluable I felt so plus the second

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piece is the the online survey that we
did and kind of reading has almost as

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many responses as we got from the entire
state of Texas on a related project but

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we're calling reading Texas
don't mess with us

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um so what's an exist existing
site. Pretty silly distinction here, but

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it's anything that was designed and
constructed after January 26 of 1992,

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that's subject to the 1991 standards.
And then if it was uh designed and

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constructed after March 15 of 2012, then
it's subject to the 2010 standards. U

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the 1991 standards just included typical
built environment assets like parking as

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doors and restrooms. The 2010 standards
added park assets, uh, playgrounds,

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sports fields, things, basketball
courts, pickle ball courts, skate parks,

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and so forth.
Um, you've got pickle ballers out there

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playing today in the drizzle. Uh, it's
important to to know the rag and the

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standards though, so that you can stay
in the driver's seat. If you wind up in

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a settlement agreement or being
compelled to compliance, you have to do

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everything in three years. If you stay
in the driver's seat, you can stretch

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that out over a period of time that
matches your resources and still meets

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semantic.
Um, what's a transition plan? Pretty

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simply put, it's a it's a phased
schedule of retrofit. It has to identify

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every deficit. So your site reports and
the transition plan may be long if

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especially if you're a larger
municipality. Uh has to recommend a

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solution or a treatment for each deficit
and that can include leave it as is till

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it's later replaced or altered. U you
have to identify the position

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responsible for the transition plan. So,
director of public works or ADA

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coordinator or whomever you wish for
that person to be. And then you have to

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note by when the work will occur. We
typically recommend that this occur in

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phases with each phase varying from
three to as many as five years depending

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on the number of deficits that you have
and the number of resources that you

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have. Uh we always add costs. That's not
a requirement from the ADA, but we know

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that no municipality can make a plan
like this uh without

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cost. So reporting and communication
uh we want to do this

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uh we want to do this individually. So
for each municipality as we near the end

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of the cycle for your project uh we will
arrange for reports to your

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stakeholders. So whether that's staff
leadership or governing board or both,

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um we're happy to do that. Uh at the end
of the project, as I mentioned earlier,

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Westco will also receive a cumulative
report that will kind of summarize what

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we saw for each of the 16.
Um staff leadership piece is

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particularly important. All of you have
designated somebody as the contact

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person for us and so we'll work with
them to identify any others on staff

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that uh we need to participate. Couple
of resources before you bombard me with

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questions. Um DOJ has a really good
hotline. Um they do a good job of

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separating enforcement from technical
assistance. So don't worry if you wind

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up calling the
202514301 number when you show up at

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work the next day. There's not going to
be a bunch of people in suits from

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00:13:02,880 --> 00:13:10,560
Washington DC. Uh they're great for
program and policy question. If it's

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brick and mortar or dirt and grass or
beaches, call the access board. They're

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the small federal agency that created
the standards for design and

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construction of outdoor assets and park
assets and buildings. They know this by

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far better than anybody else. And
they've got a great technical assistance

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service, too. There is a national ADA
network. They're happy to talk to you

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about anything, including employment,
including uh universities, including uh

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things that we haven't even thought of.
So, uh you can reach them at 800

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9494232. There are seven of those across
the country. They all use the same phone

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number, and they're more clever than I
am. they can figure out where you're

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calling from and they connect you to
your local uh ADA uh assistance center.

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Um we love to talk about this. So sorry,
I did two there. That's me.

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If if your team raises a question and
you call Westcog or you want to reach

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out to us, feel free to do that. Um as I
said, I lead the accessibility practice.

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Tatum is our master of logistics and
information. Uh I will say we've had

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great working experience with the
Westcock staff. Mike Wilson who I know

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is not here but I believe is he's on
virtually.

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Hey Mike. Uh he has been great to work
with. Uh if he doesn't know the question

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00:14:39,040 --> 00:14:45,839
or the answer to the question uh he gets
to us as soon as he can. So, and Chris

168
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has been a pleasure to work with and the
occasional times that we see Francis, he

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too has been easy to work with. So, I'll
back up not literally here on the

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screen, but can I answer questions from
any of you about the project or uh

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anything related to compliance?

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Yes, I'm sorry. Okay. Um, how often do
these plans need to be updated? That's a

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great question. U, the Title 2
regulation doesn't have a a date

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requirement for updates, but many
accredititation programs. So in

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particular for parks and recreation,
it's

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recommended actually it's not
recommended for a municipal parks

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department to get the commission on
accreditation of park and recreation

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agencies. They have to have a fresh
transition plan every 10 years. From a

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smart practice perspective, that's
probably about right. uh especially a

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community your size you're replacing
things you're changing out playgrounds

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you're act you're acquiring something
new you're raising something old so I

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think about once every 10 years makes
sense so John with with this if you're

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going to do an update every decade or so
would it make sense for municipality to

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have a log of improvements and changes
they made in interim just to facilitate

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the update to the plan yes and so one of
the things that we can do in the final

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deliverable is give you what we call
task track factor. So it's Excel. I'm

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00:16:24,240 --> 00:16:32,160
sure that somebody can convert it to a
smart sheet or some other tool. Um so we

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we developed task tracker when we were
working with a handful of communities

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that were under department of justice
settlement agreement. So it has all the

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information that transition plan has.
Then column K says

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uh playground replacement included in
town budget January 1,

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00:16:50,680 --> 00:16:59,519
2029. Uh bids let for playground
replacement April

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00:16:55,560 --> 00:17:07,280
2029. Uh playground installed June of
2029 and then playground inspected by

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name of town employee on August of 2029
and signed off as client. So, that's a

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00:17:10,640 --> 00:17:16,240
great way for you to kind of keep track
of here's the here's the literally

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thousands of projects that we would have
done over the course of 10 years. And

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some of the projects aren't going to be
brick and mortar.

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00:17:22,240 --> 00:17:27,520
It's going to be making sure that
garbage and recycling bins aren't stored

199
00:17:25,839 --> 00:17:31,840
by the door so that they block
maneuvering clearance if I use a

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mobility. So, a lot of these are low
hanging fruit things that you can do

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with current human and physical
resources.

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others.

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I surrender the clicker. Okay, very
good. Which I used. One other question.

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Um I'm kind of curious what happens
when compliance is a a matter of

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judgment say along the continent that
says full compliance in an extreme case,

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00:18:06,080 --> 00:18:11,120
right? which would require either
substantial remediation or design or

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actually just tearing everything down
and starting over again. Say to describe

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hypothetical extreme versus something
that gets close enough, right? In other

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words, there's an elevator on the far
end of the building, but not one right

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here on this side of the at what point,
how does that those types of cases where

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it's a maybe a judgment call as to just
pouch far someone's got to go to comply

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with these regulations and how is that
adjudicated and how can municipalities

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do a a better job in their own work to
uh make sure they don't cross over say a

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line?
That's that's a good question. There are

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a handful of places in the title 2
regulation where municipalities are

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given some discretion or where you can
say that a circumstance exists that

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makes compliance technically feasible.
Some of you have very hilly communities.

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So where you have naturally occurring
steep terrain for example, if you have

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trails, it's going to be hard to make
the trails meet the compliance slope. So

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that is a technical infeasibility issue.
Uh there might be in the event and

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honestly candidly we don't see this very
often but there might be an undue

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economic burden where the cost of a
project that would retrofit an asset uh

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is so great that uh you can claim that
it's an undue economic burden but you

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have to consider the entire fiscal
resources of the jurisdiction before you

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do that. Uh there are some others too.
So, I mentioned the soft task, the

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program and policy
analysis. If you have a building that's

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not accessible, but you've got another
building that is

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accessible, you might find yourself in a
situation where you leave the building

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that's inaccessible as it is, but you
take those same programs and duplicate

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them and offer them in the building that
is accessible. There's nothing wrong

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with doing that either. Uh the
Department of Justice has also in

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settlement
agreements given jurisdiction one, two,

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three years to make an inaccessible site
accessible. So we often find somebody

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has plans to build a new community
center. The old community center is not

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accessible. It gets to continue to
operate until the new one is constructed

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and open as long as it's within a
three-year period. So there are some

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interpretive things like that. And I I
should mention staff training. It wasn't

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one of the slides, but um we in our
response to WCOG offered

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um to each quad two free staff frames.
So one will be on infrastructure and it

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will review real life disputes and what
the requirements are and the other will

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be on program and policy issues. So, we
had originally thought that we would

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offer all those toward the end of the
project. We're not going to do that.

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We're going to offer them as a part of
each quad. So, sometime around the end

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of this first quad, we'll work with
Westcog to schedule both a program and

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policy training and an infrastructure
training and it'll address questions

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exactly like that.
And you can feel free to go to the

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training that's for quad four or for
quad one or go go go to all eight of

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them if your staff want to. Yes. Just in
answer to John's question, we did uh

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have a complaint filed on parking. And
what we ended up doing is measuring the

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slope of all of our parking places. The
library had to repave an area in order

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to be in compliance and it wasn't off
that much.

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Um, we had to restripe several areas and
there's a conflict with uh DOJ in the

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state of Connecticut relative to the
signs. Yes. Uh there's a federal sign

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and a state sign. And we had just
ordered all the state signs thinking we

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were doing the right thing and they said
no, they're not allowable. But

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apparently at the end they've allowed us
to go with those until we replace them

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with the new federal. Yeah, there is
that. The Connecticut sign is for those

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who haven't seen it, it's the more
mobile looking racing figure

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icon. The the argument from the DOJ side
is that that standard sitting icon has

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been around for 45 50 years and it's
recognized by everybody. So why why mess

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with something that everybody knows what
it looks like? It's kind of like

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changing the logo for Coca-Cola, I
guess, for exit signs in Connecticut.

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Exactly. Well, I'll take your word for
that. Um, we would lean

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towards the Connecticut sign as being
more stringent because it's different

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than the federal sign, but I'm not the
Department of Justice, but we would lean

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towards that. We've seen signs like
that. We've seen different size striping

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for accessible parking. So that's a a
key part of this too. You have to meet

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whichever is more stringent the federal
requirement for the the and it's been

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two years and just now our attorney sent
hopefully is the final agreement back

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that we owe J. Yeah. Can you have both I
mean it seems silly but can you have

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both federal and state signage? You can
but I don't I don't think you'd want in

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the same spot. I'm not saying I want any
issue right now. I also don't want

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people getting sued. Right. I am also
don't want people with suits and guns

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showing up. So, well, just it's not that
bad. You know, relief under the ADA is

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injunctive in nature. So, if you put up
the the racing icon sign for parking and

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somebody does file a complaint, the
worst that's going to happen is that

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you're going to be told to replace it
with the I'm standing still in my

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wheelchair sign until the state of
Connecticut shows up and says, "Where is

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the racing sign?"
Yes. John, I'm wondering how you

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selected the grouping towns because for
instance our two towns are the tiny

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towns where stride New Milford why
wouldn't we all be in the same spot I I

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know and I' I've driven through both on
the way to New Milford

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um some of it was readiness um if we had
a complete site list from New Milford

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then that elevated them to quad one u I
think we are still lacking I'm looking

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for
uh I think we're still lacking a couple

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of site list but that's fine there's
another 18 months of project so that

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would factor as well

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others just there's no state of
Connecticut DOJ right I don't believe

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are that enforcing yeah I don't I don't
believe so there is a Connecticut human

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rights act um and some states like
Illinois where we are headquarters

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uh the attorney general's office does
have a disability rights bureau and they

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do go out and enforce Illinois
requirements as well as the ADA

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requirements too. The final question I
have is when we do a capital project are

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we in fact required to allocate 20% of
that cap capital project to ADA

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compliance? So that's a good
question. One of the crystal clear

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pieces of the ADA is that if it is new
construction, it must be fully

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compliant. But if it is an alteration or
let's say it's an addition to this

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building, if there's an addition to this
building, then the addition must be

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fully
compliant, then

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20% is allocated to the path of travel.
So, think like you're a wheelchair user.

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Path of travel starts as you're pulling
into the parking lot. So, I've got to

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have accessible parking. There's got to
be accessible signage. I've got to be

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able to get to the door on a slope that
doesn't exceed 5%. There's got to be a

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level landing there. The door's got to
open with less than 8.5 pounds of force.

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I've got to be able to get in there,
maneuver through the hallway, find this

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door, open it with less than five pounds
of force. So all of that could add up to

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the 20% depending on the type of
addition that you're using. So I would

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say the answer to your question is no,
unless it's an addition or an

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alteration. But if it's new
construction, it's going to be fully

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compliant. And I will guarantee you that
for some of you who have new

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construction, we will find things that
are not compliant. Access is a function

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of did the designer get it right? Did
the contractor get it right? then you

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know darn well that the interface
between design and construction is never

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perfect. And then are your own team
maintaining the asset correctly? So all

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three of those factors can make a site
not be

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accessible. The standard of
accessibility change over time. So, if I

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built a new building that was ADA
compliant at the time it was uh received

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its CO and I maintained it, can I expect
it to stay in compliance or uh are there

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changes to the regulations that we have
to understand and um that could

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potentially take a certified building or
an ADA compliant building and uh make it

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out of compliance? No. So the standard
the design standards have changed just

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twice 1991 and then in 2010 in a normal
world I'd say look for a change around

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2030. Um so that's typically then the
cycle. So you're just held to the

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standard that was in existence when the
building was constructed. Correct. So

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it's called the concept of safe harbor.
If you diligently made sure that the

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1999 building complied with the 1991
standards and then the size of the

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restroom changed in 2010 or the height
of reach range for operating mechanisms

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like light switches changed in 2010, as
long as yours were compliant with the

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1991 standard, you don't have to go back
in and change it. So reach range was

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allowed to be 54 in. So when we audit,
if we know the building was built in

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1999, but your light switches are at 56
in, not 54 in, you fail. And now it's

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got to go down to 48 in, not 54 in. Does
that make sense? So safe harbor applied,

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but I mentioned that park assets were
not included until 2010. There's no safe

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harbor for park assets, but there is for
the

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Thank you, John. Thank you all very
much. And when do you expect to wrap up

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the uh project? What is the timeline on
that? Summer 2026.

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Yeah, late summer.
Thank you. Thank you. Appreciate it.