ADA Best Practices Tool Kit for State and Local Governments

4. Example: Installing Curb Ramps for Program Accessibility

Consider a case where the streets and sidewalks in a small town were built pre-ADA and have not been altered since. Some intersections have curb ramps; most do not. The town is trying to figure out where to install curb ramps to provide access to the town hall. The accessible entrance to the town hall is located on North Street, which is on the north side of the building. The parking garage that serves the town hall is located on North Street, directly across the street from the town hall’s accessible entrance. Public transportation stops serving the town hall are in a residential neighborhood on East Street, two blocks east of the town hall. The town is evaluating where it needs to install curb ramps to comply with Title II requirements.

Since the town hall and its surrounding streets and sidewalks were built pre-ADA and have not since been altered, the town must install curb ramps in compliance with Title II’s program access requirements for pre-ADA facilities. Under these requirements, the town may choose to install curb ramps at all pedestrian crossings on the sidewalks surrounding the town hall, but it is not necessarily required to do so. A program access approach would require the town to install curb ramps at key pedestrian crossings. To provide access to the town hall, curb ramps would need to be installed at the pedestrian crossings and transportation stops along North and East streets so people with disabilities can travel along a pedestrian route between (1) the accessible entrance to the town hall and the accessible entrance to the parking garage and (2) the accessible entrance to the town hall and the public transportation stops on East Street. In this instance, installing curb ramps at the pedestrian crossings on the south side of the townhall are not needed from a program access perspective to enable people with disabilities to access the town hall. However, they may be needed from a program access perspective for other reasons, such as providing access to other town facilities served by the parking garage or to the town’s business district. The town should seek input from people with mobility disabilities regarding the other key locations where curb ramps need to be installed to provide program access.