Reynoldson, Pixley, Whedbee v. City of Seattle - Class Action Complaint Regarding the Pedestrian Right of Way

OTHER SPECIFIC BARRIERS

49. Exhibit A to this Complaint identifies missing and Inaccessible curb ramps at various locations within the City's pedestrian right of way. Plaintiffs incorporate by reference the entire contents of Exhibit A into this Complaint as though fully alleged herein. The barriers listed in Exhibit A require some form of remediation to meet the City's program access obligations, and/or its obligations to perform new construction and/or alterations in full compliance with federal and state disability access design standards. Some of the barriers identified in Exhibit A are so severe that they constitute safety hazards to persons with mobility disabilities, including curb ramps with running slopes greater than 8.3%.

50. Exhibit A does not represent an exhaustive list of missing and Inaccessible curb ramps. Exhibit A merely provides a partial list of such barriers facing the Named Plaintiffs and class members throughout the City as they attempt to navigate the City's pedestrian routes. Neither the ADA, Section 504, nor state law requires Plaintiffs to identify each and every barrier limiting access to the City's pedestrian routes. Rather, the ADA and Section 504 require the City to complete a transition plan identifying barriers at existing facilities, including those barriers involving curb ramps, crosswalks, and mid-block barriers on sidewalks. The City has failed to comply with these requirements as alleged herein.