City of Willmar ADA Plan
City of Willmar ADA Plan
City of Willmar ADA Plan
November 2020
Prepared by:
Bolton & Menk, Inc.
2040 US-12
Willmar, MN 56201
P: 320-231-3956
[email protected]
Table of Contents
I. Introduction ................................................................................................................ 1
A. Transition Plan Need and Purpose ........................................................................ 1
B. ADA and its Relationship to Other Laws ................................................................ 1
C. Agency Requirements ............................................................................................ 1
II. Self-Evaluation ............................................................................................................ 2
A. Overview ................................................................................................................ 2
B. Methodology ......................................................................................................... 2
C. Severity ................................................................................................................. 4
D. Summary ................................................................................................................ 4
III. Policies and Practices.................................................................................................. 5
A. Previous Practices .................................................................................................. 5
B. Policy ...................................................................................................................... 5
IV. Implementation Plan .................................................................................................. 6
A. Priority Areas ......................................................................................................... 6
B. External Agency Coordination ............................................................................... 7
C. Cost Estimates........................................................................................................ 7
D. Implementation Schedule...................................................................................... 8
V. ADA Coordinator......................................................................................................... 9
VI. Public Outreach .......................................................................................................... 9
VII. Grievance Procedure .................................................................................................. 9
VIII. Monitor the Progress ................................................................................................ 10
Appendix
Appendix A: Deficiencies
Appendix B: Self-Evaluation
Appendix C: ADA Transition Plan Projects referenced from the City of Willmar Capital
Improvements Plan
Appendix D: Public Outreach Results
Appendix E: Grievance Procedure
Appendix F: ADA Coordinator Contact Information
Appendix G: ADA Design Standards and Procedures
II. SELF-EVALUATION
A. Overview
The City of Willmar is required, under Title II of the Americans with Disabilities Act (ADA)
and 28 C.F.R Sec. 35.105, to perform a Self-Evaluation of current transportation
infrastructure policies, practices, and programs. A Self-Evaluation identifies what policies
and practices impact accessibility and examines how the City implements these policies. The
goal of the Self-Evaluation is to verify that, in implementing the City’s policies and practices,
the City is providing accessibility and not adversely affecting the full participation of
individuals with disabilities.
The Self-Evaluation also examines the condition of the City’s Pedestrian Circulation
Route/Pedestrian Access Route (PCR/PAR) and identifies potential need for PCR/PAR
infrastructure improvements. These include the sidewalks, curb ramps, bicycle/pedestrian
trails, traffic control signals, and transit facilities that are located within the City public
rights-of-way. Any barriers to accessibility are identified in the Self-Evaluation and actions to
remedy noted barriers are described in this document. Pedestrian facilities were evaluated for
ADA deficiencies throughout the City. Pedestrian facilities located within MN Department of
Transportation (MnDOT) or Kandiyohi County right-of-way were not included in this
evaluation unless a cost-share agreement exists between the City and those agencies for the
maintenance/reconstruction of facilities.
B. Methodology
The Self-Evaluation field data inventory began in mid-June 2020 and concluded in mid-
August 2020. During this time, Bolton & Menk inventoried components of the PCR/PAR
environment using the latest GPS technology to collect field data for pedestrian infrastructure
features. Data was imported into Esri ArcGIS for analysis, reporting, and mapping as part of
the Transition Plan. ADA accessibility evaluation included the following:
Rating Criteria
Uniform slopes, no noticeable cracks, no vertical discontinuities, no spalling,
1
joints intact
Uniform slopes, some cracks, vertical discontinuities less than 1/4", no
2
spalling, joints intact
Gutter slope beyond flare flows back towards curb ramp at < 1.5%, some large
3 cracks and minor spalling, noticeable vertical discontinuities, joints beginning
to deteriorate, no detectable warnings
Gutter slope beyond flare flows back towards curb ramp at > 1.5%, many
cracks, multi-directional, excessive spalling, excessive vertical discontinuities,
4
joints badly deteriorated, > 1/2" vertical discontinuities, no detectable
warnings
To achieve ADA-compliance, a pedestrian ramp must achieve a condition rating of 1 or 2 and
also must exhibit the following:
Slope is less than 8.34%
Cross slope is less than or equal to 2%
Presence of a landing area greater than or equal to 4-feet by 4-feet and less than or
equal to 2% cross slopes in all directions.
An ADA-compliant detectable warning* is present (i.e. truncated domes, brushed
concrete, etc.)
Pedestrian ramps receiving a condition rating of 3 or 4 and not exhibiting the above criteria
are not compliant with ADA and are candidates for future reconstruction projects. The
timeline for modification of each of these pedestrian ramps will depend on its priority
ranking, correlation to planned projects, reasonable accommodation requests, and available
funding.
*A note on detectable warnings: Current guidance from the US Access Board and ADA
standards require the use of truncated domes as the only acceptable detectable warning for
new ramp construction. However, MnDOT does not require agencies to retrofit truncated
domes into ramps where brushed concrete, exposed aggregate, or another detectable warning
that was previously acceptable under standards at that time were employed. Ramps were
identified as compliant if one of these types of detectable warnings were present and all other
ramp elements were compliant.
Compliant and non-compliant pedestrian ramp locations are identified in Appendix B.
Sidewalks and Trails – Sidewalk and trail maintenance issues include vertical
discontinuity, gaps, steep cross slope, cracking, standing water, vegetation, spalling,
and others. Barriers to accessibility include items obstructing the PAR which could
include hydrants, lighting/traffic signal poles, power poles, manhole/handhole, valve
boxes, and locations with a narrowed PCR/PAR among others (Appendix A).
Rating Condition
1 Sidewalk is smooth with no vertical discontinuities
Sidewalk has vertical discontinuities less than 1/2 inch, and the surface is still
2
passable
3 Sidewalk has vertical discontinuities more than 1/2 inch
Sidewalk is crumbling, has many cracks, and is unpassable for wheelchairs in
4
many spots
To achieve ADA-compliance, a sidewalk or trail must achieve a condition rating of 1 or 2 and
also must exhibit the following:
Sidewalk width is 5-feet or greater
Cross slope is less than or equal to 2%
Sidewalk and trail segments exhibiting condition ratings of 3 or 4 and not exhibiting the
above criteria are not compliant with ADA and are candidates for future reconstruction
projects.
Crosswalks – Crosswalks were evaluated for their general condition. Marked
crosswalk locations were assessed for marking visibility issues and pavement
condition.
Traffic Signals – Available pedestrian signals were inventoried for APS (Accessible
Pedestrian Signal) availability, walk signal availability or countdown timers, and
push button location. Traffic signals were categorized as APS and Non-APS
locations.
C. Severity
The severity of non-compliance aims to determine which facilities pose the greatest barriers
to accessibility. In instances where a facility failed in multiple measures of accessibility due
to poor condition, these facilities would be deemed mostly inaccessible and considered a
higher severity of non-compliance. These projects would be the highest priority for
implementation. Facilities failing on a lesser level, such as a slope measurement that
minimally exceeds the standard, would be of lower priority. The specific methods of
calculating the severity ratings are found in Appendix B.
D. Summary
The City of Willmar conducted the Self-Evaluation review of programs from June - August
2020. This included an inventory of pedestrian facilities within public rights-of-way. Figure
1 shown below provides a summary of ADA compliance among pedestrian facilities in
Willmar.
30%
68%
94%
99%
70%
32%
6%
PEDESTRIAN RAMPS SIDEWALK SIGNAL CROSSWALK
1. Compliant 2. Non-Compliant
Figure 1. Pedestrian facility ADA compliance in Willmar resulting from the Self-Evaluation.
V. ADA COORDINATOR
In accordance with 28 CFR 35.107(a), the City of Willmar has identified an ADA Title II
Coordinator to oversee the City’s policies and procedures. Contact information for this individual
is in Appendix F.
Appendix B | Page 1
3. City of Willmar Comprehensive Plan: Trails & Pedestrian Plan Addendum (2011)
Safe and convenient non-motorized travel provides many benefits, including reduced traffic
congestion, user cost savings, road and parking facility savings, economic development, a better
environment, and better health to those who participant. The ultimate goal of transportation is to
provide access to goods, services and activities. In general, the more transportation options available,
the better the access.
It is also important to remember that a significant number of the community’s population are unable
to drive, and thus, are very dependent on a good non-motorized public transportation system. To be
a more livable community, it is vital that everyone, regardless of age or ability, has a means to travel
safely.
“The City of Willmar will develop and maintain an interconnected bicycle and pedestrian system
where residents and visitors have safe, accessible, and convenient options to meet their needs.”
Chapter 4 in the Trails and Pedestrian Plan Addendum has a list of short-term, mid-term, and long-
term projects for trails, bicycle routes, and pedestrian safety addressing enhancements in the
transportation system.
Policy Understanding and Recommended Revision:
The following revision to this policy is recommended as part of this review:
b. Amend the Plan to include policies for the compliant design of pedestrian facilities
based on best practices outlined in the Public Rights-of Way Accessibility Guidelines
(PROWAG) as adopted by MNDOT.
4. City of Willmar Comprehensive Plan (2009)
a) Chapter Four: Current and Emerging Issues – Transportation
Pedestrian safety - Pedestrian concerns should be at the forefront of all planning and
development activities. Trails, paths, and bike lanes emphasizing connectivity were identified by
the public during the Plan’s various meetings.
b.) Chapter 5: Goals, Objectives, and Policies – Transportation
Develop a transportation system that properly balances considerations of safety, cost,
accessibility and environmental protection.
Develop a transportation system that properly integrates all modes of transportation.
Policy Understanding and Recommended Revision:
The following revision to this policy is recommended as part of this review:
c. Amend the Plan to include policies for the compliant design of pedestrian facilities
based on best practices outlined in the Public Rights-of Way Accessibility Guidelines
(PROWAG) as adopted by MNDOT.
5. City of Willmar City Code
This plan addresses construction guidelines and design requirements for sidewalks in the city. Chapter
13, Article III, Sec. 13-66 through 13-70 provides the requirements for repair and construction
requirements. This section states that plans are required to be submitted for any sidewalk work and
Appendix B | Page 2
work will be completed under the direct supervision and inspection of the Director of Public Works in
accordance with plans and specifications approved by the City.
Policy Understanding and Recommended Revision:
The Willmar City Code outlines the City will supervise and inspect sidewalk construction per plans and
specifications approved by the City which can be viewed in Appendix G of this ADA Transition Plan.
Appendix G identifies ADA standards followed by the City. No revisions are recommended to the City
Code.
Review of Programs
The City of Willmar inventoried pedestrian ramps and sidewalks within the public rights-of-way
beginning in June of 2020 and ending in August 2020. The following provides the results of that
inventory:
1. Pedestrian Ramps
The City of Willmar has 1626 locations where pedestrian ramps exist or should exist within its
public rights-of-way. These locations were inventoried for ADA accessibility based on (1)
whether a pedestrian ramp was present and (2) if accessibility criteria outlined in Part 1 Sec.
III were met. 523 (32%) of the locations were reported to be compliant and 1103 (68%) were
reported to be non-compliant.
2. Sidewalks/Trails
The sidewalks and trails within the City of Willmar public rights-of-way were inventoried and
evaluated to determine existing accessibility with ADA and to identify existing obstructions
based on accessibility criteria outlined in Section II of this transition plan. Of the nearly 72.1
miles of sidewalk evaluated, roughly 21.6 miles (30%) had a condition rating of three or four
meaning they exhibited instances of non-accessibility along their length and require further
evaluation and remedial action.
3. Crosswalks
Crosswalks were inventoried and evaluated for the quality of markings. Of 119 crosswalks
evaluated, 1 (1%) were identified as non-compliant due to markings that were faded or
partially removed or because pavement within the crossing exhibited deficiencies.
4. Traffic Signals
Available pedestrian signals were inventoried for APS availability, walk signal availability or
countdown timers, and push button location. Of 78 signals evaluated, 73 (94%) were
identified as non-compliant due to missing APS.
Compliant and non-compliant pedestrian infrastructure is illustrated in Figures B.1 through B.28.
The timeline for replacement of these sidewalks and trails will depend on priority ranking,
correlation to planned projects, reasonable accommodation requests, and available funding. A
detailed list of these instances may be obtained upon request to the City of Willmar ADA
Coordinator (Appendix F).
Appendix B | Page 3
Table B.1 provides an implementation plan for the prioritized removal of barriers to accessibility
throughout the City as identified in this plan.
Figure B.29 details how severity scores are calculated for each item collected in the inventory.
Appendix B | Page 4
Figures B.1 to B.28 – City of Willmar ADA Accessibility
Appendix B | Page 5
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Table B.1. City of Willmar Program Review Implementation Plan
8TH ST SW Schools; Parks; Shopping Malls, Supermarkets, Strip Retail Centers $ 20,955 $ 132,000 $ $ $ 8,750 $ 161,705 1 2 Mid Term
Pedestrian Ramp
Ramp Present Ramp Missing
Missing Ramp
0 10
Below criteria will not apply if ramp is missing:
CR 1 CR 2 CR 3 CR 4
Ramp Condition Rating
0 0 1 2
CR 1 CR 2 CR 3 CR 4
Gutter Condition
0 0 1 2
Crosswalks
CR 1 CR 2 CR3 CR4
Pavement Condition
0 0 3 4
Marking Present Marking Missing
Marking Present
0 4
Crosswalk Score Range 0 10
Signals
Yes No
APS Present
0 10
Signal Score Range 0 10
A median severity rating will be produced for any given project area. For point features (e.g. pedestrian ramp), the median
severity value of all individual ratings will be used. For line features (e.g. sidewalk), the median is weighted based on the linear
footage of sidewalk segments.
Appendix C: ADA Transition Plan Projects
referenced from the City of Willmar Capital
Improvements Plan
Appendix C | Page 1
The City will continue to implement infrastructure and maintenance improvements as part of its
CIP planning and pavement management plan. With these efforts, the City will incorporate ADA-
compliant pedestrian facilities and complete accessible infrastructure improvements as needed to
ensure access for all users.
Appendix C | Page 2
Appendix D: Public Outreach Results
Appendix D | Page 1
o Willmar Main Street
o Willmar Lakes Area Convention & Visitors Bureau
o City/County Economic Development Commission
o Park & Recreation Board
o Willmar Planning and Zoning
Appendix D | Page 2
Interactive Map
Figure D.1
The images above show snapshots of the interactive map. One comment was received on the map,
which stated that “sidewalks along 15th St SW are in terrible condition, [and are] difficult to walk
even as a sighted person.” No other comments were made on this map.
Appendix D | Page 3
Survey Results
Two people completed the survey soliciting feedback on the ADA Transition Plan. Their responses are
recorded below and attached to this appendix.
Response #1:
1. Which physical access improvements should be the highest priority to improve physical access
in the City of Wilmar? (Please rank: 1-6 with 1 as the most important)
1. Sidewalks
2. Curb Ramps
3. Parking
4. Parks
5. Traffic Signals
6. Trails
7. Bus Stops
2. Please describe any other areas or locations that pose barriers to your day-to-day travel.
No Answer
3. Are there areas of the plan that you believe are lacking in clarity? If yes, please describe.
No Answer
4. Is there anything that isn’t included in the plan that should be? If yes, please describe.
No Answer
5. Name
Sean Christensen
6. Email
[email protected]
7. Address
333 6th St SWm, Willmar MN 56201
Response #2:
1. Which physical access improvements should be the highest priority to improve physical access
in the City of Wilmar? (Please rank: 1-6 with 1 as the most important)
1. Parking
2. Sidewalks
3. Curb Ramps
Appendix D | Page 4
4. Traffic Signals
5. Trails
6. Parks
7. Bus Stops
2. Please describe any other areas or locations that pose barriers to your day-to-day travel.
No Answer
3. Are there areas of the plan that you believe are lacking in clarity? If yes, please describe.
No Answer
4. Is there anything that isn’t included in the plan that should be? If yes, please describe.
No Answer
5. Name
Rob Baumgarn
6. Email
[email protected]
7. Address
Willmar
Appendix D | Page 5
Open Comment Box
One comment through the comment box was received. The message is recorded below:
Message Body:
I am not disabled. But I and many others, including a disabled pedestrian on a scooter, try to cross 19th
Ave SW most everyday. It is dangerous. Cars rarely slow down or stop for people trying to cross and
they will fly by either right in front of you or right behind you within seconds.
I feel it would be very helpful to all pedestrians, able-body and disabled, to have a couple of crosswalks
along 19th with lights that can be activated when someone would like to cross. I think lights and a
crossing like the crossing west on 19th at 21st or 22nd St SW would work well. Great locations would
be at 9th St SW (by Caseys) where crossing would allow easier access to Ramblewood Park from south
of 19th Ave SW and at 6th St SW to allow easier access to Hilltop Park from the north side of 19th Ave
SW. I suggest this intersection as it is a straight across intersection and spaced nicely between 1st St S
and 9th St SW.
It would be great to see the safety of crossing this road addressed.
Thank you.
Appendix D | Page 6
Appendix E: Grievance Procedure
In accordance with 28 CFR 35.107(b), the City of Willmar has developed the following ADA grievance
procedure for the purpose of the prompt and equitable resolution of citizens’ complaints, concerns,
comments, and other grievances.
The City understands that members of the public may desire to contact staff to discuss ADA issues
without filing a formal grievance. Members of the public wishing to contact the ADA Coordinator should
reference the contact information in Appendix F. Contacting staff to informally discuss ADA issues is
welcome and does not limit a person’s ability or right to file a formal grievance later.
Those wishing to file a formal written grievance with the City of Willmar may do so by one of the
following methods:
Internet
Visit the City’s website to access an interactive pdf form or download a paper copy of the grievance
form.
The City of Willmar Website: https://www.willmarmn.gov/
Telephone
Contact the City of Willmar’s ADA Coordinator listed in the Contact Information section of
Appendix F to submit an oral grievance. The staff person will use the internet to electronically
submit the grievance on behalf of the person filing it.
Paper Submission
A paper copy of the City’s grievance form is available by request from the City of Willmar ADA
Coordinator (contact information in Appendix F). Complete the form and submit it to the City ADA
Coordinator at the address listed.
The City of will acknowledge receipt of the grievance to the citizen within 10 working days of the
submission. City staff will then provide a response or resolution to the grievance or will provide
information on when the citizen can expect a response. If the grievance filed does not fall within
the City of Willmar’s jurisdiction, staff will work with the citizen to contact the agency with
jurisdiction.
When possible (typically within 60 calendar days or less of the grievance submission) City staff will
conduct an investigation to determine the validity of the alleged violation. As a part of the
investigation, internal staff will be consulted to fully understand the complaint and possible
solutions. City staff will contact the citizen to discuss the investigation and proposed resolution.
Appendix E | Page 1
The City of Willmar will consider all grievances within its particular context or setting. Furthermore,
the department will consider many varying circumstances including: access to applicable services,
programs, or facilities; the nature of the disability; essential eligibility requirements for
participation; health and safety of others; and degree to which a potential solution would
constitute a fundamental alteration to the program, service, or facility, or cause undue hardship to
the City of Willmar.
Accordingly, the resolution by the City of Willmar of any one grievance does not constitute a
precedent upon which the City is bound or upon which other complaining parties may rely.
Complaints of Title II violations may be filed with the Department of Justice (DOJ) within 180 days
of the date of discrimination. In certain situations, cases may be referred to a mediation program
sponsored by the DOJ. The DOJ may bring a lawsuit where it has investigated a matter and has
been unable to resolve violations.
Title II may also be enforced through private lawsuits in Federal court. It is not necessary to file a
complaint with the DOJ or any other Federal agency, or to receive a "right-to-sue" letter, before
going to court.
File Retention
The City of Willmar shall maintain ADA grievance files on behalf of the City for a period of seven
years.
Appendix E | Page 2
The City of Willmar, MN ADA Grievance Form
Instructions: Please fill out this form completely and submit to:
Sean Christensen
The City of Willmar, City Engineer – ADA Coordinator
333 Southwest 6th Street
Willmar, Minnesota 56201
Representing – person claiming an accessibility issue or alleging and ADA violation (if not the complainant):
Name: ___________________________
Description and location of the alleged violation and the nature of a remedy sought.
__________________________________________________________________________________________
__________________________________________________________________________________________
__________________________________________________________________________________________
__________________________________________________________________________________________
__________________________________________________________________________________________
If the complainant has filed the same complaint or grievance with the United States Department of Justice
(DOJ), another federal or state civil rights agency, a court, or others, the name of the agency or court
where the complainant filed it and the filing date.
Appendix E | Page 3
Appendix F: ADA Coordinator Contact
Information
Appendix F | Page 1
Appendix G: ADA Design Standards and
Procedures
3. Accessible Public Rights-of-Way Planning and Design for Alterations (August 2007)
This report and its recommendations are the work of the Public Rights-of-Way Access
Advisory Committee (PROWAAC) – Subcommittee on Technical Assistance and are intended
to provide technical assistance only. The report is not a rule and has no legal effect. It has not
been endorsed by the U.S. Access Board, the Department of Justice, or the Federal Highway
Administration of the Department of Transportation. Still it can be a technical advisory source
Appendix G | Page 1
for engineers and technicians who are planning and designing for alterations to pedestrian
elements. This document is on the Access Board website (http://www.access-
board.gov) or at http://www.access-board.gov/attachments/article/756/guide.pdf.
4. Minnesota Department of Transportation
Building on the adoption of PROWAG as planning and design guidance for accessible
pedestrian facilities, MnDOT has developed additional planning, design, and construction
guidance that is available to local agencies. Listed below is information on additional design
guidance available. This is not intended to be an exclusive or comprehensive list of ADA
guidance, but rather an acknowledgement of guidance staff should consider and a starting
point for information on providing accessible pedestrian facilities.
The MnDOT Accessibility webpage, which has good information in a variety of subject areas
related to ADA and accessibility, can be found at
http://www.dot.state.mn.us/ada/index.html. The webpage also provides the ability to sign up
for ADA policy and design training classes when available and to review material from
previous trainings.
Curb Ramp Guidelines: http://www.dot.state.mn.us/ada/pdf/curbramp.pdf
ADA Project Design Guide Memo:
http://www.dot.state.mn.us/ada/pdf/adaprojectdesignguidememo.pdf ADA Project Design
Guide: http://www.dot.state.mn.us/ada/pdf/adaprojectdesignguide.pdf
Pedestrian Curb Ramp Details Standard Plans 5-297.250 can be found on MnDOT’s website at
http://standardplans.dot.state.mn.us/
Driveway and Sidewalk Details Standard Plans 5-297.254 can be found on MnDOT’s website
at http://standardplans.dot.state.mn.us/
MnDOT’s 7000 series Standard Plates, which are approved standards drawings, provide
information on standard details of construction and materials related to curbs, gutters, and
sidewalks are on MnDOT’s website at http://standardplates.dot.state.mn.us/stdplate.aspx
The MnDOT Road Design Manual serves as a uniform design guide for engineers and
technicians working on MnDOT projects. The document is available to others as a technical
resource. Chapter 11 – Special Designs, includes information on the design of pedestrian
facilities. The Road Design Manual can be found at
(http://roaddesign.dot.state.mn.us/roaddesign.aspx)
MnDOT’s Pedestrian Accommodations Through Work Zones webpage,
http://www.dot.state.mn.us/trafficeng/workzone/apr.html contains information on providing
accessibility during impacts due to maintenance or construction activities.
Appendix G | Page 2
Design Procedures
1. Intersection Corners
The City of Willmar will attempt to construct or upgrade pedestrian curb ramps to be
consistent with Access Board recommended designs parameters and MnDOT ADA design
guidance and procedures to the extent feasible within all capital reconstruction projects.
There may be limitations which make it technically infeasible for the City to achieve these
goals at an intersection corner within the scope of any project. Those limitations will be noted
and the intersection corners will be constructed to maximize accessibility to the extent
feasible within the project scope. As future projects or opportunities arise, additional
improvements at these locations may be incorporated into subsequent projects. The City will
strive to ensure that each intersection corner is constructed to be as accessible as possible.
2. Sidewalks / Trails
The City of Willmar will attempt to construct or upgrade sidewalks and trails to be consistent
with Access Board recommended designs parameters, MnDOT ADA design guidance and
procedures to the extent feasible within all capital improvement projects. There may be
limitations which make it technically infeasible for the City to achieve these goals within all
segments of sidewalks or trails within the scope of any project. Those limitations will be
noted and those segments will be constructed to maximize accessibility to the extent feasible
within the project scope. As future projects or opportunities arise, additional improvements
at these locations may be incorporated into subsequent projects. The City will strive to ensure
that every sidewalk or trail is constructed to be as accessible as possible.
Appendix G | Page 3