HomeMy WebLinkAbout03/15/2005, C7 - RESOLUTION ADOPTING THE NOTICE AND GRIEVANCE PROCEDURE UNDER THE AMERICANS WITH DISABILITIES ACT counat
j acEnaa Report
CITY OF SAN LUIS OBISPO
FROM: Monica M. Moloney, Director of Human Resources`M _
SUBJECT: RESOLUTION ADOPTING THE NOTICE AND GRIEVANCE PROCEDURE
UNDER THE AMERICANS WITH DISABILITIES ACT
CAO RECOMMENDATION
Adopt and distribute the Notice Under the Americans with Disabilities Act and Grievance
Procedure Under the Americans with Disabilities Act per the Settlement Agreement between the
City of San Luis Obispo and the United States Department of Justice (USDOJ) effective
December 14, 2004.
DISCUSSION
On November 20, 2003 Mayor Romero received a letter from Dana Jackson, Specialist, Disability
Rights Section of the USDOJ informing him that the City of San Luis Obispo had been selected to
participate in their "Project Civic Access" (PCA) initiative. The letter explained that the USDOJ,
Civil Rights Division, Disability Rights Section is working with local governments around the
country to assist them in coming into full compliance with Title lI of the Americans with
Disabilities Act of 1990 (ADA), 42 U.S.C. §§ 12131-12134, and the Department's implementing
regulation, 28 C.F.R. Part 35. Mr. Jackson informed staff that the City was selected based on its
demographics,not because the USDOJ had received any citizen complaints.
In preparation for the USDOJ audit, the Human Resources Director formed a committee of City
employees that could provide information concerning the areas of review. At the end of a three day
on-site review in January 2004, Mr. Jackson complimented the City on its progressive approach to
providing equal access to people with disabilities. In addition, Mr. Jackson praised the City for its
cooperation in the audit. Mr. Jackson also compiled a list of areas of non-compliance with ADA
regulations and the timeframes in which the City would be required to reach compliance. Staff
reviewed the proposal and made a counter proposal asking for additional time, which was
subsequently granted by the USDOJ. A Settlement Agreement between the USDOJ and the City of
San Luis Obispo was approved by Council on September 7,2004 and went into effect on December
14, 2004 when the USDOJ signed the agreement.
The agreement includes a variety of provisions such as modifications to policies and procedures,
signage, and facilities over the course of the next three years. Each provision is assigned a
completion date and the City is required to provide the USDOJ with a summary report annually
during the three year period. The Notice (Exhibit A) states that the City will not discriminate
against qualified individuals with disabilities on the basis of disability in the City's services,
programs, or activities. The Grievance Procedure (Exhibit B) establishes a formal procedure for
those alleging discrimination on the basis of disability in the provisions of services, activities,
Resolution Adopting Notice and Grievance Procedure Under the Americans With
Disabilities Act Page 2
programs, or benefits by the City. The Notice and Grievance Procedure must be adopted and
distributed prior to June 30, 2005.
FISCAL IMPACT
The fiscal impact is minimal because the distribution of the Notice and Grievance Procedure can
be done internally and electronically with the exception of the requirement to run one
advertisement in a local paper. There are adequate funds in the Human Resources' budget to pay
for advertisements.
ALTERNATIVES
Council could elect not to adopt these documents, however, staff advises against that option
because the City entered into the Settlement Agreement with the USDOJ in good faith. Adoption
of the Notice and Grievance Procedure are part of the Settlement Agreement.
ATTACHMENTS
1. Resolution
(Exhibit A) Notice Under the Americans with Disabilities Act
(Exhibit B) Grievance Procedure Under the Americans with Disabilities Act
GAagenda reports\ADANotice&GrvncPrcdr.doc
A BHT 1
Page 1 of 2
RESOLUTION NO. (2005 Series)
A RESOLUTION OF THE COUNCIL OF THE CITY OF SAN LUIS OBISPO
ADOPTING THE UNITED STATES DEPARTMENT OF JUSTICE (USDOJ) "NOTICE
UNDER THE AMERICANS WITH DISABILITIES ACT (ADA)" AND ADOPTING
"THE CITY OF SAN LUIS OBISPO'S GRIEVANCE PROCEDURE UNDER THE
AMERICAN WITH DISABILITIES ACT (ADA)"
WHEREAS, the City of San Luis Obispo entered into a Settlement Agreement with the
USDOJ on December 14, 2004;
WHEREAS, the Settlement Agreement stipulates the City of San Luis Obispo will
formally adopt the USDOJ Notice Under the ADA (Exhibit A) by June 14, 2005;
WHEREAS, the Settlement Agreement further stipulates the City of San Luis Obispo
will formally adopt The City of San Luis Obispo's Grievance Procedure Under the ADA (Exhibit
B)by June 14, 2005;
WHEREAS, the City of San Luis Obispo intends to comply with the Settlement
Agreement and adoption of the Notice and Grievance Procedure are steps toward full
compliance;
NOW, THEREFORE, BE IT RESOLVED by the Council of the City of San Luis
Obispo that it hereby approves the USDOJ Notice Under the ADA and approves the City of San
Luis Obispo's Grievance Procedure Under the ADA.
Upon motion of , seconded by ,
and on the following vote:
AYES:
NOES:
ABSENT:
The foregoing resolution was adopted this 15"' day of March 2005.
Mayor David F. Romero
ATTEST:
Audrey Hooper
City Clerk
R �� 3
Ar"ACHMENT 1
Ps ,2 of 2
Resolution No. (2005 Series)
Page 2
APPROVED AS TO FORM:
Jonathal P. well
City Attorney
Magenda repo tAResolution-ADA Notice and Grievance Procedure.doc C•�� [�
EXHIBIT A
;e 1 of 2
NOTICE UNDER THE AMERICANS
WITH DISABILITIES ACT
d..
In accordance with the requirements of title II of the Americans
with Disabilities Act of 1990, the City will not discriminate against
qualified individuals with disabilities on the basis of disability in
the City's services, programs, or activities.
Employment. The City does not discriminate on the basis of disability in its hiring or
employment practices and complies with all regulations promulgated by the U.S. Equal
Employment Opportunity Commission under title I of the Americans with Disabilities
Act(ADA).
Effective Communication: The City will generally, upon request, provide appropriate
aids and services leading to effective communication for qualified persons with
disabilities so they can participate equally in the City's programs, services, and activities,
including qualified sign language interpreters, documents in Braille, and other ways of
making information and communications accessible to people who have speech, hearing,
or vision impairments.
Modifications to Policies and Procedures: The City will make all reasonable
modifications to policies and programs to ensure that people with disabilities have an
equal opportunity to enjoy all City programs, services, and activities. For example,
individuals with service animals are welcomed in City offices, even where pets are
generally prohibited.
Anyone who requires an auxiliary aid or service for effective communication, or a
modification of policies or procedures to participate in a City program, service, or
activity, should contact the ADA Coordinator, at (805) 781-7250 as soon as possible but
no later than 48 hours before the scheduled event.
The ADA does not require the City to take any action that would fundamentally alter the
nature of its programs or services, or impose an undue financial or administrative burden.
S�
EffiBIT A
Page 2 of 2
Complaints that a City program, service, or activity is not accessible to persons with
disabilities should be directed to:
ADA Coordinator
c/o Department of Human Resources
City of San Luis Obispo
990 Palm Street
San Luis Obispo, CA 93401
The City will not place a surcharge on a particular individual with a disability or any
group of individuals with disabilities to cover the cost of providing auxiliary aids/services
or reasonable modifications of policy, such as retrieving items from locations that are
open to the public but are not accessible to persons who use wheelchairs.
C:\DDNME-I4louscrU.00ALS-1\TempWOTICEUNDER THE AMERICANS WITH DISABD..i7'ES ACT.dnc _ l
EffiBIT B
Page 1 of 2
City of San Luis Obispo
Grievance Procedure Under
The Americans with Disabilities Act
This Grievance Procedure is established to meet the requirements of the Americans with
Disabilities Act of 1990. It may be used by anyone who wishes to file a complaint
alleging discrimination on the basis of disability in the provision of services, activities,
programs, or benefits by the City. The City's Personnel Policy governs employment-
related complaints of disability discrimination.
The complaint should be in writing and contain information about the alleged
discrimination such as name, address, phone number of complainant and location, date,
and description of the problem. Alternative means of filing complaints, such as personal
interviews or a tape recording of the complaint will be made available for persons with
disabilities upon request.
The complaint should be submitted by the grievant and/or his/her designee as soon as
possible but no later than 60 calendar days after the alleged violation to:
ADA Coordinator
c/of Department of Human Resources
City of San Luis Obispo
990 Palm Street
San Luis Obispo, CA 93401
Within 15 business days after receipt of the complaint, the ADA Coordinator or his/her
designee will meet with the complainant to discuss the complaint and the possible
resolutions. Within 15 business days of the meeting, the ADA Coordinator or his/her
designee will respond in writing, and where appropriate, in format accessible to the
complainant, such as large print, Braille, or audio tape. The response will explain the
position of the City and offer options for substantive resolution of the complaint.
If the response by the ADA Coordinator or his/her designee does not satisfactorily
resolve the issue, the complainant and/or his/her designee may appeal the decision within
15 business days after receipt of the response to the City Administrative Officer or his/her
designee.
Within 15 business days after receipt of the appeal, the City Administrative Officer or
his/her designee will meet with the complainant to discuss the complaint and possible
resolutions. Within 15 business days after the meeting, the City Administrative Officer
or his/her designee will respond in writing, and, where appropriate, in a format accessible
to the complainant, with a final resolution of the complaint.
EXHIBIT B
Page 2 of 2
All written complaints received by the ADA Coordinator or his/her designee, appeals to
the City Administrative Officer or his/her designee, and responses from these two offices
will be retained by the City for at least three years.
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