Rental Housing Accessibility Survey The first two design requirements of the 1988 Fair Housing Amendments Act The Memphis Center for Independent Living 163 Angelus Street Memphis Tennessee 38104 (901) 726-6404 v/tty (901) 726-6521 fax www.mcil.org Prepared by Tim Wheat tim@mcil.org 1990 Americans with Disabilities Act Community Organizer In cooperation with the Memphis Fair Housing Center Synopsis Local multi-family housing owners and managers must make a concentrated effort to rigorously ensure compliance with the new construction guidelines of the 1988 Fair Housing Amendments Act. Prompt observance of federal law can avoid independent complaints by individual residents as more people with disabilities seek residence in units built after March 1991. Multi-family housing providers, builders, developers and design professionals should examine current procedures to make certain that intended accessible features are included in the final product. Fair housing enforcement must be vigorously pursued to secure universal compliance. Education and public information on the new construction guidelines of the 1988 Fair Housing Amendments Act should be provided to builders and potential residents. Introduction Ten years ago, the Memphis Center for Independent Living (MCIL) found that the state fair-housing laws that are intended to give persons with disabilities more choices in housing were not strictly enforced. At the time of that investigation, the federal 1988 Fair Housing Amendments Act was beginning to take effect. The comprehensive legislation gives people with disabilities greater freedom to choose where they will live and greater freedom to visit friends and relatives. The new construction guidelines focus on creating accessible and usable communities of the future. But the Fair Housing Act has other broad implications. It proactively addresses the needs of an evolving population, looking ahead at future needs. With the aging of the population and the increase in incidence of disability that accompanies aging, significant numbers of people will be able to remain in and safely use their dwellings longer. For example, housing designed in accordance with the Fair Housing Act will have accessible entrances, wider doors, and provisions to allow for easy installation of grab bars around toilets and bathtubs, i.e., features that make housing safer and more responsive to all users [Fair Housing Act Design Manual, HUD 1996 p. 1]. Ten years have passed since these federal protections took effect. MCIL again has appraised the landscape of housing opportunities for persons with disabilities in the Memphis area. This report will summarize MCIL's examination of covered multi-family dwellings in the Memphis area for their compliance with the first two requirements of the 1988 Fair Housing Amendments Act New Construction Guidelines. MCIL 1991 Survey of Accessible Housing In 1979 the State of Tennessee legislated some degree of accessibility in private multi-family housing by adopting the 1976 version of the North Carolina Accessibility Code. MCIL conducted a survey in September of 1991 to determine how well these code changes were improving the accessibility of rental property. The "Survey of Accessible Housing: Memphis Rental Market" [Housing Opportunities Corporation and the Memphis Center for Independent Living. September 1991] consisted of site visits that focused on properties that would have obligations defined by the North Carolina Accessibility Code. The survey found that one-third of the properties had no accessible parking, and "virtually no [accessible] parking was found near common facilities such as pools, club houses, or laundry rooms (p. 23)." The survey also found that "handrails were completely absent from 92 percent of properties observed (p. 23)," and that 45 percent of the complexes did not possess a single ramp. "In approximately 50 percent of the properties," the 1991 survey stated, "no curb cuts were found (p. 23)." Local television news broadcast the survey findings. The news reporters generally stressed the absence of code enforcement as an explanation for the lack of access. During the course of the study, the federal 1988 Fair Housing Amendments Act began to impact newly constructed multi-family rental units. In most cases the comprehensive federal civil rights regulation went far beyond the statutory accessibility codes enforced by city, county and state code enforcement professionals. ANCHOR JOE BIRCH: Is there anything that can be done now to bring those rental properties that don't have the curb cuts, parking and so forth up to code? NEWSROOM DAVID TRUST: Well unfortunately probably only if residents with disabilities, like those at the Center for Independent Living, press the issue. Until then, those properties will remain an option out of the reach of disabled residents (News Channel 5 Broadcast 1991). MCIL Informal Consumer Review In early March 2000, MCIL made an informal poll of consumers' attitudes toward housing. Five questions were asked of people with disabilities about their own experiences with housing. Less than a third (29%) reported they had faced housing discrimination because of a disability, although over 70% said that they have made home modifications to accommodate a disability. About two thirds of MCIL consumers said they have fewer choices in housing because of their disability, and a third (34%) said they lived with a friend or family member because of a disability. Particularly, the appraisal noted the impact that transportation has on housing. MCIL consumers were asked if their choice of places to live would increase with "dependable affordable transportation?" An overwhelming 86% responded positively. MCIL used the informal review to better understand housing issues that concern persons with disabilities. Two MCIL representatives were presenters at the April 14, 2000 Fair Housing Seminar, Break Out Session 2: Housing Issues for Persons with Disabilities and Their Families. 1990 Americans with Disabilities Act Issues Although the ADA does not primarily deal with housing, Title III protects Americans with disabilities in use of "public accommodations". The rental and public facilities offered by housing entities are covered by the 1990 Americans with Disabilities Act and must be accessible and usable by all Americans. In the course of the survey, some ADA concerns were documented. MCIL Executive Director Deborah Cunningham complained to the U. S. Department of Justice (USDOJ) July 6, 2000 that: During our investigation we found that the Rental Office of Champion Hills at Windyke was not accessible to persons with disabilities... The front and main entrance of the rental office of Champion Hills at Windyke has two steps and no ramp to the door. Furthermore, there is no accessible route from public parking to the entrance to the "business center," which is connected to the rental office. The USDOJ referred the case Champion Hills at Windyke & Makowski & Ringel DJ 202-72-0 to the local Assistant U.S. Attorney on October 4, 2000. The resolution of this complaint will determine how MCIL will proceed with enforcement of other ADA concerns found in the course of the survey. Fair Housing events related to the new construction survey A Fair Housing Seminar: Equal Opportunity to Housing for Persons with Disabilities. April 14, 2000. Sponsored by local, state and national organizations, the Fair Housing Conference centered on equal opportunity to housing for persons with disabilities. The conference included an overview of the Fair Housing Act, special protection for persons with disabilities, accessibility, universal design, break out sessions for various groups and a final panel discussion on remedies available under the law. One hundred fifty people attended the seminar at the Cook Convention Center in Memphis. The Fair Housing Conference reached out to individuals with disabilities as well as interested and related agencies. There was no charge for the Conference. The Beginning of Fair Housing Alliance of Greater Memphis (FHAGM). Because of the increase in understanding and interest of the Fair Housing Act, local organizations were successful in creating an alliance of concerned organizations in 1997. With the mission to "work in the Memphis area to promote fair housing and fair lending choices," the Fair Housing Alliance was awarded a "Best Practice" at both the local and regional levels by the U. S. Department of Housing and Urban Development. FHAGM will obtain non-profit status in the March of 2001. The Foundation of the Mayor's Fair Housing Task Force. To get community input for a Memphis Fair Housing Plan, the City of Memphis Mayor appointed a Fair Housing Task Force. One recommendation of the task force is that Memphis "inspect new multi-family residential housing complexes for compliance with the accessibility requirements of the 1988 Amendments to the Fair Housing Act." That recommendation originated from information and experience gathered from the MCIL survey. 1973 Rehabilitation Act Section 504 Issues. In the course of the survey, two public housing providers approached MCIL for assistance with general accessibility. The Tulane and Warren Apartments are not covered under the new construction guidelines. However, they do have obligations for accessibility under the 1973 Rehab Act, Section 504. In addition to consulting with the Section 504 review that these managers made to their properties, MCIL provided each with a supplementary report with documentation of possible expanded access. The "Top Five" Report. In order to have a general view of the survey scope, MCIL's Executive Director Deborah Cunningham asked for a summary report. The aim was to make clear the progress of the survey and the basic areas where barriers were found. To accomplish this goal, an informal "top 5" were named detailing the five properties that clearly showed barriers to equal housing opportunities. A brief Microsoft Power Point presentation was developed that included photos of violations. The "Top 5 Report" was presented to local fair housing professionals to educate selected members of the community that clear violations do commonly exist. The "Top 5 Report" showed a simple method to illustrate current problems in new construction and the power of visual evidence to explain obstructions. Invited Inspections. MCIL was invited to examine the interior of some individual apartments. The residents were trying to understand how the Fair Housing Act applied to their individual situation. MCIL noticed positive and negative aspects of accommodations made to people with disabilities, and made five general written reviews of the interior inspections. Survey Procedure The new construction guidelines of the 1988 Fair Housing Amendments Act intend to create an accessible landscape at rental property. Physical barriers prevent persons with disabilities from accessing housing opportunities similar to typical residents. The general idea of this survey technique was to identify where barriers exist in newly constructed rental properties. Because a barrier is defined in relation to a covered unit, existing Fair Housing assessments started at a covered unit to ascertain related barriers. This survey, however, turned that association around. MCIL proposed to search for on-site barriers and then to logically trace that barrier back to related covered units. The first two design requirements of the Fair Housing Act are ideal for this technique. The first two requirements are: 1. Accessible Building Entrance on an Accessible Route. 2. Accessible and Usable Public and Common Use Areas. These requirements are easily observed, and can be documented with photographs. Likewise, barriers may either impact a single unit or multiple units. Each barrier found by this survey was documented with a photograph to show the general area of the barrier. However, a photograph does not necessarily show more subtle barriers such as slopes. This survey examined only the first two design requirements of the Fair Housing Act. The survey divided these two requirements into these general areas: 1. Arrival Point Accessible Routes 2. Accessible Routes to Site Facilities 3. Accessible Building Entrance Appraisal 4. Accessible Facilities Entrance Appraisal 5. Inspection of Laundry Amenities 6. Inspection of Public Toilet Rooms 7. Inspection of Accessible Parking Areas 1 and 2 contain barriers on accessible routes. The survey categorized seven types of barriers on accessible routes: cross slope, slope, headroom, protruding objects, ramps, surface and width. Slope and cross slope were measured with a "Smart Tool" digital level and reported as a percentage. A measuring tape was used to document all other barriers with results reported in inches. Areas 3 and 4 contain barriers to entrances. The survey categorized nine barriers to accessible entrances: Typical entrance, clear opening, door hardware, handle height, safe sweep, latch side, threshold, doorbell and vehicle access alternative. The vehicle access alternative category does not apply to accessible unit entrances, only site facilities. The survey did not examine all unit doors, but speculated that units throughout the facility had similar doors. The survey documented the unit entrances of the first and last address on site, as well as two random unit entrances. All public and common use facilities entrances were included. Area 5 contains barriers to public and common-use laundry amenities. The survey categorized four barriers to laundries: each type of laundry appliance accessible, height of controls, maximum reach and potential 1990 Americans with Disabilities Act issues. Area 6 contains barriers to public and common-use toilet rooms. The survey categorized 6 barriers to toilet rooms: Grab bars, knee space under an accessible lavatory, accessible fixture type and signage, accessible controls, turning space, and accessible bathing or shower facilities if provided. Area 7 contains barriers to resident and guest parking. The survey identified 6 barriers to parking: on the shortest circulation route to an accessible entrance, signs, access aisle, accessible parking serving covered units, one accessible space and curb ramps. Typically, sites were charted and unit addresses were recorded before data was gathered. Data and documenting photographs were collected and entered at or near the site. General tax information was collected for each site from the Shelby County Tax Assessor Internet site [www.assessor.shelby.tn.us] and advertisements of rental property were monitored from the Memphis edition of the "Apartment Guide Monthly," distributed free by HPC Publications a PRIMEDIA company. Consultants Mark Mazz To finalize the survey instrument, Mark J. Mazz, President of MJM Architecture [www.markjmazz.com] was consulted for suggestions and comments about the survey tool and technique. With more than twenty years of experience, Mr. Mazz is an active member of five professional organizations. He provides architectural, planning, code review, barrier-free design and expert consulting services. Mr. Mazz submitted suggestions in writing and through two telephone conversations. Chandler Reports Chandler Reports LLC [www.chandlerreports.com] has been serving real estate professionals since 1968. They provided the contact information for newly constructed multi-family dwellings built since 1990. This included a database table of more than sixty sites that may have responsibilities under the Fair Housing Amendments Act. Michael Heinrich Mr. Heinrich provided services in database design and data container programming for a Microsoft Access 2000 application. The design was for a single user for the input of data related to the New Construction Survey. Mr. Heinrich also provided valuable instruction in the collection and care of information. General Findings The survey reviewed 6162 total units clearly built for first occupancy after March 13, 1991, of which 2899 were determined to be "covered" units. The FHA Guidelines define covered multi-family dwellings as: 1. Those buildings consisting of four or more units if such buildings have one or more elevators and 2. Ground floor units in other building having four or more units. The four most common barriers: Ramps, width, slope and access aisles account for 67% of the total barriers identified. A breakdown of the occurrence of all barriers identified is represented in the following chart titled: Element Counts. Frequency of barrier elements Element names Total observed Percentage of identified barriers 1 Accessible Space 28 1.6% 2% Accessible 120 6.8% Access aisle 176 10.0% Clear Opening 1 0.1% Controls 14 0.8% Cross slope 74 4.2% Curb Ramps 15 0.9% Door hardware 156 8.9% Fixture type 15 0.9% Grab bars 6 0.3% Handle Height 3 0.2% Headroom 3 0.2% Knee space 3 0.2% Latch side 3 0.2% On shortest route 27 1.5% Protruding Objects 45 2.6% Ramps 459 26.1% Signs 92 5.2% Slope 187 10.6% Surface 42 2.4% Threshold 30 1.7% Typical Entrance 2 0.1% Vehicle alternative 1 0.1% Width 259 14.7% Overall the survey found more than 1700 barriers in newly constructed multi-family housing that are potentially actionable under the Fair Housing Act. MCIL has documented the barriers with measurements, notations and 1911 photographs in an Access 2000 database. January 29, 2001 Version: 3.7 Appling Lakes at Cordova Club 1392 Equestrian Dr. Cordova, TN 38018 (901) 755-6630 Total reported units: 312 Year reported built 1998 Tax ID: D020700287 Reported Property Value: $19,521,000.00 Notes: /ApplingLakes CRAddress: 1385 Appling Rd. Gated complex. There are 36 marked accessible parking spaces. This property provides two limited access gates to the through street and a central location for access to public transportation. The pedestrian route for the southern entrance that leads to the trash area has no curb ramp and no access from the entrance road. The stairways in all buildings do not have cane detection, although the stairs have a square wooden post that can provide some protection. The feature was not measured because it would not provide detection across the entire path of travel and would require modification to make it a compliant feature. The survey found all the checked unit doors to have doorknobs. From observations made all of the covered ground floor units do not have usable door hardware. An advertisement of this apartment complex was found to have the Fair Housing symbol. There was 3 Access Signs The number of records indicates the number of accessible parking spaces that have no sign or an inappropriate sign. All accessible parking spaces must have appropriate signage. 1 On the Shortest Circulation Route The number of records indicates the number of accessible parking spaces provided that are not on the shortest circulation route. Accessible parking must be the closest to the accessible entrance. 1 Protruding Objects The site has protruding objects in accessible routes that effect one unit or more (a) An object, not detectable by a cane, that extends beyond 4 inches into the path of travel. (b) Open riser stairways do not have an acceptable cane detection area. 12 Ramps The number of records that indicate the absence of a ramp on an accessible route or an inappropriate ramp design An accessible route needs a ramp where the slope is greater than 5%. 1 Route Surface The number of records that indicate route surface was a barrier The surface of the accessible route is an obstruction 4 Route Width The number of records that indicate the accessible route is not at least 36 inches wide (a) Narrow walkways (b) Unmarked parking areas that restrict the accessible route 2 Slope The number of records that list slope as a barrier (a) A slope greater than the maximum allowable slope, generally greater than 1:12 or 8.33% (b) A slope greater than 5% that does not include handrails. 5 Useable Door Hardware The number of records that indicate an accessible entrance does not provide the appropriate door hardware. All site facilities were included and a sample of four covered units were surveyed. Doors of covered units should be operable with a "closed fist." Autumn Ridge 3888 Autumn Ridge Dr. Memphis, TN 38119 (901) 546-0900 Total reported units: 140 Year reported built 1997 Tax ID: 09340000555 Reported Property Value: $6,022,300.00 Notes: \AutumRidge CRAddress: 6001 Ridgeway Rd. Ownership may have just changed evidenced by no management information at the site. Advertisements for Autumn Ridge were found to list "Great Atlantic" and others had no listed owner or manager. An advertisement of this apartment complex was found to have the Fair Housing symbol. There was no universal access symbol in the ad. A single entrance of the survey was found to have usable door hardware, however the other 3 do not. From observations made, most of the covered units do not have usable door hardware. The existence of one compliant door may indicate that the property provided the door hardware where the resident requests it, or when other accommodations are requested. New construction, however, 5 Accessible Parking Serving Covered Units The number of records indicates the number of parking areas that do not have an accessible parking space. While the total number of spaces required to be accessible is two percent, at least one space for each type of parking must be made accessible even if this number exceeds two percent. 3 On the Shortest Circulation Route The number of records indicates the number of accessible parking spaces provided that are not on the shortest circulation route. Accessible parking must be the closest to the accessible entrance. 7 Ramps The number of records that indicate the absence of a ramp on an accessible route or an inappropriate ramp design An accessible route needs a ramp where the slope is greater than 5%. 1 Route Width The number of records that indicate the accessible route is not at least 36 inches wide (a) Narrow walkways (b) Unmarked parking areas that restrict the accessible route 4 Useable Door Hardware The number of records that indicate an accessible entrance does not provide the appropriate door hardware. All site facilities were included and a sample of four covered units were surveyed. Doors of covered units should be operable with a "closed fist." Bailey Creek Apts 1907 North Bailey Woods Dr. Collierville, TN 38017 (901) 853-0003 Total reported units: 232 Year reported built 1998 Tax ID: C024300311 Reported Property Value: $17,221,200.00 Notes: \bstation (When starting data entry, the street name was confused with the apartment complex name to come up with the directory "bstation." The surveyor did not feel a correction was necessary.) NEW PARCEL 98, BAILEY CREEK APTS 4/10/00 CRAddress: 15 Bailey Station RD. Bailey Creek Apartments The stairways in all buildings do not have cane detection. This is listed as one violation of Protruding Objects, however it impacts e unit and nearly all accessible routes. The survey found all the checked unit doors to have doorknobs. From observations made all of the covered ground floor units did not have usable door hardware. Some of the site amenities also do not have usable door hardware. An advertisement of this apartment complex was found to have the Fair Housing symbol. There was no universal access symbol in the ad. May have ADA violations with the parking at the rental office. 1 Accessible Fixture Type and Signage The number of records indicates inappropriate fixture types or inadequate signage. At least one of every fixture type must be accessible, and signage accessible. 12 Access Aisle The number of records indicates the number of accessible parking spaces that have no access aisle or inappropriate access aisles. Accessible parking must provide a 60 inch marked access aisle. Van Accessible parking may apply to areas covered by the ADA. 1 Curb Ramps The number of records indicates the number of accessible parking spaces that have no associated curb ramp where necessary, or an inappropriately designed curb ramp. Curb ramps for parking must comply with ANSI 4.7 1 Cross Slope The number of records that list cross-slope as a barrier (a) Slope perpendicular to the direction of travel that is greater than 2% (b) A slope that requires a turn over two separate inclined planes 1 Protruding Objects The site has protruding objects in accessible routes that effect one unit or more (a) An object, not detectable by a cane, that extends beyond 4 inches into the path of travel. (b) Open riser stairways do not have an acceptable cane detection area. 16 Ramps The number of records that indicate the absence of a ramp on an accessible route or an inappropriate ramp design An accessible route needs a ramp where the slope is greater than 5%. 2 Route Surface The number of records that indicate route surface was a barrier The surface of the accessible route is an obstruction 1 Slope The number of records that list slope as a barrier (a) A slope greater than the maximum allowable slope, generally greater than 1:12 or 8.33% (b) A slope greater than 5% that does not include handrails. 7 Useable Door Hardware The number of records that indicate an accessible entrance does not provide the appropriate door hardware. All site facilities were included and a sample of four covered units were surveyed. Doors of covered units should be operable with a "closed fist." Champion Hills at Stonebridge 2918 Champion Dr. Lakeland, TN 38002 (901) 937-0190 Total reported units: 352 Year reported built Tax ID: L015900401 Reported Property Value: Notes: /ChampionHills The original tax information for this property was invalid. It may be because the apartments are new. The number of units, site year and value are not yet known. It is clear that the site year is after March of 1991. The stairways in all buildings do not have cane detection. This is listed as one violation of Protruding Objects, however it impacts e unit and nearly all accessible routes. An advertisement of this apartment complex was found to have the Fair Housing symbol and the universal access symbol. The property has an extensive collection of storage units that do not provide an accessible entrance. It was not discovered how the storage units were leased out, however, persons with mobility impairments clearly do not have equal access to these amenities. 2 Accessible Controls The number of records indicates controls that are not accessible or usable. Controls should be within reach ranges and can function with a "closed fist." 2 Grab Bars The number of records indicates where no grab bars were present or inappropriately placed. Accessible toilet rooms must include grab bars. 2 1 Accessible Parking Space Serving Facilities The number of records indicates the number of parking areas at site amenities that do not have at least one accessible parking space. There must be a minimum of one accessible space at each site amenity. 5 Access Aisle The number of records indicates the number of accessible parking spaces that have no access aisle or inappropriate access aisles. Accessible parking must provide a 60 inch marked access aisle. Van Accessible parking may apply to areas covered by the ADA. 11 Access Signs The number of records indicates the number of accessible parking spaces that have no sign or an inappropriate sign. All accessible parking spaces must have appropriate signage. 10 Accessible Parking Serving Covered Units The number of records indicates the number of parking areas that do not have an accessible parking space. While the total number of spaces required to be accessible is two percent, at least one space for each type of parking must be made accessible even if this number exceeds two percent. 1 Curb Ramps The number of records indicates the number of accessible parking spaces that have no associated curb ramp where necessary, or an inappropriately designed curb ramp. Curb ramps for parking must comply with ANSI 4.7 2 Cross Slope The number of records that list cross-slope as a barrier (a) Slope perpendicular to the direction of travel that is greater than 2% (b) A slope that requires a turn over two separate inclined planes 1 Protruding Objects The site has protruding objects in accessible routes that effect one unit or more (a) An object, not detectable by a cane, that extends beyond 4 inches into the path of travel. (b) Open riser stairways do not have an acceptable cane detection area. 54 Ramps The number of records that indicate the absence of a ramp on an accessible route or an inappropriate ramp design An accessible route needs a ramp where the slope is greater than 5%. 6 Route Width The number of records that indicate the accessible route is not at least 36 inches wide (a) Narrow walkways (b) Unmarked parking areas that restrict the accessible route 1 Useable Door Hardware The number of records that indicate an accessible entrance does not provide the appropriate door hardware. All site facilities were included and a sample of four covered units were surveyed. Doors of covered units should be operable with a "closed fist." Champion Hills at Windyke I 3788 Links Dr. South Memphis, TN 38125 (901) 751-2911 Total reported units: 176 Year reported built 1996 Tax ID: D024200253 Reported Property Value: $8,696,300.00 Notes: /CH-Windyke CHAMPION HILLS APTS 5/23/00 CRAddress: 8897 Winchester No accessible entrance to the rental office. Significant ADA concerns with the front office. This property is closely related to Champion Hills at Windyke Phase 3. They share the same rental office and site amenities, yet they have separate gates and are across a public street from each other. They will be treated as separate sites, yet noted that there is a close relationship. After entering the data from the survey an overall breakdown of the basic access at this site was made: Units with no access at all - 59.09% Access that was not from the adjacent parking lot, through another buildings pass through or a back entrance - 13.64% Steps not required to enter the front door of the unit - 27.27% The stairways in all buildings do not have cane detection. This is listed as one violation of Protruding Objects, however it impacts e unit and nearly all accessible routes. The survey found all the checked unit doors to have doorknobs. Observations made confirm that no covered ground-floor unit has usable door hardware. An advertisement of this apartment complex was found to have the Fair Housing symbol and the 1 Accessible Controls The number of records indicates controls that are not accessible or usable. Controls should be within reach ranges and can function with a "closed fist." 1 Accessible Fixture Type and Signage The number of records indicates inappropriate fixture types or inadequate signage. At least one of every fixture type must be accessible, and signage accessible. 1 1 Accessible Parking Space Serving Facilities The number of records indicates the number of parking areas at site amenities that do not have at least one accessible parking space. There must be a minimum of one accessible space at each site amenity. 2 Access Aisle The number of records indicates the number of accessible parking spaces that have no access aisle or inappropriate access aisles. Accessible parking must provide a 60 inch marked access aisle. Van Accessible parking may apply to areas covered by the ADA. 10 Access Signs The number of records indicates the number of accessible parking spaces that have no sign or an inappropriate sign. All accessible parking spaces must have appropriate signage. 6 Accessible Parking Serving Covered Units The number of records indicates the number of parking areas that do not have an accessible parking space. While the total number of spaces required to be accessible is two percent, at least one space for each type of parking must be made accessible even if this number exceeds two percent. 1 On the Shortest Circulation Route The number of records indicates the number of accessible parking spaces provided that are not on the shortest circulation route. Accessible parking must be the closest to the accessible entrance. 1 Protruding Objects The site has protruding objects in accessible routes that effect one unit or more (a) An object, not detectable by a cane, that extends beyond 4 inches into the path of travel. (b) Open riser stairways do not have an acceptable cane detection area. 20 Ramps The number of records that indicate the absence of a ramp on an accessible route or an inappropriate ramp design An accessible route needs a ramp where the slope is greater than 5%. 2 Route Width The number of records that indicate the accessible route is not at least 36 inches wide (a) Narrow walkways (b) Unmarked parking areas that restrict the accessible route 3 Slope The number of records that list slope as a barrier (a) A slope greater than the maximum allowable slope, generally greater than 1:12 or 8.33% (b) A slope greater than 5% that does not include handrails. 1 Door Threshold The number of records that indicate an accessible entrance threshold is too high. All site facilities were included and a sample of four covered units were surveyed. The primary entrance should have a threshold of less than 3/4 of an inch, with a beveled threshold the height change can be a maximum of 1 and 1/4 inches. 5 Useable Door Hardware The number of records that indicate an accessible entrance does not provide the appropriate door hardware. All site facilities were included and a sample of four covered units were surveyed. Doors of covered units should be operable with a "closed fist." Champion Hills Windyke Phase 3 8883 Grand Slam Memphis, TN 38125 (901) 937-0190 Total reported units: 88 Year reported built 1998 Tax ID: D024200285 Reported Property Value: $4,438,300.00 Notes: \CH-Windyke CHAMPION HILLS APTS 5/23/00 No accessible entrance to the rental office. Significant ADA concerns with the front office. This property is closely related to Champion Hills at Windyke I. They share the same rental office and site amenities, yet they have separate gates and are across a public street from each other. They will be treated as separate sites, yet noted that there is a close relationship. Amenities that are possibly shared are: Common use Office space, Fitness center, laundry, rental office and the swimming pool deck. The accessibility of these features are recorded in the Champion Hills at Windyke I site because they are on that property site. After entering the data from the survey an overall breakdown of the basic access at this site was made: Units with no access at all - 62.5% Access that was not from the adjacent parking lot, through another buildings pass through or a back entrance - 12.5% Steps not required to enter the front door of the unit - 27% Overall for the two related sites the break-down is similar: 60%; 13%; 27% The stairways in all buildings do not have cane detection. This is listed as one violation of Protruding Objects, however it impacts e unit and nearly all accessible routes. The survey found all the checked unit doors to have doorknobs. Observations made confirm that no covered ground-floor unit has usable door hardware. An advertisement of this apartment complex was found to have the Fair Housing symbol and the 1 Access Aisle The number of records indicates the number of accessible parking spaces that have no access aisle or inappropriate access aisles. Accessible parking must provide a 60 inch marked access aisle. Van Accessible parking may apply to areas covered by the ADA. 8 Access Signs The number of records indicates the number of accessible parking spaces that have no sign or an inappropriate sign. All accessible parking spaces must have appropriate signage. 1 On the Shortest Circulation Route The number of records indicates the number of accessible parking spaces provided that are not on the shortest circulation route. Accessible parking must be the closest to the accessible entrance. 2 Cross Slope The number of records that list cross-slope as a barrier (a) Slope perpendicular to the direction of travel that is greater than 2% (b) A slope that requires a turn over two separate inclined planes 1 Protruding Objects The site has protruding objects in accessible routes that effect one unit or more (a) An object, not detectable by a cane, that extends beyond 4 inches into the path of travel. (b) Open riser stairways do not have an acceptable cane detection area. 8 Ramps The number of records that indicate the absence of a ramp on an accessible route or an inappropriate ramp design An accessible route needs a ramp where the slope is greater than 5%. 2 Route Width The number of records that indicate the accessible route is not at least 36 inches wide (a) Narrow walkways (b) Unmarked parking areas that restrict the accessible route 1 Slope The number of records that list slope as a barrier (a) A slope greater than the maximum allowable slope, generally greater than 1:12 or 8.33% (b) A slope greater than 5% that does not include handrails. 4 Useable Door Hardware The number of records that indicate an accessible entrance does not provide the appropriate door hardware. All site facilities were included and a sample of four covered units were surveyed. Doors of covered units should be operable with a "closed fist." Dogwood Creek Apartments 1969 North Dogwood Creek Collierville, TN 38017 (901) 854-8822 Total reported units: 278 Year reported built 1997 Tax ID: C022100237 Reported Property Value: $13,457,600.00 Notes: /Dogwood 4/9/00 CRAddress: 2100 Houston-Levee RD. Dogwood Creek Apartments This was basically an apartment community organized around two small ponds and a creek. The mail area between buildings 14 and 15 does not have any access. The survey found all the checked unit doors to have doorknobs. Observations made confirm that no covered ground-floor unit has usable door hardware. The stairways in all buildings do not have cane detection. This is listed as one violation of Protruding Objects, however it impacts e unit and nearly all accessible routes. An advertisement of this apartment complex was found to have the Fair Housing symbol. There was no universal access symbol in the ad. 1 Accessible Controls The number of records indicates controls that are not accessible or usable. Controls should be within reach ranges and can function with a "closed fist." 23 Access Aisle The number of records indicates the number of accessible parking spaces that have no access aisle or inappropriate access aisles. Accessible parking must provide a 60 inch marked access aisle. Van Accessible parking may apply to areas covered by the ADA. 8 Access Signs The number of records indicates the number of accessible parking spaces that have no sign or an inappropriate sign. All accessible parking spaces must have appropriate signage. 2 Cross Slope The number of records that list cross-slope as a barrier (a) Slope perpendicular to the direction of travel that is greater than 2% (b) A slope that requires a turn over two separate inclined planes 15 Ramps The number of records that indicate the absence of a ramp on an accessible route or an inappropriate ramp design An accessible route needs a ramp where the slope is greater than 5%. 1 Route Surface The number of records that indicate route surface was a barrier The surface of the accessible route is an obstruction 2 Route Width The number of records that indicate the accessible route is not at least 36 inches wide (a) Narrow walkways (b) Unmarked parking areas that restrict the accessible route 7 Useable Door Hardware The number of records that indicate an accessible entrance does not provide the appropriate door hardware. All site facilities were included and a sample of four covered units were surveyed. Doors of covered units should be operable with a "closed fist." Eton Square 3315 Ridgeway Memphis, TN 38115 (901) 546-9800 Total reported units: 208 Year reported built 1995 Tax ID: 09320000331 Reported Property Value: $8,438,700.00 Notes: /Eton An advertisement of this apartment complex was found to have the Fair Housing symbol and "ADA" captioned beneath the universal access symbol. The stairways in all buildings do not have cane detection. This is listed as one violation of Protruding Objects, however it impacts e unit and nearly all accessible routes. The survey found all the checked unit doors to have doorknobs. Observations made confirm that no covered ground-floor unit has usable door hardware. 1 Access Signs The number of records indicates the number of accessible parking spaces that have no sign or an inappropriate sign. All accessible parking spaces must have appropriate signage. 7 Accessible Parking Serving Covered Units The number of records indicates the number of parking areas that do not have an accessible parking space. While the total number of spaces required to be accessible is two percent, at least one space for each type of parking must be made accessible even if this number exceeds two percent. 4 Cross Slope The number of records that list cross-slope as a barrier (a) Slope perpendicular to the direction of travel that is greater than 2% (b) A slope that requires a turn over two separate inclined planes 1 Protruding Objects The site has protruding objects in accessible routes that effect one unit or more (a) An object, not detectable by a cane, that extends beyond 4 inches into the path of travel. (b) Open riser stairways do not have an acceptable cane detection area. 7 Ramps The number of records that indicate the absence of a ramp on an accessible route or an inappropriate ramp design An accessible route needs a ramp where the slope is greater than 5%. 6 Route Surface The number of records that indicate route surface was a barrier The surface of the accessible route is an obstruction 4 Route Width The number of records that indicate the accessible route is not at least 36 inches wide (a) Narrow walkways (b) Unmarked parking areas that restrict the accessible route 5 Slope The number of records that list slope as a barrier (a) A slope greater than the maximum allowable slope, generally greater than 1:12 or 8.33% (b) A slope greater than 5% that does not include handrails. 4 Useable Door Hardware The number of records that indicate an accessible entrance does not provide the appropriate door hardware. All site facilities were included and a sample of four covered units were surveyed. Doors of covered units should be operable with a "closed fist." Gables at Quail Ridge 4200 Trenton Drive Bartlett, TN 38135 (901) 937-3300 Total reported units: 238 Year reported built 1996 Tax ID: B014800820 Reported Property Value: $14,248,900.00 Notes: /QuailRidge An advertisement of this apartment complex was found to have the Fair Housing symbol. There was no universal access symbol in the ad. Most units comply with the door hardware requirement; however, one unit in building 9 (6473-104) did not have usable door hardware. It is conceivable that the tenant made the change, and would not be a violation. The stairways in all buildings have cane detection. Although the cane detection was clearly intended, there is a question of the effectiveness of the items provided for detection. There are large gaps in the railing used for detection that a white cane could miss. Photo Guide: a 1-4 blgd 1; a 5-6 blgd 2; a 7-9 blgd 3; -18 blgd 5; a 19 blgd 6; b 1-6 blgd 6; b 7-9 blgd 7; b 10-15 blgd 8; b 16 trash; b 17- blgd 9; c 1 blgd 9; c 2-6 blgd 10 1 Accessible Fixture Type and Signage The number of records indicates inappropriate fixture types or inadequate signage. At least one of every fixture type must be accessible, and signage accessible. 2 1 Accessible Parking Space Serving Facilities The number of records indicates the number of parking areas at site amenities that do not have at least one accessible parking space. There must be a minimum of one accessible space at each site amenity. 6 Access Aisle The number of records indicates the number of accessible parking spaces that have no access aisle or inappropriate access aisles. Accessible parking must provide a 60 inch marked access aisle. Van Accessible parking may apply to areas covered by the ADA. 5 Accessible Parking Serving Covered Units The number of records indicates the number of parking areas that do not have an accessible parking space. While the total number of spaces required to be accessible is two percent, at least one space for each type of parking must be made accessible even if this number exceeds two percent. 1 Cross Slope The number of records that list cross-slope as a barrier (a) Slope perpendicular to the direction of travel that is greater than 2% (b) A slope that requires a turn over two separate inclined planes 12 Ramps The number of records that indicate the absence of a ramp on an accessible route or an inappropriate ramp design An accessible route needs a ramp where the slope is greater than 5%. 1 Route Surface The number of records that indicate route surface was a barrier The surface of the accessible route is an obstruction 6 Route Width The number of records that indicate the accessible route is not at least 36 inches wide (a) Narrow walkways (b) Unmarked parking areas that restrict the accessible route 9 Slope The number of records that list slope as a barrier (a) A slope greater than the maximum allowable slope, generally greater than 1:12 or 8.33% (b) A slope greater than 5% that does not include handrails. 1 Typical Entrance The number of records that indicate the accessible entrance is different than the typical entrance Entrances to units and facilities need to be as integrated as possible. 3 Useable Door Hardware The number of records that indicate an accessible entrance does not provide the appropriate door hardware. All site facilities were included and a sample of four covered units were surveyed. Doors of covered units should be operable with a "closed fist." Gables at Stone Bridge 1,2,3 2866 Morning Trace Dr. Memphis, TN 38018 (901) 386-7473 Total reported units: 500 Year reported built Tax ID: Multiple site entry Reported Property Value: $25,885,700.00 Notes: \Stone bridge This is a multi-site entry. This information is combined from: Gables at Stone Bridge 1 - Tax ID: D020300092 Gables at Stone Bridge 2 - Tax ID: D020300088 Gables at Stone Bridge 3 - Tax ID: D020300093 Gables Residential is a publicly held company. www.gables.com. (901) 372-6290 The stairways in all buildings do not have cane detection. This is listed as one violation of Protruding Objects, however it impacts e unit and nearly all accessible routes. The survey found all the checked unit doors to have doorknobs. Observations made confirm that no covered ground-floor unit has usable door hardware. An advertisement of this apartment complex was found to have the Fair Housing symbol and the universal access symbol. However, later advertisements in "Apartment Guide Monthly" did not have the universal access symbol. Individual apartments have laundry amenities and there was not an evident laundry facility on the property. 1 Accessible Fixture Type and Signage The number of records indicates inappropriate fixture types or inadequate signage. At least one of every fixture type must be accessible, and signage accessible. 3 1 Accessible Parking Space Serving Facilities The number of records indicates the number of parking areas at site amenities that do not have at least one accessible parking space. There must be a minimum of one accessible space at each site amenity. 24 Access Aisle The number of records indicates the number of accessible parking spaces that have no access aisle or inappropriate access aisles. Accessible parking must provide a 60 inch marked access aisle. Van Accessible parking may apply to areas covered by the ADA. 3 Access Signs The number of records indicates the number of accessible parking spaces that have no sign or an inappropriate sign. All accessible parking spaces must have appropriate signage. 9 Accessible Parking Serving Covered Units The number of records indicates the number of parking areas that do not have an accessible parking space. While the total number of spaces required to be accessible is two percent, at least one space for each type of parking must be made accessible even if this number exceeds two percent. 1 Curb Ramps The number of records indicates the number of accessible parking spaces that have no associated curb ramp where necessary, or an inappropriately designed curb ramp. Curb ramps for parking must comply with ANSI 4.7 1 On the Shortest Circulation Route The number of records indicates the number of accessible parking spaces provided that are not on the shortest circulation route. Accessible parking must be the closest to the accessible entrance. 1 Protruding Objects The site has protruding objects in accessible routes that effect one unit or more (a) An object, not detectable by a cane, that extends beyond 4 inches into the path of travel. (b) Open riser stairways do not have an acceptable cane detection area. 35 Ramps The number of records that indicate the absence of a ramp on an accessible route or an inappropriate ramp design An accessible route needs a ramp where the slope is greater than 5%. 4 Route Surface The number of records that indicate route surface was a barrier The surface of the accessible route is an obstruction 11 Route Width The number of records that indicate the accessible route is not at least 36 inches wide (a) Narrow walkways (b) Unmarked parking areas that restrict the accessible route 5 Slope The number of records that list slope as a barrier (a) A slope greater than the maximum allowable slope, generally greater than 1:12 or 8.33% (b) A slope greater than 5% that does not include handrails. 1 Latch Side Maneuvering Space The number of records that indicate an accessible entrance does not provide enough maneuvering space to operate the latch. All site facilities were included and a sample of four covered units were surveyed. Depending on the approach, there should be 18 inches on the latch side of the door to operate a door that opens outward. 8 Useable Door Hardware The number of records that indicate an accessible entrance does not provide the appropriate door hardware. All site facilities were included and a sample of four covered units were surveyed. Doors of covered units should be operable with a "closed fist." Gables Germantown 7455 Wolf River Pkwy Germantown, TN 38138 (901) 751-7900 Total reported units: 252 Year reported built 1996 Tax ID: G022000430 Reported Property Value: $18,501,700.00 Notes: /GablesGT FHA1988 Directory: GablesGT 6/1/00 Generally this complex only provides parking access via "built-up" ramps. The access is limited and generally too steep. An advertisement of this apartment complex was found to have the Fair Housing symbol. There was no universal access symbol in the ad. The survey found all the checked unit doors to have doorknobs. Observations made confirm that no covered ground-floor unit has usable door hardware. The stairways in all buildings have cane detection. Although the cane detection was clearly intended, there is a question of the effectiveness of the items provided for detection. There are large gaps in the railing used for detection that a white cane could miss. 1 Accessible Controls The number of records indicates controls that are not accessible or usable. Controls should be within reach ranges and can function with a "closed fist." 2 1 Accessible Parking Space Serving Facilities The number of records indicates the number of parking areas at site amenities that do not have at least one accessible parking space. There must be a minimum of one accessible space at each site amenity. 18 Access Aisle The number of records indicates the number of accessible parking spaces that have no access aisle or inappropriate access aisles. Accessible parking must provide a 60 inch marked access aisle. Van Accessible parking may apply to areas covered by the ADA. 4 Accessible Parking Serving Covered Units The number of records indicates the number of parking areas that do not have an accessible parking space. While the total number of spaces required to be accessible is two percent, at least one space for each type of parking must be made accessible even if this number exceeds two percent. 3 On the Shortest Circulation Route The number of records indicates the number of accessible parking spaces provided that are not on the shortest circulation route. Accessible parking must be the closest to the accessible entrance. 8 Cross Slope The number of records that list cross-slope as a barrier (a) Slope perpendicular to the direction of travel that is greater than 2% (b) A slope that requires a turn over two separate inclined planes 28 Ramps The number of records that indicate the absence of a ramp on an accessible route or an inappropriate ramp design An accessible route needs a ramp where the slope is greater than 5%. 1 Route Surface The number of records that indicate route surface was a barrier The surface of the accessible route is an obstruction 14 Route Width The number of records that indicate the accessible route is not at least 36 inches wide (a) Narrow walkways (b) Unmarked parking areas that restrict the accessible route 20 Slope The number of records that list slope as a barrier (a) A slope greater than the maximum allowable slope, generally greater than 1:12 or 8.33% (b) A slope greater than 5% that does not include handrails. 8 Useable Door Hardware The number of records that indicate an accessible entrance does not provide the appropriate door hardware. All site facilities were included and a sample of four covered units were surveyed. Doors of covered units should be operable with a "closed fist." Grove at Germantown 7865 Grove Court West Germantown, TN 38138 (901) 758-2881 Total reported units: 88 Year reported built 1995 Tax ID: G022000163 Reported Property Value: $5,630,700.00 Notes: /GroveGT This site includes some town homes that are not covered units. There are covered multi-family units on the site that require access to the common use areas. This property is spread out and crosses the street, Brierbrook, creating smaller parking areas for related buildings. Townhouses are integrated in the Grove Germantown compound, and are not covered units. Floor plans of units were collected from the Grove Internet advertisements and are included in the GroveGT directory with the survey photos. Multi-level units were not included in the survey but the database does inventory all the units and buildings. Chandler Research reported that there are 88 units at this site, however, 145 units were observed; 104 covered units and 41 not covered multi-level units. The survey observed 41 buildings; 29 covered and 12 not covered by the 1988 Fair Housing Amendments Act. An advertisement of this apartment complex was found to have the Fair Housing symbol and the universal access symbol. The survey found all the checked unit doors to have doorknobs. Observations made confirm that no covered ground-floor unit has usable door hardware. The stairways in all buildings do not have cane detection. This is listed as one violation of Protruding 2 Accessible Controls The number of records indicates controls that are not accessible or usable. Controls should be within reach ranges and can function with a "closed fist." 1 Knee and Toe Space The number of records indicates where the proper knee and toe space under a lavatory is not provided. Accessible lavatories must provide knee and toe space. 1 1 Accessible Parking Space Serving Facilities The number of records indicates the number of parking areas at site amenities that do not have at least one accessible parking space. There must be a minimum of one accessible space at each site amenity. 1 Access Aisle The number of records indicates the number of accessible parking spaces that have no access aisle or inappropriate access aisles. Accessible parking must provide a 60 inch marked access aisle. Van Accessible parking may apply to areas covered by the ADA. 1 Access Signs The number of records indicates the number of accessible parking spaces that have no sign or an inappropriate sign. All accessible parking spaces must have appropriate signage. 11 Accessible Parking Serving Covered Units The number of records indicates the number of parking areas that do not have an accessible parking space. While the total number of spaces required to be accessible is two percent, at least one space for each type of parking must be made accessible even if this number exceeds two percent. 5 On the Shortest Circulation Route The number of records indicates the number of accessible parking spaces provided that are not on the shortest circulation route. Accessible parking must be the closest to the accessible entrance. 6 Cross Slope The number of records that list cross-slope as a barrier (a) Slope perpendicular to the direction of travel that is greater than 2% (b) A slope that requires a turn over two separate inclined planes 1 Protruding Objects The site has protruding objects in accessible routes that effect one unit or more (a) An object, not detectable by a cane, that extends beyond 4 inches into the path of travel. (b) Open riser stairways do not have an acceptable cane detection area. 4 Route Surface The number of records that indicate route surface was a barrier The surface of the accessible route is an obstruction 4 Route Width The number of records that indicate the accessible route is not at least 36 inches wide (a) Narrow walkways (b) Unmarked parking areas that restrict the accessible route 5 Slope The number of records that list slope as a barrier (a) A slope greater than the maximum allowable slope, generally greater than 1:12 or 8.33% (b) A slope greater than 5% that does not include handrails. 1 Door Threshold The number of records that indicate an accessible entrance threshold is too high. All site facilities were included and a sample of four covered units were surveyed. The primary entrance should have a threshold of less than 3/4 of an inch, with a beveled threshold the height change can be a maximum of 1 and 1/4 inches. 7 Useable Door Hardware The number of records that indicate an accessible entrance does not provide the appropriate door hardware. All site facilities were included and a sample of four covered units were surveyed. Doors of covered units should be operable with a "closed fist." Grove at Shelby Farms 536 Shelby Grove Dr. Cordova, TN 38018 (901) 759-0770 Total reported units: 296 Year reported built 1997 Tax ID: 09108000005 Reported Property Value: $17,368,500.00 Notes: /GroveSF 5/23/00 CRAddress: 7799 Trinity Rd. This property is designed for access to all ground floor units, but poor construction and no attention to site access creates the barriers. However, there is no attempt at access to units 101 and 102 in building 6. The stairways in all buildings do not have cane detection. This is listed as one violation of Protruding Objects, however it impacts e unit and nearly all accessible routes. The survey found all the checked unit doors to have doorknobs. Observations made confirm that no covered ground-floor unit has usable door hardware. An advertisement of this apartment complex was found to have the Fair Housing symbol and the universal access symbol. 2 Accessible Controls The number of records indicates controls that are not accessible or usable. Controls should be within reach ranges and can function with a "closed fist." 1 Grab Bars The number of records indicates where no grab bars were present or inappropriately placed. Accessible toilet rooms must include grab bars. 3 1 Accessible Parking Space Serving Facilities The number of records indicates the number of parking areas at site amenities that do not have at least one accessible parking space. There must be a minimum of one accessible space at each site amenity. 1 Access Aisle The number of records indicates the number of accessible parking spaces that have no access aisle or inappropriate access aisles. Accessible parking must provide a 60 inch marked access aisle. Van Accessible parking may apply to areas covered by the ADA. 17 Access Signs The number of records indicates the number of accessible parking spaces that have no sign or an inappropriate sign. All accessible parking spaces must have appropriate signage. 7 Accessible Parking Serving Covered Units The number of records indicates the number of parking areas that do not have an accessible parking space. While the total number of spaces required to be accessible is two percent, at least one space for each type of parking must be made accessible even if this number exceeds two percent. 17 Cross Slope The number of records that list cross-slope as a barrier (a) Slope perpendicular to the direction of travel that is greater than 2% (b) A slope that requires a turn over two separate inclined planes 1 Protruding Objects The site has protruding objects in accessible routes that effect one unit or more (a) An object, not detectable by a cane, that extends beyond 4 inches into the path of travel. (b) Open riser stairways do not have an acceptable cane detection area. 2 Ramps The number of records that indicate the absence of a ramp on an accessible route or an inappropriate ramp design An accessible route needs a ramp where the slope is greater than 5%. 14 Route Width The number of records that indicate the accessible route is not at least 36 inches wide (a) Narrow walkways (b) Unmarked parking areas that restrict the accessible route 33 Slope The number of records that list slope as a barrier (a) A slope greater than the maximum allowable slope, generally greater than 1:12 or 8.33% (b) A slope greater than 5% that does not include handrails. 3 Door Threshold The number of records that indicate an accessible entrance threshold is too high. All site facilities were included and a sample of four covered units were surveyed. The primary entrance should have a threshold of less than 3/4 of an inch, with a beveled threshold the height change can be a maximum of 1 and 1/4 inches. 5 Useable Door Hardware The number of records that indicate an accessible entrance does not provide the appropriate door hardware. All site facilities were included and a sample of four covered units were surveyed. Doors of covered units should be operable with a "closed fist." Harbor Town Square 1440 Island Park Dr. Memphis, TN 38103 (901) 523-7900 Total reported units: 70 Year reported built 1997 Tax ID: Multiple site entry Reported Property Value: $2,985,600.00 Notes: 00100100061 Harbortown Square 1 00100100053 Harbortown Square 2 /HarbortownSquare CRAddress: 60 Harbor Bend Rd. This property consists of four large structures, that are defined as two buildings by the fair housing act. The two pair of structures are connected in the center by covered stair and walkways. There are also ADA considerations for 2 retail stores. An advertisement of this apartment complex was found to have the Fair Housing symbol. There was no universal access symbol in the ad. The ad further suggests that the office for Island Park is also the rental office for Harbor Town Square. Because the office is physically at the Island Park location, issues of general compliance will be listed in the survey of Island Park and not in the section for Harbor Town Square. The survey found all the checked unit doors to have doorknobs. From observations made, one of the covered units did have usable door hardware. The existence of one compliant door may indicate that the property provided the door hardware where the resident requests it, or when other accommodations are requested. New construction, however, has an affirmative duty to provide usable door hardware for all covered units. 2 Access Aisle The number of records indicates the number of accessible parking spaces that have no access aisle or inappropriate access aisles. Accessible parking must provide a 60 inch marked access aisle. Van Accessible parking may apply to areas covered by the ADA. 1 Cross Slope The number of records that list cross-slope as a barrier (a) Slope perpendicular to the direction of travel that is greater than 2% (b) A slope that requires a turn over two separate inclined planes 1 Ramps The number of records that indicate the absence of a ramp on an accessible route or an inappropriate ramp design An accessible route needs a ramp where the slope is greater than 5%. 6 Slope The number of records that list slope as a barrier (a) A slope greater than the maximum allowable slope, generally greater than 1:12 or 8.33% (b) A slope greater than 5% that does not include handrails. 4 Useable Door Hardware The number of records that indicate an accessible entrance does not provide the appropriate door hardware. All site facilities were included and a sample of four covered units were surveyed. Doors of covered units should be operable with a "closed fist." Hickory Forest 3920 Hickory Hill Rd Memphis, TN 38115 (901) 365-9741 Total reported units: 193 Year reported built 1998 Tax ID: 09340000249 Reported Property Value: $10,601,300.00 Notes: /HickoryForest 5/15/00 Five of the 26 buildings at this site have covered multi-family units. Most of the units on this site are multi-story and not covered by the new construction guidelines of the Fair Housing Act. There are 40 covered units at this site. Buildings on the site are listed in the database, but only covered units are considered in the survey. Although the 1988 Fair Housing Amendments Act does not cover a majority of the units, the site amenities still must be accessible. Both laundry facilities have steps to the entrance and do not have usable door hardware. The survey found all the checked unit doors to have doorknobs. Observations made confirm that no covered ground-floor unit has usable door hardware. Additionally, all site amenities including the entrance to the complex do not have usable door hardware. An advertisement of this apartment complex was found to have the Fair Housing symbol. There was no universal access symbol in the ad. 1 Accessible Controls The number of records indicates controls that are not accessible or usable. Controls should be within reach ranges and can function with a "closed fist." 2 1 Accessible Parking Space Serving Facilities The number of records indicates the number of parking areas at site amenities that do not have at least one accessible parking space. There must be a minimum of one accessible space at each site amenity. 2 Access Aisle The number of records indicates the number of accessible parking spaces that have no access aisle or inappropriate access aisles. Accessible parking must provide a 60 inch marked access aisle. Van Accessible parking may apply to areas covered by the ADA. 3 Accessible Parking Serving Covered Units The number of records indicates the number of parking areas that do not have an accessible parking space. While the total number of spaces required to be accessible is two percent, at least one space for each type of parking must be made accessible even if this number exceeds two percent. 8 Protruding Objects The site has protruding objects in accessible routes that effect one unit or more (a) An object, not detectable by a cane, that extends beyond 4 inches into the path of travel. (b) Open riser stairways do not have an acceptable cane detection area. 10 Ramps The number of records that indicate the absence of a ramp on an accessible route or an inappropriate ramp design An accessible route needs a ramp where the slope is greater than 5%. 2 Route Surface The number of records that indicate route surface was a barrier The surface of the accessible route is an obstruction 12 Route Width The number of records that indicate the accessible route is not at least 36 inches wide (a) Narrow walkways (b) Unmarked parking areas that restrict the accessible route 6 Slope The number of records that list slope as a barrier (a) A slope greater than the maximum allowable slope, generally greater than 1:12 or 8.33% (b) A slope greater than 5% that does not include handrails. 4 Door Threshold The number of records that indicate an accessible entrance threshold is too high. All site facilities were included and a sample of four covered units were surveyed. The primary entrance should have a threshold of less than 3/4 of an inch, with a beveled threshold the height change can be a maximum of 1 and 1/4 inches. 12 Useable Door Hardware The number of records that indicate an accessible entrance does not provide the appropriate door hardware. All site facilities were included and a sample of four covered units were surveyed. Doors of covered units should be operable with a "closed fist." Island Park 1420 Island Park Dr Memphis, TN 38103 (901) 523-7900 Total reported units: 230 Year reported built 1998 Tax ID: 06907700013C Reported Property Value: $12,529,000.00 Notes: /IslandPark Sentinel Management 5/21/00 This complex may be viewed as 3 "islands of curbs" that restrict mobility. The first Island contains building 1 and has one cut curb and one built-up ramp, a total of 2 access points. The second "island" contains the office, pool, tennis court, and resident buildings 2 and 3. There are two built-up ramps and the curb-cut at the office that provide access. The third curb "island" is around buildings 4, 5, 6, and 7. There are five built-up ramps that provide access to this area and the residential units. The built-up style ramp creates many access problems including cross-slope issues. Although an accessible route may be drawn to each ground-floor unit, accessibility issues remain common at this complex. The stairways in all buildings do not have cane detection. This is listed as one violation of Protruding Objects, however it impacts e unit and nearly all accessible routes. The survey found all the checked unit doors to have doorknobs. Observations made confirm that no covered ground-floor unit has usable door hardware. Additionally, all site amenities including the entrance to the complex did not have usable door hardware. An advertisement of this apartment complex was found to have the Fair Housing symbol. There was no universal access symbol in the ad. The ad further suggests that the office for Island Park is also the rental office for Harbor Town Square. Because the office is physically at the Island Park location, issues of general compliance will be listed in the survey of Island Park alone. 1 Knee and Toe Space The number of records indicates where the proper knee and toe space under a lavatory is not provided. Accessible lavatories must provide knee and toe space. 1 1 Accessible Parking Space Serving Facilities The number of records indicates the number of parking areas at site amenities that do not have at least one accessible parking space. There must be a minimum of one accessible space at each site amenity. 8 Access Aisle The number of records indicates the number of accessible parking spaces that have no access aisle or inappropriate access aisles. Accessible parking must provide a 60 inch marked access aisle. Van Accessible parking may apply to areas covered by the ADA. 1 Access Signs The number of records indicates the number of accessible parking spaces that have no sign or an inappropriate sign. All accessible parking spaces must have appropriate signage. 8 Curb Ramps The number of records indicates the number of accessible parking spaces that have no associated curb ramp where necessary, or an inappropriately designed curb ramp. Curb ramps for parking must comply with ANSI 4.7 2 Cross Slope The number of records that list cross-slope as a barrier (a) Slope perpendicular to the direction of travel that is greater than 2% (b) A slope that requires a turn over two separate inclined planes 1 Protruding Objects The site has protruding objects in accessible routes that effect one unit or more (a) An object, not detectable by a cane, that extends beyond 4 inches into the path of travel. (b) Open riser stairways do not have an acceptable cane detection area. 3 Ramps The number of records that indicate the absence of a ramp on an accessible route or an inappropriate ramp design An accessible route needs a ramp where the slope is greater than 5%. 5 Slope The number of records that list slope as a barrier (a) A slope greater than the maximum allowable slope, generally greater than 1:12 or 8.33% (b) A slope greater than 5% that does not include handrails. 1 Door Threshold The number of records that indicate an accessible entrance threshold is too high. All site facilities were included and a sample of four covered units were surveyed. The primary entrance should have a threshold of less than 3/4 of an inch, with a beveled threshold the height change can be a maximum of 1 and 1/4 inches. 10 Useable Door Hardware The number of records that indicate an accessible entrance does not provide the appropriate door hardware. All site facilities were included and a sample of four covered units were surveyed. Doors of covered units should be operable with a "closed fist." Lincoln At Wolfchase 8230 Rockcreek Pkwy Cordova, TN 38018 (901) 380-0188 Total reported units: 408 Year reported built 1998 Tax ID: D020800144 Reported Property Value: $27,003,700.00 Notes: \Lincoln The stairways in all buildings do not have cane detection. This is listed as one violation of Protruding Objects, however it impacts e unit and nearly all accessible routes. An advertisement of this apartment complex was found to have the Fair Housing symbol and the universal access symbol. Lincoln at Wolfchase has a building that qualifies as having two ground floors. Because of the slope of the terrain, the lower floor is a level with the ground approaching from one side, while the next floor is also level with the ground approaching the opposite side. The FAIR HOUSING ACT DESIGN MANUAL covers this topic (p. 1.27). The manual states: "Where a building has ground floor units with their own individual entrances on two or more ground floors, the Guidelines provide that each of these entrances shall be accessible entrance on an accessible route." 2 Accessible Fixture Type and Signage The number of records indicates inappropriate fixture types or inadequate signage. At least one of every fixture type must be accessible, and signage accessible. 2 1 Accessible Parking Space Serving Facilities The number of records indicates the number of parking areas at site amenities that do not have at least one accessible parking space. There must be a minimum of one accessible space at each site amenity. 8 Accessible Parking Serving Covered Units The number of records indicates the number of parking areas that do not have an accessible parking space. While the total number of spaces required to be accessible is two percent, at least one space for each type of parking must be made accessible even if this number exceeds two percent. 1 Curb Ramps The number of records indicates the number of accessible parking spaces that have no associated curb ramp where necessary, or an inappropriately designed curb ramp. Curb ramps for parking must comply with ANSI 4.7 2 Cross Slope The number of records that list cross-slope as a barrier (a) Slope perpendicular to the direction of travel that is greater than 2% (b) A slope that requires a turn over two separate inclined planes 1 Protruding Objects The site has protruding objects in accessible routes that effect one unit or more (a) An object, not detectable by a cane, that extends beyond 4 inches into the path of travel. (b) Open riser stairways do not have an acceptable cane detection area. 4 Ramps The number of records that indicate the absence of a ramp on an accessible route or an inappropriate ramp design An accessible route needs a ramp where the slope is greater than 5%. 21 Route Width The number of records that indicate the accessible route is not at least 36 inches wide (a) Narrow walkways (b) Unmarked parking areas that restrict the accessible route 1 Slope The number of records that list slope as a barrier (a) A slope greater than the maximum allowable slope, generally greater than 1:12 or 8.33% (b) A slope greater than 5% that does not include handrails. 3 Useable Door Hardware The number of records that indicate an accessible entrance does not provide the appropriate door hardware. All site facilities were included and a sample of four covered units were surveyed. Doors of covered units should be operable with a "closed fist." Lincoln On The Green 8345 Championship Dr. Memphis, TN 38125 (901) 748-0002 Total reported units: 234 Year reported built 1997 Tax ID: D024200147 Reported Property Value: $12,129,700.00 Notes: \Lincoln-Green 5/30/00 The new additions built after the FHA guidelines are contrasted with those built before the Act. The first 16 buildings do not in any way comply with the accessibility requirements. The other buildings on the site are believed to have been built for first occupancy after March of 1991. The information from Chandler Reports seems to indicate the later buildings alone. Although information and data was collected on the first 16 buildings, that data does not appear in the survey. The stairways in all buildings do not have cane detection. This is listed as one violation of Protruding Objects, however it impacts e unit and nearly all accessible routes. The survey found all the checked unit doors to have doorknobs. Observations made confirm that no covered ground-floor unit has usable door hardware. Additionally, all site amenities including the entrance to the complex did not have usable door hardware. An advertisement of this apartment complex was found to have the Fair Housing symbol. There was no universal access symbol in the ad. 1 Accessible Controls The number of records indicates controls that are not accessible or usable. Controls should be within reach ranges and can function with a "closed fist." 1 Accessible Fixture Type and Signage The number of records indicates inappropriate fixture types or inadequate signage. At least one of every fixture type must be accessible, and signage accessible. 1 Grab Bars The number of records indicates where no grab bars were present or inappropriately placed. Accessible toilet rooms must include grab bars. 12 Access Aisle The number of records indicates the number of accessible parking spaces that have no access aisle or inappropriate access aisles. Accessible parking must provide a 60 inch marked access aisle. Van Accessible parking may apply to areas covered by the ADA. 5 Cross Slope The number of records that list cross-slope as a barrier (a) Slope perpendicular to the direction of travel that is greater than 2% (b) A slope that requires a turn over two separate inclined planes 1 Protruding Objects The site has protruding objects in accessible routes that effect one unit or more (a) An object, not detectable by a cane, that extends beyond 4 inches into the path of travel. (b) Open riser stairways do not have an acceptable cane detection area. 3 Ramps The number of records that indicate the absence of a ramp on an accessible route or an inappropriate ramp design An accessible route needs a ramp where the slope is greater than 5%. 2 Route Surface The number of records that indicate route surface was a barrier The surface of the accessible route is an obstruction 3 Route Width The number of records that indicate the accessible route is not at least 36 inches wide (a) Narrow walkways (b) Unmarked parking areas that restrict the accessible route 14 Slope The number of records that list slope as a barrier (a) A slope greater than the maximum allowable slope, generally greater than 1:12 or 8.33% (b) A slope greater than 5% that does not include handrails. 1 Clear Opening Width The number of records that indicate an accessible entrance does not provide a wide enough opening. All site facilities were included and a sample of four covered units were surveyed. The door and door hardware should allow a minimum of 32 inches of space when open 90º. 1 Door Threshold The number of records that indicate an accessible entrance threshold is too high. All site facilities were included and a sample of four covered units were surveyed. The primary entrance should have a threshold of less than 3/4 of an inch, with a beveled threshold the height change can be a maximum of 1 and 1/4 inches. 2 Handle Height The number of records that indicate an accessible entrance handle is too high. All site facilities were included and a sample of four covered units were surveyed. Door handles and other hardware should be no higher than 48 inches. 7 Useable Door Hardware The number of records that indicate an accessible entrance does not provide the appropriate door hardware. All site facilities were included and a sample of four covered units were surveyed. Doors of covered units should be operable with a "closed fist." Mynders Mark Apartments 3605 Mynders Memphis, TN 38111 (901) 324-0448 Total reported units: 28 Year reported built 1995 Tax ID: 04600700003C Reported Property Value: $568,500.00 Notes: \3605Mynders 2- BR $575, 1-BR $450 3/31/00 3605 Mynders Mynders Mark Apartments Near the University of Memphis campus, the Mynders Mark clearly accommodates a student population. Most significantly, it was observed the accessible parking signs had been removed and stacked behind building 3609. The survey identified 12 ground-floor units, 6 in each building. There was an accessible entrance to each building, but it was not a direct route. The concrete used on the parking lot and from the parking lot to the buildings was a rough surface. The surveyor is not aware of a test for compliance of this. The accessible parking and the access isle had a cross-slope of 2%. There were no signs indicating accessible parking. The mailboxes protruded 7 inches into the accessible route and did not include a detectable warning for persons with visual impairments. The survey found all the checked unit doors to have doorknobs. From observations made all of the covered ground floor units did not have usable door hardware. 2 Access Signs The number of records indicates the number of accessible parking spaces that have no sign or an inappropriate sign. All accessible parking spaces must have appropriate signage. 2 Protruding Objects The site has protruding objects in accessible routes that effect one unit or more (a) An object, not detectable by a cane, that extends beyond 4 inches into the path of travel. (b) Open riser stairways do not have an acceptable cane detection area. 1 Route Surface The number of records that indicate route surface was a barrier The surface of the accessible route is an obstruction 5 Useable Door Hardware The number of records that indicate an accessible entrance does not provide the appropriate door hardware. All site facilities were included and a sample of four covered units were surveyed. Doors of covered units should be operable with a "closed fist." South Bluffs 4 Riverview Dr. W. Memphis, TN 38103 (901) 522-9800 Total reported units: 201 Year reported built 1992 Tax ID: 00208300006C Reported Property Value: $10,583,500.00 Notes: \South Bluffs SOUTH BLUFFS APT COMPLEX CRAddress: 0 Georgia 5/29/00 Basic accessibility has seemingly been designed into the site, however there are 6 ground-floor units that have no access. Access around the complex is poor due to the width of the sidewalks being restricted by parked cars. The mailbox area has extremely poor access. The office provides a segregated entrance. The survey found all the checked unit doors to have doorknobs. Observations made confirm that no covered ground-floor unit has usable door hardware. The stairways in all buildings do not have cane detection. This is listed as a single violation of Protruding Objects, however it impacts e unit and nearly all accessible routes. An advertisement of this apartment complex was found to have the Fair Housing symbol. There was no universal access symbol in the ad. 1 Access Aisle The number of records indicates the number of accessible parking spaces that have no access aisle or inappropriate access aisles. Accessible parking must provide a 60 inch marked access aisle. Van Accessible parking may apply to areas covered by the ADA. 1 Access Signs The number of records indicates the number of accessible parking spaces that have no sign or an inappropriate sign. All accessible parking spaces must have appropriate signage. 2 Accessible Parking Serving Covered Units The number of records indicates the number of parking areas that do not have an accessible parking space. While the total number of spaces required to be accessible is two percent, at least one space for each type of parking must be made accessible even if this number exceeds two percent. 2 Curb Ramps The number of records indicates the number of accessible parking spaces that have no associated curb ramp where necessary, or an inappropriately designed curb ramp. Curb ramps for parking must comply with ANSI 4.7 2 On the Shortest Circulation Route The number of records indicates the number of accessible parking spaces provided that are not on the shortest circulation route. Accessible parking must be the closest to the accessible entrance. 1 Cross Slope The number of records that list cross-slope as a barrier (a) Slope perpendicular to the direction of travel that is greater than 2% (b) A slope that requires a turn over two separate inclined planes 5 Protruding Objects The site has protruding objects in accessible routes that effect one unit or more (a) An object, not detectable by a cane, that extends beyond 4 inches into the path of travel. (b) Open riser stairways do not have an acceptable cane detection area. 9 Ramps The number of records that indicate the absence of a ramp on an accessible route or an inappropriate ramp design An accessible route needs a ramp where the slope is greater than 5%. 1 Route Headroom The number of records that list headroom as a barrier An accessible route with an obstruction, not detectable with a cane, lower than 80 inches. 1 Route Surface The number of records that indicate route surface was a barrier The surface of the accessible route is an obstruction 9 Route Width The number of records that indicate the accessible route is not at least 36 inches wide (a) Narrow walkways (b) Unmarked parking areas that restrict the accessible route 12 Slope The number of records that list slope as a barrier (a) A slope greater than the maximum allowable slope, generally greater than 1:12 or 8.33% (b) A slope greater than 5% that does not include handrails. 1 Latch Side Maneuvering Space The number of records that indicate an accessible entrance does not provide enough maneuvering space to operate the latch. All site facilities were included and a sample of four covered units were surveyed. Depending on the approach, there should be 18 inches on the latch side of the door to operate a door that opens outward. 4 Useable Door Hardware The number of records that indicate an accessible entrance does not provide the appropriate door hardware. All site facilities were included and a sample of four covered units were surveyed. Doors of covered units should be operable with a "closed fist." The Registry At Wolfchase 1810 West Wolfchase Circle Cordova, TN 38018 (901) 752-3811 Total reported units: 308 Year reported built 1998 Tax ID: D020800528 Reported Property Value: $16,621,000.00 Notes: /Registry-Wolfchase CRAddress: 8230 New Dexter Rd This property shows the best examples of access for a large site. The stairways in all buildings do not have cane detection. This is listed as a single violation of Protruding Objects, however it impacts e unit and nearly all accessible routes. An advertisement of this apartment complex was found to have the Fair Housing symbol and the universal access symbol. 1 Accessible Fixture Type and Signage The number of records indicates inappropriate fixture types or inadequate signage. At least one of every fixture type must be accessible, and signage accessible. 1 1 Accessible Parking Space Serving Facilities The number of records indicates the number of parking areas at site amenities that do not have at least one accessible parking space. There must be a minimum of one accessible space at each site amenity. 1 Access Aisle The number of records indicates the number of accessible parking spaces that have no access aisle or inappropriate access aisles. Accessible parking must provide a 60 inch marked access aisle. Van Accessible parking may apply to areas covered by the ADA. 1 Access Signs The number of records indicates the number of accessible parking spaces that have no sign or an inappropriate sign. All accessible parking spaces must have appropriate signage. 1 On the Shortest Circulation Route The number of records indicates the number of accessible parking spaces provided that are not on the shortest circulation route. Accessible parking must be the closest to the accessible entrance. 1 Protruding Objects The site has protruding objects in accessible routes that effect one unit or more (a) An object, not detectable by a cane, that extends beyond 4 inches into the path of travel. (b) Open riser stairways do not have an acceptable cane detection area. 1 Ramps The number of records that indicate the absence of a ramp on an accessible route or an inappropriate ramp design An accessible route needs a ramp where the slope is greater than 5%. 1 Route Surface The number of records that indicate route surface was a barrier The surface of the accessible route is an obstruction 1 Route Width The number of records that indicate the accessible route is not at least 36 inches wide (a) Narrow walkways (b) Unmarked parking areas that restrict the accessible route 1 Useable Door Hardware The number of records that indicate an accessible entrance does not provide the appropriate door hardware. All site facilities were included and a sample of four covered units were surveyed. Doors of covered units should be operable with a "closed fist." 1 Vehicle Access Alternative (does not apply to Accessible Unit Entrance) The number of records that indicate accessible parking is not provided at site amenities. Vehicle routes may be used as an alternative method to achieve accessibility. The Reserve at Dexter Lake 1505 Dexter Lake Dr. Cordova, TN 38018 (901) 737-7990 Total reported units: 132 Year reported built 1993 Tax ID: G022000395 Reported Property Value: $8,298,500.00 Notes: /ReserveDexterLake There is current construction evident at this site. The survey only looked at the rented units and common use amenities that were finished for use at the time of the survey. The buildings to the south were included, while all buildings north of the tennis courts were not surveyed. The survey found all the checked unit doors to have doorknobs. Observations made confirm that no covered ground-floor unit has usable door hardware. The stairways in all buildings do not have cane detection. This is listed as a single violation of Protruding Objects, however it impacts e unit and nearly all accessible routes. An advertisement of this apartment complex was found to have the Fair Housing symbol. There was no universal access symbol in the ad. 2 Accessible Fixture Type and Signage The number of records indicates inappropriate fixture types or inadequate signage. At least one of every fixture type must be accessible, and signage accessible. 1 1 Accessible Parking Space Serving Facilities The number of records indicates the number of parking areas at site amenities that do not have at least one accessible parking space. There must be a minimum of one accessible space at each site amenity. 4 Access Aisle The number of records indicates the number of accessible parking spaces that have no access aisle or inappropriate access aisles. Accessible parking must provide a 60 inch marked access aisle. Van Accessible parking may apply to areas covered by the ADA. 6 Access Signs The number of records indicates the number of accessible parking spaces that have no sign or an inappropriate sign. All accessible parking spaces must have appropriate signage. 4 Accessible Parking Serving Covered Units The number of records indicates the number of parking areas that do not have an accessible parking space. While the total number of spaces required to be accessible is two percent, at least one space for each type of parking must be made accessible even if this number exceeds two percent. 1 On the Shortest Circulation Route The number of records indicates the number of accessible parking spaces provided that are not on the shortest circulation route. Accessible parking must be the closest to the accessible entrance. 5 Cross Slope The number of records that list cross-slope as a barrier (a) Slope perpendicular to the direction of travel that is greater than 2% (b) A slope that requires a turn over two separate inclined planes 1 Protruding Objects The site has protruding objects in accessible routes that effect one unit or more (a) An object, not detectable by a cane, that extends beyond 4 inches into the path of travel. (b) Open riser stairways do not have an acceptable cane detection area. 3 Ramps The number of records that indicate the absence of a ramp on an accessible route or an inappropriate ramp design An accessible route needs a ramp where the slope is greater than 5%. 4 Route Surface The number of records that indicate route surface was a barrier The surface of the accessible route is an obstruction 2 Route Width The number of records that indicate the accessible route is not at least 36 inches wide (a) Narrow walkways (b) Unmarked parking areas that restrict the accessible route 1 Door Threshold The number of records that indicate an accessible entrance threshold is too high. All site facilities were included and a sample of four covered units were surveyed. The primary entrance should have a threshold of less than 3/4 of an inch, with a beveled threshold the height change can be a maximum of 1 and 1/4 inches. 6 Useable Door Hardware The number of records that indicate an accessible entrance does not provide the appropriate door hardware. All site facilities were included and a sample of four covered units were surveyed. Doors of covered units should be operable with a "closed fist." The Vineyards 7109 Vineyards Way Germantown, TN 38138 (901) 755-9394 Total reported units: 200 Year reported built 1997 Tax ID: G021900198 Reported Property Value: $13,995,200.00 Notes: /Vineyards The Vineyards has a unique parking problem at the garage doors. Parking is common in front of the garage door where a parked car may block the accessible route to the central ground floor units. An advertisement of this apartment complex was found to have the Fair Housing symbol. There was no universal access symbol in the ad. 1 Accessible Controls The number of records indicates controls that are not accessible or usable. Controls should be within reach ranges and can function with a "closed fist." 2 Accessible Fixture Type and Signage The number of records indicates inappropriate fixture types or inadequate signage. At least one of every fixture type must be accessible, and signage accessible. 7 Access Aisle The number of records indicates the number of accessible parking spaces that have no access aisle or inappropriate access aisles. Accessible parking must provide a 60 inch marked access aisle. Van Accessible parking may apply to areas covered by the ADA. 1 Access Signs The number of records indicates the number of accessible parking spaces that have no sign or an inappropriate sign. All accessible parking spaces must have appropriate signage. 1 On the Shortest Circulation Route The number of records indicates the number of accessible parking spaces provided that are not on the shortest circulation route. Accessible parking must be the closest to the accessible entrance. 14 Cross Slope The number of records that list cross-slope as a barrier (a) Slope perpendicular to the direction of travel that is greater than 2% (b) A slope that requires a turn over two separate inclined planes 4 Ramps The number of records that indicate the absence of a ramp on an accessible route or an inappropriate ramp design An accessible route needs a ramp where the slope is greater than 5%. 2 Route Surface The number of records that indicate route surface was a barrier The surface of the accessible route is an obstruction 26 Route Width The number of records that indicate the accessible route is not at least 36 inches wide (a) Narrow walkways (b) Unmarked parking areas that restrict the accessible route 31 Slope The number of records that list slope as a barrier (a) A slope greater than the maximum allowable slope, generally greater than 1:12 or 8.33% (b) A slope greater than 5% that does not include handrails. 1 Door Threshold The number of records that indicate an accessible entrance threshold is too high. All site facilities were included and a sample of four covered units were surveyed. The primary entrance should have a threshold of less than 3/4 of an inch, with a beveled threshold the height change can be a maximum of 1 and 1/4 inches. Trails At Kirby Parkway 6420 Knight Arnold Extd Memphis, TN 38115 (901) 794-5225 Total reported units: 290 Year reported built 1991 Tax ID: 09320000315 Reported Property Value: $10,692,700.00 Notes: /Trails-Kirby This site has strong connections to The Trails at Mt. Moriah. There is no pedestrian path between the two properties, but there are two connecting roads. Each site has a separate rental office, but they have similar signs at the separate entrances. This survey will consider The Trails as independent properties. The survey found all the checked unit doors to have doorknobs. Observations made confirm that no covered ground-floor unit has usable door hardware. The stairways in all buildings do not have cane detection. This is listed as a single violation of Protruding Objects, however it impacts e unit and nearly all accessible routes. An advertisement of this apartment complex was found to have the Fair Housing symbol. There was no universal access symbol in the ad. 1 Accessible Controls The number of records indicates controls that are not accessible or usable. Controls should be within reach ranges and can function with a "closed fist." 2 Accessible Fixture Type and Signage The number of records indicates inappropriate fixture types or inadequate signage. At least one of every fixture type must be accessible, and signage accessible. 1 Grab Bars The number of records indicates where no grab bars were present or inappropriately placed. Accessible toilet rooms must include grab bars. 2 1 Accessible Parking Space Serving Facilities The number of records indicates the number of parking areas at site amenities that do not have at least one accessible parking space. There must be a minimum of one accessible space at each site amenity. 11 Access Aisle The number of records indicates the number of accessible parking spaces that have no access aisle or inappropriate access aisles. Accessible parking must provide a 60 inch marked access aisle. Van Accessible parking may apply to areas covered by the ADA. 10 Access Signs The number of records indicates the number of accessible parking spaces that have no sign or an inappropriate sign. All accessible parking spaces must have appropriate signage. 16 Accessible Parking Serving Covered Units The number of records indicates the number of parking areas that do not have an accessible parking space. While the total number of spaces required to be accessible is two percent, at least one space for each type of parking must be made accessible even if this number exceeds two percent. 1 On the Shortest Circulation Route The number of records indicates the number of accessible parking spaces provided that are not on the shortest circulation route. Accessible parking must be the closest to the accessible entrance. 1 Protruding Objects The site has protruding objects in accessible routes that effect one unit or more (a) An object, not detectable by a cane, that extends beyond 4 inches into the path of travel. (b) Open riser stairways do not have an acceptable cane detection area. 23 Ramps The number of records that indicate the absence of a ramp on an accessible route or an inappropriate ramp design An accessible route needs a ramp where the slope is greater than 5%. 34 Route Width The number of records that indicate the accessible route is not at least 36 inches wide (a) Narrow walkways (b) Unmarked parking areas that restrict the accessible route 3 Slope The number of records that list slope as a barrier (a) A slope greater than the maximum allowable slope, generally greater than 1:12 or 8.33% (b) A slope greater than 5% that does not include handrails. 3 Door Threshold The number of records that indicate an accessible entrance threshold is too high. All site facilities were included and a sample of four covered units were surveyed. The primary entrance should have a threshold of less than 3/4 of an inch, with a beveled threshold the height change can be a maximum of 1 and 1/4 inches. 8 Useable Door Hardware The number of records that indicate an accessible entrance does not provide the appropriate door hardware. All site facilities were included and a sample of four covered units were surveyed. Doors of covered units should be operable with a "closed fist." Trails At Mt Moriah 3048 Moriah Trails Memphis, TN 38115 (901) 367-0900 Total reported units: 376 Year reported built 1995 Tax ID: 09320000396 Reported Property Value: $12,340,600.00 Notes: /Trails-Moriah CRAddress: 6421 Mt. Moriah This site has strong connections to The Trails at Kirby Parkway. There is no pedestrian path between the two properties, but there are two connecting roads. Each site has a separate rental office, but they have similar signs at the separate entrances. This survey will consider The Trails as independent properties. The survey found all the checked unit doors to have doorknobs. Observations made confirm that no covered ground-floor unit has usable door hardware. Additionally, site amenities do not have usable door hardware. An advertisement of this apartment complex was found to have the Fair Housing symbol. There was no universal access symbol in the ad. 1 Accessible Controls The number of records indicates controls that are not accessible or usable. Controls should be within reach ranges and can function with a "closed fist." 1 Accessible Fixture Type and Signage The number of records indicates inappropriate fixture types or inadequate signage. At least one of every fixture type must be accessible, and signage accessible. 1 Grab Bars The number of records indicates where no grab bars were present or inappropriately placed. Accessible toilet rooms must include grab bars. 1 Knee and Toe Space The number of records indicates where the proper knee and toe space under a lavatory is not provided. Accessible lavatories must provide knee and toe space. 3 1 Accessible Parking Space Serving Facilities The number of records indicates the number of parking areas at site amenities that do not have at least one accessible parking space. There must be a minimum of one accessible space at each site amenity. 29 Access Aisle The number of records indicates the number of accessible parking spaces that have no access aisle or inappropriate access aisles. Accessible parking must provide a 60 inch marked access aisle. Van Accessible parking may apply to areas covered by the ADA. 8 Access Signs The number of records indicates the number of accessible parking spaces that have no sign or an inappropriate sign. All accessible parking spaces must have appropriate signage. 17 Accessible Parking Serving Covered Units The number of records indicates the number of parking areas that do not have an accessible parking space. While the total number of spaces required to be accessible is two percent, at least one space for each type of parking must be made accessible even if this number exceeds two percent. 1 Curb Ramps The number of records indicates the number of accessible parking spaces that have no associated curb ramp where necessary, or an inappropriately designed curb ramp. Curb ramps for parking must comply with ANSI 4.7 3 On the Shortest Circulation Route The number of records indicates the number of accessible parking spaces provided that are not on the shortest circulation route. Accessible parking must be the closest to the accessible entrance. 14 Protruding Objects The site has protruding objects in accessible routes that effect one unit or more (a) An object, not detectable by a cane, that extends beyond 4 inches into the path of travel. (b) Open riser stairways do not have an acceptable cane detection area. 20 Ramps The number of records that indicate the absence of a ramp on an accessible route or an inappropriate ramp design An accessible route needs a ramp where the slope is greater than 5%. 2 Route Headroom The number of records that list headroom as a barrier An accessible route with an obstruction, not detectable with a cane, lower than 80 inches. 4 Route Surface The number of records that indicate route surface was a barrier The surface of the accessible route is an obstruction 79 Route Width The number of records that indicate the accessible route is not at least 36 inches wide (a) Narrow walkways (b) Unmarked parking areas that restrict the accessible route 5 Slope The number of records that list slope as a barrier (a) A slope greater than the maximum allowable slope, generally greater than 1:12 or 8.33% (b) A slope greater than 5% that does not include handrails. 4 Door Threshold The number of records that indicate an accessible entrance threshold is too high. All site facilities were included and a sample of four covered units were surveyed. The primary entrance should have a threshold of less than 3/4 of an inch, with a beveled threshold the height change can be a maximum of 1 and 1/4 inches. 1 Latch Side Maneuvering Space The number of records that indicate an accessible entrance does not provide enough maneuvering space to operate the latch. All site facilities were included and a sample of four covered units were surveyed. Depending on the approach, there should be 18 inches on the latch side of the door to operate a door that opens outward. 1 Typical Entrance The number of records that indicate the accessible entrance is different than the typical entrance Entrances to units and facilities need to be as integrated as possible. 12 Useable Door Hardware The number of records that indicate an accessible entrance does not provide the appropriate door hardware. All site facilities were included and a sample of four covered units were surveyed. Doors of covered units should be operable with a "closed fist." Wyndham Apartments 3200 Germantown Rd Memphis, TN 38119 (901) 755-8480 Total reported units: 332 Year reported built 1997 Tax ID: 08107900013 Reported Property Value: $18,520,100.00 Notes: WYNDHAM APTS 5/17/00 3200 Germantown Rd. Wyndham Apartments This is a unique property. To create a neighborhood "feel" to rental units, and to provide each resident with a garage to park their car, Wyndham Apartments are a collection of 51 buildings and a garage for each unit. There are only three apartment floor-plans and only three patterns of buildings used throughout the complex. The structures are either the pattern for a four-unit building, an eight-unit building, or a twelve-unit building. Only the twelve-unit buildings offer some access to the front door of ground-floor apartments. The four-unit and the eight-unit pattern all include a one-step threshold to ground floor units, additionally, the eight-unit buildings have a porch step. Because of the prevalence of inaccessible ground floor units, the survey did not photo all of the inaccessible thresholds although all the ground floor units were examined. The survey documented all the variations from the general pattern, and documented all of the units with ground-floor access. Likewise, because each unit has a garage for parking, the percentage of accessible parking is unique. There are no marked "on street" parking spaces which may nevertheless provide parking for visitors, and parking is common in the driveway to the unit garage yet it is also not marked for parking. There are parking pads provided near some units, however these are not marked for residents or visitors and obviously not marked for accessible parking. There is marked parking at the rental office, at the pool, and two areas at the tennis courts. There is only one space on the property marked for accessible parking. The parking survey will only take into account the marked parking at the common use areas. The FHA Amendments of 1988 require an accessible route from a unit-parking garage to the typical unit entrance. Because all but 17 of the apartments at Wyndham have at least a one-step threshold, the associated garage parking is not accessible or usable to a person with a mobility impairment. This barrier will be documented in the destination segment of the survey and not recorded in the parking segment of the survey. The path from the rented garage and the front door was not inspected in this survey. It is suspected that there is a step at all of the units, including those with no threshold [17 units]. The survey found all the checked unit doors to have doorknobs. Observations made confirm that no covered ground-floor unit has usable door hardware. Additionally, site amenities do not have usable door hardware. 2 1 Accessible Parking Space Serving Facilities The number of records indicates the number of parking areas at site amenities that do not have at least one accessible parking space. There must be a minimum of one accessible space at each site amenity. 1 Access Aisle The number of records indicates the number of accessible parking spaces that have no access aisle or inappropriate access aisles. Accessible parking must provide a 60 inch marked access aisle. Van Accessible parking may apply to areas covered by the ADA. 2 An advertisement of this apartment complex was found to have the Fair Housing symbol. There was Accessible Parking Serving Covered Units no universal access symbol in the ad. The number of records indicates the number of parking areas that do not have an accessible parking space. While the total number of spaces required to be accessible is two percent, at least one space for each type of parking must be made accessible even if this number exceeds two percent. 1 On the Shortest Circulation Route The number of records indicates the number of accessible parking spaces provided that are not on the shortest circulation route. Accessible parking must be the closest to the accessible entrance. 1 Cross Slope The number of records that list cross-slope as a barrier (a) Slope perpendicular to the direction of travel that is greater than 2% (b) A slope that requires a turn over two separate inclined planes 153 Ramps The number of records that indicate the absence of a ramp on an accessible route or an inappropriate ramp design An accessible route needs a ramp where the slope is greater than 5%. 1 Route Width The number of records that indicate the accessible route is not at least 36 inches wide (a) Narrow walkways (b) Unmarked parking areas that restrict the accessible route 20 Slope The number of records that list slope as a barrier (a) A slope greater than the maximum allowable slope, generally greater than 1:12 or 8.33% (b) A slope greater than 5% that does not include handrails. 5 Door Threshold The number of records that indicate an accessible entrance threshold is too high. All site facilities were included and a sample of four covered units were surveyed. The primary entrance should have a threshold of less than 3/4 of an inch, with a beveled threshold the height change can be a maximum of 1 and 1/4 inches. 1 Handle Height The number of records that indicate an accessible entrance handle is too high. All site facilities were included and a sample of four covered units were surveyed. Door handles and other hardware should be no higher than 48 inches. 7 Useable Door Hardware The number of records that indicate an accessible entrance does not provide the appropriate door hardware. All site facilities were included and a sample of four covered units were surveyed. Doors of covered units should be operable with a "closed fist." Conclusion More than 1700 barriers identified in Memphis area apartments portray a poor picture of housing options for people with disabilities. Some sites however, are more accessible than others and barriers that would make an apartment uninhabitable for some persons with disabilities, may not restrict others. Because of the diversity in accessibility needs of people with disabilities and the variety of barriers at a range of apartment complexes, the survey has meticulously noted the nature of the barriers at the various sites. The Memphis Center for Independent Living has a database documenting all of the Fair Housing Amendments Act considerations raised in this report. The database includes over 2000 files representing nearly four hundred million bytes. The information gathered in this survey may be used to either assist making apartments more accessible, or may be used as a tool for thoroughly enforcing the law. The new construction guidelines of the Fair Housing Amendments Act generally point to barriers that constitute discrimination in the way multi-family housing is designed. Discrimination, however, may also be found in the manner units are rented and the way tenants are regarded. The Memphis Center for Independent Living's goal is that all citizens are treated equally in the housing market and that persons with disabilities be empowered to live independently in integrated community settings. Local multi-family housing owners and managers must make a concentrated effort to rigorously ensure compliance with the new construction guidelines of the 1988 Fair Housing Amendments Act. Because the physical barriers that this survey typically identified will not go away or be forgotten over time, apartment managers can expect an increase in individual legal actions from the growing population of people with disabilities. Prompt observance of federal law may avoid lawsuits by individual residents as more people with disabilities seek residence in units built after March of 1991. Contact Information This report is a partnership project between Memphis Area Legal Services' Fair Housing Center and the Memphis Center for Independent Living. The Memphis Center for Independent Living 163 Angelus Street Memphis TN 38104 (901) 726-6404 v/tty (901) 726-6521 fax www.mcil.org Deborah Cunningham, Executive Director dc@mcil.org Sandi Klink, Program Director sandi@mcil.org Tim Wheat, 1990 Americans with Disabilities Act Community Organizer tim@mcil.org Memphis Fair Housing Center 109 North Main, 2nd Floor Memphis, TN 38103 (901) 432-4663 (HOME) (901) 529-8706 fax J. C. Cobbins, Program Manager jcobbins@malsi.org Acknowledgment and Disclaimer The work that provided the basis for this publication was supported under a grant with the United States Department of Housing and Urban Development. The substance and findings of the work are dedicated to the public. The author and publisher are solely responsible for the accuracy of the statements and interpretations contained in this publication. Such interpretations do not necessarily reflect the views of the Federal Government. Copyright (c) 2001 etc. information