U.S. Department of Justice Civil Rights Division Disability Rights Section P. O.

Box 66738 Washington, DC 20035-6738

Mr. Oliver Jordan Affirmative Action & Training Manager One Convention Center Place 1101 Arch Street Philadelphia, Pennsylvania 19107-2299 RE: Complaint Numbers XX Dear Mr. Jordan: This letter is to notify you that, based on the documentation and assurances that the Pennsylvania Convention Center Authority (Authority) has provided, we have determined that the measures undertaken to improve access to the Pennsylvania Convention Center for persons with disabilities will resolve the complaint filed under Title II of the Americans with Disabilities Act of 1990 (ADA). Title II prohibits discrimination against qualified individuals with disabilities on the basis of disability by State and local governments. The complaint alleged that the services, programs, and activities provided by the Authority, either directly or by lease, in the Exhibition Hall portion of the Pennsylvania Convention Center were not fully accessible to individuals with disabilities. The complainant provided information showing that design and initial construction of the Exhibition Hall occurred prior to January 26, 1992. Consequently, the Authority has an obligation to ensure "program accessibility" to those services, programs, and activities offered in the Exhibition Hall. A team of individuals from the Civil Rights Division conducted an on-site investigation of the Convention Center on June 9, 1994. Their review of the facility revealed several areas where modifications were necessary to insure program

accessibility for services, programs, and activities taking place in the Exhibition Hall. These observations included: 1) the bus and taxi loading zones were not accessible because they did not have curb ramps; 2) the Convention Center's entrance doors were too heavy, as the force required to open them was 10 lbs; 01-00433 -23) the box office counters were too high; 4) restrooms in the Exhibition Hall originally only had alternate stalls instead of the required larger standard stalls. At the time of the investigation, larger stalls closer in compliance to the Standards were being installed in three pairs of restrooms in the Exhibition Hall. However, signage in the restrooms was inadequate; the thresholds at some restroom entrances exceeded 1"; the knee space under the lavatories in some restrooms was less than 29"; and the pipes under the lavatories were not insulated; 5) there was no signage at phone banks without TDD's directing individuals with disabilities to phones with TDD'S; 6) the Lecture Hall lacked a permanently-installed assistive listening system; 7) there was no signage identifying seats with removable armrests in the Lecture Hall; 8) the Lecture Hall lacked an accessible route to the stage area. Through documentation, photographs, and oral assurances, the Authority has indicated that the following modifications have since taken place at the Convention Center: 1) an accessible bus and taxi drop-off and pick-up area has been designated at the West side of the 12th & Arch Street entrance;

2) automatic doors have been installed at the Convention Center's main entrances on the east and west sides of 12th & Arch Streets; 3) the Convention Authority now provides two accessible portable box offices; 4) 16 accessible stalls have been added to the restrooms in the Exhibition Hall. These stalls have been dispersed to insure that larger-sized accessible stalls are available in all parts of the Exhibition Hall. Signage has been added designating restrooms with the accessible stalls; thresholds at restroom entrances have been lowered to under 1"; the clearance space under the lavatories has been increased; and lavatory pipes have been insulated; 5) 10 public telephones with TDD's have been installed in 01-00434 -3the Convention Center (both coin- and card-operated) Signage designating the TDD's has been provided; 6) a permanently installed assistive listening system is now provided in the Lecture Hall and meeting rooms to accommodate individuals with hearing impairments; 7) seats with removable armrests have been replaced by wheelchair accessible spaces; 8) a portable lift has been purchased for the Lecture Hall to insure that individuals with mobility impairments have access to the stage. Because of the Authority's foregoing efforts to improve the accessibility of the programs and activities provided at the Pennsylvania Convention Center, we are closing our investigation of this complaint. The Department of Justice is not certifying that the changes made by the Authority are in full compliance with the Standards. Rather, the decision to close this investigation is based upon the information you have provided and

the Authority's representation that the alterations are in compliance with ADA requirements. This letter resolves only those matters set forth in the complaint that we received. It does not prohibit the Department from initiating future investigations in response to complaints about the accessibility of other services, programs, or activities undertaken by the Authority, and it does not limit the right of any individual to pursue through private litigation either the matters raised in our investigation or any other alleged violation of Title II of the ADA. We appreciate your cooperation with the investigation and resolution of this matter. If you or your staff have any questions, please feel free to call me at (202) 307-1378 (Voice) or (202) 307-2678 (TDD). In any correspondence regarding this matter, please reference the Department of Justice complaint number cited above. Sincerely,

Robb Wolfson Investigator Disability Rights Section Civil Rights Division cc: Mr. XX Ms. Shari Vegso-Wilson, Associate Advocate Eastern Paralyzed Veterans Association 01-00435