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;

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3) 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

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the 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

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