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APPROVE RESOLUTION TO ADOPT THE ADA SELF-EVALUATION AND TRANSITION PLAN UPDATE AS REQUIRED BY THE AMERICANS WITH DISABILITIES ACT (ADA)
recommended action
RECOMMENDATION
It is recommended that the City Council adopt a resolution:
1. Approving the proposed ADA Self-Evaluation and Transition Plan Update as required under the Americans with Disabilities Act; and
2. Finding the approval is exempt from the CEQA, pursuant to CEQA Guidelines Sections 15061(B)(3) and 15262; and
3. Authorizing the City Manager, or designee, to take actions that are necessary and appropriate to carry out the purpose and intent of the resolution.
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Summary
The Americans with Disabilities Act (ADA) requires state and local governments to provide people with disabilities equal access to their programs, services, and activities. The City’s ADA Self-Evaluation and Transition Plan update (Plan) supports the City’s ongoing compliance with Title II of the ADA by identifying policy-related, programmatic, and physical barriers to accessibility and provides a framework for removing those barriers over time.
The Plan (Exhibit 1 of the proposed Resolution) serves as a continuation to, and update of, the City’s 2004 ADA Self-Evaluation and Transition Plan and reflects current City programs, policies, facilities, and public right-of-way accessibility. The Plan includes a self-evaluation of City programs, activities, and services, an evaluation of City buildings, parks, parking facilities, and selected public right-of-way, and provides recommendations for barrier removal and an implementation framework for prioritizing accessibility improvements over time.
The City contracted with Harris & Associates to provide professional consulting services for the Public Facility Fee (PFF) program update, as well as an update of the City’s ADA Self-Evaluation and Transition Plan. Both efforts have progressed concurrently. Moore Iacofano Goltsman, Inc. (MIG) serves as a subconsultant to Harris and has assisted the City with preparation of the updated Plan. The Plan was developed through a multi-year process that included physical facility evaluations, interdepartmental and legal review, stakeholder engagement, and public review. Adoption of the Plan will establish the City’s updated framework for ongoing ADA improvements and support continued eligibility for certain State transportation funding that requires a current ADA Transition Plan.
DISCUSSION
Background
Title II of the Americans with Disabilities Act (ADA) applies to state and local government programs, activities, and services. Public entities are required to evaluate their programs, services, policies, and practices for accessibility. Public entities with 50 or more employees are also required to designate an employee responsible for ADA compliance, establish notice and grievance procedures, and prepare a transition plan when structural changes are necessary to achieve program accessibility.
On October 19, 2004, City Council adopted Resolution No. 04-0726, approving the City’s 2004 ADA Self-Evaluation and Transition Plan. The proposed Plan continues and updates that effort, and reflects current accessibility standards, City programs and practices, facility conditions, and implementation priorities. The ADA Self-Evaluation and Transition Plan Update was included within the scope of the City’s broader Public Facilities Fee Program Update, which was competitively solicited through a Request for Proposals (PUR 20-022). In 2021, the City entered into a professional services agreement with Harris & Associates, Inc. to lead the project, which included the PFF Nexus Study, master infrastructure planning efforts, and the ADA Plan Update. Moore Iacofano Goltsman, Inc. (MIG) serves as a subconsultant to Harris & Associates for preparation of the ADA Self-Evaluation and Transition Plan Update.
As part of the update, the City evaluated its policies, programs, and procedures, and conducted physical facility evaluations to identify accessibility barriers and potential corrective actions. The evaluations included City buildings, parks, parking facilities, and selected portions of the public right-of-way where City programs, activities, and services are provided. During the update process, several draft iterations were developed and underwent interdepartmental and legal review.
Public and stakeholder engagement was an important component of the update. The City assembled an accessibility stakeholder group that included participants from the Mayor’s ADA Roundtable, individuals with lived experience of disability-related challenges, and organizations with knowledge of accessibility needs within the Stockton community. The stakeholder group provided input regarding accessibility barriers, community priorities, and opportunities for improvement. Additional information regarding stakeholder participation and public outreach is included in Attachment A - Public Outreach Documentation.
Present Situation
The updated Plan addresses both programmatic and physical accessibility. The self-evaluation included a City staff questionnaire, review of City policies and programs, and review of City standards and specifications for the public right-of-way. The Plan identifies physical accessibility barriers and establishes approaches for barrier removal at City facilities and within the public right-of-way.
The Plan proposes a preliminary 15-year strategy to prioritize barrier removal at City buildings and provides a policy and maintenance framework to establish a consistent approach for barrier removal in the public right-of-way. The Plan also provides flexibility to modify barrier removal priorities over time in response to community requests, requests for reasonable modifications from people with disabilities, changes in City programs, and funding opportunities and constraints. The City’s ADA Coordinator or designee is responsible for ensuring that barrier removal is implemented in accordance with the Plan.
Public and stakeholder engagement has also been incorporated into the Plan update:
• On October 30, 2025, City staff provided an update on the ADA Self-Evaluation and Transition Plan at the Mayor’s ADA Roundtable, including an overview of the Plan’s purpose, project status and progress, anticipated next steps, and opportunities for continued stakeholder participation.
• The City held its first stakeholder meeting on May 5, 2026, to introduce the project and planning process, present the Self-Evaluation summary, and provide an overview of relevant City policies and programs. Stakeholders also provided feedback on accessibility within the City, including needs, challenges, opportunities, and priorities, which were considered in the Plan update.
• On August 17, 2026, the City issued a press release announcing the availability of the draft Plan and the upcoming public review period. The notice was posted on the City’s Newsroom, ADA webpage, and distributed through Ask Stockton notifications.
• Following the press release, a public review and comment period took place from August 18, 2026, through September 17, 2026.
• A second stakeholder meeting was held on August 25, 2026, to present the completed draft Plan and receive additional stakeholder feedback.
• The City also held a public webinar on September 15, 2026, to provide an overview of the Plan and additional opportunity for public input.
The Plan update is not a “project” under California Environmental Quality Act (CEQA) Guidelines Section 15378(c)(3) and (c)(2) because it will not result in a direct or reasonably foreseeable indirect physical change in the environment. To the extent it is determined to be a “project”, it is exempt under Section 15061(B)(3) because CEQA applies only to projects that have the potential for causing a significant effect on the environment, and here there is no possibility that the activity in question may have a significant effect on the environment. Additionally, the Plan update is statutorily exempt under CEQA Guidelines Section 15262 because it is a planning study for future actions that the City has not yet approved, adopted, or funded. Accordingly, staff has prepared a Notice of Exemption to be filed after approval (Exhibit 1 of the proposed Resolution).
FINANCIAL SUMMARY
Adoption of the ADA Self-Evaluation and Transition Plan Update does not, by itself, appropriate funding or authorize expenditures for individual barrier removal projects. The Plan establishes a framework for prioritizing accessibility improvements over time, with individual projects to be considered through the City’s applicable budget, capital improvement, maintenance, project approval processes, and projects and improvements identified through the ADA grievance process.
Maintaining a current ADA Self-Evaluation and Transition Plan is also a condition associated with certain State transportation funding received by the City. Adoption of the updated Plan will support the City’s continued eligibility for those funding sources.
Attachment A - Public Outreach Documentation