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15.20.015 Express Findings.
15.20.020 Amendments to Chapter 1, Division II of the California Plumbing Code.
15.20.010 Adoption of the Plumbing Code.
Except as provided in this chapter, the 2025 California Plumbing Code, including Appendix Chapters A, B, D, H, I and J, based on the 2024 Uniform Plumbing Code as published by the International Association of Plumbing and Mechanical Officials (IAPMO), shall be and become the plumbing code of the City of Coachella, regulating erection, installation, alteration, repair, relocation, replacement, maintenance or use of plumbing systems within the City. The California Plumbing Code will be on file for public examination in the office of the Building Official.
15.20.020
The 2025 Edition of the California Plumbing Code is hereby adopted with no amendments.
SECTION 7. Code Amendment.
Chapter 15.24 of Title 15 of the Coachella Municipal Code is hereby amended in its entirety to read as follows:
“Chapter 15.24 Fire Code
15.24.010 Adoption of the Fire Code.
15.24.020 Amendments to the Fire Code.
15.24.010 Adoption of the Fire Code.
Except as stated in this section or as amended below, all of the provisions and appendices of the 2025 California Fire Code, inclusive of all of the inclusions and exclusions set for in each chapter's matrix, are hereby adopted and shall apply to the City of Coachella. In addition, the following provisions that are excluded in the 2025 California Fire Code are hereby adopted - Chapter 1, Division II of the California Fire Code is hereby adopted, except that Sections 103.2 and 112.3 are not adopted, and Chapters 3, 25, Sections 403.11, 503, 510.2, 1103.2, and 5707, and Appendix N are adopted. The California Fire Code and its adopted appendices and amendments are on file for public examination in the office of the Building Official.
15.24.020 Amendments to the Fire Code.
A. SCOPE AND GENERAL REQUIREMENTS.
1. Section 101.4 of the California Fire Code is deleted in its entirety and replaced with the following:
101.4 Severability. If any provision, clause, sentence or paragraph of
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this code or the application thereof to any person or circumstances shall be held invalid, such invalidity shall not affect the other provisions of this code which can be given effect without the invalid provision or application, and to this end, the provisions of this code are hereby declared to be severable.
B. APPLICABILITY.
1. Section 102.5 of the California Fire Code is amended as follows:
102.5 Application of residential code. Where structures are designed and constructed in accordance with the California Residential Code, the provisions of this code shall apply as follows:
1. Construction and design provisions of this code pertaining to the exterior of the structure shall apply including, but not limited to, premises identification, fire apparatus access and watersupplies. Where interior or exterior systems or
devices are installed, construction permits required by Section 105.6 of this code shall apply.
2. Administrative, operational and maintenance provisions of this code shall apply.
3. Automatic fire sprinkler system requirements of this code shall apply to detached accessory buildings 3,600 square feet or greater in accordance with Section 903.2. The provisions contained in Section 903.2.18 of the California Fire Code or Section R317.5.1 of the California Residential Code may be used for the design of the automatic fire sprinkler system for detached private garages.
2. A new Section 102.13.1 is added to Section 102.13 of the California Fire Code to read as follows:
102.13.1 Application of the California Wildland-Urban Interface Code. Where a conflict exists between the provisions of this code and the California Wildland-Urban Interface Code, the more restrictive provisions shall apply.
C. DEPARTMENT OF FIRE PREVENTION
1. Sections 104.8 and 104.8.1 of the California Fire Code are deleted in their entirety and replaced with the following:
104.8 Liability. Any liability against the County of Riverside or the City of Coachella or any officer or employee for damages resulting from the discharge of their duties shall be as provided by law.
D. GENERAL AUTHORITY AND RESPONSIBILITIES.
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1. A new Section 104.1.1 is added to Section 104.1 of the California Fire Code to read as follows:
104.1.1 Authority of the Fire Chief, Chief Deputy, and Fire Department.
1. The Fire Chief, Chief Deputy, or their designee, is authorized and directed to enforce all applicable State fire laws and provisions of this code and to perform such duties as directed by the City Council.
2. The Fire Chief, Chief Deputy, or their designee, is authorized to administer, interpret and enforce this code. Under the Fire Chief, Chief Deputy, or their designee’s direction, the Riverside County Fire Department is authorized to enforce ordinances of the City of Coachella pertaining to the
following:
2.1. The prevention of fires.
2.2. The suppression or extinguishment of dangerous or
hazardous fires.
2.3. The storage, use and handling of hazardous materials.
2.4. The installation and maintenance of automatic, manual and other private fire alarm systems and fire
extinguishing equipment.
2.5. The maintenance and regulation of fire escapes.
2.6. The maintenance of fire protection and the elimination of fire hazards on land, in buildings, structures and other property, including those under construction.
2.7. The maintenance of means of egress.
2.8. The investigation of the cause, origin and
circumstances of fire and unauthorized releases of
hazardous materials.
3. The following persons are hereby authorized to interpret and enforce the provisions of this code and to make arrests and issue citations as authorized by law:
3.1. The Unit Chief, Peace Officers and Public Officers of the California Department of Forestry and Fire
Protection.
3.2. The Fire Chief, Chief Deputy, Peace Officers and
Public Officers of the Riverside County Fire
Department.
3.3. The Riverside County Sheriff and any deputy sheriff.
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3.4. The Police Chief and any police officer of the City.
3.5. Officers of the California Highway Patrol.
3.6. Code Officers of the City of Coachella Code
Enforcement Department.
3.7. Peace Officers of the California Department of Parks and Recreation.
3.8. The law enforcement officer of the Federal Bureau of Land Management.
2. Section 104.2 of the California Fire Code is deleted and replaced with the following:
104.2 Determination of compliance. The fire code official shall have the authority to determine compliance with this code, to render interpretations of this code and to develop policies, procedures, guidelines, standards, and information bulletins in order to clarify the application of its provisions. Such interpretations, policies, procedures:
1. Shall be in compliance with the intent and purpose of this code.
2. Shall not have the effect of waiving requirements specifically provided for in this code.
3. Shall be enforceable as part of this code.
3. Section 104.12 is added to Section 104 of the California Fire Code to read as follows:
104.12 Authority of the Fire Chief to close hazardous fire areas.
Except upon National Forest Land, the Fire Chief is authorized to determine and announce the closure of any hazardous fire area or portion thereof. Any closure by the Fire Chief for a period of more than fifteen (15) calendar days must be approved by the Riverside County Board of Supervisors of the County of Riverside and/or the City Council of the City of Coachella within fifteen (15) calendar days of the Fire Chief's original order of closure. Upon such closure, no person shall go in or be upon any hazardous fire area, except upon the public roadways and inhabited areas. During such closure, the Fire Chief shall erect and maintain at all entrances to the closed area sufficient signs giving notice of closure. This section shall not prohibit residents or owners of private property within any closed area, or their invitees, from going in or being upon their lands. This section shall not apply to any entry, in the course of duty, by a peace officer, duly authorized public officer or fire department personnel. For the purpose of this section, "hazardous fire area" shall mean public or private land that is
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covered with grass, grain, brush or forest and situated in a location that makes suppression difficult resulting in great damage. Such areas are designated on Hazardous Fire Area maps filed with the office of the Fire Chief.
E. FEES.
1. Section 108.2 of the California Fire Code is deleted in its entirety and replaced with the following:
108.2 Schedule of permit fees. Fees for services and permits shall be as set forth in the City of Coachella fee schedule adopted by the City Council.
2. A new Section 108.7 is added to Section 108 of the California Fire Code to read as follows:
108.7 Cost recovery. Fire suppression, investigation, rescue or emergencymedical costs are recoverable in accordance with Health and Safety Code Sections 13009 and 13009.1, as may be amended from time to time. Additionally, any person who negligently, intentionally or in violation of law causes an emergency response, including, but not limited to, a traffic accident, spill of toxic or flammable fluids or chemicals is liable for the costs of securing such emergency, including those costs pursuant to Government Code Section 53150 et seq., as may be amended from time to time. Any expense incurred by the Riverside County Fire Department for securing such emergency shall constitute a debt of such person and shall be collectable by Riverside County in the same manner as in the case of an obligation under contract, express or implied.
F. BOARD OF APPEALS.
1. Section 112.1 of the California Fire Code is deleted in its entirety and replaced with the following:
112.1 Board of appeals established. The Board of Appeals shall be the City Manager. If he or she determines an outside board is needed, he or she shall designate an outside hearing officer to hear the appeal. The Fire Chief and Chief Deputy shall be notified of any appeal and the Fire Chief or designee shall be in attendance at the appeal hearing.
Depending on the subject of the appeal, specialized expertise may be solicited, at the expense of the applicant, for the purpose of providing input to the Appeals Board.
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G. VIOLATIONS.
1. Section 113.4 of the California Fire Code is deleted in its entirety and replaced with the following:
113.4 Violation and penalties. It shall be unlawful for any person, firm, corporation or association of persons to violate any provision of this code, or to violate the provisions of any permit granted pursuant to this code or the Coachella Municipal Code. Punishments and penalties for violations shall be in accordance with the City of Coachella ordinances, fee schedule and Health and Safety Code Sections 17995 through 17995.5.
H. DEFINITIONS
1. Section 202, definition of "Fire Chief in the California Fire Code is deleted in its entirety and replaced with the following:
FIRE CHIEF. The Fire Chief of Riverside County or the Fire Chief’s designee.
I. OPEN FLAMES.
1. Section 308.1.7 of the California Fire Code is deleted in its entirety and replaced with the following:
308.1.7 Sky lanterns or similar devices. A person shall not release or cause to be released a sky lantern or similar device.
J. FIRE APPARATUS ACCESS ROADS.
1. A new Section 503.1.2.1 is added to Section 503 of the California Fire Code to read as follows:
503.1.2.1 Remoteness. Unless otherwise approved, where two fire apparatus access roads are required, they shall be placed a distance apart equal to not less than one-half of the length of the maximum overall diagonal dimension of the property or area to be served, measured in a straight line between accesses.
2. Section 503.2.1 of the California Fire Code is deleted in its entirety and replaced with the following:
503.2.1 Dimensions. Fire apparatus access roads shall have an unobstructed width of not less than 24 feet (7315 mm), exclusive of shoulders, except for approved security gates in accordance with Section 503.6, and an unobstructed vertical clearance of not less than 13 feet 6 inches (4115 mm). For additional requirements or alternatives see Riverside County Fire Department Standards and Policies, as may be amended from time to time.
3. Section 503.2.2 of the California Fire Code is deleted in its entirety and
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replaced with the following:
503.2.2 Authority. The fire code official shall be the only authority authorized to designate fire apparatus access roads and fire lanes and to modify the minimum fire lane access widths for fire or rescue operations.
4. A new Section 503.6.1 is added to Section 503.6 of the California Fire Code to read as follows:
503.6.1 Automatic opener. New motorized gates shall be provided with means to be automatically opened remotely by emergency vehicle in accordance with Riverside County Fire Department standards and policies, as may be amended from time to time.
Exception: Gates serving individual one- and two-family dwelling parcels.
A new Section 503.7 is added to Section 503 of the California Fire Code to read as follows:
503.7 Loading areas and passenger drop-off areas. On private properties, where fire apparatus access roads are utilized for loading or unloading or utilized for passenger drop-off or pick-up, an additional eight (8) feet of width shall be added to the minimum required width for the fire apparatus access road.
K. FIRE PROTECTION WATER SUPPLIES.
1. A new Section 507.5.7 is added to Section 507 of the California Fire Code to read as follows:
507.5.7 Fire hydrant size and outlets. As determined by the fire code official, fire hydrant sizes and outlets shall be based on the following:
1. Residential Standard - one (1) four (4) inch outlet and one (1) two and half (2 ½) inch outlet.
2. Super Hydrant Standard - one (1) four (4) inch outlet and two (2) two and one half (2 ½) inch outlet.
3. Super Hydrant Enhanced - two (2) four (4) inch outlet and one (1) two and one half (2 ½) inch outlet.
2. A new Section 507.5.8 is added to Section 507 of the California Fire Code to read as follows:
507.5.8 Fire hydrant street marker. Fire hydrant locations shall be visually indicated in accordance with Riverside County Fire Department Guidelines, as may be amended from time to time. Any hydrant marker damaged or removed during the course of street construction or repair shall be immediately replaced by the contractor, developer or person responsible for removal or damage.
L. FIRE COMMAND CENTER.
1. Section 508.1 of the California Fire Code is deleted in its entirety and replaced with the following:
508.1 General. Where required by other sections of this code and in all
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buildings classified as high-rise buildings by the California Building Code, in buildings greater than 300,000 square feet (27,870 m2), in area and in Group I-2 occupancies having occupied floors located more than 75 feet above the lowest level of fire department vehicle access, a fire command center for fire department operations shall be provided and comply with Sections 508.1.1 through 508.1.7.
2. Section 508.1.1 of the California Fire Code is deleted in its entirety and replaced with the following:
508.1.1 Location and access. The fire command center shall be located adjacent to the main lobby and shall be accessible from fire department vehicular access or as approved by the fire code official. The room shall have direct access from the building exterior at the lowest level of fire department access.
3. Section 508.1.3 of the California Fire Code is amended as follows:
508.1.3 Size. The fire command center shall be not less than 0.015 percent of the total building area of the facility served or 200 square feet (19 m2) in area, whichever is greater, with a minimum dimension of 0.7 times the square root of the room area or 10 feet (3,048 mm), whichever is greater. Where a fire command center is solely required because a building is greater than 300,000 square feet (27,870 m2), the fire command center shall have a minimum size of 96 square feet (9 m2) with a minimum dimension of 8 feet (2,438 mm) where approved by the fire code official.
M. FIRE PROTECTION AND UTILITY EQUIPMENT
IDENTIFICATION AND LOCATION.
1. A new Section 509.2.1 is added to Section 509 of the California Fire Code to read as follows:
509.2.1 Minimum clearances. A 3-foot (914 mm) clear space shall be maintained around the circumference of exterior fire protection system control valves, or any other exterior fire protection system component that may require immediate access, except as otherwise required or approved.
N. MECHANICAL REFRIGERATION.
1. Section 608.11.1.2 of the California Fire Code is deleted in its entirety and replaced with the following:
608.11.1.2 Manual operation. When required by the fire code official, automatic crossover valves shall be capable of manual operation. The manual valves shall be located in an approved location immediately outside of the machinery room in a secure metal box or equivalent and marked as Emergency Controls.
O. COMMERCIAL COOKING SYSTEMS.
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1. A new Section 904.14.3.2 is added the California Fire Code to read as follows:
904.14.3.2 Activation of the Fire Alarm System. Where a fire alarm signaling system, or a Dedicated Function Fire Alarm System (with available points of connection) is serving the occupancy where the extinguishing system is located, the actuation of the automatic fire-extinguishing system shall actuate the fire alarm signaling system in accordance with the requirements of NFPA 72.
P. AUTOMATIC SPRINKLER SYSTEMS.
1. Section 903.2 of the California Fire Code is deleted in its entirety and replaced with the following:
903.2 Where required. In all new buildings and structures which are 3,600 square feet or greater, an approved automatic sprinkler system shall be provided regardless of occupancy classification. Where Sections 903.2.1 - 903.2.20 of the California Fire Code require more restrictive requirements than those listed below, the more restrictive requirement shall take precedence. In addition, the following is required for existing buildings/structures:
1. All new tenants and new occupancies hereafter constructed, which exceed 3, 600 square feet shall have an approved automatic fire sprinkler system installed throughout therein.
2. All existing occupancies to which additions are made, where either the addition itself or the building and the addition in total exceeds 3,600 square feet, shall have an approved automatic fire sprinkler system installed throughout therein.
3. Change of use or occupancy that exceeds 3,600 square feet shall have an approved automatic fire sprinkler system installed throughout therein.
Exceptions: Unless required elsewhere in this code or the California Building Code, automatic fire sprinkler systems shall not be required for the following:
1. Detached Group U occupancies used for
agricultural purposes constructed in accordance
with the California Building Code.
2. Detached non-combustible equestrian arena shade canopies that are open on all sides and used for riding only - no commercial, assembly or storage uses.
3. Detached fabric or non-combustible shade structures that are open on all sides and used to shade playground equipment, temporary storage of vehicles and dining areas with no
cooking.
4. Where determined by the Fire Chief that no major life
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safety hazard exists, and the fuel load does not pose a significant threat to firefighter safety or to other structures or property, automatic fire sprinklers may be exempted.
5. Non-combustible fueling station canopies not exceeding 5,500 square feet.
One- and two-family dwellings shall have an automatic fire sprinkler system regardless of square footage in accordance with the California Residential Code. Fire sprinkler systems shall be installed in mobilehomes, manufactured homes and multifamily manufactured homes with two dwelling units in accordance with Title 25 of the California Code of Regulations.
The following exceptions in the California Fire Code shall not be allowed:
a. Exception in Section 903.2.3
b. Exception in Section 903.2.11.3
2. A new Section 903.3.5.3 is added to Section 903 of the California Fire Code to read as follows:
903.3.5.3 Hydraulically calculated systems. The design of hydraulically calculated fire sprinklersystemsshall not exceed 90% of the watersupply capacity.
Q. GENERAL FIRE PROTECTION AND LIFE SAFETY FEATURES.
1. A new Section 3206.4.2 is added to the California Fire Code to read as follows:
3206.4.2 Minimum requirements for client leased or occupant owned warehouses. Designs of an automatic sprinkler system for client leased or occupant owned buildings containing high pile storage shall be based on the requirements of NFPA 13. Unless otherwise approved a Professional Engineer, licensed in the State of California shall perform a survey of the building to determine commodity classification, storage configuration, building height and other information related to the development of an appropriate sprinkler system design. The engineer shall also make reasonable efforts to meet with the building owner or operator to understand seasonal or customer related fluctuations to the stored commodities, storage height, and configuration. The sprinkler design shall be based on the most demanding requirements determined through the onsite survey and discussions with the building owner or operator.
The technical report shall describe the basis for determining the commodity and sprinkler design selection, how the commodities will be isolated or separated, and include references to the design document(s). If a specific fire test is used as the basis of design, a copy of the fire test report shall be provided at the time of plan review.
R. MOBILE FOOD PREPARATION VEHICLES.
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1. A new Section 4107 is added to Chapter 41 of the California Fire Code to read as follows:
4107 MOBILE FOOD PREPARATION VEHICLES
4107.1 General. Mobile food preparation vehicles that are equipped with appliances that produce smoke or grease-laden vapors shall comply with this section.
4107.2 Maintenance. Maintenance of systems on mobile food preparation vehicles shall be in accordance with Sections 4107.2.1 through 4107.2.3. 4107.2.1 Exhaust system. The exhaust system, including hood, grease-removal devices, fans, ducts and other appurtenances, shall be inspected and cleaned in accordance with Section 606.3. 4107.2.2 Fire protection systems and devices. Fire protection systems and devices shall be maintained in accordance with Section 901.6.
4107.2.3 Fuel gas systems. LP-gas containers installed on the vehicle and fuel-gas piping systems shall be inspected annually by an approved inspection agency or a company that is registered with the U.S. Department of Transportation to requalify LP-gas cylinders, to ensure that system components are free from damage, suitable for the intended service and not subject to leaking. CNG containers shall be inspected every 3 years in a qualified service facility. CNG containers shall not be used past their expiration date as listed on the manufacturer’s container label. Upon satisfactory inspection, the approved inspection agency shall affix a tag on the fuel gas system or within the vehicle indicating the name of the inspection agency and the date of satisfactory inspection.
S. . FIREWORKS DISPLAY.
1. A new Section 5608.2 is added to Section 5608 of the California Fire Code to read as follows:
5608.2 Fallout Area. For aerial shells, the minimum required radius of the fallout area shall be 100 ft/in. (22 m/25 mm) of the internal mortar diameter of the largest aerial shell to be fired, unless otherwise approved.
T. APPENDIX B.
1. A new Section B103.2.1 is added to Section B103.2 of the California Fire Code to read as follows:
B103.2.1 Wildland-Urban Interface Area Subdivisions. The minimum fire flow for any new subdivision or tract constructed within a WildlandUrban Interface Area shall be 1,500 gallons per minute.
2. Table B105.2 of the California Fire Code is amended as
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follows:
TABLE B105.2
REQUIRED FIRE-FLOW FOR BUILDINGS OTHER
THAN ONE- AND TWO-FAMILY
DWELLINGS, GROUP R-3 AND R-4 BUILDINGS AND TOWNHOUSES
AUTOMATIC SPRINKLER
SYSTEM
(Design Standard)
MINIMUM FIRE-FLOW
(gallons per minute)
FLOW DURATION
(hours)
No automatic sprinkler
system
Value in Table B105.1(2) Duration in Table B105.1(2)
Section 903.3.1.1 of the
California Fire Code
50% of the value in Table
B105.1(2)a
Duration in Table B105.1(2) at
the reduced flow rate
Section 903.3.1.2 of the
California Fire Code
50% of the value in Table
B105.1(2)b
Duration in Table B105.1(2) at
the reduced flow rate
For SI: 1 gallon per minute = 3.785 L/m.
a. The reduced fire-flow shall be not less than 1,000 gallons per minute. b. The reduced fire-flow shall be not less than 1,500 gallons per minute.
U. APPENDIX C.
1. Section C103.1 of the California Fire Code is deleted in its entirety and replaced with the following:
C103.1 Hydrant spacing. Fire apparatus access roads and public streets providing required access to buildings in accordance with Section 503 of the California Fire Code shall be provided with one or more fire hydrants, as determined by Section C102.1. Where more than one fire hydrant isrequired, the distance between required fire hydrants shall be in accordance with Sections C103.2 and C103.3. Fire hydrants shall be provided at street intersections.
SECTION 8. Amendment.
Chapter 15.26 is hereby added to Title 15 of the Coachella Municipal Code as follows:
“Chapter 15.26 California Wildland-Urban Interface Code
15.26.010 Adoption of the California Wildland-Urban Interface Code.
15.26.020 Amendments to the California Wildland-Urban Interface Code.
15.26.010 Adoption of the California Wildland-Urban Interface Code.
Except as stated in this Section, all of the provisions and appendices of the 2025 California Wildland-Urban Interface Code, inclusive of all of the inclusions and exclusions set for in each chapter's matrix, are hereby adopted and shall apply to the City of Coachella. In
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addition, the following provisions that are excluded in the 2025 California Wildland-Urban Interface Code – Chapter 1, Division II of the California Wildland-Urban Interface Code is hereby adopted, except that Sections 103.2 and 112.3 are not adopted, and sections A101 through A102.2, A102.4, A104, A105.1, A105.4 through A105.4.2, A106 through A106.2 and A107 through A107.5 are adopted.
15.26.20 Amendments to the California Wildland-Urban Interface Code.
A. APPLICABILITY A new Section 102.4.1.1 is added to Section 102.4.1 of the California Wildland-Urban Interface Code to read as follows:
102.4.1.1 Application of the California Wildland-Urban Interface Code.
Where a conflict exists between the provisions of the Coachella Municipal Code and the California Wildland-Urban Interface Code, the more restrictive provisions shall apply.
A. DUTIES AND POWERS OF THE CODE OFFICIAL.
1. A new Section 104.l.l is added to Section 104.1 of the California Wildland-Urban Interface Code to read as follows:
104.1.1 Authority of the Fire Chief, Chief Deputy, and Fire Department.
1. The Fire Chief, Chief Deputy, or their designee is authorized and directed to enforce all applicable State fire laws and provisions of this code and to perform such duties as directed by the Coachella City Council.
2. The Fire Chief, Chief Deputy, or their designee is authorized to administer, interpret and enforce this code. Under the Fire Chief, Chief Deputy, or their designee’s direction, the Riverside County Fire Department is authorized to enforce ordinances of the City of Coachella pertaining to the following:
2.1. The prevention of fires.
2.2. The suppression or extinguishment of dangerous or hazardous fires.
2.3. The storage, use and handling of hazardous materials.
2.4. The installation and maintenance of automatic, manual and other private fire alarm systems and fire extinguishing equipment.
2.5. The maintenance and regulation of fire escapes.
2.6. The maintenance of fire protection and the elimination of fire hazards on land, in buildings, structures and other property, including those under construction.
2.7. The maintenance of means of egress.
2.8. The investigation of the cause, origin and circumstances of fire and unauthorized releases of hazardous materials.
3. The following persons are hereby authorized to interpret and enforce the provisions of this code and to make arrests and issue citations as authorized by law:
3.1. The Unit Chief, Peace Officers and Public Officers of the California Department of Forestry and Fire Protection.
3.2. The Fire Chief, Peace Officers and Public Officers of the Riverside
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County Fire Department.
3.3. The Riverside County Sheriff and any deputy sheriff.
3.4. The Police Chief and any police officer of any city served by the Riverside County Fire Department.
3.5. Officers of the California Highway Patrol.
3.6. Code Officers of the Riverside County Code Enforcement Department.
3.7. Peace Officers of the California Department of Parks and Recreation.
3.8. The law enforcement officer of the Federal Bureau of Land Management.
B. Section 104.2 of the California Wildland-Urban Interface Code is deleted and replaced with the following:
104.2 Determination of compliance. The fire code official shall have the authority to determine compliance with this code, to render interpretations of this code and to develop policies, procedures, guidelines, standards, and information bulletins in order to clarify the application of its provisions. Such interpretations, policies, procedures:
1. Shall be in compliance with the intent and purpose of this code.
2. Shall not have the effect of waiving requirements specifically provided for in this code.
3. Shall be enforceable as part of this code.
C. Sections 104.8 and 104.8.1 of the California Wildland-Urban Interface Code are deleted in their entirety and replaced with the following:
104.8 Liability. Any liability against Riverside County, City of Coachella, or any officer or employee for damages resulting from the discharge of their duties shall be as provided by law.
D. PERMITS. Section 105.2 of the California Wildland-Urban Interface Code is deleted in it’s entirety and replaced with the following:
105.2 Permits Required. Unless otherwise exempted, buildings or structures regulated by this code shall not be erected, constructed, altered, repaired, moved, removed, converted, demolished or changed in use or occupancy unless a separate permit for each building or structure has first been obtained from the code official.
For buildings or structures erected for temporary uses, see Section A108.3.
Where required by the code official, a permit shall be obtained for the following activities, operations, practices or functions within a wildland-urban interface area:
1. Automobile wrecking yard.
2. Candles and open flames in assembly areas.
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3. Explosives or blasting agents.
4. Fireworks.
5. Flammable or combustible liquids.
6. Hazardous materials.
7. Liquefied petroleum gases.
8. Landscape and fuel modification zones.
9. Lumberyards.
10. Motor vehicle fuel-dispensing stations.
11. Open burning.
12. Pallet Yards.
13. Pyrotechnical special effects material.
14. Tents, canopies and temporary membrane structures.
15. Tire storage.
16. Welding and cutting operations.
E. FEES. Section 108.2 of the California Wildland-Urban Interface Code is deleted in its entirety and replaced with the following:
108.2 Schedule of permit fees. Fees for services and permits shall be as set forth in City of Coachella fee schedule.
F. A new Section 108.7 is added to Section 108 of the California Wildland-Urban Interface Code to read as follows:
108.7 Cost recovery. Pursuant to California Health and Safety Code sections 11374.5(b)(1), 13009 et seq., 25515(a), 25540(a), 25541 (a), California Government Code sections 53150 et seq, and all other provisions of law, all costs incurred by the Riverside County Fire Department and the City of Coachella for the inspection and enforcement of any provision of these Codes, the investigation of any fire, explosion or other hazardous condition, the suppression of fire, the response to a traffic collision or accident, the containment and/or mitigation of a hazardous materials release, and any rescue or rendering of medical or physical aid or assistance, may be charged to any responsible party, any person who violates these Codes or any person who, due to a negligent or unlawful act or omission, is responsible for or requires or causes the emergency response of Riverside County Fire Department. Any expense incurred by the Riverside County Fire Department for such an emergency response shall constitute a debt of such person and shall be collectible by the County and City of Coachella in the same manner as in the case of an obligation under contract, express or implied. These provisions shall be applied uniformly against all such persons in violation of a Penal Code, Vehicle Code, Health and Safety Code or other state law statutory violation; only a county official shall have authority to reduce or cancel the debt obligation
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arising from the incident.
G. INSPECTION AND ENFORCEMENT. Section 109.3.7 of the California Wildland-Urban Interface Code is deleted in its entirety and replaced with the following:
109.3.7 Violation and penalties. It shall be unlawful for any person, firm, corporation or association of persons to violate any provision of this code, or to violate the provisions of any permit granted pursuant to this code or City of Coachella Municipal Code Chapter 15.26. Punishments and penalties for violations shall be in accordance with Health and Safety Code Sections 17995 through 17995.5 and Government Code Section 51185.
H. DEFINITIONS. Section 202, definition of "Fire Chief” in the California Wildland-Urban Interface Code is deleted in its entirety and replaced with the following:
FIRE CHIEF. The Fire Chief of Riverside County or the Fire Chief’s designee.
I. WILDLAND-URBAN INTERFACE AREA DESIGNATIONS. Section 302.1.1 is added to Section 302.1 of the California Wildland-Urban Interface Code to read as follows:
302.1.1 Designation of Fire Hazard Severity Zones. The City of Coachella has adopted the recommendations of the State Fire Marshal made pursuant to Government Code section 51178 and designated those areas within the County as moderate, high, and very high fire hazard severity zones as shown on the Local Responsibility Area Fire Hazard Severity Zones Maps published by the Office of the State Fire Marshal. The Maps have been adopted under City of Coachella Ordinance No. 1429.
J. SPECIAL BUILDING CONSTRUCTION REGULATIONS. Section 501.1 of the California Wildland-Urban Interface shall be amended as follows:
501.1 Scope. Buildings and structures in a wildland-urban interface area shall be constructed in accordance with the California Building Code and this code.
For the purpose of this chapter, a wildland-urban interface area shall be defined as a geographical area identified by the state as a “Fire Hazard Severity Zone” in accordance with the Public Resources Code Sections 4201 through 4204 and Government Code Sections 51175 through 51189, and other areas designated by the enforcing agency to be at a significant risk from wildfires, and shall
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include those areas designated by City of Coachella Ordinance No. 1429 as moderate, high, and very high fire hazard severity zones based on recommendations from the State Fire Marshal pursuant to Government Code Section 51178.
Exceptions:
2. Group U accessory structures not exceeding 120 square feet (11 m2) in floor area where located not less than 50 feet (15 240 mm) from applicable buildings.
3. Group U agricultural buildings not less than 50 feet (15 240 mm) from applicable buildings.
K. FIRE PROTECTION PLANS. Section 602.1 of the California Wildland-Urban Interface Code is amended as follows:
602.1 General. A fire protection plan shall be submitted to the Fire Code Official for any proposed subdivision of land or building project. The fire protection plan shall be prepared to determine the acceptability of fire protection and life safety measures designed to mitigate wildfire hazards presented for the property under consideration.
The fire protection plan shall be prepared by a registered design professional, qualified landscape architect, qualified fire safety specialist or similar specialist acceptable to the code official and shall analyze the wildfire risk of the building, project, premises or region to recommend necessary changes.
Submittal of a preliminary fire protection plan shall be required prior to the submission of a final fire protection plan.
Exception: A single-family dwelling (Group R-3 Occupancy) when located on an existing legal parcel.
L. Section 602.3.2 of the California Wildland-Urban Interface Code is amended as follows:
602.3.2 Final Fire Protection Plan. Final fire protection plan shall include items listed in Section 602.3.1 and the following:
1. A map identifying all proposed plants in the fuel modification zones with a legend that includes a symbol for each proposed plant species.
The plan shall include specific information on each species proposed, including but not limited to:
1.1. The plant life-form;
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1.2. The scientific and common name; and
1.3. The expected height and width for mature growth.
2. Identification of irrigated and non-irrigated zones.
3. Requirements for vegetation reduction around emergency access and evacuation routes.
4. Identification of existing vegetation proposed to remain.
5. Identification of points of access for equipment and personnel to maintain vegetation in common areas.
6. Methods and timetables for controlling, changing, or modifying areas on the property.
7. Legally binding statements regarding community
responsibility for maintenance of fuel modification zones.
8. Legally binding statements to be included in covenants, conditions and restrictions regarding property owner
responsibilities for vegetation maintenance.
M. VEGETATION PLAN. Section 603.1 of the California Wildland-Urban Interface Code is amended as follows:
603.1 General. Planting of vegetation for new and replacement landscaping shall be selected to reduce vegetation in proximity to a structure and to maintain vegetation as it matures.
N. Section 603.3 of the California Wildland-Urban Interface Code is amended as follows:
603.3 Landscape and Fuel Modification plans. Landscape and Fuel Modification plans shall be submitted for any project located in a WUI area.
The landscape and Fuel Modification plan shall include development and maintenance requirements for the vegetation management zone adjacent to structures and roadways, and to provide significant fire hazard reduction benefits for public and firefighting safety.
O. Section 603.3.1 of the California Wildland-Urban Interface Code is amended as follows:
603.3.1 Contents. Landscape plans shall contain the following:
1. Delineation of the 5-foot (1524 mm) (Zone 0), 30-foot (9144 mm) (Zone 1) and 100-foot (30 480 mm) (Zone 2) fuel
management zones from all structures.
2. Identification of existing vegetation to remain and proposed new vegetation.
3. Identification of irrigated areas.
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4. A plant legend with both botanical and common names, and identification of all plant material symbols.
5. Identification of ground coverings within the 30-foot (9144 mm) zone.
P. MAINTENANCE OF DEFENSIBLE SPACE. Section 604.1 of the California Wildland-Urban Interface Code is amended as follows:
604.1 General. Vegetation and fuels shall be managed to reduce the severity of potential exterior wildfire exposure to buildings and to reduce the risk of fire spreading to buildings as required by applicable laws and regulations.
Q. Section 604.3 of the California Wildland-Urban Interface Code is amended as follows:
604.3 Requirements. Vegetation and fuels around all buildings and structures shall be maintained in accordance with the following laws and regulations:
1. Public Resources Code, Section 4291.
2. California Code of Regulations, Title 14, Division 1.5, Chapter 7, Subchapter 3, Article 3, Section 1299.03.
3. California Government Code, Section 51182.
4. California Code of Regulations, Title 19, Division 1, Chapter 7, Subchapter 1, Section 3.07.
5. The requirements of Appendix A of this code and Riverside County Fire Department Guidelines.
R. Section 604.3.1 is added to Section 604.3 of the California Wildland-Urban Interface Code to read as follows:
604.3.1 Retroactivity. When required by the Fire Code Official, or State Law, existing Defensible Space/Fuel Modification Zones (FMZ) shall require retrofitting, including thinning and/or removal of plants, trees, and vegetation, to meet this Code or State Law. Upon notification by the Fire Code Official, and when approved, work to bring an existing Defensible Space and FMZ into compliance with this Code, may be done over a two to four (2-4) year period as determined by the Fire Code Official. A compliance plan prepared by the property owner may be requested for review and approval by the Fire Code Official.
S. Section 604.6 is added to the California Wildland-Urban Interface Code to read as
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follows:
604.6 Clearance of brush, vegetative growth, and combustible material from improved parcels. All improved parcels declared a Public Nuisance shall be cleared entirely of combustible material. If the Fire Code Official determines this impractical, the provisions of Section 604.7 may be used.
T. Section 604.7 is added to the California Wildland-Urban Interface Code to read as follows:
604.7 Clearance of fuels or vegetative growth from structures. Clearance of fuels and vegetative growth from structures shall be per sections 604.7.1 through 604.7.4 of this code.
U. Section 604.7.1 is added to the California Wildland-Urban Interface Code to read as follows:
604.7.1 Structures. Any person owning, leasing, controlling, operating, or maintaining any Building or structure in, upon, or adjoining any Fire Hazard Severity Zone, governed by this section, and any person owning, leasing, or controlling any land adjacent to such Buildings, shall at all times maintain around and adjacent to such Building, an effective firebreak made by removing and clearing away, all combustible material on their property for a distance not less than 100 feet from all portions of the Building.
Distances may be increased by the Fire Code Official due to a site-specific analysis based on local conditions and when required, based on a Fire Protection Plan. This section shall not apply to single specimens or stands of protected species of trees, Ornamental Landscape or similar plants used in landscaping and ground covers, that are well-pruned, maintained, and spaced, and do not form a means of rapidly transmitting fire from other nearby vegetation to a structure or from a structure to other nearby vegetation or to interrupt the advance of embers toward a structure.
V. Section 604.7.2 is added to the California Wildland-Urban Interface Code to read as follows:
604.7.2 Timing for New Buildings and additions to Existing Buildings. The provisions of Section 604.7 shall be completed prior to vertical construction of any New Building or addition to an Existing Building.
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W. Section 604.7.3 is added to the California Wildland-Urban Interface Code to read as follows:
604.7.3 Photovoltaic Systems. The clearance requirements around freestanding photovoltaic systems and equipment shall comply with the following:
1. A minimum 10-foot clearance for clusters of panels not exceeding 1,500 square feet of combined panel area.
2. A minimum of 30-foot clearance for clusters of panels greater than 1,500 square feet of combined panel area.
3. Clusters shall be separated by a minimum of 20 feet.
4. Panels and clusters shall be not located within 30 feet of any Building subject to clearance requirements of Section 604 unless the clearance requirements of Section 604 are
provided as measured from the perimeter of the panel or cluster.
X. Section 604.8 is added to the California Wildland-Urban Interface Code to read as follows:
604.8 Defensible Space clearance zones and requirements. The required 100-foot Defensible Space clearance is identified in three (3) distinct zones:
Zone 0, 1, and 2.
Y. Section 604.8.1 is added to the California Wildland-Urban Interface Code to read as follows:
604.8.1 Requirements. Defensible Space shall be in accordance with the requirements of Appendix A of this code, Riverside County Fire Department Guidelines and the specific requirements for each zone listed in Sections 604.8.2 through 604.8.5.
Z. Section 604.8.2 is added to the California Wildland-Urban Interface Code to read as follows:
604.8.2 Zone 0 purpose and location. Zone 0 reduces the likelihood of structure ignition by reducing the potential for direct ignition of the structure from flame contact, by embers that accumulate at the base of a wall, and/or indirect ignitions when embers ignite vegetation, vegetative debris, or other combustible materials located close to the structure that result in either a radiant heat and/or a direct flame contact exposure to the structure.
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Zone 0 is the horizontal area within the first five (5) feet around the structure, including stairs, balconies, attached or adjacent decks, and outbuildings. Zone 0 is measured from the edge of a structure, attached or adjacent decks, patio covers, balconies, and floor projections above-grade. Zone 0 also includes the area on the roof of a building, and underneath and on top of attached decks, patio covers, balconies, and stair landings.
Advisory Notice: Riverside County Fire Department has local Zone 0 requirements currently in effect for new Buildings and additions to existing Buildings. New State regulations for Zone 0 are currently under development by the State Board of Forestry and Fire Protection. Any State regulation more restrictive than this code shall apply. This may require thinning and/or removal of plants, trees, and vegetation to meet State Law and regulations.
AA. Section 604.8.2.1 is added to the California Wildland-Urban Interface Code to read as follows:
604.8.2.1 Non-Combustible Zone 0 for New Buildings, additions to Existing Buildings, and new or replacement landscape. Fuels, including Combustible Materials and vegetation, are prohibited in Zone 0 for all New Buildings, additions to Existing Buildings, installation of new landscape, and refurbishment of existing landscape areas.
The application date of Section 604.8.2.1 shall be the later application date when any of the following occur:
1. Fire Department Clearance for a New Building or addition to an Existing Building.
2. Building permit for a New Building or addition to an Existing Building.
3. Landscape plans submitted for Riverside County Fire
Department review.
4. Replacement of landscape when landscape plans are not required.
BB. Section 604.8.2.2 is added to the California Wildland-Urban Interface Code to read as follows:
604.8.2.2 Additional requirements in Zone 0.
1. New and existing tree canopies are prohibited within 10 feet of New Buildings, including the addition portion to Existing Buildings.
Exception: Existing protected oak trees shall be trimmed to provide a minimum 5-foot clearance above the roof and 5 feet to the side of any New Building, or the addition portion to an Existing Building.
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2. Landscaped roofs are prohibited.
3. Vegetation underneath decks is prohibited.
4. Other Combustible Materials underneath any deck, not part of the deck structure itself, shall be removed.
5. Artificial or synthetic grass is prohibited within Zone 0.
6. Vines and climbing plants are not allowed on structures, including decks, patio/shade structures, and any fences within 5 feet of a Building.
7. Combustible mulch and wood chips are prohibited.
8. Firewood is prohibited.
9. All fencing and gates shall be non-combustible. See Section 604.11.
CC. Section 604.8.2.3 is added to the California Wildland-Urban Interface Code to read as follows:
604.8.2.3 Zone 0 requirements for Existing Buildings.
DD. Section 604.8.2.3.1 is added to the California Wildland-Urban Interface Code to read as follows:
604.8.2.3.1 Zone 0 restrictions. The following requirements apply within Zone 0 for all Existing Buildings with landscape installed prior to January 1, 2026:
1. No combustible landscape mulch or wood chips.
2. No firewood.
3. No vegetation underneath decks.
4. Other Combustible Materials underneath any deck, not part of the deck structure itself, shall be removed.
5. Roofs and gutters on Buildings shall be maintained free of any leaves, needles, or other vegetative Combustible Materials.
6. The vertical clearance distance for trees and vegetation above any roof shall be not less than 3 feet.
7. A minimum 3-foot clearance of trees and vegetation shall be provided to the side and above any eave or roof projection from the exterior wall of a Building. A minimum 3-foot clearance of trees and vegetation shall be provided below any eave or roof projection. This requirement also applies to any patio cover or other Building projections.
8. New trees are not allowed.
9. New or replacement landscaping shall comply with Sections 604.8.1, 604.8.2.1, and 604.8.2.2.
EE.Section 604.8.3 is added to the California Wildland-Urban Interface Code to read as follows:
604.8.3 Zone 1 purpose and location. Zone 1 reduces the likelihood of fire
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burning directly to the structure. This is accomplished by modifying Fuels and creating a discontinuity between planting groups that limits the pathways for fire to burn to the structure and reduces the potential for near-to-building ember generation and radiant heat exposures. An additional purpose of this zone is to provide a defendable area for fire personnel to stage and take direct action.
Zone 1 is the area within 5-30 feet of structures and decks, with slopes not greater than 20 percent; 5-50 feet from Buildings and decks, when slopes are greater than 20 percent.
FF. Section 604.8.3.1 is added to the California Wildland-Urban Interface Code to read as follows:
604.8.3.1 Requirements and allowable items. This is a minimal planting zone which includes very limited trees of a fire-smart type with additional spacing provided. Plants and other vegetation shall be in accordance with Appendix A of this code and Riverside County Fire Department Guidelines.
GG. Section 604.8.4 is added to the California Wildland-Urban Interface Code to read as follows:
604.8.4 Zone 2 purpose and location. Zone 2 is designed to reduce the potential behavior of an oncoming fire in such a way as to drop an approaching fire from the crown of trees to the ground, reducing the flame heights, and the potential for ember generation and radiant heat exposure to structures.
Additional benefits of the Zone 2 include facilitating direct defense actions and improving the function of Zones 0 and 1.
Zone 2 is the area from the outer edge of Zone 1 to 100 feet from structures and decks.
HH. Section 604.8.4.1 is added to the California Wildland-Urban Interface Code to read as follows:
604.8.4.1 Requirements and allowable items. Plants and other vegetation shall be in accordance with Appendix A of this code and Riverside County Fire Department Guidelines.
II. Section 604.8.4.2 is added to the California Wildland-Urban Interface Code to read as follows:
604.8.4.2 Spacing. Spacing of vegetation and trees at the outer edge of Zone 2 shall be based upon the height of the vegetation within Zone 2 or the adjacent area beyond the 100-foot zone, whichever provides for the greater spacing. This may require clearance outside the 100-foot zone or setting back vegetation and trees within Zone 2 away from the 100-foot line.
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JJ. Section 604.8.5 is added to the California Wildland-Urban Interface Code to read as follows:
604.8.5 General requirements for Zone 0, 1, and 2.
KK. Section 604.8.5.1 is added to the California Wildland-Urban Interface Code to read as follows:
604.8.5.1 Dead and dying vegetation. All dead or dying grass, plants, shrubs, trees, branches, leaves, weeds, and tree needles shall be removed.
LL.Section 604.8.5.2 is added to the California Wildland-Urban Interface Code to read as follows:
604.8.5.2 Mulch and wood chips within Zones 1 and 2. Use of combustible Mulch and wood chips shall be in accordance with the requirements Riverside County Fire Department Guidelines.
MM. Section 604.8.5.3 is added to the California Wildland-Urban Interface Code to read as follows:
604.8.5.3 Firewood. See Section 607.
NN. Section 604.8.5.4 is added to the California Wildland-Urban Interface Code to read as follows:
604.8.5.4 Clearance from chimney, stovepipe. Any portion of a tree or shrub that extends within 10 feet horizontally or vertically of a chimney outlet or stovepipe outlet shall be removed.
OO. Section 604.8.5.5 is added to the California Wildland-Urban Interface Code to read as follows:
604.8.5.5 Trees. New trees shall be planted and maintained so that the tree’s drip line at maturity is a minimum of 10 feet from any combustible structure.
PP. Section 604.8.5.5.1 is added to the California Wildland-Urban Interface Code to read as follows:
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604.8.5.5.1 Tree spacing. The horizontal distance between crowns of new trees and crowns of adjacent trees shall not be less than 20 feet in Zone 1 and not less than 10 feet in Zone 2. Separation distance may be increased for slopes exceeding 20 percent. Required spacing is measured between trees at maturity.
QQ. Section 604.8.5.5.2 is added to the California Wildland-Urban Interface Code to read as follows:
604.8.5.5.2 Ground clearance of trees. Trees exceeding 6 feet in height shall be limbed up from the ground 6 feet or 1/3 the height of the tree, whichever is less.
Exception: Fruit trees when approved by the Fire Code Official.
RR. Section 604.8.5.5.3 is added to the California Wildland-Urban Interface Code to read as follows:
604.8.5.5.3 Ground cover under tree canopy. When approved ground cover and shrubs are located underneath trees, the vertical clearance to the lowest branch of the tree canopy shall not be less than three times the height of the ground cover or shrub under or adjacent to the tree. The horizontal clearance shall be 3 feet from the trunk of the tree.
SS. Section 604.8.5.6 is added to the California Wildland-Urban Interface Code to read as follows:
604.8.5.6 Continuous tree canopies.
TT.Section 604.8.5.6.1 is added to the California Wildland-Urban Interface Code to read as follows:
604.8.5.6.1 New Structures. Continuous tree canopies are not allowed. Tree spacing shall be in accordance with Riverside County Fire Department Guidelines.
UU. Section 604.8.5.6.2 is added to the California Wildland-Urban Interface Code to read as follows:
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604.8.5.6.2 Existing Structures. Continuous tree canopies may be allowed as determined by the Fire Code Official but will require the complete removal of any understory and smaller trees to meet requirements for a shaded fuel zone.
Any remaining trees shall be limbed up a minimum of 12 feet from the ground or 1/3 the tree height, whichever is less. The intent is to not allow a crown (canopy) fire to spread unchecked to a structure and to bring any crown fire down to the ground level prior to Zone 1.
VV. Section 604.8.5.7 is added to the California Wildland-Urban Interface Code to read as follows:
604.8.5.7 Grasses. Natural or annual grasses shall be mowed to a maximum height of 4-inch stubble with clippings removed.
WW. Section 604.9 is added to the California Wildland-Urban Interface Code to read as follows:
604.9 Fire protection equipment and utilities. The clearance requirements of Sections 604.7 and 604.8 shall apply to communication site towers and their support Buildings; required fire protection water supplies, including water tanks, water supply pumps, and pump houses; and any other utility Structure as required by the Fire Code Official. The Fire Code Official may consider a reduced distance, not less than 30 feet, for communication site towers, water tanks, and Structures with no interior space, based upon a site risk assessment.
Also see Appendix A.
XX. Section 604.10 is added to the California Wildland-Urban Interface Code to read as follows:
604.10 Planting vegetation under or adjacent to energized electrical lines.
No vegetation shall be planted under or adjacent to energized power lines that, at maturity, will grow within 10 feet of the energized conductors.
YY. Section 604.11 is added to the California Wildland-Urban Interface Code to read as follows:
604.11 Fencing.
ZZ.Section 604.11.1 is added to the California Wildland-Urban Interface Code to read as follows:
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604.11.1 Scope. This section only applies to fences, including gates within the fencing, within 5 feet of Building(s), including Decks, (Zone 0) that are in an applicable Fire Hazard Severity Zone req by Chapter 6 of this code.
AAA. Section 604.11.2 is added to the California Wildland-Urban Interface Code to read as follows:
604.11.2 New fencing. New fencing and gates shall be constructed of a noncombustible material.
BBB. Section 604.11.3 is added to the California Wildland-Urban Interface Code to read as follows:
604.11.3 Existing fencing. Fencing installed prior to January 1, 2026, may remain.
Exception: The entire fencing not parallel and within 5 feet of the Building, including gates within the fencing, shall be constructed of a non-combustible material when any portion of the existing fencing within 5 feet is being replaced.
Fencing beyond 5 feet from the Building is not required to be replaced with non-combustible material.
CCC. STORAGE OF FIREWOOD AND COMBUSTIBLE MATERIALS.
Section 607.1 of the California Wildland-Urban Interface Code is amended to read as follows:
607.1 General. Firewood and combustible materials shall not be stored in unenclosed spaces beneath Buildings or Structures, or on Decks or under eaves, canopies, or other projections or overhangs. Firewood piles shall be located 30 feet (9144 mm) or more from structures unless completely covered by a fireresistant material. Exposed wood piles located within the defensible space shall have a minimum clearance of 10 feet (3048 mm) down to bare mineral soil in all directions. Firewood shall not be stored within Zone 0.
DDD. Section 607.1.1 of the California Wildland-Urban Interface Code is amended to read as follows:
607.1.1 Combustible Materials. Combustible Materials, other than vegetation, stored within Zones 1 and 2 shall not be stored so as to pose a hazard to any Building. Piles shall not exceed 100 square feet of area and a maximum height
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of 10 feet. Piles shall be separated by a minimum of 20-foot clear area.
EEE. Section 607.2 of the California Wildland-Urban Interface Code is amended to read as follows:
607.2 Storage for off-site use. Firewood and Combustible Materials not for consumption on the premises shall not be stored within Zones 0, 1, and 2. See Appendix A for storage requirements.
FFF. BUILDING SITING AND SETBACKS. Section 608.1.1 is added to the California Wildland-Urban Interface Code to read as follows:
608.1.1 Restricted development setbacks. New Structures and additions to existing Structures shall not be constructed less than 100 feet from any protected habitat, whether on the same or adjacent Parcels, where the 100-foot Defensible Space required under Section 604.7 cannot be provided, unless an alternate method of construction and protection is provided that can ensure the safety of the Structure and emergency responders as approved by the Fire Code Official.
Protected habitat includes lands restricted from brush clearance or modification due to Federal or State listed endangered species. Protected habitat does not include sensitive habitat areas.
GGG. Section 608.2 of the California Wildland-Urban Interface Code is amended to read as follows:
608.2 General. All parcels shall provide a minimum 30-foot (9144 mm) setback for all buildings from property lines and the center of a road, except as provided for in Section 608.2.1. [14 CCR §1276.00(a)] This section applies to new Tract and Parcel maps, new Buildings, and additions to Existing Buildings.
HHH. Section 608.2.1 of the California Wildland-Urban Interface Code is amended to read as follows:
608.2.1 Setback reduction. A reduction in the minimum setback shall be based upon practical reasons, which may include but are not limited to, parcel dimensions or size; topographic limitations; Development density requirements or other Development patterns that promote low-carbon emission outcomes; sensitive habitat or other site constraints, and shall provide for an alternative method to reduce structure-to-structure ignition by incorporating a combination
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of features such as, but not limited to:
1. Non-combustible block walls or fences; or
2. Non-combustible material extending 5 feet (1524 mm) horizontally from the furthest extent of the building; or
3. Hardscape landscaping; or
4. A reduction of exposed windows on the side of the structure with setback less than 30 feet (9144 mm). [14 CCR § 1276.01] III. RIDGELINES, FUEL BREAKS, AND GREENBELTS. Section 609.2.7.1 is added to the California Wildland-Urban Interface Code to read as follows:
609.2.7.1 Greenbelts. Subdivisions and other developments, which propose Greenbelts as a part of the development plan, shall locate the Greenbelts strategically, as a separation between wildland fuels and Structures. The locations shall be approved by the inspection authority.
JJJ. Section 609.2.7.2 is added to the California Wildland-Urban Interface Code to read as follows:
609.2.7.2 Access to Greenbelts. A minimum of one (1) access point shall be provided to new Greenbelts at an approved location to allow for on-going maintenance and firefighter access. Additional access points shall be provided when required by the Fire Code Official.
KKK. APPENDIX A. Section A102.1 of the California Wildland-Urban Interface Code is amended to read as follows:
A102.1 General. Vegetation control shall comply with Sections A102.2 through A102.4 and with Chapter 6.
LLL. Section A105.1 of the California Wildland-Urban Interface Code is amended to read as follows:
A105.1 General. In addition to the requirements of the California Fire Code, Ordinance 787 and Chapter 6, storage and use of the materials shall be in accordance with Sections A105.2 through A105.4.2.
MMM. Section A105.4 of the California Wildland-Urban Interface Code is
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amended to read as follows:
A105.4 Combustible Materials. Outside storage of Combustible Materials such as, but not limited to, wood, rubber tires, building materials, or paper products shall comply with the other applicable sections of this code and this section. Storage of pallets shall be in accordance with California Fire Code Section 2810. Storage and processing of wood chips, hogged materials, fines, Compost, Compostable Material, Mulch, solid biomass, raw product, and combustible yard waste and recycle material shall be in accordance with California Fire Code Section 2808.
SECTION 7. Amendment.
Chapter 15.32 of Title 15 of the Coachella Municipal Code is hereby amended in its entirety to read as follows:
“Chapter 15.32 Existing Building Code
15.32.010 Adoption of the Existing Building Code.
15.32.020 Amendments to the Existing Building Code.
15.32.010 Adoption of the Existing Building Code.
Except as provided in this chapter, the 2025 California Existing Building Code, including Appendices A-1, based on the 2024 International Existing Building Code, as published by the International Code Council (ICC), shall become the Existing Building Code of the City of Coachella for the purpose of regulating the repair, alteration, change of occupancy, addition to and relocation, structural strength, access, safety, lighting, ventilation and energy conservation of existing buildings in the City. The California Existing Building Code is on file for public examination in the office of the Building Official.
15.32.020 Amendments to the Existing Building Code.
A. Section 202, Definitions, is hereby amended by adding the following definitions:
Substantial Structural Damage. A condition where:
1. In any story, the vertical elements of the lateral force-resisting system, have suffered damage such that the lateral load-carrying capacity of the structure in any direction has been reduced by more than 20 percent from its pre-damaged condition, or
2. The capacity of any vertical gravity load-carrying component, or any group of such components, that supports more than 30 percent of the total area of the structure's floor(s) and roof(s) has been reduced more than 20 percent from its pre-damaged
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condition, and the remaining capacity of such affected elements with respect to all dead and live loads is less than 75 percent of that required by the building code for new buildings of similar structure, purpose, and location.” SECTION 10. CEQA Analysis. The City Council finds that the adoption of the California Buildings Standards Code and local amendments thereof is exempt from the California Environmental Quality Act (“CEQA”) under CEQA Guideline section 15061(b)(3) (the common sense exemption). The action is largely administrative in nature and designed to improve and not degrade environmental quality such that there is no possibility that adopting this Ordinance would adversely affect the environment in any manner that could be significant.
SECTION 12. Severability. If any section, subsection, subdivision, paragraph, sentence, clause, or phrase of this Ordinance, or any part thereof, is for any reason held to be invalid or unconstitutional by a decision of any court of competent jurisdiction, such decision shall not affect the validity of the remaining portions of this Ordinance, or any part thereof. The City Council hereby declares that it would have passed each section, subsection, subdivision, paragraph, sentence, clause or phrase thereof, irrespective of the fact that any one or more section, subsection, subdivision, paragraph, sentence, clause or phrase would be subsequently declared invalid or unconstitutional.
SECTION 13. Publication and Effective Date. The City Clerk shall certify to the passage and adoption of this Ordinance and shall cause this Ordinance to published or posted as required by law. This Ordinance shall take effect thirty (30) days after adoption.
PASSED, APPROVED, AND ADOPTED this ______ of _____________, 2026 by the following vote:
AYES:
NOES:
ABSENT:
ABSTAIN:
Steven Hernandez, Mayor
City of Coachella
ATTEST:
___________________________________
Angela M. Zepeda, City Clerk
City of Coachella
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APPROVED AS TO FORM:
___________________________________
Ryan Guiboa, Best Best & Krieger LLP
City Attorney
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Exhibit A
Findings to Support Amendments to the
2022 Edition of the California Building Standards Code
To the extent that changes and modifications to the 2025 California Building Standards Code in this ordinance are deemed more restrictive than the standards contained in the 2025 California Building Standards Code thus requiring that findings be made pertaining to local climatic, geological, or topographical conditions to justify such modifications, the City Council hereby finds and determines as follows:
A. Extreme surface temperatures common in the lower desert areas, one hundred sixty (160) degrees Fahrenheit plus, deteriorates and dries out buildings’ materials and our high winds create extreme fire conditions which are detrimental to the general public.
B. Every three years the State of California adopts a new California Fire Code, as part of the California Building Standards Code, which becomes effective 180 days after publication by the California Building Standards Commission.
C. The 2025 California Fire Code, California Code of Regulations, Title 24, Part 9, is based on the 2024 International Fire Code.
D. The City of Coachella may establish more restrictive standards reasonably necessary to provide fire protection for life and property because of the following local climatic, geological, or topographical conditions.
I. Climatic Conditions:
Riverside County and the City of Coachella have an arid climate with annual rainfall varying from three (3) inches in Blythe to over thirty-three (33) inches in Pine Cove. The County also experiences annual hot, dry Santa Ana Winds, which contribute to fires spreading quickly throughout the County.
II. Topographical conditions
A variety of regions exist within Riverside County including deserts, mountains, brush covered wild lands, the Salton Sea and agricultural lands. Additionally, elevations within Riverside County range from three hundred (300) feet below sea level to mountains over ten thousand (10,000) feet. This variety in regions contributes to an increased emergency response time, which necessitates cooperation between local agencies.
Riverside County contains a large number of sensitive habitats for various species and vegetation, consists of large open space areas between major urban centers and includes
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landscapes varying from mountains and hills to valleys and deserts. These conditions impact building and structure location, which impedes emergency access and response.
Riverside County extends from Orange County to the State of Arizona and is mixed with congested urban areas, rural lands and wild lands, which increase Riverside County Fire Department response times to emergencies.
The topography within Riverside County extends from flat to twenty-five (25) percent slope for habitable land, which causes buildings and structures to be located in unique areas that impact emergency response and access.
III.Geological Conditions
Two major earthquake faults, the San Andreas Fault and the San Jacinto Fault, bisect Riverside County and numerous minor faults exist throughout it. As a result, a substantial amount of property and persons located in Riverside County and the City of Coachella are likely to be impacted by earthquakes and will require emergency response and rescue.
In addition to earthquakes, a substantial amount of property and persons located in Riverside County and the City of Coachella are likely to be impacted by landslides, wind erosion, blown sand, flooding and wildfires because of the County’s unique climatic, geological and topographical conditions.
F. The additional requirements included herein are necessary to properly protect the health, safety and welfare of the residents and workers of Riverside County and the City of Coachella.
G. Revenue shortages make it difficult to locate additional fire stations and provide staffing sufficient to control fires in single and multi-story retail, commercial and industrial buildings, making enhanced built-in protection necessary.
H. The sections of the California Fire Code may be referred to by the same number used in said published compilation preceded by the words “the City of Coachella Fire Code Section” or “Fire Code Section.”
I. California Health and Safety Code Sections 17958.7 and 18941.5 require that the modification or change be expressly marked and identified as to which each finding refers. The following table sets forth the 2025 California Fire Code sections that have been modified, and the associated local climatic, geological, and/or topographical conditions described above supporting the modification.
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2025 BUILDING
CODE SECTION
TITLE/SUBJECT
FINDINGS/
JUSTIFICATIONS
105.1 Required Permits Administrative
105.2, Items 2,4,and 6 Work exempt from permits I,II&III 105.2 Work exempt from permits Administrative
110.3.8 Fire- and smoke-resistant penetrations Administrative 111.1 Change of occupancy Administrative
114.4 Violation penalties Administrative
114.4.1 Violation penalties Administrative
G101.6 Administration and Enforcement Administrative
Appendix J, Section
J101.3
Administration and Enforcement
Administrative
Appendix J, Section
J101.4.1
Using alkaline fill soil
I,II&III
2025 FIRE CODE
SECTION
TITLE/SUBJECT
FINDINGS/
JUSTIFICATIONS
102.5 Application of Residential Code I, II & III
104.7 & 104.7.1 Liability; Legal defense Administrative 104.1.1 Authority of the Fire Chief and Fire Department Administrative 104.13 Authority of the Fire Chief to Close Hazardous Fire Areas Administrative
107.2 Schedule of Permit Fees Administrative
107.7 Cost Recovery Administrative
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111.1 Board of Appeals Established Administrative
112.4 Violation and Penalties Administrative
308.1.6.3 Sky Lanterns or Similar Devices I, II, & III
503.2.1 Dimensions Administrative
503.2.2 Authority Administrative
503.6.1 Automatic Opener Administrative
503.7 Loading Areas and Passenger Drop-Off Areas Administrative 507.5.7 Fire Hydrant Size and Outlets I & II
507.5.8 Fire Hydrant Street Marker I, II, & III
508.1 General I, II, & III
508.1.1 Location and Access I, II, & III
508.1.3 Exception I, II, & III
509.2.1 Minimum Clearances I & II
608.11.1.2 Manual Operation II & III
903.2 Where Required I, II, & III
903.3.5.3 Hydraulically Calculated Systems I & II
3204.2.1 Minimum Requirements for Client Leased or
Occupant Owned Warehouses Administrative
4904.2.1 High Fire Hazard Severity Zone Maps Administrative App Ch B, Table
B105.2
Required Fire-Flow For Buildings Other Than OneAnd Two-Family Dwellings, Group R-3 And R-4 Buildings And Townhouses
I, II, & III
App Ch C, C103.1 Hydrant Spacing I, II, & III
5608.1 Fireworks Display—General [Replaced with PDMC
§ 9.53.015] Administrative
This remainder of the amendments not listed in this Section are necessary for administrative clarification, and do not modify a building standard pursuant to California Health & Safety Code Sections 17958, 17958.7 and/or 18941.5. They establish administrative standards for the effective enforcement of the building standards in the City of Coachella. 2025 CFC Local Amendment Justification/Statement of Reason Building Standards Law allows local amendments in accordance with the following:
For purposes of this subdivision, a city may make reasonably necessary modifications to the requirements, adopted pursuant to Health and Safety Code Section 17958, 17958.5, 17958.7, and 18941.5, contained in the provisions of the code and regulations on the basis of local conditions.
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CFC Chapter 1 – Scope and Administration:
Section 101.4: This section is carried over from the existing previous adoption. This section resolves any conflict with the fire code provisions. Coachella maintains its own severability clause and does not adopt the fire code text.
Section 102.5: This section is carried over from the existing previous adoption. The scope and application of the fire code needs to be expanded to apply to the fire sprinkler systems for accessory structures constructed under the 2025 California Residential Code (CRC) which are permitted to exceed 3,600 square feet in area. This existing modification maintains the applicability of the 2025 California Fire Code (CFC) Section 903.2 amendment to those accessory structures greater than or equal to 3,600 square feet in area. This has no change in intent for previous adoption and maintains the protection offered.
Section 102.13.1: New section added to Section 102.13 to clarify Where a conflict exists between the provisions of the Riverside County Fire Code and the California Wildland-Urban Interface Code, the provisions of the Fire Code shall apply.
Section 103.1: New amendment of the base code text for establishing the Coachella Office of the Fire Marshal (Riverside County Fire Department) and identifying the “fire code official” as the official in charge of implementing, administering and enforcing the provisions of this code.
Section 104.1.1: This section is carried over from the existing previous adoption. It is imperative that enforcement capability be disseminated to other law enforcement entities within the Coachella area because of its vast topography and diversity. This gives the Riverside County Fire Department greater enforcement capabilities due to the presence of these other agencies across the County of Riverside.
Section 104.2: New amendment to Section 104.2 to clarify that “Guidelines” may be created to render interpretations of the Fire Code and shall be enforceable as part of the code.
Section 104.8 and 104.8.1: This section is carried over from the existing previous adoption to resolve any conflict between state law and the fire code provisions.
Section 104.12: This section is carried over from the existing previous adoption and grants authority to the Fire Chief, in cooperation with the Board of Supervisors, to close hazardous fire areas.
Section 108.2: This section is carried over from the previous adoption and relocated to the fees section of the Fire Code Section 108.2. This amendment is necessary to identify that fees are in accordance with Coachella fee schedules.
Section 108.7: This section is carried over from the previous adoption and relocated to the fees section of the fire code. This section is maintained in accordance with Health and Safety Code 13009 and 13009.1, and Government Code 53150, et seq. for cost recovery.
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Section 112.1: This section is carried over from the existing previous adoption to identify the board of appeals and additional criteria for clarification and implementation. The existing modifications to this section are consistent with Health and Safety Code 17920.5 where no board of appeals exists. This section provides for the ability to create a Board of Appeals as needed.
Section 113.4: This section is carried over from the existing previous adoption section 112.4 and relocated to this section to resolve any conflict with the fire code provisions. previous adoption requires punishments and penalties for violations to be in accordance with Health and Safety Code Sections 17995 through 17995.5.
CFC Chapter 2 – Definitions:
Fire Chief: This definition is carried over from the previous adoption. This definition was added to designate that this term means the Fire Chief of Riverside County whenever the wording appears in the California Fire Code or this Ordinance. This is to distinguish obligatory authority to the Fire Chief or any of the designated representatives for fire prevention measures and declarations in enforcing this Ordinance.
CFC Chapter 3 - General Requirements
Section 308.1.7: This section is carried over from previous adoption. This section is amended to prohibit sky lanterns and similar devices. The California State Fire Marshal's office issued Information Bulletin 12-005 indicating that there is a serious fire and safety hazard associated with sky lanterns, which include the potential to start an unintended fire on or off the property from which they are released. They are known to travel significant distances from the point of release.
The National Association of State Fire Marshals Resolution 2013-3 recommends imposing State level bans on their sale and use. Multiple fires have been reported to be linked to the use of sky lanterns including, but not limited to, a recycling plant fire in Smethwick, England which caused approx. $9M in damage and a wildfire in Shell Beach on the mountain above Pirates Code in San Luis Obispo County, CA. This is similar to the existing amendment by Orange County Fire Authority.
CFC Chapter 5 – Fire Service Features
Section 503.1.2.1: This is a new section added to be consistent with the operational needs where two points of fire access are required as identified in the Riverside County Fire Department – Commercial Access Guidelines and is consistent with Appendix D of the International Fire Code.
Section 503.2.1: This section is carried over from the previous adoption. This correlation of the fire code is necessary for minimum fire apparatus access widths for firefighter operations and consistency throughout Coachella. This modification has no change in regulatory effect.
Section 503.2.2: This section is carried over from the previous adoption. This section is enhanced to specify who has authority to designate Fire Lanes/Fire Apparatus Access Roads and modify minimum widths.
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Section 503.6.1: This section is carried over from the previous adoption. This section provides fire department and other emergency responders more rapid access to facilities with motorized gates.
Underwriters Laboratory (UL) “determined that fires today are more dangerous and pose more risks than in the past. Fire propagation is faster, and time to flashover, escape times and collapse times are all shorter” (UL Fire Safety Journal Issue 1). Placing our first responders on scene sooner or without disruption will provide for greater occupant and firefighter safety, and assist in property protection and medical emergencies.
Section 503.7: This section is carried over from the previous adoption. This section provides additional width for apparatus access roads where utilized for loading/unloading or passenger drop off/pick up to prevent interference with operational access needs.
Section 507.5.7: This section is carried over from the previous adoption. This section provides for the size and quantities of outlets for residential standard, super hydrant standard, and super hydrant enhanced fire hydrants and that they shall be required as determined by the Fire Code Official.
Section 507.5.8: This section is carried over from the previous adoption. The section provides direct references to Riverside County Fire Department Guidelines for specific requirements for the installation of blue reflective markers for fire hydrants.
Sections 508.1, 508.1.1, and 508.1.3: These sections are carried over from the previous adoption.
These sections have been amended to require fire command centers for structures larger than 300,000 square feet in size. To put into context, the Fire Command Center would be triggered when the buildings are approximately 2.5 times the typical Costco Warehouse store and approximately two times the size of a typical Walmart Supercenter. Large structures of this size pose numerous challenges to emergency responders due to the large amounts of fuel loads from the storage, manufacturing and/or processing of flammable/combustible commodities and other processes within the building. Challenges include wide distribution of smoke throughout the structure, difficulty for firefighters to locate and reach the fire and difficulty in search and evacuation of the public, employees and firefighters. These structures typically require numerous fire protection, early suppression and detection systems that may include, but are not limited to, fire pumps, multiple fire sprinkler systems, advanced fire alarm systems, smoke control systems, and refrigeration gas detection system(s). During a fire, the incident commander must have the ability to readily identify the status of the various suppression and detection systems and have access to other building information details that may include, but are not limited to, building floor plans, high-pile/rack storage details, smoke control/ventilation systems, fire sprinkler zoning details, mechanical refrigeration equipment and piping details, and hazardous materials data sheets along with quantities and storage/use locations. A fire command center provides a centralized location for the incident commander to review details about the building and the incident and to effectively coordinate emergency responders and suppression activities with increased efficiency and speed. The Riverside County Fire Department has experienced several incidents in buildings with and without Fire Command Centers. Incident Commanders found that having detailed information on built in fire protection systems and controls, building schematics and hazardous materials storage plans were vital towards mitigating the event. When this information was not available, firefighting personnel were forced to operate upon assumptions and much less information. In addition, this increased efficiency and speed results in facilities returning to
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operation more expeditiously after incidents or false alarms thereby reducing loss of revenue for the business.
Section 509.2.1: This section is carried over from previous adoption. This section encompasses other exterior fire protection water supply appliances such as Fire Department connections, and other exterior fire protection system control valves, or any other exterior fire protection system component that may require immediate access.
CFC Chapter 6 – Building Services and Systems
Section 608.11.1.2: This section is carried over from the previous adoption. This section specifies the location of manual crossover valves when manual operation is required by the Fire Code Official. The amendment specifies that the manual valves shall be located in an approved location immediately outside of the machinery room, in a secure metal box or equivalent and marked as Emergency Controls. This is to ensure that the valves are in readily accessible location(s) for access during an emergency.
CFC Chapter 9 – Fire Protection and Life Safety Systems Section 903.2: This section is carried over from the previous adoption with modification.
Modifications have been made to provide certain exemptions including, but not limited to, fueling canopies and agricultural and greenhouse Group U structures constructed in accordance with the California Building Code and specific shade structures. An additional sprinkler requirement has been added to include changes in use to existing structures greater than 3,600 sq. ft., and additions to existing structures where the new square footage is greater than 3,600 sq. ft.
The existing amendment provides a base square footage requirement for all new commercial, industrial, and residential occupancies other than one- and two-family dwellings. Though the amendment includes a reference to the requirement for one- and two-family dwellings, the authority for residential fire sprinkler requirements for these occupancies resides in Title 24, Part
2.5 [2025 California Residential Code].
Automatic sprinkler systems have been successfully used to protect industrial and commercial buildings and their occupants for more than 100 years. Historically the place which has offered the least amount of fire protection to occupants was and still is their own home. This was brought to light in 1973 by the Report of the National Commission on Fire Prevention and Control, America Burning. At the time of the report approximately 8,000 people died in structure fires every year in the United States. Nine out of ten of those victims died in their home.
However, the U.S. Fire Administration report “Fire in the United States 2004–2013 17th edition” reflects that nonresidential fire losses are costly. “National estimates of nonresidential building fires and losses, from 2004 to 2013, annually accounted for only 7 percent of fires, 2 percent of deaths, and 8 percent of injuries. These properties, however, accounted for a disproportionately large annual dollar loss, 21 percent. Trends in nonresidential buildings showed a 14 percent decrease in fires, a 9 percent increase in deaths, a 7 percent increase in injuries, and a 10 percent decrease in dollar loss from 2004 to 2013.”
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The same report concluded “…that, overall, the fire problem in the U.S. continues to improve.
Ten-year fire loss rates are down. It is likely that several factors continue to contribute to these trends:…” which includes; "fire sprinklers, which quickly combat incipient fires, especially in nonresidential and multifamily buildings, and fire codes, which have been strengthened.” Furthermore, the report reflects that the nonresidential building category includes industrial and commercial properties, institutions (such as hospitals, nursing homes and prisons), educational establishments (from preschool through university), mobile properties, and storage properties. On average, about 89 percent of nonresidential structure fires, 88 percent of deaths, 91 percent of injuries, and 92 percent of dollar losses reported to National Fire Incident Reporting System from 2004 to 2013 occurred in nonresidential buildings.
Aside from firefighter and explosion fatalities, there has never been a multiple loss of life in a fully sprinklered building due to fire or smoke. All fire protection features have a reliability factor.
Walls and shafts can be breached by means of poke-throughs and building alterations. Exit doors can be blocked or locked.
The California Residential Code requires that all one and two family dwellings be protected by sprinklers. It is still imperative, based on the geographical, topographical, climatic diversity of Coachella, to continue to protect all structures greater than 3,000 sq. ft. by fire sprinklers, to ensure faster fire suppression/control to those occupancies that would not normally be required to be protected which would exhaust a number resources including water which climatically is so precious to our environment as a whole. It will provide for less run off into ground water due to suppression activities and less pollutants into the environment. It will reduce the risk of a structure fire extending outside of the structure and potentially igniting a wildland fire.
Mobile homes are a part of the American landscape. In 2007 alone, more than 95,000 manufactured homes were shipped nationwide. Manufactured housing also accounts for approximately 10 percent of the single-family structures in the United States. The National Fire Protection Association reports in 2007-2011, 11,400 structure fires per year were reported in manufactured homes, with associated losses of; 206 civilian deaths, 434 civilian injuries, and $179 million in direct damage per year nationally. Despite the fact that we drive by them, respond to medical calls in them, and sometimes live in them, we often overlook mobile homes when it comes to training and pre-fire planning. However, as the deaths of two firefighters in Craigsville, West Virginia, showed, mobile homes can pose significant, and sometimes deadly, challenges. The burning mobile home is a less-than-stable platform, making search and possible rescue of occupants even more dangerous. The exterior walls are not as structurally sound when compared with those of most site-built homes. The narrow halls complicate search. The roof burns through more quickly than a typical residential roof and is not safe for firefighters. Mobile home fires can quickly grow out of control, because there's not as much wallboard and drywall, and there are fewer walls to keep the fire from spreading. If the first-due engine pulls up and the mobile home is burning from end to end, the firefighting strategy has already been decided. The fire must be knocked down in order to move in. If the home is in a mobile home park, again, protecting exposures is vital. Radiant heat can ignite the homes nearby. Fire sprinklers can prevent the flashover from occurring and in many cases put the fire out and save valuable resources in the process, such as water, personnel, and environmental cleanup, limited displacement into City and
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County shelter(s), and less inconvenience to the family. The mobile home, because of its construction, requires fast water.
The record for automatic fire sprinklers is based on the simple fact that there has never been a multiple death of building occupants from a fire developing in a building protected by an automatic fire sprinkler system properly installed and maintained in accordance with nationally recognized standards (NFPA 13, 13D, 13R, and NFPA 25).
AWWA Research Foundation has published the following report: Impact of Fire Flow on Distribution System Water Quality, Design, and Operation. This report concludes the following:
“Water-efficient fire suppression technologies exist that use less water than conventional standards. In particular, the universal application of automatic sprinkler systems provides the most proven method for reducing loss of life and property due to fire, while at the same time providing faster response to the fire and requiring significantly less water than conventional fire-fighting techniques. It is recommended that the universal application of automatic fire sprinklers be adopted by local jurisdictions.”
Consider the benefits: a single firefighter using a normal 1-1/2” fire hose can be applying between 175-400 gallons of water per minute when attempting to extinguish a fire. On the other hand, a single fire sprinkler will be flowing only 18- to 40- gallons of water per minute. This means that over a 5-minute period, the following quantities of water are used:
Fire-fighter with 1-1/2” hose:
175 gpm x 5 minutes = 875 gallons of water
400 gpm x 5 minutes = 2,000 gallons of water
Fire sprinkler system:
18 gpm x 5 minutes = 90 gallons of water
40 gpm x 5 minutes = 200 gallons of water
Section 903.3.5.3.3: This section is carried over from the previous adoption. The section limits all hydraulically calculated fire sprinkler systems to not exceed 90% of the water supply capacity.
The 10% buffer in hydraulic calculation is a common engineering business practice that gives some flexibility to account for system water pressures that may decrease as additional demands are placed on the water system from additional construction or as the system ages.
Section 904.2.2.1: This is a new section added to the Fire Code to require that all new hood and duct commercial kitchen extinguishing systems are monitored by a central station or remote supervising station to ensure that the fire department is notified and able to respond to a fire.
CFC Chapter 32 – High-Piled Combustible Storage
Section 3206.4.2: This section is carried over from the previous adoption and relocated to the automatic sprinkler section within Chapter 32 of the Fire Code. By requiring client leased or occupant owned warehouses to have a technical report completed by a registered engineer, it will minimize problems concerning commodity and sprinkler protection. By having an engineer
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complete a technical report for the proposed or existing building it will provide greater certainty that adequate protection for the commodities that are proposed will be sufficient. By not having adequate sprinkler protection, it could be detrimental to the building and could also cause loss of life in the event of a fire. Geographically this can be a significant problem due to the seismic activity that Coachella experiences. The Engineer can assess the adequate protection for the correct commodity classifications, ensure the correct seismic provisions are in place for the type of system to be installed, and provide a professional assurance to a very volatile type of occupancy. It takes a vast number of resources to extinguish a fire of this type. By adding this requirement, it will ensure an added level of safety. Modifications have been made to provide clarification that certain reference documents are not required.
CFC Chapter 49 - Requirements for Wildland-Urban Interface Fire Areas Section 4904.2.1: This section has been deleted and is covered by the provisions of the California Wildland-Urban Interface Code as adopted and amended.
CFC Chapter 41 – Temporary Heating and Cooking Operations Section 4107: A new Section 4107, including Sections 4107.1 through 4107.2.3 is added to the Fire Code to provide the fire department with the authority to inspect Mobile Food Preparation Vehicles during special events. This section was removed from the CFC due to conflict in regulations, however HCD agrees that there would be an expectation for fire marshals to have jurisdiction over safety inspections (especially for fire protection equipment and systems’ inspections, testing and maintenance), for participating SPCM MFF during special events requiring CFC 105.6 operational permits (such as Carnivals and Fairs, Exhibits and Trade Shows, or local codified “Special Events” …). See BSC TP-106 (Rev. 10/20) Initial Statement of Reasons June 21, 2021 Rulemaking File SFM 06/21 – Part 9 – 2021 Triennial Code Cycle.
CFC Chapter 56 – Explosives and Fireworks
Section 5608.1: A new amendment to correctly update an existing amendment of this section from another Coachella municipal code. Amendment language has been cleaned up to avoid any confusion on what may or may not be permitted.
Section 5608.2: A new Section 5608.2 is added to the Fire Code to establish a minimum required radius of the fallout area for aerial shells to be 100 ft/in. (22 m/25 mm) of the internal mortar diameter of the largest aerial shell to be fired, unless otherwise approved. This is necessary due to the climatic wind conditions within Coachella.
CFC Appendix B – Fire-Flow Requirements for Buildings
Section B103.2.1: A new Section B103.2.1 is added to the Fire Code to establish the minimum fire flow for any new subdivision or tract constructed within a Wildland-Urban Interface Area to be 1,500 gallons per minute to ensure that adequate fire-flow is provided.
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Table B105.2 of Appendix B: This amendment is carried over from the previous adoption. This allows the fire department to still have adequate fire flow mitigation with sprinkler protection and not jeopardize main distribution systems by inadequately under sizing them and have costly upgrades for future projects. With the geographical diversity that Coachella has it is important that this requirement be added to ensure adequate water in the event of a fire.
CFC Appendix C – Fire Hydrant Locations and Distribution Section C103.1 of Appendix C: This provision is carried over from the previous adoption. This provision is to clarify the additional location of fire hydrants to be at intersections. This requirement has been standard policy within Coachella and Riverside County.
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2025 California Wildland-Urban Interface Code (CWUIC) Amendments California Health and Safety Code Sections 17958.7 and 18941.5 require that the modification or change be expressly marked and identified as to which each finding refers. Therefore, the City Council finds that the following table sets forth the 2025 California Wildland-Urban Interface Code sections that have been modified and the associated local climatic, geological and/or topographical conditions described above supporting the modification. 2025 CWUIC
CODE SECTION TITLE/SUBJECT FINDINGS I, II, III
102.4.1.1 Application of the California Wildland-Urban Interface Code Administrative
104.1.1 Authority of the Fire Chief and Fire Department Administrative 104.2 Determination of Compliance Administrative
104.8 and 104.8.1 Liability Administrative
105.2 Permits Required Administrative
108.2 Schedule of Permit fees Administrative
108.7 Cost Recovery Administrative
109.3.7 Violation and Penalties Administrative
202 Fire Chief Administrative
302.1.1 Designation of Fire Hazard Severity Zones. Administrative 501.1 Scope I, II, & III
602.1 General I, II, & III
602.3.2 Final Fire Protection Plan I, II, & III
603.1 General I, II, & III
603.3 Landscape and Fuel Modification plans I, II, & III 603.3.1 Contents I, II, & III
604.1 General I, II, & III
604.3 Requirements I, II, & III
604.3.1 Retroactivity I, II, & III
604.6 Clearance of brush, vegetative growth, and combustible material from improved parcels I, II, & III
604.7 Clearance of fuels or vegetative growth from structures I, II, & III 604.7.1 Structures I, II, & III
604.7.2 Timing for New Buildings and additions to Existing Buildings I, II, & III
604.7.3 Photovoltaic Systems I, II, & III
604.8 Defensible Space clearance zones and requirements I, II, & III 604.8.1 Requirements I, II, & III
604.8.2 Zone 0 purpose and location I, II, & III
604.8.2.1 Non-Combustible Zone 0 for New Buildings, additions to Existing Buildings, and new or replacement landscape I, II, & III 604.8.2.2 Additional requirements in Zone 0 I, II, & III 604.8.2.3 Zone 0 requirements for Existing Buildings I, II, & III 604.8.2.3.1 Zone 0 restrictions I, II, & III
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2025 CWUIC
CODE SECTION TITLE/SUBJECT FINDINGS I, II, III
604.8.3 Zone 1 purpose and location I, II, & III
604.8.3.1 Requirements and allowable items I, II, & III 604.8.4 Zone 2 purpose and location I, II, & III
604.8.4.1 Requirements and allowable items I, II, & III 604.8.4.2 Spacing I, II, & III
604.8.5 General requirements for Zone 0, 1, and 2 I, II, & III 604.8.5.1 Dead and dying vegetation I, II, & III
604.8.5.2 Mulch and wood chips within Zones 1 and 2 I, II, & III 604.8.5.3 Firewood I, II, & III
604.8.5.4 Clearance from chimney, stovepipe I, II, & III 604.8.5.5 Trees I, II, & III
604.8.5.5.1 Tree spacing I, II, & III
604.8.5.5.2 Ground clearance of trees I, II, & III
604.8.5.5.3 Ground cover under tree canopy I, II, & III 604.8.5.6 Continuous tree canopies I, II, & III
604.8.5.6.1 New Structures I, II, & III
604.8.5.6.2 Existing Structures I, II, & III
604.8.5.7 Grasses I, II, & III
604.9 Fire protection equipment and utilities I, II, & III 604.10 Planting vegetation under or adjacent to energized electrical lines I, II, & III
604.11 Fencing I, II, & III
604.11.1 Scope I, II, & III
604.11.2 New Fencing I, II, & III
604.11.3 Existing Fencing I, II, & III
607.1 General I, II, & III
607.1.1 Combustible Materials I, II, & III
607.2 Storage for off-site use I, II, & III
608.1.1 Restricted development setbacks I, II, & III
608.2 General I, II, & III
608.2.1 Setback reduction I, II, & III
609.2.7.1 Greenbelts I, II, & III
609.2.7.2 Access to Greenbelts I, II, & III
A102.1 General I, II, & III
A105.1 General I, II, & III
A105.4 Combustible Materials I, II, & III
2025 CWUIC Local Amendment Justification/Statement of Reason Building Standards Law allows local amendments in accordance with the following:
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For purposes of this subdivision, a city may make reasonably necessary modifications to the requirements, adopted pursuant to the Health and Safety Code Section 17958, 17958.5, 17958.7, and 18941.5, contained in the provisions of the code and regulations on the basis of local conditions.
CWUIC Chapter 1 – Administration:
Section 102.4.1.1: A new section added to the CWUIC to clarify that where a conflict exists between the provisions of the Riverside County Fire Code and the California Wildland-Urban Interface Code, the more restrictive provisions shall apply.
Section 104.1.1: Similar to the existing Ordinance 747 amendment to the Fire Code, this section ensures that enforcement capability be disseminated to other law enforcement entities within the Riverside County area because of its vast topography and diversity. This gives the Riverside County Fire Department greater enforcement capabilities due to the presence of these other agencies across the County of Riverside.
Section 104.2: New amendment to Section 104.2 to clarify that “Guidelines” may be created to render interpretations of the Wildland-Urban Interface Code and shall be enforceable as part of the code.
Section 104.8 and 104.8.1: This amended section is the same as in the Fire Code carried over from the existing previous adoption to resolve any conflict between state law and the fire code provisions.
Section 105.2: This new amendment to CWUIC Section 105.2 adds an additional permit item for “Landscape and Fuel Modification Zones.”
Section 108.2: This amended section is similar to the previous adoption for the Fire Code. This amendment is necessary to identify that fees are in accordance with Coachella fee schedule.
Section 108.7: This new section is similar to the previous adoption for the fire code. This section is maintained in accordance with the Health and Safety Code 13009 and 13009.1, and Government Code 53150, et seq. for cost recovery.
Section 109.3.7: This amended section is similar to the previous adoption for the fire code provisions. Previous adoption requires punishments and penalties for violations to be in accordance with Health and Safety Code Sections 17995 through 17995.5.
CWUIC Chapter 2 – Definitions:
Section 202: This new amendment is similar to the previous adoption for the Fire Code. This definition was added to designate that this term means the Fire Chief of Riverside County whenever the wording appears in the California Fire Code or this Ordinance. This is to distinguish
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obligatory authority to the Fire Chief or any of the designated representatives for fire prevention measures and declarations in enforcing this Ordinance.
CWUIC Chapter 3 – Wildland-Urban Interface Areas:
Section 302.1.1: New amendment designating the Fire Hazard Severity Zones. The Coachella City Council has adopted the recommendations of the State Fire Marshal made pursuant to Government Code section 51178 and designated those areas within Coachella as moderate, high, and very high fire hazard severity zones as shown on the Local Responsibility Area Fire Hazard Severity Zones Maps published by the Office of the State Fire Marshal. The Maps have been adopted by Coachella as required by statute.
CWUIC Chapter 5 – Special Building Construction Requirements:
Section 501.1: A new amendment clarifying that for the purpose of the special building construction requirements in Chapter 5, a wildland-urban interface area shall be defined as a geographical area identified by the state as a “Fire Hazard Severity Zone” in accordance with the Public Resources Code Sections 4201 through 4204 and Government Code Sections 51175 through 51189, and other areas designated by the enforcing agency to be at a significant risk from wildfires, and shall include those areas designated as moderate, high, and very high fire hazard severity zones based on recommendations from the State Fire Marshal pursuant to Government Code Section 51178. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
CWUIC Chapter 6 – Fire Protection Requirements:
Section 602.1: A new amendment to Section 602.1 to clarify when a Fire Protection Plan is required. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 602.3.2: A new amendment to Section 602.3.2 to clarify the items required in a Final Fire Protection Plan. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 603.1: A new amendment to Section 603.1 to include a reference to replacement landscaping. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 603.3: A new amendment to Section 603.1 to require Landscape and Fuel Modification Plans for any project in a Wildland-Urban Interface Area. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
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Section 603.3.1: A new amendment to Section 603.3.1 adding the requirement for the delineation of the 5-foot (1524 mm) (Zone 0), 30-foot (9144 mm) (Zone 1) and 100-foot (30 480 mm) (Zone 2) fuel management zones from all structures as part of the landscape plans. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.1: A new amendment to Section 604.1 to delete references to State Responsibility Areas (SRA) to include the defensible space requirements within the local responsibility area. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.3: A new amendment to Section 604.3 to include a reference to Appendix A of the CWUIC and Riverside County Fire Department Guidelines.
Section 604.3.1: A new Section 604.3.1 is added to the CWUIC to add a requirement that when required, by the Fire Code Official, or State Law, existing Defensible Space/Fuel Modification Zones (FMZ) shall require retrofitting, including thinning and/or removal of plants, trees, and vegetation, to meet this Code or State Law. Upon notification by the Fire Code Official, and when approved, work to bring an existing Defensible Space and FMZ into compliance with this Code, may be done over a two to four (2-4) year period as determined by the Fire Code Official. A compliance plan prepared by the property owner may be requested for review and approval by the Fire Code Official. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.6: A new Section 604.6 is added to the CWUIC requiring that all improved parcels declared a Public Nuisance shall be cleared entirely of combustible material. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.7: A new Section 604.7 is added to the CWUIC to require clearance of fuels or vegetative growth from structures. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.7.1: A new Section 604.7.1 is added to the CWUIC to specify the requirements for clearance of vegetation around structures located in a Fire Hazard Severity Zone. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.7.2: A new Section 604.7.2 is added to the CWUIC to provide a timeline for the clearance of fuels or vegetative growth from structures. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.7.3: A new Section 604.7.3 is added to the CWUIC to delineate the vegetation clearance requirements around freestanding photovoltaic systems in the wildland-urban interface area. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
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Section 604.8: A new Section 604.8 is added to the CWUIC to indicate the three defensible space zones. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.8.1: A new Section 604.8.1 is added to the CWUIC to indicate the code sections for the defensible space requirements. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.8.2: A new Section 604.8.2 is added to the CWUIC to clarify the purpose and location of Zone 0. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.8.2.1: A new Section 604.8.2.1 is added to the CWUIC to delineate the Zone 0 requirements for all new buildings, additions to existing buildings, installation of new landscape, and refurbishment of existing landscape areas. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.8.2.2: A new Section 604.8.2.2 is added to the CWUIC to clarify the vegetation and landscape requirements in Zone 0. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.8.2.3: A new section heading 604.8.2.3 is added to the CWUIC for the Zone 0 requirements for existing buildings. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.8.2.3.1: A new Section 604.8.2.3.1 is added to the CWUIC to clarify the Zone 0 requirements applicable to existing buildings with landscape installed prior to January 1, 2026.
This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.8.3: A new Section 604.8.3 is added to the CWUIC to indicate the purpose and location of Zone 1. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.8.3.1: A new Section 604.8.3.1 is added to the CWUIC to indicate the requirements and allowable vegetation in Zone 1. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.8.4: A new Section 604.8.4 is added to the CWUIC to indicate the purpose and location of Zone 2. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.8.4.1: A new Section 604.8.4.1 is added to the CWUIC to indicate the requirements and allowable vegetation in Zone 2. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
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Section 604.8.4.2: A new Section 604.8.4.2 is added to the CWUIC to indicate the spacing requirements for trees and vegetation in Zone 2. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.8.5: A new section heading 604.8.5 is added to the CWUIC for the general requirements for Zone 0, 1, and 2. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.8.5.1: A new Section 604.8.5.1 is added to the CWUIC requiring the removal of all dead or dying grass, plants, shrubs, trees, branches, leaves, weeds, and tree needles within Zone 0, 1, and 2. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.8.5.2: A new Section 604.8.5.2 is added to the CWUIC requiring the use of combustible mulch and wood chips shall be in accordance with the requirements of Riverside County Fire Department Guidelines within Zones 1 and 2. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.8.5.3: A new Section 604.8.5.3 is added to the CWUIC indicating the requirements for firewood within Zones 0, 1, and 2 are found in Section 607 of the code. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.8.5.4: A new Section 604.8.5.4 is added to the CWUIC requiring that any portion of a tree or shrub that extends within 10 feet horizontally or vertically of a chimney outlet or stovepipe outlet shall be removed within Zones 0, 1, and 2. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.8.5.5: A new Section 604.8.5.5 is added to the CWUIC requiring that new trees shall be planted and maintained so that the tree’s drip line at maturity is a minimum of 10 feet from any combustible structure within Zones 0, 1, and 2. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.8.5.5.1: A new Section 604.8.5.5.1 is added to the CWUIC requiring the horizontal distance between crowns of new trees and crowns of adjacent trees shall not be less than 20 feet in Zone 1 and not less than 10 feet in Zone 2 and separation distance may be increased for slopes exceeding 20 percent with the required spacing measured between trees at maturity. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.8.5.5.2: A new Section 604.8.5.5.2 is added to the CWUIC addressing the ground clearance requirements for trees within Zones 0, 1, and 2. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.8.5.5.3: A new Section 604.8.5.5.3 is added to the CWUIC addressing the ground cover under tree canopies within Zones 0, 1, and 2. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
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Section 604.8.5.6: A new section heading 604.8.5.6 is added to the CWUIC to address continuous tree canopies within Zone 0, 1, and 2. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.8.5.6.1: A new Section 604.8.5.6.1 is added to the CWUIC prohibiting continuous tree canopies adjacent to new structures within Zones 0, 1, and 2. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.8.5.6.2: A new Section 604.8.5.6.2 is added to the CWUIC to address the requirements for continuous tree canopies adjacent to existing structures within Zones 0, 1, and 2. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.8.5.7: A new Section 604.8.5.7 is added to the CWUIC requiring that natural or annual grasses shall be mowed to a maximum height of 4-inch stubble with clippings removed within Zones 0, 1, and 2. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.9: A new Section 604.9 is added to the CWUIC addressing defensible space requirements around communication site towers and their support buildings; required fire protection water supplies, including water tanks, water supply pumps, and pump houses; and any other utility structure as required by the Fire Code Official within a wildland-urban interface area.
This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.10: A new Section 604.10 is added to the CWUIC prohibiting vegetation planted under or adjacent to energized power lines that, at maturity, will grow within 10 feet of the energized conductors within a wildland-urban interface area. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.11: A new section heading 604.11 is added to the CWUIC to address fencing requirements within a wildland-urban interface area. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.11.1: A new Section 604.11.1 is added to the CWUIC to address fencing requirements within Zone 0 in a wildland-urban interface area. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.11.2: A new Section 604.11.2 is added to the CWUIC to require new fencing and gates to be constructed of a non-combustible material in a wildland-urban interface area. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 604.11.3: A new Section 604.11.3 is added to the CWUIC to allow fencing installed prior to January 1, 2026 in a wildland-urban interface area to remain, except the entire fencing not parallel and within 5 feet of the building, including gates within the fencing, shall be constructed of a non-combustible material when any portion of the existing fencing within 5 feet is replaced.
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This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 607.1: A new amendment to Section 607.1 of the CWUIC to prohibit the storage of firewood within Zone 0. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 607.1.1: A new Section 607.1.1 is added to the CWUIC requiring combustible materials, other than vegetation, stored within Zones 1 and 2 shall not be stored so as to pose a hazard to any building and that piles shall not exceed 100 square feet of area and a maximum height of 10 feet and shall be separated by a minimum of 20-foot clear area when located within a wildland-urban interface area. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 607.2: A new amendment to Section 607.2 of the CWUIC to prohibit the storage of firewood and combustible materials not for consumption on the premises within Zones 0, 1, and
2. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 608.1.1: A new Section 608.1.1 is added to the CWUIC with restricted development setbacks for new structures and additions to existing structures located less than 100 feet from any protected habitat within a wildland-urban interface area. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 608.2: A new amendment to Section 608.2 of the CWUIC expanding the applicability of the required 30-foot setback to new tract and parcel maps, new buildings, and additions to existing buildings within a wildland-urban interface area. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 608.2.1: A new amendment to Section 608.2.1 of the CWUIC deleting the exception of complying with the special building construction requirements as a setback reduction within a wildland-urban interface area, since the structures would already be subject to those requirements.
This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 609.2.7.1: A new amendment to Section 608.2.7.1 of the CWUIC addressing the approval of greenbelt locations within a wildland-urban interface area. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section 609.2.7.2: A new amendment to Section 608.2.7.2 of the CWUIC addressing the access points to proposed greenbelt locations for subdivisions and other developments within a wildlandurban interface area to allow for on-going maintenance and firefighter access. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
CWUIC Appendix A – General Requirements:
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Section A102.1: A new amendment to Section A102.1 of the CWUIC adding a reference for vegetation control to Chapter 6 of the Wildland-Urban Interface Code. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section A105.1: A new amendment to Section A105.1 of the CWUIC adding a reference for the storage and use of materials to Chapter 6 of the Wildland-Urban Interface Code. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella.
Section A105.4: A new amendment to Section A105.4 of the CWUIC adding a reference for the outside storage and use of combustible materials to the applicable fire code sections. This amendment is necessary due to climatic, topographical, and geological conditions in Coachella. 2025 EXISTING
BUILDING CODE
SECTION
TITLE/SUBJECT
FINDINGS/
JUSTIFICATIONS
105.1 Definition of Structural Damage Administrative
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City of Coachella 2025 California Building Code Adoption Amendment Findings Findings and determinations relative to the adoption of administrative amendments, and where appropriate, the adoption of more restrictive building standards code provisions amendments to the 2025 Edition of the California Building Code, Part 2, Title 24 of the California Code of Regulations.
Section 15.08.030- Amendment is necessary on the basis of a local climatic and geological conditions. The City of Coachella is located in an area with very high alkaline and sulfates in the soil that cause extreme deterioration to cementitious and metallic material. The proposed amendment to Chapter 1 of the California Building Code makes modifications to address this problem and protect the investment of building owners. Climatically annual rainfall has been increasing over the past few years from an average of 2 inches a year now up to an average of 6 inches a year. The increased rain combined with the high sulfates in the soils profligates the corrosion of metals and cementitious material.
15.08.030 (D) - Amendment is necessary as the city Building Inspectors have encountered multiple instances where fireproofing corrections have caused delays in project approvals and progress.
Since this requirement is not explicitly addressed in the current building code, we are proposing an amendment to provide clarification and ensure consistent compliance. This will facilitate smoother project execution while maintain safety standards.
15.08.030 (E) - Amendment is necessary as the California Building Code is silent on issuing permits for change of occupancy. The amendment is intended to provide the city with cost recovery, for processing the applications.
15.08.030 (G)- This amendment clarifies that the building department is authorized to charge penalty fees for building code violations, ensuring the amount and enforcement process are clear and consistent, thereby strengthening compliance and public safety.
15.08.030 (H,I)- Amendment is necessary to clarify that all grading activities shall be under the jurisdiction of the Engineering Department and shall be conducted under the authority of the Director of Public Works. This clarification ensures proper oversight and compliance with all applicable regulations governing grading operations.
Attachment 2
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15.08.030 (J)- This amendment is necessary to prevent the adverse effects of corrosive soils, safeguard structural integrity, and promote durability of construction material in areas with already high alkaline and sulfates soils conditions.
Attachment 2
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STAFF REPORT
12/10/2025
TO: Honorable Mayor and City Council Members
FROM: Lizzandro Diaz, Building Official
SUBJECT: Adopt Resolution No. 2025-59 Adopting the City of Coachella Americans with Disabilities Act (ADA) Self-Evaluation and Transition Plan (SETP).
STAFF RECOMMENDATION:
Staff recommends that the City Council adopt Resolution No. 2025-59 adopting the City of Coachella ADA SETP.
BACKGROUND:
The Americans with Disabilities Act (ADA) requires public agencies to evaluate their programs, services, and activities to ensure compliance with non-discrimination requirements and to develop a Transition Plan identifying and prioritizing the removal of physical barriers that limit accessibility.
On February 14, 2024, the City Council approved a Professional Service Agreement with MIG to develop the City’s ADA SETP. The ADA SETP initiated in 2024 to assess the accessibility of city-owned facilities, parks, and communication practices.
DISCUSSION/ANALYSIS:
The completed ADA Self-Evaluation and Transition Plan provides the City with a comprehensive roadmap for achieving full ADA compliance. Key components include:
1. Introduction
Title II of the ADA requires cities to maintain accessible programs and facilities and to develop an updated Transition Plan. Program accessibility may involve modifying facilities, providing auxiliary aids, redesigning equipment, or relocating programs to accessible locations. The City conducted a Self-Evaluation and public outreach process to identify barriers and develop strategies for compliance.
2. Public Outreach
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During the development of the ADA SETP, people with disabilities and disability stakeholders provided feedback in-person and online. Input was collected through two public meetings and an online comment period promoted through social media, in-person, and advertising on the local radio. Community members raised issues related to accessible routes, public facilities, transit access, and mobility.
3. Self-Evaluation: Policies and Procedures
A program accessibility questionnaire was distributed to City staff in all service areas to evaluate programs, activities, and services offered to the public. The goal of the questionnaire was to highlight areas where the City is effectively meeting the needs of people with disabilities while also identifying gaps in practices. A complementary evaluation of the City’s services, policies, and practices was done during the same period. A detailed summary of the findings can be found in Appendix A of the final City of Coachella ADA Self-Evaluation and Transition Plan, the ADA Self-Evaluation Report also included as Attachment #3.
4. Transition Plan: Parks and Facilities
Accessibility audits identified barriers across various categories including routes, restrooms, doors, parking, play areas, outdoor features, built-in elements, and other site-specific conditions.
Appendix C of the final City of Coachella ADA Self-Evaluation and Transition Plan, the ADA Barrier Summary Report (Attachment #4) provides more detailed information on the identified facility barriers.
Removal of barriers will be considered by the following criteria:
Level of Use: Facilities that have a high level of public use are a higher priority. Complaints or Requests: Facilities that have received access-related complaints or requests are prioritized over facilities that have not. Program Uniqueness: Facilities with unique features or program areas are prioritized over more general-use facilities.
Planned Projects: Include ADA upgrades in capital improvement projects that are already planned to avoid redundant efforts.
The Transition Plan proposes a 10-year implementation schedule beginning in 2025, with barrier removal projects grouped in two-year increments.
5. Plan Implementation
Implementation will rely on procedural updates and physical improvements. The City’s ADA Coordinator (or designee) will oversee policy updates, coordinate compliance efforts, and track progress.
6. Responsible Employees, Notice Policy, and Grievance Procedure
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Title II requires designation of an ADA Coordinator, public notices of ADA rights, and a formal grievance process. The Plan includes updated policies and procedures reflecting current best practices. The final draft ADA SETP, notices, and grievance procedure are posted on the City’s website.
Environmental Review:
The actions being considered do not constitute a “project” within the meaning of the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines section 15378(b)(5) in that it is a governmental organizational or administrative activity that will not result in direct or indirect changes in the environment. Projects to remove physical barriers that may occur as a result of the Plan are subject to future discretionary approvals and environmental review for such projects will be required in the future.
FISCAL IMPACT:
Adoption of the ADA SETP does not obligate the City to specific expenditures at this time. Barrierremoval costs will be incorporated into future annual budgets.
ALTERNATIVES:
1. Adopt Resolution No. 2025-59.
2. Take no action.
3. Continue this item and provide staff with direction.
RECOMMENDED ALTERNATIVE(S):
Staff recommends alternative #1.
Attachments:
1. Resolution No. 2025-59 Adopting the City of Coachella ADA SETP.
2. Final – Americans with Disabilities Act (ADA) Self-Evaluation and Transition Plan, September 2025
3. Appendix A – ADA Self-Evaluation Report
4. Appendix C – ADA Barrier Summary Report
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RESOLUTION NO. 2025-59
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
COACHELLA, CALIFORNIA ADOPTING A NEW SELF-EVALUATION
AND TRANSITION PLAN TO CREATE ACCESSIBLE POLICIES,
PROCEDURES, PROGRAMS, AND FACILITIES FOR RESIDENTS WITH DISABILITIES IN THE CITY OF COACHELLA.
WHEREAS; the City of Coachella, under Title II Subpart A of the Americans with Disabilities Act (ADA), must enact a Self-Evaluation and Transition Plan to remove barriers to residents with disabilities, both physical, policy, and programmatic; and, WHEREAS, the City of Coachella must evaluate services, policies, practices, and physical accessibility for people with disabilities; and,
WHEREAS; the City of Coachella must identify modifications needed to services, policies, practices, and facilities; and,
WHEREAS; the City of Coachella does not have comprehensive self-evaluation and transition plan addressing accessibility for people with disabilities; and, WHEREAS; Title 28 Chapter I Subpart A of the Code of Federal Regulations prohibits public entities from discrimination on the basis of disability; and, WHEREAS; the City of Coachella must comply with the requirements of the ADA; and, WHEREAS; the City of Coachella must make continuous improvements of City programs for people with disabilities; and,
WHEREAS; the City of Coachella must enable residents with disabilities to participate equally in the City’s programs, services, and activities; and, WHEREAS; accessibility applies to all aspects of programs or services provided by the City.
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Resolution No. 2025-59
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF COACHELLA DOES HEREBY RESOLVE AS FOLLOWS:
SECTION 1: Adoption of the Coachella Self-Evaluation and Transition Plan. The City Council hereby adopts the Plan to create accessible policies, programs, procedures, and facilities set forth in the document, called “City of Coachella ADA Self-Evaluation and Transition Plan”, attached hereto, to define appropriate implementation prioritization of accessible policies, procedures, programs, and facility renovations.
PASSED, APPROVED and ADOPTED this 10
th day of December 2025.
___________________________________
Steven A. Hernandez
Mayor
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Resolution No. 2025-59
ATTEST:
___________________________________
Angela M. Zepeda
City Clerk
APPROVED AS TO FORM:
BEST, BEST & KRIEGER
___________________________________
City Attorney
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Resolution No. 2025-59
STATE OF CALIFORNIA
COUNTY OF RIVERSIDE
CITY OF COACHELLA
)
) ss.
)
I HEREBY CERTIFY that the foregoing Resolution No. 2025-59 was duly adopted by the City Council of the City of Coachella at a regular meeting thereof, held on the 10th day of December 2025, by the following vote of Council:
AYES:
NOES:
ABSENT:
ABSTAIN:
___________________________________
Delia Granados
Deputy City Clerk
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City of Coachella ADA Self-Evaluation and Transition Plan Providing Accessible Programs and Facilities under Title II of the Americans with Disabilities Act September 2025
Attachment 2
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City of Coachella, CA i
ADA Self-Evaluation and Transition Plan for Public Parks and Facilities Acknowledgments
City Leadership
Steven Hernandez, Mayor
Denise Delgado, Mayor Pro Team
Stephanie Virgen, City Council Member
Dr. Frank Figueroa, City Council Member
Yadira Perez, City Council Member
City Staff
Lizzandro Diaz, CBO; Building Official
Anahi Fernandez, Management Analyst
Community Stakeholders
Many thanks to those who shared their feedback on this plan:
Sergio Aguayo
Robert Augustin
Araceli De Leon
Layza Taina Diaz Guerrero
Karina
Crisanta Lechugat
Bambee Rodriguez
Pilar Rodriguez
Agustin Torres
Matilde Valdez-Lechuga
Consultant
www.migcom.com
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City of Coachella, CA ii
Contents
1. Introduction................................................................................................................ 1
1.1 Legislative Mandate ...................................................................................................... 1
1.2 Discrimination and Accessibility.................................................................................... 3
1.3 ADA Self-Evaluation and Transition Plan Requirements and Process........................... 4
2. Public Outreach .......................................................................................................... 6
2.1 Community Stakeholder Meeting One Summary ......................................................... 6
2.2 Community Stakeholder Meeting Two Summary ......................................................... 7
3. Self-Evaluation: Policies and Procedures...................................................................... 8
3.1 Self-Evaluation Results Overview.................................................................................. 9
3.2 Next Steps................................................................................................................... 10
4. Transition Plan: Parks and Facilities.......................................................................... 11
4.1 Sites Evaluated ............................................................................................................ 11
4.2 Accessibility Standards.................................................................................................13
4.3 Prioritiesfor Barrier Removal...................................................................................... 13
4.4 Barrier Removal Schedule ........................................................................................... 14
5. Plan Implementation ................................................................................................ 17
5.1 Triggers for Barrier Removal ....................................................................................... 17
5.2 Exceptions to Barrier Removal.................................................................................... 20
6. Responsible Employee, Notice Policy, and Grievance Procedure................................. 23
6.1 Disability Access Coordinator Roles and Responsibilities............................................ 23
6.2 Notice Under the Americans with Disabilities Act....................................................... 23
6.3 ADA Complaint and Grievance Procedure .................................................................. 24
7. Definitions................................................................................................................ 26
8. Program Accessibility Guidelines, Standards, and Resources...................................... 32
8.1 Federal, State, and Local Laws, Standards, and Ordinances....................................... 32
8.2 Guidance Documents and Articles – Creating Accessible Documents........................ 34
8.3 Guidance Documents and Articles – Web Design....................................................... 35
8.4 Guidance Documents and Articles – Signage.............................................................. 35
8.5 Training Resources...................................................................................................... 36
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City of Coachella, CA iii
Appendices
A. City of Coachella ADA Self-Evaluation Report
B. Accessible Policies and Procedures Matrix
C. City of Coachella ADA Barrier Summary Report
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City of Coachella, CA Introduction 1
1. Introduction
This Title II ADA Self-Evaluation and Transition Plan (SETP or the Plan) for Public Parks and Facilities will support the City of Coachella to fulfill the requirements set forth in Title II of the Americans with Disabilities Act (ADA). The ADA states that a public entity must reasonably modify its policies, practices, or procedures to avoid discrimination against people with disabilities. This Plan will assist the City to remove policy and programmatic barriers to accessibility and will guide the City to develop physical barrier removal solutions.
The public engagement approach and feedback that was received is described in Section 2 — Public Outreach.
The evaluation of and recommendations for policies, programs, and services is summarized in Section 3 — Self-Evaluation: Policies and Procedures of this document. Section 3 details the review of City policies, services, programs, and activities and is based on responses to a program accessibility questionnaire, which was completed by City Staff.
A description of the evaluation of physical barriers in public parks and other public city facilities and the strategy for the removal of barriers is included in Section 4 — Transition Plan: Parks and Facilities.
An overview of the considerations that the City should evaluate and address when implementing barrier removal efforts is provided in Section 5 — Plan Implementation.
Section 6: Responsible Employee, Notice Policy, and Grievance Procedure identifies the City’s designated Disability Access Coordinator, provides formal notice of nondiscrimination under the ADA, and describes the City’s ADA grievance procedure.
Commonly used terms within this document and in the ADA are included in Section 7 — Definitions, and Section 8 — Program Accessibility Guidelines, Standards, and Resources lists guidelines and resources for addressing the recommendations included in this Plan.
1.1 Legislative Mandate
The ADA is a comprehensive civil rights law for people with disabilities in both employment and the provision of goods and services. The ADA states that its purpose is to provide a “clear and comprehensive national mandate for the elimination of discrimination against individuals with disabilities.” Congress passed the ADA on July 26, 1990, emphasizing that the intent of the ADA was to dispel stereotypes and assumptions about disabilities and to assure equality of opportunity, full participation, independent living, and economic self-sufficiency for people with disabilities. Title II of the ADA covers programs, activities, and services of public entities. Under the requirements of the ADA:
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City of Coachella, CA Introduction 2
No qualified individual with a disability shall, on the basis of disability, be excluded from participation in or be denied the benefits of the services, programs, or activities of a public entity, or be subjected to discrimination by any public entity .1 Furthermore, Title II of the ADA provides that public entities must identify and evaluate all programs, activities, and services and review all policies, practices, and procedures that govern administration of the entity’s programs, activities, and services.2 This Plan, and certain documents incorporated by reference establish the City of Coachella’s ADA Self-Evaluation and Transition Plan.
Application of Regulations
As a public entity, the City of Coachella is subject to the ADA’s Title II Requirements for State and Local Government Programs and Services and isresponsible for the provision of accessible programs and facilities that are available without discrimination toward people with disabilities. A fundamental tenet of Title II of the ADA is “the principle that individuals with disabilities must be provided an equally effective opportunity to participate in or benefit from a public entity’s aids, benefits, and services.”3 This principle is referred to as program accessibility.
A public entity may not deny the benefits of its programs, activities, and services to individuals with disabilities because its facilities are inaccessible. A public entity’s services, programs, or activities, when viewed in their entirety, must be readily accessible to and useable by individuals with disabilities. This standard, known as “program accessibility,” applies to all existing facilities of a public entity. Public entities, however, are not necessarily required to make each of their existing facilities accessible.4
As a public entity, the City is required to ensure program accessibility for the programs it provides to the public.
Maintaining Accessible Facilities
In addition to providing programmatic access, the City is obligated to maintain all accessible facilities in working order. Exceptions are provided for temporary disruptions. The ADA contains the following language regarding the maintenance of accessible features:
Maintenance of Accessible Features. Public entities must maintain in working order equipment and features of facilities that are required to provide ready access to individuals with disabilities. Isolated or temporary interruptions in access due to maintenance and repair of accessible features are not prohibited.
Where a public entity must provide an accessible route, the route must remain accessible and not blocked by obstacles such as furniture, filing cabinets, or potted plants. An isolated instance of placement of an object on an accessible route, 1 DOJ, Title II Regulations Subpart B § 35.130 General prohibitions against discrimination; and Subpart D, § 35.149 Discrimination prohibited.
2 DOJ, Title II Regulations Subpart A § 35.105 Self-evaluation. 3 DOJ, Title II Technical Assistance Manual II-3.3000 Equality in participation/benefits. 4 DOJ, Title II Technical Assistance Manual II-5.1000 General.
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City of Coachella, CA Introduction 3
however, would not be a violation if the object is promptly removed. Similarly, accessible doors must be unlocked when the public entity is open for business.
Mechanical failuresin equipmentsuch as elevators or automatic doors will occur from time to time. The obligation to ensure that facilities are readily accessible to and usable by individuals with disabilities would be violated, if repairs are not made promptly or if improper or inadequate maintenance causes repeated and persistent failures.5
The City of Coachella has designated a Disability Access Coordinator. The Disability Access Coordinator is responsible for tracking the efforts of the City to comply with Title II and for the coordination and investigation of accessibility-related complaints. The Disability Access Coordinator is also considered a resource for City Departments to achieve ADA compliance and assist with policy and program development to ensure program accessibility.6
1.2 Discrimination and Accessibility
This section provides an overview of physical and programmatic accessibility and the basic methods of providing access. Absence of discrimination requires that both types of accessibility be provided. • Physical accessibility requires that a facility be barrier-free. Barriers include any obstacles that prevent or restrict the entrance to or use of a facility. • Programs offered by the City to the public must be accessible. Program accessibility requires that individuals with disabilities are provided an equally effective opportunity to participate in or benefit from a public entity’s programs and services. Accessibility includes advertisement, orientation, eligibility, participation, testing or evaluation, physical access, provision of auxiliary aids and services, transportation, policies, and communication.
The City may achieve program accessibility by several methods:
• Structural methods such as altering an existing facility • Acquisition or redesign of equipment
• Assignment of aids; or
• Providing services at alternate accessible sites
When choosing a method of providing program access, the City is required to prioritize the method that results in the most integrated setting appropriate to encourage interaction among all users, including individuals with disabilities. In compliance with the requirements of the ADA, the City must provide equality of opportunity.
5 DOJ, Title II Requirements Subpart B § 36.211 Maintenance of accessible features. 6 DOJ, Title II Regulations Subpart B § 35.130 General prohibitions against discrimination, and Subpart D, § 35.149 Discrimination prohibited.
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City of Coachella, CA Introduction 4
1.3 ADA Self-Evaluation and Transition Plan Requirements and Process The ADA Self-Evaluation and Transition Plan is intended to provide a framework for the continuous improvement of City programs and facilities for people with disabilities. The Plan is intended to be a living document that is regularly updated as programs and services change, as barriers are removed. This document includes both the programs and activities provided by the City, as well as physical elements in the parks and recreation facilities, and other city-owned or leased facilities provided for use by the public. The public right-of-way is not included in this iteration of the Plan and is intended to be added at a later date.
Self-Evaluation
The ADA Self-Evaluation identifies and makes recommendations to correct policies and practices in programs and services provided by the City that are inconsistent with Title II regulations and result in limited access for people with disabilities. As part of the Self-Evaluation, the City:
• Evaluatesservices, policies, and practices
• Identifies modifications needed to services, policies, and practices and • Involves people with disabilities in the self-evaluation process7 Programs, activities, and services offered by the City to the public must be accessible for people with and without disabilities. Accessibility applies to all aspects of the programs or services provided by the City, including:
• Notice
• Responsible Employee and Grievance
Procedure
• Customer Service
• Staff Training
• Contracting, Licensing, or Other
Arrangements
• Public Meetings
• Program Participation
• Transportation Services
• Tours and Trips
• Accessible and Adaptive Equipment
• Printed and Online Materials
• Website
• Televised and Audiovisual Information
• Telecommunications
• Emergency Planning
• Facilities
• Accessibility Practicesin the Right-ofWay
The City of Coachella evaluated its internal practices and procedures to determine current levels of service and the extent to which its policies and programs created barriers to accessibility for people with disabilities. Recommended actionsfor removing barriersto City programs, activities, and services are incorporated as part of this Plan.
7 DOJ, Title II Regulations Subpart A § 35.105 Self-evaluation.
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City of Coachella, CA Introduction 5
Transition Plan
The Transition Plan outlines a strategy for the City’s physical facilities to progress toward compliance with the ADA. The Transition Plan identifies physical barriers for people with disabilities and a schedule to remove those barriers over time and must:
• List barriers
• Identify feasible solutions to each barrier
• Establish a timeline for removing barriers
• Identify the person responsible for Title II compliance; and • Involve people with disabilities in the preparation of the Plan8 The City of Coachella completed a physical audit of public parks and city facilities to identify potential facility barriers and identify recommendations and alterationsto meetstate and federal accessibility standards. The types of facilities evaluated include:
• Community and neighborhood parks
• Buildings where City programs, activities, and services are provided • Publicly accessible portions of service facilities such as the corporate yard and wastewater treatment center
• City-owned parking lots
At the time of the facility evaluations, the following resources were used to identify barriers in physical facilities:
• 2010 ADA Standards for Accessible Design
• 2022 California Building Code, Chapter 11B (CBC) with July 2024 Supplement • 2015 Architectural Barriers Act Accessibility Guidelines (ABA) Chapter 10 for Outdoor Developed Areas
Codes and standards are revised every few years. The barrier evaluations conducted provide an assessment of current conditions as viewed by current code and provide a baseline for future barrier removal.
8 DOJ, Title II Regulations Subpart D § 35.150 Existing facilities.
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City of Coachella, CA Public Outreach 6
2. Public Outreach
Public entities are required to accept comments from interested people, including individuals with disabilities or organizations representing individuals with disabilities, on their ADA SelfEvaluation and Transition Plan. During development of this Plan, people with disabilities, those that provide caretaking, support, or services to people with disabilities, and other interested Coachella residents participated in community stakeholder meetings to offer feedback on the self-evaluation and transition plan development. Feedback was collected during two meetings and one public comment period hosted online. To reach as many parties as possible, stakeholder meetings and public comment periods were advertised to the public through methods that included posting to social media platforms, visiting in-person to non-profits serving the community, and advertising on local radio shows. Each stakeholder feedback opportunity introduced the project and provided an open forum for residents of Coachella to ask questions, make comments, and give input on the prioritization of barriers and the draft plan. Participants shared their opinions and experiences related to City facilities, programs, and services as they relate to the ADA.
2.1 Community Stakeholder Meeting One Summary
On October 24, 2024, the City of Coachella held a hybrid community stakeholder meeting with some participants present at an in-person gathering at the Coachella Civic Center, and others participating virtually through an online meeting platform. The meeting was attended by City staff, consultants, and five Coachella residents representing a diverse array of disabilities and concerns.
Throughout the meeting, some common concerns expressed by the stakeholders included:
• Routes and public right-of-way – The need for improvements to pedestrian infrastructure and routes, such as repairing potholes, slippery surfaces on sidewalks, and unsafe curb ramps.
• More accessible options – A desire for access to more inclusive playgrounds and public facilities.
• Transit and mobility – A desire for expansion of accessibility projects beyond major thoroughfares and streets. For example, stakeholders requested a more extensive transit system, as well as improvements in the public right-of-way on tributary routes that are needed to access the busier main streets from residential areas.
When asked about barrier prioritization, participants preferred the following criteria:
• Level of use – more frequently-used facilities to be prioritized over less frequently-used facilities.
• Program uniqueness – facilities that host programs and services not available elsewhere to be prioritized over redundant facilities.
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City of Coachella, CA Public Outreach 7
• Complaints and requests – facilities that are the subject of user complaints and/or requests related to accessibility to be prioritized over facilities that have not received complaints.
• Access to sites and features – routes that provide access to the main entrances or features of a site deserve high priority.
Other feedback from the meeting participants included the following:
• Participants want the City to proactively work with K-12 schools and youths with disabilities, since they will become adult members of the community. • Participants appreciate the fully accessible bus line in the heart of the city. • Participants emphasize the importance of having other meetings that inform individuals with disabilities about what services and facilities will be accessible and available to them.
• Participants asked questions regarding accessible parking spots that are not located on the closest route to facility entrances.
This feedback has been considered by the City of Coachella and is incorporated into the prioritization framework of this Self-Evaluation and Transition Plan.
2.2 Community Stakeholder Meeting Two Summary
The City of Coachella held a hybrid community stakeholder meeting on April 19, 2025. The meeting was attended in-person by city staff and online by consultants, a Spanish language translator, and one member of the public. The consultants summarized the contents of the Plan, but no comments were received about the Plan or the priorities described.
2.2 Further Comments
The City of Coachella values your opinion regarding this Plan. To share feedback on this SelfEvaluation and Transition Plan, you can contact the City’s ADA Coordinator:
Lizzandro Diaz, Building Official and Disability Access Coordinator 442-400-5751, [email protected]
53990 Enterprise Way, Coachella, CA 92236
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City of Coachella, CA Self-Evaluation:
Policies and Procedures
8 3. Self-Evaluation: Policies and Procedures
Under Title II of the Americans with Disabilities Act (ADA), all programs, activities, and services offered to the public by the City of Coachella must be accessible for people with and without disabilities. Accessibility appliesto all aspects of a program or service. Public entities are required to evaluate their programs, activities, and services, make modifications to potentially discriminatory practices, and provide the opportunity for individuals with disabilities or organizations representing people with disabilities to participate in the process. When a public entity has 50 or more employees, it is required to maintain a record of the evaluation, describe the issues identified, describe the modifications made, and list the interested individuals consulted as part of the process.9
The self-evaluation process identifies policies and practicesthat result in limitations to access for people with disabilities and makes recommendations to correct policies and practices that are inconsistent with Title II regulations. As programs and facilities’ uses change, intermittent review of accessibility should be conducted. If a public entity is the recipient of Federal Department of Transportation funds, a system for tracking program and service deficiencies and periodically reviewing and updating the self-evaluation is required.10 The City of Coachella does not currently have written policies or procedures for review as part of the self-evaluation. An Accessible Policies and Procedures Matrix (Appendix B), with guidance for the implementation of new accessible policies, has been provided by MIG. Meanwhile, a staff questionnaire was issued to representatives from 10 City of Coachella departments:
• City Manager's Office
• City Clerk
• Code Enforcement
• Development Services
• Economic Development
• Engineering
• Finance
• Human Resources
• IT Division
• Public Works
The questionnaire asked staff to answer questions regarding current practices and de facto policies within their own department that could impact the accessibility of programs, services, and communications to people with disabilities. The resulting Self-Evaluation Report (Appendix A) provides a point in time assessment of the City’s efforts to make its programs, services, and activities accessible to the public, identifies areas for improvement, and makes specific recommendations to align the City’s practices with ADA Title II requirements.
A broad overview of the Self-Evaluation Results is provided in Section 3.1 below. 9 DOJ, Title II Regulations Subpart A § 35.105 Self-evaluation. 10 Department of Transportation Title 49, Subpart A § 27.11(c) Compliance Planning.
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City of Coachella, CA Self-Evaluation:
Policies and Procedures
9 3.1 Self-Evaluation Results Overview
The self-evaluation questionnaire was organized into the following topic areas based on the requirements of Title II of the ADA:
• Notice
• Responsible Employee and Grievance
Procedure
• Customer Service
• Staff Training
• Contracting, Licensing, or Other
Arrangements
• Public Meetings
• Program Participation
• Transportation Services
• Tours and Trips
• Accessible and Adaptive Equipment
• Printed and Online Materials
• Website
• Televised and Audiovisual Information
• Telecommunications
• Emergency Planning
• Facilities
Based on the results of the survey, each of these topic areas have been categorized based on the recommended method of improvement. Three primary methods of improvement and the associated topic areas are listed below.
A. Revise Current Policy
Topic areas in this category show signs that an erroneous or ineffective policy may be in place and needs to be revised. Policy revisions are recommended for:
• Customer Service
• Website
B. Create Policy Documentation
Topic areas in this category show signs that staff may not have clear policies in place to ensure accessible programs and services are provided. A lack of documented approaches and resources can result in inconsistent application of Title II provisions. New policies and/or documentation are recommended for:
• Notice
• Responsible Employee and Grievance Procedure
• Contracting, Licensing, or Other Arrangements
• Public Meetings
• Tours and Trips
• Telecommunications
• Emergency Planning
• Facilities
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Policies and Procedures
C. Provide Training
Topic areas in this category received responses that indicate that staff may not have a clear understanding of how Title II requirements impact their work, what procedures are in place, and what resources are available to them. Updated training isrecommended for:
• Notice
• Responsible Employee and Grievance Procedures
• Staff Training
• Public Meetings
• Printed and Online Materials
• Telecommunications
• Emergency Planning
The City’s approach to the remaining topic areas (program participation, transportation services, televised and audiovisual information, and accessibility practices in the public right-of-way) were determined to be in compliance with applicable ADA requirements to the extent that those services are provided by the City.
Many of the omissions in City policies discovered through the staff questionnaire can be resolved with improved communication. City staff need clear communication about accessibility requirements, processes, and resources available to them in order to effectively and consistently deliver accessible programs, activities, and services to the public. Publishing information in an easy-to-find location and providing recurring staff training is recommended to ensure that City staff remain up to date on accessibility policies and can reference written information or reach out for assistance when needed.
Likewise, residents of the City of Coachella need clear communication of the City’s intent to uphold Title II of the ADA, its plans to provide improvements where needed, as well as access to information about the policies, facilities, program modifications, adaptive equipment, communication methods, and individualized services available to them upon request. Publishing and updating this information in an easy-to-find location helps residents with disabilities plan their participation in City programs and services with confidence and conveys the City of Coachella’s bona-fide commitment to equitable and inclusive practices.
3.2 Next Steps
As the City grows, the need for formal documentation of policies will increase. The City will use the Accessible Policies and Procedures Matrix to guide the creation of new policies that comply with the requirements of the ADA.
The City’s ADA Coordinator or designee will follow up with City Department managers to review the Self-Evaluation Report information and Accessible Policies and Procedures Matrix policies relevant to their department and coordinate with the department head or program manager to address the removal of any barriers identified. The City intends to make any necessary changes to policies and procedures within 6 months of the completion of this Plan.
City of Coachella, CA Self-Evaluation: 10
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City of Coachella, CA Transition Plan: Parks and Facilities 11
4. Transition Plan: Parks and Facilities
The process of developing an ADA transition plan includes identifying access barriers within the built environment. This Plan is organized into two parts: Parks, and other City facilities.
Detailed evaluation of the City of Coachella’s pedestrian facilities in the public right-of-way (PROW) is not included in this iteration of the ADA Transition Plan. The City anticipates completing right-of-way evaluations within the next 3 years.
4.1 Sites Evaluated
The City of Coachella evaluated City-maintained parks and building facilities between April and May of 2024. The evaluation covered all portions of the exterior and interior features of the sites used by the public. The assessed facilities include public parks and other facilities such as community centers, civic buildings, and leased tenant spaces. Figure 1 on the following page illustrates the location of the parks and facilities listed below.
Parks
• Bagdouma Park
• Dateland Park
• De Oro Park
• Rancho Las Flores Park
• Tot Lot Park
• Veteran’s Memorial Park
• Shady Lane Park
• Sierra Vista Park
Facilities
• Bagdouma Park Community Center
• Bagdouma Park Swim Center
• Boys & Girls Club
• City Sanitation Department
• Coachella City Hall
• Coachella Civic Center
• Coachella Corporate Yard
• Coachella Library
• Coachella Valley Boxing Club
• Former Branch Library
1. Main Building
2. Annex I (Raices Cultura)
3. Annex II (Latino Commission)
• Former Chamber of Commerce
1. Area I (El Tranvia)
2. Area II (The Roaster)
• Former Water Billing/Fire Station
(Firehouse Bar & Grill)
• Senior Center
One additional facility, the Community Resiliency Center, was undergoing significant renovations as of the publication of this Plan; compliance with the applicable accessibility standards will be confirmed upon project completion.
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City of Coachella, CA Transition Plan: Parks and Facilities 12 FIGURE 1: PARKS AND CITY FACILITIES MAP
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City of Coachella, CA Transition Plan: Parks and Facilities 13 The site evaluations were accomplished using a consultant team equipped with measuring devices, City facility information, and evaluation checklists. Details of the assessment results are included in the ADA Facility Barrier Reports under separate cover. The comprehensive site evaluation ADA Facility Assessment Reports are a snapshot of the facility at the time of evaluation. The reports do not necessarily reflect actionsthat the City must undertake but rather constitute a list of elements that were not consistent with accessibility standards current at the time of the evaluation. The information contained in the ADA Facility Barrier Reports has been incorporated into an ADA Barrier Analysis Excel workbook with companion facility GIS data, which serves as the City's ongoing record of the occurrence and remediation of barriers, to be updated over time as the City removes barriers or finds programmatic solutions to barriers. The record is maintained by the City's ADA Coordinator or designee. In compliance with the requirements of the ADA, the City will maintain in working order features that are required to provide access to individuals with disabilities.
4.2 Accessibility Standards
The following standards were used to evaluate and identify barriers at the parks and citywide facilities:
• 2010 Americans with Disabilities Act (ADA) Standards
• 2022 California Building Code, Chapter 11B (CBC) with July 2024 Supplement • 2015 Architectural Barriers Act Accessibility Guidelines (ABA) Codes and standards are revised every few years; The barrier evaluations that are the basis of this Plan provide a baseline for future barrier removal. When construction activities are conducted for accessibility barrier removal, those changes must be designed to comply with the applicable standards at the time that the renovation is undertaken. See Section 4.4 Barrier Removal Schedule for details on the projected timeline.
4.3 Priorities for Barrier Removal
Prioritizing the removal of barriers at City of Coachella facilities is an important component of developing and implementing an ADA transition plan. The following criteria were considered in the schedule for removing barriers:
• Level of Use*: Facilities that have a high level of public use are a higher priority. • Complaints or Requests*: Facilities that have received access-related complaints or requests are prioritized over facilities that have not. • Program Uniqueness*: Facilities with unique features or program areas are prioritized over more general-use facilities.
• Planned Projects: Include ADA upgrades in capital improvement projects that are already planned to avoid redundant efforts.
Criteria marked with an asterisk were selected by the stakeholder feedback group.
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City of Coachella, CA Transition Plan: Parks and Facilities 14 The prioritization process applied was as follows:
• Level of Use: Park and facilities will be ranked in order of most highly used (1) to least used (8th place for parks, or 13th place for facilities).
• Complaints or Requests: Parks and facilities will be scored on a scale of 1-3:
1. Facility receives frequent complaints and requests related to accessibility.
2. Facility has been the subject of a few complaints and requests related to accessibility.
3. Facility has not been the subject of complaints and requests related to accessibility. • Program Uniqueness: Parks and facilities will be scored on a scale of 1-3:
1. Facility has a unique feature or program area that is not available at any other location.
2. Facility has an uncommon feature or program area with limited availability at other locations.
3. Facility has common features or program areas that are also available elsewhere. • Planned Projects: For facilities with planned projects, such as renovations or replacements, ADA-compliant accessibility improvements will be scheduled to be conducted as part of the planned project. An estimated completion year or time range for the planned project is indicated on Tables 1 and 2 in Section 4.4: Barrier Removal Schedule.
After the facilities had been ranked according to criteria above, the City adjusted the schedule to distribute the anticipated financial burden of improvements relatively evenly across plan years.
Access to funding, such as grant opportunities that become available for a specific facility in the future, may boost the facility up in the schedule. Additionally, the City may choose to leverage items that could be accomplished at all facilities regardless of rank. For example, if the City can contract parking lot striping for all facilities that need new striping, or if signage can be bulk ordered for all facilities, then the City may move to replace all instances of one element at one time.
4.4 Barrier Removal Schedule
This Transition Plan proposes a 10-year strategy for removing barriers that limit program accessibility at City facilities. The City will accomplish barrier removals in its facilities either through policy and procedure modifications to remove programmatic barriers, or maintenance and construction projects to remove physical barriers. Starting in 2025, the City will initiate maintenance and construction projects for barrier removal in two-year increments based on established priorities developed using the criteria and prioritization process described in Section
4.3. The barrier removalschedule for parks and other City facilities is summarized in Tables 1 and 2 on the following pages.
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City of Coachella, CA Transition Plan: Parks and Facilities 15 TABLE 1: PARK BARRIER REMOVAL SCHEDULE
Park Name
2025 -
2026
2027 -
2028
2029 -
2030
2031 -
2032
2033 -
2034 2035 +
Bagdouma Park X
Dateland Park X
De Oro Park X
Rancho Las Flores Park X*
Shady Lane Park X
Sierra Vista Park X *
Tot Park X
Veteran’s Memorial Park X
* Items marked with an asterisk are prioritized based on planned projects TABLE 2: FACILITY BARRIER REMOVAL SCHEDULE
Facility Name
2025 -
2026
2027 -
2028
2029 -
2030
2031 -
2032
2033 -
2034 2035 +
Bagdouma Park Community Center X*
Bagdouma Park Swim Center X
Boys & Girls Club X
City Sanitation Department X
Coachella City Hall X
Coachella Civic Center X
Coachella Corporate Yard X
Coachella Library X
Coachella Valley Boxing Club X
Former Branch Library
(Raices Cultura, Latino Commission) X*
Former Chamber of Commerce (El
Tranvia, The Roaster) X
Former Water Billing / Fire Station
(Firehouse Bar & Grill) X
Senior Center X
* Items marked with an asterisk are prioritized based on planned projects
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City of Coachella, CA Transition Plan: Parks and Facilities 16 The City reserves the right to modify barrier removal priorities to allow flexibility in accommodating community requests, petitions for reasonable modifications from people with disabilities, changes in City programs, and funding opportunities and constraints. The ADA Title II regulations state that if a transition plan takes more than one year to fully implement, it must contain interim steps to provide program accessibility. Because the City is working with a 10-year timeline, interim measures may be implemented to provide better access for the public pending the completion of major physical barrier removal projects. The City intends to pursue a variety of interim measures for providing interim access to programs, services and activities, including:
• Relocation of a program to an accessible facility
• Installation of directionalsigns
• Installation of a power door or lift
• Adjustments to operating mechanisms
• Temporary modificationsthat increase access
• Other actions that enable better access.
It is assumed that as facility barriers are evaluated in greater detail as part of future projects and complaints, some of the barriers may fall within the safe harbor provisions or other exceptions described in Section 5 — Plan Implementation.11 After programmatic modifications and maintenance issues are resolved, and barriers falling within safe harbor provisions are identified, the City will then update the inventory of barriers and, if applicable, revise the schedule for removal of the remaining barriers.
11 Facilities that are subject to safe harbor provisions under the ADA may remain in their current condition until the City plans to alter those facilities. Future accessibility improvements at these sites may be considered on a case-by-case basis. See Section 5.2 of this document for more discussion of safe harbor provisions.
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City of Coachella, CA Plan Implementation 17
5. Plan Implementation
Title II of the ADA requires a public entity to “operate each service, program or activity so that the service, program or activity, when viewed in its entirety, is readily accessible to and usable by individuals with disabilities.”12 This requirement does not:
• Necessarily require a public entity to make each of its existing facilities accessible to and usable by individuals with disabilities
• Require a public entity to take any action that would threaten or destroy the historic significance of an historic property; or
• Require a public entity to take any action that it can demonstrate would result in a fundamental alteration in the nature of a service, program, or activity or impose undue financial and administrative burdens.
The City will accomplish barrier removals with two strategies: policy and procedure modifications to remove programmatic barriers to be coordinated by the City’s Disability Access Coordinator, and maintenance and construction projects to remove structural barriers to be coordinated by the Department heads over the operating areas in which the structural barriers exist.
5.1 Triggers for Barrier Removal
The responsibility for ensuring barrier removal will reside with the Disability Access Coordinator, or designee. Two conditions determine when barriers must be removed: to provide access to programs, activities, and services, and when a facility is altered.
Program Accessibility
A public entity must ensure that individuals with disabilities are not excluded from services, programs, and activities because existing buildings are inaccessible. A state or local government's programs, when viewed in their entirety, must be readily accessible to and usable by individuals with disabilities. Public entities do not necessarily have to make each of their existing facilities accessible. They may provide program accessibility through several methods including alteration of existing facilities, acquisition or construction of additional facilities, relocation of a service or program to an accessible facility, or provision of services at alternate accessible sites.
Facility Alterations
The City is also required to remove physical barriers when it alters a facility. Alterations are defined in the ADA standards §106.5 as “a change in a building or facility that affects or could affect the usability of a building or facility or portion thereof.” Many types of projects are considered alterations, including remodeling, renovation, rehabilitation, reconstruction, restoration, resurfacing of circulation paths or vehicular ways, and changes or rearrangement of structural parts, elements, or walls. Normal maintenance, reroofing, painting or wallpapering, or changes to mechanical and electrical systems are not considered alterations unless they affect a 12 DOJ, Title II Regulations Subpart D § 35.150 Existing facilities.
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City of Coachella, CA Plan Implementation 18
facility’s usability. For example, a project limited to an HVAC system that includes the addition of thermostats would affect a facility’s usability because it involves elements (operable parts) covered by the standards.
The ADA specifiesthat additional path of travel improvements are not required where alterations are performed solely for the purpose of barrier removal when undertaken pursuant to the requirements of the ADA.13
The standards ensure that opportunities for accessibility presented by an alteration are taken.
How and to what extent the standards apply is determined by the scope of a project and the elements and spaces altered. Only those elements or spaces altered are required to comply, but alterations made to areas containing a primary function (a major activity for which a facility is intended) also require an accessible path of travel.
When altering a primary function area, the ADA requiresthat existing barriersin the path of travel to this area must be removed to the maximum extent that is technically feasible, as long as the costs are not disproportionate to the overall project cost. Path of travel elements include, but are not limited to restrooms, doors, telephones, drinking fountains, and the route itself. The expense for making these additional elements accessible is considered disproportionate if it exceeds 20 percent of construction costs; therefore, the additional amount an agency is required to spend on construction costs for path of travel improvements would be a maximum of 20 percent. In the event that a completely accessible path of travel cannot be provided within the 20% limit, the ADA provides a list describing the order in which elements should be prioritized:
1. An accessible entrance
2. An accessible route to the altered area
3. At least one accessible restroom for each gender or a single gender-neutral restroom
4. Accessible telephones
5. Accessible drinking fountains
6. When possible, additional accessible elements such as parking, storage, and alarms Note that in California, a similar provision requires improvements to the accessible path of travel to the altered area when conducting a renovation over a certain size, known as the valuation threshold. California’s valuation threshold is updated annually and can be found on the Division of the State Architect (DSA) website.14
13 See “State and Local Government Facilities: Guidance on the Revisions to 28 CFR 35.151” subsection in Guidance on the 2010 ADA Standards for Accessible Design https://www.ada.gov/regs2010
14 See DSA Procedure PR 15-01 for details on documentation required for path of travel upgrades
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Public Right-of-Way Alterations and New Construction
In an alteration or new construction project in the public right-of-way, the City must incorporate ADA accessibility standards to the maximum extent feasible.15 As part of the Plan’s implementation, the City’s Public Works Department should document all design exceptions.
The ADA Title II toolkit incorporates the following guidance about sidewalks and curb ramps:
• When pre-ADA streets or sidewalks are altered, space limitations may restrict the ability to install accessible curb ramps. In these cases, the installed curb ramps must comply with the ADA to the maximum extent feasible, but there are still requirements to meet. • In rare instances when it is technically infeasible to install a fully compliant curb ramp during alterations to pre-ADA roadways and walkways because of physical or site constraints, state and local governments must still provide accessibility to the maximum extent feasible. Before reaching a conclusion about technical infeasibility, public entities should consider the extent to which physical or site constraints can be addressed by alternative curb ramp designs. The burden of proving technical infeasibility lies with the state or local government that constructed it.
• When highways, streets, and roads are built or altered post-ADA, they must have curb ramps at certain locations: wherever there are curbs or other barriers to entry from a pedestrian walkway or sidewalk, wherever there are curbs or other barriers to entry at any designated pedestrian crosswalks that are located mid-block, wherever sidewalks or walkways intersect with highways, streets, or roads and pedestrians may legally cross the vehicular way, and at public transportation stops.
• For pre-ADA highways, streets, roads, and sidewalks that have not been altered, public entities may choose to construct curb ramps at every point where a pedestrian walkway intersects a curb, but they are not necessarily required to do so. Alternative routes to buildings may be acceptable where people with disabilities must travel only a marginally longer route than the general public.
Roadway Alterations and Maintenance
The DOJ, in coordination with the US Department of Transportation, specifies that public agencies are required to provide curb ramps or upgrade curb ramps whenever roadways are altered. An alteration is a change that affects or could affect the usability of all or part of a building or facility. Alterations of streets, roads, or highways include activities such as reconstruction, rehabilitation, resurfacing, widening, and projects of similar scale and effect per the 2010 ADA Standards, § 106.5). In July of 2013, the “Department of Justice/Department of Transportation Joint Technical Assistance on the Title II of the Americans with Disabilities Act Requirements to Provide Curb Ramps when Streets, Roads, or Highways are Altered through Resurfacing,” document further articulated maintenance activities on streets, roads, or 15 DOJ, Title II Regulations Subpart D § 35.151(b) Alterations.
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highways, such as filling potholes, are not alterations and do not trigger barrier removal. The list below distinguishes between roadway alterations versus maintenance activities:
Alteration
• Addition of new layer of asphalt
• Cape seals
• In-place asphalt recycling
• Microsurfacing and thin-lift overlay
• Mill and fill / mill and overlay
• New construction
• Open-graded surface course
• Rehabilitation and reconstruction
• Resurfacing of a crosswalk
Maintenance
• Chip seals
• Crack filling and sealing
• Diamond grinding
• Dowel bar retrofit
• Fog seals
• Joint crack seals
• Joint repairs
• Pavement patching
• Painting or striping
• Scrub sealing
• Slurry seals
• Spot high-friction treatments
• Surface sealing
5.2 Exceptions to Barrier Removal
The City is not required to remove barriers identified within a City-owned facility as part of the transition plan:
• Where programmatic modifications can be made to provide an equivalent experience • Where there are nearby and available equivalent accessible features • Where there are no public programs or activities provided at that portion of the site; or • When safe harbor conditions are met
The following sections describe some specific exceptions to barrier removal requirements in further detail.
Safe Harbor Provisions
The 2010 Standards introduced the concept of safe harbor, a new exception that allows facilities built prior to March 15, 2012, and that were in compliance with the 1991 ADA Standards to remain as-is until a public entity plans an alteration to the structural feature .16 This safe harbor is not a blanket exemption for facilities. If a public entity undertakes an alteration to a primary function area, only the required elements of a path of travel to that area that already comply with the 1991 Standards are subject to the safe harbor. If a public entity undertakes an alteration to a primary 16DOJ, Title II Regulations Subpart D § 35.150(b)(2)(i) Safe harbor.
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function area and the required elements of a path of travel to the altered area do not comply with the 1991 Standards, then the public entity must bring those elements into compliance with the 2010 Standards.17
This exception applies to elements that might otherwise have to be modified under:
• The program access requirement for public entities
• The readily achievable barrier removal requirements for places of public accommodation; or • The path of travel requirement for any alteration that affects the usability of a primary function area in any covered facility.
If a public entity constructed or altered required elements of a path of travel in accordance with the specifications in either the 1991 ADA Standards or the Uniform Federal Accessibility Standards before March 15, 2012, the public entity is not required to retrofit such elements to reflect incremental changes in the 2010 Standards solely because of an alteration to a primary function area served by that path of travel. The 2010 Standards also identity structural elements that do not fall under the safe harbor provision.18
Historic Buildings and Facilities
Alterationsto a qualified historic building or facility must comply with the 2010 ADA Standards.19 A qualified historic property is one that is listed in or eligible for listing in the National Register of Historic Places or is designated as historic under state or local law.
Barrier removals at City historic properties should be done in full compliance with the alteration standards for other types of buildings to the maximum extent feasible. However, if following the usual standards would threaten or destroy the historic significance of a building or site feature, as determined by the State Historic Preservation Office, exceptions can apply.20 Technical Infeasibility
It is also possible that an alteration is technically infeasible. Compliance for an alteration is not required where it is “technically infeasible.” The term is defined as “something that has little likelihood of being accomplished because existing structural conditions would require removing or altering a load-bearing member that is an essential part of the structural frame; or because other existing physical or site constraints prohibit modification or addition of elements, spaces, or features that are in full and strict compliance with the minimum requirements.”21 Where 17 DOJ, Title II Regulations Subpart D § 35.151(b)(4)(ii)(C) Safe harbor. 18 DOJ, Title II Regulations Subpart D § 35.150(b)(2)(ii) 19 DOJ, Title II Regulations Subpart D § 35.151(b) Alterations; see also ADAAG at 36 CFR part 1191; Section 4.1.7 Accessible Buildings: Historic Preservation. 20 DOJ, 2010 ADA Standards for Accessible Design: §206.2.1, Ex. 1, §206.2.3, Ex. 7, §206.4, Ex. 2, and §213.2, Ex. 2.
21 Access Board. “Guide to the ADA Standards – Chapter 2: Alterations and Additions” https://www.access-board.gov/guidelines-and-standards/buildings-and-sites/about-the-adastandards/guide-to-the-ada-standards/chapter-2-alterations-and-additions
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technical infeasibility is encountered, compliance is still required to the maximum extent technically feasible.22
Undue Burden
The City is not required to take any action that it can demonstrate would result in a fundamental alteration in the nature of its program or activity, would create a hazardous condition resulting in a direct threat to the participant or others, or would represent an undue financial and administrative burden.23
A determination of undue financial or administrative burden can only be made by the head of a department or his or her designee and must be accompanied by a written statement of the reasons for reaching that conclusion. The determination that undue burdens would result must be based on all resources available for use by the City. If an action would result in such an alteration or such burdens, the City must take any other action that would not result in such an alteration or such burdens but would nevertheless ensure that individuals with disabilities receive the benefits and services of the program or activity. 22 2010 Americans with Disabilities Act Standards § 202.3 Alterations. 23 DOJ, Title II Regulations Subpart D § 35.150 Existing facilities and Subpart E § 35.164 Duties.
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City of Coachella, CA Responsible Employee, Notice Policy, And Grievance Procedure
23 6. Responsible Employee, Notice Policy, and Grievance Procedure Title II of the ADA requires a state or local government agency that employs 50 or more people to designate at least one employee to coordinate the City’s efforts to implement the plan and provide the name, office address, and telephone number of the staff responsible. Additionally, the City must establish and publish a grievance procedure and provide notice to the public with information on the protections against discrimination under the ADA.24
6.1 Disability Access Coordinator Roles and Responsibilities The Disability Access Coordinator is responsible for organizing and communicating the City’s efforts to comply with and fulfill its responsibilities under Title II of the ADA, as well as all other applicable state and federal laws. The Disabilities Access Coordinator’s responsibilities include investigating complaints that the City has engaged in any action prohibited by Title II. The City has designated an employee to fulfill these responsibilities.
6.2 Notice Under the Americans with Disabilities Act
Title II regulations require the City to inform the public of the rights and protections provided by the ADA for access to public programs, services, and activities. It is the obligation of the head of the public entity to determine the most effective way of providing notice to the public about their rights and the public entity’s responsibilities under the ADA. Publishing and publicizing the ADA notice, such as the following, is not a one-time requirement. Public agencies should provide the information on an ongoing basis and update the information whenever necessary. The following is the City of Coachella’s current notice under the ADA.
Notice Under the Americans with Disabilities Act
In accordance with the requirements of Title II of the Americans with Disabilities Act of 1990 ("ADA"), the City of Coachella will not discriminate against qualified individuals with disabilities on the basis of disability in its services, programs, or activities.
Employment: The City does not discriminate on the basis of disability in its hiring or employment practices and complies with all regulations promulgated by the U.S. Equal Employment Opportunity Commission under Title I of the ADA.
Effective Communication: The City will generally, upon request with adequate notice, provide appropriate aids and services leading to effective communication for qualified persons with disabilitiesso they can participate equally in the City’s programs,services, and activities, including qualified sign language interpreters, documents in Braille, and other ways of making information and communications accessible to people who have speech, hearing, or vision disabilities.
Modifications to Policies and Procedures: The City will make all reasonable modifications to policies and programs to ensure that people with disabilities have an equal opportunity to enjoy 24 DOJ, Title II Regulations Subpart A § 35.107 Designation of responsible employee and adoption of grievance procedures.
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City of Coachella, CA Responsible Employee, Notice Policy, And Grievance Procedure
24 all of its programs, services, and activities. For example, individuals with service animals are welcomed in City offices, even where pets are generally prohibited.
Anyone who requires an auxiliary aid or service for effective communication, or a modification of policies or proceduresto participate in a program,service, or activity of the City should contact the office of the Disability Access Coordinator as soon as possible but no later than 48 hours before the scheduled event.
The ADA does not require the City to take any action that would fundamentally alter the nature of its programs or services or impose an undue financial or administrative burden.
Complaints that a program, service, or activity of the City is not accessible to persons with disabilities should be directed to:
Lizzandro Diaz, Building Official and Disability Access Coordinator 442-400-5751, [email protected]
53990 Enterprise Way, Coachella, CA 92236
The City will not place a surcharge on a particular individual with a disability or any group of individuals with disabilities to cover the cost of providing auxiliary aids/services or reasonable modifications of policy, such as retrieving items from locations that are open to the public but are not accessible to persons who use wheelchairs.
6.3 ADA Complaint and Grievance Procedure
This Grievance Procedure is established to meet the requirements of the Americans with Disabilities Act of 1990 ("ADA"). It may be used by anyone who wishes to file a complaint alleging discrimination on the basis of disability in the provision of non-employment- related services, activities, programs, or benefits by the City of Coachella (“City”). Employees and applicants for employment with the City should follow the City’s Personnel Policies and applicable Collective Bargaining Agreements to file employment-related complaints alleging disability discrimination.
ADA Complaints
Complaints that a program, service, or activity of the City of Coachella is not accessible to people with disabilities should be directed to
Lizzandro Diaz, Building Official and Disability Access Coordinator, 442-400-5751, [email protected]
53990 Enterprise Way, Coachella, CA 92236.
The complaintshould be in writing and contain information about the alleged discrimination such as name, address, phone number of complainant and location, date, and description of the problem. Alternative means of filing complaints, such as personal interviews or a tape recording of the complaint will be made available for people with disabilities upon request.
Grievance Procedure
Within 15 calendar days after receipt of the complaint, the Disability Access Coordinator or designee will meet with the complainant to discuss the complaint and the possible resolutions.
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City of Coachella, CA Responsible Employee, Notice Policy, And Grievance Procedure
25 Within 15 calendar days of the meeting, the Disability Access Coordinator or designee will respond in writing, and where appropriate, in a format accessible to the complainant, such as large print, Braille, or audio tape. The response will explain the position of the City and offer options for substantive resolution of the complaint.
If the response by the Disability Access Coordinator or designee does not satisfactorily resolve the issue, the complainant and/or his/her designee may appeal the decision within 15 calendar days after receipt of the response to the City Manager or designee.
Within 15 calendar days after receipt of the appeal, the City Manager or designee will meet with the complainant to discuss the complaint and possible resolutions. Within 15 calendar days after the meeting, the City Manager or designee will respond in writing, and, where appropriate, in a format accessible to the complainant, with a final resolution of the complaint.
Timelines for responding to a complaint may be extended at any step of the process when the Disability Access Coordinator or City Manager determines that such an extension is needed to effectively investigate orresolve the complaint. Complainants will be notified ofsuch extensions, All written complaints received by the Disability Access Coordinator or designee, appeals to the City Manager or designee, and responses from these two offices will be retained by the City for at least five years.
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City of Coachella, CA Definitions 26
7. Definitions
The following is a summary of many definitions found in this document and within the ADA.
Please refer to the Americans with Disabilities Act for the full text of definitions and explanations.25
Accessible. A site, building, facility, or portion thereof is deemed accessible when it is approachable and usable by persons with disabilities in compliance with technical standards adopted by the relevant Administrative Authority.
Administrative Authority. A governmental agency that adopts or enforces regulations and guidelines for the design, construction, or alteration of buildings and facilities.
Alteration in the Public Right-of-Way. A change to an existing facility that affects or could affect pedestrian access, circulation, or use. Alterations include, but are not limited to, resurfacing, rehabilitation, reconstruction, historic restoration, or changes or rearrangement of structural parts or elements of a facility.
Alternative Text. Refers to the text equivalent for an image appearing in an online document. It is read by screen readers in place of the image so that the content and function of the image is accessible to people with visual or certain cognitive disabilities.
Auxiliary Aids and Services. Refers to ways to communicate with people who have communication disabilities such as blindness, vision loss, deafness, hearing loss, a combination of vision and hearing loss orspeech or language disorders. The key to deciding what aid orservice is needed to communicate effectively with people with disabilities and their companions is to consider the nature, length, complexity, and context of the communication as well as the person’s normal method(s) of communication. Auxiliary aids and services include the use of interpreters, notetakers,readers, assistive listening systems, captioning and TTYs or the provision of alternate formats such as braille, ASCII text, large print, recorded audio and electronic formats like CDs and DVDs.
Blended Transition. A raised pedestrian street crossings, depressed corners, or similar connections between the pedestrian access route at the level of the sidewalk and the level of the pedestrian street crossing that have a grade of 5 percent or less.
Clear Ground Space. The minimum unobstructed ground space required to accommodate a single, stationary wheelchair and occupant. Clear ground space provides a location for a wheelchair user to approach and make use of an element.
Complaint. A complaint is a claimed violation of the ADA.
Cross Slope. The grade that is perpendicular to the direction of pedestrian travel. On a sidewalk, cross slope is measured perpendicular to the curb line or edge of the street or highway.
Curb Line. A line at the face of the curb that marksthe transition between the curb and the gutter, street, or highway.
25 DOJ, Title II Regulations Subpart A § 35.104 Definitions.
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Curb Ramp. A ramp that cuts through or is built up to the curb. Curb ramps can be perpendicular or parallel, or a combination of parallel and perpendicular ramps.
Disability. The term disability means, with respect to an individual:
• A physical or mental impairment that substantially limits one or more of the major life activities of such individual
• A record of such impairment; or
• Being regarded as having a disability or such impairment.
Disability Access Coordinator. The individual responsible for coordinating the efforts of the government entity to comply with Title II and investigating any complaints that the entity has violated Title II. Also known as Disability Access Manager, ADA Coordinator or Accessibility Manager.
Discrimination on the Basis of Disability. Discrimination on the basis of disability means to:
• Limit, segregate, or classify a citizen in a way that may adversely affect opportunities or status because of the person's disability
• Limit, segregate, or classify a participant in a program or activity offered to the public in a way that may adversely affect opportunities or status because of the participant's disability
• Participate in a contract that could subject a qualified citizen with a disability to discrimination
• Use any standards, criteria, or methods of administration that have the effect of discriminating on the basis of disability
• Deny equal benefits because of a disability
• Fail to make reasonable modifications to known physical or mental limitations of an otherwise qualified individual with a disability unless it can be shown that the modification would impose an undue burden on the City’s operations • Use selection criteria that exclude otherwise qualified people with disabilities from participating in the programs or activities offered to the public; and • Fail to use tests, including eligibility tests, in a manner that ensures that the test results accurately reflect the qualified applicant's skills or aptitude to participate in a program or activity.26
Effective Communication. Communication with people who have vision, hearing, and/or speech disabilities is equally effective as communication with people without disabilities.
Element. An architectural or mechanical component of a building, facility, space, site, or public right-of-way.
26 DOJ, Title II Regulations Subpart B § 35.130 General prohibitions against discrimination.
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Facility. All or any portion of buildings, structures, improvements, elements, and pedestrian or vehicular routes located in the public right-of-way.
Fundamental Alteration. A modification that is so significant that it alters the essential nature of the goods, services, facilities, privileges, advantages, or accommodations offered. If a public entity can demonstrate that the modification would fundamentally alter the nature of its service, program, or activity, it is not required to make the modification. If a public accommodation (private entity) can demonstrate that a modification would fundamentally alter the nature of the goods, services, facilities, privileges, advantages, or accommodations it provides, it is not required to make the modification.
Grade. The degree of inclination of a surface. Refer to Slope. In public right-of-way, grade is the slope parallel to the direction of pedestrian travel.
Grade Break. The line where two surface planes with different grades meet.
Having a Record of Impairment. An individual is disabled if he or she has a history of having an impairment that substantially limits the performance of a major life activity; or has been diagnosed, correctly or incorrectly, as having such impairment.
International Symbol of Accessibility (ISA). The ISA is recognized worldwide as a symbol identifying accessible elements and spaces. Standards issued under the ADA and ABA Standards reference and reproduce the ISA to ensure consistency in the designation of accessible elements and spaces. Uniform iconography promotes legibility, especially for people with low vision or cognitive disabilities. Guidance on use of the ISA under the ADA is available at https://www.access-board.gov/files/aba/guides/ISA-guidance.pdf Maintenance. Routine or periodic repair of all pedestrian facilities to restore them to the standards to which they were originally designed and built. Maintenance does not change the original purpose, intent, or design of public sidewalks, shared-use paths, curb ramps, crosswalks, pedestrian islands, or other public walkways.
Operable Part. A component of an element used to insert or withdraw objects, or to activate, deactivate, or adjust the element. The technical requirements for operable parts apply to operable parts on accessible pedestrian signals and pedestrian pushbuttons and parking meters and parking pay stations that serve accessible parking spaces.
Other Power-Driven Mobility Device (OPDMD). Any mobility device powered by batteries, fuel, or other enginesthat is used by individuals with mobility disabilitiesfor locomotion and designed to operate in areas without defined pedestrian routes.
Path of Travel. A path of travel is a continuous, unobstructed way of pedestrian passage by means of which a newly constructed or altered area may be approached, entered, and exited and which connects an area with an exterior approach (including sidewalks, streets, and parking areas), an entrance to the facility and other parts of a facility. An accessible path of travel may consist of walks and sidewalks, curb ramps and other interior or exterior pedestrian ramps; clear floor paths through lobbies, corridors, rooms, and other improved areas; parking access aisles; elevators and lifts; or a combination of these elements. Within the context of alterations, path of travel also includes restrooms, telephones and drinking fountains serving the altered area.
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Primary Function. A major activity for which a facility is intended. Areas that contain a primary function include, but are not limited to, the dining area of a cafeteria, the meeting rooms in a conference center, as well as offices and other work areas in which the activities of the public entity using a facility re carried out.
Program Accessibility. A public entity's services, programs, or activities, when viewed in their entirety, must be readily accessible to and useable by individuals with disabilities.
Public Entity. Any state or local government; any department, agency, special-purpose district, or other instrumentality of a state or local government.
Public Right-of-Way. Public land or property, usually in interconnected corridors, that is acquired for or dedicated to transportation purposes.
Qualified Historic Facility. A facility that is listed in or eligible for listing in the National Register of Historic Places or designated as historic under an appropriate state or local law.
Qualified Individual with a Disability. A qualified individual with a disability means an individual with a disability who, with or without reasonable modification to rules, policies, or practices; the removal of architectural, communication, or transportation barriers; or the provision of auxiliary aids and services, meets the essential eligibility requirements for the receipt of services or the participation in programs or activities provided by the City.
Reasonable Modification. A public entity must modify its policies, practices, or procedures to avoid discrimination unless the modification would fundamentally alter the nature of its service, program, or activity.27
Regarded as Having a Disability. An individual is disabled if she or he is treated or perceived as having an impairment that substantially limits major life activities, although no such impairment exists.
Running Slope. The grade that is parallel to the direction of pedestrian travel.
Scoping. Requirements that specify what features are required to be accessible and, where multiple features of the same type are provided, how many of the features are required to be accessible.
Service Animal. Service animals are dogs (and in certain circumstances, miniature horses) that are individually trained to perform tasks for people with disabilities. Examples of such work or tasks include guiding people who are blind, alerting people who are deaf, pulling a wheelchair, alerting, and protecting a person who is having a seizure, reminding a person with mental illness to take prescribed medications, calming a person with Post-Traumatic Stress Disorder (PTSD) during an anxiety attack, or performing other duties. Service animals are working animals, not pets. The work or task a dog has been trained to provide must be directly related to the person’s disability. Dogs whose sole function is to provide comfort or emotional support do not qualify as service animals under the ADA.
27 DOJ, Title II Regulations Subpart B § 35.130 General prohibitions against discrimination.
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Title II regulations now include assessment factors to assist public entities in determining whether miniature horses can be accommodated as service animals in their facilities:
• Whether the miniature horse is housebroken
• Whether the miniature horse is under the owner’s control • Whether the facility can accommodate the miniature horse’s type, size, and weight; and • Whetherthe miniature horse’s presence will compromise legitimate safety requirements necessary for safe operation of the facility.
Slope. Ground surface that forms a natural or artificial incline. Slope is typically conveyed as either a percentage or a ratio that represents the change in elevation between two points of an incline divided by the horizontal distance between the two points. • Cross Slope: The slope that is perpendicular to the direction of travel. • Running Slope: The slope that is parallel to the direction of travel.
Substantial Limitations of Major Life Activities. An individual is disabled if she or he has a physical or mental impairment that (a) renders her or him unable to perform a major life activity, or (b) substantially limits the condition, manner, or duration under which she or he can perform a particular major life activity in comparison to other people.
Major life activities are functions such as caring for oneself, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, and working.
In determining whether physical or mental impairment substantially limits the condition, manner, or duration under which an individual can perform a particular major life activity in comparison to other people, the following factors shall be considered:
• The nature and severity of the impairment
• The duration or expected duration of the impairment; and • The permanent or long-term impact (or expected impact) of or resulting from the impairment.
Technical Standards. Specify the design criteria for accessible features, including the specific numbers, conditions, and measurements that are required.
Technically Infeasible. With respect to an alteration of a building or a facility, something that has little likelihood of being accomplished because existing structural conditions would require removing or altering a load-bearing member that is an essential part of the structural frame; or because other existing physical or site constraints prohibit modification or addition of elements, spaces or features that are in full and strict compliance with the minimum requirements.
Telecommunications Display Device (TDD). A telecommunications display device for the deaf (TDD) is an electronic device for text communication via a telephone line, used when one or more of the parties has hearing or speech difficulties. Other names for TDD include TTY.
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City of Coachella, CA Definitions 31
Telecommunications Relay Service (TRS) or 711. The free, nationwide telecommunicationsrelay service, reached by calling 711, uses communications assistants who serve as intermediaries between people who have hearing or speech disabilities who use a text telephone (TTY) or text messaging and people who use standard voice telephones. The communications assistant tells the telephone user what the other party is typing and types to tell the other party what the telephone user is saying. TRS also provides speech-to-speech transliteration for callers who have speech disabilities.
Text Telephone (TTY). Teletypewriters or text telephones have a keyboard and a visual display for exchanging written messages over the telephone. The ADA established a free, nationwide relay network to handle voice-to-TTY and TTY-to-voice calls, which is reached by calling 711. TTY is a more general term for teletypes but is often referred to as TDD.
Vertical Surface Discontinuities. Vertical differences in level between two adjacent surfaces.
Video Relay Service (VRS). Video relay service (VRS) is a free,subscriber-based service for people who use sign language and have videophones, smart phones, or computers with video communication capabilities. For outgoing calls, the subscriber contacts the VRS interpreter, who places the call and serves as an intermediary between the subscriber and a person who uses a standard voice telephone. The interpreter tells the telephone user what the subscriber is signing and signs to the subscriber what the telephone user is saying.
Wheeled Mobility Device. A manually operated or power-driven device designed primarily for use by an individual with a mobility disability for the main purpose of indoor or of both indoor and outdoor locomotion. Also referred to as a manual wheelchair, a power wheelchair, or an electric scooter.
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City of Coachella, CA Program Accessibility Guidelines, Standards, and Resources
32 8. Program Accessibility Guidelines, Standards, and Resources
8.1 Federal, State, and Local Laws, Standards, and Ordinances Americans with Disabilities Act (ADA) Title II Regulations Nondiscrimination on the Basis of Disability in State and Local Government Services. https://www.ecfr.gov/current/title-28/chapter-I/part-35 U.S. Department of Justice Civil Rights Division, Disability Rights Section U.S. Department of Justice Civil Rights Division, Disability Rights Section provides many free ADA materials including the Americans with Disability Act (ADA) text. Printed materials may be ordered by calling the ADA Information Line [800-514-0301 (Voice) or 800-514-0383 (TTY)].
Publications are available in standard print as well aslarge print, audiotape, braille, and computer disk for people with disabilities. Documents, including the following publications, can also be downloaded from the Department of Justice website. http://www.ada.gov/ • Title II Technical Assistance Manual (1993) and Yearly Supplements. http://www.ada.gov/taman2.html
• Accessibility of State and Local Government Websites to People with Disabilities. 2003. https://www.ada.gov/websites2.htm
• ADA Best Practices Tool Kit for State and Local Governments. 2008. https://www.ada.gov/pcatoolkit/abouttoolkit.htm
• ADA Guide for Small Towns. 2000. http://www.ada.gov/smtown.htm • The ADA and City Governments: Common Problems. 2000.
http://www.ada.gov/comprob.htm
• ADA Requirements: Effective Communication. 2014. https://www.ada.gov/effectivecomm.htm • ADA Requirements: Service Animals. 2010.
https://www.ada.gov/service_animals_2010.htm
• ADA Information for Law Enforcement. 2008. http://www.ada.gov/policeinfo.htm • Commonly Asked Questions About the ADA and Law Enforcement. 2006. http://www.ada.gov/q&a_law.htm
• Communicating with People Who are Deaf or Hard of Hearing: ADA Guide for Law Enforcement Officers. 2006. http://www.ada.gov/lawenfcomm.htm • Model Policy for Law Enforcement on Communicating with People Who are Deaf or Hard of Hearing. 2006. http://www.ada.gov/lawenfmodpolicy.htm
• Questions and Answers: The ADA and Hiring Police Officers. 1997. http://www.ada.gov/copsq7a.htm
• ADA Requirements: Wheelchairs, Mobility Aids and Other Power-Driven Mobility Devices. 2014. https://www.ada.gov/opdmd.htm
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City of Coachella, CA Program Accessibility Guidelines, Standards, and Resources
33 • An ADA Guide for Local Governments: Making Community Emergency Preparedness and Response Programs Accessible to People with Disabilities. 2008. https://www.ada.gov/emergencyprepguide.htm
• Access for 9-1-1 and Telephone Emergency Services. 1998. http://www.ada.gov/911ta.htm
• The Americans with Disabilities Act and Other Federal Laws Protecting the Rights of Voters with Disabilities. 2014.
https://www.ada.gov/ada_voting/ada_voting_ta.htm
• ADA Checklist for Polling Places. 2016.
https://www.ada.gov/votingchecklist.htm#toc1
U.S. Access Board
The Access Board is an independent federal agency that promotes equality for people with disabilities through leadership in accessible design and the development of accessibility guidelines and standards. Created in 1973 to ensure access to federally funded facilities, the Board is now a leading source of information on accessible design. The Board develops and maintains design criteria for the built environment, transit vehicles, information and communication technology, and medical diagnostic equipment under the Americans with Disabilities Act of 1990 (ADA) and other laws. It also provides technical assistance and training on these requirements and on accessible design and continues to enforce accessibility standards that apply to federally funded facilities under the Architectural Barriers Act of 1968 (ABA). https://www.access-board.gov/
State of California
The State of California Department of Consumer and Business Services, Building Codes Division establishes the standards for construction through the California Structural Specialty Code adopted pursuant to OAR chapter 918, division 8. As of the writing of this document, California’s provisions for accessibility standards for new construction are the 2022 California Specialty Structural Code, Chapter 11, the ICC/ANSI A117.1-2017 Accessible and Usable Buildings and Facilities incorporated by reference, and the California Transportation Commission Standards for Accessible Parking Places dated August 2018. Existing buildings fall under the 2021 California Existing Building Code (OEBC) and California Revised Statute (ORS) 447.241: “Standards for renovating, altering or modifying certain buildings.” Because building codes are updated every few years, the City should regularly review changes and update policies and procedures related to accessibility to ensure compliance with current code. https://www.California.gov/bcd/codesstand/pages/index.aspx
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34 8.2 Guidance Documents and Articles – Creating Accessible Documents Adobe Software
• Creating Accessible Adobe PDF Files. https://helpx.adobe.com/acrobat/using/creatingaccessible-pdfs.html • Create and verify PDF accessibility (Acrobat Pro).
https://helpx.adobe.com/acrobat/using/create-verify-pdf-accessibility.html • Other Acrobat training. https://experienceleague.adobe.com/en/docs/document-cloudlearn/acrobat-learning/advanced-tasks/accessibility-series/accessibility-series American Council of the Blind (ACB)
Best Practices and Guidelines for Large Print Documents used by the Low Vision Community. 2011. http://acb.org/large-print-guidelines
Braille Authority of North America and the Canadian Braille Authority Guidelines and Standards for Tactile Graphics (Web Version). 2012. http://www.brailleauthority.org/tg/web-manual/tgmanual.html GSA Government-wide Section 508 Accessibility Program
Create Accessible Electronic Documents (a compilation of federal guidance, checklists, and testing information for creating and maintaining accessible documents in various popular electronic formats, including Word, PDF, Excel, and PowerPoint). https://www.section508.gov/create/
Social Security Administration, Accessibility Support
Accessibility Resources for Document Authors. 2025.
https://www.ssa.gov/accessibility/document_resources.html University of Washington
Creating Accessible Documents. https://www.washington.edu/accessibility/documents/
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35 8.3 Guidance Documents and Articles – Web Design
National Center for Accessible Media (NCAM)
NCAM is a research and development facility dedicated to addressing barriers to media and emerging technologies for people with disabilities in their homes, schools, workplaces, and communities. NCAM is part of the Media Access Group at Boston public broadcaster WGBH, which includes two production units, The Caption Center and Descriptive Video Service (DVS).
Tools and guidelines for creating accessible digital media can be found on the NCAM website. https://www.wgbh.org/foundation/ncam/guidelines/accessible-digital-media-guidelines Utah State University, Center for Persons with Disabilities, WebAIM WebAIM (Web Accessibility in Mind) is a non-profit organization based at the Center for Persons with Disabilities at Utah State University that has provided comprehensive web accessibility solutions since 1999. Documents and training materials, including the following publications, can be downloaded from the WebAIM website. http://www.webaim.org/ Web Accessibility Initiative (WAI)
WAI develops guidelines widely regarded as the international standard for Web accessibility, support materials to help understand and implement Web accessibility, and resources, through international collaboration. The Web Content Accessibility Guidelines (WCAG) was developed with a goal of providing a single shared standard for web content accessibility that meets the needs of individuals, organizations, and governments internationally. Documents and training materials, including the following publications, can be downloaded from the WAI website. https://www.w3.org/WAI/
8.4 Guidance Documents and Articles – Signage
APH Tactile Graphic Image Library
American Printing House for the Blind, Inc. (APH). The website requires registration for access, and it is free. http://www.aph.org/tgil/
Designing for People with Partial Sight and Color Deficiencies Arditi, Aries. Effective Color Contrast: 2005.
https://pages.mtu.edu/~nilufer/classes/cs3611/interesting-stuff/designing-with-colors1/color_contrast.htm Signage and the 2010 ADA Standards
Luminant Design LLC. v2.1. 2011. http://www.luminantdesign.com/ada.html Signage Requirementsin the 2010 Standardsfor Accessible Design Society for Experiential Graphic Design (SEGD). 2024.
https://segd.org/resources/segd-2012-ada-white-paper-update/
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36 U.S. Department of the Interior, National Park Service – Harpers Ferry Center Accessibility Committee
Harpers Ferry Center (HFC)serves asthe Interpretive Design Center for the National Park Service.
HFC works to ensure that the highest level of accessibility that is reasonable is incorporated into all aspects of interpretive media, planning, design, and construction. This includes ensuring that all new interpretive media are provided in such a way as to be accessible to and usable by all people with a disability. It also means all existing practices and procedures are evaluated to determine the degree to which they are currently accessible to all visitors, and modifications are made to assure conformance with applicable laws and regulations. The HFC website includes accessibility resources, guidelines and updates, Department of the Interior Section 504, photographs of best practices, and more. http://www.nps.gov/hfc/accessibility/
8.5 Training Resources
ADA National Network
2020. https://adata.org/ada-training
Great Lakes ADA Center
2020. http://www.adagreatlakes.org/ProgramsAndServices/Trainings/ Northwest ADA Center
2020. http://nwadacenter.org/training
United States Access Board
2020. https://www.access-board.gov/training
Southeast ADA Center
2025. https://adasoutheast.org/training/
ADA Coordinator Training Certificate Program
2025. https://www.adacoordinator.org/
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Americans with Disabilities Act (ADA) Self-Evaluation Report City of Coachella, CA
December 2024
Attachment 3
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Contents
1 Introduction.................................................................................................................................................. 3 2 Questionnaire Results and Recommendations.............................................................................................. 4
2.1 Notice..........................................................................................................................................................4
2.2 Responsible Employee and Grievance Procedure........................................................................................5
2.3 Customer Service.........................................................................................................................................7
2.4 Staff Training...............................................................................................................................................8
2.5 Contracting, Licensing, or Other Arrangements..........................................................................................9
2.6 Public Meetings.........................................................................................................................................10
2.7 Program Participation...............................................................................................................................12
2.8 Transportation Services.............................................................................................................................12
2.9 Tours and Trips..........................................................................................................................................13
2.10 Accessible and Adaptive Equipment..........................................................................................................13
2.11 Printed and Online Materials....................................................................................................................14
2.12 Website .....................................................................................................................................................15
2.13 Televised and Audiovisual Information .....................................................................................................16
2.14 Telecommunications .................................................................................................................................17
2.15 Emergency Planning..................................................................................................................................17
2.16 Facilities ....................................................................................................................................................19
2.17 Accessibility Practices in the Right-of-Way ...............................................................................................20 3 Summary and Conclusion............................................................................................................................ 21 Required Actions List ...............................................................................................................................................21 Conclusion ...............................................................................................................................................................25
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1 Introduction
According to Title II of the Americans with Disabilities Act (ADA), all programs, activities, and services offered to the public by the City of Coachella must be accessible for people with and without disabilities. Accessibility applies to all aspects of a program or service. Under Title II, public entities are required to evaluate their programs, activities, and services, make modifications to potentially discriminatory practices, and provide the opportunity for individuals with disabilities or organizations representing people with disabilitiesto participate in the process. The self-evaluation process identifies barriers and makes recommendations to correct policies and practices that are inconsistent with Title II requirements. When a public entity has 50 or more employees, it is required to maintain a record of the examination, describe the issues identified, describe the modifications made, and list the interested individuals consulted as part of the process (28 CFR 35.105). As programs and facility uses change, a re-review of accessibility practices should be conducted. If a public entity is the recipient of federal funds, a system for tracking program and service deficiencies, as well as periodically reviewing and updating the self-evaluation is required (29 U.S.C. 794; 49 CFR
27.121 (b)).
The City of Coachella does not currently have written policies or procedures for review as part of the self-evaluation. As the City grows, the need for formal documentation of policies will increase. An Accessible Policies and Procedures Memo, with recommendations for ensuring that policies created by the City of Coachella comply with the requirements of the ADA, is provided under a separate cover. In lieu of reviewing formal policy documents, this report summarizes the results of a staff questionnaire issued to representatives from 11 City of Coachella departments:
• Development Services
• Human Resources
• Finance
• Engineering
• City Manager's Office
• City Clerk
• Economic Development
• Finance
• Code Enforcement
• City Manager's Office
• IT Division
The questionnaire asked staff to answer questions regarding practices within their own department, to the best of their knowledge. Results summarized in this report provide a snapshot of the City’s efforts to make its programs, services, and activities accessible to the public, and identifies opportunities for staff training and areas where changes to City policies and practices are required.
The ADA Coordinator or designee will follow up with department managers to review the ADA Self-Evaluation Report information and Accessible Policies and Procedures Memo recommendations relevant to their department. In those situations where a policy, program, or procedure creates a barrier to accessibility, the ADA Coordinator or designee will coordinate with the department head or program manager to address the removal of the barrier.
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2 Questionnaire Results and Recommendations
Examples of policies include administrative rules, public documents, forms, applications, and the City's municipal code. This section is organized into the following categories based on the requirements of Title II of the ADA
• Notice
• Responsible Employee and
Grievance Procedure
• Customer Service
• Staff Training
• Contracting, Licensing, or Other
Arrangements
• Public Meetings
• Program Participation
• Transportation Services
• Tours and Trips
• Accessible and Adaptive Equipment
• Printed and Online Materials
• Website
• Televised and Audiovisual
Information
• Telecommunications
• Emergency Planning
• Facilities
Required actions are based on legislative requirements found in the ADA, or other published standards for accessibility. Some actions are always required, such as posting a notice of nondiscrimination, while other actions are only required when requested, such as providing alternative formats (for example, large print or braille documents). In many cases, the City has multiple options for providing accessible programs, activities, and services. This section also includes implementation strategies and links to the Department of Justice’s online best practices tool kit. The Tool Kit should be considered a helpful supplement to – not a replacement for – the regulations and technical assistance materials that provide more extensive discussions of ADA requirements. For the full “Best Practices Tool Kit for State and Local Governments,” see https://www.ada.gov/pcatoolkit/toolkitmain.htm.
2.1 Notice
Title II regulations require the City to inform the public of the rights and protections provided by the ADA for access to public programs, services, and activities (28 CFR 35.106). It is the obligation of the head of the public entity to determine the most effective way of providing notice to the public about their rights and the public entity's responsibilities under the ADA.
Publishing and publicizing the ADA notice is not a one-time requirement. Public agencies should provide the information on an ongoing basis and update the information whenever necessary. (www.ada.gov/pcatoolkit/chap2toolkit.htm)
Questionnaire Response Summary
The majority of the ten respondents of the Self-Evaluation were not aware of an official nondiscrimination statement, with only three of the ten respondents reporting yes. Of the three affirmatives, two pointed to the City employee handbook and MOU, and one pointed to
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the City of Coachella Personnel Rules and Regulations. One of the respondents also noted that nondiscrimination statements were posted in common areas like the kitchen and breakroom.
Required Actions
• Provide public notice of the City's commitment to providing accessible services (28 CFR
35.106).
Implementation Strategies
• Ensure staff are aware of the public locations of the nondiscrimination statement and the procedure for filing a disability discrimination or grievance complaint. • Provide notice of the availability of program modifications, alternative formats of materials, and auxiliary aids. Include contact information for staff who can provide assistance.
Establish a standardized advanced notice requirement and publicize. • Include a nondiscrimination notice in department publications, similar to the following with up-to-date ADA Coordinator contact information:
■ The City of Coachella does not discriminate on the basis of disability in the admissions or access to its programs or activities. An ADA Coordinator has been designated to coordinate compliance with the nondiscrimination requirements contained in the Department of Justice regulations implementing Subtitle A of Title II of the Americans with Disabilities Act (42 U.S.C. 12131-12134), which prohibits discrimination on the basis on disability by public agencies. • Republish and rebroadcast radio, newspaper, television, or mailings of the notice periodically, as applicable.
• Increase outreach to people with disabilities and the organizations that serve them to provide information about available modifications and the accessibility of services, programs, and activities.
2.2 Responsible Employee and Grievance Procedure
Title II of the ADA requires a state or local government agency that employs 50 or more people to develop and publish an ADA grievance procedure and to designate at least one employee to track and respond to complaints. In Coachella, the ADA Coordinator is responsible for the coordination of the City's efforts to implement the self-evaluation and transition plan. The ADA Coordinator is responsible for investigating any complaints that the City has engaged in an action prohibited by Title II, and is often responsible for communicating the City's efforts to comply with and fulfill its responsibilities under Title II of the ADA.
Questionnaire Response Summary
Of the ten respondents in the Self-Evaluation, four answered that yes, they knew who was the designated individual responsible for ensuring the City meets ADA obligations. Respondents were split between Lizzandro Diaz and Celina Jimenez as the designated employee while
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another named Human Resources personnel as the designated individuals. The remaining six respondents were uncertain of who the City of Coachella coordinator was, with one of the six noting that there was no official designated personnel but that the building official (Lizzandro Diaz) was currently taking the lead.
When asked if there was a process for a discrimination complaint or grievance four of the ten respondents answered that they were unaware of any procedures. The rest of the respondents answered that the proper channels involved submitting a complaint through Human Resources and Risk Management, while one noted that anyone can submit a comment on the City’s website.
Regarding if their department had someone specifically assigned to manage accessibility accommodation requests, four of the ten respondents answered yes, pointing to the various individuals like Human Resources, Celina Jimenez, and Andrew Simmons. The rest of the respondents answered that their department did not have an assigned person to manage accessibility accommodation requests.
When asked if they had staff to rely on for expertise regarding disability issues, three responded that they were unaware or had no such personnel. The rest of the respondents identified someone within their department as having some expertise on ADA and disability issues.
Required Actions
• Provide the name, office address, and telephone number of the employee or employees responsible for ensuring the City meets its ADA obligations under Title II to staff and the public (28 CFR 35.107).
• Publish the grievance procedure to provide fair and prompt resolution of accessibilityrelated complaints (28 CFR 35.107). • Ensure that people claiming a violation of Title II are not retaliated against or discriminated against for making such a claim (28 CFR 35.134).
• If applicable, Department of Transportation fund recipients and subrecipients must keep complaints on file for one year and maintain a record, which may be in summary form, for five years (49 CFR 27.121 (b)).
Implementation Strategies
• Refine the role and responsibilities of the ADA Coordinator and determine whether additional employees need to be identified to support this position. ■ Provide training for this position and employees supporting this position with regard to knowledge of the ADA and other laws addressing the rights of people with disabilities.
■ Provide training on the various alternative formats and technologies that enable people with disabilities to communicate, participate, and perform tasks.
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■ Ensure that the employee in this position has or receives adequate training to negotiate and mediate topics involving the grievance process. ■ Ensure that grievances are documented effectively and addressed in a timely manner.
• Maintain a citywide page to address and inform the public on the city's obligation under Title II of the ADA. The citywide page serves to provide a one-stop portal for access to the ADA notice, ADA Coordinator, requests for auxiliary aids and services, program modifications, the complaint process, self-evaluation and transition plan documents, and other city efforts regarding accessibility.
• Provide an ADA barrier removal request form on a City web page. This barrier removal request form can provide an opportunity for a person with a disability to report a need or concern related to programs, activities, or services provided by the City without filing a formal complaint.
• When requested, provide information identifying locations for pending or in-progress grievances that have already been reported.
2.3 Customer Service
In-person interaction with the public is one of the primary functions of most City departments.
To meet ADA standards for in-person interactions, staff should be aware of the formal and informal procedures for accommodating people with disabilities, including appropriate responses to requests for program modifications and guidelines for accommodating service animals. Only dogs are recognized as service animals under Title II of the ADA; in limited cases, miniature horses that are individually trained to perform tasks for people with disabilities may also qualify to provide services. Emotional support, therapy, comfort, or companion animals are not considered service animals under the ADA.
Questionnaire Response Summary
Except for two respondents, the rest of the surveyed representatives said that they did not receive training in interacting with people with disabilities. Of the survey respondents, 7 of 10 said that they either don’t know or do not make changes to standard operating procedures to include people with disabilities. The remaining three representatives surveyed responded that yes, their departments do make changes to standard operating procedures, citing that public events are always held in accessible venues. However, when asked if there was a formal procedure for making changes, only one responded affirmatively, saying that staff would most likely have to prepare a draft for the City Manager and City Attorney’s review and City Council’s approval. The other surveyed individuals marked “no” or “don’t know.” No staff reported tracking accessibility requests, and one noted that they do charge an additional fee to people with disabilities for modifying programs or providing additional services. Every surveyed individual reported that they do not consult or work with outside organizations or groups that assist people with disabilities.
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Half of respondents reported that their department allows service animals to accompany people with disabilities while the other half of those surveyed responded that they did not know. None of the surveyed individuals reported knowing the two questions they may ask regarding service animals.
Required Actions
• Be prepared to make appropriate modifications to regular practices to accommodate individuals with disabilities’ needs when providing customer service (28 CFR 35.130). • Ensure an additional fee is not charged to people requesting a program modification due to their disability (28 CFR 35.130(f)).
• Ensure that service animals are allowed in City facilities (28 CFR 35.136). • Make reasonable modifications for people with disabilities who rely on a miniature horse that is individually trained to assist them (28 CFR 35.130(i)).
Implementation Strategies
• Ensure that staff members are aware of the City's policy regarding service animals and are trained to implement this policy appropriately. Make sure staff know the two questions they are permitted to ask regarding service animals:
■ Is the dog a service animal required because of a disability? And ■ What work or task has the dog been trained to perform? • Develop a process for determining reasonable modifications as people with disabilities request them. The process should address the following considerations:
■ Ensure the public has easy access to information about requesting modifications and understanding who to contact.
■ Ensure all staff can direct a person requesting the modification to the appropriate staff member.
■ Ensure requests can be accepted from someone on behalf of the person with a disability and are not required to be in writing.
■ Ensure that requests and outcomes are tracked.
2.4 Staff Training
As a part of the City's ongoing staff development and training, the incorporation of disabilities awareness, standards, and resources is encouraged for all staff interfacing with the public or who maintain the facilities used by the public.
Questionnaire Response Summary
Every respondent noted that they have contact with the public. Over half (60%) of those surveyed were not aware of any staff training to include people with disabilities. Others cited that employees are given annual training on discrimination and disability sensitivity, as well as
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how to provide accommodations for hearing, visual, and/or physically impaired members of the public.
Required Actions
• Ensure that city staff are knowledgeable about obligations, policies, and procedures for providing accessible services, programs, and activities to the public (28 CFR 35.130; 28 CFR
35.160).
• Ensure that city staff are knowledgeable about procedures for responding to requests for modifications (28 CFR 35.160).
• Ensure that the relevant city staff are knowledgeable about the construction and maintenance of accessible facilities (28 CFR 35.133).
Implementation Strategies
• Develop and disseminate best practice resources for staff to formalize the City's approach to addressing accessibility concerns.
• Provide training to design and maintenance staff regarding accessibility standards and maintaining facilities in an accessible condition.
• Provide all department staff with ongoing awareness and sensitivity training. • Develop a comprehensive disability access training program. Educate staff about their responsibilities under the ADA. The City's ADA Coordinator or City supervisors should be responsible for ensuring that staff members receive training. Staff members who have contact with the public should receive additional training about the process of providing modifications and assistive devices to make their programs, activities, and services accessible. Ensure that training also includes information about responding to a variety of disabilities and the availability of program-specific adaptations, assistive devices, and modifications.
• Develop standard guidelines for training materials. These guidelines should include standard language that appropriately describes the city's policy on inclusion and nondiscrimination. Staff members should receive training in using the guidelines effectively. • Offer training to staff members that have contact with the public and wish to learn basic ASL communication skills. Training should emphasize basic communication and should not be viewed as a substitute for utilizing qualified ASL interpreters when requested.
2.5 Contracting, Licensing, or Other Arrangements
All events on public property should be accessible to people with disabilities. Many public agencies rely on contractors, licensees, consultants, and other entities to deliver City services.
These entities are considered an extension of the City's services and must adhere to the same ADA regulations.
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Questionnaire Response Summary
Four out of ten surveyed representatives reported using contractors or consultants to conduct programs, activities, or services on behalf of the City. These ranged from consultants engaging in organizing public outreach events to independent contractors that provide services such as marketing, photography, or videography. Two of those surveyed reported that their department organizes special events or facilitates private events at City facilities, like organizing public outreach events for capital projects.
Regarding informing contractors, consultants, and event organizers of their obligation to ensure programs, services, and activities are accessible, only three surveyed individuals stated that they do ensure that information is communicated. According to one representative, all outreach events are required to be held in ADA accessible locations.
Required Actions
• Ensure that contractors, licensees, consultants, and other entities providing or delivering services for the city adhere to the same ADA regulations as the City (28 CFR 35.130). • Ensure the City selects procurement contractors using criteria that does not discriminate on the basis of disability (28 CFR 35.130).
• Maintain City facilities in an accessible order to help ensure the accessibility of events held by public and private organizations (28 CFR 35.133).
Implementation Strategies
• Ensure contractors, licensees, and other entities providing services to the public are aware of their obligation to make City programs and activities accessible. Provide checklists, resources, contractual language, or other means to help them understand and meet their obligations.
• Monitor public programs and activities provided by contractors, licensees, and other entities to ensure continued accessibility. Provide staff with resources for conducting this review.
• Inform organizations that coordinate or sponsor events at City facilities about applicable ADA requirements.
2.6 Public Meetings
Public meetings are a regularly occurring activity for public agencies. Any public meeting's main objective is to impart and solicit information on issues of importance to the local government.
Where these meetings are held is one of the essential considerations for meetings under the ADA requirements.
Questionnaire Response Summary
Seven out of ten surveyed individuals reported that their department does hold public meetings. All the seven departments that host public meetings are required to hold these
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meetings in accessible locations. Three out of the seven departments that hold public meetings either don’t know or do not provide American Sign Language interpretation, readers, or adaptive equipment when requested for meetings, interviews, and conferences. Of the four departments that do provide accommodation, three did not respond or are unsure of the required advanced notice to provide accommodations, while one reports a necessary advanced period of 72 hours. Only two of the seven departments surveyed ensure that individuals with hearing disabilities who do not read sign language can participate effectively in meetings, conferences, and hearings.
When asked if staff who coordinate or facilitate public meetings were provided with resources for ensuring the accessibility of meetings, only two of the seven relevant departments responded yes, one of which saying that resources were given during an annual training for staff.
Required Actions
• Provide agendas and other meeting materials in alternative formats upon request (28 CFR
35.160).
• Provide flexibility in the time limit on speaking for individuals with communication difficulties (28 CFR 35.160).
• Ensure that assistive listening devices are available for public meetings where the sound at the meeting is amplified (28 CFR 35.160; 2010 Standards 219.2 Required Systems). • Continue to provide the opportunity to participate in public meetings remotely using technology such as a telephone, video, or other digital means and when oral and written testimony is allowed, provide a similar means of participation remotely (OR HB 2560-A).
Implementation Strategies
• When possible, share meeting content before the meeting and allow the submission of questions in advance of the meeting.
• Ensure a consistent advanced notice requirement and communicate this to both staff and the general public.
■ Ensure the City allows for longer than three minutes of speaking time at City Council meetings when requested for a disability.
• Display a notice on meeting agendas and web pages providing agendas and other meeting materials, indicating the availability of alternative formats of meeting materials and other elements of meeting participation.
• Prepare a list of accessible meeting spaces to facilitate the scheduling of meetings or the relocation of meetings as needed upon request.
• Maintain a list of on-call ASL interpreters who can attend meetings upon request to assist individuals who are deaf or have hearing loss.
• Develop a checklist and provide instruction to staff on ensuring the accessibility of meetings. Guidelines should include examples of the types of modification requests that
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may be made by people with different types of disabilities, including assistive listening systems, sign language interpreters, readers, descriptive services, and other assistive technologies like real-time captioning. Other considerations include the layout of the room and the locations of the sign-in and refreshmentstables, bathrooms, and other elements to ensure these features are accessible.
• Assign a member of staff as a greeter at public meetings and events. Identify this person as a resource for people who may require assistance.
2.7 Program Participation
The public must be able to access all programs, services, and activities, regardless of disability, unless a modification would result in a fundamental alteration to the nature of a service, program, or activity, or impose undue financial and administrative burdens (28 CFR 35.164).
Admission criteria, ability to complete forms, and participation in interviews must be available to all public members by providing reasonable modifications.
Questionnaire Response Summary
Only one department identified as having programs for public participation. The programs provided by this department had no eligibility requirements and had no limitations or ratios for the number of people with disabilities who may participate. This department chose participants based on residency and requires the use of forms for admission or selection to the program. No interviews are required and people with disabilities are integrated into programs, services, and activities.
Required Actions
• No required changes to the current program participation process have been identified.
Additional information regarding requirements for any new programs developed in the future has been provided in the Accessible Policies Memo.
2.8 Transportation Services
Many public agencies provide public transportation services. The public accommodation standards for these services are set forth by the Federal Transit Administration. The requirements under Title 49 CFR Parts 27, 37, 38, and 39 (www.ecfr.gov/current/title-49) include a broad spectrum of legislation that addresses nondiscrimination policies, vehicle and equipment use, programs and services, and transit routes, as well as oversight, complaints, and monitoring (FTA C 4710.1). The scope of the review of this self-evaluation addresses any potentially discriminatory practices under Title 28 CFR Part 35 – Nondiscrimination on the Basis of Disability in State and Local Government Services.
Questionnaire Response Summary
No surveyed representative reported managing transportation services for the public.
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Required Actions
• No required changes have been identified. Additional information regarding requirements for public transportation services has been provided in the Accessible Policies Memo.
2.9 Tours and Trips
Many public agencies provide or facilitate tours and trips as part of their service. These tours and trips are subject to Title II regulations. The City is responsible for ensuring that people with disabilities can experience the tour by making modifications upon request.
Questionnaire Response Summary
One survey representative said they provide tours of the city for developers. Two departments provide facility tours or organize trips for members of the public, such as tours of the city for small businesses. All but one surveyed individual didn’t know or did not have procedures to make tours and trips accessible to persons with disabilities.
Required Actions
• Modify tours and trips upon request to enable people with disabilities to participate (28 CFR
35.130).
Implementation Strategies
• Incorporate opportunities to request accessibility modifications in registration materials for tours or trips.
• Provide information to participants in advance of a tour or trip regarding the destination, transportation method, and other characteristics of the activity so that informed requests for modifications can be made.
• Evaluate the destination of tours or trips and the means of transportation to determine accessibility and any modifications that may be required. If a tour route or a portion of a route is inaccessible and modifications are requested, reroute the tour or provide program modifications that will allow the tour to be experienced (for example, photographs, videos with closed captioning).
• Consider developing alternate accessible tour materials such as braille handouts or screen reader versions of pamphlets, captioned videos or audio transcripts, and having ASL interpreters available by request, and things like touchable materials and maps can enhance the accessibility of the tour.
2.10 Accessible and Adaptive Equipment
Adaptive aids are devices, controls, appliances, or items that make it possible for people with disabilities to improve their ability to function independently and participate in programs, services, and activities offered by the City. For example, a pen, note pad, and clipboard provided to a person with a speech disability to write notes for brief communication or
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electronic equipment such as an accessible computer station are considered adaptive equipment.
Questionnaire Response Summary
No department representative reported public use of any equipment.
Required Actions
• No required changes have been identified. Additional information regarding requirements for accessible and adaptive equipment has been provided in the Accessible Policies Memo.
2.11 Printed and Online Materials
Many public agencies develop and distribute a wide range of materials in printed and online formats. To meet the ADA's effective communication standards, (28 CFR 35.160-164) the City must be able to provide alternative formats such as easy-to-understand language, braille, large print, audio files, computer media, or other formats, when requested. Documents published online must also meet the web content standards described in Section 2.12. This responsibility extends to outside contractors and vendors who develop materials on behalf of the City.
Questionnaire Response Summary
Six out of ten of surveyed respondents confirmed that they produce or provide printed or online materials that are available to the public. Of the six confirmed representatives, four of them were aware of their responsibility to provide accessible documents. Some departments were able to provide audio recordings or a digital copy of their printed media upon request for individuals with visual disabilities, while others reported that they have not provided alternative formats when requested.
Four of the six respondents made printed and online content in simple easy-to-understand language for individuals with learning disabilities. None of the self-identified departments generating printed or online materials were able to report if they include images of individuals with disabilities in their printed and online materials.
Required Actions
• Ensure alternative formats to printed and online information are made available upon request, addressing each request on an individual basis (28 CFR 35.160). • Ensure assistance is provided upon request in filling out forms when alternative formats are unavailable or infeasible (28 CFR 35.130).
• Continue to ensure that costs for alternative formats and modifications are not assigned to a person with a disability making the request (28 CFR 35.130).
Implementation Strategies
• Include a notice on public materials printed by the City, similar to the following that contains up to date ADA Coordinator contact information:
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This publication can be made available in alternative formats, such as large print, braille, or electronic format. Requests can be made by calling the ADA Coordinator at [telephone] (voice) or by using the 711 Telecommunications Relay Service, or email [access coordinator email]. Please allow 72 hours for your request to be processed. • Develop a formal standard for the accessibility of printed and online materials and create or identify resources for achieving this standard across all departments. Ensure that this standard includes oversight for externally created materials and strategies for making existing online materials accessible.
• Develop and implementstandard templates for producing accessible City materialsthat are consistent with City branding and style.
• Train staff to provide printed and online information in alternative formats for people with various disabilities to ensure that requests are handled in a uniform and consistent manner.
Incorporate strategies for materials with complex language or other elements such as charts, graphs, maps, and other images.
• Include images of people with disabilities when images of people are included in City printed materials.
2.12 Website
As people turn to the internet as their primary source of information regarding services, programs, activities, and facilities, the City's website takes on increased importance as a communicationstool. Providing public access to City publications online is an effective means of reaching people with disabilities (www.ada.gov/websites2.htm).
On April 24, 2024, the Federal Register published the Department of Justice’s final rule updating its regulations for Title II of the ADA. The final rule has specific requirements about how to ensure that web content and mobile applications (apps) are accessible to people with disabilities. The ruling identifies Web Content Accessibility Guidelines (WCAG) Version 2.1, Level AA as the technical standard for state and local governments' web content and mobile apps.
The requirements take full effect in April of 2026 or 2027, depending on the size of the Title II entity.
Questionnaire Response Summary
All but two representatives surveyed identified their department as having a website. Four respondents confirmed that they were responsible for managing their own website. However, no department was able to name policies to ensure their website was usable by individuals with disabilities.
Required Actions
• Take appropriate steps to ensure that the City's online communication with people with disabilities is as effective as other communications with the public and ensure compliance with WCAG 2.1 digital accessibility standards (28 CFR 35.160).
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• Ensure that people with disabilities are not excluded from participating in or benefitting from the City's online services, programs, or activities (28 CFR 35.160).
Implementation Strategies
• Provide information on the city website about the accessibility of facilities. • Acquire technological resources, staffing expertise, or on-call consultant contracts to create accessible digital documents for posting on the city website. • Develop a formal standard for website accessibility and create or identify resources for achieving this standard across all departments. Ensure that this standard includes oversight for externally created web pages and incorporates strategies for making accessibility updates to existing web pages.
• Periodically conduct web accessibility analyses to measure the accessibility of the city's websites periodically. Consider adopting standards that meet or exceed WCAG 2.0 AA for the accessibility of electronic information.
2.13 Televised and Audiovisual Information
Televised and audiovisual information is a means for disseminating public information through presentations produced by the City. All televised and audiovisual information, including PowerPoint presentations, must be accessible to people with disabilities. As more communication is done remotely through the internet, it is increasingly important that all communication tools maintain accessibility as technology changes.
Questionnaire Response Summary
Of the ten representatives surveyed, three produced audiovisual or televised media for the public. All three departments relied on automatic captioning through their host sites, and one department also utilized captioning and transcription services.
Required Actions
• Provide alternative formats upon request to audiovisual presentations produced by the City or its contractors or vendors (28 CFR 35.160).
• Continue to ensure that televised and audiovisual communications with people with disabilities is as effective as televised and audiovisual communications with others (28 CFR
35.160).
Implementation Strategies
• Review City presentations, videos, and recordings of meetings to identify potential barriers to accessibility and corresponding solutions.
• Ensure auto-captioning of online video content is edited for accuracy. • Encourage presenters to read presentation slides and describe the graphic content when presenting PowerPoint or other visual presentations.
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2.14 Telecommunications
Technological advances such as cell phones, texting, and instant messaging are changing the tools that many people use to communicate. However, the provision of alternative communication technologies such as teletypewriters (TTY), telecommunication display devices (TDDs), or relay services (TRS) is still required under the ADA for communicating with the public.
Questionnaire Response Summary
All but one department communicates by telephone with the public. All surveyed department representatives were unaware of or did not use telecommunication or teletypewriter services that aid individuals with hearing or speech disabilities. For public use of phones, phones were either not allowed for public use, or the department representative didn’t know or didn’t provide TTYs for individuals with disabilities. No one was aware of providing a TTY number in materials where a phone number is listed.
Required Actions
• Ensure that staff is proficient in the use of alternative communication technologies such as TTY, TDDs, or TRS, or are able to direct the public to knowledgeable staff (28 CFR 35.161). • Ensure that city publications that list phone numbers also include information on how people who are deaf or who have hearing loss or speech disorders can communicate with the city by phone (28 CFR 35.161; 28 CFR 35.163).
• Ensure that telecommunications with people with disabilities is as effective as communications with others (28 CFR 35.161; 28 CFR 35.163). • Ensure that responses to calls from a telecommunications relay service are handled in the same manner as responding to other telephone calls (28 CFR 35.161).
Implementation Strategies
• Train staff on the use of alternative communication technologies. • Explore options for Video Remote Interpreting Services (VRI) for communicating with people who are deaf, have hearing loss, or speech disorders. There are many situations where a live interpreter is required, such as in medical situations, but VRI can be a convenient, flexible, lower-cost alternative to live interpreters.
2.15 Emergency Planning
Life and safety protocols and procedures are required to include plans for people with disabilities. The City is responsible for ensuring that staff are aware of these procedures and are trained to implement them during an emergency. Issues that have the greatest impact on people with disabilities include:
• Notification;
• Evacuation;
• Emergency transportation;
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• Access to medications, refrigeration, and back-up power; • Access to their mobility devices or service animals while in transit; and • Access to information.
In planning for emergency services, the City is required to develop strategies for notifying and assisting people with the widest range of disabilities. The City is responsible for ensuring that staff are aware of these procedures and are trained to implement them during an emergency.
Questionnaire Response Summary
All but one surveyed department self-identified as being responsible for planning, coordinating, or assisting in the City’s emergency response. The majority of departments didn’t know if their contracts with third-party services ensured compliance with ADA requirements; one department did report having an ADA-compliant contract, while for another department the question was not applicable. No department representative was able to name any written procedures for including people with disabilities in the development of emergency procedures, but one department representative did report that they seek input from people with disabilities or representative organizations for feedback on emergency simulations.
None of the departments had staff trained in notifying and assisting people with disabilities in emergency situations. Moreover, no department was aware of whether members of the public who use TTYs and computer modems had direct access to telephone emergency services.
Required Actions
• Include strategies for people with disabilities in various types of emergency situations when developing guidelines and a plan for emergency evacuations (28 CFR 35.130; 28 CFR
35.149).
• Train staff to safely evacuate people with disabilities in various types of emergency situations when developing guidelines and a plan for emergency evacuations (28 CFR
35.130; 28 CFR 35.149).
• Provide direct access to telephone emergency services, including 911 services, for people who use TDD's and computer modems (28 CFR 35.162).
• If the City becomes involved in providing emergency shelters, provide emergency sheltering programs that are accessible to people with disabilities (28 CFR 35.130; 28 CFR 35.149).
Implementation Strategies
• Review existing procedures dealing with emergencies to ensure that people with disabilities can be alerted and that they can alert emergency service providers. • Work with disability organizations to explore the use of technologies such as audible exit signs for orientation and direction or vibrating paging systems. • Develop plans that consider the needs of people using mobility aids such as wheelchairs, walkers, canes, crutches, or other power-driven mobility devices, or those with limited stamina. Plans should also address those who use oxygen or respirators, those who are
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blind or have low vision, people who are deaf or have hearing loss, people who have a cognitive disability, people with mental illness, and those with other types of disabilities. • Test the City's emergency plan and evacuation procedures with periodic drills, both announced and unannounced. Enlist people with different disabilities to role-play during emergency simulations.
• Incorporate the following elements into emergency planning for individual facilities:
■ Address what to do when an alarm is triggered;
■ Establish meeting placesfor assistance and evacuation chairs; ■ Provide direction on what to do if assistance is not available; and ■ Establish floor captains.
2.16 Facilities
City facilities should be accessible to people with different types of disabilities. A public entity is not necessarily required to make each of its existing facilities accessible, where other methods are effective in achieving program access. However, they must ensure that each service, program, or activity, when viewed in its entirety (28 CFR 35.160), is readily accessible to and usable by individuals with disabilities. The identification of structural barriers in facilities such as buildings, parks, and the public rights-of-way are required elements of an ADA Transition Plan.
Questionnaire Response Summary
No department representative reported having information on their website or printed materials about accessibility of facilities where the programs and services they offered. There were also no reports of requests to improve the accessibility of their associated facilities.
Required Actions
• Ensure that the public can obtain information regarding the existence and location of accessible facilities, entrances, and elements within facilities (28 CFR 35.163). • Provide and maintain, in working order, features of facilities required to be accessible and usable for people with disabilities (28 CFR 35.133).
• Ensure that people with disabilities are not excluded from programs due to the inaccessibility of City facilities (28 CFR 35.149).
• Prioritize methods of achieving facility accessibility that offer the most integrated setting appropriate for people with disabilities (28 CFR 35.149). • Design and construct new facilities or new parts of facilities to meet accessibility requirements (28 CFR 35.151(a)).
• Ensure that alterationsto facilities meet accessibility requirementsto the maximum extent feasible (28 CFR 35.151(b)).
• Make reasonable modifications to permit the use of mobility devices, including other power-driven mobility devices, unless they cannot be operated in accordance with the City's adopted safety requirements for pedestrian facilities (28 CFR 35.137(b)(1)).
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Implementation Strategies
• Provide information about the accessibility of City-owned and operated facilities on city publications, including city websites. This can include details about accessible entrances, bathrooms, and other elements.
• Provide information about the accessibility of non-City facilities hosting City programs and services and City-owned facilities that are leased to other entities. • Record and monitor requests relating to facility access. The ADA Coordinator can analyze accessibility requests periodically to look for global issues that can be addressed and problems that can be solved proactively.
• Develop formal standards for integrating ADA requirements into the design, construction, maintenance, and inspection of all City of Coachella facilities. As part of this effort, develop and implement standards for enforcing accessibility provisions for contractors, consultants, vendors, etc. who design, construct, maintain, and inspect City facilities. • Identify or hire staff members tasked with accessibility plan review.
2.17 Accessibility Practices in the Right-of-Way
Management, maintenance, and construction of facilities in the public right-of-way is often handled separately from other construction and maintenance projects. It is important to ensure that public right-of-way facilities comply with current standards and provide equal access to people with disabilities.
Note that although the questionnaire summary below shows that City staff is confident in their policies and procedures addressing accessibility in the public right-of-way, City sidewalks, crosswalks, and curb ramps was a primary concern for some participants in the ADA Stakeholders Feedback sessions held with community members who have disabilities or are caretakers for persons with disabilities. Community members described frustration with discontinuous accessible routes, barriers and obstacles in sidewalks, and missing or inadequate curb ramps. The discrepancy between self-reported practices in the Right-of-Way and the experiences of community members with disabilities may indicate that while design and implementation for new projects are handled effectively, existing right-of-way facilities need evaluation for repair and replacement. Further investigation into the City’s pedestrian infrastructure network and accessibility practices in the right-of-way is needed to address resident complaints.
Questionnaire Response Summary
Only one surveyed representative provided services related to the construction and maintenance of City facilities in the right-of-way. They noted that they conduct internal and external plan checks by trained and license professionals to ensure compliance with ADA requirements. No non-compliant projects are allowed to be installed and if something is missed in the plan checks, then it will be adjusted to meet compliance in the field. Although temporary
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pedestrian access routes (TPARs) are not required, if TPARs are installed, daily inspections will take place to ensure continued access.
The department does use third-party entities and to ensure ADA responsibilities are met, the department will conduct internal and external plan checks by licensed professionals. To communicate ADA requirements to third parties, they host regular pre-development team (PDT) meetings before construction and preconstruction meetings paired with daily inspections during construction.
The representative surveyed did not see any difference between accessibility components as designed versus when constructed. They also noted that they need no further staff and have adequate internal resources to meet ADA compliance and resolve issues.
Required Actions
• Ensure that the public can obtain information regarding the existence and location of accessible transportation facilities, entrances, and elements within right-of-way facilities (28 CFR 35.163).
• Provide and maintain, in working order, features of right-of-way elements required to be accessible and usable for people with disabilities (28 CFR 35.133).
Implementation Strategies
• Identify and delegate staff responsibilitiesfor updating public communications regarding accessible right-of-way facilities, temporary pedestrian access routes, and maintenance disruptions.
• Follow accessible communication requirements and strategies described in sections 2.11 Printed and Online Materials, 2.12 Website, and 2.14 Televised and Audiovisual Information, as applicable.
3 Summary and Conclusion
The self-evaluation survey reveals successful components and areas for improvement in City of Coachella policies and practices. The Required Actions from Section 2 have been compiled below:
Required Actions List
Notice
• Provide public notice of the City's commitment to providing accessible services (28 CFR
35.106).
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Responsible Employee and Grievance Procedure
• Provide the name, office address, and telephone number of the employee or employees responsible for ensuring the City meets its ADA obligations under Title II to staff and the public (28 CFR 35.107).
• Publish the grievance procedure to provide fair and prompt resolution of accessibilityrelated complaints (28 CFR 35.107). • Ensure that people claiming a violation of Title II are not retaliated against or discriminated against for making such a claim (28 CFR 35.134).
• If applicable, Department of Transportation fund recipients and subrecipients must keep complaints on file for one year and maintain a record, which may be in summary form, for five years (49 CFR 27.121 (b)).
Customer Service
• Be prepared to make appropriate modifications to regular practices to accommodate individuals with disabilities’ needs when providing customer service (28 CFR 35.130). • Ensure an additional fee is not charged to people requesting a program modification due to their disability (28 CFR 35.130(f)).
• Ensure that service animals are allowed in City facilities (28 CFR 35.136). • Make reasonable modifications for people with disabilities who rely on a miniature horse that is individually trained to assist them (28 CFR 35.130(i)).
Staff Training
• Ensure that city staff is knowledgeable about obligations, policies, and procedures for providing accessible services, programs, and activities to the public (28 CFR 35.130; 28 CFR
35.160).
• Ensure that city staff is knowledgeable about procedures for responding to requests for modifications (28 CFR 35.160).
• Ensure that the relevant city staff is knowledgeable about construction and maintenance of accessible facilities (28 CFR 35.133).
Contracting, Licensing, or Other Arrangements
• Ensure that contractors, licensees, consultants, and other entities providing or delivering services for the city adhere to the same ADA regulations as the City (28 CFR 35.130). • Ensure the City selects procurement contractors using criteria that does not discriminate on the basis of disability (28 CFR 35.130).
• Maintain City facilities in an accessible order to help ensure the accessibility of events held by public and private organizations (28 CFR 35.133).
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Public Meetings
• Provide agendas and other meeting materials in alternative formats upon request (28 CFR
35.160).
• Provide flexibility in the time limit on speaking for individuals with communication difficulties (28 CFR 35.160).
• Ensure that assistive listening devices are available for public meetings where the sound at the meeting is amplified (28 CFR 35.160; 2010 Standards 219.2 Required Systems). • Continue to provide the opportunity to participate in public meetings remotely using technology such as a telephone, video, or other digital means and when oral and written testimony is allowed, provide a similar means of participation remotely (OR HB 2560-A).
Program Participation
• No required changes have been identified.
Transportation Services
• No required changes have been identified.
Tours and Trips
• Modify tours and trips upon request to enable people with disabilities to participate (28 CFR
35.130).
Accessible and Adaptive Equipment
• No required changes have been identified.
Printed and Online Materials
• Ensure alternative formats to printed and online information is made available upon request, addressing each request on an individual basis (28 CFR 35.160). • Ensure assistance is provided upon request in filling out forms when alternative formats are unavailable or infeasible (28 CFR 35.130).
• Continue to ensure that costs for alternative formats and modifications are not assigned to a person with a disability making the request (28 CFR 35.130).
Website
• Take appropriate steps to ensure that the City's online communication with people with disabilities is as effective as other communications with the public and ensure compliance with WCAG 2.1 digital accessibility standards (28 CFR 35.160). • Ensure that people with disabilities are not excluded from participating in or benefitting from the City's online services, programs, or activities (28 CFR 35.160).
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Televised and Audiovisual Information
• Take appropriate steps to ensure that the City's online communication with people with disabilities is as effective as other communications with the public and ensure compliance with WCAG 2.1 digital accessibility standards (28 CFR 35.160). • Ensure that people with disabilities are not excluded from participating in or benefitting from the City's online services, programs, or activities (28 CFR 35.160).
Telecommunications
• Ensure that staff are proficient in the use of alternative communication technologies such as TTY, TDDs, or TRS, or are able to direct the public to knowledgeable staff (28 CFR 35.161). • Ensure that city publications that list phone numbers also include information on how people who are deaf or who have hearing loss or speech disorders can communicate with the city by phone (28 CFR 35.161; 28 CFR 35.163).
• Ensure that telecommunications with people with disabilities are as effective as communications with others (28 CFR 35.161; 28 CFR 35.163). • Ensure that responses to calls from a telecommunications relay service are handled in the same manner as responding to other telephone calls (28 CFR 35.161).
Emergency Planning
• Include strategies for people with disabilities in various types of emergency situations when developing guidelines and a plan for emergency evacuations (28 CFR 35.130; 28 CFR
35.149).
• Train staff to safely evacuate people with disabilities in various types of emergency situations when developing guidelines and a plan for emergency evacuations (28 CFR
35.130; 28 CFR 35.149).
• Provide direct access to telephone emergency services, including 911 services, for people who use TDD's and computer modems (28 CFR 35.162).
• If the City becomes involved in providing emergency shelters, provide emergency sheltering programs that are accessible to people with disabilities (28 CFR 35.130; 28 CFR 35.149).
Facilities
• Ensure that the public can obtain information regarding the existence and location of accessible facilities, entrances, and elements within facilities (28 CFR 35.163). • Provide and maintain, in working order, features of facilities required to be accessible and usable for people with disabilities (28 CFR 35.133).
• Ensure that people with disabilities are not excluded from programs due to the inaccessibility of City facilities (28 CFR 35.149).
• Prioritize methods of achieving facility accessibility that offer the most integrated setting appropriate for people with disabilities (28 CFR 35.149).