Nondiscrimination & Accessibility

Americans with Disabilities Act and Section 504 of the Rehabilitation Act of 1973 Assurance

28 Code of Federal Regulations Part 35.130, Title II of the Americans with Disabilities Act prohibits discrimination on the basis of disability by public entities. Subtitle A protects qualified individuals with disabilities from discrimination on the basis of disability in the services, programs, or activities of all state and local governments. It extends the prohibition of discrimination in federally assisted programs established by section 504 of the Rehabilitation Act of 1973 to all activities of state and local governments, including those that do not receive federal financial assistance, and incorporates specific prohibitions of discrimination on the basis of disability from Titles I, III, and V of the Americans with Disabilities Act. This rule, therefore, adopts the general prohibitions of discrimination established under section 504, as well as the requirements for making programs accessible to individuals with disabilities and for providing equally effective communications. It also sets forth standards for what constitutes discrimination on the basis of mental or physical disability, provides a definition of disability and qualified individual with a disability, and establishes a complaint mechanism for resolving allegations of discrimination.

The City of Waco, HEREBY AGREES THAT, as a condition to receiving any federal financial assistance from the U.S. Department of Transportation through the Federal Highway Administration, is subject to and will comply with all laws and regulations, and hereby gives assurance that no qualified disabled person shall, solely by reason of his or her disability, be excluded from participation in, be denied the benefits of, or otherwise be subjected to discriminations, including discrimination of employment, under any program or activity that received or benefits from this federal financial assistance. City of Waco further assures that its programs will be conducted, and its facilities operated, in compliance with all the requirements imposed by or pursuant to 49 CFR Part 27, 28 CFR Part 35, and 42 USC §§ 12101 – 12213.

Bradley Ford,
City Manager
City of Waco
9/8/2025

Americans with Disabilities Act and Section 504 of the Rehabilitation Act of 1973 Nondiscrimination Statement

The City of Waco does not discriminate against any qualified disabled person solely by reason of his or her disability, exclude from participation in, deny the benefits of, or otherwise subject individuals to discrimination, including discrimination of employment, under any program or activity that receives or benefits from federal financial assistance.

Additionally, City of Waco ensures its programs will be conducted, and its facilities operated, in compliance with all non-discriminatory practices and requirements imposed by or pursuant to 49 Code of Federal Regulations (CFR) Part 27, 28 CFR Part 35 and 42 USC §§ 12101 – 12213.

Bradley Ford,
City Manager
City of Waco
9/8/2025

This complaint procedure is established to meet the requirements of the ADA. It may be used by anyone who wishes to file a complaint alleging discrimination on the basis of disability in the provision of services, activities, programs, or benefits by the City of Waco.

The complaint should be submitted in writing as soon as possible, and no more than 180 days after the alleged incident. Complaints should contain the following information:

• Name of the person making the report of discrimination
• Contact information including address, phone number, and email of the person making the report
• A description of the alleged discrimination including the date and location of the incident and, if applicable, the names of witnesses or City staff involved, if known.

Submit complaints to:
Lhea Homesley, ADA Coordinator
Preferred Method: Complaint Form
Email: lheah@wacotx.gov
Mail: City of Waco
PO Box 2570
Waco, TX 76702-2570
Attn: ADA Coordinator

Alternative means of filing complaints, such as personal interviews, will be made available for persons with disabilities upon request by contacting the ADA Coordinator.

The individual who submitted the complaint will be notified once it has been received. The ADA Coordinator, or another authorized representative, will then contact the individual to review the allegations, investigate the concerns, and issue a written response within 45 calendar days.

If the response from the ADA Coordinator does not fully resolve the concern, a written appeal may be submitted to the City Manager or designee. The appeal should include the following information:

1. Explanation of the Appeal: A clear description of the specific aspects of the ADA Coordinator’s response that are being challenged.
2. Requested Outcome: A statement outlining the desired result or action being sought through the appeal.

Providing this information ensures the concern is clearly understood and fairly reviewed during the next stage of the process. Upon receiving the written appeal, the City Manager or designee will reach out to the individual to discuss possible resolutions and will provide a written response outlining the final decision.

All written complaints received by the ADA Coordinator, appeals to the City Manager or their designee, and responses from these two offices will be retained by the City of Waco in accordance with the Texas Local Government Retention Schedule.

The City of Waco is currently undergoing a planning process for conducting a self-evaluation to identify and address accessibility barriers within City facilities, programs, services, and activities. The Self-Evaluation will be used to develop and update the Transition Plan.

Updates will be provided on this page periodically.

Feedback Opportunity
Please contact the ADA Coordinator to provide feedback regarding concerns about the accessibility of City facilities, programs, services, and activities.

ADA Coordinator:
Lhea Homesley
Employee Relations/ADA Coordinator
lheah@wacotx.gov
(254) 750-5693

2019 ADA Transition Plan

The City of Waco is dedicated to making our website accessible for all users. To enhance accessibility for individuals with disabilities, we have implemented several features. Below are some key elements designed to improve the user experience.

We provide descriptive text equivalents for images and non-text elements, assisting users who utilize screen readers to listen to the site's content rather than reading it.

Major reports and special publications available on the website are typically offered in HTML or other accessible formats. When we publish documents in PDF format, we also ensure that an accessible version is available or provide a link for easy conversion to HTML.

The City of Waco is committed to ensuring its website meets the standards set by the Web Content Accessibility Guidelines (WCAG). These guidelines outline requirements for designers and developers to improve accessibility for people with disabilities. We are actively working towards achieving compliance with WCAG Version 2.1, Level AA.

We continuously strive to ensure that our website is accessible and user-friendly. However, due to the wide range of assistive technologies available, some users may still encounter issues. We appreciate your understanding and encourage you to provide feedback to help us improve and enhance the site's accessibility for users with disabilities.

If you use assistive technology and encounter any issues accessing information on our website, please contact the ADA Coordinator.

To help us assist you better, kindly specify the nature of your accessibility challenge, your preferred format for receiving the material, the web address of the content you requested, and your contact information.

ADA Coordinator:
Lhea Homesley
Employee Relations/ADA Coordinator
lheah@wacotx.gov
(254) 750-5693

Service animals, as defined by the Americans with Disabilities Act, are dogs who have been trained to help an individual with a specific documented disability.

Service animals must always be under the handler's control, using:

• a leash or harness; or
• voice command, if the hander's disability or dog's work task prevents using a leash

A service animal can be removed by a City official if:

• the animal is not housebroken; or
• the animal is out of control and the handler fails to control the animal

Emotional support, comfort, or companion animals are NOT considered service animals.

Please do not allow the public to approach or pet your service animal.

Texas Human Resources Code, Section 121.005 states handlers can be held liable for damage to property or injuries to persons.

Texas Human Resources Code, Section 121.006 states that it is a violation of any person to misrepresent that a dog is a specially trained service animal, when training has not been provided.

ADA Coordinator:
Lhea Homesley
Employee Relations/ADA Coordinator
lheah@wacotx.gov
(254) 750-5693

Persons with disabilities who plan to attend public meetings and who may need auxiliary aides or services should contact the ADA Coordinator at least twenty-four (24) hours before the scheduled meeting so that appropriate arrangements can be made.

ADA Coordinator:
Lhea Homesley
Employee Relations/ADA Coordinator
lheah@wacotx.gov
(254) 750-5693

Scope of Title VI Complaints

No person or groups of persons shall be excluded from participation in, be denied the benefits of, or be otherwise subjected to discrimination under any and all programs, services, or activities administered by City of Waco, and its contractors, on the grounds of race, color, national origin, age, sex, religion, or disability.

The scope of Title VI covers all internal and external activities of City of Waco.

The following types of actions are prohibited under Title VI protections (See 49 C.F.R. 21.5):

• Excluding individuals or groups from participation in programs or activities
• Denying program services or benefits to individuals or groups
• Providing a different service or benefit or providing them in a manner different from what is provided to others
• Denying an opportunity to participate as a member of a planning, advisory or similar body that is an integral part of the program
• Retaliation for making a complaint or otherwise participating in any manner in an investigation or proceeding related to Title VI of the Civil Rights Act of 1964

How to File a Formal Title VI Complaint

Any person(s) or organization(s) believing they have been discriminated against on the basis of the protected classes stated above by City of Waco or its contractors may file a Title VI complaint.

Discrimination complaints must be received no more than 180 days after the alleged incident unless the time for filing is extended by the processing agency.

Complaints should be in writing and signed and may be filed by mail, fax, in person, or e-mail. A complaint should contain the following information:

• A written explanation of the alleged discriminatory actions;
• The complainant’s contact information, including, if available: full name, postal address, phone number, and email address;
• The basis of the complaint (e.g., race, color, national origin, etc.);
• The names of specific persons and respondents (e.g., agencies/organizations) alleged to have discriminated;
• Sufficient information to understand the facts that led the complainant to believe that discrimination occurred in a program or activity that receives Federal financial assistance; and
• The date(s) of the alleged discriminatory act(s) and whether the alleged discrimination is ongoing.

Complainants are encouraged to submit complaints directly to the Texas Department of Transportation (TxDOT).

Complaints can also be filed by completing and submitting City of Waco’s Title VI Complaint Form or by sending an email or letter with the necessary information to:

City of Waco
Mailing: City of Waco, PO Box 1270, Waco TX 76701, Attn: Title VI Coordinator
Email: lheah@wacotx.gov
Phone: (254) 750-5693

If necessary, the complainant may call the phone number above and provide the allegations by telephone. The Title VI Coordinator will transcribe the allegations of the complaint as provided over the telephone and send a written complaint to the complainant for correction and signature.

Complaints can also be filed directly with the following agencies:

After submitting a complaint, the complainant will receive correspondence informing them of the status of the complaint within ten (10) business days from the City of Waco or other agency receiving the complaint.

Complaints received by City of Waco’s Title VI Coordinator are forwarded to the TxDOT Office of Civil Rights (OCR). TxDOT OCR will forward the complaint to the FHWA Texas Division Office, along with a preliminary processing recommendation. The FHWA Texas Division Office will forward the complaint to FHWA Headquarters Office of Civil Rights (HCR).

FHWA HCR is responsible for all determinations regarding whether to accept, dismiss, or transfer Title VI complaints. There are four potential outcomes for processing complaints:

• Accept: if a complaint is timely filed, contains sufficient information to support a claim under Title VI, and concerns matters under the FHWA’s jurisdiction, then HCR will send to the complainant, the respondent agency, and the FHWA Texas Division Office a written notice that it has accepted the complaint for investigation.
• Preliminary review: if it is unclear whether the complaint allegations are sufficient to support a claim under Title VI, then HCR may (1) dismiss it or (2) engage in a preliminary review to acquire additional information from the complainant and/or respondent before deciding whether to accept, dismiss, or refer the complaint.
• Procedural Dismissal: if a complaint is not timely filed, is not in writing and signed, or features other procedural/practical defects, then HCR will send the complainant, respondent, and FHWA Texas Division Office a written notice that it is dismissing the complaint.
• Referral\Dismissal: if the complaint is procedurally sufficient but FHWA (1) lacks jurisdiction over the subject matter or (2) lacks jurisdiction over the respondent entity, then HCR will either dismiss the complaint or refer it to another agency that does have jurisdiction. If HCR dismisses the complaint, it will send the complainant, respondent, and FHWA Division Office a copy of the written dismissal notice. For referrals, FHWA will send a written referral notice with a copy of the complaint to the proper Federal agency and a copy to the USDOT Departmental Office of Civil Rights.

Complaints are not investigated by City of Waco. FHWA HCR is responsible for investigating all complaints. FHWA HCR may also delegate the investigation to TxDOT OCR, who would then conduct all data requests, interviews, and analysis and create a Report of Investigation (ROI). TxDOT OCR will have sixty (60) business days from the date the investigation is delegated to prepare the ROI and send it to HCR. HCR will review the ROI and compose a Letter of Finding based on the ROI.

For further information about the FHWA investigation process and potential complaint outcomes, please visit the Questions and Answers for Complaints Alleging Violations of Title VI of the Civil Rights Act of 1964.

Complaint Log

City of Waco maintains a complaint log to document all activity related to the complaint. Information captured includes:

• Complainant’s name, and if provided, race, color, and national origin;
• Respondent’s name;
• Basis(es) of the discrimination complaint;
• Allegation(s)/Issue(s) surrounding the discrimination complaint;
• Date the discrimination complaint was filed;
• Date the investigation was complete;
• Disposition;
• Disposition date; and
• Other pertinent information.