[IL-Talk] Audio Pedestrian Signal Consent Decree

Sun Dec 14 23:51:30 UTC 2025

At the recent NFB of Chicago meeting, the consent decree in the audible
pedestrian signal case was mentioned. Below is a copy of the decree. The
court requires the City of Chicago to install APS at 71 percent of
intersections by the end of 2035. Then the court will develop a plan for
what is described as meaningful access for installations until the end of
2040. The city has created a website at chicagoaps.org for blind persons to
request an APS installation or track a request. Be sure to select the menu
display to find all the options.

Section 7(a) requires the City of Chicago to create what the order
identifies as a “APS Community Advisory Committee.” The order states “The
Committee shall include representatives from CDOT (those responsible for
implementing the remedial plan), MOPD, and Chicago’s blind community,
including

organizations that serve the blind community. The Committee should meet
quarterly and provide feedback to City of Chicago on all issues relating to
the remedial plan.”

The court order uses the word “should,” which means the advisory committee
is a required mandate and not optional. The order was entered In May 2025
so the committee should have met twice. Has anyone from the Federation
attended these meetings? If so, who? Has the Federation been formally
invited to be a member of the committee? The NFB of Illinois is an
organization that delivers services to the blind as stated in the court
order and of course represents blind people and their interests. The NFB
has a different perspective toward blind independence than the ACB, whose
members brought the lawsuit.

Something not mentioned yesterday was the free OKO iPhone app that
identifies when the walk signal at an intersection is on and also when the
countdown starts before the walk cycle ends. The app can be used on any
iPhone running iOS 17 or later, meaning all new iPhones from 2018 or later.
This list includes the iPhone XR, XS, SE second generation or later, and
the 11 series or later. OKO is only on iPhone and only traffic lights with
the hand for don’t walk and the walking man for walk can be recognized by
the app. Intersections whose walk signals just display the words walk or
don’t walk cannot be recognized by the app. The app is currently owned and
maintained by *Synapse ITS, a private equity owned transportation
technology company. Synapse ITS owns Polara Enterprises*, a major
manufacturer of Accessible Pedestrian Signals. The app used to be available
only through a paid subscription. Shortley after *Synapse ITS* acquired OKO
in July 2025, the company made the app free without any subscription.

Kelly

Case: 1:19-cv-06322 Document #: 365 Filed: 05/29/25 Page 1 of 15 PageID
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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

AMERICAN COUNCIL OF THE

BLIND OF METROPOLITAN

CHICAGO, et al.,

Plaintiff,

UNITED STATES OF AMERICA,

Plaintiff-Intervenor,

Case No. 19 C 6322

Hon. LaShonda A. Hunt

v.

THE CITY OF CHICAGO,

Defendant.

REMEDIAL PLAN ORDER

This matter is before the Court on the parties’ respective motions for
entry of a remedial

plan. (Dkts. 279, 285, 292). The motions are resolved as set forth herein.

I. Background

A. Complaint

On September 23, 2019, Plaintiffs American Council of the Blind of
Metropolitan Chicago

(“ACBMC”), Ann Brash, Maureen Heneghan, and Ray Campbell, on behalf of
themselves and all

others similarly situated, commenced this action against Defendant City of
Chicago 1 by filing a

Complaint alleging, among other things, that City of Chicago violated Title
II of the Americans

with Disabilities Act (“ADA”), 42 U.S.C. §§ 12131-34, and Section 504 of
the Rehabilitation Act

of 1973 (“Section 504”), 29 U.S.C. § 794, by failing to equip signalized
street intersections with

accessible pedestrian signals (“APS”). (Dkt. 1). On April 14, 2021, the
Court entered an order

granting Plaintiff-Intervenor United States of America’s unopposed motion
to intervene as a

plaintiff. (Dkt. 77).

The Complaint also named Chicago Department of Transportation (“CDOT”),
Lori Lightfoot, in her official

capacity as Mayor of the City of Chicago, and Thomas Carney, in his
official capacity as Acting Commissioner of the

Chicago Department of Transportation, as Defendants. (Dkt. 1). On March 9,
2020, the Court entered a Memorandum

Opinion and Order granting in part Defendant’s partial motion to dismiss
terminating CDOT, Lightfoot, and Carney

as parties. (Dkt. 43).

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B. Liability Order

On March 31, 2023, the Court 2 entered a Memorandum Opinion and Order,
among other

things, finding City of Chicago liable for violating the ADA and
Rehabilitation Act by failing to

provide meaningful access to its network of pedestrian signals. (Dkt. 248).

C. Remedial Phase

Between July 2023 and February 2024, the parties engaged in supplemental
discovery and

briefing regarding the appropriate remedy. (Dkt. 256). On November 7, 2024,
the Court held a

status hearing during which the parties stated their respective positions
concerning whether the

Court would need to hold an evidentiary hearing to determine the
appropriate remedy. (Dkt. 344).

After considering the partes’ positions, briefs, evidence, and applicable
law, the Court found an

evidentiary hearing unnecessary and issued a proposed remedial plan order
on March 10, 2025

(Dkt. 350). Having reviewed the parties’ joint statement with proposed
revisions to the remedial

plan filed on April 9, 2025 (Dkts. 351, 351-1), and held a hearing on May
28, 2025 to resolve any

remaining issues and consider the recommended independent monitor and
objections thereto (Dkt.

361), the Court finalizes the remedial plan as follows:

II.

General Provisions

A. Governing Law

This Remedial Plan Order is governed by all applicable law, rules, and
regulations,

including Title II of the ADA, 42 U.S.C. §§ 12131-34, as amended, Section
504, 29 U.S.C. § 794,

28 C.F.R. Part 35, and 49 C.F.R. Part 27.

B. Applicable Standards

City of Chicago shall install and maintain APS in compliance with the
then-current Manual

on Uniform Traffic Control Devices (“MUTCD”) (“then-current” defined to be
the version of the

MUTCD adopted by the State of Illinois at a given time), including all APS
installed and

maintained by third-party contractors.

C. Scope

Subject to the yearly minimum requirements set forth below, City of Chicago
shall install

APS at a minimum of approximately 71% of signalized intersections with
pedestrian signals by

December 31, 2035 (“Phase I”), and at the remaining signalized
intersections with pedestrian

signals but without APS by December 31, 2040 (“Phase II”). Upon the
completion of Phase I, City

of Chicago may file a motion to eliminate or extend Phase II based on a
showing that meaningful

access has been achieved.

This case was reassigned from Judge Bucklo to Judge Hunt on June 2, 2023.
(Dkt. 251).

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D. Priority

City of Chicago shall prioritize the installation of APS at certain
categories of signalized

intersections with pedestrian signals, as set forth below.

E. Discretion

City of Chicago shall have the right to use reasonable and good faith
discretion in

implementing the terms of this Remedial Plan Order including to (i) create
efficiencies in the

design, approval, bidding, and construction of APS installations, (ii)
respond to material and/or

labor shortages, (iii) group similar intersections when placing projects
for bid; (iv) re-prioritize

intersections for construction to respond to delays arising from approvals
issues, underground

utility review issues, redesign issues, and a lack of acceptable bids; and
(v) exercise engineering

judgment and discretion in designing and installing APS to the extent
permitted by the MUTCD.

When City of Chicago exercises “engineering judgment” to deviate from MUTCD

Guidance in a manner provided for by the MUTCD, it shall contemporaneously
document in

writing the reason and support for such engineering judgment and deviation.
In addition, City of

Chicago shall, on at least a monthly basis, provide the Certified
Orientation and Mobility Specialist

(“COMS”), as defined in Section VIII.A.1, infra, with identification of all
instances where

engineering judgment was used to deviate from MUTCD Guidance, with
supporting

documentation, and the COMS shall review, provide feedback, and levy
objections when

appropriate. Should the City and/or the COMS identify conditions where
engineering judgment is

repeatedly exercised, the City shall adopt written procedures and criteria
established by an

engineer and in consultation with the COMS to be applied in the exercise of
such engineering

judgment.

Such discretion may not serve to otherwise excuse the City from
non-compliance with the

requirements of this Order, including those requirements regarding
prioritization and yearly

minimum requirements, as set forth below.

F. Continuing Obligation

To stay in compliance and avoid further violations of the ADA and Section
504, barring

any changed circumstances, the policies set forth in this Remedial Plan
Order shall remain in place

after the completion of Phases I and II, as described below.

III.

Implementation

A. Priority

Within six (6) months, City of Chicago, in consultation with Plaintiffs,
United States, the

Independent Monitor, and the APS Community Advisory Committee, shall
establish a mechanism

that utilizes criteria set forth in the National Cooperative Highway
Research Program (“NCHRP”),

Accessible Pedestrian Signals: A Guide to Best Practices for APS Location
Selection, and

considers the complexity of intersections, to prioritize the installation
of APS at signalized

intersections with pedestrian signals consistent with the priority
categories set forth below. City of

Chicago is not required to score each individual intersection. For all
intersections that do not fall

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within these priority provisions, City of Chicago has discretion to select
the order of APS

installation to meet its minimum yearly requirements. City of Chicago shall
make reasonable

efforts to install APS equitably across the city.

1. Newly Pedestrian Signalized Intersections.

City of Chicago shall install APS at all newly signalized intersections
(i.e., any time that

an intersection is provided with pedestrian signals that did not previously
have pedestrian signals).

2. Existing Signalized Intersections

City of Chicago shall install APS at all signalized intersections with
pedestrian signals but

without APS based on the following priorities.

a. Public Requests

Within twelve (12) months of the date of this Order, City of Chicago shall
install APS at

all intersections for which there was an outstanding public request to
install APS as of March 9,

2025. Before doing so, City of Chicago shall attempt to confirm that each
such requestor still

desires APS installation to occur (such that City of Chicago does not
prioritize installation where

there is no unique, immediate need, as where the requestor has moved). This
12-month timeframe

is contingent upon City of Chicago’s evaluation of the adequacy of existing
infrastructure at each

intersection to support APS installation without other significant
additional upgrades, including,

but not limited to, full traffic signal modernization (“TSM”) (defined as
the simultaneous

replacement of all or substantially all of the traffic signal
infrastructure at the intersection); in such

cases a 12-month timeframe may be impossible. If the request cannot be
fulfilled within 12 months,

City of Chicago must consult with the COMS to consider ways to minimize the
impact for blind

pedestrians.

City of Chicago shall review and respond to public requests to install APS
at a signalized

intersection with pedestrian signals received during the pendency of this
Remedial Plan Order

within six (6) months of receipt. Where possible to do so, City of Chicago
must install APS at the

intersection within twelve (12) months of receipt of the request. If City
of Chicago believes that

the installation cannot be completed within twelve (12) months of receipt
of the request, it must

install APS at the intersection within twenty-four (24) months of receipt
of the request. This 24-

month timeframe is contingent upon City of Chicago’s evaluation of the
adequacy of existing

infrastructure at each intersection to support APS installation without
other significant additional

upgrades, including, but not limited to, full TSM; in such cases a 24-month
timeframe may be

impossible. If the request cannot be fulfilled within 24 months, City of
Chicago must consult with

the COMS to consider ways to minimize the impact for blind pedestrians.

If City of Chicago receives more than twenty-five (25) requests during a
calendar year, it

may file a motion seeking relief from the requirement to prioritize such
requests exceeding twentyfive

(25) per calendar year if such prioritization would impair meeting the
other targets and goals

set in this Remedial Plan Order.

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b. New Signal Equipment

City of Chicago shall install APS at all signalized intersections with
pedestrian signals that

undergo a TSM, defined as the simultaneous replacement of all or
substantially all of the traffic

signal infrastructure at the intersection.

If City of Chicago modifies a signalized intersection to install exclusive
pedestrian phases

(“EPP”), it shall not begin using or otherwise “turn on” that feature
before the APS at that

intersection are installed and operating.

c. Particularly Dangerous Conditions

Along with public requests, City of Chicago shall first prioritize
installation of APS at all

signalized intersections with pedestrian signals that are equipped with
EPP, mid-block pedestrian

crossings (“MPS”), T-shaped intersections (“TSI”), three or more distinct
streets or have other

complex geometry (as defined to be the 100 most complex intersections in
the City of Chicago’s

Complex Intersection Study, a list of which are attached as Appendix A
hereto). After APS is

installed at all intersections with EPP, MPS, TSI, and those with
intersections of three or more

distinct streets and other complex geometry, City of Chicago must
prioritize installing APS at

intersections with LPI and PTP as early in Phase I as possible.

If there is a public request for APS at an intersection with EPP or leading
pedestrian

intervals (“LPI”), and the request cannot be immediately fulfilled, City of
Chicago must consult

with the COMS to consider ways to minimize the impact for blind pedestrians
until APS are

installed and MUTCD compliant.

d. Public Transportation

City of Chicago shall prioritize signalized intersections with pedestrian
signals within 1/8

mile of public transportation, specifically CTA stations, Metra stations,
PACE stations, bus route

to bus route transfer points, and streets that pass under elevated train
lines.

e. Public Facilities

City of Chicago shall prioritize signalized intersections with pedestrian
signals within 1/8

mile of public facilities such as hospitals, police stations, major
pedestrian attractions (e.g., major

shopping areas, major cultural venues, and educational campuses),
organizations serving people

with visual disabilities and seniors, and government buildings, including
those facilities

specifically listed in Appendix B attached hereto. Should City of Chicago
require assistance

prioritizing within this category, it shall consult with the COMS and the
APS Community

Advisory Committee.

B. Phase I

1. Scope

Subject to the yearly minimum requirements set forth below, City of Chicago
shall install

APS at a minimum of approximately 71% of signalized intersections with
pedestrian signals by

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December 31, 2035. Signalized intersections at which APS is already
installed and are MUTCD

compliant at the time of installation (but not including audio-only APS)
shall count towards this

requirement.

2. Priority

During Phase I, City of Chicago shall install APS pursuant to the Priority
provisions of this

Remedial Plan Order, specifically including intersections subject to public
requests, new signal

equipment, particularly dangerous conditions, public transportation, and
public facilities.

3. Yearly Minimum Requirements

During Phase I, City of Chicago shall install APS on, at minimum, the
following number

of signalized intersections with pedestrian signals. To the extent that
City of Chicago fails to meet

a given year’s total despite having acted in good faith, any
underperformance shall be made up in

the subsequent year. To the extent that City of Chicago exceeds the minimum
requirement in a

given year, the excess may be applied to the following years’ minimum
totals. APS installations

at newly signalized intersections with pedestrian signals shall be counted
in calculating the APS

installations for any given year.

“Year 1” is defined to commence as of the date of the entry of this Order
and last for one

full calendar year.

Year 1:

Year 2:

Year 3:

Year 4:

Year 5:

Year 6:

Year 7:

Year 8:

Year 9:

Year 10:

70 Intersections

110 Intersections

135 Intersections

154 Intersections

185 Intersections

220 Intersections

235 Intersections

245 Intersections

245 Intersections

245 Intersections

4. Meaningful Access

At the completion of Phase I, City of Chicago may file a motion to
eliminate or extend

Phase II based on a showing of meaningful access.

C. Phase II

1. Scope

Subject to the yearly minimum requirements set forth below, City of Chicago
shall install

APS at all remaining signalized intersections with pedestrian signals
without APS by December

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31, 2040, unless that deadline has been eliminated or extended based on a
showing of meaningful

access.

2. Prioritization

During Phase II, City of Chicago shall install APS pursuant to the Priority
provisions of

this Remedial Plan Order, specifically including intersections subject to
public requests, new

signal equipment, public transportation, and public facilities.

3. Yearly Minimum Requirements

During Phase II, City of Chicago shall install APS at signalized
intersections with

pedestrian signals at a rate sufficient to ensure that, when installed at a
consistent rate over five

years, City of Chicago will have equipped all signalized intersections with
pedestrian signals with

APS by the end of Phase II.

IV.

Compliance

To ensure that all APS are installed and maintained in compliance with
MUTCD standards,

City of Chicago shall promptly establish and implement an APS compliance
program that proves

effective at ensuring that APS are installed and maintained in compliance
with the MUTCD and

any succeeding standards, regulations, or changes in the law setting forth
the required

specifications. An effective compliance program in this context is one that
contains at least the

following material elements:

i. An effective, on-site inspection system to assess, at the time of
installation, whether

each APS unit has been installed and programmed in compliance with the
MUTCD;

ii.

iii.

iv.

An annual, post-installation inspection program that is effective to
identify

maintenance and programming issues that arise post-installation and confirm

continued compliance with the MUTCD;

An effective system to solicit, compile, analyze, and generate reports on
complaints

and repair requests made by members of the public with regard to existing
APS

installations; and

An effective system to promptly repair and correct the maintenance and
compliance

issues identified by members of the public and City of Chicago’s own
inspectors.

V. Maintenance

A. Routine Maintenance

City of Chicago shall routinely perform maintenance inspections of all APS
to a degree

and on a schedule not less than what is performed with respect to visually
based pedestrian signals.

City of Chicago shall repair or replace APS that are not functioning as
intended within five (5)

business days after inspection or another reasonable period thereafter if
extenuating circumstances

prevent the repair or replacement from being completed.

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B. Requests for Maintenance or Repair

City of Chicago shall establish a centralized system for members of the
public or City of

Chicago officials or employees to submit a request for maintenance or
repair of an APS device.

City of Chicago shall ensure that requests are logged and accessible to the
public through the APS

website. City of Chicago shall repair or replace APS that are not
functioning as intended within

five (5) business days after a request is submitted or another reasonable
period thereafter if

extenuating circumstances prevent the repair or replacement from being
completed. Extenuating

circumstances may include, without limitation, where major damage has
occurred, where there are

prolonged materials shortages, where there is a report of an over-loud APS
device that does not

implicate safety concerns, or where spoken messages cannot be added or
fixed without technical

assistance. Should City of Chicago determine extenuating circumstances
prevent the repair or

replacement form being completed within five (5) business days, it shall
include that determination

and the reason for the delay within its tracking system accessible on the
APS website.

VI.

Communication

City of Chicago shall regularly maintain and update an accessible APS
website, consistent

with Web Content Accessibility Guidelines (“WCAG”) 2.1 Level AA, listing
intersections with

APS, providing contact information of City of Chicago official(s) to
contact regarding APS, and

permitting community members to make public requests for APS installation,
maintenance, or

repair and track the progress of such requests.

On the accessible APS website, City of Chicago shall track each request,
post the request

under a Public Request List for APS within thirty (30) days of the request,
and review and respond

within six (6) months of receipt, giving an approximate timeline of when
the request will be

completed and the relative priority of the requested intersections as
compared to other requested

intersections.

The public must be permitted to submit a request for APS installation in
several ways,

including online, by telephone, and in person at aldermanic offices or the
Mayor’s Office for

People with Disabilities (“MOPD”). City of Chicago shall ensure that all
requests are processed

through a centralized review system.

VII.

Community Involvement

A. APS Community Advisory Committee

City of Chicago shall create and regularly communicate with an APS
Community Advisory

Committee. The Committee shall include representatives from CDOT (those
responsible for

implementing the remedial plan), MOPD, and Chicago’s blind community,
including

organizations that serve the blind community. The Committee should meet
quarterly and provide

feedback to City of Chicago on all issues relating to the remedial plan.

B. Public Requests

City of Chicago shall maintain a program to accept and respond to public
requests for the

installation of APS as described in Section III.A.2.a of this Remedial Plan
Order.

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VIII. Oversight, Monitoring, and Reporting

A. City of Chicago

1. Personnel

City of Chicago must appoint and maintain (1) a single point person within
CDOT

responsible for overseeing implementation of the Remedial Plan Order, and
(2) a single point

person within CDOT responsible for assuring City of Chicago’s comprehensive
pursuit of funding

to support installation of APS.

City of Chicago must also engage a Certified Orientation and Mobility
Specialist

(“COMS”) who has demonstrated experience with and knowledge of the
technical standards for

APS, and is familiar with Chicago, to consult with City of Chicago and
provide expertise on

installation and maintenance of APS, including the reasons MUTCD standards
are critical for the

safety of travelers with vision disabilities.

City of Chicago personnel appointed pursuant to this paragraph must consult
regularly

with the APS Community Advisory Committee and COMS.

2. Reporting

City of Chicago must submit regular reports at least every six (6) months
(or another period

agreeable to the parties) addressing compliance with this Remedial Plan
Order to counsel for

Plaintiffs and United States, the COMS, and the Independent Monitor. Upon
request of the

Independent Monitor for relevant documents or information, City of Chicago
shall promptly

provide such documents and information regarding its compliance with this
Remedial Plan Order.

B. Independent Monitor

1. Selection and Appointment

Plaintiffs, United States, and City of Chicago shall jointly select and
recommend and the

Court shall appoint an Independent Monitor to oversee City of Chicago’s
compliance with this

Remedial Plan Order.

2. Authority

The Monitor shall have the power and right to retain consultants, consult
with City

personnel and COMS, and inspect APS installations. The Independent Monitor
shall have access

to City records and information about City of Chicago’s APS program. The
Independent Monitor

may identify any deficiencies and attempt to resolve them in consultation
with the parties,

including by recommending corrective action. The Independent Monitor shall
report to the Court,

City of Chicago, the Plaintiffs, and the United States to the extent that
they identify material issues

with City of Chicago’s performance under this Remedial Plan Order.

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3. Communication

The Independent Monitor may communicate ex parte with any party and the
COMS.

4. Duties

a. Oversight

The Independent Monitor shall proceed with all reasonable diligence to
oversee City of

Chicago’s compliance with this Remedial Plan order.

b. Reporting

The Monitor shall file with the Court annual written reports regarding City
of Chicago’s

performance under this Remedial Plan Order. Such reports, at a minimum,
must include the

following information:

i. The number of APS installations conducted in the prior twelve (12)
months;

ii.

iii.

iv.

Whether those installations complied with the MUTCD;

Whether installations complied with the prioritization required under the
Remedial

Plan Order;

Whether City of Chicago complied with the Communication, Community

Involvement, and Maintenance provisions of this Remedial Plan Order; and

v. Recommendations for improving implementation of the Remedial Plan Order.

c. Meetings

The Independent Monitor shall meet semiannually with the APS Community
Advisory

Committee, CDOT personnel, and COMS.

5. Fees and Expenses

Independent Monitor shall submit annual budgets and applications for fees
and expenses

for approval. City of Chicago shall pay the Independent Monitor’s
reasonable fees and expenses.

Within thirty (30) days of entry of this Order, counsel for Plaintiffs, the
United States, and City of

Chicago shall submit a joint proposed order setting forth procedures for
approval of the

Independent Monitor’s budgets, fees, and expenses.

6. Term

The Independent Monitor shall serve for a term of five (5) years, subject
to requests for

extension, replacement, or termination.

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IX.

Modification

City of Chicago, Plaintiffs, and/or the United States may seek modification
of this

Remedial Plan Order on any grounds specified in this Remedial Plan Order,
as well as to address

unforeseen circumstances, changing standards governing APS and/or
pedestrian signals, new

technology, and impossibility.

X. Dispute Resolution

If Plaintiffs or the United States believe that City of Chicago has not
complied in any

material respect with this Remedial Plan Order, they shall provide written
notice to all parties and

the Independent Monitor outlining the ways they believe City of Chicago is
in non-compliance.

Following notice of potential non-compliance, the parties must confer in
good faith for a period of

up to 30 days to resolve the dispute, with assistance from the Independent
Monitor. If the parties

are unable to resolve a dispute, any Party may make a motion to the Court
to enforce the Remedial

Plan Order.

XI.

Attorneys’ Fees and Costs

Plaintiffs are deemed to be prevailing parties in this litigation and are
thus entitled to

reasonable attorneys’ fees, costs and expenses for work performed in
connection with this

litigation, including those incurred monitoring or enforcing City of
Chicago’s implementation

obligations under the Remedial Plan Order. If Plaintiffs’ counsel and City
of Chicago are unable

to negotiate a mutually agreeable resolution as to attorneys’ fees, costs
and expenses within thirty

(30) days, Plaintiffs’ counsel may move or apply to the Court for an award
of attorneys’ fees, costs

and expenses for the work performed in connection with this litigation or
monitoring.

DATED: May 29, 2025

ENTERED:

LASHONDA A. HUNT

United States District Judge

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APPENDIX A

100 Most Complex Intersections: (i) N. Francisco Avenue, W. Fullerton
Avenue, N. Milwaukee

Avenue, and N. Sacramento Avenue, (ii) N. Southport Avenue, W. Webster
Avenue, and N.

Clybourn Avenue, (iii) N. Sheffield Avenue, W. Willow Street, and N.
Clybourn Avenue, (iv) N.

Canal Street, W. Lake Street, and N. Milwaukee Avenue, (v) N. Halsted
Street, W. North Avenue,

and N. Clybourn Avenue, (vi) N. California Avenue, W. Belmont Avenue, and
N. Elston Avenue,

(vii) N. Western Avenue, W. Diversey Parkway, and N. Elston Avenue, (viii)
Ashland Avenue,

W. Fullerton Avenue, and N. Clybourn Avenue, (ix) N. Ogden Avenue, W.
Randolph Street, and

W. Washington Boulevard, (x) S. Wentworth Avenue, W. Cermak Road, S. Clark
Street, and I90

Feeder Ramp, (xi) S. Narragansett Avenue, W. 55 th Street, and W. Archer
Avenue, (xii) S.

California Avenue, W. 40 th Place, and S. Archer Avenue, (xiii) N. Halsted
Street, W. Fullerton

Avenue, and N. Lincoln Avenue, (xiv) S. South Shore Drive, E. 71 st Street,
S. Exchange Avenue,

and S. Yates Boulevard, (xv) S. Exchange Avenue. E. 79 th Street, E.
Cheltenham Place, (xvi) S.

Exchange Avenue and E 83 rd Street, (xvii) S. Stony Island Avenue, E. 79 th
Street, S. South Chicago

Avenue and I90 Feeder Ramp, (xviii) S. Yates Boulevard, E. 87 th Street,
and S. South Chicago

Avenue, (xix) S. Vincennes Avenue and W. 99 th Street, (xx) N. Damen
Avenue, W. Diversey

Parkway, and N. Clybourn Avenue, (xxi) S. Oakley Avenue, Roosevelt Road,
and W. Ogden

Avenue, (xxii) N. Sacramento Boulevard and W. Grand Avenue, (xxiii) N.
Hoyne Avenue, W.

George Street, and N. Clybourn Avenue, (xxiv) N. Halsted Street, W. Grand
Avenue, and N.

Milwaukee Avenue, (xxv) N. Halsted Street, W. Barry Avenue, and N. Clark
Street, (xxvi) N.

Carpenter Street, N. Milwaukee Avenue, W. Huron Street, and N. Morgan
Street, (xxvii) S.

Avenue Lane, E. 95 th Street, and S. Ewing Avenue, (xxviii) S. Vincennes
Avenue and W. 119 th

Street, (xxix) N. Nagle Avenue, N. Avondale Avenue, and W. Somerset Avenue,
(xxx) N. Lehigh

Avenue, W. Devon Avenue, N. Caldwell Avenue, and N. Central Avenue, (xxxi)
Ashland Avenue,

W. Madison Street, N. Ogden Avenue, and W. Monroe Street, (xxxii) S. Canal
Street, W. 23 rd

Street, and S. Archer Avenue, (xxxiii) S. Ashland Avenue and S. Archer
Avenue, (xxxiv) S. Canal

Street, W. Cermak Road, and S. Grove Street, (xxxv) S. Damen Avenue, W.
Harrison Street, W.

Ogden Avenue, and W. Polk Street, (xxxvi) N. Clark Street, W. Diversey
Parkway, and N.

Broadway, (xxxvii) N. Sheridan Road, W. Diversey Parkway, N. Cannon Drive,
and N. Stockton

Drive, (xxxviii) N. Halsted Street, W. Grace Street, and N. Broadway,
(xxxix) N. Kedzie Avenue,

W. Addison Street, N. Elston Avenue, and N. Sawyer Avenue, (xl) S. Morgan
Street, W. Cermak

Road, and S. Canalport Avenue, (xli) N. Pulaski Road, W. School Street, and
N. Milwaukee

Avenue, (xlii) N. Larrabee Street, W. Webster Avenue, and N. Lincoln
Avenue, (xliii) S. Cottage

Grove Avenue, E. 71 st Street, and S. South Chicago Avenue, (xliv) S. Ellis
Avenue, E. 73 rd Street,

and S. South Chicago Avenue, (xlv) N. Milwaukee Avenue, W. Lawrence Avenue,
W. Higgins

Avenue, and W. Ainslie Street, (xlvi) S. Halsted Street, W. 85 th Street,
and S. Summit Avenue,

(xlvii) N. Central Avenue, W. Foster Avenue, N. Milwaukee Avenue, N.
Northwest Highway, and

W. Farragut Avenue, (xlviii) Cicero Avenue and W. Grand Avenue, (xlix) N.
Kostner Avenue, W.

North Avenue, and W. Grand Avenue, (l) S. Hoyne Avenue, W. 35 th Street,
and S. Archer Avenue,

(li) N. Ashland Avenue, W. Division Street, and N. Milwaukee Avenue, (lii)
S. Martin Luther

King Drive, E. Marquette Road, and S. South Chicago Avenue, (liii) N.
Western Avenue, W.

Armitage Avenue, and N. Milwaukee Avenue, (liv) S. Racine Avenue, W. 14 th
Street, and S. Blue

Island Avenue, (lv) S. Loomis Street, W. 18 th Street, and S. Blue Island
Avenue, (lvi) N. Central

Avenue, W. Higgins Avenue, and W. Edmunds Street, (lvii) S. Princeton
Avenue, W. Cermak

Road, and S. Archer Avenue, (lviii) N. Monticello Avenue, W. Irving Park
Road, and N. Elston

Avenue, (lix) S. Ashland Avenue, W. Cermak Road, and S. Blue Island Avenue,
(lx) S. Rockwell

Case: 1:19-cv-06322 Document #: 365 Filed: 05/29/25 Page 13 of 15 PageID
#:11352

Street, W. Pershing Road, and S. Archer Avenue, (lxi) N. Monticello Avenue,
W. Division Street,

W. Grand Avenue, and Central Park Avenue, (lxii) S. Pulaski Road, W. 87 th
Street, and South

West Highway, (lxiii) S. Western Avenue, W. 37 th Place, and S. Archer
Avenue, (lxiv) N.

Rockwell Street, W. Bryn Mawr Avenue, and N. Lincoln Avenue, (lxv) N.
Kenneth Avenue, W.

Lawrence Avenue, and N. Elston Avenue, (lxvi) N. Octavia Avenue, Irving
Park Road, and W.

Forest Preserve Avenue, (lxvii) N. Harlem Avenue and W. Grand Avenue,
(lxviii) S. Pulaski Road,

W. 50 th Street, and S. Archer Avenue, (lxix) S. Martin Luther King Drive
and E. 51 st Street, (lxx) S.

Lawndale Avenue, W. 83 rd Place, and W. Columbus Avenue, (lxxi) N.
Elizabeth Street, W. Grand

Avenue, and N. Ogden Avenue, (lxxii) N. Racine Avenue, W. Cortland Street,
N. Clybourn

Avenue, and W. Armitage Avenue, (lxxiii) S. Sacramento Avenue, W. 42 nd
Street, and S. Archer

Avenue, (lxxiv) N. Harlem Avenue, W. Palatine Avenue, and N. Avondale
Avenue, (lxxv) N.

Kedzie Avenue, W. Walton Street, and W. Grand Avenue, (lxxvi) N. Clark
Street, W. Rosehill

Drive, N. Ashland Avenue, W. Victoria Street, W. Edgewater Avenue, (lxxvii)
N. Clark Street,

W. Peterson Avenue, N. Ridge Avenue, and N. Paulina Street, (lxxviii) S.
Ashland Avenue, W.

111 th Street, and W. Chelsea Place, (lxxix) S. Torrence Avenue and E. 100
th Street, (lxxx) N.

Racine Avenue, W. Erie Street, N. Ogden, and W. Ohio Street, (lxxxi) N.
Paulina Street, W. Adams

Street, and W. Ogden Avenue, (lxxxii) S. Jefferson Street, W. Cermak Road,
and S. Lumber Street,

(lxxxiii) S. Albany Avenue, W. 43 rd Street, and S. Archer Avenue, (lxxxiv)
N. Leclaire Avenue,

W. Armitage Avenue, W. Grand Avenue, and N. Lawler Avenue, (lxxxv) S.
Woodland Avenue,

E. 75 th Street, S. South Chicago Avenue, (lxxxvi) S. Loomis Street, W.
Fuller Street, and S. Archer

Avenue, (lxxxvii) S. Avenue L, E. 100 th Street, and S. Indianapolis
Avenue, (lxxxviii) S. Western

Avenue, W. Pershing Road, and S. Western Boulevard, (lxxxix) South State
Street, E. Marquette

Road, I94 Feeder Ramp, S. Wabash Avenue, (xc) S. Pulaski Road, W. Harrison
Street, W. 5 th

Avenue, and W. Flournoy Street, (xci) N. Austin Avenue, W. Lawrence Avenue,
and N. Mason

Avenue, (xcii) S. Damen Avenue and W. 37 th Street, (xciii) N. Melvina
Avenue, N. Elston Avenue,

N. Milwaukee Avenue, and W. Holbrook Street, (xciv) N. Nagle Avenue, W.
Devon Avenue, and

N. Milwaukee Avenue, (xcv) S. Normal Avenue, W. 18 th Street, S. Canalport
Avenue, S. Clinton

Street, (xcvi) S. Mackinaw Avenue, S. DuSable Lake Shore Drive, S. Ewing
Avenue, and S.

Harbor Avenue, (xcvii) S. Wentworth Avenue, W. 73 rd Street, and S.
Vincennes Avenue,

(xcviii) N. Ravenswood Avenue, W. Addison Street, and N. Lincoln Avenue,
(xcix) S. Pulaski

Road, W. Cermak Road, W. Ogden Avenue, and S. Harding Avenue, and (c) N.
Western Avenue,

W. Logan Boulevard, and West Jones Street.

Case: 1:19-cv-06322 Document #: 365 Filed: 05/29/25 Page 14 of 15 PageID
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APPENDIX B

Centers for People with Visual Disabilities: (i) The Chicago Lighthouse at
1850 W Roosevelt

Road, (ii) Second Sense at 65 E Wacker Place, (iii) Friedman Place at 5527
N Maplewood Avenue,

(iv) Access Living at 115 W Chicago Avenue, (v) Equip for Equality at 20
North Michigan

Avenue, (vi) Blind Service Association at 17 N State Street, (vii) Harold
Washington Library

Assistive Resources and Talking Book Center at 400 S State Street, (viii)
Illinois Center for

Rehabilitation and Education-Wood at 1950 W Roosevelt Road, (ix) National
Federation of the

Blind Illinois at 5128 N Oak Park Avenue, (x) JVS Chicago - Disability
Services at 216 W Jackson

Boulevard, (xi) JVS Chicago - Disability Services at 909 W Wilson Avenue,
(xii) JVS Chicago –

Disability Services at 6639 N Kedzie Avenue, and (xiii) UIC Institute on
Disability and Human

Development (IDHD) at 1640 W Roosevelt Road

Senior Centers: (i) Central West Center at 2102 W. Ogden Avenue, (ii)
Northeast (Levy) Senior

Center at 2019 W. Lawrence Avenue, (iii) Northwest (Copernicus) Senior
Center at 3160 N.

Milwaukee Avenue, (iv) Renaissance Court at 78 E. Washington, (v) Southeast
(Atlas) Senior

Center at 1767 E. 79th Street, (vi) Southwest Center at 6117 S. Kedzie
Avenue, (vii) Abbott Park

Satellite Senior Center at 49 East 95th Street, (viii) Auburn Gresham
Satellite Senior Center at

1040 West 79th Street, (ix) Austin Satellite Senior Center at 5071 W.
Congress Parkway, (x)

Chatham Satellite Senior Center at 8300 S. Cottage Grove, (xi) Edgewater
Satellite Senior Center

at 5917 N. Broadway, (xii) Englewood Satellite Senior Center at 653-657
West 63rd Street, (xiii)

Garfield Ridge Satellite Senior Center at 5674B South Archer Avenue, (xiv)
Kelvyn Park Satellite

Senior Center at 2715 N. Cicero Avenue, (xv) North Center Senior Satellite
at 4040 N. Oakley,

(xvi) Norwood Park Senior Satellite at 5801 N. Natoma, (xvii) Pilsen
Satellite Senior Center at

2021 South Morgan, (xviii) Portage Park Satellite Senior Center at 4100
North Long, (xix)

Roseland Satellite Senior Center at 10426 South Michigan Avenue, (xx) South
Chicago Satellite

Center at 9233 South Burley, and (xxi) West Town/Logan Square Satellite
Senior Center at 1615

West Chicago Avenue.

Other: (i) the intersection of E Lower Wacker Drive, N Lakeshore Drive, N
Breakwater Access,

and N Lake Front Drive, (ii) the intersection of E Lake Street and N
Columbus Drive, (iii) the

intersection of S Indiana Avenue and E Roosevelt Road, (iv) the
intersection of W Jackson Street

and S Jefferson Street, (v) the intersection of W Jackson Street and S
Desplaines Street, (vi) the

intersection of W Adams Street and S Desplaines Street, (vii) the
intersection of W Monroe Stret

and S Jefferson Street, (viii) the intersection of W Monroe Street and S
Desplaines Street, (ix) the

intersection of W Monroe Street and S Halsted Street, (x) the intersection
of W Madison Street

and S Jefferson Street, (xi) the intersection of N Halsted Street and W
Erie Street, (xii) the

intersection of W Division Street and N Clybourn Avenue, (xiii) the
intersection of W Division

Street and N Wells Street, (xiv) the intersection of E Division Street and
N Lakeshore Drive, (xv)

the intersection of E Cedar Street, N Rush Street, and N State Street,
(xvi) the intersection of N

Rush Street and E Bellevue Place, (xvii) the intersection of N Rush Street
and E Oak Street, (xviii)

the intersection of N Rush Street and E Walton Place, (xix) the
intersection of Kinzie Street and N

State Street, (xx) the intersection of W Wrightwood Avenue and N Clark
Street, (xxi) the

intersection of N Clark Street and W Wellington Avenue, (xxii) the
intersection of N Clark Street

and N Southport Avenue, (xxiii) the intersection of N Ashland Avenue and W
Berteau Avenue,

(xxiv) the intersection of N Clark Street and W Albion Avenue, and (xxv)
the intersection of N

Clark Street and W North Shore Avenue.

Case: 1:19-cv-06322 Document #: 365 Filed: 05/29/25 Page 15 of 15 PageID
#:11354

Centers for People with Visual Disabilities: (i) The Chicago Lighthouse at
1850 W Roosevelt