What actions did Budget take to address the violations alleged by the Department in the Notice Letter?

• 1. By letter dated April 24, 1996 (the "Notice Letter"), the Department notified Avis that, based on its investigation and the information Avis provided in response to the Department's request, Avis was, in general, providing an acceptable level of service to individuals who use wheelchairs. However, in its letter, the Department also informed Avis that it had concluded that Avis was in violation of certain of the provisions of the ADA cited above relating to (i) the acquisition of accessible shuttle vehicles, (ii) the provision of curbside service to individuals who use wheelchairs, (iii) the existence of architectural barriers that the Department believed should have been removed under Avis' obligation to engage in readily achievable barrier removal, and (iv) the provision of effective communication for individuals who are deaf or hard of hearing. Since that time, Avis and the Department have engaged in negotiations in an effort to resolve this matter without resort to litigation. During this period Avis has taken action to eliminate most of the violations identified by the Department in the Notice Letter by, for example, acquiring and deploying accessible shuttle vehicles and removing architectural barriers at the Detroit Airport and other Avis rental car facilities nationwide.
• 1. The original purpose of this Agreement was to set forth the agreement between the parties regarding the remaining violations at the Detroit Airport. However, in the course of negotiations, Avis determined that it would prefer to enter into a nationwide settlement in order to establish its obligation to acquire, modify, and deploy shuttle vehicles at its' corporately operated airport rental car facilities nationwide (the "Airport Facilities"), whether currently or hereafter operated by Avis. In addition, the parties desire to reach a comprehensive agreement regarding the actions Avis has taken and will take nationwide to establish policies and procedures for providing curb-side service to individuals with mobility impairments and/or those who are deaf or hard of hearing.
• 1. Avis does not admit that it is in violation of any of the provisions of the ADA with respect to the operation of its shuttle services at the Detroit Airport or any of its other Airport Facilities.
• 1. Therefore, in order to avoid further investigation and possible litigation, and in consideration of the mutual promises and covenants contained in this Agreement, the Department and Avis have entered into this Settlement Agreement.

Source: Item 23 — RECEIPTS (FDD pages 80–426)