Defined Terms.
Accessible Pedestrian Signal. A device that communicates information about the pedestrian WALK phase in non-visual format.
Accessible Route. A continuous, unobstructed path that complies with Chapter 4.
Channelizing Island. Curbed or painted area outside the vehicular path that is provided to separate and direct traffic movement, which also may serve as a refuge for pedestrians.
Cross Slope. The slope that is perpendicular to the direction of travel. This is usually called superelevation on curves in the public right-of-way (see superelevation).
Crosswalk. That part of a roadway at an intersection that is included within the extensions of the lateral lines of the sidewalks on opposite sides of the roadway, measured from the curbline or, in the absence of curbs, from the edges of the roadway or, in the absence of a sidewalk on one side of the roadway, the part of the roadway included within the extension of the lateral lines of the sidewalk at right angles to the centerline. Also, any portion of a roadway at an intersection or elsewhere that is distinctly indicated for pedestrian crossing by lines or other markings on the surface.
Curb Line. A line at the face of the curb that marks the transition between the sidewalk and the gutter or roadway.
Curb Ramp. A ramp cutting through a curb or built up to it.
Detectable Warning. A surface feature built in or applied to walking surfaces or other elements to warn of hazards on a circulation path.
Dynamic Envelope. The clearance required for a rail vehicle and its cargo overhang due to any combination of loading, lateral motion, or suspension failure.
Element. An architectural or mechanical component of a building, facility, space, site or public right-of-way.
Facility. All or any portion of buildings, structures, improvements, elements and pedestrian or vehicular routes located on a site or in a public right-of-way.
Grade. (See running slope).
Grade Break. The meeting line of two adjacent surfaces of different slope (grade).
Locator Tone. A repeating sound that identifies the location of the pedestrian push button.
Pedestrian Access Route. An accessible corridor for pedestrian use within the public right-of-way.
Public Right-of-Way. Land or property, usually in a corridor, that is acquired for or devoted to transportation purposes.
Roundabout. A circular intersection that has yield control of entering traffic, channelized approaches, counterclockwise circulation, and appropriate geometric curvature to limit travel speeds on the circulatory roadway.
Running Slope. The slope that is parallel to the direction of travel expressed as a ratio of rise to run. In the public right-of-way, this is usually called grade, and is expressed in percent.
Sidewalk. That portion of a public right-of-way between the curb line or lateral line of a roadway and the adjacent property line that is improved for use by pedestrians.
Splitter Island. A flush or raised island that separates entering and exiting traffic in a roundabout.
Street Furniture. Elements in the public right-of-way that are intended for use by pedestrians.
Superelevation. Cross slope on a curve in the roadway (see cross slope).
Walk Interval. That phase of a traffic signal cycle during which the pedestrian is to begin crossing, typically indicated by a WALK message or the walking person symbol and its audible equivalent.
American Institute of Architects, October 28, 2002
The American Institute of Architects
Introduction
The American Institute of Architects, founded in 1857, is the professional organization for more than 70,000 licensed architects and associated professionals. With headquarters in Washington, D.C., and more than 300 state and local chapters worldwide, the AIA seeks to promote a more humane built environment through education, government advocacy, community redevelopment, and public outreach activities.
As part of its commitment to making the built environment fully accessible for the safe, enjoyable use of everyone, the AIA supports the goal of the Draft Guidelines.General CommentsAccessible Pathways to and through the Built Environment
AIA architects recognize the value of developing a network of accessible pathways to and through the built environment, including those in the public rights-of-way, within a site, and within buildings and facilities. Accessible pedestrian routes, approaches, and entrances are often important aspects of an architect's design of a building or space, and development of a seamless pedestrian path is a desirable goal.Clarity and Certainty
The AIA advocates clear and certain guidance to help ensure compliance with the ADA.
Clearly written, concise guidelines will help ensure that architects understand the requirements of ADAAG and, even more important, will provide them with a high degree of certainty that their designs meet its accessibility standards. The AIA urges the U.S. Architectural and Transportation Barriers Compliance Board (Access Board) to continue to strive for clarity and certainty in the ADAAG.Curb Ramps
The Draft Guidelines are inconsistent in their treatment of curb ramps. In particular, the draft is inconsistent in the way it handles the allowable slopes for parallel curb ramps and perpendicular curb ramps running parallel to street grades. The maximum-length exception for parallel curb ramps is not applied to perpendicular curb ramps. When the direction of street grade is parallel to the curb ramp, however, it should not matter which type of curb ramp is used. Both should be required to have the same maximum required distance. Otherwise, to stay within the maximum slope requirements, a curb ramp would have to be extremely long.Grade of Pedestrian Access Routes
The Draft Guidelines prohibit slopes on pedestrian access routes from exceeding the grade established for the adjacent roadway. However, where parallel or perpendicular curb ramps are installed in line with the direction of sidewalk travel, the curb ramp on the uphill side of a landing at mid-block and the perpendicular curb ramp on the uphill side of an intersecting street will have to exceed the grade of the adjacent street. Exceeding the grade of the street is necessary in order to overcome the difference in elevation from the street to the top of the curb/sidewalk.Changes in Level
The Draft Guidelines address the issue of changes in level in several places. The current ADAAG acknowledges the reality of changes in level, addresses how they should be accomplished, and provides minimum acceptable standards for accessible floor and ground surfaces. In contrast, the Draft Guidelines prohibit changes in level in most areas.
The Draft Guidelines do not permit changes in level along accessible routes more often than every 30 inches
The Draft Guidelines also prohibit changes in level to regulate the unevenness of the surface, although the Access Board has decided this is premature until measurable technical specifications are identified. The discussion says, "this would not rule out the use of bricks or other small pavers, installed in a manner that provides a relatively flush surface and that are properly maintained." This assumption is inaccurate. Particularly in exterior applications, installing unit pavers without a change of level within a 30-inch zone would be almost impossible. The pavers would have to be installed with extreme precision, and the joints would have to be grouted exactly flush with the top of the pavers. In addition, such materials and the supporting substrates are subject to movement due to changes in temperature and moisture content, as well as inherent differences in the materials. It is unrealistic and unreasonable to expect that such a surface could be maintained in a "perfectly" smooth condition.
Vertical changes in level at curb ramps, blended transitions, landings, and gutter areas along pedestrian routes are also prohibited in the Draft Guidelines. This requirement would prohibit the use of any material whose texture had even the smallest groove or crack and would essentially eliminate the use of many materials. Unit pavers, for example, could not be used because they would create tremendous problems in trying to achieve and maintain perfect flatness. Even scored concrete would not be allowed under this requirement, regardless of how narrow the score. Square, metal utility covers measuring less than 30 inches by 30 inches
Whereas the current ADAAG specifies minimum requirements, the Draft Guidelines?by allowing no changes in level and requiring perfectly flat surfaces?up the ante considerably by moving to optimum requirements.Pedestrian Overpasses and Underpasses
The requirements for pedestrian overpasses and underpasses in the Draft Guidelines are linked to the rise of the ramped approach. The vague terms used in the guidelines do not define the "approach" and do not appear to consider the distance over which the approach might span. There are no such limitations on ramp rise in other areas of the built environment. Elevators are expensive to install and maintain in such environments. Moreover, elevators in unsupervised public areas are subject to vandalism and may pose a security threat by providing hiding spaces for criminals. Given these problems, it is unlikely that pedestrian overpasses and underpasses will be built.Conclusion
Accessibility in the public rights-of-way is an important and highly complex subject. It is important that the impact of regulations be completely understood before development of a final rule. It is equally important that requirements be written in clear and concise language in order to achieve the desired accessibility without misinterpretations and misunderstandings.Comments to Specific Text
The following table includes comments to the specific text of the Draft Guidelines.
Draft Guidelines for
Accessible Public Rights-of-Way The American Institute of Architects Comments
1101 Application and Administration
1101.1 General. For the purposes of these requirements, the terms listed in section 1101.3 shall have the indicated meaning.
1101.2 Referenced Standards.
1101.2.1 MUTCD. Copies of the referenced standards may be obtained on-line from the Federal Highway Administration at http://mutcd.fhwa.dot.gov. The reference to where it can be obtained is not necessary in a code. This is good commentary information.
MUTCD 2000-Millennium Edition Manual on Uniform Traffic Control Devices.
1101.3 Defined Terms.
Accessible Pedestrian Signal. A device that communicates information about the pedestrian WALK phase in non-visual format.
Accessible Route. A continuous, unobstructed path that complies with Chapter 4. This definition is superior to the one in the 2 April 02 draft ADAAG.
Channelizing Island. Curbed or painted area outside the vehicular path that is provided to separate and direct traffic movement, which also may serve as a refuge for pedestrians. Delete the last part of the definition?"which also may serve as a refuge for pedestrians." This is clearly not what defines the channelizing island and should be left to commentary.
Cross Slope. The slope that is perpendicular to the direction of travel. This is usually called superelevation on curves in the public right-of-way (see superelevation). The added text about superelevation is advisory and as such unfit for the definition. Recommendation: Place this text in a commentary if there is value in the explanation. Also, see comment under definition of "Superelevation."
Crosswalk. That part of a roadway at an intersection that is included within the extensions of the lateral lines of the sidewalks on opposite sides of the roadway, measured from the curbline or, in the absence of curbs, from the edges of the roadway or, in the absence of a sidewalk on one side of the roadway, the part of the roadway included within the extension of the lateral lines of the sidewalk at right angles to the centerline. Also, any portion of a roadway at an intersection or elsewhere that is distinctly indicated for pedestrian crossing by lines or other markings on the surface. This definition is unnecessarily confusing.
There is no need to introduce a new term, "roadway," when ADAAG already has a defined term "vehicular way."
"Lateral lines of the sidewalk" is not a common term and is confusing. It might be clearer to say the "edges of the sidewalk," if that is what is meant.
It is unclear why the measurement method is given in the definition. This might be pertinent in some technical criteria and, if so, should be included in the technical provisions, not the definition. However, no place was found in this document where the measurement of the crosswalk was needed.
In addition, the measurement method is included in the middle of the definition, breaking the thought of what defines a crosswalk.
The phrase "?within the extension of the lateral lines of the sidewalk at right angles to the centerline" is unclear. Right angles to the centerline of what?
The last sentence is too open-ended. If this is intended to capture mid-block crosswalks, a new definition should be added. If it is intended to capture all marked crosswalks, then it will likely negate the rest of the definition when it is applied in the real world. For example, the intersection could have a meandering marked path across the intersection that is outside the area of the defined crosswalk, and it would qualify under this part of the definition as a crosswalk.
Proposed definition:
Crosswalk: That part of the vehicular way that is included within the projection of the line of the sidewalk edges across the intersection. Where sidewalks occur on both sides of the intersection, the imaginary lines connect the sidewalk edges across the intersection.
Alternate proposal:
Crosswalk: That part of a vehicular way at an intersection that is included within the imaginary lines connecting sidewalk edges across the vehicular way. In the absence of a sidewalk on one side of the roadway, it is the part of the vehicular way that is included in the projection of the line of the sidewalk edges across the intersection.
Curb Line. A line at the face of the curb that marks the transition between the sidewalk and the gutter or roadway. The definition of curb line needs clarification. Is this line the top back of the curb, the top front, or the toe of the curb? Some curb faces are sloped, raising the question of where the curb line falls.
Curb Ramp. A ramp cutting through a curb or built up to it. A transition at a curb that has a running slope of less than 1:20
A curb ramp is a feature that is more commonly understood than a "blended transition," which is not defined. Recommend defining blended transition, at least in commentary.
Detectable Warning. A surface feature built in or applied to walking surfaces or other elements to warn of hazards on a circulation path.
Dynamic Envelope. The clearance required for a rail vehicle and its cargo overhang due to any combination of loading, lateral motion, or suspension failure. The suspension failure is a little perplexing. Isn't that covered under lateral motion? If not, how is it an enforceable part of the guidelines? Does the envelope include the area of trains that have derailed due to suspension failure? If this is not a necessary part of the definition, it is best deleted or moved into commentary.
Element. An architectural or mechanical component of a building, facility, space, site or public right-of-way. See comments at right-of-way.
Facility. All or any portion of buildings, structures, improvements, elements and pedestrian or vehicular routes located on a site or in a public right-of-way. See comments at right-of-way.
Grade. (See running slope). The term "grade" is probably not necessary in this document, but if found to be necessary, consistency of use will be extremely important. If it is necessary, then it should be differentiated from the term "running slope" by definition. Grade is commonly used by industry for sitework and roadwork. So, if it is necessary to use the term, define it as the slope or running slope of the vehicular way, whichever is appropriate. As shown here, it appears to include only the running slope and not the cross slope. It is unclear how that can be, at an intersection where the running slope of two streets cross, but nonetheless, the definition should be separated from "running slope," which is typically used for the sidewalk or pedestrian access route. Another problem with identifying this term with a running slope is the following definition of "grade break," which is not limited to running slope.
In addition, the term should not be used for other purposes in the rule. For example, the term "grade" is used with a completely different meaning in two places?sections 1103.7 and 1103.8.1?in the draft guidelines. Another term should be used here.
Grade Break. The meeting line of two adjacent surfaces of different slope (grade). "Grade" now becomes the same as any slope, not just running slopes. See comments to the definition of "Grade."
Locator Tone. A repeating sound that identifies the location of the pedestrian push button. A message that says "the button is on the other side of the intersection" satisfies this definition, though clearly not the intended result.
Alternative text:
Locator Tone. A repeating sound originating from a location adjacent to the pedestrian push button for purposes of identifying the location of the pedestrian push button.
Pedestrian Access Route. An accessible corridor for pedestrian use within the public right-of-way. The term "corridor" adds unnecessary questions to the definition. Corridors in buildings have space defining walls. Corridors in transportation planning have a definition relating to roadways (as used in the next definition). Recommendation: For clarity, use a more common term such as path, pathway, or route. A term commonly used for the setting will help avoid questions about what is meant.
Recognizing that there has been a huge effort not to use the term "accessible route" in this document, it is still a logical term that simply has different technical criteria in the public right-of-way.
Public Right-of-Way. Land or property, usually in a corridor, that is acquired for or devoted to transportation purposes. ADA in general and ADAAG in particular are rather loose in the use of the word "public." Does this imply that the public owns the underlying property? Or simply has an easement? Alternatively, this could be read to suggest that it is the public who has the right of transportation, or it could be read that he who acquires has the right of transportation. The word "transportation" carries the strong suggestion (almost to the point of being a necessary part of the definition of the word) that something is carried. This tends to exclude pedestrian sidewalks from the definition of public right-of-way.
As written, the definition could include many things that are not intended, such as bicycle paths, skateboard parks, etc.
"Land" is a subset of "property," so why use both words?
The "usually in a corridor" is advisory text unfit for a definition. Many people will not understand the term "corridor" in this context, particularly since the term as used here has a different meaning than the one used in the definition of "Pedestrian Access Route."
This definition could include land that a property owner buys from his neighbor for transporting timber to the highway.
This definition is crucial to scoping the regulation, but without better coordination with the definition of site it will weaken accessibility. The proposed definition describes something that can exist on sites, so using the rule that the specific requirements trump the general requirements, it follows that designers will be permitted to use the weaker requirements of rights-of-way where previously they were required to provide a higher level of accessibility.
Roundabout. A circular intersection that has yield control of entering traffic, channelized approaches, counterclockwise circulation, and appropriate geometric curvature to limit travel speeds on the circulatory roadway.
Running Slope. The slope that is parallel to the direction of travel expressed as a ratio of rise to run. In the public right-of-way, this is usually called grade, and is expressed in percent. Delete the phrase "expressed as a ratio of rise to run" and the second sentence as advisory material inappropriate for a definition.
Again, the term "grade" appears as running slope only. See comments to definitions of "Grade" and "Grade Break."
Sidewalk. That portion of a public right-of-way between the curb line or lateral line of a roadway and the adjacent property line that is improved for use by pedestrians. This is poor code drafting, because the intent of the designer is the triggering condition. If the designer improved the shoulder of the road to make life easier for the snowplow, it is not a sidewalk even though it looks like a sidewalk and its use by pedestrians is tolerated.
In addition, it can be read in two different ways: It can be read to be only the improved portion of that area, or the entire area if any of it is improved. Clarification of this definition is critical to the definition of "Crosswalk," as well as the technical criteria for on-street parking in Section 1109.2 (Exception).
Splitter Island. A flush or raised island that separates entering and exiting traffic in a roundabout.
Street Furniture. Elements in the public right-of-way that are intended for use by pedestrians. This definition might be too broad. There can be many things intended for use by pedestrians that would also be defined as elements, such as pedestrian push buttons and pedestrian overpasses. Yet those are not intended to be covered by the definition of street furniture. It might be best simply to delete the definition.
Superelevation. Cross slope on a curve in the roadway (see cross slope). Delete definition. The term is not used in this document, except in commentary in the definition of the term "Cross Slope." Inclusion of a definition that is not used in the technical requirements is inappropriate.
Walk Interval. That phase of a traffic signal cycle during which the pedestrian is to begin crossing, typically indicated by a WALK message or the walking person symbol and its audible equivalent.
The term "Walk Interval" logically includes the time interval for walking all the way across an intersection, or at least to a refuge island. However, that is not what the definition says. This causes confusion. The definition, coupled with the technical provisions where the term is used, appears to define a specific time to start the walk across the intersection. After that interval it is not safe to start. For the blind this is an important feature of the signal.
Because the term does not indicate the definition, it is confusing. Recommend a new term that is indicative of the definition, such as:
Start Walk Phase: That time interval of a traffic signal cycle . . . etc.
1102 Scoping Requirements
1102.1 General. All areas of newly designed and newly constructed facilities in public rights-of-way and altered portions of existing facilities in public rights-of-way shall comply with Chapter 11. Most newly constructed public rights-of-way are designed and constructed by ADA title III entities, while most alteration projects are conducted by ADA title II entities.
Due to a window between the effective dates for various parts of the original ADAAG through which projects could have avoided ADA compliance, the original ADAAG took the nonsensical position that an addition was some sort of alteration. This window has long since closed, so there is no good reason to continue with that approach.
Additions should be treated as new construction. An addition should not be treated as an alteration, like the approach taken by the current ADAAG 4.1.5.
The form of the charging statements is not consistent with the remainder of ADAAG.
Replace 1102.1 through 1102.2.2 with:
1102.1 General. Rights-of-way shall comply with Chapter 11.
1102.2 Existing Public Rights-of-Way. Additions to existing public rights-of-way shall comply with 1102.2.1. Alterations to existing public rights-of-way shall comply with 1102.2.2. See Comment to 1102.1.
1102.2.1 Additions. Each addition to an existing public right-of-way shall comply with the applicable provisions of Chapter 11. Where the addition connects with existing construction, the connection shall comply with 1102.2.2. See Comment to 1102.1. The only valid piece in this section is the guidance given on how to deal with the interface of new additions to the existing construction.
1102.2.2 Alterations. Where existing elements or spaces in the public right-of-way are altered, each altered element or space shall comply with the applicable provisions of Chapter 11. See Comment to 1102.1.
EXCEPTION: In alterations, where compliance with applicable provisions is technically infeasible, the alteration shall comply to the maximum extent feasible. Delete because the general text at ADAAG 202.3 controls this.
1102.2.2.1 Extent of Application. An alteration of an existing element, space, or area of a public right-of-way shall not impose a requirement for accessibility greater than required for new construction. Delete because the general text at ADAAG 202.3.2 controls this.
1102.2.2.2 Prohibited Reduction in Access. An alteration that decreases or has the effect of decreasing the accessibility of a public right-of-way or site arrival points to buildings or facilities adjacent to the altered portion of the public right-of-way, below the requirements for new construction at the time of the alteration is prohibited. Delete because the general text at ADAAG 202.3.1 controls this.
This is particularly confusing and open-ended. In an alteration, if, in order to make a sidewalk accessible, one would decrease the accessibility of the site arrival point, this section would prohibit that.
However, if by making the same site arrival point accessible will make the sidewalk less accessible than the requirements for new construction, this section would prohibit that as well. This leaves the designers in the position of not being able to meet the rule either way. And someone will be required to make a decision about which is the most important piece of the route to be accessible. For example, it might have to be decided whether the cross slope of the sidewalk becomes too steep or the landing at the building door includes a step.
1102.3 Alternate Circulation Path. An alternate circulation path complying with 1111 shall be provided whenever the existing pedestrian access route is blocked by construction, alteration, maintenance, or other temporary conditions. Delete, because it is an operational issue better contained in the regulations issued by DOJ, DOT, DOD, HUD, GSA, and USPS.
1102.4 Sidewalks. Where sidewalks are provided, they shall contain a continuous pedestrian access route complying with 1103. The pedestrian access route shall connect to elements required to comply with Chapter 11.
1102.5 Protruding Objects. Protruding objects on sidewalks and other pedestrian circulation paths shall comply with 1102.5 and shall not reduce the clear width required for pedestrian accessible routes. Delete all of 1102.5 because ADAAG 204 controls this issue.
1102.5.1 Protrusion Limits. Objects with leading edges more than 27 inches
EXCEPTION: Handrails shall be permitted to protrude 4-1/2 inches
1102.5.2 Post-Mounted Objects. Free-standing objects mounted on posts or pylons shall overhang circulation paths 4 inches
EXCEPTION: This requirement shall not apply to sloping portions of handrails serving stairs and ramps. See above
1102.5.3 Reduced Vertical Clearance. Guardrails or other barriers shall be provided where the vertical clearance is less than 80 inches
EXCEPTION: Door closers and door stops shall be permitted to be 78 inches
1102.6 Curb Ramps and Blended Transitions. A curb ramp or blended transition complying with 1104, or a combination of curb ramps and blended transitions, shall connect the pedestrian access routes to each street crossing within the width of each crosswalk.
1102.7 Pedestrian Signs. Signs for pedestrian use shall comply with 1102.7.
1102.7.1 Bus Route Identification. Bus route identification signs shall comply with 703.5.1 through 703.5.4, and 703.5.7 and 703.5.8. In addition, to the maximum extent practicable, bus route identification signs shall comply with 703.5.5. Bus route identification signs located at bus shelters shall provide raised and Braille characters complying with 703.2, and shall have rounded corners. Delete all material covered elsewhere in ADAAG (e.g., signs are now in 810.4 in
EXCEPTIONS 1: Bus schedules, timetables and maps that are posted at the bus stop or bus shelter shall not be required to comply with 1102.7. Delete?see above.
2: Signs shall not be required to comply with 703.2 where audible signs are user- or proximity-actuated or are remotely transmitted to a portable receiver carried by an individual. Move to 810.4 (Draft ADAAG number)
1102.7.2 Informational Signs and Warning Signs. Informational signs and warning signs shall comply with 703.5. Delete
1102.8 Pedestrian Crossings. Where a pedestrian crossing is provided, it shall comply with the applicable provisions of 1105. Where pedestrian signals are provided at a pedestrian crossing, they shall comply with 1106. "Pedestrian crossings" is an undefined term. How can one know if one is provided? Should define the term and include what is being crossed.
1102.9 Street Furniture. Street furniture that is intended for use by pedestrians and installed on or adjacent to a sidewalk shall comply with 309 and 1107. Delete the phrase "that is intended for use by pedestrians," since this text is part of the definition. The phrase "or adjacent" is problematic because the land adjacent may be outside the right-of-way, thus violating the definition and illegally requiring work on property not under the control of the entity responsible for the right-of-way.
1102.10 Stairs. Where provided, stairs shall comply with 504. Stair treads shall have a 2 inch
1102.11 Handrails. Where provided, handrails shall comply with 505.
1102.12 Vertical Access. Where provided elevators shall comply with 407, limited-use/limited-application elevators shall comply with 408, and platform lifts shall comply with 410. Vertical access shall remain unlocked during the operating hours of the facility served. Delete because ADAAG 407 controls this issue. Delete the hours of service material as better suited to the adopting agency's regulation.
1102.13 Bus Stops. Bus boarding and alighting areas shall comply with 810.2. Bus shelters shall comply with 810.3. Delete
1102.14 On-Street Parking. Where on-street parking is provided, at least one accessible on-street parking space shall be located on each block face and shall comply with 1109. There is no substantiation given for a parking space on every block face. The ratio of the number of accessible parking spaces to the overall number of on-street parking spaces in the area varies with the length of the block face and type of parking. There is no credit given to public off-street parking made available, for example, by a city. There is no exception given for blocks that feature nothing but a parking garage containing a number of accessible parking spaces. Many businesses provide parking garages with accessible spaces for their clients. The requirement to provide an accessible parking space on each block face needs further study.
As stated in earlier comments, most streets are developed by Title III entities for residential areas. It does not seem logical to require accessible on-street parking on each block face for these areas as well. The effects of this requirement and the justification for the numbers need further clarification.
1102.15 Passenger Loading Zones. Where passenger loading zones are provided, they shall connect to a pedestrian access route and shall provide a minimum of one passenger loading zone in every continuous 100 linear feet (30 m) of loading zone space, or fraction thereof, complying with 302, 503.2, 503.3, and 503.5. Delete. This is already covered in ADAAG.
1102.16 Call Boxes. Where provided, call boxes shall comply with 1110.
1103 Pedestrian Access Route
1103.1 General. Pedestrian access routes shall connect to elements required to be accessible and shall comply with 1103. This could be confused as scoping and as requiring pedestrian access routes where pedestrian routes are not planned. This needs to be clarified.
1103.2 Components. Pedestrian access routes shall consist of one or more of the following components: walking surfaces, ramps, curb ramps, blended transitions, crosswalks, pedestrian overpasses and underpasses, elevators, and platform lifts. All components of a pedestrian access route shall comply with the applicable portions of this chapter.
1103.3 Clear Width. The minimum clear width of a pedestrian access route shall be 48 inches
1103.4 Cross Slope. The cross slope of the pedestrian access route shall be 1:48
1103.5 Grade. The grade of the pedestrian access route within a sidewalk shall not exceed the grade established for the adjacent roadway. The grade and the running slope are the same. See comments to definition of "Grade."
See General Comment at the beginning of this paper regarding limitations on pedestrian access routes and how they cannot comply with this at curb ramps.
This requirement is an absolute that precludes making the pedestrian access route more accessible by increasing or decreasing the slope. If the roadway is dead level or negative, there is no reason the slope of the pedestrian access route should not exceed the slope of the roadway.
In addition, the approach to a pedestrian underpass could warrant exceeding the adjacent roadway to accomplish the additional height to take the accessible pedestrian route over something.
EXCEPTION: The running slope of a pedestrian access route shall be permitted to be steeper than the grade of the adjacent roadway, provided that the pedestrian access route is less than 1:20
Consider again the place where most new streets are built: the residential development. Again, if there is reason to have the sidewalk any steeper than the roadway, you will end up with ramps and handrails along the street in front of the houses. Or, more likely, you will not have any sidewalks in the development.
1103.6 Surfaces. The surfaces of the pedestrian access route shall comply with 302.
1103.7 Surface Gaps at Rail Crossings. Where the pedestrian access route crosses rail systems at grade, the horizontal gap at the inner edge of each rail shall be constructed to the minimum dimension necessary to allow passage of railroad car wheel flanges and shall not exceed 2-½ inches (64 mm). The term "grade" is used here in a manner different than the definition. See comments to definition of "Grade."
EXCEPTION: On tracks that carry freight, a maximum horizontal gap of 3 inch
1103.7.1 Detectable Warnings. Where rail systems cross pedestrian facilities that are not shared with vehicular ways, a detectable warning shall be provided in compliance with 1108. This could be read to require detectable warnings at pedestrian overpasses and underpasses.
1103.8 Changes in Level. Changes in level shall comply with 303. Changes in level shall be separated horizontally 30 inches
Note also that even unit pavers that are 30 X 30 inches
EXCEPTION: The horizontal separation requirement shall not apply to detectable warnings. Here is a real conflict in thinking. The guideline states that there can be no changes in level, not even a very narrow scored line in the concrete, yet it mandates changes in level at every curb ramp and intersection of a pedestrian access route and rail crossing with the inclusion of detectable warnings.
1103.8.1 Rail Crossings. Where the pedestrian access route crosses rail systems at grade, the surface of the pedestrian access route shall be level and flush with the top of the rail at the outer edge and between the rails. The term "grade" is used here in a manner different from the definition. See comments to definition of "Grade."
1104 Curb Ramps and Blended Transitions
1104.1 General. Curb ramps and blended transitions shall comply with 1104.
1104.2 Types. Perpendicular curb ramps shall comply with 1104.2.1 and 1104.3; parallel curb ramps shall comply with 1104.2.2 and 1104.3; blended transitions shall comply with 1104.2.3 and 1104.3.
1104.2.1 Perpendicular Curb Ramps. Perpendicular curb ramps shall comply with 1104.2.1, and shall have a running slope that cuts through the curb at right angles or meets the gutter grade break at right angles. A grade break occurs when two slopes meet. A running slope doesn't "meet the grade break" but rather meets the gutter. The meeting of the ramp slope and the gutter slope forms the grade break.
Delete "grade break" in the last sentence.
This section is in direct conflict with1104.3 Common Elements, which prohibits grade breaks in gutter areas.
Note also that "Perpendicular Curb Ramp" is not defined except by these technical criteria. There is no obvious difference to distinguish it from a "parallel curb ramp." See comments to Section 1104.2.2 Parallel Curb Ramps.
1104.2.1.1 Running Slope. The running slope shall be 1:48
There should be an exception for running slopes at mid-block crossings in accordance with the exception at 1104.2.1.3.
1104.2.1.2 Cross Slope. The cross slope shall be 1:48
EXCEPTION: This requirement shall not apply to mid-block crossings.
1104.2.1.3 Landing. A landing 48 inches
EXCEPTION: Running and cross slope requirements shall not apply to mid-block crossings. This exception appears to be misplaced. It appears that there should be a separate exception for running and cross slopes beneath their respective sections.
1104.2.1.4 Flares. Flared sides with a slope of 1:10
1104.2.2 Parallel Curb Ramps. Parallel curb ramps shall comply with 1104.2.2, and shall have a running slope that is in-line with the direction of sidewalk travel.
1104.2.2.1 Running Slope. The running slope shall be 1:48
EXCEPTION: A parallel curb ramp shall not be required to exceed 15 feet
1104.2.2.2 Cross Slope. The cross slope shall be 1:48
1104.2.2.3 Landing. A landing 48 inches
EXCEPTION: Running and cross slope requirements shall not apply to mid-block crossings.
1104.2.2.4 Diverging Sidewalks. Where a parallel curb ramp does not occupy the entire width of a sidewalk, drop-offs at diverging segments shall be protected with a barrier.
1104.2.3 Blended Transitions. Blended transitions shall comply with 1104.3, and shall have running and cross slopes of 1:48
1104.3 Common Elements. Curb ramps and blended transitions shall comply with 1104.3.
1104.3.1 Width. The clear width of landings, blended transitions, and curb ramps, excluding flares, shall be 48 inches
1104.3.2 Detectable Warnings. Detectable warning surfaces complying with 1108 shall be provided, where a curb ramp, landing, or blended transition connects to a crosswalk. There has been much testimony and debate regarding the benefits and necessity of detectable warnings. Before there is a requirement for detectable warnings to be provided in so many places, the Board should be certain that it is not creating a less accessible walking surface for anyone. Some people have to drag their feet when they walk, and this document is riddled with requirements prohibiting level changes for people who use wheelchairs. It is counterintuitive that such opposing requirements are both so important, and yet both are required in the same location within the pedestrian access route.
1104.3.3 Surfaces. Surfaces of curb ramps, blended transitions, and landings shall comply with 302. Gratings, access covers, and other appurtenances shall not be located on curb ramps, landings, blended transitions, and gutter areas within the pedestrian access route.
1104.3.4 Grade Breaks. Grade breaks shall not be permitted on curb ramps, blended transitions, landings, and gutter areas within the pedestrian access route. Surface slopes that meet at grade breaks shall be flush. Another misuse of the term "grade break." The first sentence says that grade breaks are not permitted, and then says that surface slopes that meet at grade breaks must be flush. This is either a conflict or, at best, confusing because it can be read to mean that it is the same area. For example, a grade break is not allowed in a gutter area, which can be considered an area with a surface, which would then be allowed, but regulated by the last sentence. If surface slopes are other than the listed areas, then that term should be defined and addressed in a new section. And if the problem with them is vertical changes in level, then that should be addressed in 1104.3.5. Otherwise the idea of "flush" is unclear in this application.
Another conflict is that grade breaks are not allowed on curb ramps. Built-up curb ramps that have flares will by their nature have grade breaks at the sides where the flare meets the running slope of the ramp. The definition of ramp causes the flare to be considered a ramp, where a pedestrian circulation path crosses the curb ramp, as allowed by 1104.2.1.4.
1104.3.5 Changes in Level. Vertical changes in level shall not be permitted on curb ramps, blended transitions, landings, or gutter areas within the pedestrian access route. How is it that curb ramps and blended transitions are not allowed to have even the slightest vertical changes in level, but are required to have detectable warnings, which by definition consist of a bunch of level changes. This is counterintuitive.
1104.3.6 Counter Slopes. The counter slope of the gutter area or street at the foot of a curb ramp or blended transition shall be 1:20
This is a conflict.
1104.3.7 Clear Space. Beyond the curb line, a clear space of 48 inches
A clear space of 48 inches
Also, it is unclear what the "parallel" vehicle travel lane is. Parallel to what?
1105 Pedestrian Crossings "Pedestrian crossings" is an undefined term.
1105.1 General. Pedestrian crossings shall comply with 1105. "Pedestrian crossings" is an undefined term.
1105.2 Crosswalks. Crosswalks shall comply with 1105.2.
1105.2.1 Width. Marked crosswalks shall be 96 inches
1105.2.2 Cross Slope. The cross slope shall be 1:48
The requirement for a crosswalk to have a minimal cross slope will increase the width of every intersection in sloping terrain, because of the need to create this tabletop effect.
EXCEPTION: This requirement shall not apply to mid-block crossings. If it is acceptable to have a cross slope at the mid-block crossing, why not at the intersection? The establishment of crosswalks at mid-block seems to have different requirements because of their effect on vehicular traffic safety. This certainly needs to be a consideration at intersections as well.
1105.2.3 Running Slope. The running slope shall be 1:20
As this tabletop and running slope limitation continues for intersection after intersection up a hill or mountain, it will require that the hill or mountain be removed to a large degree. Otherwise, at some point, the natural slope will depart from the street grade, separating the adjacent sites from the sidewalk/street by a vertical barrier.
1105.3 Pedestrian Signal Phase Timing. All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
What effect will longer crossing times?and the concomitant increases in engine idling time and vehicle trip times?have on clean air requirements?
1105.4 Medians and Pedestrian Refuge Islands. Medians and pedestrian refuge islands in crosswalks shall comply with 1105.4 and shall be cut through level with the street or have curb ramps complying with 1104 and shall contain a pedestrian access route complying with 1103. Where the cut-through connects to the street, edges of the cut-through shall be aligned with the direction of the crosswalk for a length of 24 inches
1105.4.1 Length. Where signal timing is inadequate for full crossing of all traffic lanes or where the crossing is not signalized, cut-through medians and pedestrian refuge islands shall be 72 inches
1105.4.2 Detectable Warnings. Medians and refuge islands shall have detectable warnings complying with 1108. Detectable warnings at cut-through islands shall be separated by a 24 inch
EXCEPTION: Detectable warnings shall not be required on cut-through islands where the crossing is controlled by signals and is timed for full crossing.
1105.5 Pedestrian Overpasses and Underpasses. Pedestrian overpasses and underpasses shall comply with 1105.5.
1105.5.1 Pedestrian Access Route. Pedestrian overpasses and underpasses shall contain a pedestrian access route complying with 1103.
1105.5.2 Running Slope. The running slope shall not exceed 1:20
1105.5.3 Approach. Where the approach exceeds 1:20
1105.5.4 Stairs. Stairs shall comply with 504. For buildings, the only stairs that are required by ADAAG 210 to comply with 504 are those used in the accessible means of egress. If an accessible pedestrian route is provided by ramps or elevators, it does not seem that the stairs in these locations should be required to meet 504.
1105.5.5 Escalators. Escalators shall comply with 810.9.
1105.6 Roundabouts. Where pedestrian crosswalks and pedestrian facilities are provided at roundabouts, they shall comply with 1105.6.
1105.6.1 Separation. Continuous barriers shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited. Where railings are used, they shall have a bottom rail 15 inches
1105.6.2 Signals. A pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the crosswalk, including the splitter island. Signals shall clearly identify which crosswalk segment the signal serves.
1105.7 Turn Lanes at Intersections. Where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island. Crosswalk is a defined term that seems to indicate that there is a crosswalk at every intersection that has a sidewalk on any part of the intersection. That definition does not mention the use by pedestrians. The term "pedestrian crosswalk" is not defined. See earlier comment about the term "pedestrian crossing."
It is unclear whether this is for crossing the slip lane or for crossings that parallel the direction of the slip lane.
1106 Accessible Pedestrian Signal Systems
1106.1 General. Pedestrian signal systems shall comply with 1106.
1106.2 Pedestrian Signal Devices. Each crosswalk with pedestrian signal indication shall have a signal device which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device and shall comply with 1106.3.
1106.2.1 Location. Pedestrian signal devices shall be located 60 inches
The control face must face the intersection, so people standing in front of it will have their backs to the intersection. With the face of the device facing the intersection, it is unclear how it will also be parallel to the direction of the crosswalk it serves.
Ten feet from other signal devices seems like a lot when the right-of-way might not be that wide.
EXCEPTION: The minimum distance from other signal devices shall not apply to signal devices located in medians and islands.
1106.2.2 Reach and Clear Floor or Ground Space. Pedestrian signal devices shall comply with 308. A clear floor or ground space complying with 305 shall be provided at the signal device and shall connect to or overlap the pedestrian access route.
1106.2.3 Audible Walk Indication. The audible indication of the WALK interval shall be by voice or tone.
1106.2.3.1 Tones. Tones shall consist of multiple frequencies with a dominant component at 880 Hz. The duration of the tone shall be 0.15 seconds
1106.2.3.2 Volume. Tone or voice volume measured at 36 inches
1106.3 Pedestrian Pushbuttons. Pedestrian pushbuttons shall comply with 1106.3.
1106.3.1 Operation. Pedestrian pushbuttons shall comply with 309.4.
1106.3.2 Locator Tone. Pedestrian pushbuttons shall incorporate a locator tone at the pushbutton. Locator tone volume measured at 36 inches
1106.3.3 Size and Contrast. Pedestrian pushbuttons shall be a minimum of 2 inches
1106.3.4 Optional Features. An extended button press shall be permitted to activate additional features. Buttons that provide additional features shall be marked with three Braille dots forming an equilateral triangle in the center of the pushbutton.
1106.4 Directional Information and Signs. Pedestrian signal devices shall provide tactile and visual signs on the face of the device or its housing or mounting indicating crosswalk direction and the name of the street containing the crosswalk served by the pedestrian signal.
1106.4.1 Arrow. Signs shall include a tactile arrow aligned parallel to the crosswalk direction. The arrow shall be raised 1/32 inch
1106.4.2 Street Name. Signs shall include street name information aligned parallel to the crosswalk direction and complying with 703.2. With all of the requirements for push buttons, arrows, signs, and street names, as well as distances from other devices, the area at the intersection could become cluttered with items that will possibly block the view of motorists, a safety problem that could jeopardize pedestrians as well as motorists. Consideration should be made for the clutter that might occur.
1106.4.3 Crosswalk Configuration. Where provided, graphic indication of crosswalk configuration shall be tactile and shall comply with 703.5.1.
1107 Street Furniture
1107.1 General. Street furniture shall comply with 1107.
1107.2 Clear Floor or Ground Space. Street furniture shall have clear floor or ground space complying with 305 and shall be connected to the pedestrian access route. The clear floor or ground space shall overlap the pedestrian access route 12 inches
1107.3 Drinking Fountains. Where drinking fountains are provided, they shall comply with 602.
1107.4 Public Telephones. Where public telephones are provided, they shall comply with 1107.4.
1107.4.1 Single Telephone. Where a single public telephone is provided, it shall comply with 704.2 and 704.4
1107.4.2 Multiple Telephones. Where a bank of public telephones is provided, at least one telephone shall comply with 704.2, and at least one additional telephone shall comply with 704.4.
1107.4.3 Volume Controls. All public telephones shall provide volume controls complying with 704.3.
1107.5 Public Toilet Facilities. Permanent or portable public toilet facilities shall comply with 603. At least one fixture of each type provided shall comply with 604 through 610. Operable parts, dispensers, receptacles, or other equipment shall comply with 309.
EXCEPTION: Where multiple single-user toilet facilities are clustered at a single location, at least 5 percent, but no fewer than one single-user toilet at each cluster shall comply with 603 and shall be identified by the International Symbol of Accessibility complying with 703.7.2.1.
1107.6 Tables, Counters, and Benches. Tables, counters, and benches shall comply with 1107.6.
1107.6.1 Tables. Where tables are provided in a single location, at least 5 percent but no fewer than one, shall comply with 902.
1107.6.2 Counters. Where provided, counters shall comply with 904. It is unclear where counters might occur in a public right-of-way. The guidelines should not attempt to address temporary vendor operations, but only the permanent street furniture.
1107.6.3 Benches. Where benches without tables are provided at a single location, at least 50 percent, but no fewer than one, shall comply with 903 and shall have an armrest on at least one end. It is unclear why 50% of the benches should comply with the provisions of 903. Also, there is no reason given in the discussion why an armrest is required on 50% of the benches in the public right-of-way, when these have not been and are not required in ADAAG.
1108 Detectable Warning Surfaces
1108.1 General. Detectable warnings shall consist of a surface of truncated domes aligned in a square grid pattern and shall comply with 1108. Delete because this material is covered elsewhere in ADAAG.
Note also that the requirement that the domes be on a square grid is nearly meaningless. A square grid can be applied over the domes at an angle and they would meet the provision. A square grid can be applied over the domes with only certain domes hitting on the grid and, because the grid is moved over the domes, the other domes meet the grid. Some domes might be aligned by a square grid of one size and the other domes aligned to a different size square grid.
1108.1.1 Dome Size. Truncated domes in a detectable warning surface shall have a base diameter of 0.9 inches
1108.1.2 Dome Spacing. Truncated domes in a detectable warning surface shall have a center-to-center spacing of 1.6 inches
1108.1.3 Contrast. Detectable warning surfaces shall contrast visually with adjacent walking surfaces either light-on-dark, or dark-on-light. Delete because this material is covered elsewhere in ADAAG.
1108.1.4 Size. Detectable warning surfaces shall extend 24 inches
1108.2 Location.
1108.2.1 Curb Ramps and Blended Transitions. The detectable warning surface shall be located so that the edge nearest the curb line is 6 inches
1108.2.2 Rail Crossings. The detectable warning surface shall be located so that the edge nearest the rail crossing is 6 inches
1108.2.3 Platform Edges. Detectable warning surfaces at platform boarding edges shall be 24 inches
1109 On-Street Parking
1109.1 General. Car and van on-street parking spaces shall comply with 1109.
1109.2 Parallel Parking Spaces. An access aisle at least 60 inches
EXCEPTION: An access aisle is not required where the width of the sidewalk between the extension of the normal curb and boundary of the public right-of-way is less than 14 feet
1109.3 Perpendicular or Angled Parking Spaces. Where perpendicular or angled parking is provided, an access aisle 96 inches
1109.4 Curb Ramps or Blended Transition. A curb ramp or blended transition complying with 1104 shall connect the access aisle to the pedestrian access route. This will likely result in a curb ramp cutting into the sidewalk, which will require additional right-of-way space.
1109.5 Obstructions. There shall be no obstructions on the sidewalk adjacent to and for the full length of the space. This does not make sense for perpendicular or angled parking (i.e., the parking space is not parallel to the sidewalk, and the access aisle is connected to the pedestrian access route).
EXCEPTION: This provision shall not apply to parking signs complying with 1109.6 and parking meters complying with 1109.7.2. If the obstructions are a problem for the parallel parked cars, why wouldn't the signs and parking meters be obstructions?
1109.6 Signs. Parking spaces shall be designated as reserved by a sign complying with 502.6. Signs shall be located at the head or foot of the parking space so as not to interfere with the operation of a side lift or a passenger side transfer. Delete "so as not to interfere with the operation of a side lift or a passenger side transfer." This is commentary.
1109.7 Parking Meters. Where parking meters are provided, they shall comply with 1109.7.
1109.7.1 Operable Parts. Operable parts shall comply with 309.
1109.7.2 Location. A parking meter shall be located at the head or foot of the parking space so as not to interfere with the operation of a side lift or a passenger side transfer. Delete "so as not to interfere with the operation of a side lift or a passenger side transfer." This is commentary.
EXCEPTION: Where parking meters are not provided at the space, but payment for parking in the space is included in a centralized collection box or paying station, the space shall be connected to the centralized collection point with a pedestrian access route.
1109.7.3 Displays and Information. Displays and information shall be visible from a point located 40 inches
1110 Call Boxes
1110.1 General. Call boxes shall comply with 1110.
1110.2 Operable Parts. Operable parts shall comply with 308 and 309.4. Where provided, labeling shall comply with 703.2 and 703.3.
EXCEPTION: Mechanically operated systems in which the signal is initiated by a lever pull shall be permitted to have an activating force of 12 lbf
1110.3 Turning Space. A turning space complying with 304 shall be provided at the controls. Most of these devices will be located in remote areas along a highway. An accessible pedestrian route to the device is not likely to be there. Why require a turning space? Why not a simple pull-in and back-out clear floor space?
1110.4 Edge Protection. Edge protection complying with 405.9.2 shall be provided where the area at the call box is adjacent to an abrupt level change. "Adjacent to an abrupt level change" needs to be clarified. An abrupt level change is a compliant ¼-inch vertical change in level. An abrupt change in level can also mean a rock wall in front of the area. An abrupt change in level can also be the curb that is provided for edge protection. If it means a substantial drop off, then say that.
In addition, what is meant by "the area at the call box is adjacent"? This gives no guidance as to what is under consideration. The turning space required at 1110.3 probably is the area of concern.
1110.5 Motor Vehicle Turnouts. Where provided, a motor vehicle turnout shall have a minimum paved area of 16 feet
1110.6 Two-Way Communication. Where provided, two-way voice communication shall comply with 1110.6, 708.2 and 708.3. The only two-way communications systems within right-of-ways appear to be pay phones and duress call boxes. Does this mean that every pay phone in the right-of-way must have a TTY? Most duress call boxes do not support free-form communication for those who hear, so why is a TTY necessary?
1110.6.1 Volume Controls. Volume controls complying with 704.3 shall be provided.
1110.6.2 TTY. A TTY complying with 704.4 shall be provided.
1111 Alternate Circulation Path Please note that circulation paths are not regulated for running or cross slopes, so this section greatly lowers the level of accessibility that must be provided.
1111.1 General. Alternate circulation paths shall comply with 1111.
1111.2 Width. The alternate circulation path shall have a width of 36 inches
1111.3 Location. The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street. Why on the same side of the street? If the disruption that triggered a need for an alternate circulation path is the replacement of the old sidewalk, why force the city to lose a travel lane?
1111.4 Protection. The alternate circulation path shall comply with 307 and shall be protected with a barricade complying with 1111.6 to separate the pedestrian access route and alternate circulation path from any adjacent construction, drop-offs, openings, or other hazards. Delete reference to 307, because all circulation paths are already obliged to follow 307. Delete the phrase "pedestrian access route," because this section concerns alternate circulation paths. Justify the requirement that barricades be provided at drop-offs adjacent to alternate circulation paths when regular circulation paths are not similarly regulated.
Further, as worded this will require barricades along all curbs, thereby forcing parkers to walk in traffic until they reach an intersection before they can join the sidewalk.
1111.5 Signs. Signs complying with 703.5 shall be provided at both the near side and the far side of the intersection preceding a disrupted pedestrian access route. The "near side and the far side of the intersection" is confusing. Where is that? Could it be said as "both sides of the intersection, preceding, and on the same side of the street as a disrupted pedestrian access route"?
1111.6 Barricades. Barricades shall be continuous, stable, and non-flexible and shall consist of a solid wall or fence or a Type II or Type III barricade as specified in MUTCD section 6F-60 with the bottom or lower rail 1-1/2 inches
Brant Williams, P.E., October 28, 2002
Comments of the Draft Guidelines
Portland Office of Transportation
Brant Williams, P.E.
Director
1101 Application and Administration
1102 Scoping Requirements
1102.1 General. All areas of newly designed and newly constructed facilities in public rights-of-way and altered portions of existing facilities in public rights-of-way shall comply with Chapter 11.
1102.2 Existing Public Rights-of-Way. Additions to existing public rights-of-way shall comply with 1102.2.1. Alterations to existing public rights-of-way shall comply with 1102.2.2.
1102.2.1 Additions. Each addition to an existing public right-of-way shall comply with the applicable provisions of Chapter 11. Where the addition connects with existing construction, the connection shall comply with 1102.2.2.
PDOT COMMENT: Recommend that this term be deleted because it does not add any clarity to the draft regulation. Keep just two terms in this section: NEW CONSTRUCTION and ALTERATIONS.
1102.2.2 Alterations. Where existing elements or spaces in the public right-of-way are altered, each altered element or space shall comply with the applicable provisions of Chapter 11.
EXCEPTION: In alterations, where compliance with applicable provisions is technically infeasible, the alteration shall comply to the maximum extent feasible.
PDOT COMMENT: Both "technically infeasible" and "maximum extent feasible" need to be clearly stated in 1101.3 Defined Terms.
1102.5 Protruding Objects. Protruding objects on sidewalks and other pedestrian circulation paths shall comply with 1102.5 and shall not reduce the clear width required for pedestrian accessible routes.
PDOT COMMENT: The end phrase of the above sentence should be corrected to read " ... pedestrian access routes."
1102.5.2 Post-Mounted Objects. Free-standing objects mounted on posts or pylons shall overhang circulation paths 4 inches
PDOT COMMENTS: The proposed standard for a 4 inch
The second sentence is not clear in its application. We assume that the Board means that where signs have multiple posts or pylons that are spaced more that 12 inches
Some agencies utilize a vertical sign structure consisting of vertical, horizontal, and diagonal elements that are attached together to form a truss or frame. Signs can be mounted from the walking surface to the top of the structure. If this vertical sign structure is detectable, it should not be a problem for blind travelers.
EXCEPTION: This requirement shall not apply to sloping portions of handrails serving stairs and ramps.
1102.14 On-Street Parking. Where on-street parking is provided, at least one accessible on-street parking space shall be located on each block face and shall comply with 1109.
PDOT COMMENTS: This requirement means that at least one accessible on-street parking space be provided on every single newly constructed block face. This requirement is problematic for several reasons. First, using the measurement of "block face" as its basis will result in an inconsistent application of this requirement. The City of Portland typical block face is 200 feet
Secondly, given the small block sizes in Portland, the number of accessible parking spaces compared to the total number of spaces on the block face is excessive. Best case scenario in our downtown, we can provide 9 on-street parking spaces per block face. However, on average, this number is significantly less due to driveways, loading zones, curb extensions at corners, etc. The average is more likely to be around 6 spaces per block. Providing one accessible space for every 6 on-street spaces is again excessive. We would recommend that this rule be consistent with the requirements for private parking areas; i.e. a similar proportion of accessible on-street spaces to the total number of on-street spaces for both off-street and on-street parking areas.
Thirdly, as it reads, this rule includes all residential streets as well as other classifications of streets. This appears to be an oversight in writing the draft guidelines.
And lastly, the original Section 14 and the recommendations of PROWAAC limit this requirement to central business districts of cities. We recommend that this requirement be revised to include the provisions identified both in Section 14 and the PROWAAC report.
1103 Pedestrian Access Route
1103.8 Changes in Level. Changes in level shall comply with 303. Changes in level shall be separated horizontally 30 inches
PDOT COMMENT: This proposed standard needs to be more clearly defined in its application. Consider changing the term "changes in slope" because all surfaces in the public right-of-way are actually built on sloping surfaces. Very rarely in the outdoor environment would one encounter a truly "level" situation.
We assume that the Board is attempting to regulate the frequency of slope changes or "grade breaks" ( a more common term ) in the longitudinal Pedestrian Access Route.
EXCEPTION: The horizontal separation requirement shall not apply to detectable warnings.
1104 Curb Ramps and Blended Transitions
1104.1 General. Curb ramps and blended transitions shall comply with 1104.
1104.2 Types. Perpendicular curb ramps shall comply with 1104.2.1 and 1104.3; parallel curb ramps shall comply with 1104.2.2 and 1104.3; blended transitions shall comply with 1104.2.3 and 1104.3.
1104.2.1 Perpendicular Curb Ramps. Perpendicular curb ramps shall comply with 1104.2.1, and shall have a running slope that cuts through the curb at right angles or meets the gutter grade break at right angles.
PDOT COMMENTS: PROWAAC spend countless hours with the issue of directionality and it was discussed in 2 pages of the report to the Board. It was not fully resolved because the needs of the wheelchair users and blind travelers were at odds. The question that could not be resolved was as follows:
1. Should a perpendicular ramp be aligned with the direction of travel and benefit the blind and sighted travelers and create a potential problem for wheelchair users. OR
2. Should a perpendicular ramp be aligned at a right angle to the radius of a corner to the benefit of wheelchair users and lose a directionality for blind travelers.
There are many arguments for both cases depending upon which group is being viewed as receiving preferential treatment. The draft regulation gives preference to wheelchair users and has the following undesirable impacts:
. Ramp alignment at a right angle to the radius forces the ramp to be skewed from the direction of travel
. Blind travelers lose directionality that could have been provided if the ramp were aligned in the true direction of travel. [ We continuously receive comments from members of our blind community that ramps should be build to align with the straight direction of travel. ]
. Sighted travelers lose the benefit of the ramp and will encounter a portion of the curb on the ramp flare if they chose to travel in a straight line. This creates a tripping hazard for both sighted and low vision pedestrians.
. Ramp alignment on the radius creates a very complicated design and an extreme construction challenge and contributes significantly to the design and construction cost of each ramp.
. Ramp alignment on the radius calls for shifting the ramp a few feet left or right of the true direction of travel. This realignment does not improve cross-slope and warping problems. Most ramps will have some warping between the level landing and the street gutter because the outdoor environment is rarely level.
. Ramp alignment on the radius has a poor architectural appearance and violates "form" without contributing to improved "function."
. Wheelchair users need to take an out of direction travel path upon leaving the landing to proceed down the ramp and enter the crosswalk. They then need to make another direction change to align with the crosswalk direction of travel. This path of travel resembles an "S."
. Persons with limited mobility skills that tend to shuffle as they travel, will need to follow an "S" path of travel to utilize the benefit of a curb ramp and avoid the vertical rise of the curb in the flare section of a ramp when it is aligned on the axis of the radius
We feel that the Access Board should abandon the right angle with radius alignment requirement or better yet, support the ramps being aligned with the direction of travel. The very worst thing that could happen is that wheelchair users would make the smaller "S" path of travel as they proceeded down the ramp to allow the wheelchair to align the front caster wheels at a right angle with the street gutter. All other users, blind, low vision, persons with limited mobility skills, and sighted pedestrian would benefit from the ramp being aligned with the direction of travel.
1104.2.1.4 Flares. Flared sides with a slope of 1:10
PDOT COMMENT: The term slope is erroneous because in infers that one of the components is dead level. This does not happen in the public right-of-way because unlike the building environment where dead level is common, it rarely happens in the street area. PROWAAC discussed this issue extensively and came to the conclusion that the curbed portion of the flare needed to transition from the curb ramp base [ zero curb exposure ] to the top of the full curb [typically 6 inch
This provision can be rewritten as follows: "Curb ramp flares adjacent to curb ramps that are provided where a circulation path crosses the curb ramp, shall have the curb exposure, as measured along the gutterline, rise from zero-exposure at the ramp to full curb exposure on a ratio of 1 foot
1104.2.2 Parallel Curb Ramps. Parallel curb ramps shall comply with 1104.2.2, and shall have a running slope that is in-line with the direction of sidewalk travel.
1104.2.2.4 Diverging Sidewalks. Where a parallel curb ramp does not occupy the entire width of a sidewalk, drop-offs at diverging segments shall be protected with a barrier.
PDOT COMMENT: It would be far better to not allow this type of curb ramp design at intersections rather than require a continuous barrier. Since "barrier" is not defined, we will assume that it means a fence, handrail, roadway guardrail, raised landscape planter, or any other type of acceptable barrier. A schematic drawing would be helpful to understand this parallel ramp concept.
At a typical corner where a parallel ramp is used, this regulation would essentially divide the pedestrian area in half running parallel to the curb as it curves around a corner. Persons wanting to cross at the intersection must make a decision on the approach to the corner to chose the "low road" to the ramp or the "high road" to stay on the sidewalk and avoid the crossing. Those persons choosing to cross at the intersection must utilize the parallel curb ramp to reach the crosswalk. This means that all "crossers", disabled or not, will need to descend the ramp to the crosswalk.
The divided sidewalk will certainly cause problems for blind travelers because if they miss the parallel ramp, they could not reach the crosswalk because of the barrier. Likewise, if the blind traveler did not want to cross the street, the barrier could divert them down to street level at the crosswalk where they did not want to go.
This design is also unsafe in that it removes any means of escape for pedestrians in the event a vehicle cuts too close to the ramp. Without the barrier, pedestrians that recognize the danger of an approaching errant vehicle could move to the back of the sidewalk to avoid being injured. With the barrier, the pedestrian could not move out of harm's way. In fact, they would be trapped between the oncoming errant vehicle and the barrier.
In tangent areas, where isolated parallel ramps are the best design solution, such as access to an on-street disabled parking space from sidewalk level, it could be beneficial to utilize a barrier. There certainly other examples where a barrier would be helpful. However, the Access Board must answer the question: What persons are you attempting to protect? Blind persons using long canes will likely find the ramp and the adjacent curb and not be in danger. Sighted persons, including mobility device users, will see the ramp and the adjacent sidewalk. So who really needs the barrier? The fall into the parallel curb ramp would be the same as a fall from the curb at sidewalk level to the adjacent street level. But the Board is not recommending barriers between sidewalk level and street level.
1104.2.3 Blended Transitions. Blended transitions shall comply with 1104.3, and shall have running and cross slopes of 1:48
PDOT COMMENT: As we understand a blended transition, it is simply a large landing that runs parallel to the curb radius. This landing more resembles the landing used on a parallel curb ramp, only that is probably larger and is not necessarily served by a parallel ramp. It more typically models the street surface extended into the corner pedestrian area with a drainage slope pitched to the street.
Because of the running and cross slope limitations, this blended transitions could only fit if the street gutter grade were 2% or flatter. Further, because of drainage issues, this type of landing would rarely be used. This blended transition would afford little protection to pedestrians because it is level with the roadway and excludes barrier curbs.
We question why the Board would offer this as an accessibility improvement when it has so many limiting and detrimental characteristics.
1104.3 Common Elements. Curb ramps and blended transitions shall comply with 1104.3.
1104.3.4 Grade Breaks. Grade breaks shall not be permitted on curb ramps, blended transitions, landings, and gutter areas within the pedestrian access route. Surface slopes that meet at grade breaks shall be flush.
PDOT COMMENT: The PROWAAC report specifically recommended that where a curb ramp meets the street surface at the gutter, the two sloping surfaces must be flush so that there is not a vertical "lip" on the curb ramp. This may be implied in either 1104.3.4 or in 1104.3.5, but it is not clearly stated.
1104.3.7 Clear Space. Beyond the curb line, a clear space of 48 inches
PDOT COMMENT: We understand that this requirement will provide a 4' X 4' refuge area on the street pavement beyond the curb ramp where a pedestrian would not be struck by parallel traveling vehicles and bicycles. However, geometrically, this will not always work. Take the case of a small corner radius of 10' and a sidewalk built adjacent to the curb. A parallel ramp design is the only possible alternative. The bottom landing of the curb ramp is centered on the diagonal of the radius. It is then mathematically impossible to create the refuge area on the pavement and be wholly outside the parallel vehicle travel lane.
Since a parallel curb ramp already has a level landing / refuge within the sidewalk and adjacent to the street, we suggest that the clear space requirement be removed for all parallel curb ramps. If this condition is not removed, the Board will have automatically excluded parallel curb ramps at corners with a radius of less than 15'.
1105 Pedestrian Crossings
1105.1 General. Pedestrian crossings shall comply with 1105.
1105.2 Crosswalks. Crosswalks shall comply with 1105.2.
1105.2.1 Width. Marked crosswalks shall be 96 inches
1105.2.2 Cross Slope. The cross slope shall be 1:48
PDOT COMMENTS: This one sentence provision potentially has more impact that any other part of Chapter 11. Without directly stating it, this regulation will require that all future intersections be essentially flat. Construction of flat intersections and steep intersection approaches and departures are technically infeasible, extremely expensive, environmentally unsound, and are in conflict with safe roadway design.
The outdoor environment, all formed at the whim of Mother Nature, cannot be made to conform to the indoor environment that man builds. In Portland, as well as many other cities across this nation, we build streets with centerline grades that range from 0.5% to as much as 22%. We do this to make the developable land with the confines of our urban growth boundary available for its highest and best use. The Tualatin Mountains, within our city limits, rises more than 1000 feet
Even if the excessive cost factors were ignored and construction to meet these standards were attempted, the environmental damage would be staggering. To create a tabled or flat intersection in hilly terrain, calls for major excavations into uphill slopes and massive fill sections on downhill slopes. The combined work for a single intersection could involve the clear cutting of all vegetation and earth disturbances on at least 2 acres [ 87,120 square feet ] of land to create one intersection. The resultant "flat intersection" would have street slopes far steeper that if the roadway were build to conform to the natural grade of the existing terrain. Disabled persons could certainly be able to use the intersection but would not be able to get to the intersection or leave it because the roadway / sidewalk slopes would be too steep.
Flat intersection design requires the use of long vertical curves to smooth out longitudinal grade breaks. These curves are a function of the roadway speed, safe stopping sight distance, and roadway running slopes. The length of smoothing out one intersection will exceed the distance to the next intersection. This means that the next intersection must be moved farther away to make the running grades work with the flat intersections. In some cases, this flat intersection requirement has the effect of eliminating subdivisions on steep terrain because the land area cannot be reformed to fit the platting of lots and blocks because "accessible" intersections cannot be designed.
Roadway designers must take into consideration multiple variables that affect the safe usability of the facilities. These variables include, but are not limited to: horizontal alignment, vertical alignment, safe stopping sight distance, existing terrain, environment, design speeds, maximum grades, critical length of grades, and many others. Roadway alignments with numerous breaks because of successive intersections is poor design. Although it may be beneficial to reduce grades at intersections, attempting to make them "flat", is flawed design. The Green Book points out that "? the gradeline of the major highway should be carried through the intersection, and that of the crossroad should be adjusted to it. This design requires transition of the crown of the minor highway to an inclined cross section at its junction with the major highway." In other words, even on local streets, one street follows the natural gradeline downhill, and intersecting streets are warped to fit.
EXCEPTION: This requirement shall not apply to mid-block crossings.
1105.3 Pedestrian Signal Phase Timing. All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
PDOT Comment: This requirement could have severe consequences regarding the timing of signals, vehicular delays, overall congestion, and pollution levels.
In Portland, an intersection that is 60 ft
Complaints regarding traffic congestion are common in urban areas such as Portland. The reduction in the pedestrian crossing rate used to calculate the timing of traffic signals would undoubtedly result in increased congestion, and longer delays.
A couple of other unintended consequences of the slower crossing speed could include shorter "Walk" intervals (the "Walk" phase being shortened to help absorb the longer "Flashing Don't Walk phase), and pedestrian pushbuttons where none currently exist (to avoid serving the ped phase when no pedestrians are present). Pedestrians who push the pedestrian button and then proceed to cross the street when an adequate gap occurs are often long gone by the time the pedestrian phase is served. Providing shorter walk times at locations where pedestrians may be tempted to cross against the signal indication can help to reduce unnecessary delay to motorists.
We often hear complaints that the pedestrian crossing time is too short from pedestrians who do not understand the meaning of the pedestrian signal indications. Most pedestrians are more comfortable with the pedestrian signal timing after they are educated on the meaning of the signal indications. Most complaints are regarding the short "Walk" phases. Few people complain about the "Flashing Don't Walk" clearance intervals.
One other consequence of lengthened flashing don't walk intervals will be increased non-compliance by the majority of pedestrians. Today we already have a severe problem with pedestrians disregarding the pedestrian signals. Using the 3 fps rate for the flashing don't walk lengths will generate crossing intervals that can be easily met by over 95% of the population. Users will see this exceeding long length as unnecessary and pay even less attention to pedestrian signals.
It is our recommendation that the policy be modified to allow agencies to implement pedestrian crossing times based off of local knowledge using crossing speeds ranging from 3.0 fps for a disabled person to 4.0 fps for an average pedestrian. The City of Portland has already made accommodations for slower than average and disabled pedestrians at several signalized intersections, and would prefer to work directly with these groups to identify problem locations where pedestrian needs could be better met. This would allow us to balance the needs of ALL users of the ROW to maximize the safety and efficiency of the signal for all users.
1105.4 Medians and Pedestrian Refuge Islands. Medians and pedestrian refuge islands in crosswalks shall comply with 1105.4 and shall be cut through level with the street or have curb ramps complying with 1104 and shall contain a pedestrian access route complying with 1103. Where the cut-through connects to the street, edges of the cut-through shall be aligned with the direction of the crosswalk for a length of 24 inches
1105.4.1 Length. Where signal timing is inadequate for full crossing of all traffic lanes or where the crossing is not signalized, cut-through medians and pedestrian refuge islands shall be 72 inches
PDOT COMMENT: The meaning of this regulation is not clear and should be revised to say: "Where pedestrians are expected to wait because signal timing is inadequate for full crossing of the traffic lanes or where the crossing is not signalized and a pedestrian must wait for gaps in the vehicle traffic flow, a refuge area, 72 inches
1105.5 Pedestrian Overpasses and Underpasses. Pedestrian overpasses and underpasses shall comply with 1105.5.
PDOT COMMENT: This condition is not entirely clear to most readers. There are a number of situations that need to be evaluated before specific regulations can be set. Otherwise, the Access Board is attempting to force fit one solution to fit all situations. A sampling of common overpass / underpass situations is as follows:
. At-grade intersections where pedestrians are routed over a bridge structure. These are built in to provide pedestrian only access over a busy arterial street. A good example is the intersection of the Las Vegas Boulevard [ the Strip ] and Tropicana Boulevard in Las Vegas, NV. Four separate bridge structures exist to safely route pedestrians between the various casinos at this very busy street intersection. All have escalators and elevators.
. At-grade intersections where pedestrians are routed under the roadway through an underpass or tunnel. Portland used to have several of these pedestrian only tunnels beneath busy arterial streets. However, most have been closed because pedestrians felt unsafe using these isolated facilities.
. Grade separated intersections where one street is on a bridge structure and the other roadway or pedestrian route is below the bridge. In some situations, pedestrian connections are made using pedestrian stairways between the two levels. An example of this type of route exists in downtown San Antonio, TX along the "Riverwalk" where the San Antonio River frontage includes a pedestrian route.
. Grade separated intersections where one street is in a tunnel beneath the surface street. Again, in some situations where both streets have pedestrian sidewalks, the two levels may be connected with pedestrian stairways.
. Pedestrian only connections using stairways between roadways at different levels. These usually occur in areas with steep terrain. These stairways usually create a non-accessible "shortcut" to avoid a longer, more circuitous route on surface sidewalks.
. Pedestrian only connections that are made beneath or over multiple roadway bridge structures. These more resemble "catwalk" type bridges connected under or over larger bridges. These occasionally occur where a pedestrian route crosses a complex freeway interchange that includes multiple roadway bridges at different levels.
. Pedestrian only bridge structures over water, canyons, railroad facilities, and other obstacles.
. There are other possible combinations of roadways and pedestrian routes not discussed.
The Board needs to clearly define the conditions where elevators and escalators are needed. Consideration must be given to the purpose of the pedestrian route and a variety of other factors. Clearly, the pedestrian bridges in Las Vegas that carry thousands of daily pedestrian trips that avoid conflict with traffic volumes exceeding 50,000 cars per day should have both escalators and elevators. However, pedestrian stairways between streets in steep terrain, that carry less that 25 pedestrian trips per day, should not warrant the need for an elevator.
1105.5.3 Approach. Where the approach exceeds 1:20
PDOT COMMENT: This is a very broadly written requirement that requires the installation of elevators if the ramps at overpasses or underpasses exceed 60 inch
It appears that the Access Board is setting a requirement for the public right-of-way that does not exist for buildings. Elevators are being required in the outdoor environment when they are NOT REQUIRED in the indoor environment.
Elevators in buildings are the obvious mode of choice because they are build in a space that is typically secure and environmentally controlled. Elevators are the most cost efficient means to move persons between different levels. The benefit of an elevator in an interior space typically outweighs the cost of construction and maintenance. However, this is not the case for elevators in an outdoor environment.
Elevators in the public right-of-way are subject to multiple adverse conditions. These adverse conditions can easily affect the working parts of this type of machine and cause them to fail. Excessive heat or cold can damage or destroy hydraulic systems. Precipitation, in the form of rain, ice, or snow can stop moving parts with rust or ice seizure. Dust and debris in the outdoor environment can also stop moving parts from moving. Exterior elevators cannot always be secured and are subject to damage by vandalism, which in turn causes failures.
Interior elevators simple attach to the interior structure of the building. Exterior elevators are considerably more expensive because they need their own exterior structural support system.
We request that the Board reconsider this proposed requirement. The public right-of-way is not a square or rectangular space that is confined by exterior building walls. It is a longitudinal or linear space that affords public agencies the ability to make accessible connections using sidewalks and ramps. Public works agencies should be given the option to choose different options that provide accessible connections. Ramps and sidewalks could be used where space is available. Elevators and escalators could be used where space is severely constrained.
1105.6 Roundabouts. Where pedestrian crosswalks and pedestrian facilities are provided at roundabouts, they shall comply with 1105.6.
1105.6.1 Separation. Continuous barriers shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited. Where railings are used, they shall have a bottom rail 15 inches
PDOT COMMENTS: Continuous barriers need to be defined here or in section 1101.3 Defined Terms. Continuous barriers should include, and not be limited to: landscape buffers that do not contain a walkable surface as defined by 302.1, fences, pedestrian railings, and vehicular guardrails.
No guidance is provided regarding the boundary for where a roundabout intersection begins or ends and thus a barrier begins or ends. The nature of a roundabout intersection is similar to a curved section of roadway or a mid-block crossing. The requirement of a street-side barrier at a roundabout intersection to separate vision impaired pedestrians from the roadway seems arbitrary. The logical extension of such need for barrier would be to install barriers at the edge of every sidewalk which is adjacent to a street. No substantive argument or evidence has been provided that distinguishes a modern roundabout pedestrian crossing as inherently less safe than any other mid-block crossing design or intersection treatment, and thus warranting such barrier. Location of the pedestrian crossing can be accomplished with a depressed landing adjacent to the ramp that directs pedestrians into the marked crossing.
1105.6.2 Signals. A pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the crosswalk, including the splitter island. Signals shall clearly identify which crosswalk segment the signal serves.
PDOT COMMENT: The guideline appears to apply to all sizes and types of roundabouts with pedestrian facilities regardless of the level of auto or pedestrian traffic use. As roundabouts have so many different applications, with a similar variety of pedestrian environments, a single protocol without regard to traffic volume or the number of entry or exit lanes a pedestrian is expected to cross will unduly limit the modern roundabout's application due to the cost of this guideline. This would be unfortunate as modern roundabouts have a clear record of reducing total crashes and crash severity as compared to standard signalized traffic control. We suggest that the Board conduct additional research into the methods used in Australia and Europe, where modern roundabouts are used at high pedestrian use locations with regular frequency.
The guideline singles out the modern roundabout intersection control geometry without a clear argument or evidence of a safety need. The logical extension of this guideline is the need for pedestrian actuated signals at all intersections, regardless of traffic volume.
Signalizing each approach to a roundabout could also have several negative consequences including increased congestion, queues extending into the roundabout, rear-end accidents, and increased costs. Adding signals to each approach of a roundabout could easily add over $150,000 to the cost of the roundabout installation, not counting added annual maintenance and operation costs.
1105.7 Turn Lanes at Intersections. Where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island.
PDOT COMMENTS: The correct term for "slip lanes", as used by the AASHTO Policy on Geometric Design of Highways and Streets [ the Green Book ], is auxiliary lanes.
For right turn auxiliary lanes, traffic is not always controlled with signals. Below are some of the methods currently used in this application:
. Signal control of through traffic lanes and signal control of the auxiliary right turn lane.
. Signal control of the through lanes and "yield" control of the turn lane.
. Signal control of the through lanes and "stop" control of the turn lane.
. Stop control of the through lanes and "yield" control of the turn lane.
. No control of the through lanes and no control of the turn lane.
. Other combinations are possible.
The proposed regulation requires a pedestrian traffic signal for all situations without considering the variety of variables involved. The Board needs to study this further before setting a requirement that one solution fits all applications.
1106 Accessible Pedestrian Signal Systems
1106.1 General. Pedestrian signal systems shall comply with 1106.
1106.2 Pedestrian Signal Devices. Each crosswalk with pedestrian signal indication shall have a signal device which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device and shall comply with 1106.3.
PDOT COMMENTS: We do not believe that every signalized crosswalk with pedestrian signals needs to have accessible signals as well. In downtown Portland we have numerous small, yet closely spaced signalized intersections. Many of the crossing distances are less than 30 feet
That said, we also agree that many of our signalized intersections do need accessible signals. We just ask that the Board add language to allow exceptions where accessible signals would not be required. Wording for this exception could read something like the following: "An accessible signal may not be required if an engineering study shows that visually impaired pedestrians using skills taught by orientation and mobility specialists can easily use the crosswalk in question. Factors for not needing an accessible signal may include short crossing distances, simple signal phasing, other clear audible queues, and simple intersection geometrics. The engineering study must provide compelling reasons for not installing an accessible pedestrian signal."
1106.4 Directional Information and Signs. Pedestrian signal devices shall provide tactile and visual signs on the face of the device or its housing or mounting indicating crosswalk direction and the name of the street containing the crosswalk served by the pedestrian signal.
1106.4.2 Street Name. Signs shall include street name information aligned parallel to the crosswalk direction and complying with 703.2.
PDOT COMMENT: We strongly object to this requirement in that it is inconsistent with other requirements. Street name signs are not required at any other type of intersection. Use of a traffic signal at certain intersections to give traffic flow specific timed intervals of having the right-of-way is still only a form of traffic control. Stop controlled or yield controlled intersections are not much different, yet tactile signs for pedestrians are not required. If the Board wants to provide guidance information for blind travelers, then all intersections should have tactile signs that identify the street names.
1107 Street Furniture
1108 Detectable Warning Surfaces
PDOT COMMENTS: After spending $20,000 to test products, make over 100 installations, and conduct opinion surveys with more than 40 blind persons, we are not convinced that requiring detectable warnings at all curb ramps is good public policy.
Our findings indicate that blind persons could not depend upon the detectable warnings even if every ramp included them. Blind travelers use so many other cues to travel that detectable warning would only provide minor benefit. Most of the persons that we worked with were reasonably well trained and travel quite well without detectable warnings. The opinions of our blind public pertaining to detectable warnings are not any different than the comments received by the Board in response to the proposed draft guidelines. Many liked them, many did not.
From a cost perspective, installation of detectable warnings will be a very expensive endeavor. We found that it would cost between $25 - $30 per square foot of detectable warning surface. A single ramp installation would be at least $200. A typical intersection with 8 individual ramps will cost $1,600. Portland alone has 15,000 intersections. Over time we will spend $24 million (in equivalent 2002 dollars) to complete all of the detectable warning installations in Portland. The national investment in this effort will certainly exceed $10 Billion.
Based upon the input of our blind citizens, we support the discretionary application of detectable warnings only at certain locations. These locations include:
. On perpendicular curb ramps that have grades (slopes) flatter that 5%
. In advance of all active railroad tracks that cross the pedestrian access route of a sidewalk area
. At all other areas where the pedestrian sidewalk area is not clearly delineated from the roadway by curbs or other channelizing barriers.
We also found that detectable warnings were almost useless on all diagonal curb ramps and most ramps that were not aligned directly in-line with the direction of travel. Our blind traveling public seldom strayed off-course to even find diagonal curb ramps. Other types of ramps with radial alignments were easily found by long cane users as they detecting a curb on the flare of the ramp. None of our blind travelers wanted to waste their time searching for the detectable warning surface in these locations.
The Access Board needs to give greater consideration to this issue. It is very clear that some locations should have detectable warning. Most other locations do not need them. Portland would rather utilize members of our blind community to evaluate all questionable locations and would follow their guidance on whether detectable warnings should be installed or not. We feel that this would be a better alternative that having the nation needlessly spend billions of dollars for detectable warnings that provide no benefit to the users.
1108.2 Location.
1108.2.1 Curb Ramps and Blended Transitions. The detectable warning surface shall be located so that the edge nearest the curb line is 6 inches
PDOT COMMENT: Alignment of the detectable warnings is not discussed. Detectable warnings need have the square grid pattern aligned with the direction of travel.
On ramps that intersect the street surface on a radius, the detectable warning surface should also be correctly aligned for pedestrian travel but should not be required to exactly follow the radius of corner. Companies manufacture detectable warning products to meet the square grid pattern. These products cannot be installed to meet a horizontal curved area. An exception needs to be noted and a graphic provided.
1109 On-Street Parking
1110 Call Boxes
1111 Alternate Circulation Path
1111.1 General. Alternate circulation paths shall comply with 1111.
1111.2 Width. The alternate circulation path shall have a width of 36 inches
1111.3 Location. The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street.
PDOT COMMENTS: It is very shortsighted for the Access Board to decide that one alternative circulation path on the same side of the street will fit all situations. There are a variety of work zones in pedestrian areas that we encounter daily. Most could not accommodate a same side of street alternate circulation path. Sidewalk work zone examples include, but are not limited to:
1. Complete demolition and full reconstruction of roadways including the removal of all existing vehicular travel lanes, bike paths, furnishing zones, and sidewalks. All travelers are detoured to parallel alternate streets.
2. Similar to #1 above, but only half of the street width is being demolished and reconstructed at one time. All travelers are detoured to the opposite side of the street or to parallel streets.
3. Utility connections from the street to a building. This work zone crosses vehicle travel lanes, bike lane, furnishing zone, and sidewalk. The safety of all public users prevents access to the work zone. Users are shifted to the opposite side of the street.
4. Intersection closures for street paving. All users are detoured to parallel open streets.
5. Installation of curb ramps or new sidewalk facilities the prevent the public from using these facilities until the concrete has sufficiently cured.
6. New building construction which utilizes the full sidewalk width and portions of the street area. Pedestrians and vehicles are either moved to the opposite side of the street or detoured to parallel open streets.
We suggest that this condition be amended to read: "1111.3 Location. An alternate circulation path shall be provided to the disrupted pedestrian access route, on the same side of the street, on the opposite side of the street, or on a parallel street with a marked detour route.
Victor M. Mendez, P.E., October 21, 2002
Arizona Department of Transportation
Intermodal Transportation Division
RE: COMMENTS ON AMERICANS WITH DISABILITIES ACT DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY
Dear Mr. Windley:
The Arizona Department of Transportation (ADOT) has reviewed the Americans With Disabilities Draft Guidelines for Accessible Rights-of-Way published on 17 Jun 2002. ADOT endorses the Board's aim of ensuring that access for persons with disabilities is provided wherever a pedestrian way is newly built or altered, and that the same degree of convenience, connection, and safety afforded the public generally be available to pedestrians with disabilities.
Noting our endorsement of the Board's aim, we have taken the time to comment on each of the sections and sub sections to the draft guidelines in hope of assisting in the rulemaking process. The comments are enclosed for consideration by the Architectural and Transportation Barriers Compliance Board. We understand that the Board will review all the comments submitted prior to continuing with the proposed rulemaking.
Please contact Kenneth Cooper at [...] if you or the Board have any questions or if you wish to discuss the comments.
Sincerely yours,
Victor M. Mendez, P.E.
Director
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COMMENTS FROM ARIZONA DEPARTMENT OF TRANSPORTATION
AMERICANS WITH DISABILITIES ACT
DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY
PUBLISHED JUNE 17, 2002
General Comments:
A. The Arizona Department of Transportation (ADOT) supports the position expressed in the Introduction to the Draft Guidelines for Accessible Public Rights-of-Way that, "The guidelines do not require alterations or retrofits to existing public rights-of-way, but would apply where a pedestrian route or facility is altered as part of a planned project to improve existing public rights-of-way.";
B. ADOT recommends the inclusion of graphics to help clarify and explain the guidelines; and
C. ADOT strongly recommends that maximum crosswalk, landing, and ramp slopes be redefined to take into account the grade of the adjacent facility. It may be technically infeasible and poor engineering practice to provide running and/or cross slopes of 1:48
Sec. 1101 Application and Administration
Sec. 1101.1 General: For the purposes of these requirements, the terms listed in section 1101.3 shall have the indicated meaning.
ADOT has "No comment" on this section.
Sec. 1101.2 Referenced Standards
Recommend that the following manuals also be included by reference into the guidelines as they provide nationally accepted guidance regarding the design of roadways and pedestrian facilities:
A. American Association of State Highway and Transportation Officials (AASHTO), A Policy on Geometric Design of Highways and Streets 2001;
B. AASHTO, Roadside Design Guide 2002; and
C. Federal Highway Administration, Highway Design Handbook For Older Drivers and Pedestrians 2001.
Sec. 11012.1 MUTCD: Copies of the referenced standards may be obtained on-line from the Federal Highway Administration at http://mutcd.fhwa.dot.gov. MUTCD 2000-Millennium Edition Manual on Uniform Traffic Control Devices.
The Arizona Department of Transportation (ADOT) supports the inclusion of the Manual on Uniform Traffic Control Devices (MUTCD) into the guidelines by reference.
Sec. 1101.3 Defined Terms:
ADOT requests a definition be added that clarifies where slope maximum and minimum values are provided, "maximum" and "minimum" refer to the steepness of the slope.
Accessible Pedestrian Signal. A device that communicates information about the pedestrian WALK phase in non-visual format.
Accessible Route. A continuous, unobstructed path that complies with Chapter 4.
Channelizing Island. Curbed or painted area outside the vehicular path that is provided to separate and direct traffic movement, which also may serve as a refuge for pedestrians.
Cross Slope. The slope that is perpendicular to the direction of travel.
This is usually called superelevation on curves in the public right-of-way (see superelevation).
ADOT requests clarification of this definition as the second sentence is not wholly correct. Curves in the public right-of-way may have a normal crown and not be superelevated. Superelevation usually occurs, but not exclusively, in rural settings and where the prevailing speed is greater than 35 miles per hour.
Crosswalk. That part of a roadway at an intersection that is included within the extensions of the lateral lines of the sidewalks on opposite sides of the roadway, measured from the curbline or, in the absence of curbs, from the edges of the roadway or, in the absence of a sidewalk on one side of the roadway, the part of the roadway included within the extension of the lateral lines of the sidewalk at right angles to the centerline. Also, any portion of a roadway at an intersection or elsewhere that is distinctly indicated for pedestrian crossing by lines or other markings on the surface.
ADOT requests clarification of this definition as it appears to conflict with the requirements for crosswalk width as detailed in Sec. 1105.2.1 Width since existing sidewalks are often less than ninety-six inches (96-in) in width. Sidewalks location is quite variable in relation to the curb line while the location of the crosswalk should be established beyond the stop bar, if present, and stop bar location is a function of the radius of the intersection. Therefore, ADOT recommends that the location of the crosswalk not be defined in relation to the sidewalk location.
Curb Line. A line at the face of the curb that marks the transition between the sidewalk and the gutter or roadway.
Curb Ramp. A ramp cutting through a curb or built up to it.
Detectable Warning. A surface feature built in or applied to walking surfaces or other elements to warn of hazards on a circulation path. Dynamic Envelope. The clearance required for a rail vehicle and its cargo overhang due to any combination of loading, lateral motion, or suspension failure.
Element. An architectural or mechanical component of a building, facility, space, site or public right-of-way.
Facility. All or any portion of buildings, structures, improvements, elements and pedestrian or vehicular routes located on a site or in a public right-of-way.
Grade. (See running slope).
Grade Break. The meeting line of two adjacent surfaces of different slope (grade).
Locator Tone. A repeating sound that identifies the location of the pedestrian push button.
Pedestrian Access Route. An accessible corridor for pedestrian use within the public right-of-way.
Public Right-of-Way. Land or property, usually in a corridor, that is acquired for or devoted to transportation purposes.
ADOT recommends adding the phrase "and under the jurisdiction of a public agency." As written, the definition could also define parking lots or private transportation facilities such as found in gated communities.
Roundabout. A circular intersection that has yield control of entering traffic, channelized approaches, counterclockwise circulation, and appropriate geometric curvature to limit travel speeds on the circulatory roadway.
Running Slope. The slope that is parallel to the direction of travel expressed as a ratio of rise to run. In the public right-of-way, this is usually called grade, and is expressed in percent.
Sidewalk. That portion of a public right-of-way between the curb line or lateral line of a roadway and the adjacent property line that is improved for use by pedestrians.
Recommend replacing the word "lateral" with "edge" and the term "adjacent property" with "right-of-way".
Splitter Island. A flush or raised island that separates entering and exiting traffic in a roundabout.
Street Furniture. Elements in the public right-of-way that are intended for use by pedestrians.
Superelevation. Cross slope on a curie in the roadway (see cross slope).
Recommend deletion of this term.
Walk Interval. That phase of a traffic signal cycle during which the pedestrian is to begin crossing, typically indicated by a WALK message or the walking person symbol and its audible equivalent.
Sec. 1102 Scoping Requirements
Sec. 1102.1 General: All areas of newly designed and newly constructed facilities in public rights- of-way and altered portions of existing facilities in public rights-of-way shall comply with Chapter 11.
ADOT supports the position that the new guidelines apply to areas of newly designed and constructed facilities in public rights-of-way and requires provision of sidewalks, street crossings, street furniture, parking, or other pedestrian elements only where they are provided as part of construction or improvement projects. ADOT supports clarification of the guideline explicitly stating that pavement-surface treatment projects such as seal coats, friction-course overlays, and mill-and-replace projects not be considered as construction or improvements triggering compliance with these guidelines.
Sec. 1102.2 Existing Public Rights-of-Way. Additions to existing public rights-of-way shall comply with 1102.2.1. Alterations to existing public rights-of-way shall comply with 1102.2.2.
Sec. 1102.2.1 Additions: Each addition to an existing public right-of-way shall comply with the applicable provisions of Chapter 11. Where the addition connects with existing construction, the connection shall comply with 1102.2.2.
ADOT has "No comment" on this section.
Sec. 1102.2.2 Alterations: Where existing elements or spaces in the public right-of-way are altered, each altered element or space shall comply with the applicable provisions of Chapter 11.
EXCEPTION: In alterations, where compliance with applicable provisions is technically infeasible, the alteration shall comply to the maximum extent feasible.
ADOT supports the position that the guidelines apply to alterations to existing facilities only in relation to the scope of the project. We think the term "technically infeasible" should be expanded to clearly include consideration of site conditions and topography. We also support the position that lack of existing public right-of-way may be a sufficient reason to prevent the widening of sidewalks and would like to see language in the guideline relieving agencies of any obligation to purchase additional right-of-way. ADOT could support sidewalk widening through the use of no-cost, dedicated pedestrian easements over private land. ADOT also supports the position that new facilities should smoothly transition into older ones.
Sec. 1102.2.2.1 Extent of Application: An alteration of an existing element, space, or area of a public right-of-way shall not impose a requirement for accessibility greater than required for new construction.
ADOT supports the position that an alteration of an existing area of a public right-of-way shall not impose a requirement for accessibility greater than required for new construction.
Sec. 1102.2.2.2 Prohibited Reduction in Access. An alteration that decreases or has the effect of decreasing the accessibility of a public right-of-way or site arrival points to buildings or facilities adjacent to the altered portion of the public right-of-way, below the requirements for new construction at the time of the alteration is prohibited.
ADOT supports the position that an alteration shall not decrease the accessibility of a public right-of-way below the requirement for new construction at the time of the alteration.
Sec. 1102.3 Alternate Circulation Path: An alternate circulation path complying with 1111 shall be provided whenever the existing pedestrian access route is blocked by construction, alteration, maintenance, or other temporary conditions.
ADOT strongly opposes adoption of this section as written. The current language could require the construction of an alternative circulation path for situations such as the short-term maintenance of the sidewalk or adjacent road. See Section 1111 Alternate Circulation Path for further comments. Compliance would present an unacceptable burden upon the State and local jurisdictions, and the motoring public without a commensurate benefit to pedestrians.
Sec. 1102.4 Sidewalks: Where sidewalks are provided, they shall contain a continuous pedestrian access route complying with 1103. The pedestrian access route shall connect to elements required to comply with Chapter 11.
ADOT supports the position that where sidewalk is provided it should contain a continuous pedestrian access route (PAR) connecting to elements required to comply with Chapter 11.
Sec. 1102.5 Protruding Objects: Protruding objects on sidewalks and other pedestrian circulation paths shall comply with 1102.5 and shall not reduce the clear width required for pedestrian accessible routes.
ADOT has "No comment" on this section.
Sec. 1102.5.1 Protrusion Limits. Objects with leading edges more than 27 inches
EXCEPTION: Handrails shall be permitted to protrude 4-1/2 inches
ADOT has "No comment" on this section.
Sec. 1102.5.2 Post-Mounted Objects: Free-standing objects mounted on posts or pylons shall overhang circulation paths 4 inches
EXCEPTION: This requirement shall not apply to sloping portions of handrails serving stairs and ramps.
ADOT requests clarification of this guideline in the form of a graphic representation. It appears that the last sentence contradicts guidance given in the first sentence by allowing the lowest edge of a sign to be mounted at 27 inches
Sec. 1102.5.3 Reduced Vertical Clearance: Guardrails or other barriers shall be provided where the vertical clearance is less than 80 inches
EXCEPTION: Door closers and door stops shall be permitted to be 78 inches
ADOT requests clarification of this proposed guideline. Does the term "guardrail" refer to vehicular w-beam or thrie beam, or is it a pedestrian-type barrier? Regardless of the definition, we are concerned that guardrail installed at twenty-seven inches (27 in), adjacent to the PAR, could constitute a tripping hazard for the visually impaired.
Sec. 1102.6 Curbs and Blended Transitions: A curb ramp or blended transition complying with 1104, or a combination of curb ramps and blended transitions, shall connect the pedestrian access routes to each street crossing within the width of each crosswalk
ADOT supports the proposed guideline requiring that curb ramps be placed in-line with the crosswalk they serve; curb cuts at the mid-point of the curb radius will normally not be allowed. This may effectively double the number, and cost, of curb ramps required on construction projects, but the total cost of such ramps is minimal in terms of the larger project. We note however that sound engineering judgment may dictate the use of only one ramp at a particular intersection due to site geometry and conditions.
Sec. 1102.7 Pedestrian Signs: Signs for pedestrian use shall comply with 1102.7.
ADOT supports the proposed guideline as written. It reiterates guidance given in the MUTCD.
Sec. 1102.7.1 Bus Route Identification: Bus route identification signs shall comply with 703.5.1 through 703.5.4, and 703.5.7 and 703.5.8. In addition, to the maximum extent practicable, bus route identification signs shall comply with 703.5.5. Bus route identification signs located at bus shelters shall provide raised and Braille characters complying with 703.2, and shall have rounded corners.
EXCEPTIONS.
1. Bus schedules, timetables and maps that are posted at the bus stop or bus shelter shall not be required to comply with 1102.7.
2: Signs shall not be required to comply with 703.2 where audible signs are user- or proximity-actuated or are remotely transmitted to a portable receiver carried by an individual. (Sec. 703 Signs can be found on the Access Board website at http://www. access-board.gov/ada-aba/htm l/tech-0 7. html).
ADOT has "No comment" on this section.
Sec. 1102.7.2 Informational Signs and Warning Signs: Informational signs and warning signs shall comply with 703.5.
ADOT has "No comment" on this section.
Sec. 1102.8 Pedestrian Crossings: Where a pedestrian crossing is provided, it shall comply with the applicable provisions of 1105. Where pedestrian signals are provided at a pedestrian crossing, they shall comply with 1106.
ADOT strongly opposes this guideline. See Sec. 1105 Pedestrian Crossings for further comment.
Sec. 1102.9 Street Furniture: Street furniture that is intended for use by pedestrians and installed on or adjacent to a sidewalk shall comply with 309 and 1107. (Sec. 309 Operable Parts can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-03.html)
ADOT has "No comment" on this section.
Sec. 1102.10 Stairs: Where provided, stairs shall comply with 504. Stair treads shall have a 2 inch
ADOT has "No comment" on this section.
Sec. 1102.11 Handrails: Where provided, handrails shall comply with 505. (Sec. 505 Handrails can be found on the Access Board website at http.//www.access-board.gov/ada-aba.html/tech-05.hmtl)
ADOT has "No comment" on this section.
Sec. 1102.12 Vertical Access: Where provided elevators shall comply with 407, limited use/limited-application elevators shall comply with 408, and platform lifts shall comply with 410. Vertical access shall remain unlocked during the operating hours of the facility served (Sections 407, 408 & 410 can be found on the Access Board website at http://www. access-board.gov/ada-aba/html/tech-04.hmtl)
ADOT has "No comment" on this section.
Sec. 1102.13 Bus Stops. Bus boarding and alighting areas shall comply with 810.2. Bus shelters shall comply with 810.3. (Sections 810.2 & 810.3 can be found on the Access Board website at http://www. access-board.gov/ada-aba/html/tech-08.html)
ADOT has "No comment" on this section.
Sec. 1102.14 On-Street Parking: Where on-street parking is provided, at least one accessible on-street parking space shall be located on each block face and shall comply with 1109.
ADOT strongly opposes this guideline. See Sec. 1109 On-Street Parking for further comments.
Sec. 1102.15 Passenger Loading Zones: Where passenger loading zones are provided, they shall connect to a pedestrian access route and shall provide a minimum of one passenger loading zone in every continuous 100 linear feet (30 m) of loading zone space, or fraction thereof complying with 302, 503.2, 503.3, and 503.5.
ADOT has "No comment" on this section.
Sec. 1102.16 Call Boxes: Where provided, call boxes shall comply with 1110.
See Sec. 1110 Call Boxes for comments.
Sec. 1103 Pedestrian Access Route
Sec. 1103.1 General: Pedestrian access routes shall connect to elements required to be accessible and shall comply with 1103.
ADOT supports the proposed guideline as written.
Sec. 1103.2 Components: Pedestrian access routes shall consist of one or more of the following components: walking surfaces, ramps, curb ramps, blended transitions, crosswalks, pedestrian overpasses and underpasses, elevators, and platform h/is. All components of a pedestrian access route shall comply with the applicable portions of this chapter.
ADOT has "No comment" on this section.
Sec. 1103.3 Clear Width: The minimum clear width of a pedestrian access route shall be 48 inches
ADOT supports the proposed guideline as written.
Sec. 1103.4 Cross Slopes: The cross slope of the pedestrian access route shall be 1:48
ADOT supports the goal of the proposed guideline, but requests clarification of how the term "technically infeasible" will be applied to pedestrian access routes in areas with greater than a two percent (2%) grade.
Sec. 1103.5 Grade: The grade of the pedestrian access route within a sidewalk shall not exceed the grade established for the adjacent roadway.
EXCEPTION: The running slope of a pedestrian access route shall be permitted to be steeper than the grade of the adjacent roadway, provided that the pedestrian access route is less than 1:20
ADOT cannot support the proposed guideline because the exception requires the maximum running slope of the PAR to be less than 1:20
Sec. 1103.6 Surfaces: The surfaces of the pedestrian access route shall comply with 302. (Sec. 302 Floor or Ground Surfaces can be found on the Access Board website at http://www. access- board.gov/ada-aba/htm l/tech-03.hmtl).
ADOT supports the proposed guideline as written.
Sec. 1103.7 Surface Gaps at Rail Crossings.' Where the pedestrian access route crosses rail systems at grade, the horizontal gap at the inner edge of each rail shall be constructed to the minimum dimension necessary to allow passage of railroad car wheel flanges and shall not exceed 2-'/2 inches
EXCEPTION: On tracks that carry freight, a maximum horizontal gap of 3 inch
ADOT has "No comment" on this section.
Sec. 1103.7.1 Detectable Warnings: Where rail systems cross pedestrian facilities that are not shared with vehicular ways, a detectable warning shall be provided in compliance with 1108.
ADOT supports the proposed guideline as written.
Sec. 1103.8 Changes in Level.' Changes in level shall comply with 303. Changes in level shall be separated horizontally 30 inches
ADOT requests clarification of this guideline. What is meant by "Changes in level shall be separated horizontally 30 inches
Sec. 1103.8.1 Rail Crossings.' Where the pedestrian access route crosses rail systems at grade, the surface of the pedestrian access route shall be level and flush with the top of the rail at the outer edge and between the rails.
ADOT supports the proposed guideline as written.
Sec. 1104 Curb Ramps and Blended Transitions
Sec. 1104.1 General.' Curb ramps and blended transitions shall comply with 1104.
ADOT has "No comment" on this section.
Sec. 1104.2 Types: Perpendicular curb ramps shall comply with 1104.2.1 and 1104.3; parallel curb ramps shall comply with 1104.2.2 and 1104.3; blended transitions shall comply with 1104.2.3 and 1104.3.
ADOT cannot support this section because it does not include provision for curb ramps that are in-line with a crosswalk, but neither perpendicular nor parallel. Good engineering practice may include design and construction of non-perpendicular and non-parallel curb ramps.
Sec. 1104.2.1 Perpendicular Curb Ramps: Perpendicular curb ramps shall comply with 1104.2.1, and shall have a running slope that cuts through the curb at right angles or meets the gutter grade break at right angles.
ADOT supports this guideline as written.
Sec. 1104.2.1.1 Running Slope: The running slope shall be 1:48
ADOT cannot support this guideline as written because it ignores the possibility of site-specific conditions which could result in running slopes greater than 1:12
Sec. 1104.2.1.2 Cross Slope: The cross slope shall be 1:48
EXCEPTION: This requirement shall not apply to mid-block crossings.
ADOT cannot support this guideline and requests that the guideline be reworded to allow the cross slope to match the existing roadway grade. The proposed guideline has an unanticipated and unacceptable consequence when a curb ramp is provided on a facility with greater than a 1:48
Sec. 1104.2.1.3 Landing: A landing 48 inches
EXCEPTION: Running and cross slope requirements shall not apply to mid-block crossings.
ADOT supports the requirement for a minimum of a 48-inch by 48-inch landing at the top of the curb ramp. However, we cannot support the guideline language for maximum running and cross slopes of 1:48
Sec. 1104.2.1.4 Flares: Flared sides with a slope of 1:10
ADOT cannot support the proposed guideline as written because it ignores site-specific conditions that might require a flare slope of greater than 1:10
Sec. 1104.2.2 Parallel Curb Ramps: Parallel curb ramps shall comply with 1104.2.2, and shall have a running slope that is in-line with the direction of sidewalk travel.
ADOT supports this guideline.
Sec. 1104.2.2.1 Running Slope: The running slope shall be 1:48
EXCEPTION: A parallel curb ramp shall not be required to exceed 15 fret (4570 mm) in length.
ADOT cannot support this guideline as written as it would require extensive engineering and construction efforts in areas where the sidewalk and PAR were adjacent to a roadway with a grade greater than eight and one-third percent (8.33%). We do support a maximum ramp length of fifteen feet (15 ft).
Sec. 1104.2.2.2 Cross Slope: The cross slope shall be 1:48
ADOT cannot support this guideline as written as it ignores site-specific conditions that could result in the cross slope being greater than 1:48
Sec. 1104.2.2.3 Landing: A landing 48 inches
EXCEPTION: Running and cross slope requirements shall not apply to mid- block crossings.
ADOT supports the guideline requirement for a minimum 48-inch by 48-inch landing at bottom of the parallel ramp. However, we oppose the guideline for maximum running and cross slopes of 1:48
Sec. 1104.2.2.4 Diverging Sidewalks: Where a parallel curb ramp does not occupy the entire width of a sidewalk, drop-offs at diverging segments shall be protected with a barrier.
ADOT supports the proposed guideline as written, but requests clarification of what constitutes a "barrier".
Sec. 1104.2.3 Blended Transitions: Blended transitions shall comply with 1104.3, and shall have running and cross slopes of 1:48
ADOT cannot support the guideline because of its call for maximum running and cross slopes of 1:48
Sec. 1104.3 Common Elements: Curb ramps and blended transitions shall comply with 1104.3.
Sec. 1104.3.1 Width: The clear width of landings, blended transitions, and curb ramps, excluding flares, shall be 48 inches
ADOT supports the proposed guideline as written.
Sec 1104.3.2 Detectable Warnings: Detectable warning surfaces complying with 1108 shall be provided, where a curb ramp, landing, or blended transition connects to a crosswalk.
ADOT supports the proposed guideline, noting however the comments we've provided pertaining to Sec. 1108 Detectable Warning Surfaces.
Sec. 1104.3.3 Surfaces: Surfaces of curb ramps, blended transitions, and landings shall comply with 302. Gratings, access covers, and other appurtenances shall not be located on curb ramps, landings, blended transitions, and gutter areas within the pedestrian access route.
ADOT requests a rewording of second sentence of this guideline to acknowledge that circumstances will occur that may require the placement of gratings, access covers, and other appurtenances within the PAR.
Sec. 1104.3.4 Grade Breaks: Grade breaks shall not be permitted on curb ramps, blended transitions, landings, and gutter areas within the pedestrian access route. Surface slopes that meet at grade breaks shall be flush.
ADOT requests clarification of the last sentence and what is meant by "surface slopes" and how they shall be "flush".
Sec. 1104.3.5 Changes in Level: Vertical changes in level shall not be permitted on curb ramps, blended transitions, landings, or gutter areas within the pedestrian access route.
ADOT requests clarification of "vertical changes in level".
Sec. 1104.3.6 Counter Slopes: The counter slope of the gutter area or street at the foot of a curb ramp or blended transition shall be 1:20
ADOT requests that definition of the term "counter slope" be provided.
Sec. 1104.3.7 Clear Space: Beyond the curb line, a clear space of 48 inches
ADOT strongly opposes this guideline. This guideline would result in an increase in the roadway width by forty-eight inches (48 in) on each side of the road at every ramp location for a total of ninety-six (96 in
Sec. 1105 Pedestrian Crossings
Sec. 1105.1 General: Pedestrian crossings shall comply with 1105.
Sec. 1105.2 Crosswalks: Crosswalks shall comply with 1105.2.
Sec. 1105.2.1 Width: Marked crosswalks shall be 96 inches
ADOT cannot support the proposed guideline as written because it mandates a minimum width contrary to that called for in the MUTCD. Section 3B.17 Crosswalk Width of the MUTCD calls for a minimum width of six feet (6 ft), which is research based. Nothing has been presented to show the necessity of widening a crosswalk to eight feet (8 ft).
Sec. 1105.2.2 Cross Slope: The cross slope shall be 1.48 maximum measured perpendicular to the direction of pedestrian travel.
EXCEPTION: This requirement shall not apply to mid-block crossings.
ADOT strongly opposes this guideline. The effect of this guideline could be monumental in locations where the longitudinal grade of the roadway exceeds two percent (2%, 1:48
Sec. 1105.2.3 Running Slope: The running slope shall be 1.20 maximum measured parallel to the direction of pedestrian travel in the crosswalk
ADOT cannot support this guideline as it would have a negative effect on the placement of marked pedestrian crossings on roadways with grades steeper than five percent (5%, 1:20
Sec. 1105.3 Pedestrian Signal Phase Timing: All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3. 0 feet
ADOT cannot support this guideline as it would impact the pedestrian signal phase timing of almost every traffic signal in the State and two of the consequences would be overwhelming. First, almost every traffic signal in Arizona would have to be re-timed to account for the increase in pedestrian travel length. The current MUTCD guidelines for pedestrian signal phase timing allow the length to be measured from the curb face to the center of the furthest through travel lane. This guideline would add a minimum of fourteen feet (14 ft) to the length which equates to a minimum addition of 4.67 seconds
Sec. 1105.4 Medians and Pedestrian Refuge Islands: Medians and pedestrian refuge islands in crosswalks shall comply with 1105.4 and shall be cut through level with the street or have curb ramps complying withllO4 and shall contain a pedestrian access route complying with 1103. Where the cut-through connects to the street, edges of the cut-through shall be aligned with the direction of the crosswalk for a length of 24 inches
ADOT cannot support this guideline because the language in Sec. 1104 Curb Ramps is already overly restrictive at locations with roadway grade is greater than two percent (2%) (see comment for Sec. 1104.2.1.2 Cross Slope, above).
Sec. 1105.4.1 Length: Where signal timing is inadequate for full crossing of all traffic lanes or where the crossing is not signalized, cut-through medians and pedestrian refuge islands shall be 72 inches
ADOT cannot support this guideline as our current standard width for medians at intersections is forty-eight inches (48 in).
Sec. 1105.4.2 Detectable Warnings: Medians and refuge islands shall have detectable warnings complying with 1108. Detectable warnings at cut-through islands shall be separated by a 24 inch
EXCEPTION: Detectable warnings shall not be required on cut-through islands where the crossing is controlled by signals and is timed for full crossing.
ADOT cannot support this guideline as our current standard width for medians at intersections is forty-eight inches (48 in
Sec. 1105.5 Pedestrian Overpasses and Underpasses: Pedestrian overpasses and underpasses shall comply with 1105.5.
Sec. 1105.5.1 Pedestrian Access Route: Pedestrian overpasses and underpasses shall contain a pedestrian access route complying with 1103.
ADOT supports the proposed guideline as written.
Sec. 1105.5.2 Running Slope: The running slope shall not exceed 1:20
ADOT cannot support the proposed guideline as written as it could require the running slope of the PAR to be independent of the longitudinal grade of the adjoining roadway. To require a PAR running slope less than 1:20
Sec. 1105.5.3 Approach: Where the approach exceeds 1:20
ADOT supports the part of the guideline pertaining to minimum ramp width. We strongly oppose that part calling for a limited-use/limited-application or standard elevator where the rise of the ramped approach exceeds sixty inches (60 in). We are deeply concerned that about the safety of pedestrians using such elevators and think it inadvisable to install elevators if we cannot guarantee pedestrian security. In Arizona there are also regular, but unplanned interruptions in electrical service due to electrical storms in the summer and snow storms in the winter. These interruptions could trap people in the elevators without any simple means of extricating them until power is restored. Equally as important in our opposition to the requirement for elevators are their exorbitant costs and the notion we should provide a facility for disabled pedestrians which is well beyond what we'd provide for pedestrian traffic in general.
Sec. 1105.5.4 Stairs: Stairs shall comply with 504. (Sec. 504 Stairways can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-05.hmtl)
ADOT has "No comment" on this section.
Sec. 1105.5.5 Escalators: Escalators shall comply with 810.9.
ADOT has "No comment" on this section.
Sec. 1105.6 Roundabouts: Where pedestrian crosswalks and pedestrian facilities are provided at roundabouts, they shall comply with 1105.6.
Sec. 1105.6.1 Separation: Continuous barriers shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited. Where railings are used, they shall have a bottom rail 15 inches
ADOT strongly opposes this guideline as written because of its possible negative impacts on motorist and pedestrian safety. If handrail is used as a barrier on sidewalks abutting the curb it could present a spearing hazard to motorists. Other types of barrier could present tripping hazards to pedestrians if placed lower than twenty-seven inches (27 in) and a sight restriction to motorists if places above that point. We would like to know why sidewalk at a roundabout is being treated differently from that at any other street intersection?
Sec. 1105.6.2 Signals: A pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the crosswalk, including the splitter island. Signals shall clearly identify which crosswalk segment the signal serves.
ADOT cannot support this guideline as written. It is inadvisable to promulgate a guideline that would mandate the installation of any traffic control signal without an engineering study to confirm the need for such a signal. Warrants for installation of a signal would investigate such variables as sight distance, traffic volume, pedestrian volume, vehicle speed, and vehicle gap.
Sec. 1105.7 Turn Lanes at Intersections: Where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island.
ADOT cannot support this guideline as written. We request a definition for the term "slip lane" be added to Sec. 1101.3 Terms. Within the Arizona highway system unrestricted right turns are sometimes provided at freeway ramps to handle the volume of exiting traffic. The installation of a signal could cause a dangerous situation where off-ramp traffic would back up onto the freeway. Again, without a case-by-case engineering study, as detailed in the MUTCD, it would be inadvisable to mandate installation of a signal at these locations.
Sec. 1106 Accessible Pedestrian Signal Systems
Sec. 1106.1 General: Pedestrian signal systems shall comply with 1106.
Sec. 1106.2 Pedestrian Signal Devices: Each crosswalk with pedestrian signal indication shall have a signal device which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device and shall comply with 1106.3.
ADOT strongly opposes this guideline as written. We see no added value to implementing this guideline, and a possible increased liability due to system failure and application inconsistency.
Sec. 1106.2.1 Location: Pedestrian signal devices shall be located 60 inches
EXCEPTION: The minimum distance from other signal devices shall not apply to signal devices located in medians and islands.
ADOT cannot support the proposed guideline as written because locating all traffic control devices should be done as part of a site-specific engineering study. We think it would be poor engineering practice to utilize this guideline without an investigation of the site and analysis thereof.
Sec. 1106.2.2 Reach and Clear Floor or Ground Space: Pedestrian signal devices shall comply with 308. A clear floor or ground space complying with 305 shall be provided at the signal device and shall connect to or overlap the pedestrian access route. (Sec. 308 Reach Ranges and Sec. 305 Knee and Toe Clearance can be found on the Access Board website at http://www. access-board.gov/ada-aba/html/tech-03.html)
ADOT has "No comment" on this section.
Sec. 1106.2.3 Audible Walk Indication: The audible indication of the WALK interval shall be by voice or tone.
ADOT cannot support this guideline as written. Because of the number of different languages spoken in Arizona it would be technically infeasible to provide any message, in every language, in a timely manner. To arbitrarily decide not to offer the message in a particular language could also leave this Department open to charges of not providing equal access to public services. Also, as noted above, advocacy groups for the visually impaired have not achieved a clear consensus regarding the need for and design of audible and vibrotactile indications.
Sec. 1106.2.3.1 Tones: Tones shall consist of multiple frequencies with a dominant component at 880 Hz. The duration of the tone shall be 0.15 seconds
ADOT has "No comment" on this section.
Sec. 1106.2.3.2 Volume: Tone or voice volume measured at 36 inches
ADOT cannot support this section of the guidelines because the sound level produced could be considered a nuisance, particularly in the evening hours and at locations in residential neighborhoods.
Sec. 1106.3 Pedestrian Pushbuttons: Pedestrian pushbuttons shall comply with 1106.3.
Sec. 1106.3.1 Operation. Pedestrian pushbuttons shall comply with 309.4. (Sec. 309.4 Operation can be found on the Access Board website at http://www.access board.gov/ada-aba/html/tech-03.hmtl)
ADOT has "No comment" on this section.
Sec. 1106.3.2 Locator Tone. Pedestrian pushbuttons shall incorporate a locator tone at the pushbutton. Locator tone volume measured at 36 inches
ADOT cannot support the proposed guideline because the sound level produced could be considered a nuisance, particularly in the evening hours and at locations in residential neighborhoods.
Sec. 1106.3.3 Size and Contrast. Pedestrian pushbuttons shall be a minimum of 2 inches
ADOT supports the proposed guideline as written.
Sec. 1106.3.4 Optional Features: An extended button press shall be permitted to activate additional features. Buttons that provide additional features shall be marked with three Braille dots forming an equilateral triangle in the center of the pushbutton.
ADOT has "No comment" on this section.
Sec. 1106.4 Directional Information and Signs. Pedestrian signal devices shall provide tactile and visual signs on the face of the device or its housing or mounting indicating crosswalk direction and the name of the street containing the crosswalk served by the pedestrian signal.
ADOT cannot support this section as the name of streets served by a particular crosswalk is not currently provided at any location. Each location would require costly, custom-made signs which would have to be replaced if damaged or otherwise vandalized.
Sec. 1106.4.1 Arrow: Signs shall include a tactile arrow aligned parallel to the crosswalk direction. The arrow shall be raised 1/32 inch
ADOT can support this guideline.
Sec. 1106.4.2 Street Name. Signs shall include street name information aligned parallel to the crosswalk direction and complying with 703.2. (Sec. 703.2 Characters That Are Both Tactile and Visual can be found on the Access Board website at http://www.access board.gov/ada-aba/html/tech-07.html)
ADOT cannot support this section of the guidelines because it puts an unreasonable burden on the State and other jurisdictions to produce costly, custom-made signs for each location.
Sec. 1106.4.3 Crosswalk Configuration: Where provided, graphic indication of crosswalk configuration shall be tactile and shall comply with 703.5.1. (Sec. 703.2 Location can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-07.hmtl)
ADOT can support this section as long as there is no requirement to provide graphic indication of the crosswalk configuration.
Sec 1107 Street Furniture
Sec. 1107.1 General: Street furniture shall comply with 1107.
Sec. 1107.2 Clear Floor or Ground Space: Street furniture shall have clear floor or ground space complying with 305 and shall be connected to the pedestrian access route. The clear floor or ground space shall overlap the pedestrian access route 12 inches
ADOT support this section of the guidelines.
Sec. 1107.3 Drinking Fountains: Where drinking fountains are provided, they shall comply with 602. (Sec. 602 Drinking Fountains and Water Coolers can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-06.hmtl)
ADOT has "No comment" on this section.
Sec. 1107.4 Public Telephones: Where public telephones are provided, they shall comply with 1107.4.
ADOT has "No comment" on this section.
Sec. 1107.4.1 Single Telephone: Where a single public telephone is provided, it shall comply with 704.2 and 704.4. (Sec. 704.2 Wheelchair Accessible Telephones and Sec. 704.4 TTYs can be found on the Access Board website at http://www.access board.gov/ada-aba/html/tech-07.html)
ADOT has "No comment" on this section.
Sec. 1107.4.2 Multiple Telephones: Where a bank of public telephones is provided, at least one telephone shall comply with 704.2, and at least one additional telephone shall comply with 704.4.
ADOT has "No comment" on this section.
Sec. 1107.4.3 Volume Controls: A 11 public telephones shall provide volume controls complying with 704.3. (Sec. 704.3 Volume Control Telephones can be found on the Access Board website at http.//www. access-board.gov/ada-aba/html/tech-0 7.html)
ADOT supports the proposed guideline as written.
Sec. 1107.5 Public Toilet Facilities: Permanent or portable public toilet facilities shall comply with 603. At least one fixture of each type provided shall comply with 604 through 610. Operable parts, dispensers, receptacles, or other equipment shall comply with 309.
EXCEPTION: Where multiple single-user toilet facilities are clustered at a single location, at least 5 percent, but no fewer than one single-user toilet at each cluster shall comply with 603 and shall be identified by the International Symbol of Accessibility complying with 703.7.2.1. (Sec. 603 Toilet and Bathing Rooms and Sections 604 through 610 can be found on the Access Board website at http.//www.access-board.gov/ada-aba/html/tech-06.html, Sec. 309 Operable Parts at http.//www.access-board.gov/ada-aba.html/tech-03.html and Sec. 703.7.2.1 Finish and Contrast at http.//www. access-board.gov/ada-aba/html/tech-07.html.)
ADOT has "No comment" on this section.
Sec. 1107.6 Tables, Counters, and Benches: Tables, counters, and benches shall comply with 1107.6.
Sec. 1107.6.1 Tables: Where tables are provided in a single location, at least 5 percent but no fewer than one, shall comply with 902. (Sec. 902 Dining Surfaces and Work Surfaces can be found on the Access Board website at http.//www.access-board.gov/ada-aba/html/tech-09.hmtl)
ADOT has "No comment" on this section.
Sec. 1107.6.2 Counters: Where provided, counters shall comply with 904. (Sec. 904 Sales and Service Counters can be found on the Access Board website at http://www. access-board.gov/ada-aba/html/tech-09.hmtl)
ADOT has "No comment" on this section.
Sec. 1107.6.3 Benches: Where benches without tables are provided at a single location, at least 50 percent, but no fewer than one, shall comply with 903 and shall have an armrest on at least one end (Sec. 903 Benches can be found on the Access Board website at http://www. access-board.gov/ada-aba.html/tech-09.hmtl)
ADOT has "No comment" on this section.
Sec 1108 Detectable Warning Surfaces
Sec. 1108.1 General: Detectable warnings shall consist of a surface of truncated domes aligned in a square grid pattern and shall comply with 1108.
ADOT cannot support this guideline because it would restrict the free market development of truncated dome systems by prohibiting the diamond pattern. While the argument arises that the square pattern is friendlier to vibration- sensitive people, there is no research on the possible number of individuals affected. Depending on the dimensions used in the square or diamond pattern and the width of the wheelchair, its wheels will either hit or miss the truncated domes. Therefore, we see no reason to favor one pattern over another in the rulemaking process.
Sec. 1108.1.1 Dome Size: Truncated domes in a detectable warning surface shall have a base diameter of 0.9 inches
ADOT supports the proposed guideline as written.
Sec. 1108.1.2 Dome Spacing: Truncated domes in a detectable warning surface shall have a center-to-center spacing of 1.6 inches
ADOT supports this guideline while recommending removal of reference to "square grid" from the last sentence (see comment on Sec. 1108.1 General, above).
Sec. 1108.1.3 Contrast: Detectable warning surfaces shall contrast visually with adjacent walking surfaces either light-on-dark, or dark-on-light.
ADOT supports the proposed guideline as written.
Sec. 1108.1.4 Size: Detectable warning surfaces shall extend 24 inches
ADOT supports the proposed guideline as written.
Sec. 1108.2 Location
Sec. 1108.2.1 Curb Ramps and Blended Transitions: The detectable warning surface shall be located so that the edge nearest the curb line is 6 inches
ADOT supports the proposed guideline as written.
Sec. 1108.2.2 Rail Crossings: The detectable warning surface shall be located so that the edge nearest the rail crossing is 6 inches
ADOT supports the proposed guideline, but recommends the term "vehicle dynamic envelope" be used consistent with the term "dynamic envelope" as shown in Sec. 1103 Terms.
Sec. 1108.2.3 Platform Edges: Detectable warning surfaces at platform boarding edges shall be 24 inches
ADOT has "No comment" on this section.
Sec 1109 On-Street Parking
Sec. 1109.1 General: Car and van on-street parking spaces shall comply with 1109.
ADOT has "No comment" on this section.
Sec. 1109.2 Parallel Parking Spaces: An access aisle at least 60 inches
EXCEPTION: An access aisle is not required where the width of the sidewalk between the extension of the normal curb and boundary of the public right-of-way is less than 14 feet
ADOT requests further clarification of this guideline before deciding whether we support it.
Sec. 1109.3 Perpendicular or Angled Parking Spaces: Where perpendicular or angled parking is provided, an access aisle 96 inches
ADOT cannot support this guideline as written because the incremental value of a ninety-six (96-in) wide access aisle over the currently used sixty-inch (60-in) wide access aisle has not been established.
Sec. 1109.4 Curb Ramps or Blended Transitions: A curb ramp or blended transition complying with 1104 shall connect the access aisle to the pedestrian access route.
ADOT supports this guideline in concept, noting however the comments regarding the 1:48
Sec. 1109.5 Obstructions. There shall be no obstructions on the sidewalk adjacent to and for the full length of the space.
EXCEPTION: This provision shall not apply to parking signs complying with 1109.6 and parking meters complying with 1109.7.2.
ADOT supports the proposed guideline as written.
Sec. 1109.6 Signs: Parking spaces shall be designated as reserved by a sign complying with 502.6. Signs shall be located at the head or foot of the parking space so as not to interfere with the operation of a side lift or a passenger side transfer. (Sec. 502 Parking Spaces can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-05.hmtl)
ADOT supports the proposed guideline as written.
Sec. 1109.7 Parking Meters: Where parking meters are provided, they shall comply with 1109.7.
ADOT supports the proposed guideline as written.
Sec. 1109.7.1 Operable Parts. Operable parts shall comply with 309. (Sec. 309 Operable Parts can be found on the Access Board website at http://www.access board.gov/ada-aba/html/tech-03.hmtl)
ADOT supports the proposed guideline as written.
Sec. 1109.7.2 Location: A parking meter shall be located at the head or foot of the parking space so as not to interfere with the operation of a side l or a passenger side transfer.
EXCEPTION: Where parking meters are not provided at the space, but payment for parking in the space is included in a centralized collection box or paying station, the space shall be connected to the centralized collection point with a pedestrian access route.
ADOT supports the proposed guideline as written.
Sec. 1109.7.3 Displays and Information.' Displays and information shall be visible from a point located 40 inches
ADOT supports the proposed guideline as written.
Sec. 1110 Call Boxes
Sec. 1110.1 General: Call boxes shall comply with 1110.
ADOT has "No comment" on this section..
Sec. 1110.2 Operable Parts: Operable parts shall comply with 308 and 309.4. Where provided, labeling shall comply with 703.2 and 703.3. (Sec. 703 Signs can be found on the Access Board website at http.//www.access-board.gov/ada-aba/html/tech-07.hmtl)
EXCEPTION: Mechanically operated systems in which the signal is initiated by a lever pull shall be permitted to have an activating force of 12 lbf
ADOT supports the proposed guideline as written.
Sec. 1110.3 Turning Space: A turning space complying with 304 shall be provided at the controls. (Sec. 304 Wheelchair Turning Space can be found on the Access Board website at http.//www. access-board.gov/ada-aba/htm l/tech-03.hmtl
ADOT supports the proposed guideline as written.
Sec. 1110.4 Edge Protection: Edge protection complying with 405.9.2 shall be provided where the area at the call box is adjacent to an abrupt level change. (Sec. 405.9.2 Curb or Barrier can be found on the Access Board website at http://www.access-board.gov/ada-aba.html/tech-04.hmtl)
ADOT supports the proposed guideline, but would request further clarification regarding the terms "abrupt level change" and "edge protection".
Sec. 1110.5 Motor Vehicle Turnouts: Where provided, a motor vehicle turnout shall have a minimum paved area of 16 feet
ADOT supports the basic guideline, but question the requirement of a sixteen-foot (1 6-ft) wide paved area. Provision of a thirteen-foot (1 3-fl) wide paved area is sufficient to provide for an eight-foot (8-ft) wide parking space and a five-foot (5-fl) wide access and the incremental value of an eight-foot (8-ft) wide access route has not been established route (see comment for Sec. 1109.2 Parallel Parking Spaces, above).
Sec. 1110.6 Two- Way Communication: Where provided, two-way voice communication shall comply with 1110.6, 708.2 and 708.3. (Sec. 708 Two-Way Communication Systems can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-07.hmtl)
ADOT has "No comment" on this section.
Sec. 1110.6.1 Volume Controls: Volume controls complying with 704.3 shall be provided (Sec. 704.3 Volume Control Telephones can be found on the Access Board website at http.//www. access-board.gov/ada-aba/html/tech-07.hmtl)
ADOT has "No comment" on this section..
Sec. 1110.6.2 TTY A TTY complying with 704.4 shall be provided (Sec. 704.4 TTYs can be found on the Access Board website at http://www.access-board.gov/ada-aba.html/tech-07.hmtl)
ADOT has "No comment" on this section.
Sec. 1111 Alternate Circulation Path
Sec. 1111.1 General: Alternate circulation paths shall comply with 1111.
ADOT supports the proposed guideline as written.
Sec. 1111.2 Width: The alternate circulation path shall have a width of36 inches
ADOT strongly supports the guideline requirement for the alternate circulation path minimum width of thirty-six inches (36 in).
Sections 1111.3 Location: The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street.
ADOT strongly opposes this guideline's requirement for the "Alternate Circulation Path" to be located on the same side of the street as the disrupted PAR. This provision would impose a central-planning approach to traffic control for construction and maintenance operations, and would negatively impact pedestrian comfort and safety while creating an unreasonable burden upon State and local agencies. This provision does not appear to consider the following: A) the length of time a project is underway; B) the type and nature of the project; C) the probable negative impact upon the other users of the transportation facility due to reduced roadway capacity; D) the advisability of and risk inherent in moving pedestrians adjacent to construction or maintenance operations; E) the impact of noise on the pedestrian; nor F) the impact to construction programs, in terms of time and money spent on meeting this guideline.
This proposed guideline is also contrary to guidance provided by the Manual on Uniform Traffic Control Devices (MUTCD), Section 6D.O I Pedestrian Considerations This section of the MUTCD delineates three considerations, of which the first two address this matter. They are as follows:
A. Pedestrians should not be led into conflicts with work site vehicles, equipment, and operations. and
B. Pedestrians should not be led into conflicts with vehicles moving through or around the work site.
Further clarification is provided in the MUTCD on page 6D- 1 as, "Pedestrians should be appropriately directed with advance signing that encourages them to cross to the opposite side of the roadway." (emphasis added) and 6D-2 as, "Whenever it is feasible, closing off the work site from pedestrian intrusion may be preferable to channelizing pedestrian traffic along the site with temporary traffic control devices such as cones, tubular markers, barricades and drums, or other suitable fencing."
Sec. 1111.4 Protection: The alternate circulation path shall comply with 307 and shall be protected with a barricade complying with 1111.6 to separate the pedestrian access route and alternate circulation path from any adjacent construction, drop-offs, openings, or other hazards.
ADOT cannot support this guideline because the Alternate Circulation Path should not be adjacent to construction or maintenance operations (see comment on Sec. 1111.3 Location, above).
Sec. 1111.5 Signs: Signs complying with 703.5 shall be provided at both the near side and the far side of the intersection preceding a disrupted pedestrian access route. . (Sec. 703.5 Braille can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-07.hmtl)
ADOT strongly supports the placement of signs, at both the near side and far side of the intersections preceding a disrupted PAR, encouraging all pedestrians to cross to the opposite side of the roadway wherever possible (see comment on Sec. 1111.3 Location, above).
Sec. 1111.6 Barricades: Barricades shall be continuous, stable, and non-flexible and shall consist of a solid wall or fence or a Type II or Type III barricade as specified in MUTCD section 6F-60 with the bottom or lower rail 1-1/2 inches
ADOT cannot support this guideline as written because no temporary barricade system is totally "non- flexible"; temporary barricades differ by how much rigidity they provide. The proposed guideline would also prohibit the use of both Type II and Type III temporary barricades to define the alternative circulation path because they use "T-type" supports that would encroach into the path. Temporary concrete barrier (TCB), which can move up to three feet (3 ft) laterally when struck, would meet most of the intent of this guideline, however, TCB should not be used arbitrarily. Sound engineering judgment should be used to determine, on a case-by-case basis, the advisability of introducing another hazard (the TCB itself) onto the project. Indiscriminate use of TCB could put the public's health, safety, and welfare at risk.
Charles Carmalt, October 28, 2002
In a separate e-mail I will be sending a Microsoft Word version of these comments with formatting as an attachment, which you may find more convenient to use. I will also mail that document as a letter to the Access Board.
My original intent in responding to the draft standards was that I had been informed that the Board would be establishing 60" as the minimum width for sidewalks. I am glad to see that the Board has instead recommended a minimum width of 48". As discussed below, I believe that the wider width would result in fewer sidewalks being constructed, and would be severely counter-productive.
However, the idea of requiring wider sidewalk widths is consistent with a general fault of many of the proposed guidelines. The guidelines appear to have been drafted to address common problems experienced in cities by different types of persons having disabilities, or at intersections on very heavily traveled arterial highways. However, the regulations of the Access Board will extend throughout the nation and will be applied on streets, roads, highways, lanes and other public rights-of-way in rural, exurban, suburban and neighborhood environments, not just in city centers. In many of these environments, some of the mandatory standards presented would be either inappropriate or, as in the case of 5' sidewalks, counter-productive by discouraging roadway design practices that soften the roadway environment and make roadways more convenient for all non-motorized users.
I encourage you to critically evaluate the effect and appropriateness of these standards in environments where the frequency and intensity of conflicts between different users can be anticipated to be substantially less than in city centers and similar intensely used areas.
My comments are as follows:
Section 1101.3
Defined Terms
Cross slope. Cross-slope is not usually called superelevation. Superelevation is a roadway design treatment that adjusts the cross slope to mitigate the impact of curvature. I recommend that the second sentence be deleted.
Similarly, if you must define superelevation, you should define it using language that in fact is descriptive. I looked for a definition in both AASHTO's Policy on Geometric Design and ITE's Traffic Engineering Handbook but found none. I suggest something like the following:
Superelevation - an adjustment to the cross slope of a traveled way that is introduced to mitigate the outward centrifugal force created by a horizontal curve. Superelevation is conventionally termed "banking".
However, I question whether a definition is required. You may wish to conduct a search to determine if it is used in the text of the regulations.
Note that if you do use the term, you should use an all-inclusive term such as traveled way rather than roadway or highway. Superelevation can be introduced on paths and sidewalks as well as highways. Conversely, reverse superelevation, or banking in the reverse direction of a curve, can pose a special problem for persons in wheelchairs. Unfortunately, it is relatively easy to inadvertently introduce reverse superelevation along a pedestrian access route if the designer is not attentive.
Section 1102.10
Stairs. This section should be amended to provide guidance regarding where the use of stairs may be appropriate in public rights-of-ways. The guidance should strongly discourage the use of stairs except in situations where the natural grade clearly necessitates their use of stairs. Thoughtless designers who introduce unnecessary stairs into public the right-of-way are being cruel to all users.
When stairs are introduced, they should be located out of the preferred pedestrian route so that most users will be attracted to a route without barriers.
Section 1102.14
On-street parking. On-street parking requirements should only apply in locations where the parking is used by the general public in a mixed use environment and where the parking supply is constrained.
On most residential streets in suburbs, and many other streets, parking is permitted but only lightly used. I feel certain that most persons that might seek an accessible space in a confined and shared parking environment would seek to use a parking space most convenient to the specific destination in an unconfined environment. This could include blocking the driveway at the intended destination.
In areas surrounding Lawrenceville, municipalities use accessible parking regulations to regulate spaces in front of homes or businesses that have individuals who regularly need such a reservation. This more flexible approach helps to protect proximity of parking for persons who need such protection. At locations where the general public is being encouraged to park, such as in a village center, the approach proposed in the draft regulations is currently followed.
This section should establish conditions under which it should be implemented. This could either be a warrant based system using a variable associated with constrained parking demand, or it could be based on engineering judgment. Note that an approach frequently followed is to supply accessible spaces in convenient segregated off-street locations and allow the on-street supply to be used for persons not requiring accessible design. Where practical, this approach usually results in superior design.
Proposed 1102.14 is an example of a regulation aimed at a dense urban environment that would be impractical or counter-productive in other environments. It should be more narrowly drafted.
Section 1103.3
Clear width.
I strongly endorse the use of 48 inches
Some language should be included to provide guidance where such additional width is required - for example surrounding hospitals, in retail centers, near nursing homes or other places that serve persons with disabilities, etc. A methodology should be presented for determining the amount of additional width required and the extent of the surrounding area within which widening should occur.
Section 1103.3
The minimum clear width should be enlarged to six feet if the pedestrian access route immediately abuts a curb. (Note: a curb represents a vertical edge that is a hazard not only for persons in wheel chairs and blind persons but for all pedestrians. Slipping off of a curb can cause serious injury. A requirement that sidewalks be widened if they abut a curb is relatively standard.
Section 1103
Add a section on edges.
This section should include specific guidance regarding the treatment of edges adjacent to pedestrian access routes. Routes that abut a vertical surface such as a wall should be widened by at least one foot.
The surface of a pedestrian access route should not directly abut an edge. Language similar to 405.9.2 should be provided describing edges and design approaches presented to indicated the protection that should be provided.
I recently was walking along a bridge over a river that was constructed within the past three years. The wooden sidewalk has railings. However, the 5' boards that create the sidewalk terminate with no edge treatment or curb. Instead, a vertical drop to the river is presented at the edge. The user of a wheelchair could readily have a wheel caught in this edge, would be thrown against the railing and would be unable to extricate himself or herself. I will be working to correct this instance, put the regulations should prohibit it from occurring along a pedestrian access route.
Section 1103.5
Grade Exception. The proposed regulations allow for the pedestrian access route to be steeper than the grade of the adjacent roadway. I understand that there may be unique conditions in which this may be appropriate, in particular to create level platforms at doorways. However, the blanket exception, as worded, goes to far.
In our area, and in many other suburban areas, designers of late have become very fond of introducing unnecessary vertical and horizontal curvature into sidewalks to make them more appealing to motorists. The vertical curves especially are an unwarranted and unnecessary burden to all pedestrians, and are a viciously cruel insult to persons in wheelchairs. Your regulations should include language requiring designers to keep pedestrian access routes as flat as possible and permitting exceptions only where other accessibility requirements require an adjustment.
In addition, designers should be encouraged to introduce modest horizontal diversions, where appropriate, to reduce the grade of a pedestrian access route. Horizontal diversions should also be encouraged along routes that have a grade in excess of 1:20
Section 1103
Pedestrian Access Route and stairs. As indicated above, stairs should be kept out of the pedestrian access route. Where stairs may be desirable, the pedestrian access route should be designed in such a fashion that the route that employs stairs can be perceived as a secondary route.
Where grades make steps unavoidable and an elevator is required, the elevator should be located in a convenient and obvious location requiring little circuitous travel. Standards are needed, appropriate for public environments.
Section 1104.2.1.2
Cross slope. The reason for exempting mid-block crossings from the maximum 1:48
Section 1104.3.1
Width. I strongly encourage you to require curb ramps or blended transitions to extend for the full width of a crosswalk, if marked, or the full width of the extending sidewalk if no crosswalk is marked.
A person needing the use of a curb ramp should not have to search for its location but instead assume that a transition free of vertical change in level will be available at the roadway edge. In a city, fighting to move at right angles to the flow of pedestrians to the available curb ramp can be difficult and/or dangerous. In suburban areas, the crosswalk should provide visual guidance regarding the curb ramp location. See below regarding crosswalk width.
Section 1104.3.4
Grade breaks. As I understand this section, it applies only to grade breaks in curb ramps and blended transitions. The first sentence indicates that grade breaks are not permitted at curb ramps, blended transitions, etc.; the second sentence says that when they do occur they shall be flush. Either grade breaks are permitted or they are not permitted.
I obviously don't understand the meaning of flush in the second sentence, and it is not defined. I think that you mean that there shall be no change in level at a grade break.
From a practical perspective, this will be very difficult to achieve. With differential settling, differences of less than ¼ inch are bound to occur. Furthermore, unintentional grade breaks are likely to evolve. Do these exceptions become instantly in contravention of the regulations?
Section 1104.3.5
Changes in level. Similarly, although a project may be initially designed to result in no changes in level, the requirement that different materials be used in the sequence of devices described, curb ramps, landings and gutters, will over time result in some changes in level evolving. What reasonable approach should be permitted to allow minor, unintended changes in level but also require greater changes to be corrected?
Section 1104.3.7
Clear space in crosswalk. I and many other designers are working to reduce the length of crosswalks through the introduction of curb extensions and refuge islands. These can be very beneficial to all pedestrians. What we are trying to do is keep as much of the crosswalk as possible out of the roadway by narrowing the roadway as much as possible.
The clear space within a crosswalk mandated by this section represents unneeded roadway width. This section will prohibit curb extensions. Is that really your intent? I strongly encourage you to revise this section. Please use the regulations to encourage the practice of installing curb extensions at crosswalks, not prevent it.
Section 1105.2.1
Width of crosswalks. The requirement that crosswalks have a minimum width of 8' is another example of introducing a regulation aimed at dense urban environments that would be impractical or counter-productive in other environments. It should be more narrowly drafted.
Crosswalks in outlying areas are lightly used. While a downtown crosswalk may have several hundred persons crossing every hour, even thousands, in suburban areas we usually are talking about less than 100 per day. In this environment, the crosswalk markings are serving a different function, and the potential of conflicting pedestrian movements are very limited and easily overcome.
A major purpose of the crosswalk lines in these less traveled areas is to direct pedestrians in the most advantageous and hopefully shortest route. The crosswalk lines can be very helpful in guiding persons to the curb ramps on opposite side of the street. They can also encourage pedestrians to cross at locations where motorists will have the best sight vision of the pedestrians.
The wide width will restrict the utility of crosswalks in guiding pedestrians to the available curb ramps. In my opinion, an 8' width may reduce the visibility of the crosswalk compared to a 6' width, especially if transverse crosswalk lines are used.
In heavily developed urban areas, on the other hand, crosswalk lines may need to be wider than 8'. A procedure should be provided to guide designers in those situations as well.
Section 1105.2.2
Cross slope. I recommend that you amend this language to specify that you are speaking of the cross slope of the roadway, not the cross slope of the crosswalk. I was very confused.
Section 1105.3
Pedestrian signal phase timing. As I understand this section, the draft regulations are requiring that a 14% slower walking speed be assumed. In addition, the regulations require that crosswalks be extended by 48" to provide a clear space within the roadway, and this section requires that the pedestrian clearance interval also include the length of the entire curb ramp, which often are 5 to 10 feet
The net effect of this section will be to create very lengthy pedestrian crossing phases, necessitating longer traffic signal cycles. This in turn will encourage more pedestrians to illegally cross outside of the pedestrian phase, since they will grow impatient.
I agree with the reduction in assumed walking speed. However, agencies should be allowed to retain other current procedures for timing pedestrian phases.
Section 1105.6.2
Signals at roundabouts. I strongly oppose this section. Roundabouts have many features that are beneficial to all pedestrians, including those with pedestrians. Most notably, crossing distances are substantially shorter, and motorists have much better ability to see crossing pedestrians compared to turning motorists.
Requiring pedestrian signals at all roundabout crosswalks will substantially increase the cost of installing roundabouts. Since most pedestrians will ignore the signals, finding the short crossing distances easy to negotiate, the use of signals at these locations will breed contempt for traffic signals by pedestrians. If pedestrian signals are activated frequently, traffic engineers will develop lengthy signal cycles, frustrating pedestrians.
Instead, the Board should work with AASHTO and Federal Highway to develop additional design guidance to enhance the visibility of crossing pedestrians and to encourage yielding behavior by motorists. Consideration should be given to using raised crossings or other traffic calming measures to slow drivers at roundabout crosswalks.
If signals are to be required, there should be a volume warrant. As worded, this section would apply to any roundabout regardless of its environment if pedestrian crosswalks and facilities are provided. A neighborhood traffic circle with less than 1000 vehicles ADT would have to have signal controlled crossings even though no signal would be warranted without the circle and the circle would enhance pedestrian safety and slow vehicle speeds.
At exurban locations, this requirement will encourage road designers to eliminate crosswalks and sidewalks so as to avoid the requirement to install pedestrian signals.
I recommend that the Board instead seek to develop a warrant based crosswalk signal that would take into effect the volume of traffic using each roundabout approach and exit, and the volume of pedestrian activity. On roundabouts with high motor vehicle volumes but only limited pedestrian activity, a flasher system should be required to alert motorists to the presence of pedestrians.
Finally, to the extent feasible, if pedestrian signals are to be introduced in areas with roundabouts, it should be done in conjunction with other pedestrian improvements that would move pedestrian crossing locations to mid-block sites independent of the roundabout. From a land use perspective, this is difficult, since it requires directing transportations away from their travel paths.
This is an area requiring much more research.
The proposal as presented is another example of introducing a regulation aimed at a dense urban environment that would be impractical or counter-productive in other environments. It should be more narrowly drafted.
Section 1105.7
Turn Lanes at Intersections. This section requires the provision of a pedestrian activated traffic signal at any right or left turn slip lane. My comments regarding roundabouts also apply to this recommendation.
The proposal as presented is another example of introducing a regulation aimed at dense urban environments or suburban environments with intense vehicular traffic; it would be impractical or counter-productive in other environments. It should be more narrowly drafted.
Slip lanes are introduced for many reasons. One important one is to accommodate the wide turning requirements of large vehicles with less pavement, especially at intersections with acute angles. This is desirable for all roadway users and can make pedestrian crossings easier to negotiate.
Slip ramps may be appropriate on low volume roadways if the roadways intersect at a very acute angle or if there are large vehicles that use the intersection. In this situation, a traffic signal could not meet any reasonable warrant; a roadway designer would likely prefer to construct a wide, unchannelized intersection rather than install a traffic activated pedestrian signal.
Even in urban locations, most pedestrians will ignore the pedestrian crossing device unless turning volumes are both high and continuous.
Alternative designs for slip ramps are needed that improve a driver's ability to observe pedestrians and yield to crossing pedestrians. These improved designs exist, and also substantially reduce crashes between motor vehicles. By employing detectable warnings at crossing locations in combination with improved slip ramps, the negative impacts currently experienced can be substantially reduced. Use of rumble strips on slip lanes in advance of crosswalks should be tested as a method of alerting persons with visual disabilities of the presence of an approaching vehicle and would also alert motorists of the crosswalk.
Finally, there is a need to establish a warrant based system to determine when pedestrian activated signals should be installed. I expect that this will usually only be necessary when the volume of turning traffic exceeds 1000 vehicles in the peak design hour.
Section 1106.2.1
Location of pedestrian signal devices. I may be misinterpreting this, but I think the last sentence should state that devices should be perpendicular to the direction of the crosswalk it serves. A device parallel to the crosswalk could not be seen. If I am misinterpreting your intent, others also will like do so.
Charles Carmalt
American Association of State Highway and Transportation Officials (AASHTO), October 23, 2002
[PDF Version]
James C. Codell, III, President
Secretary
Kentucky Transportation CabinetJohn Horsley
Executive Director
Mr. Scott Windley
Architectural and Transportation Barriers Compliance Board
Office of Technical and Informational Services
1331 F Street NW, Suite 1000
Washington, DC 20004-1111
SUBJECT: AASHTO Comments and Recommendations on the US Access Board's
Draft Guidelines for Accessible Public Rights-of-Way
In response to the federal notice of availability of the draft Guidelines for Accessible Public Rights-of-Way, the American Association of State Highway and Transportation Officials (AASHTO) respectfully submits the attached comments and recommendations. These comments were adopted by the AASHTO Board of Directors on October 14, 2002, and represent the official AASHTO recommendations on the draft accessibility regulations.
AASHTO would like to thank the US Access Board for the opportunity to comment on the draft guidelines at this early stage in their development. We believe that these guidelines will be an important step in improving accessibility on our transportation system throughout the country. In addition, AASHTO appreciates the Access Board's extensive outreach efforts in the preparation of the draft guidelines, including technical experts from the transportation and public works fields in addition to advocates for the disabled community.
However, as stated in the attached comments, additional work is needed to ensure that the final rule does not impose overwhelming costs and manpower demands, as well as liability exposure, on the State DOTs. AASHTO requests that the US Access Board provide cost estimates for the implementation of these guidelines to illustrate the potential financial impacts on the implementing agencies prior to the release of the Notice of Proposed Rule Making. In addition, we feel that several proposed guidelines will have unintended negative effects on safety and/or accessibility due to their restrictive wording. AASHTO recommends keeping the guidelines as flexible as possible to ensure that the best solution can be implemented in any given situation. AASHTO would like to offer its expertise and the expertise of its members to work cooperatively with the Access Board to refine specific technical issues and develop further guidance.
Finally, it should be noted that several million dollars worth of research is currently underway through such agencies as the National Institutes of Health and the Transportation Research Board that addresses many of the issues discussed in the draft guidelines. Research topics include pedestrian safety and accessibility at roundabouts and free-flow turn lanes, innovative treatments at unsignalized pedestrian crossings, and guidance on installing accessible pedestrian signals. AASHTO feels it would be premature to make final decisions on these issues without the benefit of the latest research.
Thank you for your consideration of the views of the State Transportation Departments as you develop a Notice of Proposed Rule Making on accessible public rights-of-way. If you have questions or need additional information on the attached material, please contact Dr. Anthony Kane, Director of AASHTO's Office of Engineering and Technical Services, at [ ... ].
Sincerely,
James C. Codell, III
President
Attachment
cc: John Horsley
Comments and Recommendations
on the
Draft Guidelines for
Accessible Public Rights-of-Way
Submitted to:
United States Architectural and Transportation Barriers Compliance Board
By:
American Association of State Highway
and Transportation Officials
October 2002
Adopted by resolution of the AASHTO Board of Directors
October 14, 2002
Contents:
Introduction
Broad Issues/Concerns
Technical Comments
Definitions
Areas of Primary Concern
Line-by-Line Comments and Recommendations
Resolution of the AASHTO Board of Directors
Comments and Recommendations on the Draft Guidelines for Accessible Public Rights-of-Way
October 2002
Introduction
AASHTO would like to thank the US Access Board for the opportunity to comment at this early stage on the draft Guidelines for Accessible Public Rights-of-Way. These guidelines will be an important step in improving accessibility for disabled persons throughout the country on our transportation system. We applaud the Access Board's inclusion of a wide range of people and expertise on the Public Rights-of-Way Access Advisory Committee, which developed the Building a True Community report, on which these draft guidelines are based. It is obvious that the work that went into developing the draft guidelines was extensive, and we appreciate these efforts.
As we enter the next phase of development, which includes the refinement of specific technical issues and the development of further guidance and research, AASHTO would like to offer its expertise and the expertise of its members in working cooperatively with the Access Board. Currently, the guidelines provide little or no allowance for engineering judgment to be exercised in the design and construction of these facilities to ensure the safety and welfare of the public, especially in situations where we feel the guidelines will produce unintended consequences. In many cases, extremely specific requirements have been set forth, and there appears to be very little room for developing alternate and sometimes better solutions. These issues need to be addressed appropriately before the release of a proposed rule.
The following pages contain AASHTO's comments on the draft guidelines, based on reviews by several State Department of Transportation (DOT) experts representing a cross-section of transportation engineering disciplines, including planning, design, construction, safety, maintenance, public transportation, and others. We feel that these responses represent "real life" concerns and issues that will be encountered if the guidelines are releases as-is, and that it would be better to address them now rather than wait until there are problems and conflicts in the implementation phase. AASHTO welcomes the opportunity to work cooperatively with the US Access Board to address these issues, and stands ready to offer assistance and expertise where it is needed.
Broad Issues/Concerns
. Maintenance Implications - It is unclear to AASHTO what type and amount of additional maintenance these regulations imply for the long term, as well as how often all aspects of the public right-of-way will need to be inspected for consistency with these accessibility guidelines. The increase in inspection, inventory, and maintenance that would be needed appears to be tremendous given the wide range of facilities and features that must be accommodated, including complex signal systems, street furniture, elevators, work zones, and additional signing. In addition, start-up costs for developing a system to track all of these features and mainstream them into DOT operations, as well as into the transportation funding approval process, will take a significant effort on the part of the States and local jurisdictions.
. Relationship to Other Regulations - AASHTO is also unclear as to how these proposed guidelines relate to other regulations that must be met within the transportation field, such as air quality, historical preservation, and environmental protection regulations. Many of the proposed accessibility guidelines, if implemented, could have profound impacts on the ability of States and local jurisdictions to meet these existing federal mandates. These conflicts could result in substantial penalties being levied or the denial of transportation funding if existing regulations are not met; or, conversely, they could result in the inability of the State or local area to implement portions of the accessibility guidelines in order to meet the existing laws. Additional details are included in the discussion of specific draft guidelines, but a few examples include the following:
? Air quality regulations could be an issue if numerous additional traffic signals are installed, or if traffic congestion is increased through the wholesale reduction in "green time" for motor vehicles.
? Historic preservation issues could be a problem if the alterations include the installation of non-historic treatments, such as concrete sidewalks in historic districts that are traditionally brick or stone, or infringements on historic buildings or properties.
? Environmental regulations may be in conflict with these guidelines where additional right-of-way is required, since a strong demonstration of need is required for such acquisitions.
It will need to be determined which regulations take precedence when there is a conflict and additional guidance will need to be provided to the State DOTs and others when this issue is resolved. Additional information should be sought from groups that deal with these issues on a regular basis.
. Cost Implications - Obviously, cost will always be an issue when new unfunded mandates are being proposed. As discussed in AASHTO's recent Bottom Line Report, 2002, estimated annual needs with regard to the nation's transportation system have reached $90 billion, while the current federal highway program hovers around $30 billion per year. This discrepancy represents a tremendous shortfall in funds, and it means that State DOTs and local jurisdictions are already stretching their dollars extremely thin. Several proposals contained in the draft guidelines would carve another sizable chunk out of the pie. Finding additional funding sources for these projects, as opposed to simply earmarking existing highway funding, would be a significant help in getting the needed accessible features out on the highway system in a timely manner. AASHTO calls on the US Access Board to provide cost estimates and a financial plan for the implementation of these guidelines to illustrate the potential financial impacts of their proposed solutions to accessibility issues on the implementing agencies prior to the release of the Notice of Proposed Rule Making. AASHTO is willing to work cooperatively with the Access Board in this endeavor.
Technical Comments
. Construction Tolerances - Tolerances within the highway construction industry are rarely to the nearest millimeter - and, in some cases, inches are too precise. Highway construction tolerances are not the same as those in architectural design. The Access Board needs to revise the units of measure used throughout these guidelines appropriately based on the item being measured. Examples of this excessive precision include the maximum curb ramp length of 4,570 mm and a maximum vertical change along the pedestrian access route of 6.4 mm. There is concern that this precision is not achievable in the field and that the State DOTs could be held liable if the dimensions of accessibility features are off by as little as a millimeter. At its Annual Meeting in October 2002, AASHTO funded a research project through the National Cooperative Highway Research Program (NCHRP), which is a subgroup of the National Academy of Sciences, to develop appropriate construction tolerances for the various items listed in the draft guidelines. The results of this study will be provided to the Access Board to assist in the development of appropriate highway construction tolerances within the proposed guidelines.
. Metric Conversions - Metric conversions should be soft conversions based on existing highway construction conversion standards. This will help minimize such odd and unachievable dimensions as 6.4 mm maximum change in vertical, 305 mm minimum post spacing, and 1,220 mm minimum pedestrian access route width.
. Notation for Slope - AASHTO recommends the use of current standard notation for slope, e.g., 1V:48H, which stands for "1 vertical to 48 horizontal," throughout the guidelines. This notation was developed to prevent confusion between the metric and US Customary notations, which are exactly opposite each other (1:48 in
In addition, AASHTO suggests using the terms "steeper" and "shallower," instead of "greater than" and "less than," when referring to slopes.
Definitions (from Section 1101.3, Defined Terms)
Proposed Revisions
. Accessible Pedestrian Signal - AASHTO proposes using the definition of Accessible Pedestrian Signal that is included in the Manual on Uniform Traffic Control Devices (MUTCD, 2000, p. 4A-1), which is a federally-mandated set of standards for the transportation industry: "A device that communicates information about pedestrian timing in non-visual format, such as audible tones, verbal messages, and/or vibrating surfaces."
. Cross Slope - Revise this definition in the draft guidelines by deleting the second sentence, which states: "This is usually called superelevation on curves in the public right-of-way (see superelevation)." This additional information is confusing and inaccurate from an engineering perspective, and the term "superelevation" does not appear in the draft guidelines. The definition for cross slope should be as follows: "The slope that is perpendicular to the direction of travel."
. Pedestrian Access Route - Refine this definition to state: "An accessible corridor intended for pedestrian use within the public right-of-way." AASHTO is concerned that highway projects such as shoulder closings in rural areas or pothole-filling projects on parts of the roadway not intended for pedestrian use (but which may, from time to time, be used by pedestrians) would invoke the need to provide an alternate circulation path, which would constitute a huge additional expense. In addition, it seems clear that it was not the Access Board's intent to require shoulders or other parts of the roadway (exclusive of the crosswalks) to fall under the other requirements in these guidelines, such as the maximum cross slope of 1V:48H (Section 1103.4) or the restriction on changes in level (Section 1103.8), but it is possible that this interpretation could be promulgated if the phrase "intended for" is not added to the definition.
Proposed Additions
. Alteration - A tremendous amount of clarification is needed related to the term "alteration," as well as the requirements that it triggers. Currently, this term is open to a wide range of interpretation, which is likely to expose public agencies to potential lawsuits. In addition, standard engineering terminology needs to be used to ensure that the requirements are understood and implemented correctly. If a concise definition cannot be developed that adequately explains the varying levels of alteration and their associated requirements/improvements, then additional guidance in this area will be necessary. AASHTO proposes working cooperatively with the Access Board to address this issue. (See also comments under Section 1102.2.2, Alterations.)
. Edge Delineation - AASHTO recommends removing the term "barrier" from the guidelines and replacing it with "edge delineation" or a similar phrase where appropriate. As currently used, the term "barrier" has a different meaning from that commonly understood by transportation engineers, which will lead to confusion regarding what is required or desired. The AASHTO Roadside Design Guide, a nationally recognized set of guidelines for roadside safety issues, defines "barrier" as follows:
A roadside barrier is a longitudinal barrier used to shield motorists from natural or man-made obstacles located along either side of a traveled way. It also may be used to protect bystanders, pedestrians, and cyclists from vehicular traffic under special conditions. (Roadside Design Guide, p. 5-1)
To the typical highway engineer, examples of barriers include the massive concrete "Jersey" barriers seen often along major freeways, steel or timber guardrail, and 3-strand cable systems. These barriers must meet very specific performance criteria to ensure that they can safely contain and redirect errant motor vehicles.
Based on the usage of the term "barrier" in the draft guidelines, it is assumed that barriers could include walls, raised lips, or even planting or vegetative strips. The primary purpose behind this type of barrier seems to be to indicate to the visually impaired that: 1) the sidewalk is diverging at a parallel curb ramp (Section 1104.2.2.4); or 2) they are leaving the pedestrian access route and they should redirect themselves appropriately (Section 1105.6.1). Serious consideration should be given to renaming this feature for clarification purposes, as well as to prevent the construction or installation of many unintended and undesired roadside features that could be safety hazards for motor vehicle users.
. Roadway - AASHTO recommends defining the term "roadway" to include bridges to ensure that the ADAAG requirements for "structures" (a common term for bridges in transportation engineering) are not applied to bridges. Bridges are natural extensions and connections of roadways and are part of the public right-of-way; thus, their accessibility requirements should be guided by the proposed guidelines for public rights-of-way. A simplified version of the definitions for "highway" and "roadway" found in the MUTCD (2001, p. 1A-16 and 1A-19) could be used: "The portion of the public way ordinarily used for vehicular travel, shoulder, or parking, inclusive of bridges, but exclusive of the sidewalk or curb."
. Roadway Preservation and Preventative Maintenance - AASHTO recommends using the following definition for roadway preservation and preventative maintenance, and feels that these activities should be exempt from the requirement to install additional accessibility features:
Roadway Preservation and Preventative Maintenance are activities undertaken to provide and maintain serviceable roadways and/or planned strategies of cost-effective treatments to an existing roadway and its appurtenances that preserve the system, retard future deterioration, and maintain the functional condition of the system. Also, the process used to extend the functional condition by adding longer life to the roadway surface without increasing the structural capacity of the roadway.
Proposed Deletions
. Running Slope - Both "grade" and "running slope" are used throughout the guidelines interchangeably. For example, the term "grade" is used in Section 1103.5 when referring to the Pedestrian Access Route, but "running slope" is used in Section 1105.2.3, which refers to crosswalks (which are part of the pedestrian access route). AASHTO recommends removing the term "running slope" from the guidelines and using "grade" consistently, since it is more common among transportation engineers.
. Superelevation - AASHTO recommends removing this term from the definitions since it is not used in the draft guidelines. However, if the Access Board includes it, then the definition needs to be clarified to ensure its accuracy: "The increased cross-slope on a roadway curve that assists in counteracting the lateral acceleration imposed on traveling vehicles."
Areas of Primary Concern
Section 1102.2.2 - Alterations
"Where existing elements or spaces in the public right-of-way are altered, each altered element or space shall comply with the applicable provisions of Chapter 11. EXCEPTION: In alterations, where compliance with applicable provisions is technically infeasible, the alteration shall comply to the maximum extent feasible."
Background
AASHTO's major concern with this section of the draft guidelines is that there is no clear definition of an "alteration." It appears that alterations, and the accessibility improvements that are associated with them, constitute a "sliding scale" where greater alterations will necessitate more substantial accessibility accommodations. While this seems logical, it is very much open to interpretation, which, in AASHTO's view, means open to litigation. It is unclear what specific types of modifications to the sidewalk, roadway, signals, etc., trigger accessibility improvements, and which improvements are required.
For example, does re-striping the roadway trigger any accessibility improvements? Filling potholes? Conducting underground utility work for significant distances? (Utility work is typically permitted, but not carried out, by the State DOT.) The question of modifications triggering accessibility improvements is also unclear in the area of traffic signal installations. For example, do signal bulb replacements trigger accessibility improvements? Signal re-timing? Signal head replacements/changes? Box hardware improvements? Pole relocation? There are so many different types of "alterations" and so many different interpretations of this term that additional guidance is necessary. To simplify the issue, it might be possible to tie accessibility improvements to standard categories of highway projects, such as "roadway preservation," "preventative maintenance," "rehabilitation," "reconstruction," etc.
Once the "trigger" has been determined, the next question becomes, "What accessibility improvements should reasonably be expected to be made?" For example, if pavement reconstruction is determined to be a "trigger," then does this necessitate constructing curb ramps? Widening the sidewalk? Reconstructing parking spaces? Installing accessible pedestrian signals? Depending on the extra cost and time added to the project to accomplish these improvements, which could be substantial depending on the type of project being undertaken, it is possible in such politically driven agencies as state and local transportation departments that a project could be postponed or pushed down the priorities list (due to lack of time and/or funds) in favor of more straight-forward projects that can be accomplished more quickly and easily.
In all such proposed guidance, standard engineering terminology needs to be used to ensure that the requirements of this section are understood and implemented correctly by the transportation agencies. If a concise explanation cannot be developed in the Guidelines that adequately details the varying levels of alteration and their associated requirements/improvements, then additional guidance in this area will be necessary.
Additional concerns of AASHTO surround the interpretation of the phrases "technically infeasible" and "maximum extent feasible." This terminology does not indicate a level of reasonableness in the construction of accessibility improvements, since almost anything is "technically" feasible. The more likely reason that the accessibility guidelines will not be met is due to significant social, economic, or cost constraints, such as tearing down or altering a building that abuts the existing right-of-way, conflicting with historic preservation issues, etc.
Related to the issue of "maximum extent feasible" is the determination of whether this has been accomplished. Who will make this determination? The US Department of Justice? The US Department of Transportation? If it becomes a self-certification process, how can a State DOT reduce its exposure to unnecessary and very expensive legal challenges? In this case, it would be helpful to State and local governments if a simple format were developed to document these decisions to help lessen the possibility of litigation and to help protect them in legal disputes.
Recommendations
1.) AASHTO proposes working with the Access Board to develop additional guidance related to the definition of "alterations" and the accessibility improvements they trigger, using typical highway construction/engineering terminology to ensure understanding by implementing agencies. Specific examples of alterations and their associated accessibility improvements would be extremely helpful. A "cookbook" type approach would be preferred by the State DOTs to help ensure that they are meeting the guideline and to assist in averting costly legal action by outside groups. Of primary concern is the potential for requiring accessibility improvements in conjunction with routine roadway preservation and preventative maintenance (see proposed definitions). AASHTO recommends exempting these work activities from triggering additional accessibility features.
2.) The phrases "technically infeasible" and "maximum extent feasible" should be removed from the text because they do not accurately portray the conditions surrounding the ability to implement certain guidelines. These terms are open to interpretation and present a very real concern to the DOTs regarding liability. Replacement terms could include "reasonable" or "practicable," which allow some room for the balancing of competing interests.
An option that should be considered as an alternative to using these terms would be to set a maximum cost limit, as a percentage of the highway construction project, which could be used to determine if an accessibility treatment is an unreasonable expenditure given the size of the project being undertaken. A process such as this would be easy to understand by the highway agencies and would prevent small projects from triggering huge associated investments that could lead to the cancellation of the project.
3.) AASHTO proposes to work cooperatively with the Access Board in the development of an "accessibility design exception" process to be used when it is not reasonable to install certain accessibility features. This process could be based on the existing design exception process that has been used in the transportation engineering field for decades. The process would serve to document and get appropriate sign-offs on the effort to meet the "maximum extent feasible" guideline (or other such replacement guideline) so that these types of decisions are not constantly litigated through the courts. Since the Federal Highway Administration (FHWA) will likely be the agency that adopts and regulates these provisions, it should be the entity to determine if the State DOT did its job "to the maximum extent feasible."
Section 1102.3 - Alternate Circulation Paths
"An alternate circulation path complying with [Section] 1111 shall be provided whenever the existing pedestrian access route is blocked by construction, alteration, maintenance, or other temporary conditions."
Section 1111.3 - Location [of Alternate Circulation Paths]
"The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street."
Background
This section of the guidelines calls for the construction of alternate circulation paths when the existing pedestrian access route (i.e., the sidewalk) is temporarily blocked. In addition, this alternate path must be accessible and must be provided on the same side of the street. AASHTO has serious concerns regarding these guidelines related to many different issues, including pedestrian safety, the location of the alternate path, the guideline's application to short-duration projects, the Board's definition of "other temporary conditions," liability exposure of the State DOTs, the apparent prohibition of street closures, and the likely increases in project cost and time. Requiring this provision in every situation will have serious unintended consequences that we feel confident the Access Board would prefer to avoid. AASHTO feels that existing standards found in the MUTCD more effectively address the need and proper consideration for alternate circulation paths.
While it may be preferable to have an alternate circulation path parallel to and on the same side of the street as the disrupted pedestrian access route, this is not always possible, nor is it always advisable. For example, in a situation where construction traffic must cross the same-side alternate circulation path, this guideline puts pedestrians in direct conflict with construction traffic. Thus, in this case, for pedestrian safety reasons, it would be preferable to have the alternate circulation path across the street or at some other location.
In addition to the safety issue, AASHTO feels that there are other considerations that must be addressed when determining where to locate the alternate circulation path. AASHTO interprets these guidelines to require infringements into the roadway (properly shielded) for the alternate circulation path when there are no other reasonable alternatives. However, AASHTO feels that there is a point at which the congestion, delay, and cost to vehicle users due to lane closures would outweigh the need to provide the alternate path on the same side of the street, and would thus warrant this requirement unreasonable (or in the Access Board's terminology, "technically infeasible"). In addition, depending on the extent or type of construction project (such as a utility repair or installation), the alternate path on the "same side of the street" may come very close to crossing the street, so the option should be available to properly close the sidewalk on the "construction side" of the street and utilize the pedestrian access route on the opposite side of the street.
It also appears that there was no consideration given to the length of time that a disruption to the pedestrian access route would occur. Would the design and construction of a properly protected alternate circulation path be required for a disruption of 15 minutes? 2 hours? There is no consideration for what would be reasonable from this standpoint - the guideline states that a same-side alternate circulation path must be constructed in every case. Especially for small, short-duration projects, this guideline would increase costs significantly, as well as increasing the time and effort, both in design and construction, needed to conduct these projects. In addition, there is tremendous concern from the State DOTs that they would be held responsible (and liable) for checking and enforcing accessibility compliance, even if the work being done is performed by another (or private) entity or a local jurisdiction. This would require substantial inspection time, money, and manpower that the DOTs do not have.
In addition to the length of time a disruption occurs, there is also a concern regarding the types of disruptions that could be considered "other temporary conditions." AASHTO understands that accommodations should be made during events such as street fairs, parades, and the like, but this guideline could also be interpreted to include such uncontrollable events as a moving company placing boxes or furniture on the sidewalk, or the accumulation of snow and ice, which strikes such large areas that it prevents any jurisdiction from providing accessible pedestrian facilities in all locations within a specified period of time. These situations need to be exempted from this requirement, or the applicable situations should be specified.
This guideline also appears to prohibit the closure of sidewalks under any circumstance, which could lead to the prevention of road closures during construction if they have sidewalks. It might also force the State DOT or local jurisdiction to construct a protected pedestrian path (or paths) through the construction area in the vicinity of the disrupted sidewalks, which could dramatically increase the cost and complexity of staging construction projects, as the contractor would have to work "around" the pedestrian path(s) and relocate it/them when work needs to be done in that area.
As currently written, the guideline conflicts with the existing federal standards for traffic control, contained in the Manual on Uniform Traffic Control Devices (MUTCD), which provide for an "alternate route," but not necessarily paralleling the original route. While this conflict does not indicate which guideline should be changed, AASHTO believes that the MUTCD does a much more effective job of addressing all of the concerns that must be considered in a work zone and, thus, better protects the pedestrian. The MUTCD states that "provisions should be made for persons with disabilities as determined by an engineering study." The draft guideline in Section 1111.3 essentially takes away the judgment of the engineer, who is responsible not only to oversee projects, but also to provide for the safe and efficient mobility needs of all citizens. In addition, the MUTCD accounts for many situations that the current guideline does not effectively address, such as pedestrian conflicts with work site vehicles, as noted in the excerpt below:
There are three considerations in planning for pedestrians in temporary traffic control zones:
A. Pedestrians should not be led into conflicts with work site vehicles, equipment, and operations.
B. Pedestrians should not be led into conflicts with vehicles moving through or around the work site.
C. Pedestrians should be provided with a safe, convenient path that replicates as nearly as possible the most desirable characteristics of the existing sidewalk(s) or a footpath(s).
Consideration should be made to separate pedestrian movements from other work site activity and motor vehicle traffic. Pedestrians should be appropriately directed with advance signing that encourages them to cross to the opposite side of the roadway. In urban and suburban areas with high motor vehicle traffic volumes, these signs should be placed at intersections so that pedestrians are not confronted with midblock work sites that will induce them to attempt skirting the work site or making a midblock crossing.
?Whenever it is feasible, closing off the work site from pedestrian intrusion may be preferable to channelizing pedestrian traffic along the site with temporary traffic control devices?.
From Manual on Uniform Traffic Control Devices, FHWA, 2001, Section 6D-01
In addition to conflicts with the MUTCD, the guideline also appears to conflict with the current Code of Federal Regulations (28 CFR 36.211, "Maintenance of accessible features") regarding the allowance for temporary closures, which states:
a) A public accommodation shall maintain in operable working condition those features of facilities and equipment that are required to be readily accessible to and usable by persons with disabilities by the Act or this part. b) This section does not prohibit isolated or temporary interruptions in service or access due to maintenance or repairs.
However, the phrase "temporary interruptions" is not well defined or explained, which leaves it open to interpretation.
Recommendations
AASHTO recommends using the language found in Section 6D-1 of the MUTCD, discussed previously, as the guideline for considering all issues related to alternate circulation paths.
However, if this language is not acceptable, then AASHTO strongly recommends providing reasonable alternatives for locating alternate circulation paths when same-side-of-street routes or routes through construction work zones are cost prohibitive, would involve significant safety concerns to pedestrians or motor vehicle occupants, or are otherwise ill-advised.
AASHTO also recommends that a minimum time period for access route closure be specified for which the construction of an alternate circulation path would be required, such as "closures that last for a period of 24 hours or greater" or "closures which last overnight." In addition, AASHTO recommends including an exemption from this guideline for full street closures, as these are sometimes needed for safe and efficient construction.
Finally, AASHTO recommends including an exemption for uncontrollable occurrences, such as snow and ice accumulation, from the list of "other temporary conditions." For example, the guideline could read, "?or other temporary conditions over which the local jurisdiction has control."
Section 1103.4 - Cross Slope [of the Pedestrian Access Route]
"The cross slope of the pedestrian access route shall be 1:48
Section 1105.2.2 - Cross Slope [of Crosswalks]
"The cross slope shall be 1:48
Background
This provision was included in the draft guidelines to assist manual wheelchair users in negotiating the pedestrian access route. Facilities with greater cross-slopes are difficult to traverse due to the natural tendency of the wheelchair to follow the downhill slope; thus, the wheelchair user must constantly correct for this occurrence, which greatly increases the level of exertion required.
As discussed in Section 1103.2 of the draft guidelines, crosswalks (in addition to sidewalks, ramps, and other features) are considered part of the pedestrian access route, to which this stipulation applies. (Note: mid-block crossings, including crosswalks and perpendicular ramps, are exempt from this requirement per Sections 1104.2.1.2 and 1105.2.2.) Thus, crosswalks across hilly roads will need to be "tabled" or flattened out to achieve the required two percent cross slope. AASHTO is extremely concerned about the implications of this requirement, which are extensive and far reaching.
The treatments used to achieve the required cross slope on crosswalks may not conform to existing highway design and construction standards, which puts the State DOTs at risk for lawsuits. Currently, many governmental entities have a liability defense when a public project is designed in accordance with prevailing design standards. Deviating from these design standards to accommodate a requirement on cross-slope - a requirement whose safety implications have not been studied - will result in a loss of a defense regarding the design of the roadway. Design exceptions, which are needed whenever roadway designs differ from existing standards, would be needed in many cases in order to construct these "tabled" crosswalks and intersections. These design exceptions would have to be defensible in court from a motor vehicle safety perspective.
In addition, tabling the crosswalk or intersection could require adjustments in the vertical alignment of the roadway well beyond the intersection which, depending on the road's design speed, may be significant. These adjustments could lead to significant costs to redesign and reconstruct existing intersections, including the relocation of drainage features, raising/lowering adjacent sidewalks, relocating or modifying underground and adjacent above-ground utilities, and constructing retaining walls. Street elevations may end up being different from the adjacent sidewalk elevations, which poses additional pedestrian access constraints. In addition, in many cases the roadway and associated sidewalk will have to steepened on either side of the intersection to accommodate the flattened intersection. For these reasons, at a minimum, existing intersections should be exempted from this provision. If this requirement is retained, it should apply only to new construction at a new location.
Tabling crosswalks or intersections may also have unintended negative impacts on the control and safety of motor vehicles and their occupants, as well as comfort issues for those with spinal cord injuries. These concerns are heightened for emergency vehicles. Loss of control of vehicles in urban areas could have tremendous safety implications for pedestrians alongside the roadway. In addition, maintenance costs for motor vehicle users are likely to be higher, and could be significant, as a result of tabling and other remediations. Tabling could also be of concern to bicyclists and motorcyclists, depending on how they are designed/constructed. For these reasons, AASHTO believes that this guideline needs modification, even for new construction.
Finally, as mentioned in the discussion of alterations, an "accessibility design exception" process is needed to determine when the "maximum extent feasible" has been achieved and to help minimize the number of costly legal challenges.
Recommendations
AASHTO proposes tying the implementation of this guideline to the existing topography in the project area. The guideline should state that the cross slope of a crosswalk should be the minimum possible while still providing a roadway design that meets accepted roadway design criteria. While the accommodation of disabled pedestrians is of immense importance, there are many other factors that must be considered in any given intersection design. The current draft guideline serves to take away the judgment of the engineer to provide a roadway facility that is safe and functional for all users. In some cases, as detailed above, "tabling" the intersection will have many unintended negative impacts.
If the above proposal is unacceptable, AASHTO proposes to work with the Access Board on the development of design examples to better assess the potential impacts of "tabling" on the existing roadway network. These impacts include, but are not limited to, construction costs, safety of pedestrians and motor vehicle occupants, accessibility of adjacent parts of the pedestrian access routes, and vehicle user costs.
Section 1103.8 - Changes in Level [in Pedestrian Access Routes]
"Changes in level shall comply with [Section] 303. Changes in level shall be separated horizontally 30 inches
Background
Though this section refers to an existing section of ADAAG for the definition of "changes in level," it is still a major concern for the State DOTs with regard to long-term maintenance.
This guideline refers to ADAAG Section 303, "Changes in Level," which allows for a maximum vertical change in level of ¼ inch (or ½ inch with a bevel). Though this level of precision is likely to be attainable in new construction (though the metric equivalents, 6.4 mm and 13 mm, are more problematic due to construction tolerances), it would be very difficult to maintain a ¼-inch maximum vertical change along all portions of the pedestrian access route for the life of the facility. The level of inspection and maintenance effort required to stay within these guidelines, including both manpower commitments and monetary costs, would be a great burden for the State DOTs, as well as for local transportation and public works departments. How often would inspection be required? Monthly? Semiannually? Yearly? And would every crack greater than ¼ inch require immediate repair?
In addition to the level of effort, time, and cost required, there would be severe liability issues for State DOTs and local jurisdictions in attempting to maintain facilities to the exacting requirements stated in this guideline. Every crack or separation with a vertical height greater than ¼ inch on a sidewalk would be a potential lawsuit. This size crack, unfortunately, is very common and is almost impossible to prevent. Facilities in the public right-of-way, such as sidewalks, are not constructed to the same tight standards as large commercial office buildings - to do so would increase costs significantly. In addition, sidewalks and crosswalks are subjected to external forces, such as tree roots, heavy vehicles, and snow removal equipment, that contribute to their deterioration and with which buildings do not have to contend. Thus, the construction tolerances for indoor, architect-designed structures are not transferable to these facilities.
Recommendations
AASHTO has recently funded a research study through the NCHRP program to look into appropriate construction tolerances for the facilities discussed in these guidelines and recommends that the Access Board "reserve" this section until the project is complete, which should be in Summer 2003. In addition, AASHTO proposes working with the Access Board to determine appropriate and achievable monitoring systems for these issues, including such things as reasonable monitoring cycles and response times for needed corrections.
Section 1104.2 - Types [of Curb Ramps and Blended Transitions]
"Perpendicular curb ramps shall comply with [Sections] 1104.2.1 and 1104.3; parallel curb ramps shall comply with [Sections] 1104.2.2 and 1104.3; blended transitions shall comply with [Sections] 1104.2.3 and 1104.3."
Background
AASHTO assumes that the Access Board, by omission, is proposing to disallow diagonal ramps. This restriction would be problematic for many State DOTs that routinely use these features effectively. It is common practice to use diagonal ramps in certain situations and, in fact, it is required by law in at least one state. While it is true that diagonal ramps lack certain characteristics that are helpful to the blind community, such as directionality, they also have characteristics that are advantageous in other situations. Disallowing diagonal ramps limits the options of a design engineer for use in locations where they may be appropriate.
For example, at intersections with large curb radii, it is difficult to place curb ramps within the extended lines of the sidewalk. To maintain a perpendicular transition from the ramp to the roadway at these locations, as required in Section 1104.2.1, the ramp must be placed outside the curb return. This necessitates locating the crosswalk farther from the intersection, which has safety and visibility implications for both pedestrians and vehicles. The Building a True Community report developed by the Public Rights-of-Way Access Advisory Committee (PROWAAC) included many cases where the construction of diagonal ramps is necessitated by the intersection geometry, so it is unclear why the Access Board chose to disallow them.
In addition to the issues associated with new construction, there are also questions regarding how to handle existing diagonal ramps. Does the omission of diagonal ramps from this guideline require replacing them with parallel or perpendicular curb ramps when an alteration is being done in the intersection? If this is required, what level of alteration triggers the requirement to replace the diagonal ramp?
Recommendations
AASHTO recommends including diagonal ramps in the guidelines as an acceptable option for use in appropriate situations.
Sections 1105.6, 1105.6.1, and 1105.6.2 - Roundabouts, including Separation and Signals
Section 1105.6 - Roundabouts: "Where pedestrian crosswalks and pedestrian facilities are provided at roundabouts, they shall comply with [Section] 1105.6."
Section 1105.6.1 - Separation [at Roundabouts]: "Continuous barriers shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited. Where railings are used, they shall have a bottom rail 15 inches
Section 1105.6.2 - Signals [at Roundabouts]: "A pedestrian activated traffic signal complying with [Section] 1106 shall be provided for each segment of the crosswalk, including the splitter island. Signals shall clearly identify which crosswalk segment the signal serves."
Background
These sections have significant implications for the future operation of roundabouts, and AASHTO is seriously concerned that these guidelines will effectively negate the advantages that their expanded implementation could provide in the United States. Based on extensive positive experiences in European countries, roundabouts are being introduced in projects throughout the nation because they provide many advantages over traditional stop-controlled intersections: 1) they reduce delay (and increase vehicle throughput) by slowing traffic at the intersection through the use of visual cues and turning movements without stopping it; 2) because of this reduction in speed, they reduce the severity of intersection crashes that occur when stop signs are missed or disregarded; and 3) they aid in improving air quality by reducing the number of vehicle stops.
The phrase "continuous barriers" implies roadside hardware, such as steel guardrail or concrete traffic barriers, to the traffic engineering community. With respect to the separation of pedestrians from traffic at roundabouts, AASHTO feels that constructing barriers such as these around roundabouts may actually decrease safety for drivers and could even trap misdirected blind pedestrians within the roundabout. In addition, the use of standard roadway barriers at intersections is undesirable due to their height and the resulting impact on sight distance available to drivers. Design engineers strive to ensure that there are no obstructions between 2 feet and 7 feet
As for signalization, it should be noted that the stopping of traffic is contrary to the philosophy of roundabouts and will defeat the purpose of constructing them. In addition to this, signalizing each intersection in the roundabout will be costly due to the sheer number of installations that would be needed, as well as dangerous to both drivers and pedestrians. Drivers are less likely to expect a traffic signal within a roundabout and may not react to it in time for safe pedestrian crossings. In addition, given the tight geometrics of the typical roundabout, placing the necessary signals in locations where they can be seen and where they will be easily understood as regulating traffic on a given portion of the roundabout will be extremely difficult. It is likely that these signals will give the pedestrian a false sense of safety when stepping out onto the roadway. Drivers are also unlikely to expect a queue within the roundabout, which will likely result in increased rear-end crashes and, potentially, subsequent impacts with pedestrians.
Recommendations
AASHTO recommends "reserving" Sections 1105.6 through 1105.6.2 until NCHRP Project 3-65, Applying Roundabouts in the United States, is complete, which is anticipated in June 2005. This $700,000 study, which is just getting underway, will investigate and propose recommendations for the safety and operation of roundabouts, including "the effects of different design configurations on the safety of bicycles and pedestrians, particularly pedestrians with disabilities." Because of the concerns this section of the guidelines has raised within the transportation community, AASHTO will be seeking additional funding for this project to both accelerate the study as well as to look more comprehensively at pedestrian accessibility issues.
After completion of this study, AASHTO recommends developing a joint working group with the Access Board, including experts from the traffic engineering, roadway design, and operations disciplines, to find mutually beneficial solutions to provide for safe and accessible pedestrian movements at roundabouts.
Section 1105.2.1 - Width [of Crosswalks]
"Marked crosswalks shall be 96 inches
Background
The current edition of the MUTCD requires a 72-inch minimum crosswalk width, while the draft guidelines require an extra two feet in all cases. This requirement for a 96-inch crosswalk does not appear to be driven by accessibility needs. While major metropolitan areas may need extra width in their crosswalks to handle large platoons of pedestrians, the decision to provide extra width should be made by considering relevant factors at a specific location and should not be mandated here.
Eight-foot wide crosswalks are excessive in many small rural towns where few pedestrians are present. In addition, the additional 24 inches
Recommendations
AASHTO recommends that these guidelines remain consistent with the MUTCD, retaining the 72-inch minimum crosswalk width.
Section 1105.3 - Pedestrian Signal Phase Timing
"All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
Background
AASHTO is very concerned about this guideline, as the slower crossing speeds and longer distance for calculating the traffic signal timing will have a significant effect on traffic flow, especially in major metropolitan areas where congestion is already heavy. This guideline will slow the walking speed down by 25% (from 4 feet
The MUTCD, which contains the current federal standards for traffic signal timing, has widely accepted criteria for walking speeds and distances. Current guidelines in the MUTCD recommend the use of 4 fps, with slower speeds to be used when conditions indicate a slower speed is appropriate. In addition, the minimum distance to be used for calculating pedestrian signal phase timing is from the curb on one side of the street to the center of the farthest traveled lane on the opposite side, or to a median of sufficient width for pedestrians to wait.
The current design criteria allow the designer the flexibility to tailor the timing design of each intersection. Decreasing the walk speed at all intersections to a maximum of 3 fps will increase the duration of the signal phases that have a pedestrian component. This change will either increase the cycle length or require an inequitable split of the existing cycle. The end result will be increased delay and congestion.
The increased distance required for calculating the pedestrian signal timing, due to the inclusion of the ramp distance, will further exacerbate the impact of this guideline. The extra distance could add a minimum of 10 feet
This guideline will especially have impacts on arterial highways and other corridors with coordinated traffic signals that are used to keep traffic moving smoothly through multiple intersections. The changes proposed in this guideline could throw off timing and traffic progression in these corridors - which is critical for keeping traffic flowing smoothly - and potentially throw them into gridlock. It would be a massive effort to re-time these crucial corridors. In addition, any increase in delay at traffic signals will diminish the efforts of state and local governments to improve air quality, which is greatly affected by stop-and-go traffic, as required by the Clean Air Act.
Using the current MUTCD guidelines, the designer has the option to use the slower speed and longer distance when conditions warrant. The designer also has the opportunity to specify a pedestrian signal button that can be used to request a longer crossing time when needed, such as with an extended button push or other mechanism. A solution such as this would have far fewer impacts on the flow of traffic and would serve to provide accessibility and mobility for all citizens at a reasonable cost.
Recommendations
AASHTO recommends maintaining the design criteria for traffic signals as defined in the MUTCD. Language can be added regarding when a slower walk speed or longer distance would be appropriate for an intersection, and/or the appropriate application of push-buttons to select an extended crossing time.
Section 1105.5.3 - Approach [for Pedestrian Crossings]
"Where the approach exceeds 1:20
Background
The current ADAAG (Section 405.6) has established a maximum rise of 30 inches
AASHTO is extremely concerned about the ramifications of this guideline on existing pedestrian routes at grade-separated interchanges and bridges, since it will essentially require elevators to connect all routes between the upper and lower roadways. It will also have major cost implications for new grade separation projects, which have benefits for pedestrians such as removing at-grade crossings and allowing the direct crossing of major facilities such as freeways without having to divert to adjacent interchanges. These increased costs may lead to a decreased use of pedestrian over/underpasses. It could also lead to a decreased use of sidewalks on the upper portions of grade-separated roadways, since these will necessitate the addition of elevators. It will also likely limit the installation of new pedestrian facilities if they are not currently present at over/underpass locations.
Elevators, in addition to significantly increasing design and construction costs, will cause an increase in maintenance needs and operating costs. There are also security concerns, as they would require increased monitoring by police or other security patrols to ensure that they do not become a haven for thieves, drug addicts, or the homeless. Also, it seems possible that stairs and/or ramps would still be required at these locations to ensure continuous access in the event that the elevators are inoperative. In addition, it is not clear whether each pedestrian route at an overpass or underpass would require an elevator. For example, if a four-legged intersection is replaced with an overpass, would four elevators be required so that no road crossings are required? Finally, due to the high installation and maintenance costs of elevators, it is extremely important to define the level of alteration that would require their installation at existing locations.
Recommendations
AASHTO recommends allowing for alternate solutions, such as innovative ramp and landing designs that could reduce the impact of the rise to the pedestrian, or other reasonable mechanical means for providing accessibility. Elevators could be options for the designer in areas with high pedestrian volumes or other conditions that would warrant them, but should not be mandated as the only solution for elevation changes of five feet or more.
Section 1105.7 - Turn Lanes at Intersections
"Where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal complying with [Section] 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island."
Background
Similar to the proposal to signalize roundabouts, AASHTO is extremely concerned about the ramifications of installing traffic signals at free-flow turn lanes. Signalizing these locations may actually decrease the safety of pedestrians and vehicles for many of the same reasons mentioned in the comments on signals in roundabouts. The installation of a traffic signal, or any type of traffic control, is typically the result of an extensive traffic engineering study that determines whether such a device is warranted and in the community's best interest. The MUTCD, which provides guidance for determining when signals are warranted, is based on years of experience and its guidance is familiar to the general public. Drivers do not expect to find a traffic signal at a slip lane and may not react to it in time for safe pedestrian crossings, especially if it is only occasionally activated. It is also likely that these signals will give the pedestrian a false sense of safety when stepping out onto the roadway. When activated sporadically, it will likely result in increased rear-end crashes and, potentially, subsequent impacts with pedestrians. A regulation such as this guideline, which throws out or ignores existing traffic engineering knowledge and regulations, should not be implemented.
In addition, signals are likely to have significant operational impacts on slip lanes - lowering traffic throughput in these locations - and will effectively negate the advantages they provide at high traffic volume intersections. It should be noted that any increase in delay at traffic signals will diminish efforts by state and local governments to improve air quality as required by the Clean Air Act. Furthermore, it is unclear whether this guideline is also intended to be applied to slip lanes at unsignalized intersections, which would contribute to even more confusion and potential danger for drivers and pedestrians alike. Overall, traffic signals should only be installed after a traffic engineering study has been conducted that indicates that a traffic signal is warranted.
Currently, NCHRP is embarking on two research studies related to this guideline. The first study is NCHRP Project 3-72, Lane Widths, Channelized Right Turns, and Right Turn Deceleration Lanes in Urban and Suburban Areas. As the name implies, the primary objective of the study is to develop design guidance or criteria addressing the safety and operational trade-offs of motorists, pedestrians, and bicyclists in three specific situations: selecting lane widths, channelizing right turns, and using right-turn deceleration lanes at driveways and unsignalized intersections. The study will focus on urban and suburban arterial highways with speeds of 45 miles per hour or less. In addition, the study will consider the needs of a full range of pedestrian ages and visual, as well as other, impairments. The output will include recommended language for the AASHTO "Green Book," the forthcoming AASHTO Pedestrian Guide, the AASHTO Bicycle Facilities Guide, the MUTCD, and the Traffic Control Devices Handbook. Proposals for this 2-year, $450,000 study are due in December 2002.
The second NCHRP study related to this guideline is Project 3-71, Innovative Pedestrian Treatments at Unsignalized Crossings. This project, funded at $550,000, will identify and study enhanced pedestrian treatments that are currently being used at unsignalized locations across the country to determine which ones are effective. Treatments to be studied include Yield to Pedestrian signs, in-roadway crosswalk lighting, median refuge islands, placement of an advance yield line at mid-block crosswalks, and overhead supplemental devices.
In addition, the National Institutes of Health are embarking on a study of pedestrian issues that should include information right-turn lanes.
Recommendations
AASHTO recommends "reserving" Section 1105.7, "Turn Lanes at Intersections," until further research can be conducted. AASHTO proposes working with the Access Board to develop alternative solutions for this issue when this research is complete.
Section 1106.1 - General [Accessible Pedestrian Signal Systems]
"Pedestrian signal systems shall comply with [Section] 1106."
Background
Section 1106 will require the installation of Accessible Pedestrian Signal (APS) systems at all existing signalized intersections with pedestrian indications. This will be a major cost item for State DOTs and local municipalities.
The added complexity of the systems will increase installation time and cost, as well as maintenance needs. In addition, the greater complexity of these systems will likely increase maintenance and down-time and make the system less user friendly. The increased number of components required for APS systems also makes the placement of the devices more difficult.
AASHTO supports the concept of providing APS systems to deliver consistent and unambiguous information to assist in the safe and efficient pedestrian crossing of an intersection, but believes that additional research is required. In support of this, the National Cooperative Highway Research Program has an ongoing project - NCHRP Project 3-62, Guidelines for Accessible Pedestrian Signals - that is expected to be completed in October 2004. This research project will develop guidelines and training materials for use by the State DOTs in implementing accessible pedestrian signals.
Recommendations
AASHTO recommends "reserving" Section 1106 until further research is conducted, or at least until the current NCHRP project on APS systems is complete to ensure a logical and comprehensive approach to installing these devices.
AASHTO Comments and Recommendations on the Draft Guidelines for Accessible Public Rights-of-Way
Line-by-Line Review
SECTION / TITLE / DRAFT GUIDELINE / COMMENTS AND RECOMMENDATIONS
1101 Application and Administration
1101.1 General. For the purposes of these requirements, the terms listed in section 1101.3 shall have the indicated meaning.
1101.2 Referenced Standards.
1101.2.1 MUTCD. Copies of the referenced standards may be obtained on-line from the Federal Highway Administration at http://mutcd.fhwa.dot.gov. MUTCD 2000-Millennium Edition Manual on Uniform Traffic Control Devices.
1101.3 Defined Terms.
Accessible Pedestrian Signal. A device that communicates information about the pedestrian WALK phase in non-visual format. See discussion and recommendations in Definitions Section.
Accessible Route. A continuous, unobstructed path that complies with Chapter 4.
Channelizing Island. Curbed or painted area outside the vehicular path that is provided to separate and direct traffic movement, which also may serve as a refuge for pedestrians.
Cross Slope. The slope that is perpendicular to the direction of travel. This is usually called superelevation on curves in the public right-of-way (see superelevation). See discussion and recommendations in Definitions Section.
Crosswalk. That part of a roadway at an intersection that is included within the extensions of the lateral lines of the sidewalks on opposite sides of the roadway, measured from the curbline or, in the absence of curbs, from the edges of the roadway or, in the absence of a sidewalk on one side of the roadway, the part of the roadway included within the extension of the lateral lines of the sidewalk at right angles to the centerline. Also, any portion of a roadway at an intersection or elsewhere that is distinctly indicated for pedestrian crossing by lines or other markings on the surface.
Curb Line. A line at the face of the curb that marks the transition between the sidewalk and the gutter or roadway.
Curb Ramp. A ramp cutting through a curb or built up to it.
Detectable Warning. A surface feature built in or applied to walking surfaces or other elements to warn of hazards on a circulation path.
Dynamic Envelope. The clearance required for a rail vehicle and its cargo overhang due to any combination of loading, lateral motion, or suspension failure.
Element. An architectural or mechanical component of a building, facility, space, site or public right-of-way.
Facility. All or any portion of buildings, structures, improvements, elements and pedestrian or vehicular routes located on a site or in a public right-of-way.
Grade. (See running slope).
Grade Break. The meeting line of two adjacent surfaces of different slope (grade).
Locator Tone. A repeating sound that identifies the location of the pedestrian push button.
Pedestrian Access Route. An accessible corridor for pedestrian use within the public right-of-way. See discussion and recommendations in Definitions Section.
Public Right-of-Way. Land or property, usually in a corridor, that is acquired for or devoted to transportation purposes.
Roundabout. A circular intersection that has yield control of entering traffic, channelized approaches, counterclockwise circulation, and appropriate geometric curvature to limit travel speeds on the circulatory roadway.
Running Slope. The slope that is parallel to the direction of travel expressed as a ratio of rise to run. In the public right-of-way, this is usually called grade, and is expressed in percent.
Sidewalk. That portion of a public right-of-way between the curb line or lateral line of a roadway and the adjacent property line that is improved for use by pedestrians.
Splitter Island. A flush or raised island that separates entering and exiting traffic in a roundabout.
Street Furniture. Elements in the public right-of-way that are intended for use by pedestrians.
Superelevation. Cross slope on a curve in the roadway (see cross slope). See discussion and recommendations in Definitions Section.
Walk Interval. That phase of a traffic signal cycle during which the pedestrian is to begin crossing, typically indicated by a WALK message or the walking person symbol and its audible equivalent.
1102 Scoping Requirements
1102.1 General. All areas of newly designed and newly constructed facilities in public rights-of-way and altered portions of existing facilities in public rights-of-way shall comply with Chapter 11. See discussion of and recommendations for Section 1102.2.2, Alterations, in Areas of Primary Concern section.
1102.2 Existing Public Rights-of-Way. Additions to existing public rights-of-way shall comply with 1102.2.1. Alterations to existing public rights-of-way shall comply with 1102.2.2. See discussion of and recommendations for Section 1102.2.2, Alterations, in Areas of Primary Concern section.
1102.2.1 Additions. Each addition to an existing public right-of-way shall comply with the applicable provisions of Chapter 11. Where the addition connects with existing construction, the connection shall comply with 1102.2.2. Comments: Need clarification regarding how accessible facilities "connect" to existing construction. Does the "connection" refer only to the sidewalk, or does it include the pedestrian signals and/or other features?
Recommendations: Recommend clarification of the types pf treatments necessary when "connecting" with existing construction.
1102.2.2 Alterations. Where existing elements or spaces in the public right-of-way are altered, each altered element or space shall comply with the applicable provisions of Chapter 11. EXCEPTION: In alterations, where compliance with applicable provisions is technically infeasible, the alteration shall comply to the maximum extent feasible. See discussion of and recommendations for Section 1102.2.2, Alterations, in Areas of Primary Concern section.
1102.2.2.1 Extent of Application. An alteration of an existing element, space, or area of a public right-of-way shall not impose a requirement for accessibility greater than required for new construction.
1102.2.2.2 Prohibited Reduction in Access. An alteration that decreases or has the effect of decreasing the accessibility of a public right-of-way or site arrival points to buildings or facilities adjacent to the altered portion of the public right-of-way, below the requirements for new construction at the time of the alteration is prohibited.
1102.3 Alternate Circulation Path. An alternate circulation path complying with 1111 shall be provided whenever the existing pedestrian access route is blocked by construction, alteration, maintenance, or other temporary conditions. See discussion of and recommendations for Sections 1102.3, Alternate Circulation Path, and 1111.3, Location [of Alternate Circulation Paths], in Areas of Primary Concern section.
1102.4 Sidewalks. Where sidewalks are provided, they shall contain a continuous pedestrian access route complying with 1103. The pedestrian access route shall connect to elements required to comply with Chapter 11.
1102.5 Protruding Objects. Protruding objects on sidewalks and other pedestrian circulation paths shall comply with 1102.5 and shall not reduce the clear width required for pedestrian accessible routes.
1102.5.1 Protrusion Limits. Objects with leading edges more than 27 inches
1102.5.2 Post-Mounted Objects. Free-standing objects mounted on posts or pylons shall overhang circulation paths 4 inches
1102.5.3 Reduced Vertical Clearance. Guardrails or other barriers shall be provided where the vertical clearance is less than 80 inches
1102.6 Curb Ramps and Blended Transitions. A curb ramp or blended transition complying with 1104, or a combination of curb ramps and blended transitions, shall connect the pedestrian access routes to each street crossing within the width of each crosswalk. Comments: The placement recommendations for curb ramps could increase construction costs, but the impact is expected to be minimal.
1102.7 Pedestrian Signs. Signs for pedestrian use shall comply with 1102.7.
1102.7.1 Bus Route Identification. Bus route identification signs shall comply with 703.5.1 through 703.5.4, and 703.5.7 and 703.5.8. In addition, to the maximum extent practicable, bus route identification signs shall comply with 703.5.5. Bus route identification signs located at bus shelters shall provide raised and Braille characters complying with 703.2, and shall have rounded corners. EXCEPTIONS 1: Bus schedules, timetables and maps that are posted at the bus stop or bus shelter shall not be required to comply with 1102.7. 2: Signs shall not be required to comply with 703.2 where audible signs are user- or proximity-actuated or are remotely transmitted to a portable receiver carried by an individual.
1102.7.2 Informational Signs and Warning Signs. Informational signs and warning signs shall comply with 703.5.
1102.8 Pedestrian Crossings. Where a pedestrian crossing is provided, it shall comply with the applicable provisions of 1105. Where pedestrian signals are provided at a pedestrian crossing, they shall comply with 1106. See comments and recommendations in Sections 1105 and 1106.
1102.9 Street Furniture. Street furniture that is intended for use by pedestrians and installed on or adjacent to a sidewalk shall comply with 309 and 1107. See comments and recommendations in Section 1107.
1102.10 Stairs. Where provided, stairs shall comply with 504. Stair treads shall have a 2 inch
1102.11 Handrails. Where provided, handrails shall comply with 505.
1102.12 Vertical Access. Where provided elevators shall comply with 407, limited-use/limited-application elevators shall comply with 408, and platform lifts shall comply with 410. Vertical access shall remain unlocked during the operating hours of the facility served.
1102.13 Bus Stops. Bus boarding and alighting areas shall comply with 810.2. Bus shelters shall comply with 810.3. Comments: The bus stop pads and shelter requirements should have minimal impact to state and transit agencies because requirements are similar to previous editions.
Recommendations: For clarification purposes, recommend repeating language from ADAAG Section 810.3 in
1102.14 On-Street Parking. Where on-street parking is provided, at least one accessible on-street parking space shall be located on each block face and shall comply with 1109. Comments: 1.) While this guideline attempts to propose a simple way to determine the number of accessible parking spaces in public rights-of-way, it has several unintended impacts that need to be addressed. In particular, in urban areas this provision may create a significantly higher proportion of accessible spaces than intended by the Access Board on smaller blocks (based on their commentary), due to existing restrictions, such as driveways, fire hydrants, setbacks from corners, etc. In general, one space per block face will result in a significant increase in the number of spaces as compared to ADAAG Section 208 and Table 208.2. 2.) If an entire block has parking spaces of the same dimension as an accessible space, do certain spaces need to be restricted for use as accessible spaces? 3.) Challenges are anticipated with drainage needs. See additional comments in Section 1109.
Recommendations: 1.) Recommend a combination of wording for accessible parking spaces of existing ADAAG and proposed guideline: "1 accessible space per 25 spaces, not to exceed 1 accessible space per block face."
1102.15 Passenger Loading Zones. Where passenger loading zones are provided, they shall connect to a pedestrian access route and shall provide a minimum of one passenger loading zone in every continuous 100 linear feet (30 m) of loading zone space, or fraction thereof, complying with 302, 503.2, 503.3, and 503.5. Comments: Anticipated impacts are expected to be minimal.
1102.16 Call Boxes. Where provided, call boxes shall comply with 1110.
1103 Pedestrian Access Route
1103.1 General. Pedestrian access routes shall connect to elements required to be accessible and shall comply with 1103.
1103.2 Components. Pedestrian access routes shall consist of one or more of the following components: walking surfaces, ramps, curb ramps, blended transitions, crosswalks, pedestrian overpasses and underpasses, elevators, and platform lifts. All components of a pedestrian access route shall comply with the applicable portions of this chapter.
1103.3 Clear Width. The minimum clear width of a pedestrian access route shall be 48 inches
Recommendations: 1.) Recommend allowing a reduction in the clear width of the accessible pedestrian route to 32" for short distances, similar to existing ADAAG section 403.5.1
1103.4 Cross Slope. The cross slope of the pedestrian access route shall be 1:48
1103.5 Grade. The grade of the pedestrian access route within a sidewalk shall not exceed the grade established for the adjacent roadway. EXCEPTION: The running slope of a pedestrian access route shall be permitted to be steeper than the grade of the adjacent roadway, provided that the pedestrian access route is less than 1:20
Recommendations: Recommend exempting ramps from this requirement. Also recommend that the sidewalks be allowed to exceed the roadway grades when necessary to tie into the level landing at the top of a perpendicular ramp.
1103.6 Surfaces. The surfaces of the pedestrian access route shall comply with 302.
1103.7 Surface Gaps at Rail Crossings. Where the pedestrian access route crosses rail systems at grade, the horizontal gap at the inner edge of each rail shall be constructed to the minimum dimension necessary to allow passage of railroad car wheel flanges and shall not exceed 2-½ inches (64 mm). EXCEPTION: On tracks that carry freight, a maximum horizontal gap of 3 inch
Recommendations: Recommend an exemption from this requirement until at least 4 years after appropriate gap closure technology is approved by the Federal Railroad Administration (FRA).
1103.7.1 Detectable Warnings. Where rail systems cross pedestrian facilities that are not shared with vehicular ways, a detectable warning shall be provided in compliance with 1108. See discussion and recommendations in Section 1108.
1103.8 Changes in Level. Changes in level shall comply with 303. Changes in level shall be separated horizontally 30 inches
1103.8.1 Rail Crossings. Where the pedestrian access route crosses rail systems at grade, the surface of the pedestrian access route shall be level and flush with the top of the rail at the outer edge and between the rails.
1104 Curb Ramps and Blended Transitions
1104.1 General. Curb ramps and blended transitions shall comply with 1104.
1104.2 Types. Perpendicular curb ramps shall comply with 1104.2.1 and 1104.3; parallel curb ramps shall comply with 1104.2.2 and 1104.3; blended transitions shall comply with 1104.2.3 and 1104.3. See discussion on Section 1104.2, Types [of Curb Ramps and Blended Transitions], in Areas of Primary Concern section.
1104.2.1 Perpendicular Curb Ramps. Perpendicular curb ramps shall comply with 1104.2.1, and shall have a running slope that cuts through the curb at right angles or meets the gutter grade break at right angles.
1104.2.1.1 Running Slope. The running slope shall be 1:48
Recommendations: Recommend adding the following text to Section 1104.2.2.1: "EXCEPTION: A perpendicular curb ramp shall not be required to exceed 15 feet
1104.2.1.2 Cross Slope. The cross slope shall be 1:48
1104.2.1.3 Landing. A landing 48 inches
1104.2.1.4 Flares. Flared sides with a slope of 1:10
Recommendations: Recommend changing the wording of this guideline to something similar to the "Building a True Community" Report: "The length of the flares shall be at least ten times the curb height, measured along the curb line."
1104.2.2 Parallel Curb Ramps. Parallel curb ramps shall comply with 1104.2.2, and shall have a running slope that is in-line with the direction of sidewalk travel. Recommendations: Recommend modifying wording for clarification: "?running slope that is parallel to the curb."
1104.2.2.1 Running Slope. The running slope shall be 1:48
Recommendations: Recommend keeping the "exception," as well as clarifying what specific dimension it refers to. Also recommend adding language which states that if the slope of a parallel curb ramp is steeper than 1V:20H, it does not invoke the requirements of Section 405 of ADAAG, i.e., handrails, etc.
1104.2.2.2 Cross Slope. The cross slope shall be 1:48
1104.2.2.3 Landing. A landing 48 inches
1104.2.2.4 Diverging Sidewalks. Where a parallel curb ramp does not occupy the entire width of a sidewalk, drop-offs at diverging segments shall be protected with a barrier. Comments: 1.) Is a barrier required for a minimal drop-off of a couple inches or less? Can it be sloped like the flared section of a perpendicular ramp? 2.) Should there be a recommendation for a minimum sidewalk width in which the entire sidewalk should be used for the parallel ramp?
Recommendations: 1.) Recommend allowing alternate treatments for delineating diverging segments of sidewalk at parallel curb ramps. 2.) Recommend stating a minimum width for sidewalk diverges to ensure that an unusable space is not created. 3.) Further guidance, including diagrams, would be helpful. See also discussion of "Barrier" in the Definitions section of the Overview Document.
1104.2.3 Blended Transitions. Blended transitions shall comply with 1104.3, and shall have running and cross slopes of 1:48
1104.3 Common Elements. Curb ramps and blended transitions shall comply with 1104.3.
1104.3.1 Width. The clear width of landings, blended transitions, and curb ramps, excluding flares, shall be 48 inches
1104.3.2 Detectable Warnings. Detectable warning surfaces complying with 1108 shall be provided, where a curb ramp, landing, or blended transition connects to a crosswalk. Comments: 1.) If a 1V:15H slope is considered detectable by various disabled groups, the State DOTs would welcome the reduction in cost that not having to install detectable warnings at these locations would provide. 2.) Does the crosswalk reference exclude driveways, parking spaces, and other features?
Recommendations: 1.) Recommend allowing the construction of ramp slopes steeper than 1V:15H without detectable warnings, as discussed in the commentary section of the draft guidelines. See also comments in Section 1108. 2.) Recommend clarification on locations for detectable warnings.
1104.3.3 Surfaces. Surfaces of curb ramps, blended transitions, and landings shall comply with 302. Gratings, access covers, and other appurtenances shall not be located on curb ramps, landings, blended transitions, and gutter areas within the pedestrian access route. Comments: The surface recommendations are believed to be a minimal impact on new construction. However, there are potential high costs in alteration if an access cover is located on a landing, as this would require substantial drainage or possibly utility work.
1104.3.4 Grade Breaks. Grade breaks shall not be permitted on curb ramps, blended transitions, landings, and gutter areas within the pedestrian access route. Surface slopes that meet at grade breaks shall be flush.
1104.3.5 Changes in Level. Vertical changes in level shall not be permitted on curb ramps, blended transitions, landings, or gutter areas within the pedestrian access route.
1104.3.6 Counter Slopes. The counter slope of the gutter area or street at the foot of a curb ramp or blended transition shall be 1:20
1104.3.7 Clear Space. Beyond the curb line, a clear space of 48 inches
Recommendations: 1.) Recommend that this clear space "beyond the curb line" not be required for parallel curb ramps as it would be a duplication of the landing space. 2.) Recommend clarification of where to measure clear space from for perpendicular curb ramps (assumed to be face of curb).
1105 Pedestrian Crossings
1105.1 General. Pedestrian crossings shall comply with 1105.
1105.2 Crosswalks. Crosswalks shall comply with 1105.2.
1105.2.1 Width. Marked crosswalks shall be 96 inches
1105.2.2 Cross Slope. The cross slope shall be 1:48
1105.2.3 Running Slope. The running slope shall be 1:20
Recommendations: Recommend an exception for crosswalks across superelevated (banked) sections of roadways.
1105.3 Pedestrian Signal Phase Timing. All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
1105.4 Medians and Pedestrian Refuge Islands. Medians and pedestrian refuge islands in crosswalks shall comply with 1105.4 and shall be cut through level with the street or have curb ramps complying with 1104 and shall contain a pedestrian access route complying with 1103. Where the cut-through connects to the street, edges of the cut-through shall be aligned with the direction of the crosswalk for a length of 24 inches
1105.4.1 Length. Where signal timing is inadequate for full crossing of all traffic lanes or where the crossing is not signalized, cut-through medians and pedestrian refuge islands shall be 72 inches
1105.4.2 Detectable Warnings. Medians and refuge islands shall have detectable warnings complying with 1108. Detectable warnings at cut-through islands shall be separated by a 24 inch
1105.5 Pedestrian Overpasses and Underpasses. Pedestrian overpasses and underpasses shall comply with 1105.5.
1105.5.1 Pedestrian Access Route. Pedestrian overpasses and underpasses shall contain a pedestrian access route complying with 1103.
1105.5.2 Running Slope. The running slope shall not exceed 1:20
1105.5.3 Approach. Where the approach exceeds 1:20
1105.5.4 Stairs. Stairs shall comply with 504.
1105.5.5 Escalators. Escalators shall comply with 810.9.
1105.6 Roundabouts. Where pedestrian crosswalks and pedestrian facilities are provided at roundabouts, they shall comply with 1105.6. See discussion of and recommendations for Sections 1105.6, Roundabouts, 1105.6.1, Separation, and 1105.6.2, Signals, in Areas of Primary Concern section.
1105.6.1 Separation. Continuous barriers shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited. Where railings are used, they shall have a bottom rail 15 inches
1105.6.2 Signals. A pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the crosswalk, including the splitter island. Signals shall clearly identify which crosswalk segment the signal serves. See discussion of and recommendations for Sections 1105.6, Roundabouts, 1105.6.1, Separation, and 1105.6.2, Signals, in Areas of Primary Concern section.
1105.7 Turn Lanes at Intersections. Where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island. See discussion of and recommendations for Section 1105.7, Turn Lanes at Intersections, in Areas of Primary Concern section.
1106 Accessible Pedestrian Signal Systems
1106.1 General. Pedestrian signal systems shall comply with 1106. See discussion of and recommendations for Section 1106.1, General [Accessible Pedestrian Signal Systems], in Areas of Primary Concern section.
1106.2 Pedestrian Signal Devices. Each crosswalk with pedestrian signal indication shall have a signal device which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device and shall comply with 1106.3.
1106.2.1 Location. Pedestrian signal devices shall be located 60 inches
Recommendations: 1.) Recommend developing illustrative standard drawings for intersections using required spacings to determine feasibility and reasonability of spacing. 2.) Recommend defining "pedestrian control device" or rewording first sentence. 3.) Recommend rewording second sentence to state: "The face of the pedestrian signal should face the crosswalk it serves."
1106.2.2 Reach and Clear Floor or Ground Space. Pedestrian signal devices shall comply with 308. A clear floor or ground space complying with 305 shall be provided at the signal device and shall connect to or overlap the pedestrian access route.
1106.2.3 Audible Walk Indication. The audible indication of the WALK interval shall be by voice or tone.
1106.2.3.1 Tones. Tones shall consist of multiple frequencies with a dominant component at 880 Hz. The duration of the tone shall be 0.15 seconds
1106.2.3.2 Volume. Tone or voice volume measured at 36 inches
1106.3 Pedestrian Pushbuttons. Pedestrian pushbuttons shall comply with 1106.3. Comments: Several of the requirements for accessible pedestrian signals are anticipated as having a major impact with regard to both cost and manpower, such as the extended button press feature, which not all controllers support and for which new national specifications would be needed.
1106.3.1 Operation. Pedestrian pushbuttons shall comply with 309.4.
1106.3.2 Locator Tone. Pedestrian pushbuttons shall incorporate a locator tone at the pushbutton. Locator tone volume measured at 36 inches
1106.3.3 Size and Contrast. Pedestrian pushbuttons shall be a minimum of 2 inches
1106.3.4 Optional Features. An extended button press shall be permitted to activate additional features. Buttons that provide additional features shall be marked with three Braille dots forming an equilateral triangle in the center of the pushbutton. Comments: 1.) The extended button push should be allowed as an alternative to using a walk speed of 3 fps and the longer crossing distance discussed in Section 1105.3. 2.) The specification of a single push button with three braille dots for additional features may preclude future enhancements to the signals, and/or the provision of a variety of features using individual buttons.
Recommendations: 1.) Recommend utilizing the extended button push as an alternative to using a 3-foot-per-second walking speed at all intersections. 2.) Recommend removal of the requirement for the Braille dots to allow for future enhancements/additional buttons.
1106.4 Directional Information and Signs. Pedestrian signal devices shall provide tactile and visual signs on the face of the device or its housing or mounting indicating crosswalk direction and the name of the street containing the crosswalk served by the pedestrian signal.
1106.4.1 Arrow. Signs shall include a tactile arrow aligned parallel to the crosswalk direction. The arrow shall be raised 1/32 inch
1106.4.2 Street Name. Signs shall include street name information aligned parallel to the crosswalk direction and complying with 703.2. Comments: 1.) This guideline would require custom signs at each and every location, which will increase the cost and time required to install and maintain as compared to simple, mass-produced arrow signs without street name information. 2.) It is not clear if Braille is required in addition to raised letters. 3.) Given the stipulations for text size and spacing, a long street name may make the sign protrude greater than 4 inches
1106.4.3 Crosswalk Configuration. Where provided, graphic indication of crosswalk configuration shall be tactile and shall comply with 703.5.1.
1107 Street Furniture
1107.1 General. Street furniture shall comply with 1107. Comments: 1.) The State DOTs are concerned that they will be held liable for privately owned street fixtures and furniture on State roads over which they have little control, simply because it falls within their right-of-way. In many cases, there are maintenance agreements with local jurisdictions, but these would do little to protect States from being sued. 2.) An inventory and monitoring system for privately owned street fixtures and furniture on public rights-of-way would need to be created and maintained by the DOTs. This would involve notable initial time and cost at start-up and potential significant costs to fix any identified problems, partly because the responsible parties for these fixtures vary from state to state. These inventories would also have training costs to teach what needs to be inventoried and maintained. Finally, these inventories would affect local jurisdictions the greatest because of the number of sites with furniture under local agencies' control. 3.) Some states cannot require a permit for nor remove newspaper boxes due to first amendment laws; thus, there is little the State DOT can do to regulate these (and possibly other) street appurtenances. 4.) The end result of all of these potential problems may be a reduction in or elimination of new street furniture.
1107.2 Clear Floor or Ground Space. Street furniture shall have clear floor or ground space complying with 305 and shall be connected to the pedestrian access route. The clear floor or ground space shall overlap the pedestrian access route 12 inches
SECTION
TITLE DRAFT GUIDELINE COMMENTS AND RECOMMENDATIONS
1107.3 Drinking Fountains. Where drinking fountains are provided, they shall comply with 602.
1107.4 Public Telephones. Where public telephones are provided, they shall comply with 1107.4.
1107.4.1 Single Telephone. Where a single public telephone is provided, it shall comply with 704.2 and 704.4
1107.4.2 Multiple Telephones. Where a bank of public telephones is provided, at least one telephone shall comply with 704.2, and at least one additional telephone shall comply with 704.4.
1107.4.3 Volume Controls. All public telephones shall provide volume controls complying with 704.3.
1107.5 Public Toilet Facilities. Permanent or portable public toilet facilities shall comply with 603. At least one fixture of each type provided shall comply with 604 through 610. Operable parts, dispensers, receptacles, or other equipment shall comply with 309. EXCEPTION: Where multiple single-user toilet facilities are clustered at a single location, at least 5 percent, but no fewer than one single-user toilet at each cluster shall comply with 603 and shall be identified by the International Symbol of Accessibility complying with 703.7.2.1.
1107.6 Tables, Counters, and Benches. Tables, counters, and benches shall comply with 1107.6.
1107.6.1 Tables. Where tables are provided in a single location, at least 5 percent but no fewer than one, shall comply with 902.
1107.6.2 Counters. Where provided, counters shall comply with 904.
1107.6.3 Benches. Where benches without tables are provided at a single location, at least 50 percent, but no fewer than one, shall comply with 903 and shall have an armrest on at least one end.
1108 Detectable Warning Surfaces
1108.1 General. Detectable warnings shall consist of a surface of truncated domes aligned in a square grid pattern and shall comply with 1108. Comments: There is a high potential for increased costs in installation, construction, and/or litigation. There are costs to perform the necessary tests to determine what materials work best under what conditions. Testing is currently being done on slipperiness and other characteristics of various materials. Differences in temperature can cause the material to separate from the concrete. Poor performance could result in high maintenance efforts and increased inspection efforts. There are questions about liability concerns when a tripping hazard is created by the separated material (how often to inspect, how soon to repair, etc.). A major concern is that if the devices are viewed as a safety treatment, the courts may require them to be installed at all locations. This would be a major impact for states and an even larger impact for municipalities.
1108.1.1 Dome Size. Truncated domes in a detectable warning surface shall have a base diameter of 0.9 inches
1108.1.2 Dome Spacing. Truncated domes in a detectable warning surface shall have a center-to-center spacing of 1.6 inches
1108.1.3 Contrast. Detectable warning surfaces shall contrast visually with adjacent walking surfaces either light-on-dark, or dark-on-light.
1108.1.4 Size. Detectable warning surfaces shall extend 24 inches
1108.2 Location. Comments: The possibility of placing detectable warnings on curb ramps leading to driveways is not addressed in the current draft guidelines. This may be advisable depending on how large the driveway is (e.g., a large business entrance) and/or whether it is depressed or not.
Recommendations: Recommend further guidance.
1108.2.1 Curb Ramps and Blended Transitions. The detectable warning surface shall be located so that the edge nearest the curb line is 6 inches
Recommendations: Recommend modifying wording: "?so that the edge nearest the curb is?from the face [or back] of curb."
1108.2.2 Rail Crossings. The detectable warning surface shall be located so that the edge nearest the rail crossing is 6 inches
1108.2.3 Platform Edges. Detectable warning surfaces at platform boarding edges shall be 24 inches
1109 On-Street Parking
1109.1 General. Car and van on-street parking spaces shall comply with 1109.
1109.2 Parallel Parking Spaces. An access aisle at least 60 inches
Recommendations: 1.) Recommend beginning section, "For accessible parking spaces,?" 2.) Recommend adding an exception stating that bike lanes are allowed to overlap the access aisle.
1109.3 Perpendicular or Angled Parking Spaces. Where perpendicular or angled parking is provided, an access aisle 96 inches
Recommendations: Recommend rewording beginning of section to state, "Where accessible perpendicular or angled parking is provided,?"
1109.4 Curb Ramps or Blended Transition. A curb ramp or blended transition complying with 1104 shall connect the access aisle to the pedestrian access route.
1109.5 Obstructions. There shall be no obstructions on the sidewalk adjacent to and for the full length of the space. EXCEPTION: This provision shall not apply to parking signs complying with 1109.6 and parking meters complying with 1109.7.2. Comments: It is unclear how far back on the sidewalk from the accessible parking space this restriction applies, i.e., how far back is "adjacent to...the space"?
Recommendations: Recommend clarifying verbiage.
1109.6 Signs. Parking spaces shall be designated as reserved by a sign complying with 502.6. Signs shall be located at the head or foot of the parking space so as not to interfere with the operation of a side lift or a passenger side transfer.
1109.7 Parking Meters. Where parking meters are provided, they shall comply with 1109.7.
1109.7.1 Operable Parts. Operable parts shall comply with 309.
1109.7.2 Location. A parking meter shall be located at the head or foot of the parking space so as not to interfere with the operation of a side lift or a passenger side transfer. EXCEPTION: Where parking meters are not provided at the space, but payment for parking in the space is included in a centralized collection box or paying station, the space shall be connected to the centralized collection point with a pedestrian access route.
1109.7.3 Displays and Information. Displays and information shall be visible from a point located 40 inches
1110 Call Boxes
1110.1 General. Call boxes shall comply with 1110. Comments: Clarification is needed on the type of roadway improvement that would trigger the need for accessibility improvements to call boxes.
1110.2 Operable Parts. Operable parts shall comply with 308 and 309.4. Where provided, labeling shall comply with 703.2 and 703.3. EXCEPTION: Mechanically operated systems in which the signal is initiated by a lever pull shall be permitted to have an activating force of 12 lbf
1110.3 Turning Space. A turning space complying with 304 shall be provided at the controls.
1110.4 Edge Protection. Edge protection complying with 405.9.2 shall be provided where the area at the call box is adjacent to an abrupt level change.
1110.5 Motor Vehicle Turnouts. Where provided, a motor vehicle turnout shall have a minimum paved area of 16 feet
1110.6 Two-Way Communication. Where provided, two-way voice communication shall comply with 1110.6, 708.2 and 708.3.
1110.6.1 Volume Controls. Volume controls complying with 704.3 shall be provided.
1110.6.2 TTY. A TTY complying with 704.4 shall be provided.
1111 Alternate Circulation Path
1111.1 General. Alternate circulation paths shall comply with 1111.
1111.2 Width. The alternate circulation path shall have a width of 36 inches
1111.3 Location. The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street. See discussion of and recommendations for Sections 1102.3, Alternate Circulation Path, and 1111.3, Location [of Alternate Circulation Paths], in Areas of Primary Concern section.
1111.4 Protection. The alternate circulation path shall comply with 307 and shall be protected with a barricade complying with 1111.6 to separate the pedestrian access route and alternate circulation path from any adjacent construction, drop-offs, openings, or other hazards.
SECTION
TITLE DRAFT GUIDELINE COMMENTS AND RECOMMENDATIONS
1111.5 Signs. Signs complying with 703.5 shall be provided at both the near side and the far side of the intersection preceding a disrupted pedestrian access route. Comments: Costs for installation and maintenance of signage could be moderate, especially if broadcast signage or flashing beacon lights accompanied by an audible tone are required. Additional research is needed to determine acceptable signs for various situations. In addition, these signs would need to be included in the MUTCD.
1111.6 Barricades. Barricades shall be continuous, stable, and non-flexible and shall consist of a solid wall or fence or a Type II or Type III barricade as specified in MUTCD section 6F-60 with the bottom or lower rail 1-1/2 inches
AASHTO POLICY RESOLUTION
TITLE: AASHTO'S RESPONSE ON THE US ACCESS BOARD'S
DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY
WHEREAS, AASHTO created an Ad-hoc Task Force on Accessibility in Public Rights-of-Way consisting of representatives from: the Standing Committee on Highways; the Standing Committee on Public Transportation; the Highway Subcommittees on Construction, Design, Maintenance, and Traffic Engineering; and the Joint Task Force on Non-Motorized Transportation; and
WHEREAS, the Task Force was charged with developing a response to the Draft Guidelines for Accessible Public Rights-of-Way that were recently released by the US Architectural and Transportation Barriers Compliance Board, also known as the US Access Board; and
WHEREAS, the guidelines include sections on scoping requirements, pedestrian access routes, curb ramps and blended transitions, pedestrian crossings, accessible pedestrian signal systems, work zones, street furniture, detectable warning surfaces, on-street parking, call boxes, and alternate circulation paths; and
WHEREAS, the Task Force diligently worked to represent the views of all AASHTO member state transportation departments in its recommendations; and
WHEREAS, these recommendations help to ensure accessibility for all while maintaining the engineering guidelines that have become critical to constructing, operating, and maintaining a safe and efficient transportation system.
NOW, THEREFORE, BE IT RESOLVED, that the AASHTO Board of Directors approves the recommendations developed by the Task Force on Accessibility in Public Rights-of-Way and subsequently endorsed by the Standing Committee on Highways; and
BE IT FURTHER RESOLVED, that the AASHTO Board of Directors directs that these recommendations be submitted to the US Access Board on or before October 28, 2002, as the official AASHTO response to the request for comments on the Draft Guidelines for Accessible Public Rights-of-Way; and
BE IT FURTHER RESOLVED, that the AASHTO Board of Directors calls on the US Access Board to provide cost estimates for the implementation of these guidelines to illustrate the potential financial impacts of their proposed solutions to accessibility issues on the implementing agencies prior to the release of the Notice of Proposed Rule Making on Accessible Public Rights-of-Way.
J. Tom Coleman Jr., October 25, 2002
Georgia Department of Transportation
Subject: Comments on the proposed "Guidelines for Accessible Public Rights-of-Way"
Dear Mr. Windley:
The Georgia Department of Transportation (GDOT) completely agrees with the concept of the ADA that no person should be denied services because that person has a disability. The GDOT has reviewed the proposed "Guidelines for Accessible Public Rights-of-Way" dated June 17, 2002. Based on the review, some of the requirements should be given further consideration before implementation.
The GDOT has also reviewed the AASHTO comments on the proposed ADA guidelines and agree with their recommendations. The GDOT comments were developed independently but address many of the same issues.
Several of the proposed requirements will have major impacts on project design on required Rights-of-Way. If the plans for a project are near completion, the plans would need to be changed, the Environmental Document would need to be reevaluated and additional R/W would need to be acquired which will result in a considerable delay in letting the project for construction. When the text of the document has been finalized, the required implementation date should be given careful consideration.
Attached are the GDOT comments on the proposed ADA guidelines for public Rights-of-Way.
Sincerely,
Signed by Commissioner Coleman
J. Tom Coleman Jr.
Commissioner
Attachments
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Comments on the Proposed ADA Guidelines for Accessible Public R/W
The Georgian Department of Transportation (GDOT) completely agrees with the concept of the ADA that no person should be denied services because that person has a disability. However, the proposed "Guidelines for Accessible Public Rights-of-Way" dated June 17,2002 specify some requirements that we feel should be given further consideration before implementation.
The GDOT has reviewed the AASHTO comments on the Proposed ADA Guidelines and agrees with their recommendations. The GDOT comments were developed independently but address many of the same issues.
Overview:
Several of the major issues are addressed in general in the Synopsis. More specific comments are addressed in the responses to the individual sections.
The ACCESS BOARD has received many comments that have been posted on their website.
The comments seemed to fit into two categories. The first type response was from persons with disabilities or groups representing persons with disabilities. These comments were generally short and contained references to specific items. Sometimes the comments were in support of or opposed to an item. For example, the visually impaired groups generally supported the detectable warnings at the bottom of the ramps and the groups representing persons with mobility and balance disabilities considered the detectable warnings a tripping hazard to walkers and an inconvenience to persons in wheelchairs. The varied responses from the persons with different viewpoints indicate that there is no solution that satisfies all users in all situations.
The second type of response was from persons or groups that will implement the design requirements. These responses were generally longer and pointed out that many of the requirements would have consequences that the Access Board and the individual members of the Board had not intended or anticipated. Often these responses could be summarized by the following statement: Change the "design requirements" to "design recommendations." This will allow the Engineer to consider all the factors influencing the area in the design of the project.
Following the same thought, as written the only allowable reason for not meeting ALL the design requirements is if it is "Technically Infeasible" to meet the requirements. (And this is only allowed on "alterations", new construction must meet all the Design Requirements.) Technically Infeasible is not defined in the ROW section but a definition is needed. Also, the DOJ Title II Technical Assistance Manual specifically states that when determining Technical Infeasibility, cost is not to be considered. When a roadway type project is being constructed on the R/W, and enough money is available, anything can be built, therefore nothing is technically infeasible. In a slight contradiction, the DOJ CFR states that if you have to remove a load bearing wall in a building then complying with the design requirements is Technically Infeasible. More guidance is required.
The Dept. of Justice, Housing and Urban Development, Dept. of Interior, Dept. of Labor and possibly other agencies have included guidance for not meeting the ADA design requirements in their respective CFRs. Some of the guidance is not in complete agreement but generally they allow deviation from the Design Requirements due to "Technical Infeasibility", "Conflicts with existing law to protect historic resources", "Disproportionality" of the cost of satisfying all the ADA design requirements with the project cost, "Undue Administrative Burden", "Undue Financial Burden" and "Fundamental Alteration of the Nature of the Service". The various CFRs generally require that the head of the agency approve the deviation from the Design Requirements. The FHWA CFR simply states that "wheel chair ramps and other features that may be required to meet ADA are required". The FHWA is the agency that oversees most federal monies spent on public R/W. The FHWA has not provided any usable guidance (that the ADA required them to provide by 1992) on when exceptions to the ADA Design Requirements are justified therefore, the guidance must be included in this document. Also, it is unclear whether guidance included it this document or guidance included in the various CFRs will control.
To follow up on the "unintended consequences" of these requirements, if cost cannot be considered when determining technical infeasibility and if the design parameters are adopted exactly as written, many urban projects will not be built. The disruption to the adjacent properties and the surrounding communities will be too severe. The end result of these requirements (to provide a high level of accessibility) will be less accessibility in areas that would have been improved. The changes to the proposed ADA Design Requirements that the GDOT proposes are to ensure that this is not the result of the ADA Design Requirements.
Whether or not cost can be DIRECTLY considered when determining whether it is necessary to comply with the ADA Design Requirements, the cost of compliance WILL be considered. The funding of projects for new roadways and roadway improvements may seem to be infinite to persons not familiar with the magnitude of these projects, however there is a limited amount of money available and an infinite demand for these funds. Also, the funding is usually divided into categories and specified for certain uses. (For example, resurfacing, intersection improvement, Interstate Highways, bridge rehabilitation, etc.) If one project is very costly, either the project will not be constructed or other projects in that funding category will not be constructed in order to fund the project that is constructed.
The GDOT believes that the intent of the ADA was to provide better access (and service) to everyone (including persons with disabilities), not lower the level of access (and service) to everyone equally.
There is an article in the 9/19/02 edition of the Govt. Computer News about problems providing GIS maps over the Internet. The information has to be provided in usable form to all users to comply with Section 508 of the 1998 ADA Amendment. It would be unfortunate (but not unexpected) if this service was withheld from all citizens in order to comply with the ADA. There is no technology available for blind users to obtain the same information (in an easily useable format) that sighted users obtain, therefore the result may be less service for everyone. (Including the blind person that previously had a sighted friend or family member obtain and interpret the information.)
The ADA does not require that sidewalks be included in roadway projects but if sidewalks are provided the ADA requires that they must be useable by all users. If this premise is used to judge the requirements listed in the "Guidelines for Accessible Public Rights-of-Way", some of the requirements do not appear to fall under ADA regulation. For example, requirements for traffic signals where none would be required except by these guidelines. The GDOT recommends that all the requirements be reviewed and any requirements that are not definitely issues covered by the ADA be removed or changed to recommendations.
There appear to be some discrepancies in the commentary and between the commentary and the proposed text. For example: Commentary 1102.1 "The draft guidelines would not require the provision of sidewalks, street crossings, street furniture, parking or other pedestrian elements where none are intended." Commentary 1105.2 - Crosswalks - "?specifications apply to both marked and unmarked crossings, wherever pedestrian travel is not prohibited." TEXT 1102.1 "All areas of newly designed and newly constructed facilities in public rights-of-way and altered portions of existing facilities ? shall comply with Chapter 11.
The final document should be clear and concise. The commentary provided should clarify and provide examples for the Design Requirements. All discrepancies in the commentary (from the text of the requirements) should be omitted or clearly noted as minority opinions.
There are also some discrepancies between the proposed Chapter 11 requirements the previous sections (Ramps are also addressed in Chapter 405 and Curb Ramps are also addressed in Chapter 406). If the requirements are different on public R/W it should be noted in the other chapters whenever there is a difference.
Several of the design requirements for cross slope, grade breaks, etc. are covered in "1103 Pedestrian Access Route". The same requirements are duplicated other sections (ramps, transitions, crosswalks etc.). Consider eliminating the requirements from the other sections since by definition these areas are part of the "Pedestrian Access Route".
The guideline commentary stated "guidelines depart from the advisory committee's report in several areas, which are detailed in the following discussion." There are several items that differ from the Jan. 2001 report in the proposed text that are not discussed. (Possibly "Changes in level" (1103.8) should be "Grade Breaks" and "Grade Breaks" (1104.3.40) should be omitted.)
As an aside: There was an ADA seminar presented in Atlanta last year. Several of members of the Public R/W committee were present. Several questions were posed about the effect of implementing various design parameters. A common answer was "Oh, you would not have to meet that requirement, it isn't reasonable in that case". As written, the requirements do not allow for that solution. The only acceptable solution is "MEET THE DESIGN PARAMETERS".
The SCOPING REQUIREMENTS section needs to be expanded and clarified. Chapter 1102.2.2 states "Where existing elements or spaces in the public R/W are altered, each altered element shall comply with the applicable provisions of Chapter 11."
When a road is resurfaced the crosswalks are altered. This provision requires the cross slope to be less that 2.08% in the crosswalk. This requires that the intersection be "tabletopped" and requires vertical grade changes all of the approach roadways. This requirement will essentially prohibit any resurfacing projects in urban areas where any existing grade or crossslope in the intersection exceeds 2%. (Even if the project would remove severe ruts, vertical lips, and potholes in the crosswalk that make the existing crosswalk unusable for pedestrians with disabilities.)
The "tabletopping requirement will have severe negative impacts on all projects where the natural terrain slopes exceed 2%.
The commentary on 1105.2 - Crosswalks - that states that "?specifications apply to both marked and unmarked crossings, wherever pedestrian travel is not prohibited." If this is intended to be a true statement, it should be reconsidered. Other sections require a pedestrian activated signal where a right turn slip lane is present. A "slip lane" definition should be added but the figures show a right turn movement separated by an island. This would require a traffic signal at nearly every intersection on a multilane road. Also, when a business obtains a driveway access permit on a corner, GDOT requires the addition of a right turn lane. This provision would also require a signal at the intersection (which the developer would be happy to do since it would increase the value of his business). The MUTCD has very specific warrants for the installation of signals that are based on years of experience to provide the best compromise between motorist safety, pedestrian safety and overall usability of the Rights-of-Way. If the Access Board decides that these warrants should be ignored, the decision to ignore them should be based on documented research.
Most GDOT projects are "alterations" in some (or many) respects. For instance even a new roadway on a new location generally follows the existing terrain and crosses existing roads that have homes and businesses near the newly created intersection (or interchange). In the design process we attempt to minimize the impact on these homes and businesses while providing a road that is safe for the traveling public.
As written, the guidelines only allow a deviation from the design parameters when the project is an "alteration" (or where an "addition" project connects with existing construction) and when it is "technically infeasible" to meet the requirement. (Although the Chapter 2 Scoping Requirements in the ABA/ADA final draft commentary (p16) mentions "disproportionality" it is not mentioned in the actual text.)
Additional guidance on what is "technically infeasible" should be provided. When building a road it is usually "technically feasible" to do anything if enough money is available.
The 1999 publication "Accessible Rights of Way, A Design Guide" has a more realistic approach for not meeting the ADA design requirements. "Technically Infeasible", "Fundamental Alteration of the Nature of the Project" and "Undue Burden" were mentioned as justification for not fully complying with the design requirements.
Note that the GDOT has a finite amount of money available. If complying with all of the ADA design parameters adds excessive cost to a project then fewer projects will be built. The overall effect will be fewer projects constructed and fewer accessibility improvements therefore there will be less overall benefit provided to disabled users. (For example, table-topping an intersection in a lightly populated area as part of a major roadway reconstruction project could easily cost an additional $ 2 million on a $20 million contract. That $ 2 million could upgrade 2 or 3 intersections in a highly urbanized area with large numbers of pedestrians.)
The CFR for the Dept. of Justice, Labor, HUD give guidelines on when exceptions to the ADA design parameters are justified. (But the justifications are not the same.) In order to provide consistency in implementing these requirements this information should be included in the Accessibility Guidelines.
For example:
CFR 35.150 states:
A public entity shall 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. This paragraph does not --
(1) Necessarily require a public entity to make each of its existing facilities accessible to and usable by individuals with disabilities;
(2) Require a public entity to take any action that would threaten or destroy the historic significance of an historic property; or
(3) 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 in undue financial and administrative burdens. In those circumstances where personnel of the public entity believe that the proposed action would fundamentally alter the service, program, or activity or would result in undue financial and administrative burdens, a public entity has the burden of proving that compliance with § 35.150(a) of this part would result in such alteration or burdens. The decision that compliance would result in such alteration or burdens must be made by the head of a public entity or his or her designee after considering all resources available for use in the funding and operation of the service, program, or activity, and must be accompanied by a written statement of the reasons for reaching that conclusion. If an action would result in such an alteration or such burdens, a public entity shall 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 or services provided by the public entity.
The GDOT recommends the wording in this section be expanded to address situations where it is not necessary to meet all the design requirements and included in these guidelines. This section should describe and give guidance on "Technically Infeasible", "Fundamental Alteration of the Nature of the Project", "Undue Burden", Undue Financial Burden", and "Disproportionality". The section should also address how to handle conflicts with other Federal laws that deal with preserving historical and archeological sites, wetlands, and other natural resources. This section should also address the level of documentation and level of approval required.
Making the design parameters "recommendations" instead of "requirements" would solve many of these problems.
As written it is not defined precisely where pedestrians must be accommodated on the public R/W. This should be addressed.
GDOT Commentary: It seems that the disruption to the surrounding area, cost, and impacts on the safety of the motorists should be weighed against the need for pedestrian accommodation. This should be an Engineering Decision not a mandated requirement. The GDOT often uses curb and gutter and sidewalks to minimize the R/W requirements (or stay on existing R/W) not to provide pedestrian accommodations. Without relaxation of the design requirements (or allowing engineering judgement) many projects will not be built. The projects improve usability (even though they might not meet all the design requirements) for disabled users.
When the text of the document has been finalized, the required implementation date should be given careful consideration. Several of the proposed requirements will have major impacts on the design of the project and on the required Rights-of-Way. A lead time of 2 years would not be unreasonable for full compliance with some of the proposed requirements. This would allow time to reevaluate the Environmental Document, change the plans and acquire the additional Rights-of-Way.
The following is the Text of the Draft Guidelines for Accessible Public Rights-of-Way with GDOT comments and recommended changes noted.
1101 Application and Administration (referenced standards and defined terms)
1102 Scoping Requirements
1103 Pedestrian Access Route
1104 Curb Ramps and Blended Transitions
1105 Pedestrian Crossings
1106 Accessible Pedestrian Signal Systems
1107 Street Furniture
1108 Detectable Warning Surfaces
1109 On-Street Parking
1110 Call Boxes
1111 Alternate Circulation Path
1101 Application and Administration
1101.1 General. For the purposes of these requirements, the terms listed in section 1101.3 shall have the indicated meaning.
1101.2 Referenced Standards.
1101.2.1 MUTCD. Copies of the referenced standards may be obtained on-line from the Federal Highway Administration at http://mutcd.fhwa.dot.gov/.
MUTCD 2000-Millennium Edition Manual on Uniform Traffic Control Devices.
GDOT Comment - Add AASHTO 2001 Design Guide to the list on standards
1101.3 Defined Terms.
GDOT Comments -
Add definitions for:
Slip Ramp
Perpendicular Curb Ramp
Parallel Curb Ramp
Addition
Alteration
Blended Transition
Technically infeasible
Disproportionality
Undue Financial Burden
Undue Administrative Burden
Fundamental Alteration of the Nature of the Project
Agency that approves ADA design requirements exceptions
GDOT Recommended Definitions -
New facility: A new roadway on new alignment where the horizontal or vertical alignment, or crossslope are not controlled by an existing facility.
Alteration: A project or portion of a project where the horizontal or vertical alignment or crossslope of the roadway are controlled by an existing facility is an "alteration". No alterations may be done that have the effect of decreasing accessibility.
Fundamental alteration in the nature of a project: An improvement that changes the basic concept for the project.
Program Accessibility: If the facility is accessible to people with disabilities through another method or alternative routes, the facility may not be required to comply with all ADA design parameters. Note that curb cut ramps are specifically named as a required element and cannot be excluded.
Undue financial burden: If the cost of providing or maintaining a facility that fully complies with ADA design parameters is prohibitively expensive or the required future funding is not guaranteed, full compliance with the ADA design parameters may be considered an undue financial burden.
For small projects, if complete compliance with the ADA design parameters adds over 20% to the total cost of the project, complete compliance is not required (but should be considered). However, the facilities shall be improved to the maximum extent possible using the 20% additional costs.
For large projects, if complete compliance with the ADA design parameters adds over 20% to the cost of the area of the project where the improvement is needed, complete compliance is not required (but should be considered). However, the facilities shall be improved to the maximum extent possible using the 20% additional costs. (This is intended to address major alteration projects where small areas are not in compliance with the ADA design parameters.)
Disproportional: If the cost of constructing a project (or portion of a project) that fully complies with ADA design parameters is prohibitively expensive full compliance with the ADA design parameters may be considered Disproportional.
For small projects, if complete compliance with the ADA design parameters adds over 20% to the total cost of the project, complete compliance is not required (but should be considered). However, the facilities shall be improved to the maximum extent possible using the 20% additional costs.
For large projects, if complete compliance with the ADA design parameters adds over 20% to the cost of the area of the project where the improvement is needed, complete compliance is not required (but should be considered). However, the project shall meet the ADA Design Requirements to the maximum extent possible using the 20% additional costs. (This is intended to address major projects where small areas are not in compliance with the ADA design parameters.)
Technically infeasible: If complying with the ADA design parameters require that the roadway alignment, grade, sight distance or clear zone not to meet AASHTO desirable requirements then complying with ADA design parameters is "technically infeasible".
Conflicts with other laws that protect historical, cultural, or natural resources make complying with ADA design parameters "technically infeasible".
Note that if complete compliance is "technically infeasible" the facility shall be modified to comply with ADA design parameters to the "maximum extent possible".
Accessible Pedestrian Signal. A device that communicates information about the pedestrian WALK phase in non-visual format.
Accessible Route. A continuous, unobstructed path that complies with Chapter 4.
GDOT Comment:
The definition of Accessible Route should be clarified. It is not clear whether shoulders are an "accessible route" on a road with no curb and gutter and/or no sidewalk.
Channelizing Island. Curbed or painted area outside the vehicular path that is provided to separate and direct traffic movement, which also may serve as a refuge for pedestrians.
Cross Slope. The slope that is perpendicular to the direction of travel. This is usually called superelevation on curves in the public right-of-way (see superelevation).
Crosswalk. That part of a roadway at an intersection that is included within the extensions of the lateral lines of the sidewalks on opposite sides of the roadway, measured from the curbline or, in the absence of curbs, from the edges of the roadway or, in the absence of a sidewalk on one side of the roadway, the part of the roadway included within the extension of the lateral lines of the sidewalk at right angles to the centerline. Also, any portion of a roadway at an intersection or elsewhere that is distinctly indicated for pedestrian crossing by lines or other markings on the surface.
GDOT Comment:
The definition of crosswalk appears to say that a crosswalk is only present if there is sidewalk present or if there is a "marked" crosswalk. While this definition makes it easier to comply with the ADA Design Requirements, it appears to conflict with the text of in other sections of the requirements and with the commentary.
Curb Line. A line at the face of the curb that marks the transition between the sidewalk and the gutter or roadway.
Curb Ramp. A ramp cutting through a curb or built up to it.
Detectable Warning. A surface feature built in or applied to walking surfaces or other elements to warn of hazards on a circulation path.
Dynamic Envelope. The clearance required for a rail vehicle and its cargo overhang due to any combination of loading, lateral motion, or suspension failure.
Element. An architectural or mechanical component of a building, facility, space, site or public right-of-way.
Facility. All or any portion of buildings, structures, improvements, elements and pedestrian or vehicular routes located on a site or in a public right-of-way.
Grade. (See running slope).
Grade Break. The meeting line of two adjacent surfaces of different slope (grade).
Locator Tone. A repeating sound that identifies the location of the pedestrian push button.
Pedestrian Access Route. An accessible corridor for pedestrian use within the public right-of-way.
GDOT Recommended Definition
Pedestrian Access Route. An accessible route, designated by the responsible agency, for pedestrian use within the public right-of-way.
This will allow the "rural" projects to be excluded from ADA requirements.
Public Right-of-Way. Land or property, usually in a corridor, that is acquired for or devoted to transportation purposes.
Roundabout. A circular intersection that has yield control of entering traffic, channelized approaches, counterclockwise circulation, and appropriate geometric curvature to limit travel speeds on the circulatory roadway.
Running Slope. The slope that is parallel to the direction of travel expressed as a ratio of rise to run. In the public right-of-way, this is usually called grade, and is expressed in percent.
Sidewalk. That portion of a public right-of-way between the curb line or lateral line of a roadway and the adjacent property line that is improved for use by pedestrians.
GDOT Comment:
What does "improved for use by pedestrians" mean? We are concerned that this could be interpreted to mean shoulders on "rural" projects or the flat graded area behind the curb if no concrete sidewalk is present.
This definition is critical. For instance if the paved shoulder is a "sidewalk", the ADA design requirements apply to rural projects. The GDOT requires separate right turn lanes on multilane rural roads at all intersections as a safety feature to allow the right turning traffic to move out of the high speed travel lanes. These requirements would mandate that pedestrian activated signals with locator tones be provided at essentially all intersections.
Splitter Island. A flush or raised island that separates entering and exiting traffic in a roundabout.
Street Furniture. Elements in the public right-of-way that are intended for use by pedestrians.
Superelevation. Cross slope on a curve in the roadway (see cross slope).
Walk Interval. That phase of a traffic signal cycle during which the pedestrian is to begin crossing, typically indicated by a WALK message or the walking person symbol and its audible equivalent.
1102 Scoping Requirements
1102.1 General. All areas of newly designed and newly constructed facilities in public rights-of-way and altered portions of existing facilities in public rights-of-way shall comply with Chapter 11.
GDOT Recommended wording:
1102.1 General. All areas of newly designed and newly constructed facilities in public rights-of-way and altered portions of existing facilities in public rights-of-way that include provisions for pedestrians shall comply with Chapter 11.
GDOT Comment:
The SCOPING REQUIREMENTS need to be expanded and clarified. If the exceptions recommended in 1102.2.2 (specifically Fundamental Alteration of the Nature of a Project are not allowed, when a road is resurfaced the crosswalks are altered. This provision requires the cross slope to be less that 2.08% in the crosswalk. This requires that the intersection be "tabletopped" and requires vertical grade changes all of the approach roadways. This requirement will essentially prohibit any resurfacing projects in urban areas where any existing grade or crossslope in the intersection exceeds 2%. (Even if the project would remove severe ruts, vertical lips, and potholes in the crosswalk that make the existing crosswalk unusable for pedestrians with disabilities.)
The same situation will exist if a traffic signal needs to be upgraded. As written, a signal could not be upgraded to allow for protected pedestrian movements without "tabletopping" the intersection.
1102.2 Existing Public Rights-of-Way. Additions to existing public rights-of-way shall comply with 1102.2.1. Alterations to existing public rights-of-way shall comply with 1102.2.2.
1102.2.1 Additions. Each addition to an existing public right-of-way shall comply with the applicable provisions of Chapter 11. Where the addition connects with existing construction, the connection shall comply with 1102.2.2.
1102.2.2 Alterations. Where existing elements or spaces in the public right-of-way are altered, each altered element or space shall comply with the applicable provisions of Chapter 11.
GDOT Comment: Define Spaces as used above.
EXCEPTION: In alterations, where compliance with applicable provisions is technically infeasible, the alteration shall comply to the maximum extent feasible.
GDOT Recommended Wording
EXCEPTION: In alterations, the project shall comply with applicable provisions unless the following applies. If full compliance is not required, the alteration shall comply to the maximum extent feasible.
A public entity shall operate each service, program, or activity and construct each project so that the service, program, or activity, and constructed project when viewed in its entirety, is readily accessible to and usable by individuals with disabilities. This paragraph does not --
(1) Necessarily require a public entity to make all areas of its existing facilities accessible to and usable by individuals with disabilities; or
(2) Require a public entity to take any action that would threaten or destroy the historic significance of an historic property; or that conflict with other laws that protect natural or archeological resources or cemeteries; or
(3) Require a public entity to take any action that is technically infeasible; or
(4) 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 in undue financial and administrative burdens or in a fundamental alteration of the nature of the project. Also, if the additional cost of fully complying with the ADA Design Requirements exceeds 20% of the cost of the project in the area affected by the improvement, full compliance may be considered "Disproportional" to the cost of constructing that area of the project. In those circumstances where personnel of the public entity believe that the proposed action would fundamentally alter the project, service, program, or activity, or the cost is disproportional or would result in undue financial and administrative burdens, a public entity has the burden of proving that compliance would result in such alteration or burdens. The decision that compliance would result in such alteration or burdens must be made by the head of a public entity or his or her designee after considering all resources available for use in the funding and operation of the service, program, or activity, and must be documented by a written statement of the reasons for reaching that conclusion. If an action would result in such an alteration or such burdens, a public entity shall 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 or services provided by the public entity.
1102.2.2.1 Extent of Application. An alteration of an existing element, space, or area of a public right-of-way shall not impose a requirement for accessibility greater than required for new construction.
1102.2.2.2 Prohibited Reduction in Access. An alteration that decreases or has the effect of decreasing the accessibility of a public right-of-way or site arrival points to buildings or facilities adjacent to the altered portion of the public right-of-way, below the requirements for new construction at the time of the alteration is prohibited.
GDOT Comment: As worded it appears redundant. The GDOT wording states that regardless of what exceptions may be approved the accessibility cannot be less that before the project was constructed.
GDOT Recommended wording:
1102.2.2.2 Prohibited Reduction in Access. An alteration that decreases or has the effect of decreasing the accessibility of a public right-of-way or site arrival points to buildings or facilities adjacent to the altered portion of the public right-of-way is prohibited.
1102.3 Alternate Circulation Path. An alternate circulation path complying with 1111 shall be provided whenever the existing pedestrian access route is blocked by construction, alteration, maintenance, or other temporary conditions.
GDOT Comment: The amount of time of the closure and the expected pedestrian usage should be a factor. As written this would require a pedestrian bridge to be constructed if the entire bridge had to be closed for just 10 minutes.
See other comments on 1111
1102.4 Sidewalks. Where sidewalks are provided, they shall contain a continuous pedestrian access route complying with 1103. The pedestrian access route shall connect to elements required to comply with Chapter 11.
1102.5 Protruding Objects. Protruding objects on sidewalks and other pedestrian circulation paths shall comply with 1102.5 and shall not reduce the clear width required for pedestrian accessible routes.
1102.5.1 Protrusion Limits. Objects with leading edges more than 27 inches
EXCEPTION: Handrails shall be permitted to protrude 4-1/2 inches
1102.5.2 Post-Mounted Objects. Free-standing objects mounted on posts or pylons shall overhang circulation paths 4 inches
EXCEPTION: This requirement shall not apply to sloping portions of handrails serving stairs and ramps.
1102.5.3 Reduced Vertical Clearance. Guardrails or other barriers shall be provided where the vertical clearance is less than 80 inches
EXCEPTION: Door closers and door stops shall be permitted to be 78 inches
1102.6 Curb Ramps and Blended Transitions. A curb ramp or blended transition complying with 1104, or a combination of curb ramps and blended transitions, shall connect the pedestrian access routes to each street crossing within the width of each crosswalk.
1102.7 Pedestrian Signs. Signs for pedestrian use shall comply with 1102.7.
1102.7.1 Bus Route Identification. Bus route identification signs shall comply with 703.5.1 through 703.5.4, and 703.5.7 and 703.5.8. In addition, to the maximum extent practicable, bus route identification signs shall comply with 703.5.5. Bus route identification signs located at bus shelters shall provide raised and Braille characters complying with 703.2, and shall have rounded corners.
EXCEPTIONS 1: Bus schedules, timetables and maps that are posted at the bus stop or bus shelter shall not be required to comply with 1102.7.
2: Signs shall not be required to comply with 703.2 where audible signs are user- or proximity-actuated or are remotely transmitted to a portable receiver carried by an individual.
1102.7.2 Informational Signs and Warning Signs. Informational signs and warning signs shall comply with 703.5.
1102.8 Pedestrian Crossings. Where a pedestrian crossing is provided, it shall comply with the applicable provisions of 1105. Where pedestrian signals are provided at a pedestrian crossing, they shall comply with 1106.
1102.9 Street Furniture. Street furniture that is intended for use by pedestrians and installed on or adjacent to a sidewalk shall comply with 309 and 1107.
1102.10 Stairs. Where provided, stairs shall comply with 504. Stair treads shall have a 2 inch
1102.11 Handrails. Where provided, handrails shall comply with 505.
1102.12 Vertical Access. Where provided elevators shall comply with 407, limited-use/limited-application elevators shall comply with 408, and platform lifts shall comply with 410. Vertical access shall remain unlocked during the operating hours of the facility served.
1102.13 Bus Stops. Bus boarding and alighting areas shall comply with 810.2. Bus shelters shall comply with 810.3.
GDOT comment: The bus stop locations are determined (and often changed) by the local transit authority. The GDOT does not have control on where these are placed and often the bus stops a several locations along a block. In many areas that have bus service there is not space available to provide these landings at all bus stops without severe disruption of the community. Consider requiring one accessible bus landing per block or every ¼ mile.
1102.14 On-Street Parking. Where on-street parking is provided, at least one accessible on-street parking space shall be located on each block face and shall comply with 1109.
GDOT Comment: The requirement will generally be achievable. However many of the small towns in Georgia are built with a small square. The blocks are very short and the sidewalks are often elevated. In this situation the addition of the accessible parking space (and an access route to the elevated sidewalk) would eliminate most or all the remaining spaces in the block. This would effectively put the businesses on the Town Square out of business. Often the entrances to the businesses are not accessible from the sidewalk due to steps. This requirement would provide access to the sidewalk in front of the businesses but would not provide access to the business.
This is another example of where "Engineering Judgement" should be used instead of a mandated requirement.
1102.15 Passenger Loading Zones. Where passenger loading zones are provided, they shall connect to a pedestrian access route and shall provide a minimum of one passenger loading zone in every continuous 100 linear feet (30 m) of loading zone space, or fraction thereof, complying with 302, 503.2, 503.3, and 503.5.
1102.16 Call Boxes. Where provided, call boxes shall comply with 1110.
1103 Pedestrian Access Route
1103.1 General. Pedestrian access routes shall connect to elements required to be accessible and shall comply with 1103.
1103.2 Components. Pedestrian access routes shall consist of one or more of the following components: walking surfaces, ramps, curb ramps, blended transitions, crosswalks, pedestrian overpasses and underpasses, elevators, and platform lifts. All components of a pedestrian access route shall comply with the applicable portions of this chapter.
1103.3 Clear Width. The minimum clear width of a pedestrian access route shall be 48 inches
1103.4 Cross Slope. The cross slope of the pedestrian access route shall be 1:48
Also, see comments on crosswalks (which are a part of the pedestrian access route).
The requirement for a 1:48
1103.5 Grade. The grade of the pedestrian access route within a sidewalk shall not exceed the grade established for the adjacent roadway.
EXCEPTION: The running slope of a pedestrian access route shall be permitted to be steeper than the grade of the adjacent roadway, provided that the pedestrian access route is less than 1:20
1103.6 Surfaces. The surfaces of the pedestrian access route shall comply with 302.
1103.7 Surface Gaps at Rail Crossings. Where the pedestrian access route crosses rail systems at grade, the horizontal gap at the inner edge of each rail shall be constructed to the minimum dimension necessary to allow passage of railroad car wheel flanges and shall not exceed 2-½ inches (64 mm).
EXCEPTION: On tracks that carry freight, a maximum horizontal gap of 3 inch
1103.7.1 Detectable Warnings. Where rail systems cross pedestrian facilities that are not shared with vehicular ways, a detectable warning shall be provided in compliance with 1108.
1103.8 Changes in Level. Changes in level shall comply with 303. Changes in level shall be separated horizontally 30 inches
GDOT Comment: 303 allows a ¼" max vertical lip, ¼" to ½" beveled on 1:2
EXCEPTION: The horizontal separation requirement shall not apply to detectable warnings.
GDOT Comment: What horizontal separation requirement? It is unclear what this means even if a horizontal separation requirement is specified.
1103.8.1 Rail Crossings. Where the pedestrian access route crosses rail systems at grade, the surface of the pedestrian access route shall be level and flush with the top of the rail at the outer edge and between the rails.
1104 Curb Ramps and Blended Transitions
1104.1 General. Curb ramps and blended transitions shall comply with 1104.
1104.2 Types. Perpendicular curb ramps shall comply with 1104.2.1 and 1104.3; parallel curb ramps shall comply with 1104.2.2 and 1104.3; blended transitions shall comply with 1104.2.3 and 1104.3.
1104.2.1 Perpendicular Curb Ramps. Perpendicular curb ramps shall comply with 1104.2.1, and shall have a running slope that cuts through the curb at right angles or meets the gutter grade break at right angles.
1104.2.1.1 Running Slope. The running slope shall be 1:48
1104.2.1.2 Cross Slope. The cross slope shall be 1:48
EXCEPTION: This requirement shall not apply to mid-block crossings.
1104.2.1.3 Landing. A landing 48 inches
EXCEPTION: Running and cross slope requirements shall not apply to mid-block crossings.
EDITORIAL COMMENT: The cross slope and running grade requirements do not apply at mid-block crossings 1104.2.1.3). If "Engineering Judgement" cannot be used, all pedestrian crossings at intersections can be prohibited and mid-block crossings provided. Is this the intention of these requirements?
1104.2.1.4 Flares. Flared sides with a slope of 1:10
1104.2.2 Parallel Curb Ramps. Parallel curb ramps shall comply with 1104.2.2, and shall have a running slope that is in-line with the direction of sidewalk travel.
1104.2.2.1 Running Slope. The running slope shall be 1:48
EXCEPTION: A parallel curb ramp shall not be required to exceed 15 feet
1104.2.2.2 Cross Slope. The cross slope shall be 1:48
1104.2.2.3 Landing. A landing 48 inches
GDOT Comment: This is a major problem. See comments on crosswalk cross slope 1105.2.2. Since this area at the edge of the curb, this can sometimes be accomplished by increasing the radii at the corners to get this are away form the travel lanes to allow room for warping the slope, but this increases the length of the crosswalk. Consider that this will require tradeoffs for the pedestrian.
EXCEPTION: Running and cross slope requirements shall not apply to mid-block crossings.
1104.2.2.4 Diverging Sidewalks. Where a parallel curb ramp does not occupy the entire width of a sidewalk, drop-offs at diverging segments shall be protected with a barrier.
1104.2.3 Blended Transitions. Blended transitions shall comply with 1104.3, and shall have running and cross slopes of 1:48
1104.3 Common Elements. Curb ramps and blended transitions shall comply with 1104.3.
1104.3.1 Width. The clear width of landings, blended transitions, and curb ramps, excluding flares, shall be 48 inches
1104.3.2 Detectable Warnings. Detectable warning surfaces complying with 1108 shall be provided, where a curb ramp, landing, or blended transition connects to a crosswalk.
1104.3.3 Surfaces. Surfaces of curb ramps, blended transitions, and landings shall comply with 302. Gratings, access covers, and other appurtenances shall not be located on curb ramps, landings, blended transitions, and gutter areas within the pedestrian access route.
1104.3.4 Grade Breaks. Grade breaks shall not be permitted on curb ramps, blended transitions, landings, and gutter areas within the pedestrian access route. Surface slopes that meet at grade breaks shall be flush.
GDOT comment: Where did this come from? It appears to be impossible to meet this requirement unless the entire intersection is on the same slope (no crown in the roadways). Also, does flush mean less than the 1/4" vertical lip allowed in the pedestrian access route?
1104.3.5 Changes in Level. Vertical changes in level shall not be permitted on curb ramps, blended transitions, landings, or gutter areas within the pedestrian access route.
GDOT comment: If the intent is to require no vertical lips (0" allowable) in these areas it is impossible to meet. If the ¼" allowed in the pedestrian access path it is OK this requirement is redundant.
1104.3.6 Counter Slopes. The counter slope of the gutter area or street at the foot of a curb ramp or blended transition shall be 1:20
GDOT comment: This is OK but it is not what the 2001 report recommended. A definition or picture of "counter slope" would be good.
1104.3.7 Clear Space. Beyond the curb line, a clear space of 48 inches
GDOT comment: The 4x4 clear area is required to begin beyond the curb line. Since the gutter slope only is required to be 5% or less in this area, Can the 4x4 area can include the gutter if the gutter slope is 2.08%? This should be clarified.
1105 Pedestrian Crossings
1105.1 General. Pedestrian crossings shall comply with 1105.
1105.2 Crosswalks. Crosswalks shall comply with 1105.2.
1105.2.1 Width. Marked crosswalks shall be 96 inches
1105.2.2 Cross Slope. The cross slope shall be 1:48
GDOT comment: This is a major problem, especially if reasonable grounds for exceptions are not provided. This requires "tabletopping" the intersection and adjusting the grades on the approaches. If one of the roads is in a curve where the superelevation is greater than 2.08% it requires a change in the horizontal alignment.
GDOT recommendation: Change "The cross slope shall" to "When practical the cross slope should".
EXCEPTION: This requirement shall not apply to mid-block crossings.
1105.2.3 Running Slope. The running slope shall be 1:20
GDOT comment: This is a problem, especially if reasonable grounds for exceptions are not provided and the cross slope requirements are changed. If the cross slope requirements are not change this requirement is meaningless and will not control. This requires changing the grade in the intersection and adjusting the grades on the approaches to less than 5 %. If one of the roads is in a curve where the superelevation is greater than 5% it requires a change in the horizontal alignment.
GDOT recommendation: Change "The running slope shall" to "When practical the cross slope should".
1105.3 Pedestrian Signal Phase Timing. All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
GDOT comment: Currently the GDOT normally uses 3.5 fps that was recommended in the Jan. 2001 report. The speed is reviewed on a case by case basis and 3.0 fps or sometime less is used depending on the type of the pedestrians at the intersection. It is possible to set the signal timing for a pedestrian speed of 3 feet
1105.4 Medians and Pedestrian Refuge Islands. Medians and pedestrian refuge islands in crosswalks shall comply with 1105.4 and shall be cut through level with the street or have curb ramps complying with 1104 and shall contain a pedestrian access route complying with 1103. Where the cut-through connects to the street, edges of the cut-through shall be aligned with the direction of the crosswalk for a length of 24 inches
1105.4.1 Length. Where signal timing is inadequate for full crossing of all traffic lanes or where the crossing is not signalized, cut-through medians and pedestrian refuge islands shall be 72 inches
GDOT Comment: The 6 foot
1105.4.2 Detectable Warnings. Medians and refuge islands shall have detectable warnings complying with 1108. Detectable warnings at cut-through islands shall be separated by a 24 inch
EXCEPTION: Detectable warnings shall not be required on cut-through islands where the crossing is controlled by signals and is timed for full crossing.
1105.5 Pedestrian Overpasses and Underpasses. Pedestrian overpasses and underpasses shall comply with 1105.5.
1105.5.1 Pedestrian Access Route. Pedestrian overpasses and underpasses shall contain a pedestrian access route complying with 1103.
1105.5.2 Running Slope. The running slope shall not exceed 1:20
1105.5.3 Approach. Where the approach exceeds 1:20
GDOT Comment: The requirement to require elevators at pedestrian overpasses / underpasses where the total rise / fall of the ramps is over 60 inches
1105.5.4 Stairs. Stairs shall comply with 504.
1105.5.5 Escalators. Escalators shall comply with 810.9.
1105.6 Roundabouts. Where pedestrian crosswalks and pedestrian facilities are provided at roundabouts, they shall comply with 1105.6.
GDOT Comment: The GDOT agrees that it is a challenge for a pedestrian (especially a vision-impaired pedestrian) to cross a roundabout. However adding pedestrian signals to the roundabout not only decreases the capacity of the intersection it violates driver expectations and provides the pedestrians with a false since of security. The GDOT feels that this requirement would increase vehicular accidents (mostly rear-end collisions) and increase pedestrians accidents. The only advantage to it would be that the driver could be charged with running a traffic light in addition to failing to yield to a pedestrian. As an aside, the definition of roundabout states "an intersection that has yield control?". If this requirement is implemented the definition is wrong.
1105.6.1 Separation. Continuous barriers shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited. Where railings are used, they shall have a bottom rail 15 inches
1105.6.2 Signals. A pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the crosswalk, including the splitter island. Signals shall clearly identify which crosswalk segment the signal serves.
1105.7 Turn Lanes at Intersections. Where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island.
If the discussion in the commentary that states crosswalks are wherever pedestrians crossing are not prohibited is true, the requirement for a pedestrian actuated signal at right and left turn slip lanes should be reconsidered. On most multilane roads the GDOT constructs right turn lanes to allow the turning traffic to get out of the through lanes. This is done to reduce accidents by providing a safer right turn. As written, this requires a pedestrian activated signal (even if a pedestrian is at the intersection just once every 6 months). This is not only very costly and provides very little benefit; it violates driver expectations and will result in increased accidents and probably increase pedestrian accidents. (see roundabout discussion)
Another consideration for not providing the pedestrian activated signal at all slip lanes and roundabouts: In some area of the state, persons (and sometimes organized groups of persons) solicit handouts at intersections. These persons benefit from stopped traffic. The pedestrian signal would continually be activated by these persons (resulting in traffic congestion) even if no pedestrian was attempting to use the crosswalk.
1106 Accessible Pedestrian Signal Systems
1106.1 General. Pedestrian signal systems shall comply with 1106.
The signal that re
1106.2 Pedestrian Signal Devices. Each crosswalk with pedestrian signal indication shall have a signal device which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device and shall comply with 1106.3.
1106.2.1 Location. Pedestrian signal devices shall be located 60 inches
EXCEPTION: The minimum distance from other signal devices shall not apply to signal devices located in medians and islands.
1106.2.2 Reach and Clear Floor or Ground Space. Pedestrian signal devices shall comply with 308. A clear floor or ground space complying with 305 shall be provided at the signal device and shall connect to or overlap the pedestrian access route.
1106.2.3 Audible Walk Indication. The audible indication of the WALK interval shall be by voice or tone.
1106.2.3.1 Tones. Tones shall consist of multiple frequencies with a dominant component at 880 Hz. The duration of the tone shall be 0.15 seconds
1106.2.3.2 Volume. Tone or voice volume measured at 36 inches
1106.3 Pedestrian Pushbuttons. Pedestrian pushbuttons shall comply with 1106.3.
1106.3.1 Operation. Pedestrian pushbuttons shall comply with 309.4.
1106.3.2 Locator Tone. Pedestrian pushbuttons shall incorporate a locator tone at the pushbutton. Locator tone volume measured at 36 inches
1106.3.3 Size and Contrast. Pedestrian pushbuttons shall be a minimum of 2 inches
1106.3.4 Optional Features. An extended button press shall be permitted to activate additional features. Buttons that provide additional features shall be marked with three Braille dots forming an equilateral triangle in the center of the pushbutton.
1106.4 Directional Information and Signs. Pedestrian signal devices shall provide tactile and visual signs on the face of the device or its housing or mounting indicating crosswalk direction and the name of the street containing the crosswalk served by the pedestrian signal.
1106.4.1 Arrow. Signs shall include a tactile arrow aligned parallel to the crosswalk direction. The arrow shall be raised 1/32 inch
1106.4.2 Street Name. Signs shall include street name information aligned parallel to the crosswalk direction and complying with 703.2.
1106.4.3 Crosswalk Configuration. Where provided, graphic indication of crosswalk configuration shall be tactile and shall comply with 703.5.1.
1107 Street Furniture
1107.1 General. Street furniture shall comply with 1107.
1107.2 Clear Floor or Ground Space. Street furniture shall have clear floor or ground space complying with 305 and shall be connected to the pedestrian access route. The clear floor or ground space shall overlap the pedestrian access route 12 inches
1107.3 Drinking Fountains. Where drinking fountains are provided, they shall comply with 602.
1107.4 Public Telephones. Where public telephones are provided, they shall comply with 1107.4.
1107.4.1 Single Telephone. Where a single public telephone is provided, it shall comply with 704.2 and 704.4
1107.4.2 Multiple Telephones. Where a bank of public telephones is provided, at least one telephone shall comply with 704.2, and at least one additional telephone shall comply with 704.4.
1107.4.3 Volume Controls. All public telephones shall provide volume controls complying with 704.3.
1107.5 Public Toilet Facilities. Permanent or portable public toilet facilities shall comply with 603. At least one fixture of each type provided shall comply with 604 through 610. Operable parts, dispensers, receptacles, or other equipment shall comply with 309.
EXCEPTION: Where multiple single-user toilet facilities are clustered at a single location, at least 5 percent, but no fewer than one single-user toilet at each cluster shall comply with 603 and shall be identified by the International Symbol of Accessibility complying with 703.7.2.1.
1107.6 Tables, Counters, and Benches. Tables, counters, and benches shall comply with 1107.6.
1107.6.1 Tables. Where tables are provided in a single location, at least 5 percent but no fewer than one, shall comply with 902.
1107.6.2 Counters. Where provided, counters shall comply with 904.
1107.6.3 Benches. Where benches without tables are provided at a single location, at least 50 percent, but no fewer than one, shall comply with 903 and shall have an armrest on at least one end.
1108 Detectable Warning Surfaces
1108.1 General. Detectable warnings shall consist of a surface of truncated domes aligned in a square grid pattern and shall comply with 1108.
1108.1.1 Dome Size. Truncated domes in a detectable warning surface shall have a base diameter of 0.9 inches
1108.1.2 Dome Spacing. Truncated domes in a detectable warning surface shall have a center-to-center spacing of 1.6 inches
1108.1.3 Contrast. Detectable warning surfaces shall contrast visually with adjacent walking surfaces either light-on-dark, or dark-on-light.
1108.1.4 Size. Detectable warning surfaces shall extend 24 inches
1108.2 Location.
1108.2.1 Curb Ramps and Blended Transitions. The detectable warning surface shall be located so that the edge nearest the curb line is 6 inches
1108.2.2 Rail Crossings. The detectable warning surface shall be located so that the edge nearest the rail crossing is 6 inches
1108.2.3 Platform Edges. Detectable warning surfaces at platform boarding edges shall be 24 inches
1109 On-Street Parking
1109.1 General. Car and van on-street parking spaces shall comply with 1109.
1109.2 Parallel Parking Spaces. An access aisle at least 60 inches
GDOT comment: The vehicular travel lane should not include the bike lane, if present.
EXCEPTION: An access aisle is not required where the width of the sidewalk between the extension of the normal curb and boundary of the public right-of-way is less than 14 feet
1109.3 Perpendicular or Angled Parking Spaces. Where perpendicular or angled parking is provided, an access aisle 96 inches
1109.4 Curb Ramps or Blended Transition. A curb ramp or blended transition complying with 1104 shall connect the access aisle to the pedestrian access route.
1109.5 Obstructions. There shall be no obstructions on the sidewalk adjacent to and for the full length of the space.
EXCEPTION: This provision shall not apply to parking signs complying with 1109.6 and parking meters complying with 1109.7.2.
1109.6 Signs. Parking spaces shall be designated as reserved by a sign complying with 502.6. Signs shall be located at the head or foot of the parking space so as not to interfere with the operation of a side lift or a passenger side transfer.
1109.7 Parking Meters. Where parking meters are provided, they shall comply with 1109.7.
1109.7.1 Operable Parts. Operable parts shall comply with 309.
1109.7.2 Location. A parking meter shall be located at the head or foot of the parking space so as not to interfere with the operation of a side lift or a passenger side transfer.
EXCEPTION: Where parking meters are not provided at the space, but payment for parking in the space is included in a centralized collection box or paying station, the space shall be connected to the centralized collection point with a pedestrian access route.
1109.7.3 Displays and Information. Displays and information shall be visible from a point located 40 inches
1110 Call Boxes
1110.1 General. Call boxes shall comply with 1110.
1110.2 Operable Parts. Operable parts shall comply with 308 and 309.4. Where provided, labeling shall comply with 703.2 and 703.3.
EXCEPTION: Mechanically operated systems in which the signal is initiated by a lever pull shall be permitted to have an activating force of 12 lbf
1110.3 Turning Space. A turning space complying with 304 shall be provided at the controls.
1110.4 Edge Protection. Edge protection complying with 405.9.2 shall be provided where the area at the call box is adjacent to an abrupt level change.
1110.5 Motor Vehicle Turnouts. Where provided, a motor vehicle turnout shall have a minimum paved area of 16 feet
1110.6 Two-Way Communication. Where provided, two-way voice communication shall comply with 1110.6, 708.2 and 708.3.
1110.6.1 Volume Controls. Volume controls complying with 704.3 shall be provided.
1110.6.2 TTY. A TTY complying with 704.4 shall be provided.
1111 Alternate Circulation Path
1111.1 General. Alternate circulation paths shall comply with 1111.
Also see comment in 1102.3
1111.2 Width. The alternate circulation path shall have a width of 36 inches
1111.3 Location. The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street.
GDOT comment: This should be a recommendation and subject to Engineering judgement. This will require additional easement and may cause additional displacements. Providing a pedestrian route on the same side of the road for a few hours, weeks or months should be weighed against the community impacts. Especially since many existing sidewalks were built to avoid taking homes and there is limited pedestrian usage.
This requirement may reduce the overall safety to the pedestrians since it will provide path near the construction equipment.
On a project where existing bridges with sidewalk on both sides are being widened, this requirement will require pedestrian accommodations on both sides, which will often require a temporary pedestrian bridge (or 2 temporary bridges).
1111.4 Protection. The alternate circulation path shall comply with 307 and shall be protected with a barricade complying with 1111.6 to separate the pedestrian access route and alternate circulation path from any adjacent construction, drop-offs, openings, or other hazards.
GDOT comment: This needs clarification. In the permanent condition the pedestrian on the sidewalk is only protected from traffic by curb(2 feet
1111.5 Signs. Signs complying with 703.5 shall be provided at both the near side and the far side of the intersection preceding a disrupted pedestrian access route.
1111.6 Barricades. Barricades shall be continuous, stable, and non-flexible and shall consist of a solid wall or fence or a Type II or Type III barricade as specified in MUTCD section 6F-60 with the bottom or lower rail 1-1/2 inches
David J. Barakian, September 24, 2002
City of Palm Springs
Department of Public Works and Engineering
Palm Springs, CA 92262
Re: Comments Regarding "Draft Guidelines for Accessible Public Rights-of-Way"
Enclosed, please find the comments provided by myself, the Director of Public Works/City Engineer, and Phil Kaplan, the ADA Coordinator for the City of Palm Springs.
Sincerely,
David J. Barakian
Director of Public Works/City Engineer
Comments Regarding "Draft Guidelines for Accessible Public Rights-of-Way"
Additions and Alterations (1102.2), 2
Alternate Circulation Path (1102.3, 1111), 1
Pedestrian Access Route (1102.4), (1103): I recommend that clearer guidance be given with respect to sidewalk cross slope through a drive approach, i.e. does a 48-inch "flat" area need to be provided around the approach in areas with curb adjacent sidewalk to avoid the large cross slopes in approaches? Also, I recommend the issue of sidewalk or pedestrian access adjacent to bay parking areas to be addressed. I feel sidewalks should not be allowed behind vehicles parking in "bays" 90 degrees
Grade (1103.5), 1
Surface Gaps at Rail Crossings (1103.7), 1
Curb Ramps and Blended Transitions (1102.6, 1104), 1
Pedestrian Signal Phase Timing (1105.3), 1
Pedestrian Overpasses and Underpasses (1105.5), 1
Roundabouts (1105.6):
2
3
Accessible Pedestrian Signal Systems (1102.8, 1106), 2
Street Furniture (1102.9, 1107), 1
1102.2.2 Alterations: Impossible to interpret this.
1102.8 Pedestrian Crossings: Is every crosswalk a pedestrian crossing?
1102.9 Street Furniture: Not customers of a restaurant?
1105.3 Pedestrian Signal Phase Timing, 2
1105.6.2 Signals: With audible tone and vibro tactile indications?
1109.2 Parallel Parking Spaces: These need a drawing to explain.
Amadeo Saenz, Jr., P.E., October 25, 2002
On behalf of the Texas Department of Transportation (TxDOT), I would like to thank the U.S. Access Board (Board) for its extensive effort to develop guidelines with specific application to the public rights of way. I agree that practitioners need specific guidance applicable to public right of way projects that recognize the site constraints involved in these types of projects.
Recognizing that no rule of this type will ever satisfy all parties, we believe that, overall, the Board has done a good job of balancing accessibility needs with the real world limitations of restrictive right of way widths, challenging terrain, and other factors. However, some of the draft provisions do cause particular concern for this agency and will be addressed in detail in the comments that follow.
I thank the Board for allowing our representative to serve on the Public Rights of Way Access Advisory Committee and appreciate the opportunity to comment on these important guidelines.
Sincerely,
Amadeo Saenz, Jr., P.E.
Assistant Executive Director
Engineering Operations
[PDF Version]
Comments and Recommendations
on the
Draft Guidelines for
Accessible Public Rights-of-Way
October 2002
Broad Issues
Cost is always an issue when new regulations are imposed. TxDOT is already stretching available funding extremely thin and we are only able to fund approximately a third of the needed improvements that have been identified. Some proposals contained in the draft guidelines would require a substantial amount of funds.
Tolerances within the highway construction industry are rarely to the nearest millimeter - and, in some cases, inches are too precise. Highway construction tolerances are not the same as those in architectural design. The Access Board needs to revise the units of measure used throughout these guidelines appropriately based on the item being measured. Examples of excessive precision include the maximum curb ramp length of 4,570 mm and the minimum rise of 1,525 mm for which an elevator is required. This precision is not achievable in the field and TxDOT cannot afford to be held liable if certain measurements are off by as little as a millimeter.
Defined Terms (§1101.3)
a) Alteration. A tremendous amount of clarification is needed related to the term "alteration," as well as the requirements that it triggers. Currently, this term is open to a wide range of interpretation, which is likely to open up public agencies to potential lawsuits. Standard engineering terminology needs to be used to ensure that the requirements are understood and implemented correctly. Either a definition or additional guidance in this area is necessary so that agencies and their staff can be certain that they are meeting the requirements of the ADAAG. Such definition or guidance should utilize terminology more familiar to transportation engineers - such as resurfacing, restoration, rehabilitation and reconstruction.
b) Barrier. TxDOT recommends removing this term from the guidelines and replacing it with "edge delineation" or a similar phrase where appropriate. Otherwise, the term needs to be defined. As currently used, the term "barrier" has a different meaning from that commonly understood by transportation engineers, which will lead to confusion regarding what is required or desired. Transportation engineers will think of longitudinal barriers that are placed along the roadside to shield motorists from obstacles. Examples of barriers include the massive concrete "Jersey" barriers seen often along major freeways and steel W-beam guardrail. These barriers must meet very specific performance criteria to ensure that they can safely contain and redirect errant motor vehicles and are not what we believe you generally intend to require in the pedestrian environment.
c) Blended Transition. While discussing the draft provisions with several transportation engineers, it is evident that this term is not widely recognized and needs definition to ensure that the related provisions are properly interpreted.
d) Cross Slope. The definition for cross slope is different than that used by the highway design community. Cross slope would generally be used to describe any pavement slope that is perpendicular to the direction of vehicular travel. The term superelevation is only used to describe the increased cross slope that is placed on roadway surfaces in the presence of a horizontal curve, often called "banking". TxDOT suggests that the two terms not be used interchangeably and that the second sentence under the cross slope definition be stricken.
e) Pedestrian Access Route. Refine this definition to state: "An accessible corridor intended for pedestrian use within the public right-of-way." TxDOT does not generally intend for pedestrians to utilize shoulders and could not design shoulders to meet the cross-slope and other requirements contained herein and still meet roadway design engineering criteria.
f) Roadway. TxDOT recommends that a definition of "roadway" should be included, to define a roadway as a vehicular travelway, whether on the ground or on a bridge. This is necessary to avoid issues and confusion regarding sidewalks on bridges that have a running slope greater than 5% (1:20). We suggest "The portion of the public way ordinarily used for vehicular travel, shoulder, or parking, inclusive of bridges, but exclusive of the sidewalk or curb."
g) Running Slope. Both "grade" and "running slope" are used throughout the guidelines interchangeably. For example, the term "grade" is used in Section 1103.5 when referring to the Pedestrian Access Route, but "running slope" is used in Section 1105.2.3, which refers to crosswalks (which are part of the pedestrian access route). TxDOT recommends removing the term "running slope" from the guidelines and using "grade" consistently, since it is the more common term used by transportation engineers.
h) Superelevation. Delete this term since it is not used in the draft rule. If it is retained, it should be correctly defined as "The increased cross-slope on a roadway curve that assists in counteracting the lateral acceleration imposed on traveling vehicles."
Scoping Provisions (§1102)
a) §1102.1 and §1102.2.2 - As mentioned briefly under the comments related to defined terms, much clarification is needed on what constitutes a newly built or altered pedestrian way. In the area of signals, some very simple improvements could be misconstrued as an alteration. Clarity is essential for the proper application of these requirements by state and local governments. For example, if an existing signal is re-timed to account for changing traffic demands, does this constitute an alteration? What about changing out the signal lamps to LED displays? More definitive scoping language on a variety of project types is needed to provide clarity for practitioners. We suggest using standard roadway design terminology to clearly communicate to practitioners the scope of ADA improvements necessitated by various types of road projects. Industry standard terminology is generally referred to as the 4R's (resurfacing, restoration, rehabilitation and reconstruction) and preventive maintenance. TxDOT definitions for these terms are as follows:
· Preventive Maintenance - Preventive maintenance for pavements is a relatively light-duty treatment applied before the pavement shows obvious signs of deterioration. These treatments preserve condition and prolong pavement life either by repairing the surface or by preventing intrusion of water into the underlying layers. Some typical preventive maintenance treatments for pavements are: seal coat, thin overlay, crack seal and joint treatment.
· Resurfacing - Resurfacing is the application of an additional surface to an existing base pavement or wearing surface to improve the ride, strength, or safety of the pavement.
· Restoration (2R) - Work proposed to restore the pavement structure, riding quality, or other necessary components to their existing cross section configuration.
· Rehabilitation (3R) - Rehabilitation is work proposed to improve serviceability and extend the service life of existing highways and streets and to enhance safety. Work is usually accomplished within the existing right of way. Work may include the upgrading of geometric features such as roadway widening, minor horizontal re-alignment, and improving bridges to meet current standards for structural loading and to accommodate the approach roadway width.
· Reconstruction (4R) - Work proposed on the approximate alignment of an existing route that meets the geometric criteria for a new facility. Reconstruction includes projects that provide substantial changes in the general geometric character of a highway, such as widening to provide additional through travel lanes, horizontal or vertical re-alignment, etc.
Language should be provided to indicate the level of accessibility improvements necessitated by the scope of various roadway projects. Suggested language might look something like:
· Preventive maintenance, signal maintenance - no accessibility upgrades required
· Resurfacing - curb ramps to eliminate barriers to an existing sidewalk or path
· Restoration(2R) - curb ramps to eliminate barriers to an existing sidewalk or path, repair damaged sidewalk or ramps
· Rehabilitation (3R) - curb ramps to be installed/upgraded, sidewalk to be widened to provide accessible pedestrian route
· Reconstruction (4R) - curb ramps to be installed, sidewalk to be widened to provide accessible pedestrian route, accessible pedestrian signals to be installed at signalized intersections
· New construction - Meet ADAAG
b) §1102.2 - Many improvements within existing public right of way can be accomplished if "additional right-of-way" can be acquired and budgets are unlimited as the explanatory language to this draft rule suggests. The problem is with the amount of time involved in obtaining this right-of-way. Frequently, condemnation of property is necessary for acquisition and this is a lengthy process. With regard to signals, they are frequently installed following one or more crashes in an effort to improve intersection safety. The same is true for some crosswalk installations. Installation of a signal or crosswalk in these situations is a high priority for the public. While we agree that accessibility improvements should be made as a result of this alteration, we need the flexibility to address the immediate need for a signal or crosswalk and, if necessary, defer other improvements until additional right of way can be acquired.
c) §1102.2.1 - Clarify whether "additions to the public right of way" means the acquisition of additional ROW or the addition of a particular feature within an existing ROW. The draft language states that "where the addition connects?" - where does a connection end? For example, if a new signal is installed, it "connects" to the sidewalk so how much of the existing sidewalk is subject to §1102.2.2? The sidewalk connects to curb ramps, they connect to the crosswalk, then to the opposing corner - where does this "connection" end?
d) §1102.3 - There are times when only a short duration closure of a sidewalk is necessary. The draft provision needs to be modified to allow for short duration closures without invoking the requirement for an alternate circulation path. For example, if a utility needs to access their facility by utilizing a manhole in the sidewalk, an alternate path should not be required if the closure only persists for less than 24 hours.
e) §1102.5 - It is possible that, given the ADA requirements for letter size and stroke width for pedestrian pushbutton signs, along with those listed in 1102 of this document, the resulting sign sizes may protrude beyond the 4 inches
f) §1102.5.1 - The language says 'Objects? shall protrude?'. This makes it sound impossible to have objects that don't protrude. We suggest rewording this sentence.
g) §1102.6 - Combined with §1104.2, this section appears to eliminate the use of diagonal ramps. See comments under §1104.2.
h) §1102.10 - TxDOT suggests that the draft language be revised to also require placement of a contrast strip on the upper approach to stairs.
i) §1102.13 - We believe the embedded reference to 810.2 is incorrect. While it makes sense to refer to 810, section 810.2.3 refers back to section 402 which is inappropriate. It appears that the reference to 402 should be replaced by a reference to §1103.
j) §1102.14 requires one accessible parking space be provided on each block face that includes on-street parking. ADAAG utilizes a table in 4.1.2(5) [now 208.2] which required that 1 in
Technical Provisions
§1103 Pedestrian Access Route
a) §1103.3 - A provision is needed to allow limited encroachments into the pedestrian access route, similar to that afforded in 403.5.1.
b) §1103.5 - We support this provision. As mentioned under "defined terms", we believe that "roadway" should be defined to specifically include roadways that are on structures as part of the definition. This draft rule is not clear on whether roadways on bridges are included in this provision. Certainly, grades should be minimized on structures but physical constraints often make this difficult, particularly in alterations. Bridges have to achieve a minimum clearance over the roadway, railroad or waterway they cross, and frequently have to tie into streets at either end of the structure.
In addition, since the curb ramp is considered part of the pedestrian access route (per Section 1103.2), the ramps will always exceed the grade of the adjacent roadway because they have to provide the transition from sidewalk to roadway. Curb ramps need an exemption from this provision. In also should be recognized that if the roadway is on a grade, that roadway grade will begin while you are still holding the corner basically level to get the landings in. Some amount of "exceeding the roadway grade" may be required just to tie the sidewalk into the landing elevation. Additional language needs to be included to ensure that this condition does not result in a violation of the guidelines.
§1104 Curb Ramps and Blended Transitions
a) §1104.2 - TxDOT suggests revising the language to clearly permit the installation of diagonal curb ramps. Diagonal curb ramps are not included in the draft rule as a type of curb ramp. §1102.6 requires the provision of "a curb ramp? (for) each crossing." The draft rule isn't clear on whether diagonal ramps would still be allowed. It is rumored that diagonal curb ramps would be prohibited by virtue of their omission here. While we recognize the need to provide one curb ramp for each crossing direction whenever possible, there are instances in which a diagonal curb ramp is the only type of installation that is feasible. This is most common where a large corner radius is needed to accommodate the turning movements for large trucks. Since the Manual on Uniform Traffic Control Devices (MUTCD) contains regulatory requirements for the location of the crosswalk markings, it is not always possible to move the crosswalks far enough from the intersection to accommodate individual ramps. In order to comply with the MUTCD, accommodate the expected truck turning movements, and provide for accessibility for pedestrians, the use of diagonal curb ramps is sometimes necessary. Diagonal curb ramps may also be the only available option when adding curb ramps as required under an alteration project, and where underground drainage structures or utilities preclude the placement of individual curb ramps.
While the PROWAAC report discouraged the use of diagonal (shared) curb ramps, the committee did recognize in the discussion that sometimes intersection geometry precludes the placement of a separate curb ramp for each crosswalk. The committee went on to say that combination of such variables as curb radius, sidewalk width, and furnishing zone width, create situations where shared curb ramps are the only possible alternative. Some of the situations the committee cited are:
· A corner with a radius that is so large that the crosswalks meet at the midpoint of the curve.
· A corner where placing two curb ramps would result in them being located outside the crosswalk markings, or would result in stop bars placed too far back on the side street for driver safety or pedestrian safety.
· An intersection that is skewed, such that two curb ramps will not fit in the acute angle corners.
· An alteration, where the corner has retaining walls, buildings, or other barriers that are technically infeasible to relocate.
· An intersection in which one street has an unavoidably steep grade, and a shared curb ramp at the midpoint of the curb return may have less severe warp than a curb ramp or flush landing closer to the tangent of the steep street.
· An intersection in an area of steep terrain, where both streets are flattened to allow for acceptable crosswalk slopes. It may be feasible to flatten a small intersection area and provide accessible crosswalks leading to a shared ramp. Placement of a pair of curb ramps would necessitate a larger flattened area, resulting in steeper sidewalks between intersections.
b) §1104.2.1 - This section appears to prohibit the use of a directional curb ramp within a curb radius, as shown in Figure X02.4G in the committee report. Where these ramps can be provided without much warping, they provide directionality to visually impaired users and they also work well when a curb ramp to cross the main throughway is not needed.
c) §1104.2.1.3 - The draft language says 'overlap other landings and clear floor or ground space' is permitted but then §1107.2 limits the overlap to 12". This section should be reworded for clarity.
d) §1104.2.1.4 - Current ADAAG requires a flare with a 1:10
In addition, the actual way to dimension the flare should be re-evaluated. The PROWAAC recommendation for side flares in their report, Building a True Community, was that the flare should be ten times as long as the curb height. This results in the required slope on the flare being measured relative to the grade of the roadway and the cross slope on the curb ramp. It is not logical to require an absolute slope relative to a horizontal plane in a sloping environment such as the public right of way. Based on our suggested 1:4
e) §1104.2.2.1 - The language needs to be clarified to indicate whether the 15' maximum length extension applies to either sloped portion on a parallel ramp (as indicated in the committee report) or to the entire curb ramp combination (two sloped portions plus the lower landing).
f) §1104.2.2.4 - Why is a barrier required regardless of the height of the dropoff when no barrier is required adjacent to a 6" dropoff at the curb/street interface? What type of barrier is recommended in this situation? Please refer to our discussion regarding the use of the term 'barrier' under defined terms.
g) §1104.3.2 - It's not clear whether detectable warnings are required on curb ramps that don't connect to a crosswalk, such as those connecting to parking spaces or within internal streets within a park for example.
h) §1104.3.2 and §1108.2 - It is not clear that detectable warnings are not to be provided at driveway crossings. The committee report was more definitive on this point and we fear that some people will consider driveways as an intersection that requires placement of the detectable warning.
i) §1104.3.3 - In
j) §1104.3.7 -While we understand the need for this clear space at the bottom of a diagonal and perpendicular curb ramps, we don't understand the phrase "beyond the curb line." The lower landings of parallel curb ramps and the relatively level design of blended transitions should allow users to line up with the crosswalk and wait for the pedestrian signal nearly at the edge of the street.
§1105 Pedestrian Crossings
a) §1105.2.1 - We recommend that this language be revised to be consistent with the MUTCD, retaining the 72-inch minimum crosswalk width. The draft requirement for a 96-inch crosswalk does not appear to be driven by accessibility needs but rather by pedestrian advocacy. While major metropolitan areas may need this width to handle platoons of pedestrians, that decision is an engineering one made with judgement and considering relevant factors at a specific location and should not be mandated here. Eight-foot wide crosswalks are excessive in many small rural towns where few pedestrians are present. In addition, the additional 24-inches in width will further exacerbate the difficulty of constructing the crosswalk with a maximum 2% cross slope.
b) §1105.2.2 - Since the rules apply to "both marked and unmarked crossings, wherever pedestrian travel across the roadway is not prohibited", creating "tabled areas" will be a requirement for virtually every street/highway intersection.
While we understand the need to minimize the cross slope in crosswalks to make the crossing as accessible as possible, tabling every intersection would violate several engineering principles used for roadway design and would result in roadways that do not comply with the nationally accepted design practice outlined in the Policy on Geometric Design of Highways and Streets published by the American Association of State Highway and Transportation Officials (AASHTO). While tabling intersections might be acceptable at the lowest speed ranges common in highly developed urban areas, this practice would not be acceptable on roadways designed to accommodate higher design speeds. Most downtown urban roadways were constructed long ago. The roadways being constructed now are typically more in the suburban areas, as cities continue to grow. In these areas, design speeds are typically higher than in the downtown grid and generally range from 40-50 mph. At those speeds, cars and trucks cannot safely traverse a roadway grade that is leveled at every intersection. Vehicles would be vaulting or "bottoming out" at every intersection. Abrupt profile changes makes driving more difficult and would increase the possibility of rear-end collisions due to vehicles suddenly reducing speeds to traverse the intersection. The department suggests that the language be revised to require the minimum feasible cross slope that can be achieved for the design speed and the terrain in the area.
To further illustrate our concerns with this requirement, we did a sample design for a street on 5% grade (not uncommon in hilly areas), with cross streets occurring at 500' spacing. That's not uncommon, and is actually longer than the spacing in many areas. Using these conditions, it is impossible to connect the "table" areas at the intersections with a profile that meets a 40 mph design speed (our typical thoroughfare design speed). We ended up with a grade between the intersections of over 8%, and vertical curves that would only meet about a 32 mph design. It should also be noted that in this sample problem, the grade revision resulted in a cut at the low end of approximately 3' and a "hump" at the upper end of approximately 2' in height. These conditions will require acquisition of additional ROW and/or special design of driveways, retaining walls, drainage facilities, etc.
From what we can tell, if we have any grades that go above about 4%, (less if cross streets are more closely spaced) we will not be able to meet both the AASHTO and the ADAAG criteria. The conditions we've described are worsened if (1) the cross street is wider, (2) the cross street spacing is less, or (3) the grade of the main street is greater.
The draft rule would lead to significant costs to redesign and reconstruct existing intersections, including relocating drainage features, raising/lowering adjacent sidewalks, relocating or modifying underground and adjacent above-ground utilities, and constructing retaining walls. For these reasons, and the operational problems described above, we suggest this language be rewritten to read "Cross slope in crosswalks shall be the minimum possible while still providing a roadway design that meets accepted roadway design criteria."
c) §1105.3 - Pedestrian Signal Phase Timing.
A primary concern when dealing with pedestrian clearance phases is the effect on efficiency of the intersection. Longer pedestrian phases result in more delay for the opposing street. Another concern is the impact on preemption designs for intersections near railroad crossings. Longer clearance phases can often result in substantially higher costs due to circuitry that may be needed on the rail line for advance train warning.
TxDOT does not support the use of a slower walking speed in calculating pedestrian clearances for all cases. Rather, we suggest that a provision be added which would allow for the use of MUTCD valuesunless the pushbutton is held down for an extended period of time. This would still allow for the long clearance phases for mobility impaired persons, but not penalize the efficiency of intersection operations for every pedestrian phase served.
Also, the draft language isn't clear as to whether the length of one or both adjoining curb ramps has to be included in the crossing distance calculation. While it may make sense to include the length ofone perpendicular curb ramp since users would wait on the top landing to begin to cross, if the adjoining curb ramp is a parallel curb ramp or a blended transition, the user will be at the edge of the street when the light changes and the additional distance would not be necessary to include in the calculation.
Any increase in delay at signals will diminish efforts by state and local governments to improve air quality as required by the Clean Air Act.
d) §1105.4.1 - If a landing area only has to be 4'x4', why does a median have to be 6' wide to provide refuge? This minimum 6' dimension will be simply impossible to meet in many medians and triangular channelizing islands at intersections.
e) §1105.4.2 - The two foot minimum separation between detectable warnings may not be possible to meet on the above mentioned small channelizing islands. In addition, we would suggest eliminating the exception to this section. Even if the signal is timed for the full crossing, some individuals may require more time to cross. We think it would be more consistent to always provide the detectable warning in the median.
f) §1105.5.3 - We have concerns about the construction and maintenance of elevators in the outdoor environment as required under this section.
The cost for elevator installation would be in the $125,000 range. We think this would be additional cost because either stairs or ramps would still be required for emergency evacuation and we would anticipate using ramps to provide for evacuation for the disabled. We would have to provide electrical power (3 phase 208 service) to each site, telecom service line, a crane, a concrete pit, a concrete slab for the elevator machine room and exterior building finish, i.e., brick, concrete tilt wall, concrete masonry walls, metal panels, or stucco finish. The elevator would be a holeless telescopic twin jack hydraulic elevator machine type, 5'?8" x 5'?0" unconditioned cab, 2500 lb. maximum capacity, travel height of 18'. (greater travel heights available at higher costs). The elevator would meet ADA requirements, having a front and rear entry.
The best of elevators break down and could strand disabled persons in severe weather. Emergency response time to malfunctioning elevators at best could be expected to be an hour or two. Emergency response time during peak traffic and inclement weather conditions could be longer. Elevators would be subject to vandalism to both the operational features of the elevator and the emergency telephone. When the emergency telephone is out of order a person could be stranded on an elevator for an unacceptable amount of time. As the elevator gets older, the down time will become significant. Parking garage elevators are routinely used as bathrooms and have the smell of urine. It could be expected that elevators at these sites would be even worse with the limited traffic at night. In addition, we are extremely concerned about the potential for these elevators to become the site of criminal activity since they will not be heavily utilized and may be located in remote areas.
Daily inspections would be required to insure adequate service. Daily inspections will take one to two hours depending on the travel time. This would cost about $10,000 per year. Maintenance of the elevators would require service contracts with elevator specialist companies. Routine preventive maintenance service of the elevator would be about $1000 per year. Utilities costs for telephone and electric service would be about $500 per year. It is hard to estimate the cost of service calls. Rough estimates would be zero to $5,000 per year. As the system gets older the cost would go up. In communities where there are no elevator repair companies the cost would be higher. Total maintenance cost would range between $11,500 and $16,500 per year. This does not include rehabilitation cost due to wear out or costs due to major damage caused by vandalism.
A majority of the pedestrian overpasses built in Texas are for providing safe access for students to public schools and the schools, cities, or DOTs bear the brunt of paying for the overpass. In many communities the extra cost of the elevators would prevent pedestrian overpasses from being built. TxDOT recommends the elimination of this requirement. If desired, the Access Board might want to allow elevators to be provided in lieu of ramps but they should not be required.
g) §1105.6.1 - The rule needs to be clarified as to whether vegetation/ landscaping along the roundabout would provide sufficient barrier between the street and the sidewalk. As previously mentioned, the term "continuous barriers" tends to mean roadside hardware such as metal beam guard fence or concrete traffic barrier in the traffic engineering community. We suggest the language be revised to require "separation by landscaping or barriers" instead. In addition the use of come standard roadway barriers at intersections is undesirable due to their height and the resulting impact on sight distance available to drivers. Designers need to make sure that there are no obstructions to between 2' and 7' above the pavement (the general guidelines for sight distance obstructions.)
h) §1105.6.2 - Traffic signals should be installed only after a traffic engineering study has been conducted that indicates a traffic signal is warranted. In order to install pedestrian activated crossing signals at each roundabout crosswalk would require the signalization of the roundabout, which defeats the purpose of the roundabout, to control traffic without signals. The MUTCD does not address the signalization of traffic circles. MUTCD signing and marking requirements for traffic signals and roundabouts conflict with each other. A roundabout would be very inefficient if operated as a signalized intersection and would be a poor design decision from a planning standpoint. In addition, drivers are less likely to expect a traffic signal within a roundabout and may not react to it in time for safe pedestrian crossings. Signals that are not operated continuously may catch drivers unaware when they are used, resulting in low compliance with the signal indication. It is recommended that an alternative to this requirement be investigated.
i) §1105.7 - TxDOT strongly opposes any requirement for traffic signals on slip turn lanes at intersections. In addition, crosswalks are provided at many unsignalized intersections, yet this language appears to require signals for the turn lanes, even when the rest of the intersection is not signalized. Traffic signals should only be installed after a traffic engineering study has been conducted that indicates a traffic signal is warranted.
There is very little discussion given for the draft requirement for the installation of pedestrian signals at turning lanes. TxDOT has an estimated 7,500 traffic signals on our facilities. We estimate that approximately 25% of these intersections have two right turn lanes. The signal for each right turn lane is estimated to add $1250 to the cost of the intersection. Therefore, this provision will cost the state approximately $4,687,500 to implement as these intersections are rehabilitated over the next 10-15 years. It's very difficult to estimate the increased delay cost, and associated degradation in air quality (including in non-attainment areas) that would result from this requirement but we believe it will be significant.
Drivers do not expect to find a traffic signal at a slip lane and may not react to it in time - especially if it is only occasionally activated - for safe pedestrian crossings. It is likely that these signals will give the pedestrian a false sense of safety when stepping out onto the roadway. When activated sporadically, it will also likely result in increased rear-end crashes and, potentially, subsequent impacts with pedestrians. In addition, signals are likely to have significant operational impacts on slip lanes - lowering traffic throughput in these locations - and will effectively negate the advantages they provide at high traffic volume intersections. In addition, any increase in delay at signals will diminish efforts by state and local governments to improve air quality as required by the Clean Air Act.
TxDOT recommends that the Board look into specific traffic and pedestrian volumes or other factors to determine when it would be most beneficial to require these signals.
§1106 Accessible Pedestrian Signals
a) §1106 - If accessible pedestrian signals must be installed (based on the draft language) anytime a pedestrian signal is "altered" (reference §1102.2.2), then TxDOT would have to replace all signals with APS over about a 5-10 year period as pedestrian pushbuttons are replaced due to damage. Based on current pricing for parts and labor, TxDOT estimates that the average cost to retrofit an existing intersection would be approximately $5,000. With approximately 7,500 traffic signals on TxDOT roadways, and over 11,000 signals throughout the state, this represents an additional expense of $39 million for TxDOT and $57 million statewide.In addition, TxDOT feels that the installation and maintenance of these devices would increase the operation and liability costs to state, county, and city governments considerably. The decision to install these devices should be based on planning and engineering decisions based on a specific need and not made a blanket requirement.
TxDOT currently performs a number of electronic and destructive tests on traffic signal devices placed in the field. We are concerned about adopting a specific type of device before it has been adequately tested for reliability or durability.
b) §1106.2.1 - The term "pedestrian signal devices" generally includes a variety of signal equipment. It appears here that the Board is specifically talking about the location of the push button in the first sentence. We suggest changing the language to read "Pedestrian push buttons shall be located?" The draft rule requires pedestrian push buttons to be a minimum of 10' apart from each other and located within a specified distance of the curb and the crosswalk. These separations will not be possible on small channelizing islands and where right of way is limited at the corner. We suggest adding an exception for these locations.
c) §1106.2.3.1 appears to allow the cuckoo/chirp type of audible signal. We understood from the committee report that there are problems interpreting these signals and suggest that they not be permitted.
d) §1106.4.2 - The requirement for street names to be placed on signs at every pedestrian push button will necessitate the purchase of new equipment by this department and likely by other public agencies responsible for sign placement. Current practice is to place a sign with an arrow at the pushbutton. To minimize the cost of these signs, we make the signs with simply the bar of the arrow and omit the arrowhead. When signs are placed in the field, the arrowhead is stuck onto the sign to indicate the appropriate direction. This allows for bulk production of the signs. The proposed requirement would substantially increase the production time and cost for signs located at pushbuttons. TxDOT anticipates a six month delay in getting a given sign produced for a specific push button. Field crews will be required to make an additional trip to the location to mount the sign or installation of the push button will have to be deferred until the sign is available. Mass production would be impossible since each sign would have a unique name and would have to include tactile characters in compliance with ADAAG 703.2. In addition, 703.2 requires that raised characters be duplicated in Braille.
§1108 Detectable Warning Surfaces
a) §1108.1.1, 1108.1.2 - TxDOT supports the flexibility provided in the draft language for the size and spacing of the truncated domes. This will allow the department to consider products offered by several vendors to achieve compliance.
b) §1108.1.3 - The requirement for visual contrast on the detectable warning is extremely vague with no measurement being required. This is likely to result in much confusion and inconsistency of application across the country. We suggest the Board specify a level of minimum contrast and a simple and reliable method for measuring contrast in the field.
c) §1108.1.4 - Since the draft rule says "24 inches
d) §1108.2 - It is not clear that detectable warnings are not to be provided at driveway crossings. The committee report was more definitive on this point and we fear that some people will consider driveways as an intersection that requires placement of the detectable warning.
e) §1108.2.1 - Language needs to be clarified whether "nearest the curb line" refers to the face of curb or the back of curb. Vertical curbs are typically 6 inches
§1109 On-Street Parking
§1109.5 - How far back on a sidewalk from the accessible parking space does this restriction on obstructions apply? (i.e., how far back is "adjacent to...the space"?)
§1111 Alternate Circulation Path
In many cases, there is not enough available space for a parallel pedestrian access route on the same side of the street. Also, there are times that only a short duration closures of a sidewalk are necessary. The MUTCD allows for a pedestrian detour to be set up which would send pedestrians across the street at the nearest possible signalized crossing. In our opinion, this is more than adequate. We recommend that the language in section 1111.3 be changed to read "? on either side of the street" and that engineering judgement be allowed to govern where the agency determines it safe to provide an alternate path.
Re: Draft guidelines on Public Rights-of-Way Accessibility as proposed by the U.S. Access Board.
I wish to thank you for allowing myself and others an opportunity to provide comments on the set of Draft Guidelines on Accessible Public Rights-of-Way as proposed by the US Access Board.
I have reviewed the new guidelines, dated June 17, 2002, and I would like to make comments of concern on these guidelines. There is significant unintended consequences with many of the suggestions coming from the access board. There should be additional thought given to how the suggestions impact the whole community, rather than the impaired. Further thought should be given to the whole Nation and its' terrain rather than a flat surface. The new regulations have to be stringent enough to enforce, yet flexible enough to provide the best solution in all situations. The access board has a difficult decision to make, whether to leave good roadway practices in place for vehicular safety or sacrifice these practices for the benefit of those with disabilities. Thoroughfares accommodating pedestrian traffic may need some design changes, but it is essential that traffic safety and proper vehicular traffic flow is not diminished.
1102.2 General.
The acquisition of additional right-of-way is a great idea, but the cost of necessary right-of-way to have fully compliant curb ramps will add $150.00 to $1,500.00 cost per ramp. All acquisitions have to have documentation and recorded easements or right of entry permits prior to construction. Most municipalities do not have the staff nor the funds to add to the existing burden of providing new ramps. Cities have a right-of-way widths that will handle acceptable sidewalk widths and allow compliant curb ramp installations in less than half of the planned curb ramp locations. Existing drainage and utilities prohibit compliance in the many of the locations surveyed.
If municipalities were able to obtain the easements or acquire necessary right-of-way with no cost to the tax payers, they would be able to have fully compliant ramps. Currently, narrow sidewalks, steep running grades and cross slopes, and insufficient right-of-way is the current major problem that hinders our goal for full compliance.
If the proposed guidelines and standards are too exacting and requires strict mandated regulation for attaining maximum compliance, some of the guidelines will not be attainable as accessible pedestrian corridors without excessive costs to developers and the City.
The roadways are intended to move vehicular traffic as efficiently as well as have sidewalks for pedestrians. Roadways should have president over pedestrian movement not pedestrian over vehicular movement. We may be able to have harmony in movements at most intersections, but not at all intersections because of topographical constraints. There are many existing streets with grades that range from 9% to 12%. The majority of the street intersections have pedestrian paths with cross slopes in the 1:96
In historic areas the street cross slope may be in excess if 14%, though rare. These streets are generally resurfaced and maintained using the circa 1890-1920, parabolic crown. Some streets dating from 1845 have been flattened somewhat by adding asphalt or raising the gutter line, altering the curb height to less than five or six inches.
1102.3 Alternate Circulation Path.
This is to comply with 1111. When a roadway is closed in part or whole a safe alternate pedestrian route will be determined. Likewise for building renovation and/or construction, if the sidewalk must be closed, an alternate safe route will be defined. This route may be on the opposite side of the street or in may be a detour to the next parallel street that is accessible.
1102.4 Sidewalks.
This paragraph refers to 1103 and must comply with chapter 11. 1103.3 requires a minimum clear width of 48 inches
1102.8 Pedestrian Crossings.
References 1105, specifically 1105.2.2 Cross Slope. The cross slope shall be 1:48
1102.14 On-Street Parking.
If this proposal is intended to include residential areas to have designated accessible parking, then, in some cases it is not feasible because of the existing short distances between street intersections. In the business districts, usually, insufficient sidewalk widths and structural problems do not allow provision for this proposal. The unintended consequences will be significant and costly.
1103.2 Components.
Pedestrian overpasses and underpasses in their existing state are accessible routes. The sidewalks follow the running slopes of the street that are usually less than 6%. The need for elevators and platform lifts should be based on local area need, with some flexibility based on need rather than a cover-all regulation. The cost of installing 2 lifts or limited use elevators will add significantly to the cost of planned pedestrian accessible routes. The proposed regulation will cause some planned improvements to be discarded.
1103.3 Clear Width.
New construction should be able to readily accommodate this provision, but existing right-of-ways and street widths may severely limit the pedestrian path to 36 inches
1104.2.1.2 Cross Slope.
This proposed regulation will in effect cause problems with roadway drainage as well as with curb lane vehicular traffic when the street running slope is 1.5% or greater. The ramp will be warped to the street and sidewalk running grades which causes the rigid wheelchair frame to have three wheels on the ramp and one in the air. This much warp in the ramp to landing causes some mobility devices to tip over and spill the occupant to the pavement with possible injuries.
1104.2.1.3 Landing.
The 48 inch
1104.2.2.3 Landing.
The 1:48
1104.2.2.4 Diverging Sidewalks.
Without further clarification as to the protection barrier size and where the drop-off is located, street side or back of sidewalk, makes this statement a possible conflict with traffic safety as well as pedestrian safety.
1104.3.3 Surfaces.
This proposed regulation may work well for new construction, but existing street intersections in most cities usually have utility access covers and power poles that prevent proper ramp construction. The cost to relocate these appurtenances to a fitting location out side the ramps and landings can cost in excess of $3,500.00 per ramp. If a utility grating needs moving or adjusting to provide ADAAG pedestrian access, the cost for engineering and construction soars to more than $40,000.00 per ramp. Needless to say a curb ramp will not be constructed at these locations.
1105.2 Cross Slope.
Pedestrian crossings on roadways intended for vehicular traffic should maintain the same uninterrupted grade as the roadway. The proposed changes to the crosswalk slope will cause a tabling effect that will cause unintended consequences. The majority of street intersections where pedestrian access paths are located will be between ? inch to ½ inch per foot. This paragraph could have significant bearing whether developers and property owners would bear the additional cost associated with compliance.
1105.2.3 Running Slope.
There are many existing intersections that cannot be adjusted to this criteria. The historic districts, for instance, often have slightly steeper grades. A steep grade of 14% with a travel distance of 8 feet
1105.5 Pedestrian Overpasses and Underpasses.
Having to provide an elevator for every location that meets the proposed criteria is not feasible in most communities. However, because of increased project costs, construction of these facilities should be done with combined efforts of the disabled community and the municipality. The decision to fund a projects as well as where the project is located according to several factors may cause the project to be dropped from an improvement program. Construction of these facilities have to be funded and once these facilities are operational, they must be properly maintained. The cost of repairs due to vandalism is another concern for not constructing elevators.
The installation of an underpass at any location should be done in accordance with area need, based on potential user input. In some locations the underpass has the potential for flooding and water reaches a depth of 4 to 5 feet
1105.6 Roundabouts.
Continuous barriers should not be considered as a way to channelize pedestrians. Everyone in the community should receive adequate training on circumventing the hazards as a pedestrian vs. traffic. Perimeter walkways and training where the safest places are for pedestrians to get around this type of intersection is better than too many signals. The committee needs to take a different approach to melding vehicular and pedestrian traffic flow. Another thought is that a perfectly clean open roundabout becomes cluttered and ugly with barriers that may have a tendency to make the roundabout feel constrained and not freely useable.
1105.7 Turn Lane Intersections.
Traffic signals installed to stop traffic on the right turn "slip" lanes will only create congested intersections and increased air pollution. If a modification to an intersection is warranted, it should be done in concert with the disabled community and professional traffic engineers. This paragraph does not help the pedestrian as related to safety.
1106 Accessible Pedestrian Signal System.
I generally agree with the proposal to require devices to provide guidance to pedestrians, though it will increase installation costs. The location of the system may not meet dimension requirements at each intersection all the time. This proposed regulation should be a concept and not a hard mandate. It should promote community involvement to place the accessible system where needed rather than at all signal locations. There needs to be a paragraph that lets the city and community work together to decide what pedestrian crossing time is required at some major intersections. The time is based on actual need rather that a fixed 3 second
1106.4 Directional Information and Signs.
The requirement for "..of tactile and visual signs on the face of the device or its housing or mounting indicating crosswalk direction and the name of the street.. ". Tactile street names that are attached to the hardware changes these devices from "off the shelf" equipment to custom devices. This will make them more difficult and difficult to maintain.
1108 Detectable Warning Surfaces.
I am glad to see the detectable warning surfaces have been reduced to 24 inches
1109 On-Street Parking.
There is insufficient thought put into these proposals. Residential neighborhoods comprise the majority of the construction where the term block face is considered. To require indented, signed, accessible parking on every residential block face is hopefully not what the committee intended. The central business district has areas that has parking with meters and a few spaces that are designated for handicapped parking. The requirement for designated accessible spaces should not be a requirement. It is too costly for installing, moving signs. If the proposal becomes effective, the disabled persons or community and the city should work to achieve a satisfactory solution.
In our city the right-of-way usually is not wide enough to accommodate access aisles as proposed. There has been little or no concern for existing drainage run-off in the streets. New construction of accessible aisles may not warranted in the majority of cities. The street system allows parking needs with little hindrance to the intended wheelchair user. If the proposal becomes mandatory there may be unintended consequences. Why should a municipality be required to have reserved parking spaces designated for the disabled along each block? All motorists have the same equal opportunity to the current first come first parked situation. I have heard several comments concerning equal rights. One being, "This is beginning to become a bit biased".
In some areas the distance between cross streets may be as much as 550 feet
1111.3 Location.
This proposal needs to be reasonable. An alternate location paralleling the pedestrian route on the same side of the street is not possible when half or all the roadway is blocked by construction.
It would be better to have an alternate path that is best suited for pedestrians, even if it takes them on the opposite side of the street or on the next block that has an accessible walkway. Municipalities generally practice same side accessible movement if it is feasible. We have to look at liability issues when the accessible walkway is adjacent to some types of construction or demolition.
I have read the comments submitted to your office by AASHTO and concur with their comments.
Thank you for letting me have an opportunity to share my thoughts as it relates to the proposed standards. The above comments and suggestions should not be viewed as objections to the concept of providing reasonable access for the disabled community. In my opinion, it is imperative that reasonable accommodations for the disabled be placed within the right-of-way. My desire is to communicate potential pit-falls or unintended consequences associated with several of the proposed standards.
Frank Belock, October 25, 2002
Re: City of San Diego
Comments to Proposed Public Right-of-Way Guidelines
Dear Mr. Windley:
This letter consists of comments on behalf of the City of San Diego regarding the Draft Guidelines for Accessible Public Rights-of-Way issued June 17, 2002. San Diego is the seventh largest city in the nation, with nearly 1.3 million residents, and represents the commercial, governmental, and cultural hub to the county's 2.8 million people. In addition, San Diego is one of the premier vacation and convention destinations in the country, attracting more than 15 million visitors annually. Such a population naturally consists of a large number of disabled individuals as well. Thus, it is important that we strive to provide access along our public rights-of-way to those with disabilities, as well as all members of society.
These comments represent various concerns from a number of departments within the City of San Diego. Being charged with implementing these proposed regulations, the City has a great interest in their development.
While specific sections are addressed below, we have an overriding concern with the nature of the proposed Chapter 11 as it is currently written. There appears to be a lack of specificity in general, making compliance extremely difficult. The "discussion" portion of the guidelines provides a great deal of insight lacking from the proposed regulations themselves. For example, the discussion area relating to additions and alterations states that "compliance is 'prorated' based on the extent of the work planned." This concept of "prorating" the work is mentioned nowhere in the regulations.
This type of confusion and ambiguity in the regulations will have a chilling effect on compliance. If it is unclear what it means to comply with a specific section, then challenges to construction projects would be quite easy, resulting in costly litigation and delays. Soaring costs can quickly turn a routine construction project into a cost-prohibitive quagmire. Greater clarity and specificity in what it means to comply with these regulations, or providing clear discretion to the affected government entity, will help reduce the chilling effect of challenges to construction projects.
1101.2.1 MUTCD.
Many States have adopted the MUTCD with an amendment providing supplemental regulation particular to that State. We question what effect a State's adoption of the MUTCD, along with any State amendments, has on providing a "Reference Standard" to these guidelines. We propose that a State's adoption of the MUTCD should be the recognized "Reference Standard."
1101.3 - Defined Terms:
While some definitions are provided in the Right-of-Way Guidelines themselves, other important terms lack interpretation. Some definitions refer to other chapters of the ADAAG which do not relate to public rights-of-way. We have addressed our concerns by providing suggested language below.
Alterations.
"Alteration" should be defined specifically as it applies to this Chapter, considering it will be the primary trigger for implementing these regulations. Referring to the general definition of "Alteration" provided in section 3.5 of the ADAAG is insufficient, because section 3.5 relates to structures, rather than streets, sidewalks, and the like. That existing definition states:
An alteration is a change to a building or facility that affects or could
affect the usability of the building or facility or part thereof. Alterations include, but are not limited to, remodeling, renovation, rehabilitation, reconstruction, historic restoration, resurfacing of circulation paths or vehicular ways, changes or rearrangement of the structural parts or elements, and changes or rearrangement in the plan configuration of walls and full-height partitions. Normal maintenance, re-roofing, painting or wallpapering, or changes to mechanical and electrical systems are not alterations unless they affect the usability of the building or facility.
This definition fails to specifically address the circumstances unique to public rights-of-way. For an alteration to trigger compliance with Chapter 11, it should in some way effect the accessibility of the right-of-way. Simply rehabilitating a portion of the public right-of-way to its original condition as a result of routine maintenance or subsurface work would not constitute an "alteration," but rather a "restoration." We propose following definitions:
Alteration.
Any work to a public right-of-way that modifies its physical aspects to an extent that its access is appreciably affected. Alterations include any appreciable change to the slope, grade, or elevation of a Pedestrian Access Route. Alterations do not include resurfacing, slurry sealing, filling potholes or trenches, or similar work, if the effect is to restore the surface to its original condition without appreciably affecting the slope, grade, elevation, transition to sidewalks or other factors of accessibility. The scope of work required to comply with Chapter 11 shall not extend beyond the precise portion or aspect of the public right-of-way altered.
Addition.
An expansion, extension, or increase in the gross surface area of a sidewalk, roadway, or Pedestrian Access Route. The scope of work required to comply with Chapter 11 shall not extend beyond the precise portion or aspect of the public right-of-way which constitutes the addition.
Block Face.
The length of a side of a roadway adjoining a sidewalk which has a natural ending or is intersected by another roadway. Where no natural ending or intersecting roadway exists for more than 300 yards along the length of a roadway adjoining a sidewalk, then an individual Block Face will be considered every 300-yard section and remaining fraction thereof. For purposes of this Chapter, Block Face applies exclusively to areas zoned as commercial, business or mixed-used, and not residential areas.
New Construction.
An area of newly designed and newly constructed public rights-of-way, which is not an alteration or addition. The scope of work required to comply with Chapter 11 shall not extend beyond the precise portion or aspect of the public right-of-way which is considered to be new construction.
Street Furniture.
Elements in the public right-of-way that are intended for use by pedestrians. This includes drinking fountains, public telephones, toilet facilities, tables, and benches.
Technical Infeasibility.
Technical infeasibility includes those circumstances where compliance would require alterations to existing buildings or structures along the public right-of-way, interfering with subsurface structures or utilities, and other factors determined on a case-by-case basis. Technical infeasibility shall also apply to those circumstances where compliance requires a governmental entity to acquire additional public right-of-way through the use of eminent domain, easements, or similar legal proceedings. Where technical infeasibility is encountered, compliance is required to the maximum extent possible.
1102 - Scoping Requirements.
The discussion indicates that only those elements affected by construction must comply with the provisions. However, there appear to be areas of easy misinterpretation, such as 1102.4, which states, "The pedestrian access route shall connect to elements required to comply with Chapter 11." This could increase the scale of work required under this chapter more than intended. Adoption of a clear definition for "alteration," such as we have proposed above, would specify that only the precise features being touched in the alteration are affected by Chapter 11, and nothing more.
The discussion relating to additions and alterations which recognize the ability of local government to acquire right-of-way where "practicable" may have a chilling effect on projects. While a municipality's use of easements or the power of eminent domain may not be technically infeasible, they generally do involve costly litigation with an uncooperative property owner. This burdensome and expensive process could force policy makers to abandon a worthy project. Therefore, we propose adding language to 1102 which would have the local government entity: "Acquire public right-of-way where practicable as determined by the local jurisdiction."
1102.2.2.2.1 Prohibited Reduction in Access.
An alteration that decreases or has the effect of decreasing the accessibility of a public right-of-way or site arrival points to buildings or facilities adjacent to the altered portion of the public right-of-way, below the requirements for new construction at the time of the alteration is prohibited.
This section is somewhat difficult to read, and could be interpreted to mean that the governmental entity also has an obligation that extends beyond the public right-of-way to the accessibility on the adjoining private property of buildings and facilities themselves. It appears the Board's intent is to bring the accessibility of buildings and facilities adjacent to the public right-of-way up to the standards for new construction, but only to the extent that it relates to the public right-of-way itself.
Removing ambiguity would encourage compliance, because the responsibility of the government entity would be clear. We propose the following version for section 1102.2.2.2.1:
1102.2.2.2.1 Prohibited Reduction in Access.
An alteration shall not decrease or have the effect of decreasing the accessibility of a public right-of-way or site arrival points to buildings or facilities adjacent to the altered portion of the public right-of-way. Such alterations must meet the requirements for new construction to the maximum extent feasible, but in no circumstance shall any obligation to provide accessibility extend beyond the public right-of-way to the adjacent private property, buildings, or facilities.
1102.3 Alternate Circulation Path.
"An alternate circulation path complying with 1111 shall be provided whenever the existing pedestrian access route is blocked by construction alteration, maintenance, or other temporary conditions." Section 1111 states "the alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street."
The nature of construction in some areas may not provide an opportunity to have the alternate route on the same side of the street without placing pedestrians in an unsafe condition, or having an adverse impact on vehicular traffic. Section 1102.3 should recognize these situations. We propose the following revision to section 1111.3:
1111.3 Location.
The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street, unless such a path will put pedestrian safety in greater jeopardy, or impede normal vehicular traffic. In such cases where the alternate circulation path is not parallel to the disrupted pedestrian access route, or on the same side of the street, the alternate path shall be direct and accessible to the maximum extent feasible.
1102.6 Curb Ramps and Blended Transitions.
By failing to address unmarked crosswalks, this section creates a conflict in the requirement to have the ramp located within the width of each crosswalk and the desire of the advisory committee to discourage single ramp installations. This is especially the case at unmarked crosswalks and 48" sidewalks, which are attached to the back of the curb head. The "unmarked crosswalk" definition, clarifying that a crosswalk is the extension of sidewalk lines, means that only a single combined ramp could be constructed, because it is located within the unmarked crosswalks.
We seek clarification on how to reconcile this apparent conflict.
1102.14 On-Street Parking.
Where on-street parking is provided, at least one accessible on-street parking space shall be located on each block face and shall comply with 1109.
It is our position that this requirement is flawed in several respects. First, it needs to differentiate between residential and commercial areas. While the need for accessible street parking in business areas is understandable, because all members of society frequent these locations, the same cannot be said for residential areas. Only specific areas where disabled individuals live or frequent would necessitate a designated disabled spot. Anything more would be plainly excessive, taking up space that may never be used. Currently, the City of San Diego accommodates individual requests in residential areas for designated disabled parking spaces. These spaces are specifically located at accessible locations agreed upon by both City officials and the disabled individual. With such accommodations available from local governments, residential areas should be exempt from the requirement of 1102.14.
Second, a working definition of "block face" is needed for areas that do not have tradition street designs which designate the beginning and end of a block. Some "block faces" could extend great distances. Clear guidance, as we have suggested above, would help eliminate this ambiguity.
Third, placing curb ramps at disabled spaces could very well lure mid-block pedestrian crossing where none was intended. (See section 1109) Encouraging these spaces to be located at the end of blocks, where accessible curb ramps already exist, would reduce unsafe street crossings.
Finally, reserving one space per block face, using a traditional city block as a model, is patently excessive. Many traditional block faces in the City of San Diego, for example, have but two or three total spaces, and rarely more than ten. The ADAAG requirements for parking lots uses a ratio of one disabled parking space for every twenty five regular spaces, and even less frequency when total spaces exceed 100. Requiring on-street parking to provide such an excessive ratio of disabled parking spaces, beyond that required in other parts of the ADAAG, would have the unintended consequence of further reducing already sparse street parking in urban areas.
We propose using a ratio such as found in the ADAAG section 4.1.2(5)(a), where no more than 4 percent of the total spaces are set aside for accessible, disabled parking. Our rewritten version of 1102.14 is as follows:
1102.14 On-Street Parking.
Where on-street parking is provided, a minimum of 4 percent of the total parking spaces shall be accessible on-street parking spaces and shall comply with 1109. The location of these spaces shall be as near to primary destination points as is feasible.
1102.15 Passenger Loading Zones.
Requiring one accessible space in 100 linear feet of loading zone space or fraction thereof is inappropriate where there is insufficient public right-of-way to comply with cut out requirements of 503.2, 503.3, and 503.5. We propose adding the same exemption found for parallel parking spaces (section 1109.2) with the following language:
EXCEPTION: Compliance with this section is not required where the width of the sidewalk between the extension of the normal curb and boundary of the public right-of-way is less than 14 feet
1103.5 Grade.
The grade of the pedestrian access route within a sidewalk shall not exceed the grade established for the adjacent roadway.
EXCEPTION: The running slope of a pedestrian access route shall be permitted to be steeper than the grade of the adjacent roadway, provided that the pedestrian access route is less than 1:20
There should be another exemption to 1103.5. to accommodate the transitions to level areas. For example, if one is trying to level out the landing in front of a business to provide access to that facility, or create a driveway running perpendicular to the sidewalk, then the adjacent transition between the level area and the sidewalk will necessarily exceed the slope of the street. We propose adding the following exception to 1103.5:
EXCEPTION: The running slope of a pedestrian access route shall be permitted to be steeper than the grade of the adjacent roadway at the transition between the pedestrian access route and a more level cross surface. In these cases, compliance with 1103.5 shall be made to the maximum extent feasible.
1104 Curb Ramps and Blended Transitions.
The wording seems to imply that ramps can only be parallel or perpendicular, thereby prohibiting diagonal curb ramps. However, in the discussion portion of the draft guidelines, the Board seeks to only "discourage" the use of diagonal curb ramps. While diagonal curb ramps may not always be ideal, often they are the best option, especially where sidewalk space is limited.
Many times crosswalks are skewed and the allowance of a ramp parallel to the crosswalk (but not perpendicular to the road) might provide better direction. In 1104.2.1.1 & 1104.2.2.1 it is not clear why there would be concern for specifying a minimum slope. A section 1104.2.3 could be added to state that in skewed crosswalks pedestrian ramps should be installed in the center of the crosswalk, or a parallel curb ramp should be utilized.
1104.2.2.4 Diverging Sidewalks.
It is unclear what a "barrier" is as it relates to this section.
1104.3.2 Detectable Warnings.
The public hearing in Portland, Oregon on October 8, 2002, was filled with blind individuals denouncing detectable warnings unhelpful, and even presenting safety concerns. A great number of previously submitted written comments reinforce this sentiment. Because the blind community itself, for whom detectable warnings are intended, objects to these surfaces, it is our position that they should not be used at curb ramps, except when absolutely necessary. If the Board does mandate this requirement, it is our contention that detectable warnings should only be required for ramps where the slope is too slight for blind persons to detect, such as a slope of 1:15
1105.2.1 Width of Pedestrian Crosswalks.
In 1105.2.1, the marked crosswalk width is increased to a minimum of 96 inches
Finally, it is unclear whether a minimum crosswalk width of 96 inches
1105.2.1 Width. Marked crosswalks shall be 96 inches
1105.2.2 Cross Slope.
In 1105.2.2 the maximum cross slope of 1:48
1105.2.3 Running Slope.
The 1:20
1105.3 Pedestrian Signal Phase Timing.
To reduce the signal phase timing to 3.0 feet
Lengthening signal times will increase system wide congestion and delay, adversely impacting air quality due to greater automobile emissions. More traffic accidents would be the result of added congestion, as those waiting at signals for longer periods of time would be more aggressive getting through the next intersection. This will be most problematic for signals that are part of a coordinated traffic signal system generally used in urban areas.
A reasonable response to increased signal phase timing would be to evaluate each crossing on a case-by-case basis. Working with the disabled community would assist local governments in identifying those intersections where increased crossing times are necessary. Furthermore, updated technologies could provide for increased crossing time where specifically requested, such as systems where pedestrians hold the crossing signal button down for three seconds to make the signal increase the crossing time to 3.0 feet
The current value of 4.0 feet
1105.5 Pedestrian Overpasses and Underpasses.
The requirement to install an elevator where the rise of a ramped approach exceeds 60 inches
Public safety is our primary concern. An unsupervised elevator in relatively remote area presents unique concerns. Where use at night would be infrequent, and by individuals or small groups of people, opportunistic criminals would find the perfect setting for preying on their victims. Elevators are closed from outside view, allowing the most heinous of crimes to occur inside. Even closed-circuit television cameras are of nominal value since the response time to the elevator would be too long to act as a deterrent. Even elevator malfunctions present a unique safety concern, especially to passengers at odd hours of the night.
Yet another consideration with providing an unsupervised elevator in remote areas includes the use by homeless persons. This population is well known to appropriate any unsupervised structure that provides shelter from the elements. An elevator would be no different. Homeless individuals using these elevators as a temporary home would undoubtedly deter anyone from its use.
We propose the Board eliminate this requirement all together. While we recognize the difficulty to disabled individuals for ramps that rise to certain heights, we must also take into account the adverse effects this type of elevator presents to the entire population. On balance, it is clear the pros are overwhelmingly outweighed by the cons of such a proposal, and we anticipate the Board will act accordingly.
1105.6 Roundabouts.
The requirements proposed in this section are not consistent with accessible pedestrian considerations in other areas. There will also be unintended consequences associated with these requirements if implemented.
In 1105.6.1, the requirement to install a continuous barrier is not consistent with other applications where pedestrians are prohibited, yet barriers are not required. As a matter of consistency, if barriers are required here, they should also be required at all "high-design" intersections, and even mid-block locations to prohibit pedestrian crossings. The different treatment for similar pedestrian crossings is bewildering.
Furthermore, this requirement defeats the purpose of the roundabout which is to provide an unsignalized traffic calming device. To require signals at roundabout crossings would not necessarily improve pedestrian safety. An unintended consequence may be drivers running the red light in disrespect for these signals where unwarranted stop lights are installed.
The positive guidance approach is the best way to handle the concern of pedestrians wandering through the center of the roundabout. As shown in the discussion page picture, sidewalks and ramp locations can better address pedestrian channelization than ugly, hard to maintain, hazardous barriers.
Whether intended or not, this section presents a requirement that is so at odds with the objective and design of a roundabout, that it would effectively eliminate these traffic control devices from being constructed in the future. As such, we propose eliminating this requirement all together, allowing other portions of Chapter 11 to provide guidance for crossings at roundabouts. At the very most, mandate the use of traffic warning devices, such as those found at school crossings, which would alert drivers to be especially cautious.
1105.7 Turn Lanes at Intersections.
There are already countless "slip" lanes at un-signalized intersections, and this design is continuing to be built. Slip lanes at un-signalized intersections provide a valuable means of allowing vehicles to make safe turns without impeding the flow of traffic. The imposition of this requirement would essentially eliminate slip lane design for un-signalized intersections. It should be clarified that this section applies only to signalized intersections, thereby eliminating the need to place traffic signals where none is needed or intended.
Section 1106.2 - Pedestrian Signal Devices.
The public hearing in Portland, Oregon on October 8, 2002, and previously submitted written comments should be a clear indication of the blind community's adverse reaction to a audible pedestrian signals. Such devices generally mask and confuse other environmental indicators, such as traffic noise, which blind persons must use to sense when it is safe to cross. Although section 1106.3.2. attempts to specify some criteria for audible pedestrian signal devices, the nature of the sound itself is not addressed. Either eliminating this section, or adequately addressing the blind community's concerns is needed here.
1106.2.1 Location [Pedestrian Signal Devices].
There are many circumstances where the precise device location mandated by this section cannot be met. Subsurface utilities, fire hydrants, or other preexisting items may directly conflict with the placement provisions of 1106.2.1. While moving such infrastructures may not be "technically infeasible," doing so would nevertheless present an hardship. The "location" wording should be changed to communicate the concept as a guidance statement rather than a mandate, or at the very least exempting situations where preexisting features pose such an obstacle.
1106.4 Directional Information and Signs.
Tactile street name signs are not required at any other location and, to require them on pedestrian crossing hardware, changes these devices from "off the shelf" equipment to custom devices. This presents a concern of cost, maintenance, and efficacy. Furthermore, this section fails to specify whether the street names should be in Braille, raised lettering, an audio message, or some combination of these. When combining all these features along with a directional arrow and crosswalk configuration, the unique features required at every individual corner of an intersection would be clearly cost prohibitive, subject to constant maintenance to ensure accuracy, and be so convoluted that the information is more confusing to a blind person than if there were no such signs at all. This is especially true with regard to crosswalk configurations (1106.4.3), because there is no standard for graphic indications of intersections.
We agree that directional arrows, as required by 1106.4.1, are appropriate. However, the other technical requirements under 1106.4 should be either omitted altogether or be made discretionary.
1108 Detectable Warning Surfaces.
Although we have concerns about detectable warning surfaces (see our comment on section 1104.3.2), we like that this area has been minimized to 24 inches
1109.2 - Parallel Parking Spaces
The requirement to provide a 60 inch
In addition, the 5 foot
1111.6 Barricades.
The restriction of non-flexible fencing material would appear to be an unnecessary restriction. Plastic fencing products are now extremely strong, durable, and easy to install. If erected correctly, this type of barricade would accommodate the need to provide pedestrian channelization and protection in a reasonable manner. Furthermore, allowing the use of this material would make it much easier and efficient to provide protection in very short-term construction areas, thereby encouraging compliance with this section.
Conclusion.
These comments are intended to promote regulations that are as clear, defined, and unambiguous as possible. The closer Chapter 11 gets to this end, the more the Board can expect compliance from jurisdictions like the City of San Diego. It is our goal and ambition to make San Diego among the most accessible cities in the nation. As such, the Board should view these comments as constructive criticism intended to promote regulations that will, in the end, provide local governments with the best opportunity to meet the needs of those with disabilities. If you have any questions regarding these comments, please contact either Timothy Campen, Deputy City Attorney, at 619-533-6295, or Fletcher Callanta, ADA Coordinator - Engineering and Capital Projects, at 619-533-3420.
Sincerely yours,
By
Frank Belock, Director
Engineering and Capital Projects
CITY OF LINCOLN NE
RE: Draft Guidelines on Accessible Public Rights-of-Way
The City of Lincoln has reviewed the draft Guidelines on Accessible Public Rights-of-Way. While we applaud efforts to improve mobility for all citizens, we are concerned that the draft guidelines currently under consideration will have numerous consequences, many of which are negative.
You will find enclosed a copy of a letter compiled by Randy Hoskins, the City's Traffic Engineer. The letter outlines the concerns the City of Lincoln has with proposed guidelines. These concerns have been raised through Public Works Department and City Council review.
We would encourage you to take another look at the guidelines. Many are excellent and will provide needed improvements. Others may have unintended consequences that will be difficult to enforce, apply and/or fund. Still others may make for less safe conditions for all pedestrians, along with increasing delay, costs and pollution of vehicular traffic.
Sincerely,
Don Wesely
Mayor of Lincoln
October 20, 2002
Scott Windley
RE: Draft Guidelines on Accessible Public Rights-of-Way
Dear Mr. Windley:
The City of Lincoln has reviewed the Draft Guidelines for Accessible Public Rights-of-Way. We realize that Title II of the ADA requires governments to not discriminate against people with disabilities and we support the efforts to improve existing conditions. However, the guidelines as proposed would have serious consequences that would impose significant costs on local governments. It is also our feeling that these would be overly restrictive and would not allow sufficient latitude to design on a case by case basis.
Our comments and concerns are as follow:
Curb Ramps and Blended Transitions (1102.6, 1104)
- Also, drivers may not be as alert to persons crossing at the apex of a corner.
It would seem drivers would be much more alert at this point in the roadway than after driving around a corner and encountering a pedestrian when their vehicle has attained a higher speed than at the apex of the corner.
Other Requirements for Curb Ramps and Blended Transitions (1104.3.3 - 1104.3.7)
- prohibit the placement of... utility and sewer access covers, and similar fixtures on ramps, landings, transitions and portions of the gutter within the pedestrian access route;
If these items meet the criteria set forth for changes in level, why would they not be allowed?
- prohibit grade breaks on ramp runs, blended transitions, landings, and gutter areas within the pedestrian access route;
How will the gutter work if it must be at the same grade as the ramp? That will either force all the water out into the street or funnel it all back onto the sidewalk.
- prohibit any vertical changes in level on curb ramps, landings and gutter areas within the pedestrian access route;
Again, if the vertical change is within the requirements for changes in level, it should be allowed. To keep nuisance water from ponding within a ramp area, a minimal lip is often maintained to keep the water off the ramp and moving around the corner.
- require clear space at least 48 by 48 inches
This is confusing as to intent.
Crosswalks (1105.2)
- The cross slope is limited to 1:48
This may be fine for new areas, but it is often not realistic in built environments. Changing slopes of streets to accommodate this ruling may not be feasible.
Pedestrian Signal Phase Timing (1105.3)
- The draft guidelines would require pedestrian signal phase timing to be calculated according to a walking speed of 3.0 feet
This would have a major negative impact on traffic. Requiring this change would more than offset the gains our jurisdiction has made through expenditures of hundreds of thousands of dollars to improve the traffic carrying capabilities of our streets, which has been a mantra of the FHWA for years. To make this change system-wide would increase energy consumption, pollution and vehicular costs to motorists to accommodate a small percentage of the population who might use a signal. It would seem that if the route is used by handicapped individuals who cannot cross in the 3.5 ft/sec time, then the change to a 3.0 ft/sec crossing time COULD be used as needed.
Pedestrian Overpasses and Underpasses (1105.5)
- The draft guidelines address access to pedestrian overpasses and underpasses, which would be required to provide a pedestrian access route. A ramp would be required where the running slope exceeds 1:20
Implementation of this rule would practically kill off the installation of underpasses and overpasses for pedestrian crossings. Since it is quite rare where the grade change of such a structure would be less than five feet, nearly every one constructed would require an elevator. The major reason stated for not installing these structures is cost. When you add the cost of providing elevators at each end to the already high price, you have just made these infeasible except in the most extreme cases. By doing so, this would increase the hazard to all pedestrians, handicapped and able-bodied alike, forcing them to cross using at-grade crossings.
Roundabouts (1105.6)
- To provide safer crossing at roundabouts, the draft guidelines would require pedestrian activated crossing signals at each roundabout crosswalk, including those at splitter islands.
This requirement sounds as if it was written by a group of people scared of new ideas and who have absolutely no clue what they are talking about. We have just completed a roundabout to replace a signal at one of the highest accident locations in the City. A lot of people opposed to this installation stated it would be dangerous for pedestrians to cross. Quite the opposite is true. Pedestrians only have to cross one lane at a time, they are crossing at a point where traffic is moving slowly entering or leaving the roundabout and the driver is alert because of the increased requirements placed on them. To now have to signalize these would completely waste the advantages they naturally provide pedestrians. In certain areas where high volumes of pedestrians and vehicles exist, crossing lights may be of use, but a requirement for all or even most locations can only benefit signal suppliers.
Since vehicles would be moving at higher speeds and pedestrians would have longer crossing distances, by using the same logic, we should put in crossing signals at every unsignalized intersection also.
- Barriers or similarly distinct elements are needed to prevent blind persons from inadvertently crossing a roundabout roadway in unsafe locations. The draft guidelines would require a continuous barrier along the street side of the sidewalk where pedestrian crossing is prohibited. If a railing is used, it must have a bottom rail no higher than 15 inches
Since vehicles would be moving at higher speeds and peds would have longer crossing distances, by using the same logic, we should put in barriers at every unsignalized intersection also. Again, this just doesn't make sense. By following the sidewalk, pedestrians are directed to the safest crossing locations.
Turn Lanes at Intersections (1105.7)
- The draft guidelines also include a requirement for a pedestrian activated signal at each segment of a crosswalk that crosses right or left turn slip lanes.
This will likely increase vehicular crashes. In order to place the signals where turning vehicles can see them an adequate distance in advance of the crossing, they will also be visible to through vehicles who may become confused by several conflicting indications. Rear end and side-swipe crashes will likely result.
This should not be mandatory at all locations, but rather should be considered on a case by case basis. If signals are not needed for non-handicapped persons, there is a question as to whether or not they would be needed for handicapped individuals.
Accessible Pedestrian Signal Systems (1102.8, 1106)
1106.2 Pedestrian Signal Devices. Each crosswalk with pedestrian signal indication shall have a signal device which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device and shall comply with 1106.3.
Obviously these add cost to signal installation/maintenance. Where will the funding for this come from in these tight economic times?
1106.2.1 Location. Pedestrian signal devices shall be located 60 inches
This will require major reconstruction of many traffic signals. In many locations, it is not possible to comply with this due to existing obstructions in the way of the signal, including underground utilities.
1106.3.2 Locator Tone. Pedestrian pushbuttons shall incorporate a locator tone at the pushbutton. Locator tone volume measured at 36 inches
This is another cost concern. It is also sometimes a concern with nearby residents/businesses as to the addition of noise pollution.
1106.4.2 Street Name. Signs shall include street name information aligned parallel to the crosswalk direction and complying with 703.2.
Another cost concern.
On-Street Parking (1102.14, 1109)
- The draft guidelines would require access to at least one parking space on each blockface.
In an area with 150 foot
This also does not specify if this would be required city-wide or only in commercial areas. Providing the required handicapped parking space with signing, pavement markings and ramps on every block in the city would create an astronomical cost.
- Requirements address adjoining access aisles at spaces, accessible connecting routes, signs, and parking meters. An accessible parallel space and access aisle, which must be flush with the street, can be achieved by indenting the curb line, similar to a loading zone.
This will create problems during snow events. Plows will come along and push snow into the indented area, making them useless. These will also create discontinuities in the sidewalks in downtown areas where sidewalks normally run from the face of buildings to the edge of the curb. In high ped areas, this will have a major negative impact. I think the cost of lawsuits related to trips and falls in these inset areas each year will greatly outweigh any benefits derived from their installation.
Passenger Loading Zones (1102.15)
- ADAAG requirements for passenger loading zones would be applied to loading zones in the public right-of-way. Where a long loading zone is provided, at least one area in every 100 continuous feet must comply with requirements in ADAAG section 302 and 503 which address the surfacing, the size of vehicle pull-up spaces (8 by 20 feet
These will not work well at schools where it is important to provide curbs to create barriers to vehicles running onto sidewalks and hitting pedestrians.
- 1111.3 Location. The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street.
This is a costly unfunded mandate. Providing parallel ped access on the same side of the Street as the existing path is often not practicable. Based on costs and usage, it is often impossible to justify not moving pedestrians, both able bodied and disabled, to an adjacent route.
- 1102.5.2 Post-Mounted Objects. Free-standing objects mounted on posts or pylons shall overhang circulation paths 4 inches
The MUTCD allows secondary signs to have a minimum height of 72", vs. 80" required here. This would require major work to change signs throughout the city.
Again, we support reasonable access for disabled pedestrians and continually review our standards and processes to assure that what we are doing is reasonable and safe. We are concerned that these draft guidelines, if adopted, would create major consequences for communities of all sizes. We would ask that these consequences be considered more carefully before enacting any changes to the existing requirements.
Sincerely,
Randy Hoskins, P.E.
City Traffic Engineer
City of Lincoln, Nebraska
Norman H. Roush, P. E., October 21, 2002
West Virginia Department of Transportation
WV Division of Highways
The Federal Register dated June 17, 2002, made available for comment the Draft Guidelines on Accessible Public Rights-of-Way.
The West Virginia Division of Highways offers the enclosed comments for consideration of the Access Board in their continued effort to provide improved accessibility to public facilities around our Country. We also concur with the comments furnished by AASHTO in response to this Notice of Proposed Rulemaking.
Thank you for the opportunity to provide input into development of these Guidelines. If you have any questions, please contact me at [ ... ].
Very truly yours,
Norman H. Roush, P. E.
Deputy Commissioner
Enclosure
cc: Ms. Lisa M. Fontana, Institute of Transportation Engineers
Mr. Jim McDonnell, Associate Program Director for Engineering, AASHTO
1. The entire document appears to be written as if a highway were a building. The requirements are probably not attainable in rolling and mountainous terrain.
2. Will there be a process where exceptions to the criteria can be approved? If not, there will be some highways and streets which may not be safe for vehicles.
3. The compliance date for parts of all of these requirements will be significant. There are a lot of items which can be expected to be done as retrofits and there are some additions, such as new traffic signals, which will take time and dollars to implement. An appropriate phase-in period should be established.
4. It should be noted that the waiver on detectable warnings expired last July 1st. All curb ramps which we are constructing should have truncated domes included.
5. The MUTCD is currently the only referenced standard. It appears that the document should include other standards or references such as the AASHTO "A Policy on Geometric Design for Streets and Highways," the AASHTO "Guide to Standardized Highway Barrier Hardware," and possibly others.
6. 1101.3, Defined Terms, Channelizing Island: Will a painted island be considered an adequate pedestrian refuge?
7. 1101.3, Defined Terms, Dynamic Envelope: This definition should refer to suspension "deflection" or "flexure."
8. 1101.3, Defined Terms, Locator Tone: This need not be limited to pedestrian push buttons.
9. 1101.3, Defined Terms, Sidewalk: The "improved area" may be no more than a gravel path.
10. 1101.3, Defined Terms, Street Furniture: This may include artwork, lighting poles, or other items which are outside the scope of pedestrian use.
11. 1102.2.2. Alterations: This action is ill defined and can and will be interpreted differently by many involved parties. A clearer description of the intent of this section is needed.
12. 1102.3, Alternate Circulation Path: In some built-up areas, the only alternate path may be a major detour and could be quite long. Would an alternate circulation path with lower standards be considered to eliminate a major detour? Could a combination of an alternate circulation path with lower standards, along with a detour, be approved?
13. 1102.5.3, Reduced Vertical Clearance: A drawing would be helpful. A guardrail less than 27 inches
14. 1102.14, On-Street Parking: One accessible space per block face seems excessive and meaningless. Some blocks are very short while others approach ½ mile in length. A handicapped space per a number of spaces would be better guidance. This should be done by table or formula as in 4.1.2.
15. 1103.3, Pedestrian Access Route, Clear Width: There appears to be a 12 inch
16. 1103.4 and 1105.2.2, Cross Slopes: These requirements would require the vertical alignment of a road or street to be controlled by the pedestrian facility. In mountainous terrain, it may be physically impossible to provide the cross walks with a 1:48
The requirements for maximum cross slopes, grades, elevation differences, while possible to attain during construction, will become a problem later if it is intended for the original design values to remain during the life of the facility. Pedestrian facilities along highways are built on soil and settlement is common and expected, yet there is no indication in the standards that changes during the life of the facility due to Mother Nature would be acceptable. These facilities are not being built in the same manner as buildings which have firm unyielding foundations.
17. 1103.5, Grade: This states a grade on a pedestrian access route shall not exceed the grade established by the adjacent roadway. What is required if the grade of the roadway is 10% or greater? Is the pedestrian access to be allowed to have the same grade?
18. 1104, Curb Ramps and Blended Transitions: Drawings are essential for an adequate review of this section.
19. 1104.2.2.1: The running slope is limited to 1:12
20. 1104.3.4.: Why are no grade breaks allowed? If kept below the maximum slope of 1:12
21. 1104.3.6, Counter Slopes: This term needs defined in 1101.3. A drawing would be helpful. Roadways with superelevation may have a steeper counter slope than 5%.
22. 1104.3.7, Clear Space: It appears that we will be required in the future to build 48 inch
23. 1105.2, Crosswalks, 1105.2.1., Width: This rule would require a minimum 96 inch
24. 1105.6, Roundabouts: It is suggested that the requirement to provide pedestrian signals at roundabouts be reconsidered for practicality and instead be offered as an option to be considered on a case-by-case basis.
25. 1105.7, Turn Lanes at Intersections: This section would require that we signalize turning movements which we now operate under YIELD control. If no pedestrians are present, this should still be allowed.
26. 1106.2, Pedestrian Signal Systems: Will the signal devices be only for exclusive devices? As currently proposed, this may create some rather long WALK intervals for pedestrians.
27. 1109 and 1109.3, Off-Street Parking: All handicapped spaces do not necessarily have to be so wide. The 96" minimum requirement for an access aisle on perpendicular or angled parking spots appears to be excessive.
28. General Comment: Is there any number of pedestrians which would allow these standards to be ignored or must all pedestrian facilities meet all of these requirements? In the majority of pedestrian facilities, the provisions of 1102.2 - Alterations will be the norm in establishing pedestrian facilities and many, if not most, will not meet the requirements of these standards.
29. General Comment: Several dimensions are listed as exact number and no tolerances are provided. It is recommended that reasonable tolerances be provided on all dimensions. Highways and pedestrian facilities outside of buildings such exact dimensions are almost impossible to obtain or maintain.
30. General Comment: Is there to be any consideration of rural highways where sidewalks are not provided, yet pedestrians are allowed?
31. General Comment: At what volume of pedestrians are these guidelines to be required? If there are only two pedestrian per day and no special needs people, are pedestrian facilities required?
Randy Hoskins, P.E., October 23, 2002
Please consider the attached comments regarding the draft guidelines. A hardcopy version will be sent to you in the mail.
Randy Hoskins, P.E.
City Traffic Engineer
Lincoln, NE
Scott Windley
Office of Technical and Informational Services
Architectural and Transportation Barriers Compliance Board
1331 F St. NW, Suite 1000
Washington, DC 20004-1111
RE: Draft Guidelines on Accessible Public Rights-of-Way
Mr. Windley:
The City of Lincoln has reviewed the Draft Guidelines for Accessible Public Rights-of-Way. We realize that Title II of the ADA requires governments to not discriminate against people with disabilities and we support the efforts to improve existing conditions. However, the guidelines as proposed would have serious consequences that would impose significant costs on local governments. It is also our feeling that these would be overly restrictive and would not allow sufficient latitude to design on a case by case basis.
Our comments and concerns are as follow:
Curb Ramps and Blended Transitions (1102.6, 1104)
- Also, drivers may not be as alert to persons crossing at the apex of a corner.
It would seem drivers would be much more alert at this point in the roadway than after driving around a corner and encountering a pedestrian when their vehicle has attained a higher speed than at the apex of the corner.
Other Requirements for Curb Ramps and Blended Transitions (1104.3.3 - 1104.3.7)
- prohibit the placement of ...utility and sewer access covers, and similar fixtures on ramps, landings, transitions and portions of the gutter within the pedestrian access route;
If these items meet the criteria set forth for changes in level, why would they not be allowed?
- prohibit grade breaks on ramp runs, blended transitions, landings, and gutter areas within the pedestrian access route;
How will the gutter work if it must be at the same grade as the ramp? That will either force all the water out into the street or funnel it all back onto the sidewalk.
- prohibit any vertical changes in level on curb ramps, landings and gutter areas within the pedestrian access route;
Again, if the vertical change is within the requirements for changes in level, it should be allowed. To keep nuisance water from ponding within a ramp area, a minimal lip is often maintained to keep the water off the ramp and moving around the corner.
- require clear space at least 48 by 48 inches
This is confusing as to intent.
Crosswalks (1105.2)
- The cross slope is limited to 1:48
This may be fine for new areas, but it is often not realistic in built environments. Changing slopes of streets to accommodate this ruling may not be feasible.
Pedestrian Signal Phase Timing (1105.3)
- The draft guidelines would require pedestrian signal phase timing to be calculated according to a walking speed of 3.0 feet
This would have a major negative impact on traffic. Requiring this change would more than offset the gains our jurisdiction has made through expenditures of hundreds of thousands of dollars to improve the traffic carrying capabilities of our streets, which has been a mantra of the FHWA for years. To make this change system-wide would increase energy consumption, pollution and vehicular costs to motorists to accommodate a small percentage of the population who might use a signal. It would seem that if the route is used by handicapped individuals who cannot cross in the 3.5 ft/sec time, then the change to a 3.0 ft/sec crossing time COULD be used as needed.
Pedestrian Overpasses and Underpasses (1105.5)
- The draft guidelines address access to pedestrian overpasses and underpasses, which would be required to provide a pedestrian access route. A ramp would be required where the running slope exceeds 1:20
Implementation of this rule would practically kill off the installation of underpasses and overpasses for pedestrian crossings. Since it is quite rare where the grade change of such a structure would be less than five feet, nearly every one constructed would require an elevator. The major reason stated for not installing these structures is cost. When you add the cost of providing elevators at each end to the already high price, you have just made these infeasible except in the most extreme cases. By doing so, this would increase the hazard to all pedestrians, handicapped and able-bodied alike, forcing them to cross using at-grade crossings.
Roundabouts (1105.6)
- To provide safer crossing at roundabouts, the draft guidelines would require pedestrian activated crossing signals at each roundabout crosswalk, including those at splitter islands.
This requirement sounds as if it was written by a group of people scared of new ideas and who have absolutely no clue what they are talking about. We have just completed a roundabout to replace a signal at one of the highest accident locations in the City. A lot of people opposed to this installation stated it would be dangerous for pedestrians to cross. Quite the opposite is true. Pedestrians only have to cross one lane at a time, they are crossing at a point where traffic is moving slowly entering or leaving the roundabout and the driver is alert because of the increased requirements placed on them. To now have to signalize these would completely waste the advantages they naturally provide pedestrians. In certain areas where high volumes of pedestrians and vehicles exist, crossing lights may be of use, but a requirement for all or even most locations can only benefit signal suppliers.
Since vehicles would be moving at higher speeds and pedestrians would have longer crossing distances, by using the same logic, we should put in crossing signals at every unsignalized intersection also.
- Barriers or similarly distinct elements are needed to prevent blind persons from inadvertently crossing a roundabout roadway in unsafe locations. The draft guidelines would require a continuous barrier along the street side of the sidewalk where pedestrian crossing is prohibited. If a railing is used, it must have a bottom rail no higher than 15 inches
Since vehicles would be moving at higher speeds and peds would have longer crossing distances, by using the same logic, we should put in barriers at every unsignalized intersection also. Again, this just doesn't make sense. By following the sidewalk, pedestrians are directed to the safest crossing locations.
Turn Lanes at Intersections (1105.7)
- The draft guidelines also include a requirement for a pedestrian activated signal at each segment of a crosswalk that crosses right or left turn slip lanes.
This will likely increase vehicular crashes. In order to place the signals where turning vehicles can see them an adequate distance in advance of the crossing, they will also be visible to through vehicles who may become confused by several conflicting indications. Rear end and side-swipe crashes will likely result.
This should not be mandatory at all locations, but rather should be considered on a case by case basis. If signals are not needed for non-handicapped persons, there is a question as to whether or not they would be needed for handicapped individuals.
Accessible Pedestrian Signal Systems (1102.8, 1106)
1106.2 Pedestrian Signal Devices. Each crosswalk with pedestrian signal indication shall have a signal device which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device and shall comply with 1106.3.
Obviously these add cost to signal installation/ maintenance. Where will the funding for this come from in these tight economic times?
1106.2.1 Location. Pedestrian signal devices shall be located 60 inches
This will require major reconstruction of many traffic signals. In many locations, it is not possible to comply with this due to existing obstructions in the way of the signal, including underground utilities.
1106.3.2 Locator Tone. Pedestrian pushbuttons shall incorporate a locator tone at the pushbutton. Locator tone volume measured at 36 inches
This is another cost concern. It is also sometimes a concern with nearby residents/businesses as to the addition of noise pollution.
1106.4.2 Street Name. Signs shall include street name information aligned parallel to the crosswalk direction and complying with 703.2.
Another cost concern.
On-Street Parking (1102.14, 1109)
- The draft guidelines would require access to at least one parking space on each block face.
In an area with 150 foot
This also does not specify if this would be required city-wide or only in commercial areas. Providing the required handicapped parking space with signing, pavement markings and ramps on every block in the city would create an astronomical cost.
- Requirements address adjoining access aisles at spaces, accessible connecting routes, signs, and parking meters. An accessible parallel space and access aisle, which must be flush with the street, can be achieved by indenting the curb line, similar to a loading zone.
This will create problems during snow events. Plows will come along and push snow into the indented area, making them useless. These will also create discontinuities in the sidewalks in downtown areas where sidewalks normally run from the face of buildings to the edge of the curb. In high ped areas, this will have a major negative impact. I think the cost of lawsuits related to trips and falls in these inset areas each year will greatly outweigh any benefits derived from their installation.
Passenger Loading Zones (1102.15)
- ADAAG requirements for passenger loading zones would be applied to loading zones in the public right-of-way. Where a long loading zone is provided, at least one area in every 100 continuous feet must comply with requirements in ADAAG section 302 and 503 which address the surfacing, the size of vehicle pull-up spaces (8 by 20 feet
These will not work well at schools where it is important to provide curbs to create barriers to vehicles running onto sidewalks and hitting pedestrians.
- 1111.3 Location. The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street.
This is a costly unfunded mandate. Providing parallel ped access on the same side of the street as the existing path is often not practicable. Based on costs and usage, it is often impossible to justify not moving pedestrians, both able bodied and disabled, to an adjacent route.
- 1102.5.2 Post-Mounted Objects. Free-standing objects mounted on posts or pylons shall overhang circulation paths 4 inches
The MUTCD allows secondary signs to have a minimum height of 72", vs. 80" required here. This would require major work to change signs throughout the city.
Again, we support reasonable access for disabled pedestrians and continually review our standards and processes to assure that what we are doing is reasonable and safe. We are concerned that these draft guidelines, if adopted, would create major consequences for communities of all sizes. We would ask that these consequences be considered more carefully before enacting any changes to the existing requirements.
Randy Hoskins, P.E.
City Traffic Engineer
City of Lincoln, Nebraska
Mark Richert, October 28, 2002
Attached for the Board's consideration are the comments of the Association for Education and Rehabilitation of the Blind and Visually Impaired (AER). These comments were prepared after long and thoughtful scrutiny by members of AER's Orientation and Mobility Division. Please direct requests for further information to Janet M. Barlow [...]
AER and its members appreciate the opportunity to submit these comments and commend the Access Board for its diligence in addressing these pressing issues.
Sincerely,
Mark Richert
Executive Director
Association for Education and Rehabilitation of the Blind and Visually Impaired
Alexandria, VA
Contact: Janet M. Barlow
SUBJECT: Draft Guidelines for Accessible Public Rights-of-Way (June 17, 2002)
The Association for the Education and Rehabilitation of the Blind and Visually Impaired (AER) is an international membership organization of approximately 4600 professionals. Its mission is "to develop and promote professional excellence through support of those who provide education and rehabilitation services to people with visual impairments". The Orientation and Mobility Division of AER represents over 1000 orientation and mobility specialists, individuals who teach independent travel skills to persons who are blind or visually impaired. Certified Orientation and Mobility Specialists (COMS) are graduates of specialized college degree programs in education and/or rehabilitation. The following information and recommendations have been developed by the members of the Environmental Access Committee of AER's Orientation and Mobility Division.
We are delighted that guidelines for the public rights-of-way are now being developed that will address the needs of pedestrians who are blind or visually impaired. Following these recommendations is a resolution passed at the AER conference this summer in support of these guidelines. The transportation and public works community needs guidelines and specific direction to provide facilities that are accessible to pedestrians who are visually impaired or blind.
We are particularly pleased that specifications for detectable warnings and accessible pedestrian signals have been included. As representatives of a profession that has taught travel skills to individuals who are blind over the past 50 years, we recognize the evolution of intersection design and traffic control that now necessitates some of the modifications and accommodations that these guidelines require. Comparing a photo of an intersection in the 1960's with a photo of a current intersection makes it clear that the tasks and issues have changed. While individuals who are blind do cross streets without accessible pedestrian signals and do manage to locate the street edge without detectable warnings, these two tasks, in particular, have become much more difficult, and sometimes impossible, in the past twenty years due to changes in intersection design and signalization.
We strongly support the draft guidelines. The implementation of the draft recommendations on Accessible Pedestrian Signals (APS) and the resultant improvement in predictability and accessibility will go a long way towards insuring that the pedestrian environment remains accessible into the future. Please note in our comments, however, that we recommend that the Access Board add additional language specifying types of intersections where APS should be installed. In addition, we recommend some wording changes in the section on walk messages and suggest a more precise requirement for pole location than that in the PROWAAC report or the MUTCD. We feel that in new construction a tighter specification is possible, and necessary, to make the interface as unambiguous and quiet as possible.
Many who have provided comments seem to be misinformed regarding the types of APS recommended in these guidelines. Their comments and objections to "screeching signals" and "bird calls" indicate that they are unaware of the new types of signals recommended by PROWAAC and these draft guidelines. While many NFB members are expressing opposition to 'beeping signals' on every corner, the Access Board may wish to review articles by NFB President Mark Mauer in which he discusses signals in Australia and Sweden favorably ("World Blind Union Fifth General Assembly" The Braille Monitor, Vol. 44, No.3, March 2001 and "Blindness, Travel, the Environment, and Technology", The Braille Monitor, Vol. 42, No. 9, November, 1999, posted at www.nfb.org). The signals in Australia and Sweden include locator tones and audible and vibrotactile walk indications, installed close to each crosswalk location. This type of signal is exactly what these draft guidelines are calling for.
We have provided our response to the Board's question regarding detectable warnings in the section of these comments regarding the 'Discussion of Provisions'. We have also provided a response to the questions on roundabouts later in these comments. Many specific wording changes and the rationale for the suggested change are included later in this letter as well.
While the Board did not ask for specific comment on the issue of 'directionality' of curb ramps, we urge consideration of issues expressed in the PROWAAC discussions and research to develop solutions. Pedestrians who are blind or visually impaired try to avoid using the slope of the curb ramp as a cue to the direction of the crossing. However, it is difficult to avoid traveling and aligning in the direction of the slope. The detectable warning, as specified, is not an alignment cue, but a 'stop' indication.
The provision of additional alignment information at some types of curb ramps and blended transitions, particularly where the ramp is not aligned with the crosswalk direction, is needed. In addition, the PROWAAC committee was unable to agree on a specification for a tactile cue in the sidewalk to indicate the location of midblock crossings and roundabout crossing to pedestrians who are blind or visually impaired. Research is needed to identify solutions and address concerns of persons with mobility impairments as well as the needs of individuals who are blind or visually impaired. This research should evaluate the ability of pedestrians who are blind or visually impaired to detect and align with various surfaces, such as the bar tiles used in Europe and Japan, line tiles sold by US manufacturers, and other possible alignment surfaces, as well as the ability of wheelchair users and those with mobility impairments to navigate over and around such surfaces.
The Access Board should move as quickly as possible to implement this draft as a rule. Some in the transportation industry may urge waiting for the completion of additional research. Travelers who are blind or visually impaired are required to use the sidewalks and street crossings in their daily travel, usually in conjunction with the use of public transportation. They are at risk in traveling, due to the lack of consideration in current intersection and sidewalk designs. As additional research is completed, it can be incorporated into designs and provisions. These guidelines need to be completed and published as a final rule.
We encourage your consideration of the following specific comments as rulemaking process continues:
DISCUSSION OF PROVISIONS
Detectable Warning
The Board asks for response on a question regarding installation of detectable warnings only on curb ramps with a slope of 1:15
RESPONSE: We support the requirement for detectable warnings on ALL ramps and sidewalk/street transitions leading to crosswalks, regardless of slope. AER resolutions 98-01 and 94-08, supporting this requirement, follow.
Rationale: Two studies confirmed that removal of the curb was problematic for travelers who are blind. Barlow and Bentzen, found that 39% of blind travelers did not detect the street and stop when they approached the crosswalk on a curb ramp. Repeating their analysis using only the ramps that met ADA requirements at that time, (those that had a slope of 1:12
Roundabouts
We applaud the Board's strong stance on signalization of roundabout crossings. We expect that there are alternative solutions to provide accessibility, however, roundabout proponents have been slow to respond to concerns of pedestrians with disabilities. Proponents of roundabouts often quote the reduction in crashes as support for the safety of the installations. Crash data do not tell the whole story; there is little or no information on pedestrian avoidance of roundabout locations. Anecdotal information from Europe and Australia, as well as from US installations, indicates that pedestrians who are blind or visually impaired avoid crossing at roundabouts.
While there is ongoing research on the challenges for pedestrians who are blind or visually impaired and potential solutions, there is a need to slow the proliferation of inaccessible roundabouts in the United States. We believe that traffic engineers and designers who desire to solve this problem can do so, however, the will did not seem to be present until the draft guideline was published which required their attention to the issue. Many designers and governments who are complaining about the problems of signalization seem unable to consider pedestrian signals that function differently than those that have traditionally been installed in the US, as considered by the PROWAAC and the Access Board. The experience of England and other countries with signalization of pedestrian crossings at roundabouts should be considered.
Designers who develop better solutions can always install solutions that provide better accessibility, in full compliance with guidelines. We urge the Board to continue to require signalization of the pedestrian crossings.
1101.3 DEFINED TERMS
Detectable warning
ADD: standardized
Detectable Warning. A standardized surface feature built in or applied to walking surfaces or other elements to warn of hazards on a circulation path.
Rationale: Those reading the definition need to understand that the surface of the detectable warning is specified in ADAAG and that various textured surfaces may not meet the requirements of a detectable warning.
Locator tone:
CHANGE to: Pushbutton Locator Tone?a repeating sound that informs approaching pedestrians that they are required to push a button to actuate pedestrian timing and that enables pedestrians who have visual disabilities to locate the pushbutton.
Rationale: The above definition is the definition and term used in the MUTCD.
1102. SCOPING
1102.5.2 Protruding objects
1102.5.2 Post-Mounted Objects.
ADD: Where a sign or other obstruction is mounted between posts or pylons and the clear distance between post or pylons is greater than 12 inches
Rationale: We are delighted with the reduction of distance that objects can protrude from posts. This will eliminate many hazards in the sidewalk area. Pedestrians who are blind or visually impaired may travel on any part of the public sidewalk and are not limited to the pedestrian access route, a fact which many designers do not seem to understand.
The sentence regarding posts and pylons seemed to be missing a section regarding the distance between posts and pylons. In addition, we encourage the addition of the requirement for a lower bar on such signs. Signs between poles, and railings with their leading edges higher than 15 inches
The three principal cane techniques are: 1) the touch technique, where the cane is lifted slightly off the ground and moved in an arc from side-to-side and touches the ground at points outside both shoulders; 2) the constant contact technique, where the cane is slid from side-to-side in a path extending just beyond both shoulders; and 3) the diagonal technique, where the cane is held in a stationary position diagonally across the body with the tip just above the ground at a point outside one shoulder and the handle extended to a point outside the other shoulder. When one of these techniques is used and the element is in the detectable range, it gives a person of average adult stature, who uses proficient technique with a long cane, sufficient time to detect the element with the cane before there is body contact. The typical cane techniques do not locate objects extending into the travel path above the hips. For persons of short stature, including children, simple geometry indicates that they will be unlikely to detect objects with a long cane before contacting them with the body when the leading edge is as high as 27 inches
1102.7.1 Bus Route Identification. Exception 2
ADD: If portable receivers are required to access the signs, receivers must be freely distributed persons with disabilities who cannot read print signs.
Rationale: Allowing such an exception does not provide accessible information unless there is a concomitant requirement to distribute the receivers to those who may wish to access the information.
1102.8 Pedestrian crossings
CHANGE TO: Where a pedestrian crossing is provided, it shall comply with the applicable provisions of 1105. Where pedestrian signals are provided at a pedestrian crossing, where pedestrian signal timing is actuated by pedestrian detectors (pushbuttons) or by passive pedestrian detection, or where leading pedestrian intervals or exclusive pedestrian phasing is used, pedestrian signals shall comply with 1106.
Rationale: The draft language does not require accessible information to be provided at intersections unless pedestrian signals are installed. The Manual on Uniform Traffic Control Devices (MUTCD) only requires (using 'shall' language) the installation of pedestrian signals at limited locations, such as school zones, crossings where a signal is installed due to high pedestrian volumes, and where there is exclusive pedestrian phasing. Other locations are discussed in 'should' language. We are concerned that this rule may encourage traffic engineers to limit the installation of pedestrian signals, in order to avoid installing accessible pedestrian signals. In the MUTCD, pedestrian signals are not required at some locations because the vehicular signal can be considered adequate, under provisions in the MUTCD, to provide information to pedestrians. Under the current draft guidelines, therefore, there would be no imperative to make the "green ball" information accessible. These locations may not provide adequate information for pedestrians who are blind without installation of accessible pedestrian signals.
The locations suggested above and in the PROWAAC report are ones at which the signal features make it hard to detect the pedestrian crossing phase without provision of accessible information. Locations such as those are known to be problematic for pedestrians who are blind or visually impaired. In addition, there may be other locations where the traffic movement does not provide sufficient information for pedestrians who are blind or visually impaired.
We are unable at this time to suggest language that will cover all possible situations in which accessible information may be needed by an individual pedestrian who is blind. Therefore we recommend that at signalized intersections in new construction where pedestrian facilities such as sidewalks are provided but pedestrian signalization is not, that conduit piping be installed in relation to the curb ramps such that a retrofit with APS if required could be easily accomplished.
As we stated previously, many who have provided comments seem to be misinformed regarding the types of APS recommended in these guidelines as well as the types of intersection signalization typically used now. (see our opening comments). Most newly installed intersections will be traffic actuated and will have complex traffic patterns. Pedestrian actuated traffic signals change with each cycle and usually require the pedestrian to push a button to get enough time in the cycle to cross the street. As well, the vehicular patterns and pedestrian timing may vary, depending on the signal timing plan of the intersection. The pedestrian timing may be concurrent with the traffic moving parallel to the pedestrian's path, or at a totally different time in the cycle. Pedestrians who misjudge the starting traffic pattern may find themselves in the street when cars are moving perpendicular to their path with a 'green arrow'. These changes have resulted in our advocacy for Accessible Pedestrian Signals to provide individuals who are blind or visually impaired with the signal information provided to persons who are sighted.
At the public information meeting in Portland, APS device costs of $4000 per device were suggested by some individual commenters. These estimates are incorrect. The cost of a pushbutton integrated APS, such as referred to in the draft guidelines, is currently approximately $400. per device. As with many items, that estimate may be reduced with quantity purchasing.
1102.10 Stairs
We agree with this addition that will make stairs in the public rights-of-way more visible to all pedestrians. We suggest a slight revision in the language.
DELETE: 'of color'
INSERT: "contrasting with the tread and riser, dark on light or light on dark,"
1102.10 Stairs. Where provided, stairs shall comply with 504. Stair treads shall have a 2 inch
Rationale: Light/dark contrast is the important feature, not color or hue.
1104 CURB RAMPS AND BLENDED TRANSITIONS
1104.3 Common Elements
MOVE: 1104.3 Common elements to 1104.2 and Types to 1104.3
Rationale: The common elements need to be more clearly described before the details of the various types of ramps. In addition, blended transitions may need additional language to clarify that a raised intersection or raised crosswalk could provide a blended transition.
1104.2.1 Perpendicular curb ramps.
ADD: Where possible, the slope of the curb ramp shall be aligned with the sidewalk and crosswalk direction.
Rationale: The orientation of curb ramps toward the intersection can be disorienting for travelers who are blind or visually impaired. In addition, they require an extra turn for wheelchair users. We believe that the guidelines need to encourage orientation of the ramp in the direction of travel on the crosswalk.
PROWAAC debated at great length on the issue of curb ramp orientation. While travelers who are blind or visually impaired do not use the slope of the ramp to determine their crossing alignment, it is difficult to prevent the slope from influencing travel direction. Advocates for pedestrians with visual impairments recognize the safety issues for wheelchair users of warping at the gutter/ramp intersection, however, whenever possible, the slope of the ramp should be aligned with the crosswalk and the grade break should be aligned perpendicular to the crosswalk alignment. The language of the guidelines needs to state that and encourage two ramps more strongly.
1105 PEDESTRIAN CROSSINGS
1105.4.2 Medians and Pedestrian Refuge Islands - Detectable Warnings
DELETE: Exception
Rationale: Detectable warnings inform the pedestrian who is blind or visually impaired about the presence of a cut-through island or median. They should be required at all medians and islands. Although the pedestrian may not need to stop at that location when the signal timing is adequate for a full crossing, slower pedestrians may prefer to stop and wait, if they know the refuge exists. In the absence of an APS, blind pedestrians frequently begin crossing during the clearance interval because of the difficulty of determining the exact onset of the walk interval, and the resulting inability to "claim" the crosswalk before vehicles turning across the crosswalk. Hence, they may have insufficient time to cross the street. Denying them the information that they have a safe refuge constitutes discrimination and endangers the life safety of pedestrians who are blind in such situations. Even in the presence of APS, because they are unable to make eye contact with drivers, pedestrians with visual impairments have difficulty claiming the crosswalk during the walk interval, and may be delayed in starting crossings relative to sighted pedestrians.
In addition, contacting the side edge unexpectedly when traveling within the cut-through section of the median can be disorienting and confusing if pedestrians do not realize they are within a median area. The detectable warning provides the pedestrian with information about the location of the cut-through refuge area.
1105.6 Roundabouts
1105.6.1 Separation
CHANGE TO: Continuous barriers landscaping separation or railings shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited. When railings are used, they shall have a bottom rail 15 inches
Rationale: Use of the word barriers is confusing. Landscaping can be an appropriate guide to guide individuals to the crosswalk location, instead of a barrier or guardrail.
1105.6.2 Signals
We urge the Board to keep this language and requirement for signals at each crossing of roundabouts. See previous comments in answer to the question in the Preamble.
1105.7 Turn lanes at Intersections
We also applaud the inclusion of pedestrian activated signals at these locations, which have been problematic for pedestrians who are blind for years.
1106. ACCESSIBLE PEDESTRIAN SIGNAL SYSTEMS
1106. 1 General.
We recommend the use of the term "Accessible Pedestrian Signal (APS)", rather than Signal Systems or Pedestrian Signal Devices in this text to more closely conform to the MUTCD language and typical current terminology.
Rationale: The Board has introduced new language in these guidelines that does not match with language typically used in either the traffic engineering or the orientation and mobility professions. 'Signal system' is a defined term in the MUTCD ("Signal System - two or more traffic control signals operating in signal coordination"). 'Signal system' is not used with that meaning in these guidelines. It is important that engineers and those who are familiar with the MUTCD understand these guidelines properly.
1106.2 Pedestrian Signals.
CHANGE: Each crosswalk with pedestrian signal indication, or where pedestrian signal timing is actuated by pedestrian detectors (pushbuttons) or by passive pedestrian detection, or where a leading pedestrian interval or exclusive pedestrian phasing is used, shall have a signal device an Accessible Pedestrian Signal which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device Accessible Pedestrian Signal and shall comply with 1106.3.
Rationale: As stated earlier in our discussion of scoping, 1102.8, pedestrian signals are not required at some locations because the vehicular signal can be considered adequate, under provisions in the MUTCD, to provide information to pedestrians. These locations may not provide adequate information for pedestrians who are blind without installation of accessible pedestrian signals.
The term 'signal device' has a different meaning in the traffic engineering profession and may not be understood to mean a device that is commonly known as an Accessible Pedestrian Signal. There's no need to introduce confusion.
1106.3 Location.
CHANGE: Pedestrian signal devices Accessible Pedestrian Signals shall be located 60 inches
Rationale: In new construction, the location for the APS can and should be restrictive and consistent. The 'box' in the MUTCD was developed in consideration of retrofit situations and local practice; it is a large area 10 feet
The requirement of location more than 30 inches
1106.2.3 Audible Walk Indication
CHANGE: The audible indication of the WALK interval shall be by voice speech message or tone.
Rationale: The use of the term 'speech message' is more accurate. We are concerned that use of 'voice' will be considered to require the recording of human voice messages. Some methods of digital speech may provide more consistent messaging than individual recordings. Currently, AT&T provides text to speech messaging capabilities on the web and in commercially available software. (http://www.naturalvoices.att.com/demos/index.html)
1106.2.3.1 Tones.
CHANGE: Tones shall consist of multiple frequencies with a dominant component at 880 Hz. The duration of the tone shall be 0.15 seconds
Rationale: The current wording of the duration and repetition rate could be understood to indicate a continuous tone. We assume that the Board intended to require a tone such as is used in the Swedish or Australian signals. These repeat at rates of around 7 to 10 repetitions per second with short bursts of sound, with silence between tones of around 50 milliseconds. A repetition rate of 0.15 seconds
1106.2. Speech WALK Messages.
ADD A NEW SECTION
ADD: 1106.2._ Speech WALK Messages.
ADD: 1106.2. WALK signals may be in the form of speech messages.
1106.2._._ Speech WALK messages shall contain the words "WALK SIGN."
1106.2._._ Speech WALK messages shall repeat throughout the WALK interval or be combined with a repeating WALK tone.
Exception: Speech messages may be limited to a maximum of seven seconds in duration where pedestrian signals rest in WALK.
1106.2._._ At intersections having concurrent pedestrian phasing, speech messages shall follow the model: "Howard. Walk sign is on to cross Howard." Designation of "street, "avenue," etc. shall be used whenever its omission could lead to ambiguity.
Rationale: The language of speech walk messages must be consistent and these guidelines should repeat at least the same specifications as in the MUCTD. The MUTCD specifies that speech WALK messages should say 'Walk sign', in order to provide information about the status of the walk indication without providing a command, such as 'walk now'. Accessible Design for the Blind completed a survey of pedestrians who are blind, traffic engineers and orientation and mobility specialists last year and developed recommendations for speech WALK messages, as well as pushbutton informational messages. The recommended wording for WALK messages was "Howard. Walk sign is on to cross Howard."
In the US, speech WALK messages are commonly used in newer accessible pedestrian signal installations. All of the pushbutton-integrated devices on the market in the US are capable of providing speech messages. Speech WALK messages are not necessary to providing unambiguous information regarding which crosswalk has the WALK interval, provided that pushbuttons are installed in the locations specified, and they will be unintelligible to some users in some ambient noise conditions. However, speech walk signals are perceived as being more user-friendly than tonal WALK signals. Good installation has a number of requirements.
Speech WALK messages should continue to repeat throughout the WALK interval, or be combined with a WALK tone for the balance of the WALK interval so that pedestrians with visual impairments will know when the WALK interval ends, they will be aware of its full duration, and be able to initiate street crossings in knowledge of the status of the pedestrian signal. Combination of a speech WALK signal with a tone signal may have some of the advantages of both. It should be clear that this is permitted.
At many intersections of an arterial with a minor street, the pedestrian signal on the minor street "rests in WALK" during the vehicular green of the arterial, until a pedestrian or vehicle actuates the signal to enter or cross the arterial. WALK signals that sound continuously during what is sometimes a walk interval some minutes long will be particularly objectionable in neighborhoods. Most of the pushbutton-integrated APS have means to limit the WALK signal to a certain number of seconds. Pedestrians may be able to actuate the audible WALK signal multiple times during the same (rest-in-)WALK interval.
1106.2.3.2 Volume
ADD: Exception: When special activation is used to provide audible beaconing, the volume may exceed 5dB above ambient noise level.
Rationale: Special activation of louder signals may be useful in some situations to provide beaconing. If it is provided by special activation, such as a long press of the pushbutton, as suggested by PROWAAC and provided by several US manufacturers of APS, the louder signal will only sound when someone requests such a feature. Allowing a volume increase in response to special activation will provide some flexibility as these features develop in response to needs and as research continues on these issues.
Additional speakers mounted at pedhead might be found to provide directional information to pedestrians who are blind or visually impaired; we do not want these guidelines to prevent further evaluation of that option.
1106.2.3.3 Duration
ADD: WALK tones shall repeat throughout the WALK interval.
Exception: WALK tones may be limited to a maximum of seven seconds in duration where pedestrian signals rest in WALK.
Rationale: At many intersections of an arterial with a minor street, the pedestrian signal on the minor street "rests in WALK" during the vehicular green of the arterial, until a pedestrian or vehicle actuates the signal to enter or cross the arterial. WALK signals that sound continuously during a walk interval that is often several minutes long will be particularly objectionable in neighborhoods. Most of the pushbutton-integrated APS have means to limit the WALK signal to a certain number of seconds. Pedestrians can actuate the audible WALK signal multiple times during the same rest-in-WALK interval, if needed.
1106.3.2 Pushbutton Locator Tone.
ADD: Exception: When special activation is used to provide audible beaconing, the volume of the locator tone for the succeeding clearance interval may exceed 5dB above ambient noise level
Rationale: When special actuation of louder signals is used to provide beaconing, having the loudness of the pushbutton locator tone increased for the remainder of the pedestrian phase is essential to enabling those who need this assistance to home in on the opposite corner while they are still in the middle of the crossing.
1107.4 Arrow
ADD: more specific information on contrast
1106.4.Arrow. Signs shall include a tactile arrow aligned parallel to the crosswalk direction. The arrow shall be raised 1/32 (0.8 mm) minimum and shall be 1-1/2 inches
Rationale: Contrast in hue may not be perceptible but light/dark will be perceptible for most who use visual information.
1106.4.2 Street name
CHANGE TO READ: Accessible pedestrian signals shall include street name information aligned parallel to the crosswalk direction and complying with 703.3, or shall provide street name information in audible format.
Rationale: Street name information provided in audible format will be usable by more individuals than street name information provided in tactile format.
Providing street name information in tactile characters will result in signs that are very large. Most persons who read by touch read Braille. If there is a requirement for tactile street name information, it is more reasonable to require Braille information than tactile characters. It will serve those who will use it better, and require smaller, less expensive signs.
1108. DETECTABLE WARNINGS
1108.1.2 Size
CHANGE Add a maximum depth:
1108.1.4 Size. Detectable warning surfaces shall extend 24 inches
Rationale: We assume the Board did not establish a maximum depth of detectable warning because there is some research evidence that deeper warnings are more detectable. However, while research by Bentzen and others consistently found that blind persons more reliably detected detectable warnings at 30 inches
Failure to specify a maximum depth could result in continued installation of detectable warnings on the full surface of curb ramps. Installing such large areas of detectable warning surfaces as entire curb ramps provides less precise information to blind pedestrians than installing a smaller amount in a very predictable location. In addition, larger depth may result in increased expense and greater possible adverse impact on persons with mobility impairments.
1108.2.1 Curb Ramps and Blended Transitions
ADD EXCEPTION:
Exception: At cut-through islands and medians, the detectable warning may be located so that the edge nearest the crosswalk is at the curb line.
Rationale: The PROWAAC recommendation that detectable warnings be 6-8 inches
However, requiring that detectable warnings be 6-8 inches
1108.2.2 Rail Crossings
ADD EXCEPTION.
Exception: Where automatic gates across pedestrian ways bar pedestrian access to the crossing when rail vehicles are approaching or at a crossing, the detectable warning surface shall be located to the side of the automatic gate farthest from the crossing.
Rationale: Automatic gates can cause serious head injury to blind pedestrians approaching crossings. There is currently no reliable way for pedestrians who are blind to be notified of the location of automatic gates. Gate support is typically outside the normal pedestrian route and not likely to be encountered by blind pedestrians. Where there is a gate, a blind pedestrian may become trapped between the gate and the crossing, with the gate barring the way for the blind pedestrian to move farther away from the crossing.
Thank you for opportunity to comment. It is important that the needs of pedestrians, including those who are visually impaired or blind, are considered in the ADA guidelines.
Following: AER Resolutions
Resolution 2002 - 05
WHEREAS people with disabilities and in particular those who are blind or visually impaired have difficulties negotiating Public Rights of Way in the United States and in Canada; and
WHEREAS, in the United States, the Architectural and Transportation Barriers Compliance Board (Access Board) has developed draft design guidelines to ensure that access for persons with disabilities is provided wherever a pedestrian way is newly built or altered, and to insure that the same degree of convenience, connection, and safety afforded the public generally is available to pedestrians with disabilities; and
WHEREAS street crossings at signalized intersections are often inaccessible to pedestrians with vision impairments; and
WHEREAS the U.S. Access Board has therefore proposed guidelines for
accessible pedestrian signals at all crosswalks with pedestrian signal
information, and guidelines to make all pedestrian pushbuttons accessible; and
WHEREAS in Canada, recommendations for revised standards for accessible
pedestrian signals and accessible pedestrian pushbuttons are currently being developed by the Canadian National Committee on Accessible Pedestrian Signals; and
WHEREAS where boundaries between pedestrian and vehicular ways are not
reliably detectable to pedestrians with vision impairments, these
pedestrians may be unaware when they move from the pedestrian way into the vehicular way; and
WHEREAS the U.S. Access Board has therefore proposed guidelines for defining the boundary between the pedestrian way and the vehicular way by the use of truncated dome detectable warnings where curb ramps, landings and blended transitions connect to crosswalks, and at cut-through medians and islands, and at level rail crossings in the pedestrian way; and
WHEREAS crossings at roundabouts and slip lanes are often inaccessible to pedestrians with vision impairments because of difficulties inherent in determining safe crossing times based on acoustic information, and because of difficulties in locating crosswalks; and
WHEREAS the U.S. Access Board has therefore proposed guidelines for
accessible pedestrian signals for each segment of each crosswalk, and
barriers where crossing is not permitted; and
WHEREAS pedestrians with vision impairments are at an equally great risk from objects protruding from poles and from walls; and
WHEREAS the U.S. Access Board has therefore proposed guidelines in which the amount by which objects may protrude from both poles and from walls is four inches; and
WHEREAS temporary circulation paths are independently usable by persons with vision impairments only if they know about them, and temporary barriers that are not detectable by the use of a long cane do not adequately protect pedestrians with vision impairments, or channelize them along an alternate route if they are not readily detectable by the use of a long cane; and
WHEREAS the U.S. Access Board has therefore proposed guidelines for signs, and guidelines for barricades that are readily detectable by persons traveling with the aid of a long cane; and
WHEREAS persons with low vision are at particular risk of falling at stairs because of inability to visually determine the depth of tread and height of riser; and
WHEREAS the U.S. Access Board has therefore proposed a guideline for
contrasting color along the nosings of stairs, that will increase the
perceptibility of tread depth and riser height;
Therefore be it resolved that on this 21st day of July, 2002, in the city of Toronto, Ontario, that the Association for Education and Rehabilitation of the Blind and Visually Impaired (AER) commends the Access Board for attending carefully to the unique access needs of persons with vision impairments in the preparation of the Draft Guidelines for Accessible Public Rights-of-Way.
Be it further resolved that AER urges the U.S. Federal Highway Administration to bring the Manual on Uniform Traffic Control Devices into harmony with the Draft Guidelines for Accessible Public Rights-of-Way.
Be it further resolved that the AER urges the Transportation Association of Canada to incorporate the recommendations of the Canadian National Committee on Accessible Pedestrian Signals into the Canadian Manual of Uniform Traffic Control Devices.
Be it further resolved that the AER urges the Canadian Standards Association to consider harmonizing Canadian standards with the recommendations in the U.S. Draft Guidelines for Accessible Public Rights-of-Way concerning detectable warnings, protruding objects, temporary circulation paths, roundabouts and stair nosings.
RESOLUTION 94-08
WHEREAS professionals in Orientation and Mobility have observed that when visually impaired pedestrians approach streets at curb ramps they are at risk of walking unaware into the path of moving traffic, since there is no clearly defined distinction at curb ramps between the roadway and sidewalk; and
WHEREAS research has now been conducted which confirms that for persons who are visually impaired, there is a high level of risk of inadvertent street entry associated with the presence of curb ramps, particularly those having slopes of 1:12
WHEREAS it has been demonstrated that detectable warnings complying with ADAAG 4.29.2 are highly detectable by persons with visual impairments, and can provide an effective stop signal for persons who are blind or visually impaired which can be used to determine the end of the sidewalk and the beginning of the vehicular way; and
WHEREAS research has now been conducted which addresses concerns about safety of detectable warnings, indicating that detectable warnings on slopes have minimal impact on the safety and ease of travel for persons having physical disabilities (Bentzen, et al. 1994); and
WHEREAS research has demonstrated that 24 inches
WHEREAS consistency in dimensions and placement of detectable warnings is of critical importance in successful interpretation by the user in varied settings;
THEREFORE BE IT RESOLVED on this 13th day of July, 1994, in the city of Dallas, Texas, that AER urges the Architectural and Transportation Barriers Compliance Board (Access Board) to issue a rule requiring a 24 inch
BE IT FURTHER RESOLVED that AER urges the Access Board to issue a rule requiring a similar 24 inch
Resolution 98-01
WHEREAS Orientation and Mobility Specialists have observed that when visually impaired pedestrians approach streets at curb ramps they are at risk of walking unaware into the path of moving traffic, since there is no clearly defined distinction at curb ramps between the roadway and sidewalk; and
WHEREAS research has now been conducted which confirms that for persons who are visually impaired there is a high level of risk of inadvertent street entry associated with the presence of curb ramps, particularly those having slopes of 1:12
WHEREAS it has been demonstrated that detectable warnings complying with ADAAG 4.29.2 are highly detectable by persons with visual impairments, and can provide an effective stop signal for persons who are blind or visually impaired which can be used to determine the end of the sidewalk and the beginning of the vehicular way; and
WHEREAS research has now been conducted which addresses concerns about safety of detectable warnings, indicating that detectable warning on slopes have minimal impact on the safety and ease of travel for persons having physical disabilities (Bentzen, B., Nolin, T., Easton, R., Desmaris, P., and Mitchell, P., 1994; Hauger, et al, 1996); and
WHEREAS research has demonstrated that 24 inches
WHEREAS it was the nearly unanimous recommendation of the workshop on curb ramps and detectable warnings sponsored by the U.S. Access Board and Project ACTION in January, 1995, that no additional research was needed on detectable warnings at curb ramps and that a detectable warning should forthwith be required on the full width of curb ramps beginning at the curb line and extending back 24"; and
WHEREAS numerous municipalities in the United States have installed detectable warnings on curb ramps and have reported no instances in which safety has been compromised by the presence of detectable warnings on curb ramps;
THEREFORE BE IT RESOLVED on this 12th day of July, 1998, in Atlanta, Georgia that AER urges the U.S. Access Board to provide specific opportunity for public comment on detectable warnings at curb ramps and hazardous vehicular ways when the notice of proposed rulemaking for the revised ADA Accessibility Guidelines is published.
BE IT FURTHER RESOLVED that AER continues to strongly advocate the provision of a 24" wide detectable warning surface at the bottom of curb ramps and at hazardous vehicular ways, particularly where those hazardous vehicular ways are blended curbs or raised crossings at intersections.(See AER Resolution 94-08).
BE IT FURTHER RESOLVED that AER urges Transport Canada to require a 24" wide detectable warning surface at the bottom of curb ramps and at hazardous vehicular ways, particularly where those hazardous vehicular ways are blended curbs or raised crossings at intersections.
Resolution 98-02
WHEREAS the Americans with Disabilities Act guarantees the right of access to information to persons with disabilities; and
WHEREAS many signalized intersections provide information to pedestrians with sight which is not provided to pedestrians with visual impairments; and
WHEREAS it has been demonstrated ( Crandall, W., Bentzen, B.L., and Myers, L., 1998) that competent, independent, blind pedestrians at unfamiliar signalized intersections may initiate as many or more than 34% of crossings during the clearance or DON'T WALK intervals if those intersections are not equipped with accessible pedestrian signals; and
WHEREAS accessible pedestrian signals have been widely used for more than 10 years in countries including Australia, Japan, Sweden, and the United Kingdom and are considered by traffic engineers to be widely effective not only in providing information to blind pedestrians but also in decreasing general pedestrian delay and facilitating vehicular flow at signalized intersections; and
WHEREAS increasing numbers of quiet vehicles, including electric vehicles and those with quiet internal combustion engines, make acoustic information from vehicles inconsistent, resulting in the inability of pedestrians who are blind to reliably detect the onset of the WALK interval by listening for a surge of vehicles; and
WHEREAS inexpensive technologies exist to make Accessible Pedestrian Signals which are automatically responsive to ambient sound , being very quiet at night and in low traffic situations, while still loud enough to be heard above vehicular sound in high traffic situations; and
WHEREAS accessible vibrotactile and speech transmission signal systems exist which add no noise to the environment; and
WHEREAS the Transportation Equity Act for the 21st Century provides that "Transportation plans and projects . . . shall include the installation, where appropriate, and maintenance of audible traffic signals and audible signs at street crossings;"
THEREFORE BE IT RESOLVED on this 12th day of July, 1998, in Atlanta, Georgia that AER urges the U.S. Federal Highway Administration and Transport Canada to develop recommended practices for installation of pedestrian signals which make information which is regularly provided to other pedestrians, accessible to pedestrians who are visually impaired, including but not limited to: information specifying WALK and DON'T WALK intervals; information indicating the presence and location of push-buttons; and information unambiguously indicating the street to which the signal applies.
Resolution 98-03
WHEREAS traffic engineers are increasingly utilizing signal systems in which the only safe time to cross signalized intersections is provided in response to pedestrian use of a push button; and
WHEREAS persons who are visually impaired consistently identify location of the push button as the major problem they experience at pedestrian actuated intersections (American Council of the Blind survey, 1998; City of San Diego, Department of Transportation, 1994; and Tauchi, M., Sawai, H., Takato, J., Yoshiura, T., and Takaeuchi, K., 1998 ); and
WHEREAS persons who are visually impaired often have insufficient time when pedestrian push buttons are far from associated crosswalks, to actuate push buttons and then prepare to cross before the onset of the WALK interval (American Council of the Blind survey, 1998); and
WHEREAS unobtrusive technologies exist for providing information in accessible format, specifying the presence and location of push buttons;
THEREFORE BE IT RESOLVED that AER urges the U.S. Federal Highway Administration and Transport Canada to develop standards for push button location technology such as quiet audible locator tones, and to require the placement of newly installed pedestrian push buttons in close proximity to the top landing of the curb ramp serving that crossing, within accessible reach range for use from a wheelchair, and near enough to the curb line that persons with visual impairments can actuate the push button and then align and prepare for crossing before the onset of the WALK interval.
RESOLUTION 2000-05
WHEREAS there are roundabouts in many states in the United States, and many more are proposed or under construction; and
WHEREAS roundabouts have been shown to reduce the rate of serious personal injury crashes to drivers and passengers relative to similar signalized intersections, and thus have demonstrated their usefulness as an option for intersection design; and
WHEREAS despite the benefits to motorists, recent research at roundabouts in the U.S. indicates that blind pedestrians have difficulty at some roundabouts in determining appropriate times to begin crossing, and also may have difficulty locating crosswalks, aligning to cross the street, and maintaining their heading while crossing; and
WHEREAS focus groups of blind pedestrians conducted by U.S. researchers in the United Kingdom and France reported that the many roundabouts in those countries caused serious access problems for pedestrians who are blind or visually impaired; and
WHEREAS persons with blindness or visual impairments have the right to full access to public rights of way, including roundabouts;
NOW THEREFORE BE IT RESOLVED, this 19th day of July, 2000 in
BE IT FURTHER RESOLVED that, as research identifies best practices concerning roundabouts and blind pedestrians, these practices be implemented by traffic engineers and planners, and included in all U.S. and Canadian design manuals covering roundabouts.
Unanimously Approved
Eugene Lozano, Jr., October 27, 2002
I am submitting to you the comments of the California Council of the Blind
regarding: DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY, Docket
Number: 02-1, Submitted: October 27, 2002, to be included in the docket record.
In Microsoft Word 2000 files, you will find attached the following:
1. CCB Resolution 96B-8
2. CCB Resolution 98B-7 Accessible Pedestrian Traffic Signals 3. CCB Resolution 2000A-11 Directional Curb Ramps and Curb Cuts 4. CCB Resolution 2000B-7 Detectable Warning Specifications 5. CCB Resolution 2001A-8 The Visibility of Marked Pedestrian Crossings 6. CCB Resolution 2001B-5 Accessible Pedestrian Signals Minimum Standards 7. CCB Resolution 2001B-9 Installation of Sidewalks and Their Separation from Bicycle Lanes 8. California Council of the Blind's comments on Public Rights-of-Way Guidelines June 17, 2002
If there is any questions regarding this submittal, I can be reached at [...].
Respectfully,
Eugene Lozano, Jr., Chair
Committee on Access and Transportation
California Council of the Blind, Inc.
EXECUTIVE OFFICES
California Council of the Blind
Resolution 96B-8
WHEREAS, there exists a trend to construct corners, sidewalks, and bus-stop pads, either without curbs or with rolled/rounded curbs; and
WHEREAS, this trend is promoted primarily by persons with mobility-limiting
disabilities for reasons of increased access, as well as by architects who view this design as esthetically pleasing; and
WHEREAS, the absence of curbs or the presence of rolled/rounded curbs presents serious hazards for pedestrians, and especially for blind and visually impaired pedestrians; and
WHEREAS, the presence of vertical/squared-faced curbs decreases significantly the serious hazards found at curbless or rolled/rounded curb locations, while at the same time vertical/squared-faced curbs provide a cue with which a blind or visually impaired person may align when crossing a vehicular way; Now therefore
BE IT RESOLVED, by the California Council of the Blind, in convention assembled this 24th day of November, 1996, in the city of San Diego, California, that this organization support the use of vertical/squared-faced curbs at corners, sidewalks, and bus-stop pads adjoining vehicular ways, such as intersections, streets, or parking lots with curb ramps, in accordance with federal, state, or local accessibility standards and local building codes, except in cases where building officials can show that there is a demonstrated need for the use of curbless
corners, sidewalks, bus-stop pads, or walking surfaces which are not separated by railings, planters, or other elements between the pedestrian areas and the vehicular areas, so long as, in such cases, the boundary between these areas is defined by a continuous detectable warning which complies with Title 24 of the California Code of Regulations, and
BE IT FURTHER RESOLVED that this organization and its chapters advocate for the inclusion in building codes and regulations of vertical/squared-faced curb requirements at corners, sidewalks, bus-stop pads, and other appropriate walking surfaces, and
BE IT FURTHER RESOLVED that this organization oppose, by any means necessary, efforts which may compromise the safety and independent travel of blind or visually impaired pedestrians in their access to corners, sidewalks, bus-stop pads, and other walking surfaces.
Resolution 98B-7
Accessible Pedestrian Traffic Signals
WHEREAS, it is becoming increasingly common for entities in this state and throughout the country, when installing audible and other accessible pedestrian traffic signals, not to place a signal at every comer of an intersection where a pedestrian crossing can be made; and
WHEREAS, this practice violates the spirit of full accessibility; and
WHEREAS, more importantly, the failure to install an accessible pedestrian traffic signal at each comer of an intersection at which a pedestrian crossing can be made leads to confusion, thus creating serious safety concerns; and
WHEREAS, this failure may also create liability problems for public entities, now,
THEREFORE, BE IT
RESOLVED, by the California Council of the Blind, in convention assembled this 8th day of November, 1998, in the city of Ontario, California, that this organization urge the California Traffic Control Devices Committee and the California Department of Transportation to amend guidelines contained in the California Department of Transportation traffic manual to require that, at any intersection at which an audible pedestrian traffic signal is installed, a signal be placed on each comer at which a pedestrian crossing can be made, and BE IT FURTHER
RESOLVED, that the president of this organization transmit a copy of this resolution to the U.S. Department of Transportation/Federal Highway Administration's, Bicycle and Pedestrian Guidelines Committee, the National Committee to Revise the Manual on Uniform Traffic Devices, and the American Council of the Blind, in order to pursue the adoption of similar guidelines on
the national level.
Resolution 2000 A 11 Directional Curb Ramps and Curb Cuts
Whereas, for more than two decades federal and state accessibility standards have mandated the installation of curb ramps and curb cuts at street crossings as part of new construction and alterations; and
Whereas, these accessibility standards have never clearly addressed the orientation of these curb ramps and curb cuts at street crossings; and
Whereas, this failure has frequently resulted in the construction of curb ramps and curb cuts on opposite corners or pedestrian islands that are either not in alignment or not in the intended path of travel; and
Whereas, these practices create access barriers and severe safety hazards for pedestrians with disabilities, and specifically those with visual impairments; and
WHEREAS, these dangers include, (1) a pedestrian with a disability using curb ramps must enter the intersection between perpendicular crosswalks, making them vulnerable to turning traffic while trying to get into one of the crosswalks,
(2) after entering the intersection within the crosswalk, a pedestrian with a disabilities using curb ramps must exit the intersection by leaving the crosswalk to go around the corner within a turn lane to access the only available curb ramp, and
(3) when entering an intersection, a blind or visually impaired pedestrian can easily miss the opposite intended curb and be within moving traffic; and
Whereas, field experience has shown that when curb ramps and curb cuts at opposite corners or pedestrian islands are in alignment within the intended path of travel, they provide greater access and safety for all pedestrians; and
Whereas, field experience has also demonstrated that properly oriented curb ramps and curb cuts have become reliable and effective directional aids in aligning blind and visually impaired travelers with the intended path of travel; and
Whereas, the practice of properly orienting curb ramps and curb cuts fulfills the spirit of full accessibility and safety and may also reduce liability problems for public entities; and
Whereas, these issues are currently being discussed by members of the Public Rights of Way Access Advisory Committee of the Architectural and Transportation Barriers Compliance Board, now therefore, BE IT
RESOLVED, by the California Council of the Blind, in convention assembled this 21st day of May, 2000, in the city of Sacramento, California, that this organization urge the Architectural and Transportation Barriers Compliance Board, and the California Division of the State Architect Access Compliance Program to amend accessibility standards to require that, to the extent technically feasible, there be two curb ramps on each corner at which curb ramps are installed and that all curb ramps and curb cuts on opposite corners and pedestrian islands be in alignment and within the intended path of travel, and be it further
RESOLVED, that a copy of this resolution be submitted to the American Council of the Blind for consideration at its 2000 annual convention.
Resolution 2000B-7 Detectable Warning Specifications
Whereas, the California Council of the Blind has long advocated for detectable warning surfaces adjacent to hazardous areas; and
Whereas, reports and research studies sponsored by the US Architectural and Transportation Compliance Board (Access Board), the US Department of Transportation, and Project Action agree that where a curb ramp or level curb pedestrian way exist, a detectable warning strip must be placed immediately adjacent to the vehicular way in order to indicate, for persons who are blind or visually impaired, the precise location of the danger; and
Whereas, some of this work has shown the value of detectable warnings having the following surface characteristics: 70% color contrast from the adjoining walking surface, safety yellow, resiliency, sound difference from the adjoining walking surface, and the alignment of truncated domes on a square grid; and
Whereas, the need has been demonstrated for a depth of 36 inches
Whereas, the Access Board's Public Right of Way Access Advisory Committee is currently considering the reintroduction into the American's With Disabilities Act Accessibility Guidelines (ADAAG) of detectable warning surface requirements for curb ramps, curb cuts, track crossings, hazardous vehicular areas, and reflecting pools, now, therefore, be it
Resolved, by the California Council of the Blind in convention assembled this 5th day of November, 2000, in the city of Los Angeles, that this organization advocate for the following standards:
(1) The need for detectable warning surfaces at all curb ramps and curb cuts, regardless of slope, track crossings, hazardous vehicular areas, and reflecting pools.
(2) The detectable warning surface at such locations shall extend the full width of the demarcation of the hazardous area, and shall have a depth of 36 inches
(3) The detectable warning surface shall have the following features:
(a) The detectable warning surface shall consist of a durable, slip-resistant material, having a surface texture composed of an alignment pattern of raised, truncated
domes, on a square grid with a diameter of 0.9 inches
Page 2 Resolution 2000B-7 Detectable Warning Specifications continued
(b) The detectable warning surface shall have at least a 70% color contrast from the adjoining walking surfaces, either light on dark, or dark on light. The material used to provide contrast shall be an integral part of the walking surface. Warning surfaces shall differ from adjoining walking surfaces in resiliency or sound on cane contact. This surface shall be reserved for warning only.
(c) The color yellow shall conform to Federal Color No. 33538, as shown in table number 4 of standard number 595B. Where the color value contrast between the yellow warning and the main walking surface is less than 70%, at least a 2 inch
Resolution 2001A-8 The Visibility of Marked Pedestrian Crossings
Whereas, marked crossings are of particular use as visual guides to pedestrians with low vision and are of greatest assistance at irregular intersections and mid-block crossings; and
Whereas, both The Manual on Uniform Traffic Control Devices (MUTCD) published by the Federal Highway Administration (FHWA) and the California Department of Transportation (Cal Trans) Traffic Manual require that when crosswalk lines are installed, they shall be solid white lines, marking both edges of the crosswalk, except that the Cal Trans manual requires that, in the case of school crossings, the outside edges be outlined with safety yellow crosswalk lines, and
Whereas, many urban street crossings are, however, beginning to be delineated in brick or other unit paving materials, particularly where design standards have been developed for an historic district or other significant area; and
Whereas, these street crossings utilizing brick or other unit paving materials have been found by pedestrians with low vision to be difficult to visually distinguish from the adjoining street surface; and
Whereas, when adjacent public sidewalks are similarly paved, it is difficult to distinguish between sidewalk areas and street crossings, particularly if non-raised sidewalks have been installed in lieu of well-defined sidewalk curb ramps, and
Whereas, in addition, colors used in brick or unit paving materials cannot be easily distinguished by persons with color blindness, and
Whereas, it is essential to use markings with a strong visual contrast, both between sidewalk surfaces and crossings and between street surface and crosswalk lines, now therefore, be it
Resolved, by the California Council of the Blind, in convention assembled this 22nd day of April, 2001, in the city of Sacramento, California, that this organization urge the California Department of Transportation and local Public Works Departments to cease installing street crossings that are delineated in brick or other unit paving materials, and be it further
Resolved, that when the California Department of Transportation or a local Public Works Department decides to install street crossings that are delineated in brick or other unit paving materials in historic districts or other significant areas that their edges shall be marked with white crosswalk lines except if they are at school crossings, which requires the use of safety yellow crosswalk lines.
Resolution 2001B-5
Accessible Pedestrian Signals Minimum Standards
WHEREAS, the California Council of the Blind (CCB) has, for many years, advocated strongly for the use of accessible pedestrian signals, and has been a leader in providing advice on the most appropriate standards to govern their use and installation; and
WHEREAS, subsequent to the adoption of accessible pedestrian signals standards in the Federal Highway Administration (FHWA) Manual on Uniform Traffic Control Devices 2000 millennium edition, as well as accessible pedestrian signals recommendations January 10, 2001 by the Public Rights-of-Way Access Advisory Committee (PROWAAC) of the Federal Access Board, the California Traffic Control Devices Committee is examining the extent to which changes should be made in the audible pedestrian signals guidelines contained in the California Traffic Manual; and
WHEREAS, the CCB, pursuant to Resolution 2001A-1, expressed its view that neither the FHWA standards nor the PROWAAC recommendations were wholly satisfactory, and that California should not, in adopting changes to its guidelines, accept the totality of either federal document; and
WHEREAS, the CCB, at the behest of the California Traffic Control Devices Committee (CTCDC), is providing input on proposed changes to the aforementioned manual, NOW, THEREFORE, BE IT
RESOLVED, by the California Council of the Blind, in convention assembled this 4th day of November 2001, in the city of Los Angeles, California that this organization urge the California Traffic Control Devices Committee (CTCDC) to include all of the following requirements in the California Traffic Manual:
(1) Whenever the state or a local jurisdiction is evaluating the desirability of placing accessible pedestrian signals at a specific existing signalized location, the professional to be consulted in this matter shall be an orientation and mobility instructor certified by the Academy for Certification of Vision Rehabilitation and Education Professionals (ACVREP);
(2) The state or a local jurisdiction shall not require or request that organizations who represent pedestrians who have disabilities and other community organizations be in agreement that there is a widespread community demand for the installation of an accessible pedestrian signal at a specific existing signalized location;
Whenever the state or a local jurisdiction is installing a new, or upgrading an existing traffic signal, the signal shall be automatically equipped with accessible pedestrian signals;
(3) The following minimum features requirements shall apply to all accessible pedestrian signals (including overhead devices) that are installed in the state:
(a) All accessible pedestrian signals must have an auditory tone to announce the walk interval. Until ongoing research has been concluded, the auditory tones shall be limited to two options, either a Cuckoo walk sound for a crosswalk in the North-South direction and a Peep-Peep walk sound for a crosswalk in the East-West direction (the closest proximity to these compass directions) or verbal messages to communicate the walk interval that provides a clear message that the walk interval is in effect, as well as to which crossing it applies.
(b) All accessible pedestrian signals must have vibrotactile devices to indicate both that the walk interval is in effect and to which direction it applies, through the use of a vibrating directional arrow or some other means;
(c) All accessible pedestrian signals must have a pedestrian push button with a locator tone;
(d) All audible tones and locator tones must automatically adjust in volume in relation to the ambient noise level;
(e) Activation of the pedestrian traffic signal shall simultaneously activate the accessible pedestrian signal;
(f) All Pedestrian push buttons that activate an accessible pedestrian signal must be marked with a universal tactile and visual symbol that identifies that there is an accessible pedestrian signal at the crossing, and BE IT FURTHER
RESOLVED that these standards not prohibit the state or a local jurisdiction from providing additional accessible pedestrian signal features if requested by organizations who represent pedestrians who have disabilities, other community organizations, and/or individuals, and BE IT FURTHER
RESOLVED, that this organization transmit a copy of this resolution to the Federal Access Board for use in its consideration of future guidelines on this subject, and BE IT FURTHER
RESOLVED, that this organization transmit a copy of this resolution to the American Council of the Blind for consideration by the ACB Board of Directors or at the 2002 ACB Convention.
Resolution 2001B-09
Installation of Sidewalks and Their Separation from Bicycle Lanes
WHEREAS, the public is entitled to access in public rights-of-way; and
WHEREAS, many miles of public rights-of-way in the United States have been
developed in such a way that only motor vehicular access is provided; and
WHEREAS, neither the Americans with Disabilities Act nor any other federal, state, or local law requires jurisdictions to provide sidewalks or bicycle lanes; and
WHEREAS, both pedestrians and bicyclists are entitled to their fair share of the public right-of-way; and
WHEREAS, due to the significant speed differential between bicycles and pedestrians, the physical separation of sidewalks from bicycle lanes, including those located on bridges, are necessary for safety and access for all; NOW, THEREFORE BE IT
RESOLVED by the California Council of the Blind, in convention assembled this 4th day of November 2001, in the city of Los Angeles, California that this organization recommend that the Federal Access Board, the United States Department of Transportation, the United States Department of Justice, the California Department of Transportation, and the Division of the State Architect require that, whenever a road or bridge is constructed or reconstructed in a public right-of-way in an urbanized area, sidewalks shall, unless technically infeasible, be included, with these sidewalks to be physically separated from bicycle lanes and roadways, and BE IT FURTHER,
RESOLVED, that the California Council of the Blind and its local chapters work closely with pedestrian, transportation, and bicycle advocacy organizations in order to support the physical separation of bicycle from pedestrian facilities and the adequate provision of both types of facilities by prioritizing their construction ahead of the construction of automobile facilities, and to ensure that bicycle and pedestrian facilities are constructed at the appropriate width, and BE IT FURTHER
RESOLVED, that this organization transmit a copy of this resolution to the Federal Access Board for use in its consideration of future guidelines on this subject, and BE IT FURTHER
RESOLVED, that this organization transmit a copy of this resolution to the American Council of the Blind for consideration by the ACB Board of Directors or at the 2002 ACB Convention.
Eugene Lozano, Jr., Chair
Committee on Access and Transportation
California Council of the Blind
EXECUTIVE OFFICES
COMMENTS OF THE CALIFORNIA COUNCIL OF THE BLIND
Regarding: DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY
Docket Number: 02-1
Submitted: October 27, 2002
Submitted by: Eugene Lozano, Jr., Chair, Committee on Access and Transportation, California Council of the Blind
The California Council of the Blind (CCB) is pleased to submit the following comments on the Draft Guidelines for Accessible Public Rights-Of-Way, which were issued on June 17, 2002.
The CCB, a state affiliate of the American Council of the Blind (ACB), is a statewide membership organization. Its members are blind, visually impaired and fully sighted individuals who are concerned about the dignity and well-being of blind and visually impaired people throughout the state. Formed in 1934, the Council has become the largest organization of people who are blind or visually impaired in the state of California, with over 50 chapters and special interest affiliates and a membership of over 3,000.
Through a variety of programs and services, CCB enables people who are blind or visually impaired to live and work independently and to participate in their own communities. The Council has influenced change in such areas and issues as civil rights, employment, rehabilitation, transportation, environmental access, travel, recreation, Social Security, and other benefits. To strengthen advocacy efforts, the Council often works in coalition with other state disability groups.
On behalf of the CCB, I wish to express our support to the recommendations contained in this draft. These guidelines are vital to insure that persons with disabilities have an equal opportunity to participate in their community. In the text that follows, we will highlight some of the proposals which we believe have the greatest impact on pedestrians who are physically disabled, blind or visually impaired, and provide our comments, amendments, and recommendations thereon.
In our comments, any language that is to be added will be underlined and in bold text and any language to be deleted will have a strike out through the text.
1. Section 1102.3. Alternate Circulation Path. The proposed guideline requires an alternate circulation path whenever the existing sidewalk is
blocked by construction, alteration, maintenance or other temporary conditions. This will insure that people with disabilities will not be denied access to the public sidewalks for the duration of the construction project, which can last for years.
2. Section 1102.10. Stairs. The proposal to require a 2-inch visually contrasting strip along each tread nosing is very important for persons with visual impairments, particularly those with little or no depth perception. This section needs to be amended as follows: "Where provided, stairs shall comply with 504. The upper approach as well as all stair treads shall have be clearly marked with a 2-inch (51 mm) wide strip of color contrasting with the tread and riser, dark on light or light on dark, the full width of the front edge of each tread."
The upper approach is not a stair tread and it is essential that its nosing be seen before someone begins to decent a stairway. Also, light/dark contrast is the important feature followed by the color hue. There are persons with eye conditions such as macular degeneration, which have the color blindness in the areas of red and green, but can see safety yellow. Therefore, they must rely on the contrast between the stripping material from the materials that make up the upper approach and the individual traits of the stairway.
As stated by many studies (Rodstein, M., "Accidents Among the Aged: Incidence, Causes, and Prevention," Journal of Chronic Disease, 1964, 7: 515-526; Sekuler, R., Hutman, L.P., and Owsley, C. J., "Human Aging and Spatial Vision," Science, September 1980, 209(4462) : 1255-1256; Pauls, J.L., "What Can We Do to Improve Stair Safety," Building Standards, May-June 1994), stair falls are a cause of many serious injuries, and the largest category of these falls are caused by misjudging and overstepping the width of treads. Lori Sakamoto, O.D., and Edwin B. Mehr, O.D., in "A New Method of Stair Markings for he Visually Impaired," state that "Judging stair tread width requires that a traveler differentiate between the light and dark areas produced by the shadows of steps. This type of spatial discrimination depends upon contrast sensitivity. Decrease in contrast sensitivity is a normal age-related change. In the presence of ocular pathology there is an even greater problem with stair discrimination." Thus discerning where steps begin and end can be a problem for a great many people, including aging people with gradually deteriorating contrast sensitivity, as well as those officially considered "visually impaired."
It has been argued that all that is required to alleviate this problem is adequate lighting. This is a drastic over simplification, as Dr. Samuel Genensky, O.D. and founder of the Center for the Partially Sighted, which was originally established in Santa Monica, California, and is now in Los Angeles, discussed in his May 6, 1992 comments on proposed ANSI A 117.1 Regulations for the Marking of Steps and Stairs 4.9.9: "...steps and stairs can only be illuminated so as to cast shadows that reveal their presence if the artificial illumination is placed very precisely so as to produce the required shadows. Unfortunately, the positioning of artificial illumination to achieve this effect is not very practical, and could prove to be counter-productive." This specific type of lighting is very different, he explains, from the generic, overall lighting usually used to illuminate spaces in buildings. "To require that builders and building owners provide illumination for the steps and stairs in addition to the illumination of the broader areas when the illumination of the broader areas illuminates the stairs adequately, is both costly and unjust, especially when one realizes that the marking of the stairs...coupled with the overall room and/or hall lighting will accomplish the task to everyone's satisfaction and safety." Furthermore, the lighting problem is even more complex where outside stairs are concerned. "In the case of steps and stairs that in the daytime depend n illumination from the sky or sun, the presence or absence of shadows cast by the steps or stairs changes from hour to hour depending on the position of the sun and on the light provided by the sky."
Stair markings are already required by several different sets of regulations, including the California Building Code (Part 2, Title 24, CCR), section 1133B.4.4 Striping for the visually impaired, July 1999 (this requirement has been in the California Building Code since 1981), and the National Fire Protection Association, Inc.'s "Code for Safety of Life from Fire in Buildings and Structures," Section 8-2.5.6.9(g), 1988. These precedents for this section argue for its validity.
As a personal note, when I was a visually impaired pedestrian growing up in san Francisco, I found that the stripping on the exterior stairs rather than grooves was the most effective way for me to distinguish the upper approach and all treads of stairs. It was not uncommon to find on some of the steeper hills in the city that there were some steps incorporated into the sidewalk (some were very steep), and there were some occasions I came close to falling down them when they were not marked, particularly when it was dark.
Now as a totally blind pedestrian, I still support stair strippings, but would like to see that on the upper approach of each flight of steps, there be a safety yellow colored detectable warning surface set back the depth of one stair tread to alert me of the potential hazard of a series of stairs, which is in the public right of way.
3. Section 1102.12. Vertical Access. The proposal to require that vertical access elevators and lifts remain unlocked is vital for persons with disabilities, who cannot use stairways. This will insure that access to the disabled is as readily available as it to the general public. Experience has shown that locked elevators and lifts in effect deny access to persons with disabilities.
4. Section 1102.13 Bus Stops. "Bus boarding and alighting areas shall comply with 810.2. ..." The CCB requests this section and section 810.2 be amended to require that all newly constructed or altered bus stop pads be required to be raised, to have a minimum 6 inch
Therefore, we request that these sections be amended to require bus stop pads to be raised with a minimum 6 inch
Please refer to the attached CCB Resolution 96B-8.
5. Section 1102.14. On-Street Parking. The proposed requirement that at least one accessible on-street parking space be provided for each block face is absolutely necessary to insure that persons with disabilities are able to have equal access to on street parking.
6. Section 1103.7.1 Detectable Warnings. The proposed guideline is essential to ensure where rail systems cross pedestrian facilities that are not shared with vehicular ways that detectable warning surfaces be installed on both sides of the track(s) so to alert a person who is blind or visually impaired that they are entering a potentially hazardous situation.
7. Section 1103.8. Changes in Level. Requiring that changes in level can not occur more frequently than every 30 inches
8. Section 1104.3.2. Detectable Warnings. The proposed guideline to require Detectable Warnings or truncated domes at all curb ramps regardless as to their slopes is vitally important to persons who are blind or visually impaired. Truncated domes are necessary to insure that persons with visual impairments are able to detect where the sidewalk stops and the street begins. Research has been conducted which addresses concerns about safety of detectable warnings, indicating that detectable warning on slopes and on generally horizontal surfaces have minimal impact on the safety and ease of travel for persons having physical disabilities (Bentzen, B., Nolin, T., Easton, R., Desmaris, P., and Mitchell, P., 1994; Hauger, et al, 1996). By requiring that the truncated domes be in a line and widely spaced pattern, wheelchair users will be able to wheel across the domes without difficulty.
The ATBCB has concluded research demonstrating the need for detectable warnings and their effectiveness for persons having visually impairments and their potential benefit also for persons having physical disabilities (Hauger et al. 1996); the original requirement was suspended pending the conduct of this research.
Additional research by Bentzen and Barlow (Impact of curb ramps on the safety of persons who are blind, Journal of Visual Impairment and Blindness 89, 319-328) found that on 35% of approaches to unfamiliar intersections via curb ramps (without detectable warnings), experienced blind travelers stepped into the street before they realized they were in the street. Moreover, on 59% of those approaches, there was traffic on the street into which they stepped. A very high level of risk. Moreover, failure to detect streets was very highly correlated with slope of curb ramp, with more failures to detect the street occurring when the slope was minimal.
Bentzen and Barlow's research substantiates the need for detectable warnings on all curb ramps regardless of their slope and would refute the argument to restrict the use of detectable warnings on curb ramps with the slope of 1 unit vertical to 15 units horizontal or less.
The proponent of restricting the detectable warning surfaces to such a gradual slope is citing the California Code of Regulations, Title 24 Accessibility Standards section 1127B.5 (8) 1999 edition without knowing any of the background history, which established the 1 unit vertical to 15 units horizontal or less limitation for detectable warnings on curb ramps in the state of California.
This requirement was originally established in 1994 by the Office of the State Architect (OSA), now the Division of the State Architect (DSA), to provide some degree of safety for persons who are blind or visually impaired when negotiating curb ramps. The ADAAG requirement for detectable warning had been suspended, but the danger still existed for persons who are blind or visually impaired when negotiating curb ramps. Therefore, Jud Boies, Chief, OSA made an arbitrate decision with no research backing to propose a regulation to limit the installation of detectable warning surfaces on those curb ramps with a slope of 1 unit vertical to 15 units horizontal or less so to reduce some, but not all of the danger faced by blind or visually impaired pedestrians. He felt that it would be irresponsible to know of the danger, and not to address the issue while waiting for research to be performed, which might take many years.
Through formal public hearings, Mr. Boies took the proposed regulation to the California Disability Community and requested input from its members. The members of the Disability Community felt that the safety of blind and visually impaired pedestrians was a paramount issue that needed to be addressed immediately. Also, they felt that Mr. Boies' proposed regulation was the best compromise that could be achieved while waiting for the federal government to sponsor research on the Detectability of Detectable Warnings by Individuals with Visual Impairments, and the Safety and Negotiability on Slopes for Persons with Physical Disabilities.
As it can be seen there is no scientific research to support a limitation of detectable warning surfaces on curb ramps with the slope of 1 unit vertical to 15 units horizontal or less. Rather, there is research that substantiates the need for detectable warning surfaces on all curb ramps regardless of their slope.
Please refer to the attached CCB Resolution 2000B-7 Detectable Warning Specifications.
9. There needs to be created a section 1104.3.8 "Non-shared Curb Ramps." These proposed guidelines fail to clearly address the problems of shared curb ramps by not requiring there be a ramp for each crossing at a corner. The orientation of curb ramps toward the center of an intersection can be disorienting for pedestrians who are blind or visually impaired. In addition, they require an extra turn for wheelchair users. We believe that the guidelines need to encourage orientation of the ramp in the direction of travel along the direction of the crosswalk. The public right-of-way access advisory committee addressed this issue in the "Building a True Community Final Report Public Rights-of-Way Access Advisory Committee" page 80 under heading "Discussion" and made several recommendations, which do not appear to have been incorporated into these draft guidelines.
CCB feels it is vital for the Access Board to address the issue of providing separate curb ramps at corners in these draft guidelines so to ensure greater safety and orientation assistance to persons with disabilities, particularly those with visual impairments.
Please refer to the attached CCB resolution 2000 A-11 Directional Curb Ramps and Curb Cuts.
10. Section 1105.2 Crosswalks. The proposal to require that marked crosswalks have a width of 96 inches
Section 1105.2 needs to be amended to have a section 1105.2.4 that requires that the crosswalk markings be a clearly contrasting color from the road pavement and the sidewalk such as white as required in the Manual on Uniform Traffic Control Devices. Further, the proposed section that the state and local jurisdictions be prohibited from installing street crossings that are delineated in brick or other unit paving materials, and furthermore, when these governmental entities decide to install street crossings that are delineated in brick or other unit paving materials in historic districts or other significant areas that their edges shall be marked with white crosswalk lines.
Persons with visual impairments use the crosswalk markings as a visual guide to make street crossings because of the high visibility of the white color. When traffic engineers use street crossings that are delineated in brick or other unit paving materials with red and other non-clearly contrasting color, access and safety are diminished for persons with visual impairments.
Please refer to attached CCB Resolution 2001A-8 The Visibility of Marked Pedestrian Crossings.
11. Section 1105.4 Medians and Pedestrian Refuge Islands. It is essential to persons who are blind or visually impaired that where the cut-through connects to the street, edges of the cut-through shall be aligned with the direction of the crosswalk for a length of 24 inches
12. The proposed section 1105.4.2 Detectable Warnings guideline that requires Detectable Warnings/truncated domes at cut-throughs and curb ramps at medians and pedestrian refuge islands is vitally important to persons who are blind or visually impaired. Detectable warnings are necessary to insure that persons who are blind or visually impaired are able to detect where the medians and pedestrian refuge islands stops and the street begins.
However, the exception must be deleted. Detectable warnings inform the pedestrian who is blind or visually impaired about the presence of a cut-through island or median. They should be required at all medians and islands. Although the pedestrian may not need to stop at that location when the signal timing is adequate for a full crossing, slower pedestrians may prefer to stop and wait, if they know the refuge exists. In the absence of an APS, blind or visually impaired pedestrians frequently begin crossing during the clearance interval because of the difficulty of determining the exact onset of the walk interval, and the resulting inability to "claim" the crosswalk before vehicles turning across the crosswalk. Hence, these pedestrians may have insufficient time to cross the street. Denying these pedestrians the information that they have a safe refuge constitutes discrimination and endangers the life safety of pedestrians who are blind or visually impaired in such situations. Even in the presence of APS, because they are unable to make eye contact with drivers, pedestrians with visual impairments have difficulty claiming the crosswalk during the walk interval, and may be delayed in starting crossings relative to sighted pedestrians.
In addition, contacting the side edge unexpectedly when traveling within the cut-through section of the median can be disorienting and confusing if pedestrians do not realize they are within a median area. The detectable warning provides the pedestrian with information about the location of the cut-through refuge area.
By requiring that the detectable warning domes be in a line and widely spaced pattern, wheelchair users will be able to wheel across the domes without difficulty.
13. Section 1105.5.3. Overpass and Underpass Approach. Requiring an elevator to provide accessibility where sidewalks cross overpasses and underpasses that create a rise in the sidewalk greater than five feet is essential to insure that people with disabilities will not be barred from using the sidewalks by the difficulty in ascending more than five feet. Most people with mobility disabilities do not have the stamina to ascend more than five feet at a time.
14. Section 1105.6.1. Separation. Requiring a continuous barrier e.g., railing along the street side of the sidewalk where people will be precluded from inadvertently entering the vehicular way in "roundabouts" is one of the essential cues of notifying/guiding persons who are blind and visually impaired where to locate and to make a street crossing. However, it is unclear what a continuous barrier is, except for a railing and should be clarified in this section. Therefore, the CCB recommends the deletion of the word "barriers" and replace it with "landscaping separation or railings" so that the text will read as follows, "Continuous barriers landscaping separation or railings shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited. When railings are used, they shall have a bottom rail 15 inches
15. Section 1105.6.2 Signals. CCB concurs with the Access Board's recommendation that pedestrian activated traffic signals complying with 1106 be provided for each segment of the crosswalk, including splitter island, as indicated in 1105.6.2. When traffic sound cues are absent or unpredictable, information can be insufficient to locate the crosswalk and for determining the onset of the walk interval, especially at a roundabout.
When traffic signals and stop signs regulate traffic movements at intersections, the resulting breaks in traffic flow usually provide identifiable and predictable periods - gaps - during which pedestrians can cross. Such predictable breaks do not usually occur at roundabouts, and so pedestrians must make judgments about the speed and travel paths of approaching vehicles (and the duration of gaps between vehicles). The selection of appropriate gaps at roundabouts is problematic for most persons who are blind or visually impaired.
Traffic sounds at roundabouts can provide ambiguous cues whether circulating vehicles will exit or continue around the circulatory roadway or to know when it is appropriate time to cross.
Therefore, the requirement for the use of accessible pedestrian activated traffic signals at roundabouts appears to be the only feasible means of giving blind and visually impaired pedestrians safe access to the crosswalks at roundabouts, while causing a minimal interference with the flow of traffic on the roundabout. Further, it is important that at these intersections, as well as at those intersections where a pedestrian crosswalk is provided at a right or left turn slip lane, an accessible pedestrian activated traffic signal that complies with 1106 is provided for each segment of the pedestrian crosswalk, including the island.
16. Section 1105.7 Turn Lanes and Intersections. CCB concurs with the Access Board's recommendation that where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island.
17. Section 1106.1 General. The CCB feels it is essential for the safety of persons with disabilities, especially those with visual impairments and/or hearing loss that this section and all its subparts be adopted. Requiring audible and vibrotactile indications of the WALK interval as well as locator tones at signalized intersections provides the same opportunities and safety provided for the general public. Lack of audible/vibrotactile indicators with locator tones where the general public is provided signalized intersections is program access discrimination under title 2 of the ADA and section 504 of the Rehabilitation Act of 1973 because this precludes persons with visual impairments and/or hearing losses from the full and equal use of the public right of way.
Further, we agree with the Access Board that care should be exercised in the location of pedestrian push buttons to insure that, to the maximum extent feasible, push buttons for accessible pedestrian signals will be positioned where they can be located and activated by the pedestrian while leaving sufficient opportunity for the pedestrian to reach the curb in time to respond to the walk interval indication. If the recommended guidelines are followed correctly, the accessible pedestrian signal systems will not be disruptive to the surrounding community. Therefore, we believe their benefits far outweigh the minimal impact they may have on the environment.
We would like to take this opportunity to share with you an unexpected benefit of the use of accessible pedestrian signal systems, which was given to the Sacramento County Disability Compliance Office on Wednesday, July 3, 2002 from Collette Guido, 2251 Watt Ave. #133, Sacramento, CA 95825. Her statement follows:
"-----Original Message-----
From: CGCheapSuit@aol.com [mailto:CGCheapSuit@aol.com]
Sent: Wednesday, July 03, 2002 2:16
To: Bennett. Cheryl
Cc: CGCheapSuit@aol.com
Subject: RE: Disability Advisory Committee Meeting
I am e-mailing my address to the Board on 4/02/02 per Mike Wilkerson's request.
A message to the County Board of Supervisors: I have noticed at Butano St. and Watt Ave. a great improvement to the pedestrians' crossing with the sound of the chirping signal to assist the visually impaired. I live very near this crossing, however, I have a physical impairment, which requires a walker or wheel chair. When crossing I have observed that cars turn neither right or left while a pedestrian is on the crossing walk. As opposed to crossings without the sound, people have ignored myself and husband, still making the turns, during our crossing. I believe we could assist all pedestrians' with the sound of the chirping, it seems to capture the attention of the driver that a pedestrian is crossing and to wait until their all the way across before turning. I hope with all sincerity that we can install these devices to help save all the lives of persons' in our community, whether disabled or not. Thank-You for your consideration, Sincerely, Colette Guido"
We feel these guidelines are reasonably written regarding the manner in which visually impaired individuals should be able to effectively access information about signal phases, as well as street identification and intersection design. It is essential that accessible pedestrian signals convey information in a manner that is unambiguous and we believe these guidelines will accomplish this.
Please refer to the attached CCB Resolution 2001B-5 Accessible Pedestrian Signals Minimum Standards.
18. Section 1106.2 Pedestrian Signal Devices. CCB concurs with the Access Board's recommendation that each crosswalk with pedestrian signal indication shall have a signal device, which includes audible and vibrotactile indications of the WALK interval. Without such a requirement, traffic engineers may decide not to fully equip all crosswalks at an intersection with accessible pedestrian signals based on the idea that it is not worth the investment of money and time for a small segment of the pedestrian population. The result of such action by traffic engineers are the violation of one civil rights to have full and equal access to a program that is available to all other pedestrians, a reduction in safety, and confusion as to where pedestrians can legally cross at an intersection.
Please refer to the attached CCB Resolution 98B-7 Accessible Pedestrian Traffic Signals.
19. Section 1106.2.3 Audible Walk Indication. CCB concurs with the Access Board's recommendation that the audible indication of the WALK interval shall be by voice or tone. We feel the term "voice" clearly indicates that the message must consist of the full pronunciation of all vowels and such consonants as (b), (d), (g), (m), etc. It has been the experience of some of our members that digital speech/synthetic speech does not always provide an accurate reproduction of the full human voice, which results in uncertainty and confusion as to what has been said. The use of "JAWS" or "Window Eyes synthetic speech" is problematic for some persons with hearing loss or auditory perceptional processing learning disabilities because the speech is robotic and does not have all the richness of the human voice, which adds to the intelligibility of the message. On the other hand, the AT&T text to speech messaging capabilities, http://www.naturalvoices.att.com/demos/index.html provides a far superior representation of the human voice, which would be more intelligible to these individuals in the outdoor environment than would be the use of JAWS or Window Eyes synthetic speech. Therefore, it is our opinion until there is a criteria established for digital speech, the term "voice" needs to be used to clearly indicate there is to be accurate reproduction of the human voice contained within any message admitted by an accessible pedestrian signal.
Further, CCB recommends that this section be expanded to include recommendations for speech WALK messages, as well as push button informational message based on the work performed by Bentzen, B., Ph.D., Barlow, J., M.Ed., and Franck, L., M.Ed., Determining Recommended Language for Speech Messages used by Accessible Pedestrian Signals: Final Report, Accessible Design for the Blind, January 7, 2002.
20. Section 1106.2.3.1 Tones. CCB wishes to know what research was the basis for the proposed language, "The duration of the tone shall be 0.15 seconds
21. Section 1106.3.1 Operation. CCB recommends that this section be amended as follows: "Pedestrian pushbuttons shall comply with 309.4. Activation of the pedestrian traffic signal shall simultaneously activate the accessible pedestrian signal." This section needs to clarify that it is required that when a pedestrian signal is activated simultaneously, it is to communicate information about the pedestrian WALK phase in visual and non-visual formats. Not to provide this information simultaneously is program access discrimination under title 2 of the ADA and section 504 of the Rehabilitation Act of 1973 because this precludes persons with visual impairments and/or hearing losses from the full and equal use of the public right of way.
This amendment would ensure that section 1106.3.4 Optional Features can be implemented if the community has a desire for additional information to be provided e.g., street name, description of crossing, etc. by accessible pedestrian signals. If an extended button press is permitted to communicate information about the pedestrian WALK phase in non-visual format, it will preclude additional information to be provided without using a separate device with locator tone, which would add to the cost of making an intersection more accessible.
22. Section 1106.3.2 Locator Tone. CCB concurs with the Access Board's recommendation for the use of locator tone as part of an accessible pedestrian signal. The locator tone alerts the blind or visually impaired pedestrian to the presence of the push button and the location of the corresponding crosswalk. In addition, as the locator tone becomes consistently incorporated into accessible pedestrian signal systems, the blind or visually impaired pedestrian will have the benefit of knowing that further accessible information is forthcoming as a result of his/her long press activation of the push button. Since these tones are only audible at close range, if the recommended guidelines are followed correctly, they will not be disruptive to the surrounding community.
23. Section 1108 Detectable Warning Surfaces. The requirement for detectable warnings at all curb ramps, blended transitions, track crossings, medians/pedestrian refuge islands, and platform edges is strongly supported by the CCB. There is no well-substantiated evidence in research or practice that detectable warning surfaces are barriers to pedestrians. There is, in fact, substantial evidence to the contrary. Research by Hauger, Rigby, Safewright and McAuley (Detectable warning Surfaces at Curb Ramps, Journal of Visual Impairment and Blindness 90:512-525
In the same project, 1,683 pedestrians, many of whom had shopping carts, and two of whom happened to be mobility impaired, were observed at three entrances to retail stores where detectable surfaces had been installed. There were no incidents of trips, slips or falls, and at two of the sites where it was possible to easily avoid traversing the detectable warning surface, only a small percentage of persons did not walk on the detectable warning surface. Those who did not walk on the detectable warning surfaces may have just been going in a slightly different direction to get to their destination by the shortest route. People were observed running and bicycling cross the detectable warning with no apparent concern.
Prior to installation of detectable warnings along Bay Area Rapid Transit (BART) platforms, BART installed detectable warnings at the entrance to a much-used elevator. This was a surface most pedestrians had not previously experienced and could not possibly have expected in such a location. All traffic in and out of the elevator was videotaped over a period of several months without incident or adverse comment (Personal communication, Ralph Weule, BART). Since the installation of detectable warnings on all platforms of BART there have been no individuals or groups who have complained to BART that their travel has been adversely affected by the presence of detectable warnings at platforms edges (Personal communication, Ralph Weule, BART). Furthermore, at locations where riders are transferring from a vehicle to a platform, crossing a small gap, and frequently negotiating a small level change BART's experience has been extremely positive with an approximate 70 % reduction in trackway falls by vision impaired patrons and an approximate 40 % reduction in trackway fall incidents overall, as well as an overall reduction in platform gap falls after detectable warning surfaces were installed (1994 APTA Annual Conference, BART Experience With Platform Edge Detection Tiles By Lee Cohen, Senior Safety Engineer).
In research by Bentzen, Nolin, Easton, Desmarais and Mitchell (Detectable Warnings: Detectability by individuals with visual impairments, and safety and negotiability on slopes for persons with physical impairments, US Department of Transportation, Volpe National Transportation Systems Center. Final Report DOT-VNTSC-FTA-94-4, 1994), 40 participants having a wide range of physical disabilities, who traveled either with no aid, aids having wheels (such as wheelchairs and scooters), or aids having tips (such as canes, crutches and walkers) traveled up and down 10, 4' x 6' ramps having a slope of 1:12
While off-street curb ramps, pedestrian islands, vehicular ways or porte-cochere or similar areas in front of adjacent to existing hotels, motels or restaurants are less highly traveled than the public right of way, and there is numerically less risk to persons who are unable to detect the limit of the pedestrian way. Nonetheless, in these situations persons who are visually impaired are at a high level of risk precisely because of slow moving traffic which does not provide consistent auditory clues regarding the limit of the pedestrian way. In addition, the frequency of backing traffic in such locations, typically automobiles which do not have an alerting backing up tone, makes traffic especially unpredictable to persons who are visually impaired who either by accident or by intent to cross the vehicular way, are in the vehicular way. Competent blind travelers, normally needing no assistance to cross most streets, driveways and track crossings, should not be subjected to the choice of facing exceptional risk or seeking, waiting for, and accepting help which they would not need if detectable warnings were provided to define the limit of the pedestrian way.
24. Section 1108.1.1 Dome Size. CCB feels the proposed standard allows too much latitude in the dimensions of the truncated domes. We feel a more definitive standard is essential to ensure the consistency/standardization of detectable warning truncated domes, which is needed for optimum underfoot detection.
We would like to propose substituting this section with the following language, "The detectable warning surface shall consist of a durable, slip-resistant material, having a surface texture composed of raised truncated domes aligned in a square grid pattern with a diameter of 0.9 inches
For many years these dimensions have been in use in Japan, United States, the State of California, and experience to date indicates that surfaces comprised of domes having .9 inch
Our concern is by requiring dome dimensions of having a base diameter of up to a maximum 1.4 inches
The additional specification we are proposing for measuring the truncated dome height is to ensure that a height of 0.2 inches
We would like to stress that uniformity and consistency are critical for an effective detectable warning surface. Therefore, it is crucial that strict language that specifies all dome size dimensions must be incorporated in this section and any associated figure to ensure that effective detectable warning surfaces are installed in the environment.
Please refer to the attached Resolution 2000B-7 Detectable Warning Specifications.
25. Section 1108.1.3 Contrast. We agree with this section and feel this section needs to be amended to require that there be at least a 70 percent contrast between the detectable warning surface and the adjoining walking surface. This Specification for at least a 70 percent contrast will ensure that the detectable warning surface is seen by all and from a distance.
Also, we would like to see this section to be amended to require that "the detectable warning surface be the color yellow conforming to Federal Color No. 33538, as shown in Table IV of Standard No. 595B. Where the color value contrast between the yellow warning and the main walking surface is less than 70 percent, a 2 inch-wide (50 mm) black strip shall separate the yellow warning from the main walking surface. Contrast shall be determined by: Contrast = [(B1-B2/B1)] 100 percent where B1 = light reflectance value (LRV) of the lighter area and B2 = light reflectance value (LRV) of the darker area." This color of yellow has been specified by the city of Roseville, California, the city of Sacramento, California, and the county of Sacramento for the detectable warning surfaces that they have installed within the last four years without any complaints regarding the ecstatic of the color.
There are several reasons for this choice of color. Physiologically, yellow is at the peak of the human photopic luminosity function, and thus is the color that appears brightest to the human eye. Yellow is quite distinctive in its color appearance, so that it is easily recognized. When used as a cautionary floor or other walking surface, yellow is likely to be distinct and easily differentiated from its immediate background. This is because yellow or colors close to it are rarely used for floors and other walking surfaces. Alternative warning markings, such as black or white, are more likely to loose conspicuousness against certain commonplace backgrounds, as walking surfaces are most commonly of neutral colors. Safety yellow is an unusual color to encounter in one's environment and almost invariably denotes risk and the need for caution.
The American National Standards Institute defines safety yellow as "the color for the identification of CAUTION" and that it should be used for "marking physical hazards which might result in: striking against, stumbling, falling, tripping, or being caught in-between" (ANSI Z535.1-1991, 6.3). The International Organization for Standardization states that yellow denotes "Caution, risk of danger . . . indications of dangers," (ISO 3864-1984(E), 5.1).
In research by Bentzen, Nolin, and Easton (Detectable Warning Surfaces: Color, Contrast, and Reflectance, US Department of Transportation. Final Report September 1994) report, "Subjective preference for the two contrasts in which the detectable warning was safety yellow (Pantone 109u), despite the relatively low value of those contrasts (40% and 62%), suggests that this color was more salient to persons with low vision than the other colors tested. While this research does not reveal the reason for the subjective superiority of safety yellow, its strong preferability, coupled with its high objective detectability even in contrasts as low as 40%, indicate that specification of safety yellow (ISO 3864) for detectable warnings could result in excellent visual detectability, as well as providing a standard color which already has international recognition for warnings."
Thus choosing safety yellow for detectable warnings is in conformance with existing national and international standards. The use of safety yellow results in warnings which are universally recognized and which are reliably visually detectable and highly salient to people having low vision.
Please refer to the attached Resolution 2000B-7 Detectable Warning Specifications.
26. Section 1108.1.4 Size. The CCB wishes to have the 24 inch
Research has been conducted which addresses concerns about safety of detectable warnings, indicating that detectable warning on slopes and on generally horizontal surfaces have minimal impact on the safety and ease of travel for persons having physical disabilities (Bentzen, B., Nolin, T., Easton, R., Desmaris, P., and Mitchell, P., 1994; Hauger, et al, 1996).
Research has found that persons who are blind more reliably detected detectable warnings at 30 inches
Consistency in depth of detectable warnings promotes consistent interpretation. Blind pedestrians in any setting of the US should know that when they encounter a detectable warning, they need to stop immediately and check it out, as there is a vehicular or falling hazard immediately ahead. There is very minimal stopping distance.
The deeper the detectable warning, the greater the possible adverse effect on persons with mobility impairments, and the greater the expense of installation and maintenance. Therefore, the depth of 36 inches
Permitting the depth of detectable warnings to be 36 inches
Please refer to the attached Resolution 2000B-7 Detectable Warning Specifications.
27. Section 1108.2.2 Rail Crossings. The CCB supports this section and feels that an exception needs to be added to address rail crossings that have automatic gates.
We propose the following language, "Exception: Where automatic gates across pedestrian ways bar pedestrian access to the crossing when rail vehicles are approaching or at a crossing, the detectable warning surface shall be located to the side of the automatic gate farthest from the crossing."
Automatic gates can cause serious head injury to pedestrians who are blind or visually impaired when approaching crossings. There is currently no reliable way for pedestrians who are blind to be notified of the location of automatic gates. Gate support is typically outside the normal pedestrian route and not likely to be encountered by blind pedestrians. Where there is a gate, a blind pedestrian may become trapped between the gate and the crossing, with the gate barring the way for the blind pedestrian to move farther away from the crossing.
28. Sections 1111.4 and 1111.6. Barricades. It is essential for the safety of persons with disabilities, especially those with visual impairments, that the proposed guidelines require a solid wall or fence for barricades to separate the sidewalk from adjacent construction sites, drop-offs, openings and other hazards, as proposed. These barricades will avoid someone from rolling, walking, tripping or falling into a hazardous construction area.
Recommended Topics to be added to these proposed Guidelines
1. Recommended section 11XX Curb and Gutter. The CCB feels very strongly that a section regarding the type of curbs that are to be used in new construction and alterations development must be addressed in these guidelines. Our preference is that type 2 curbs be used for all developments regardless of their zoning, street width, or intersection width. Type 2 curbs provide a greater degree of safety and access along sidewalks, the radius of corners, and bus stops for all pedestrians, including those with disabilities. The type 2 curb provides the following benefits over the use of the type 1 and 1A curbs:
a) They discourage motor vehicles from cutting corners and possibly striking a pedestrian wanting to make a crossing.
b) They provide a more effective orientation cue, which a blind or visually impaired pedestrian can use to align him or herself when crossing a vehicular way.
c) They add to the detectability of gradually sloped flared sides of curb ramps.
d) They discourage the parking of motorized vehicles on or across sidewalks, which can be a potential hazard to persons who are blind or visually impaired and a physical barrier to the pedestrian access route for persons with mobility limitations.
e) They reduce the horizontal and vertical gaps that must be bridged by a person alighting a transit vehicle from a bus stop pad.
However, we do acknowledge there may be construction and financial reasons e.g. the placement of a driveway that requires the use of type 1 curb in single family residential developments, which necessitate their use and the use of type 1A in other locations. Therefore, with grade reluctants, we are proposing the limited use of type 1 and 1A curbs in addition to type 2 in
"Curb and gutter shall be installed adjacent to all developments as follows:
A. Type 1A Curb and Gutter: All developments and all locations not included in B through D below, or as required by the Director of the state or local Department of Transportation.
B. Type 1 Curb and Gutter: 40 foot
C. Type 2 Curb and Gutter: Frontage roads; parks; unfenced schools; open space areas; public facilities; 40-foot, 50-foot, 56-foot, 60-foot, 66-foot, 74-foot, 84-foot, 108-foot, and 130-foot streets with commercial, industrial, and multi-family (not duplex) developments.
D. Type 2 Curb and Gutter: Within the curb return areas of all intersections regardless of their width, and at all bus turnouts, bus stops, bays, or other areas where a lift or ramp is to be deployed.
E. Type 2 Curb and Gutter: Locations on 40-foot, 50-foot, 56-foot, 60-foot, 66-foot, 74-foot, 84-foot, 108-foot, and 130-foot streets where the sidewalk is separated from the curb by lawn or approved landscaping."
Please refer to the attached CCB Resolution 96B-8.
2. Recommended section 11XY Separation of Sidewalks from Bicycle Lanes. The CCB recommends these guidelines to include a section, which requires that whenever a road or bridge is constructed or reconstructed in a public right-of-way in an urbanized area that a sidewalk shall be constructed unless technically infeasible, which is physically separated from a bicycle lane and/or roadway. Many of our members have had the unfortunate and dangerous experience of having to share the public right-of-way with bicyclists when state or local Department of Transportation has deemed as a cost saving solution to place both modes of transportation within the same facility e.g., bicycle lane. What have frequently occurred in a shared facility are conflicts between fast moving bicyclists with pedestrians, which often results in non-reported injuries unless there is a fatality. These conflicts are less avoidable when the pedestrian has a disability that prevents them from seeing, hearing, or moving in response to an approaching bicycle, especially if it is coming from behind them.
We strongly believe that both pedestrians and bicyclists are entitled to their fair share of the public right-of-way, which consists of separate facilities for each and that these facilities be separated from the roadway so to ensure greater safety and access for each.
Please refer to the attached CCB Resolution 2001B-09 Installation of Sidewalks and Their Separation from Bicycle Lanes.
We are proposing that the Public Rights-of-way Access Advisory Committee be convened to consider these two recommendations so that they can be included in the next release of these guidelines.
Thank you for your time and consideration to the California Council of the Blind, Inc.'s comments, amendments, and recommendations.
Respectfully submitted,
Eugene Lozano, Jr., Chair
Committee on Access and transportation
California Council of the Blind
CITY OF ABILENE
Dear Sirs:
Attached are comments on Draft Guidelines for Accessible Public Rights-Of-Way, June 14, 2002. These comments are made on the basis of my position with the City of Abilene.
I am currently the Traffic & Transportation Administrator for the City of Abilene. I have been employed by the City of Abilene for 24 years in several different professional positions in Traffic Engineering and Public Works. I served on the City's team that prepared our Transition Plan for implementing the Americans With Disabilities Act in the early 1990's. I hold a Bachelor of Science degree in Civil Engineering and a Master of Engineering degree in Civil Engineering from Texas A&M.
Thank you for the opportunity to provide these comments.
Sincerely,
James Condry
Traffic and Transportation Administrator
COMMENTS ON DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS OF WAY
JUNE 14, 2002
In Section 1101.3, revise the definition of the term "sidewalk".
The definition is too broad because it includes any improvement for use by pedestrians. There are some improvements to the right-of-way that facilitate use by pedestrians that should not be included in the definition of a sidewalk. The following are some examples of such improvements that have been constructed by the City of Abilene: grading of rough or steeply sloped sections of the right-of- way to produce a "level" and "smooth" surface for pedestrians and constructing base material shoulder. Also, the City of Abilene allows property owners to pave the parkway (right-of-way between the curb or edge of pavement and the property line). This is often done by business owners so that they do not have to maintain the parkway. It produces a surface that is firm and relatively smooth although not usually flat. It is a better walking surface for pedestrians than bare ground; however, it is not constructed for that purpose and it is not a sidewalk in the normal understanding of the term.
The general concept of a sidewalk is that it is a hard surface (portland cement concrete, asphaltic concrete, brick, concrete payers, etc.) path constructed for use by pedestrians and sometimes bicycles. A path for pedestrians constructed of gravel, crushed rock, or other aggregates does not constitute a sidewalk. An improved earthen path, i.e., level and smooth or even compacted, is also not a sidewalk.
The following is a recommended definition for sidewalk:
Sidewalk. A path with a firm, stable surface constructed for use by pedestrians within that portion of a public right-of-way between the curb line or lateral line of a roadway and the adjacent property line.
2. In Section 1101.3, revise the definitions of "channeling island" and "splitter island".
The definition of a channelizing island needs to be more robust and should incorporate the key concepts from the AASHTO design guidelines. Since a splitter island is a channelizing island that is used at a roundabout (see definition of roundabout), the splitter island definition can reference the channelizing island definition.
The following definitions are recommended:
Channelizing Island. At an intersection, the area defined by curbs, pavement markings, or unpaved areas formed by pavement edges for the purpose of directing traffic into defined paths, providing refuge areas for pedestrians or providing locations for traffic control devices.
Splitter Island. A channelizing island that separates entering and exiting traffic at a roundabout.
3. In Section 1101.3, revise the definition of "crosswalk".
The portion referencing the point of measurement is confusing. It is also unnecessary. The only measurements associated with a crosswalk, i.e., the 48- inch
Where there is sidewalk on only one side of the street, the requirement for the crosswalk to be at right angles to the street being crossed creates problems when streets intersect at other than right angles. In that situation, pedestrians will cross parallel to the street that intersects the street being crossed. This is the normal location for a crosswalk. If the intersection angle is significantly different than 90°, the requirement for the crosswalk to be at right angles to the center line of the street being crossed will result in the two types of problem situations shown in the attached Figure A. The sidewalk in the northwest corner would project into the intersection. The sidewalk in the southwest corner would project to the opposite curb at a considerable distance from the intersection.
The issue of directing pedestrians into the crosswalk can be handled in the same manner as cut-throughs in medians and refuge islands (Section 1105.4). That is, require the edges of the ramp or landing to be aligned with the direction of the crosswalk for a length of 24 inches
The following is a recommended definition of a crosswalk:
Crosswalk. Any portion of a roadway at an intersection or elsewhere that is distinctly indicated for pedestrian crossing by lines or other markings on the surface; that part of a roadway at an intersection that is included within the extensions of the lateral lines of the sidewalks on opposite sides of the roadway; or in the absence of a sidewalk on one side of the roadway, the part of the roadway included within the extension of the lateral lines of the sidewalk parallel to the street that intersects the street being crossed.
4. In Section 1101.3, add a definition for "blended transition".
The guidelines do not have sufficient information for an clear understanding of the term "blended transition". The supporting material indicates that it is an alteration in grade to the sidewalk and/or the pavement that produces a situation where some portion of the curb return is flush with the pavement at the crosswalk. It also appears that only the flat (1:48 slope maximum) portion that abuts the edge of pavement is the "blended transition", while the portion connecting to the sidewalk is either ramps or a curb ramps.
If these discernments are correct, then the following is recommended definition for a blended transition. If these discernments are not correct, then obliviously a different definition is needed.
Blended Transition. A portion of sidewalk at the intersection curb radius that is flush with the abutting pavement and that is created by altering the grade of the sidewalk and/or the pavement.
5. In Section 1101.3, add a definition for "slip lanes".
The term "slip lane" is not used in this part of the country and the term is not used in the AASHTO Policy on Geometric Design. The term appears to refer to some type(s) of exclusive use turn lanes. Exclusive use turn lanes are used to increase capacity and/or to improve safety of traffic operations at intersections. The operational characteristics are influenced primarily by two key elements: the method used to separate the turn lanes from the adjacent through lane and the type of control used.
For right turn only lanes, the following methods are used to separate the turn lane from the adjacent through lane in Abilene.
. Single solid lane line.
. Small channelizing island of pavement markings, typically about three to five feet wide at the crosswalk.
. Small raised channelizing island, typically about three to five feet wide at the crosswalk.
. A corner island about 10 to 15 feet
. A large corner island about 50 feet
For right turn only lanes, the following are some forms of control used in Abilene.
. Signal control of through lanes with signal control of turn lane.
. Signal control of through lanes with yield control of turn lane.
. Stop control of through lanes with stop control of turn lane.
. Stop control of through lanes with yield control of turn lane.
. No control of through lanes and no control of turn lane.
It is not clear from the guidelines if the term slip lane refers to all exclusive use turn lanes or if it is a special type of exclusive use turn lane. If it is a special type, then the characteristics (geometric and/or control) that distinguish it from exclusive use turn lanes in general need to be clearly defined.
6. In Section 1102.1, insert the following statement:
These guidelines do not require the provision of sidewalks, street crossings, street furniture, parking, or other pedestrian elements where none are intended. These guidelines address such elements only where they are provided as part of construction or improvement projects.
7. Section 1102.2 refers to "existing public rights-of-way". However, based upon the context, including the Section 1102.1 reference to "facilities in public rights-of way", Section 1102.2 is actually referring to "existing facilities in public rights-of way". To correct this, insert the words "facilities in" between the words "existing" and "public" in the following locations:
. Title of Section 1102.2
. First sentence of Section 1102.2
. Second sentence of Section 1102.2
. First sentence of Section 1102.2.1
8. Section 1102.3, requires an alternate circulation path to be provided whenever the existing pedestrian access route is blocked. This requirement is excessive.
Construction, alternation, and maintenance can result in blocking both vehicular and pedestrian paths. In an urban environment, a specific alternative path for vehicles (a detour) or for pedestrians is often not provided. Where streets with sidewalks are in a closely spaced grid, alternative paths exist, It is usually more practical for short duration activities (up to several days) to allow motorists and pedestrians to find their own alternative paths than to try to direct them to a specific route. For example, recently the City of Abilene allowed full closure of one block of a street in the downtown area for several days due to a short duration construction activity (the erection of steel on a building adjacent). The street was closed to vehicle use and the sidewalks were closed to pedestrian activity. Given the closely spaced grid street pattern and the short duration of the project, signing of a detour for vehicles was not required and creation of a pedestrian path through the site was not required. Under the guidelines, an "alternate circulation path" would have been required because the existing pedestrian access route was blocked. However, it was not practical to provide a specific alternative path for pedestrians through or adjacent to the site.
The provision for an alternate circulation route should take into account factors other than the fact that a pedestrian access route is blocked, just as the MUTCD does in Part 6 relative to construction and maintenance activities. Factors to consider are the duration of the temporary conditions and the availability of existing alternative routes in the vicinity. An alternate circulation path in compliance with the guidelines should only be required if an alternate circulation path is provided for non-ADA pedestrians.
9. In Section 1102.5, correct the last phrase to read "pedestrian access routes" instead of "pedestrian accessible routes".
10. In Section 1102.5.2, the second sentence is not clear. The 12-inch dimension is not related to a specific element such as height or width or distance between poles. A similar situation is addressed in Section 307.2. There the phrase "and the clear distance between posts and pylons" precedes "...is greater than 12 inches
11. The requirements of Sections 1102.5.1, 1102.5.2, and 1102.5.3 are covered in
Sections 307.2, 307.3, and 307.4. Therefore, Sections 1102.5.1, 1102.5.2, and
1102.5.3 should be deleted and in Section 1102.5 reference should be made to
Sections 307.2, 307.3, and 307.4. The reference to other sections of the ADAAG
instead of repeating them is used throughout the Accessible Public Rights of
Way guidelines.
12. In Section 1102.14, the phrase "where on-street parking is provided" is too vague. If it refers only to locations where parking spaces are marked on the street, then it should state: "where on-street parking is marked on the street". If it includes locations where on-street parking is allowed even though it is not marked, then it should state: "where on-street parking is allowed on the street
13. In Section 1102.14, the requirement for accessible on-street parking should only apply to locations where parking spaces are marked (or designated) on the street. Requiring accessible on-street parking where on-street parking is allowed but not marked is excessive. For example, most residential streets in Abilene are 36 to 40 feet
14. In Section 1102.14, the requirement for one accessible space per block face is excessive.
The number of parking spaces in a block face can vary greatly due to length of block face, size and number of driveways, and the orientation (angle) of the parking. For example in the downtown area of Abilene, there are 99 block faces on which on-street parking spaces are marked. The number of spaces per block face ranges from 2 to 16 with an average of 9. Converting one non-accessible space per block face to an accessible space to meet the requirement of one per block face would result in 6% to 50% of the total spaces for a given block face being accessible. The total number of marked spaces is 881. At one accessible space per block face the resulting 99 accessible spaces would be 11 % of the total spaces. The true impact is even greater, since typically a second parking space is lost when a parking space is converted to accessible because an adjacent space is converted to the access aisle.
In Texas, parking spaces designated for the disabled with the international symbol (as required for accessible spaces) can only be used by properly designated vehicles transporting persons with disabilities. Vehicles meeting this requirement do not constitute 11 % of the vehicles that park on-street. Also, persons with disabilities may park in spaces that are not designated for the disabled (and they do so if they do not need the access aisle next to them, e.g., someone with a breathing disability that limits their walking distance).
A different requirement for on-street accessible spaces is needed. One alternative is to require an accessible space for each block face except for block faces with a small number of marked parking spaces, e.g., a block face with less than 20 spaces. Another alternative is to require one space for each pair of adjacent block faces. A third alternative is to require one accessible space for every X spaces, e.g., 25 or 50, along contiguous block faces.
The following is a recommended replacement for Section 1102.14:
1102.14 On-Street Parking. Where on-street parking is marked on the pavement, a minimum of one accessible on-street parking space shall be provided for each pair of adjacent block faces but not less than one accessible space for each 50 on-street parking spaces. Accessible on- street parking spaces shall comply with 1109.
15. Section 1104 only address perpendicular curb ramps, parallel curb ramps, and blended transitions.
The titles and descriptions of perpendicular curb ramps and parallel curb ramps imply that these are to be placed within a straight section of the street curb. Therefore, it is presumed that diagonal and corner type curb ramps are not allowed. If perpendicular and parallel curb ramps can only be placed in sections of straight curb, i.e., not within the curb return, then this could place them at an unacceptable distance from the intersecting street where there are large curb returns.
The use of the diagonal and corner type ramps should not be precluded. In Abilene, typical intersection curb return radii are 20 to 25 feet
16. Section 1104.2.3. on blended transitions has only the requirement for slope and for compliance with the common elements in Section 1104.3. In the drawing of a blended transition in the supplemental information, it appears to be similar to the landing associated with the parallel curb ramp. If that is true, then there should be a requirement that the blended transition be large enough to contain a square of 48 inch by 48 inch
17. In Section 1104.3.7, the following elements concerning the required "clear space" are unclear.
a. The clear space is required to be "beyond the curb line". If this means within the pavement area of the street, then the requirement should be stated as such.
b. The clear space is required to be "outside the parallel vehicle travel lane". It is not clear to what the vehicle travel lane is to be parallel. This reference could be to the street parallel to the crosswalk or to the street parallel to the curb line being crossed.
c. If the clear space is indeed on the pavement side of the curb lines, the rationale for such a requirement is unclear. It would be safer to have the clear space on the sidewalk side of the curb line. If the clear space is on the sidewalk side of the curb line, then it appears that it could be the same area as the landing at the bottom of a parallel curb ramp on even a portion of the blended transition.
18. Section 1105.3 uses the term "pedestrian signal phase timing". However, what is being described is what the MUTCD refers to as the "pedestrian signal clearance time". Since the MUTCD is the official document related to traffic signals (and other traffic control devices), the term should be changed to "pedestrian signal clearance time" to make it consistent with the MUTCD
19. Section 1105.3 requires the pedestrian signal clearance time to be based upon a pedestrian walk speed of 3.0 feet
The MUTCD currently uses a pedestrian walk speed of 4.0 feet
The following is a recommended replacement for the first sentence of Section
1105.3:
At signal locations with pedestrian access routes, the pedestrian signal clearance time shall be calculated using a pedestrian walk speed of 3.5 feet
20. Section 1105.3 requires calculation of pedestrian signal clearance time to be based upon the entire length of the crosswalk plus the length of the curb ramp. The MUTCD currently recommends that the pedestrian clearance time be sufficient for pedestrians to travel the distance from the curb to the middle of the farthest traffic lane. Basing the pedestrian clearance on the total crosswalk distance within the street is not unreasonable, although the MUTCD recommendation is sufficient for many situations. However, requiring the inclusion of the curb ramp length in the distance for calculating pedestrian clearance time is unnecessary and can be excessive if the ramps are long. Also for parallel curb ramps, there is a landing before the ramp begins.
21. Section 1105.6.2 requires pedestrian signals for crosswalks at roundabouts. This is an unreasonable requirement.
Roundabouts are intersections that by design are intended to operate without the need for a traffic signal for vehicular control. The very nature of a roundabout makes installing signal control for vehicles at a roundabout unreasonable. Although signal control for entering vehicles can be reasonably accomplished, signal control for exiting traffic is impractical. This is due to several factors including: the need for visibility of the signal heads for the controlled movement and the lack of storage space for stopped vehicles within the roundabout.
The features that make roundabouts a desirable form of intersection control for vehicular traffic can pose a problem for pedestrians. Instead of crossing the traffic lanes near the circular portion of the roundabout, it would be safer to have pedestrian crossings of the approach/departure roadways at a distance from the roundabout. Although it results in a longer distance for pedestrians, this "mid block" location provides improved visibility of the crossing location for the motorist.
22. Section 1105.7 requires pedestrian signals for crosswalks crossing right or left turn slip lanes. Because there is no definition of a slip lane, it is difficult to comment on all aspects of this requirement. However, the following issues can be addressed.
This requirement makes no distinction between right and left turn lanes at signalized intersections and those at non-signalized intersections. Therefore, this requirement would force the signalization of intersections that otherwise would not need a signal and which do not meet the signal warrants of the MUTCD This is an unreasonable requirement.
The geometric design of some exclusive use turn lanes is such that signalizing them will be difficult, similar to the problems associated with signalizing roundabouts.
23. In Section 1111.3, the alternate circulation path is required to be parallel and on the same side of the street as the disrupted pedestrian access route. The requirement to be the same side of the street is often impractical, if not impossible.
For example, assume that a construction project occupies the parkway and the adjacent parking lane of a street, and as a result, a pedestrian access path in the parkway is blocked. It is more practical and safer to provide the alternative circulation path on the other side of the street than it is to shift traffic lanes over to create an alternate circulation path between the construction and the traffic lanes.
This portion of the requirement, i.e., "on the same side of the street", should be deleted.
24. The term "barrier" is used in Section 1104.2.2.4 and Section 1105.6.1. No information is given relative to what constitutes an acceptable barrier. If the barriers in Section 405.9.2 that serve as edge protection for ramps are acceptable barriers, then these should be referenced. If these are not acceptable, then the parameters of acceptable barriers must be given.
James Condry
Traffic & Transportation Administrator
City of Abilene
Steven R. Schooley, P.E., PTOE, October 22, 2002
KANSAS ASSOCIATION for UNIFORM TRAFFIC CONTROL [PDF Version]
Dear Access Board Members:
The Kansas Association for Uniform Traffic Control (KAUTC) is a diverse organization made up of city, state, county and federal traffic engineers and technicians as well as consultants, educators and vendors from the traffic engineering fields. Many of our members have reviewed in detail the draft guidelines and have expressed opinions about the difficulties involved in meeting the guidelines as well as the problems that will be created if the guidelines are followed. We have encouraged our members to prepare their own response to these guidelines. As an organization it would be difficult to prepare a unified response on every item, but we certainly all agree that the proposed guidelines need to be carefully reviewed and several of the proposed requirements would be too costly and difficult to implement. Please carefully review the comments received and take into consideration the costs, benefits and possible unintended consequences of each of the proposed recommendations. We want to develop a transportation system that serves all the public, but it must be reasonable and economically feasible.
Sincerely,
KANSAS ASSOCIATION FOR UNIFORM TRAFFIC CONTROL
Steven R. Schooley, P.E., PTOE
KAUTC, Past President
Cc: KAUTC Executive Board
October 25, 2002
Re: Draft Rights-of-Way Guidelines [PDF Version]
Dear Access Board Members:
The City of Lenexa Transportation Division of Public Works has reviewed the proposed guidelines and has prepared the following comments. I would like to express that the City of Lenexa certainly supports providing facilities to be accessible for all people. We do however have concerns with many of the proposed requirements as they will have unintended consequences, will be excessively costly and we believe are unnecessary to provide an accessible community.
These comments have been prepared with the section referenced from the proposed guidelines in bold followed by the requirement or statement from the guidelines in italics then our comments in normal text following.
---- Comments----
Defined Terms - Crosswalk - Crosswalk is defined to include "in the absence of a sidewalk on one side of the roadway"
This would seem to imply that all the requirements of a crosswalk would be appropriate whether or not a sidewalk is present, or whether or not the intersection is intended for use by pedestrians. Many roadways are designed to prohibit pedestrians (e.g.: freeways, highways and rural roadways) and the implication that crosswalks exist on these roadways is not appropriate.
Defined Terms - Pedestrian Access Route - An accessible corridor for pedestrian use within the public right-of-way.
This seems to imply that pedestrian access routes should be provided in all public rights-of-ways. Some public rights-of-ways are not intended for use by any pedestrians. These public rights-of-ways should not be subject to the requirements to provide an accessible route.
Section 1102.2.2 Existing Public Right-of-Way - Alterations - All alterations are required to meet the current standard except where "technically infeasible"
This provision may make maintenance and rehab work much more costly. For example a simple sidewalk replacement may require the purchase of additional right-of-way, additional grading and maybe even retaining walls to meet the current standard. This might be "technically feasible" but would not be very practical nor economically reasonable. "Technically infeasible" needs a clearer definition and could result in projects not being "altered" or repaired due to the unreasonably high cost of compliance with current standards.
Section 1102.3 Alternate Circulation Path - An alternate pedestrian circulation path shall be provided through construction areas.
The discussion on this section indicates that the alternate path must be on the same side of the street as the disrupted sidewalk. This may not be feasible in some instances. It should be possible to re-direct pedestrians to the other side of the street, or to another reasonably accessible alternate path. Costs and volume of pedestrians should be appropriate factors to consider when making this decision.
Section 1102.5 Protruding Objects - Objects shall not protrude more than 4"into the circulation path.
It appears that this requirement would prohibit drinking fountains, telephones, call boxes, pole mounted traffic signal, street light control boxes, signs, etc. This would make it difficult to construct projects with limited space and appears to preclude the use of devices that would be beneficial to pedestrians.
Section 1102.7.2 Pedestrian Signs - Informational Signs and Warning Signs - Informational signs and warning signs for pedestrians shall comply with 703.5.
Section 703.5 defines Braille signs. This would not be practical for all pedestrian signs. Some signs are placed to be read from long distances and some are primarily for the motorists. Many signs cannot be reached by blind persons, and it would not be practical to place them where blind pedestrians could read them. This requirement may result in signs being placed at inappropriate locations and result in unsafe applications.
Section 1102.13 Bus Stop - shall comply with 810.2 and 810.3
Cannot find these sections. They do not exist in the document available on the Internet.
Section 1102.14 On-Street Parking - On-street parking should have one handicap space per block face.
An all-inclusive statement requiring one handicap space per block face is unreasonable. Most of the locations where on-street parking is permitted are in residential areas. Most locations are sparsely used and homeowners park in front of their home. In these residential areas it is unreasonable to mark any handicap spaces, unless requested by the adjacent homeowner.
In commercial areas one space per block may be too many if there are only two or three parking spaces on each block. At other locations where there may be 50 or more parking spaces along a block it may be necessary to provide several handicap parking spaces. Also it may depend on the availability of off-street parking spaces. Some areas provide ample convenient off-street parking spaces with reasonable accommodations for handicap parking; while in other areas the off-street parking is less convenient and difficult to access. In the latter condition it may be necessary to provide several on-street handicap parking space to serve the adjacent businesses.
Section 1103.5 Pedestrian Access Route - Grade - Grade of the pedestrian access route shall not exceed the grade established for the adjacent roadway except if it is less than 1:20
Section 405 requires the use of handrails and extended floor or ground surface or guard curb or barrier. Should this be required on sidewalks? The discussion on pedestrian access route, however, indicates that handrails will not be required. This should be clarified. It does not seem reasonable to provide handrails and extended floor or ground surface or guard curb or barrier for sidewalks.
Section 1103.8 Pedestrian Access Route - Changes in level- Changes in level shall comply with 303.
Section 303.4 indicates that changes in level greater than ½ inch shall be ramped and comply with 405 or 406. Section 405 indicates that handrails and extended floor or ground surface or guard curb or barrier are required on the ramp if the grade change is greater than 6". This would imply that handrails and extended floor or ground surface or guard curb or barrier are require on changes in grade level greater than 6". This does not seem appropriate on sidewalks.
Section 1104 Curb Ramps and Blended Transitions - In
Two separate ramps at intersections with large radii could create some unintended consequences. This would force the ramps to be located further away from the intersection placing the crossing for pedestrians further away from the intersection. This is not where drivers are looking for pedestrians to cross. Also the crosswalk and related stop bar would be further from the intersection. When the stop bar and crosswalk are too far from the intersection drivers tend to encroach into the crosswalk thereby blocking the pedestrians path. Also as vehicles attempt to make right-turns on red with the stop bar too far back may have to maneuver well into the crosswalk area to see oncoming traffic. Finally the further back from the intersection the stop bar is located the longer clearance time is required for the signal operation and motorists would experience greater delays.
At intersections with small radii (30' or less) separate curb ramps would work well and provide better operation, however at intersections with large radii (50' or more) a single ramp typically works best.
Section 1104.3.2 Curb Ramps and Blended Transitions - Detectable Warnings - Detectable warnings shall be provided, where curb ramps, landing or blended transition connects to a crosswalk.
It will be difficult to remove snow and ice from detectable warnings. Snow and ice accumulated in detectable warnings is potentially unsafe for all pedestrians.
Section 1105.2.1 Crosswalk - Width - Crosswalks shall be 96 inches
This is in conflict with the MUTCD, which only requires crosswalks to be a minimum of 6' wide. In many locations where pedestrian volumes are low 6' should be more than adequate. Wider crosswalks create larger intersection areas and are generally undesirable when not needed.
Section 1105.2.2 Crosswalk - Cross Slope - The cross slope shall not exceed 1:48
This standard would require a "table" to be created at every intersection where the grade of the road exceeds 1:48
Section 1105.2.3 Crosswalks - Running Slope - The running slope shall not exceed 1:20
Same comment as above. Also this could be a problem with roadways that are super elevated where the cross slope of the roadway might be 7-8%, which would exceed the required minimum of 5%.
Section 1105.3 Pedestrian Signal Phase Timing - The pedestrian walk speed shall be 3.0 ft/sec. And the crossing length should include the length of the curb ramp.
This is an unreasonable requirement. Currently the requirements in the MUTCD indicate that the walking speed should be 4.0 ft/sec and allow the pedestrian to get to the far side of the traveled way (currently proposed with revision 2). Adding the entire length of the crosswalk plus the curb ramp could add 15 to 20 feet
Excessive pedestrian clearance times may also tend to encourage pedestrians to attempt to start to cross during the clearance time as they see that the timing is excessive for normal crossing. This will lead to disrespect for the signal indications, more violations by pedestrians, and reduce safety.
Section 1105.4 Medians and Pedestrian Refuge Islands - The width is not mentioned.
Should the width be 48 inches
Section 1105.5.3 Pedestrian Overpasses and Underpasses - Approach - Where the rise exceeds 60 inches
The advisory committee has asked for input on the minimum height where an elevator would be required. The requirement to install an elevator should not only be based on the height, but also on the volume of pedestrians and in association with the needs of the disabled community. It seems unreasonable to install an elevator that might only be needed once a week or once a month (this is assuming that there is another alternate pedestrian access route). On the other hand an elevator that is used several times an hour might be appropriately justified.
The cost of a pedestrian overpass is often times difficult for a community to justify. The extra cost required to install, operate and maintain an elevator would likely prohibit many new installations or alterations to existing facilities.
Section 1105.6.1 Roundabouts - Separation - Continuous barriers are required along the street side of the sidewalk where pedestrian crossing is prohibited.
The advisory committee indicates that this is to keep visually impaired pedestrians from inadvertently entering the roundabout. This is excessive and unreasonable. The edge of the sidewalk and the curbing on the road should be clear indications that pedestrians are not to walk into the roundabout.
Section 1105.6.2 Roundabouts - Signals - Signals are required at each pedestrian crossing location in a roundabout.
The requirement to signalize the pedestrian crossings at roundabouts is unreasonable. It appears from the discussion that the advisory committee feels that roundabouts are unsafe for pedestrians. There is no documented proof, that we are aware of, that indicates roundabouts are unsafe for pedestrians. Roundabouts are a good form of traffic control that has been used for many years successfully in other countries. The experience in the U.S. has been tainted by poor designs of circular intersections in the early years of transportation development. These rotary intersections have serious operational problems, which have resulted in a reluctance to consider circular intersections. Modern roundabouts are considerably different and at the right location may be a good, safe and efficient alternative to standard signalized intersections.
There also seems to be a misunderstanding that standard signalized intersections are in some way "safe" for pedestrians. When in-fact pedestrians are exposed to very real hazards at a signalized intersection as they cross the street, even in a marked crosswalk with pedestrian signal indications. The hazards include right-turns on red, right turns, left-turns that are permitted during the circular green phase and possible violations of the red light. Left-turn movements during the green ball, while pedestrians are in the parallel crosswalk to the left can be particularly problematic, especially if the pedestrian is traveling in the same direction as the vehicle. The driver of the vehicle is paying attention to selecting an appropriate gap in oncoming traffic and not typically looking at the crosswalk; an unnoticed pedestrian in the crosswalk behind or directly to the side could certainly be vulnerable. In this case it is essential that the pedestrian pay attention to what is happening so that conflict with the vehicle is avoided especially if the driver is not paying attention to activity in the crosswalk.
Mid-block pedestrian signals can also be problematic. Most pedestrian signals are seldom used, drivers get accustom to the signals staying green and when activated the unexpected requirement to stop can result in violations and rear-end accidents.
In summary, every type of traffic control is not fool proof. If drivers obey the laws all intersections can be safe. Roundabouts are a good safe alternative that can be used by traffic engineers in appropriate situations. Roundabouts require reduced speeds and although the accident rate may not be significantly lower certainly the severity of the accidents is reduced. If the pedestrian crossings were signalized at roundabouts the added complexity, increased congestion and degraded traffic operations would certainly increase driver frustration and confusion and likely result in higher accident rates. The objective should be to improve safety and reduce accidents for everyone.
1105.7 Turn Lanes at Intersections - It is required to signalize all pedestrian crosswalks that cross right or left turn slip lanes.
Slip lanes are not defined. It is assumed that these are free-flowing turn lanes. The requirement to signalize all free-flowing turn lanes appears to be unnecessary and could certainly be problematic. Is a free-flow right-turn lane at an unsignalized intersection a slip lane? Would this requirement then extend to all unsignalized intersections? I'm certain that this is not the intent of the requirement. Additional unnecessary and unwarranted signals will increase driver frustration and likely increase violations and degrade the overall public safety.
1106.2.1 Accessible Pedestrian Signal System - Location - specific requirement for the location are identified.
The location criteria should be included as guidance rather than specific requirements as some of the requirements may be very difficult to meet.
1106 Accessible Pedestrian Signal Systems - Requires signal systems to have audible and vibrotactile devices.
Is this necessary? It seems that many blind people do not feel that this is necessary. Also it has been our understanding that most blind people will walk a route with a coach to learn the location of devices and the pathway they should follow before they venture out on their own. These requirements will significantly increase the cost of a traffic signal and do not seem necessary.
1106.4.2 Directional Information and Signs - Street Name - Street name signs are required to comply with 703.2. Requiring signs to be both tactile and visual.
This will require a new set of custom-made signs for each signalized intersection in addition to the street name signs already provided for the motoring public. This does not seem necessary.
1107.4 Public Telephones - All public telephones shall have volume controls, and have TTY capability.
Increasingly it is becoming more and more difficult to find a public pay phone. Some of the reasons that pay phones are being removed or not installed in public places include: increased availability of cell phones (less need for pay phones), use by drug dealers, vandalism, and general loitering around the phones. These increased requirements will further add to the reasons that pay phones will not be installed.
1109.2 On-Street Parking - Parallel Parking Spaces - An access aisle at least 60 inches
This will require significant reconfiguration of the street and sidewalk in order to accommodate a handicap parking space. As the need for on-street handicap parking will likely need adjustment periodically to accommodate changes in adjacent land uses is it perhaps better to just provide a curb ramp associated with each handicap on-street parking space.
1109.6 On-Street Parking - Signs - Signs are required to be 60" minimum above the ground.
This height is too low to be seen by traffic when vehicles are parked nearby. The minimum height requirement should be the same as required in the MUTCD and should be 7 feet
1110.6 Two-Way Communication - Shall comply with sections 708.2 and 708.3.
Cannot find these sections. They do not exist in the document available on the Internet.
1110.6.2 Two-Way Communication - TTY - A TTY shall be provided
Will this requirement make the two-way communication devices too complex, expensive and difficult to maintain thus eliminating them from installation?
------ End of Comments -------
We certainly appreciate the opportunity to comment on these proposed guidelines. We want to develop a transportation system that is accessible to all members of the community and is cost effective. Maximizing the limited dollars available is important in this day of limited resources.
Sincerely,
CITY OF LENEXA
Steven R. Schooley, P.E., PTOE
Transportation Manager
Lynn B. Jarman, October 24, 2002
ACCESSIBILITY IN THE PUBLIC RIGHT-OF-WAY DRAFT GUIDELINES
(Response to the Access Board's request for review and comment)
Salt Lake City Public Services has reviewed the proposed guidelines and respectfully submits the following recommended revisions and statements of concern:
1102.3, 1111.3 Alternate Circulation Path
Location. The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street.
Recommended Revision: The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street, unless in the judgment of the engineer, significant pedestrian safety issues exist, then the alternate circulation path shall be provided on the opposite side of the street.
1102.14 On Street Parking. Where on-street parking is provided, at least one accessible on-street parking space shall be located on each block face and shall comply with 1109.
Concern: Block lengths are not consistent across the country; the ratio of accessible stalls to non-accessible stalls will vary from city to city based on the standard block length. The proposed guideline does not clearly define whether the requirements apply to all block faces within a city, or only those locations with pavement marked stalls. The cost to identify accessible stalls on all block faces, including residential areas would be extreme.
1104 Ramps and Blended Transitions
1104.2.2.1 Running Slope
EXCEPTION: A parallel curb ramp shall not be required to exceed 15 feet
Recommended Revision: A parallel curb ramp shall not be required to exceed 16 feet
(The proposed minimum pedestrian access width is 48 inches; therefore, the common sidewalk scoring pattern would occur every 48 inches
1104.3.2 Detectable Warnings (see 1108)
1105 Pedestrian Crossings
1105.2 Crosswalks
1105.2.2 Cross Slope. The cross slope shall be 1:48
Concern: This requirement will create "tabled areas" in the roadway, potentially creating vehicular traffic hazards, particularly in areas where roadways have steep running slopes.
1105.3 Pedestrian Signal Phase Timing. All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
Recommended Revision: All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
Concern: Some consideration has been given to a walk speed of 2.5 feet
1105.5 Pedestrian Overpasses and Underpasses
1105.5.3 Approach. Where the approach exceeds 1:20
Concern: Overpasses and underpasses exceeding the maximum stated approach rise should not require the installation of an elevator. The extreme cost for installation, maintenance, and security makes this requirement an unjustifiable burden on municipalities with limited resources. Efforts should be made to meet ramping requirements, but site conditions may present a situation of infeasibility.
1105.6 Roundabouts
1105.6.2 Signals. A pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the crosswalk, including the splitter island. Signals shall clearly identify which crosswalk segment the signal serves.
Concern: Installation of pedestrian signals at each roundabout crossing negates the intended benefits of installing a roundabout. Additional signalization does not always result in greater pedestrian safety. Instead of requiring signals at all roundabouts, local engineers should evaluate roundabout installations to determine which locations would logically benefit from the installation of pedestrian signals.
1105.7 Turn Lanes at Intersections. Where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island.
Concern: Additional signalization does not directly equate to improved pedestrian safety. Well-engineered slip lanes (channelized turn lanes) with properly established pedestrian crossing times will result in improved safety. The slip lane design may or may not include additional signalization; the engineer should make this decision.
1108 Detectable Warning Surfaces
Concern: Considerable concern appears to exist from both the professional and public sectors regarding the installation of truncated domes. The major organizations representing the blind community cannot come to agreement on this issue. Initial installation costs and ongoing maintenance costs, especially in areas experiencing ice and snow, present real concerns regarding this proposed standard. Further evaluation is needed to ensure implementation of this guideline will provide the desired benefit.
Salt Lake City Public Services appreciates the opportunity to provide comment on the proposed guidelines. The Board's efforts in this matter are admirable. Hopefully, with feedback from local jurisdictions, guidelines meeting the true needs of our communities will be developed and adopted by those enforcing construction standards.
Sincerely,
Lynn B. Jarman
Salt Lake City Public Services
Engineering Division
Planning and Programming Manager
Freddie Simmons, P.E., October 29, 2002
We support AASHTO's comments on this and offer the additional comments from Florida DOT... (See attached file: Draft Guidelines for Accessible Public ROW - FDOT
Comments.doc)
thanks...
Freddie Simmons, P.E.
State Highway Engineer
The ability to travel freely is a right shared by everyone. Unfortunately, no path is ever totally free of all obstacles. Terrain, weather and distance will forever plague the pedestrian traveler. Traffic engineers recognize the duty we have not to create further impediments. However, so long as budgets remain limited, the world of transportation will be a zero-sum game. Balance is critical so that an improvement for one portion of the population does not become a burden on another.
Many of these guidelines incorporate new technologies or new ideas. Too often, these are concepts that sound plausible but do not work in reality. For instance: the painting mid-block crosswalks so people can safely cross the street. Experience has shown that they make pedestrians feel safer without actually changing driver's behavior. It is the wary that avoids the speeding truck bumper, not the blissful. New ideas are important. It is how we evolve as a society, but to require unproven theories on the trusting public is not a wise decision.
Many of these changes are being implemented as conditions warrant. For instance: Accessible Pedestrian Signals are available and policies allow for their use. It is through this slow-growth process that good ideas can be recognized from the bad. Declaring a policy that has hidden flaws nationwide has serious life-and-death consequences.
The various Departments of Transportation across the nation are staffed by dedicated professionals who have years of training and experience on balancing the needs of the public. We look at not only how much a feature will cost directly, but how it will impact those who have to keep it functioning as designed. These requirements ignore all this and mandate how things shall be with no knowledge of the impact or effectiveness. It is important for the Board to understand that these unbalanced and unfunded mandates may benefit a small fraction of the public, but will certainly impact all.
Section 1102: Scoping Requirements
1102.1: General - All areas of newly designed and newly constructed facilities in public rights-of-way and altered portions of existing facilities?
1102.2.2 Alterations - Where existing elements or spaces in the public right-of-way are altered, each altered element or space shall comply?
Background: The requirement is for any altered portions or spaces of existing facilities. This brings to question if the changes are related to the current project. Does the addition of a turn lane mandate the upgrade of the signals? Does changing the signals to the new LED systems mandate the installation of curb ramps? Does the closing of a median opening mandate the reconstruction of nearby driveway openings to correct cross-slope problems? Many of these items are totally unrelated to the other and could expand the scope of projects beyond any financial capacity to support.
Recommendation: Recommend narrowing the definition of altered portions and reducing the requirement to a 'should comply' standard.
1102.2.2 Alterations: Exception - In
Background: This requirement is a huge liability burden if the only limitation is 'technical infeasibility'. It is rare that a solution is technically infeasible but very common that a solution is financially infeasible or politically impractical.
Recommendation: Recommend providing some protection to the agencies who have to meet this burden by use of an 'impractical' standard.
1102.2.2 Prohibited Reduction in Access - An alteration that decreases or has the effect of decreasing the accessibility of a public right-of-way or site arrival points to buildings or below the requirements for new construction at the time of the alteration is prohibited.
Background: This requirement allows for no changes for future conditions. Once a sidewalk or other access has been placed, it is there forever. This constraint would not allow for the removal of pedestrian bridges that are rarely used and have become a center for crime. This requirement would not allow the removal of mid-block crosswalks that are of questionable benefit and provide a false sense of security to users.
Recommendation: Recommend removing this requirement from the planned guidelines.
1102.3 Alternate Circulation Path - An alternate circulation path complying with 1111 shall be provided whenever the existing pedestrian access route is blocked by construction, alteration, maintenance, or other temporary condition.
Background: This requirement is not only a huge financial burden for the simpler activities. The requirement is for 'temporary conditions'. How temporary is temporary? Does a crash that blocks a sidewalk require the construction of an alternate path as part of the response? Does a drill rig parked on a sidewalk to get soil samples mandate the need?
Recommendation: Recommend incorporating time limits on the minimums necessary. A standard of 'overnight' is easily understandable and enforceable.
1103 Pedestrian Access Route
1103.3 Clear Width - The minimum clear width of a pedestrian access route shall be 48 inches
Background: This is an expansion of the current width requirement for 36 inches
Recommendation: Recommend retaining the current ADA standard of 36 inches
1103.5 Grade - The grade of pedestrian access route within a sidewalk shall not exceed the grade established for the adjacent roadway.
Background: This requirement opens the various agencies to immense liability because of limitations caused by terrain. This is an immense county with an incredibly diverse landscape. This standard will rule out many viable designs simply because the adjacent roadway does not follow the same contours. Field conditions are notorious for not allowing what appear to be simple solutions planned by a distant designer. A short grade change to align a sidewalk at a crossing that slightly exceeds this minimum will be fodder for the circling legal vultures.
Recommendation: Recommend loosening this standard to only 'should not exceed'. This will allow enough variation to provide legal protection while eliminating the most grievous examples that are truly a problem.
1104 Curb Ramps and Blended Transitions
1104.2.2.3 Landing - A landing 48 inches
Background: This requirement needs clarification on the exact conditions that this standard shall be applied. Is this landing required to be outside of vehicular travel lanes? The minimum cross slope requirement will produce problems for vehicle control in hilly terrain. These landings will function as unexpected 'speed bumps' for the right side of the vehicles. Drainage can also be a problem because of the minimum running slope.
Recommendation: Recommend further study to determine how this requirement is to be implemented and insure there are no expected developments before this standard is applied nationwide.
1104.2.2.4 Diverging Sidewalks - Where a parallel curb ramp does not occupy the entire width of a sidewalk, drop-offs at diverging segments stall be protected with a barrier.
Background: This requirement is vague on the situations that require a barrier and what will satisfy the need for a barrier. How big is the minimum allowable drop-off? Can landscaping satisfy the requirement for a barrier? Or is a concrete wall necessary.
Recommendation: Recommend clarifying this standard by defining a drop-off better, such as: greater than 10 inches
1104.3.1 Width - The clear width of landings, blended transitions, and curb ramps, excluding flares, shall be 48 inches
Background: This requirement is an expansion of the current 36-inch standard (section 4.7.3). This expansion is without merit. The current standard is based on the physical needs of wheelchair users. Expanding it to 48 inches
Recommendation: Recommend keeping the width to the current standard unless a justifiable need is presented.
1104.3.2 Detectable Warnings - Detectable warning surfaces complying with 1108 shall be provided, where a curb ramp, landing, or blended transition connects to a crosswalk.
Background: This requirement has been 'on-hold' and awaiting further study most of the time ADA has been in effect. These tactile surfaces are not universally desired by the intended users and can present difficulties to other users. They can be a tripping hazard to those who tend to shuffle their feet. They are a maintenance headache to keep clean and serviceable. It is questionable if they do not generate more problems then they supposedly resolve.
Recommendation: Recommend continuing the suspension on these tactile surfaces until the 'appropriateness of providing detectable warnings at vehicular-pedestrian intersections in the public right-of-way should be established' as called for in the Access Board's own advisory committee in a letter dated July 29, 1996. The 'appropriateness' study called for in this letter does not appear to be in the public domain.
1104.3.6 Counter Slopes - The counter slope of the gutter area or street at the foot of a curb ramp or blended transition shall be 1:20
Background: This requirement is confusing as to which direction the slope is to be measured. The term 'counter slope' is non-standard and is not presented in section 1101.3 Defined Terms. If the slope is in reference to the cross slop of the accessible path, this will be equal to the grade of the adjacent roadway and impossible to satisfy. If the counter slope is the running slope of the crosswalk, drainage problems may result because of an insufficient slope.
Recommendation: Recommend properly identifying the slope in question before continuing this requirement.
1104.3.7 Clear Space - Beyond the curb line, a clear space of 48 inches
Background: This requirement is an extreme example of the continued and subtle attempt to expand the space requirements of the accessible route. The lack of a need for 48 inches
Recommendation: Recommend keeping the current standard of 36 inches
1105.2 Crosswalks
1105.2.1 Width - Marked crosswalks shall be 96 inches
Background: This requirement is excessive of the national traffic standards and current ADA requirements without providing sufficient justification on this expansion. Currently, the Manual on Uniform Traffic Control Devices (MUTCD) advises that crosswalks 'should not be less than 6 ft
Recommendation: Recommended retaining the current national standard of 6 feet
1105.3 Pedestrian Signal Phase Timing - All pedestrian signal phase timing shall be calculated using a pedestrian walking speed of 3.0 feet
Background: This requirement will have massive negative impact on the quality of life for the entire population with no appreciable benefits. The current MUTCD standard is 4 ft
Recommendation: Recommend keeping the current standard of 4 feet
1105.5 Pedestrian Overpasses and Underpasses
1105.5.3 Approach - Where the approach exceeds 1:20
Background: This requirement will essentially eliminate the use of pedestrian overpasses/underpasses except at locations with fulltime workers. Pedestrian overpasses/underpasses are rarely used now because of the cost and space requirements for the access ramps. This need to provide for a limited portion of the population hurts the rest by eliminating this solution unless all can be accommodated. With the expanded use of motorized wheelchairs and personal electric vehicles, the number of people is dwindling that cannot handle the 5 foot
Recommendation: Recommend removing this 5-foot limitation because of the limited benefits generated verses the potential loss of access to the general population.
1105.6 Roundabouts
1105.6.1 Separation - Continuous barriers shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited. Where railings are used, they shall have a bottom rail 15 inches
Background: This requirement is unnecessary, vague and potentially dangerous. A roundabout is simply a circular travel lane. Barriers are not typically used adjacent to travel lanes unless it is to keep vehicles from leaving them. This requirement implies it is to keep the pedestrians from entering the roadway. A barrier will not keep pedestrians out if they really want to enter and if they do get inside, they are then trapped. Europeans, who have far greater experiences then American, do not include such a 'pedestrian barrier'. A railing close to the travel lane can also be dangerous if struck by a vehicle. An out-of-control motorcyclist leaving the roadway could be decapitated. A vehicle could snag the railing and whip it through a crowd. If these possibilities sound too far fetched, look into the MUTCD restriction against using portable school signs. Cars were hitting these signs and sending them into groups of children.
Recommendation: Recommend removing this requirement because of the potential problems it could cause. A better solution would be to restrict the crosswalks from the roundabout 'core' and designate a minimum distance of 20 feet
1105.6.2 Signals - A pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the crosswalk, including the splitter island. Signals shall clearly identify which crosswalk segment the signal serves.
Background: This requirement essentially eliminates the benefits produced by roundabouts by turning them all into expensive signalized intersections. Roundabouts are used to produce traffic calming without grossly impacting roadway capacity. They help with meeting clean air mitigation goals and reduce the maintenance burden by removing marginally warranted traffic signals. Signalization of any approach totally defeats these benefits. It has been proved that roundabouts can reduce pedestrian crashes because of slower traffic conditions and through the use of splitter islands as pedestrian refuge islands. They are claimed to be dangerous for the blind, but roundabouts are best for replacing intersections that are 'stop controlled', not signalized intersections. The pedestrian is still vulnerable to errant drivers. In addition, the pedestrian only has to cross a single lane of traffic instead of the two or more lanes typically found.
Recommendation: Recommend removing this requirement from the guidelines and examining minimum requirements for pedestrian crossings at roundabouts.
1106 Accessible Pedestrian Signal Systems
1106.2 Pedestrian Signal Devices - Each crosswalk with pedestrian signal indication shall have a signal device which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device and shall comply with 1106.3
Background: This requirement will triple the installation costs of pedestrian features according to the latest quotes. These devices are new to the market and will have corresponding developmental problems. The vibrotactile requirement is especially troubling because this is a mechanical device and will be subject to high maintenance attention. These devices are not wanted by a significant portion of the targeted population for various reasons and will generate resentment by others because of the high cost and lack of need. The current MUTCD allows traffic engineers to install these devices where there is a need and where they will be used. A blanket approach would not be cost effective and will diminish the travel skills of the average blind pedestrian. These devices induce the false sense of security that the path is safe to cross while masking the noise generated by the truck running the light.
Recommendation: Recommend not making this a universal requirement but recognizing the current ability of traffic engineers to use these devices where they are warranted.
1106.2.1 Location - Pedestrian signal devices shall be located 60 inches
Background: This requirement severely limits the locations pedestrian signal devices can be located. It disallows a common cost-saving technique of co-locating two signal heads on one pole. Terrain features or right-of-way restrictions can limit the space available to meet these exacting standards.
Recommendation: Recommend the Board follow the guidance given by the MUTCD. This states 'Pedestrian signals indications should be conspicuously and recognizable to pedestrians at all distances from the beginning of the controlled crosswalk to a point 10 feet
1106.3 Pedestrian Pushbuttons
1106.3.2 Locator Tone - Pedestrian pushbuttons shall incorporate a locator tone at the pushbutton?
Background: This requirement will greatly increase the cost of pedestrian detectors while annoying the general public with the non-stop beeping. These beeps will mask the traffic noise used by blind pedestrians and will become common targets for vandals.
Recommendation: We recognize the usefulness of these locator tones and recommend they be only used at locations that have Accessible Pedestrian Signals. The recommendation given above for Accessible Signals will limit the locator tone detectors only to those locations that they are necessary and will produce the most benefit.
1106.4 Directional Informational and Signs
1106.4.2 Street Name - Signs shall include street name information aligned parallel to the crosswalk direction and complying with 703.2.
Background: This requirement will greatly increase the maintenance burden for minimal benefit to the traveling public. The same information can be obtained by asking a passerby. The only pedestrians who will require these signs are blind pedestrians outside of their normal walking route who does not pass anyone. This is an incredibly small fraction of the trips. Currently, street name signs are placed high so as to be visible and safe from vandals. The tactile requirement means signs must be close enough to be touched, and damaged. These signs will have to be custom made for each location and will become common 'souvenir' items.
Recommendation: Recommend the Board use a 'should' standard and only require the signs in a central business district.
1106.4.3 Crosswalk Configuration - Where provided, graphic indication of crosswalk configuration shall be tactile and shall comply with 703.5.1.
Background: This requirement is similar to 1106.4.2 for the limited benefits produced.
Recommendation: We recognize the worth of tactile depiction of complicated intersections and recommends the Board pursue standardization of these techniques before requiring them nationally.
1108 Detectable Warning Surfaces
Again, to restate comments from 1104.3.2. These tactile surfaces are still questionably beneficial in most locations. The Access Board itself has recognized the problems of these surfaces by repeatedly suspending their implementation. They may be of benefit in some locations but if they become too common, they may become ignored. They can also be hazardous to certain members of the population and are difficult to keep clear of ice and snow.
1108.2.1 Curb Ramps and Blended Transitions - The detectable warning surface shall be located so that the edge nearest the curb line is 6 inches
Background: This requirement is vague as to which side of the curb the warning is to be located. If the surface is placed on the ramp side, a tripping hazard is probable by the fact some people cannot raise their feet high enough and may stumble. If the surface is placed on the gutter side of the curb, drainage and vehicle damage become an issue.
Recommendation: Recommend this section be clarified and tactile surfaces not included in curb ramp slopes.
1108.2.2 Rail Crossings - The detectable warning surface shall be located so that the edge nearest the rail crossing is 6 inches
Background: This requirement is probably unnecessary and could possibly do more harm than good. The only time these warnings would be necessary is when crossing arms do not cover the pedestrian route across the tracks, an uncommon occurrence. These warnings will supposedly benefit a blind pedestrian who can feel these slight variations of texture but is unable to feel the vibrations caused by the massive train barreling down the tracks or hear the earsplitting whistle that can rattle windows. These warnings will be dangerous to those pedestrians that shuffle along and trip over the 'truncated domes' and pitch forward onto the tracks.
Recommendation: Recommend not including these as a blanket requirement at rail crossings but allow the local agencies to specify locations where they can provide a worthwhile benefit.
1109 On-Street Parking
1109.2 Parallel Parking Spaces - An accessible aisle at least 60 inches
Background: This requirement is confusing and could have great impact on project budgets. Is this access aisle required for all parking spaces or only for accessible spaces as required in 4.1.2 (5) (a)? If the requirement is only for accessible spaces, this is a reasonable standard. If the requirement is for all parking spaces, vast amounts of right-of-way will be inefficiently used and available parking spaces severely limited.
Recommendation: Recommend clarification on this requirement so as to specify that it apply to accessible parking spaces. I do not recommend it become the standard for all on-street parking.
1109.5 Obstructions - There shall be no obstructions on the sidewalk adjacent to and for the full length of the space
Background: This requirement eliminates an important safety feature that also improves the quality of life for everyone: trees. Again, there is confusion over whether this applies to all parking spaces or only to those designated as 'accessible'. If this is to apply to all on-street parking spaces, there will be a serious degradation in the quality of life for all. General pedestrian safety will be impacted. Clean air mitigation will suffer. Restricting obstructions for the entire length of the parking space is rather excessive and should only focus on what is necessary for access.
Recommendation: Recommend this standard only apply to 'accessible parking spaces' and restricts obstructions to the center 50 percent of the space so as not to interfere with the operation of a side lift or a passenger side transfer.
1111 Alternate Circulation Path
1111.3 Location - The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street.
Background: This requirement is excessive and will greatly impact minor projects for minimal benefit. The unwarranted constraint of placing the alternate path on the same side of the street as the original path is entirely unnecessary. This says people cannot cross the street to reach another route but can be taken over hill and dale to get around some utility work. Many times an entire block of sidewalk is disrupted by maintenance work. What sense does it make to acquire a construction easement, cut ramps through parking lots, and lay temporary asphalt, when a perfectly accessible route is across two lanes of traffic? The MUTCD says 'Bicyclist and pedestrians should be provided with access and reasonably safe passage through the temporary control zone.'
Recommendation: Recommend the Board follow the example of the MUTCD and use a more generalized statement while requiring any route to be fully accessible.
The Board maintains a similar responsibility for accessibility guidelines under the Architectural Barriers Act (ABA). The ABA requires access to certain facilities designed, built, altered, or leased with Federal funds, including those allocated for transit. Like ADAAG, the Board's ABA accessibility guidelines apply to new construction and alterations.
Public Rights-of-Way Access Advisory Committee
The advisory committee met regularly over a year's time, usually in Washington, D.C. but also in Austin and San Francisco. Its work culminated in the issuance of a report, "Building a True Community," which was submitted to the Board in January 2001. The committee's report provides criteria for the construction or alteration of public rights-of-way that reflects the broad spectrum of expertise represented by committee members. The report follows a "toolbox" approach to the establishment of guidelines designed to facilitate implementation and to promote an understanding of the needs of all users of public rights-of-ways. The report comprehensively covers the various components of public streets and sidewalks and provides criteria for sidewalks, street fixtures and furnishings, street crossings, vehicular ways, parking, and other components of public rights-of-way. In addition, the report includes advisory notes, figures, and discussion of issues that merit further study or special attention in the Board's rulemaking. To what extent were transit facilities addressed? There seems to be little addressed.
General Scoping: New Construction, Alterations, and Additions (1102)
Scoping requirements in section 1102 indicate where the draft guidelines apply and which elements and spaces must comply with the technical provisions. The draft guidelines cover new construction (1102.1) and additions and alterations (1102.2). Scoping provisions address various elements and spaces, including access routes, curb ramps, signs, crossings, and street furniture (1102.3 through 1102.16). Does this include access to transitfacilites?
Additions and Alterations (1102.2)
Much of the work that occurs in public rights-of-way involves alterations to existing facilities or the addition of facilities within the constraints posed by existing developed rights-of-way. The draft guidelines, consistent with ADAAG, would apply technical requirements according to the scope of work for a planned alteration or addition. This application is based on the premise that the more extensive the work is, the greater are the opportunities to achieve access. In effect, compliance is "prorated" based on the extent of the work planned. Industry and local practices, among other factors, typically govern the scope of a project. For example, industry practice may broaden the scope of work for a planned improvement project to ensure a smooth transition to adjacent areas, improve safety, or upgrade existing elements, such as drainage structures, within or near the area to be improved. Clear definitions are needed for "alteration" and what types of roadway projects trigger ADA improvements. Also, a process is needed for "accessibility design exceptions", similar to the design exception process currently used by the FDOT and FHWA.
Accessible Elements and Spaces: Scoping and Technical Requirements (1102.3 - 1111)
Alternate Circulation Path (1102.3,1111)
The draft guidelines address construction within public rights-of-way and call for alternate circulation paths where pedestrian access routes are temporarily blocked by construction, alteration, maintenance, or other temporary conditions. Technical specifications address the minimum clear width (36 inches), location (on the same side of the street parallel to the disrupted pedestrian access route), hazardous protruding objects, and criteria for signs and barriers. Construction at public rights-of-way can be particularly hazardous to people with visual or mobility impairments if the site is not adequately protected with a barrier or barricade. In particular, tape or a series of widely spaced traffic cones placed around a construction site may not be detected by some pedestrians. Such markings do not provide sufficient cues to enable a blind pedestrian to anticipate a hazard, nor do they provide an edge along which to travel around an obstruction. Barriers would be required to be detectable, with edge protection and railings. The requirements for barriers are based on proposed MUTCD standards (Chapter 6). Make sure temporary access to transit is included.
Pedestrian Access Route (1102.4,1103)
Minimum Clear Width (1103.3)
The draft guidelines specify a minimum clear width of 48 inches
Pedestrian Signs (1102.7)
Bus Route Identification (1102.7.1)
Bus route identification signs would be subject to the visual character requirements, except those for character height (which would apply only to the maximum extent practicable) and sign height. This requirement would not apply to bus schedules, timetables, or maps. This provision is consistent with existing ADAAG provisions for bus stops and shelters (section 810.4). In addition, the draft guidelines would require route identification signs located at bus shelters to be tactile and provide information in raised and Braille characters according to specifications in ADAAG (section 703.2). Raised characters are to have rounded corners. An exception permits certain types of audible signs to substitute for tactile signage. When is this exception in force?
Informational Signs and Warning Signs (1102.7.2)
ADAAG specifications for visual legibility would also apply to informational signs and warning signs located in public rights-of-ways, but the draft guidelines would not require the inclusion of raised and Braille characters. This provision would apply to signs that label or provide information about, or direction to, public buildings, transit stations and stops, and many other facilities and elements. It would also cover signs at elements for pedestrian use, such as signal pushbuttons, and signs that warn of sidewalk closings or that provide direction to alternate pedestrian routes. This is a particularly difficult situation for blind pedestrians. During construction, if routes are changed, they can quickly become dangerous for blind persons walking into potentially dangerous construction areas. Identifiable warnings and barriers are important for safety, not just accessibility.
Pedestrian Crossings (1102.8,1105)
Roundabouts (1105.6)
A growing trend in roadway design favors continuous-flow roundabouts over traditional signalized intersections. While their design varies widely, roundabouts typically feature a circulatory roadway around a central island. Entering traffic yields to vehicles already in the circle. Increasingly popular in the U.S. because they add vehicle capacity and reduce delay, roundabouts are a common feature in Europe and Australia. Because crossing at a roundabout requires a pedestrian to visually select a safe gap between cars that may not stop, accessibility has been problematic. While roundabouts may be an asset to traffic planners in controlling and slowing the flow of traffic at intersections without using traffic signals, the absence of stopped traffic presents a problem for pedestrians with vision impairments in crossing streets. Pedestrians report that vehicles at roundabouts, as well as at other unsignalized crossings, often do not yield for pedestrians. Persons with vision impairments and pedestrians who may hesitate at such crossings are at a particular disadvantage. Can we 'require' "Yield to Pedestrians" signs and entrances/exits to roundabouts?
Accessible Pedestrian Signal Systems (1102.8,1106)
The Board is proposing to apply these requirements where pedestrian signal systems are provided at pedestrian crossings. The advisory committee had recommended limiting their application only where certain types of pedestrian signal systems are provided, such as those that are pedestrian activated. The Board believes that access should be required at all crossings equipped with pedestrian signals to ensure a consistent level of accessibility within a pedestrian network. Compliant products are available. A project the Board sponsored on accessible pedestrian signals provides a synthesis on current technology in accessible pedestrian signals, including a listing of devices and manufacturers in the U.S. and abroad, and a matrix comparing the features of each device. The project report,"Accessible Pedestrian Signals" provides information on several different types of devices on the market, including audible, vibrating, and receiver-based infrared systems. Audible systems are now available that feature discreet tones which automatically adjust to the ambient noise level. These systems have replaced older products that had raised concerns about noise pollution. Maybe not require accessible ped signals everywhere, but primarily on/near transit corridors because of transit dependence.
Detectable Warning Surfaces (1108)
Guidance is needed on the location of detectable warning surfaces when curb is not present. For example, there a many instances where sidewalks are present along uncurbed roadways. It appears appropriate that sidewalks that are interrupted by major roads and streets should have warnings, but not residential type driveways. However, commercial establishment driveways can range from very low traffic volume to very high volume. More specific guidance for these situations should be provided.
1101.3 Defined Terms.
Alteration: Need a clear definition, with examples, for Alteration to assist determination when accessibility upgrades are triggered. Especially for routine and/or on-going roadway repair and maintenance activities (resurfacing, restriping, patching potholes, utility construction, etc.) To what extent/at what level do these activities require the accessibility upgrades to surrounding/adjacent facilities in the right-of-way? (EG: For 3-R (resurfacing, rehabilitation and restoration) projects - would it be required to widen existing 3-foot wide curb ramps to 4-foot wide to meet these recommendations?)
1106.2.3.2 Volume. Tone or voice volume measured at 36 inches
1106.3 Pedestrian Pushbuttons. Pedestrian pushbuttons shall comply with 1106.3.
1106.3.4 Optional Features. An extended button press shall be permitted to activate additional features. Buttons that provide additional features shall be marked with three Braille dots forming an equilateral triangle in the center of the pushbutton. Maybe add a raised 'arrow' pointing toward the direction the button controls; or adding Braille characters on a sign describing the street name for which crossing the button controls.
Nathanael T. Wales, September 23, 2002
Dear Members of the Board:
I have reviewed the Board's Draft Guidelines on Public Rights of Way (Sections 1100 through 1111). Having reviewed them, I am e-mailing the following comments to you in advance of my attendance at the Board's public meeting on October 8 in
I am blind and am a member of the National Federation of the Blind. Professionally, I graduated from the University of California at Davis in 2001 with a Bachelor of Science degree in civil and environmentalengineering, and I have worked full time for a little more than the past year as a water resources engineer for the State of California. I am commenting on these draft guidelines as a blind person living in and traveling independently throughout the Sacramento, California, area; as anengineer who has taken civil engineering planning and design courses at theuniversity level and who has worked in the field specifically doing planning work on civil engineering projects in collaboration with other governmental agencies; and as one who has professionally reviewed thousandsof pages of public comments on engineering projects and their guiding policies (and who is therefore sensitive to the volume of comments of whichthese are a part).
Overall, I believe that the draft guidelines will greatly improve access for the disabled to public rights of way. In general, I believe that regulating new and altered public rights of way to these standards will improve not only access to the disabled but also overall pedestrian safetyand will heighten the regard that the general public holds towards walkingas an alternative to driving. I do, however, wish to comment on and express my concern about two general areas of the draft guidelines that aredirected at improving access for blind pedestrians: the use and design of detectable warnings on curb ramps (1104.3.2, 1105.4.2, and 1108) and the use and design of accessible pedestrian signals (1106). In short, I believe that the draft guidelines are unnecessarily broad and sweeping in scope and far too restrictive and prescriptive in design. These portions of the draft guidelines are precisely the sort of regulations that frustrate planners and engineers and may ultimately cause local governmentsto decide not to make safety improvements at intersections--even at the most dangerous intersections--because of the substantial expense of following these prescriptive and inflexible guidelines.
First, I believe that the scope of requiring detectable warnings on curb ramps and pedestrian refuge islands (1104.3.2 and 1105.4.2, respectively) is unnecessarily broad. I appreciate the Board's invitation for public comment on this specific matter, and I am pleased to provide mine. It is my experience as a blind pedestrian using a white cane that curb ramps arevery accurately detectable because I am able to detect with my cane and underfoot the change in slope on the ramp in combination with other clues indicating that I am approaching the intersection (such as cross traffic, idling cars, the corner of a building on the block, and the presence of a perpendicular sidewalk). Only the most shallow curb ramps and blended curbs (generally a bad idea in almost every case because of dangerous turning traffic and more difficult drainage) are more difficult to detect precisely. Generally, I and most other blind pedestrians use other environmental clues (such as those I mentioned above) to accurately locatethe intersection and find the location of any shallow curb ramp or blendedcurb safely. It is therefore my opinion that detectable warnings should only be used on the most shallow curb ramps (those with a slope of 1:15
My experience traveling throughout Sacramento is the basis of my opinion. The city, as part of the settlement of a lawsuit, is rebuilding thousands of very poorly designed and constructed curb ramps. As part of the plan the city council adopted from the public works department, detectable warnings are only being used on curb ramps with a slope of 1:15
Further, I believe that the design prescribed for detectable warnings (1108) is overzealous, inflexible, and impractical. The draft guidelines require 2 feet
Secondly, I believe that the draft guidelines regarding the use of accessible pedestrian signals (APS's) (1106.2) are equally as broad and overreaching. Because I and other blind pedestrians, whether we use a white cane or a guide dog, determine when we have the walk interval and itis safe to cross based on a number of factors including not only traffic patterns in the intersection but also whether other pedestrians and bicyclists are crossing in our desired direction, APS's are generally unnecessary. These techniques work well and very safely in the vast majority of intersections, including four way intersections and intersections between one-way streets. It is only at a relatively small number of intersections in very specific cases that I and other blind pedestrians have found that APS's are needed. Such specific cases include intersections between a street with a high traffic volume and a street witha very low traffic volume (and at such intersections an APS is only neededfor crossing the high volume street), T-intersections (and at such intersections an APS is only needed for crossing the through street), intersections with one or more left and right turn slip lanes (and at suchintersections an APS is only needed to cross the one or more turn slip lanes), and roundabouts (cases that may prove less favorable for traffic flow because of the need for pedestrian activated signals for all pedestrians).
Further, the requirement that an APS have both an audible indication of thewalk interval (1106.2) and a locator tone (1106.3.2) is unnecessary in allcases for me and other blind pedestrians. The vibrotactile indication of the walk interval is completely sufficient. In fact, an audible indicationwill not only add to noise pollution but also mask audible clues in the environment (such as other traffic) that we use and will further potentially disorient those of us mistakenly using the audible indication from the APS to find the way across the intersection. In addition, locatortones on APS push buttons are entirely unnecessary, especially in consideration of the draft guidelines' specific requirements for the location of pedestrian crossing push buttons. Rather, locator tones will add greatly to noise pollution at the intersection during every second of every minute of every hour of every day of every week of every month of every future year, will be difficult to distinguish on channelizing islandsat intersections with turn slip lanes (which may require up to three locator tones within a few square feet) and may further cause blind pedestrians to become disoriented on such islands, and may finally misleadblind pedestrians crossing an intersection away from their destination corner.
In conclusion, on these two broad matters I believe that the current draftguidelines' broad scope and extraordinarily restrictive and prescriptive approach to intersection safety and public rights of way accessibility willfrustrate engineers looking for innovative and tailored solutions to the specific design situations with which they work. These draft guidelines will provide engineers with little flexibility in implementing more effective detectable warnings less prone to such problems as leaf cover inSacramento or less likely to be the cause of a personal injury liability for their local government. The overzealous implementation of APS's may result in noise pollution from up to 12 audible walk indications beeping atonce and up to 16 constant locator tones at four way intersections with right turn slip lanes; such four way intersections with right turn slip lanes are very common in Sacramento and Davis. Finally, the associated expense of detectable warnings on curb ramps and accessible pedestrian signals may discourage local governments from improving sidewalks and installing new traffic signals at intersections altogether, leading to continuing danger to automobile traffic and pedestrians alike in locationswhere sidewalks and signals may be most needed.
Again, I believe that, overall, these draft guidelines will provide much needed access for the disabled to pedestrian rights of way. I believe thatthey will implement positive change. I do believe, though, that the scope and restriction of the guidelines regarding detectable warnings and accessible pedestrian signals must be carefully re-considered. Finally, I thank the Board for this opportunity to comment on these guidelines and fortaking the time to read my comments carefully and thoughtfully.
Sincerely,
Nathanael T. Wales
Diana Ibarra, October 28, 2002
Public Comments
Public Right of Way
Diana Ibarra (Architect)
2207 E. Concord St.
Orlando, FL 32803
407-895-9565
As an architect I offer the following comments regarding the Public Right of Way Draft. These are frequently encountered questions.
01) See attached .jpg drawing re: Detectable warning locations
I have not seen this condition drawn or documented in the varying publications.
The streets are tree-lined with a setback from the road to the sidewalk edge. This occurs in residential as well as commercial locations. The sidewalk is a 5' ribbon that runs directly into the curb ramp. If this case is encountered, the ramp often ends up occurring on the radius of the roadway.
Opt. 1: Many developers drop the curb ramp prior to the street. In this case, should the tactile warnings be located at the base of the ramp (per documentation) or should the tactile warnings be located in a splayed condition along the radius. Does it lead to confusion if the person traverses a curb ramp to a flat level surface with no detectable warnings? If the detectable warnings were located at the base of the ramp it would seem that the purpose of "alerting to roadway" is lost and a person may continue on with a false sense of security.
Opt. 2: If the ramp is pushed to the edge of the roadway, can a wheelchair negotiate the splayed detectable warnings? Do the detectable warnings located on a curve create any confusion for the visually impaired user who may lose directional orientation as to appropriate cross walk?
02) Title II and private property
Jurisdictions (state, county, or city) regularly improve the roadway system. Many times when major roadway realignment projects occur the road is often raised and crowned above previous topographic levels. (The raising of the road can easily differ between 12" and 6'-0"). Bus stops are added, pedestrian walkways are provided. However, the access from the roadway and new sidewalks to the resulting lower grades where businesses occur is not provided. Since this is on the Public ROW and not the private property owner's property per se, does the jurisdiction bear the responsibility of providing ramps down to the previous grade level walkways?
If the distance from the Public ROW edge to the private landowner's property line is substantial, (50' to 200', e.g. transmission lines or other utility easements), who bears the responsibility of crossing that property to reach the private property's sidewalk?
03) Detectable warnings:
As an architect, I personally prefer the 2'-0" band at the edge of danger (i.e. metro platform, roadway, drive lane, etc.) vs. the full length and width of a curb ramp. The 2'-0" band is more consistent with detectable warnings observed overseas.
04) Level road way crossing:
I am not a civil engineer, however, the typical drainage flow arrangements for roadways tend to use the road as a giant gutter. This often conflicts with the 2% cross slope requirement when there is a slight hill. I understand the goal regarding "table" at the intersection, however, I submit that many civil engineers are not currently designing to this end and there will be a large number of lawsuits which will be much more costly to repair than any Title III modifications currently encountered. In order to "retrofit" an incorrect installation depths of 8' to 16' are required to connect new piping. Either the entire property has to be regarded or numerous additional outlets are required based upon the tables. It is not as simple as replacing grab bars. The cost of correcting this needs to be considered.
05) Residential:
Do these guidelines apply to residential streets in speculative subdivisions that are covered under the Fair Housing Act? Or are they strictly for commercial downtown business districts and places of public accommodation (malls, offices etc.)?
06) 1104.3.7
Does the 48-inch x 48-inch minimum landing "beyond the curb line" refer to the roadway side of the curb line or the building/sidewalk side of the curb line?
If it refers to the roadway side of the curb line, does this exclude bicycle paths built parallel with the road?
07) 1102.10 Two-inch contrasting strip
This appears to be very limiting in the design options. E.g. direct lighting on stair treads or integrally lit stair treads provide good visibility without mandating the contrasting color. Is there performance criterion that can be provided to support alternative technical solutions?
08) 1102.5.3 EXCEPTION
This appears to be achievable with 7'-0" doors. Typical 6'-8" doors often have a closer 2" lower. The typical user of a 6'-8" door is less familiar with the more technical options of recessed parallel arm closers and those types of closers often can not be accommodated on a typical 6'-8" door. The dimension is suitable for commercial storefront applications; however, smaller businesses with residential appearances may not be able to comply without affecting the structural header. There are models that would have the closer arm approximately located at 6'-6-1/2" to 6'-7" aff. (where the closer is mounted above on the header with the arm mounted on the door). This especially occurs in the retrofit conditions.
(This is not insurmountable, however, it is something that the typical small business owner will not be aware of the ramifications as they select a product from the local home improvement store).
Douglas Weiszhaar, October 25, 2002
Enclosed is the Minnesota Department of Transportation's (Mn/DOT) response to the Access Board's Draft Guidelines for Accessible Public Rights of Way. The response is a consensus position that has representation, comment, and involvement from all affected facets of Mn/DOT and its partners from the cities and counties.
Mn/DOT and its transportation partners have a distinguished history of working to make the transportation system accessible to all users and of working with communities to achieve the letter and the spirit embodied in the Americans with Disabilities Act. The comments enclosed are a continuation of that history and Mn/DOT's commitment to keep an open dialogue that allows us to responsibly build and maintain the best transportation system possible.
Sincerely,
Douglas Weiszhaar
Acting Commissioner
Minnesota Department of Transportation's
Response to the Access Board
on
Draft Guidelines for Accessible Public Rights of Way
October 25, 2002
General Discussion
The Minnesota Department of Transportation's (Mn/DOT) review of the Access Board's Draft Guidelines for Accessible Public Rights of Way, surfaced broader themes and concerns about the guidelines, which are discussed here.
Flexibility
The wide range of environments that will be encountered by designers within the public right of way was clearly not considered. The rigidity of the guidelines do not allow for engineering judgement and do not respect the cultural, environmental, and physical conditions that a designer must consider on a site by site basis. The current approach of the guidelines may result in poor design, dangerous conditions, a reduction of general services, and operational shortcomings unless flexibility is introduced.
Availability of Resources
There is great concern that the guidelines have been developed without a context that takes the cost of construction and ongoing maintenance into consideration. While it has been made clear that the Access Board views cost as an issue of implementation to be managed by the FHWA and the Department of Justice, guidelines cannot be responsibly developed without these topics being taken into consideration. Many who provided comments are working within a transportation system where resources are already severely taxed?
Like many similar large DOT maintenance organizations, Mn/DOT does not have the budget to do sufficient maintenance on its systems. Therefore, we must put activities that are legally or clearly public safety related at the top of our list when we prioritize resource expenditures - including personnel time and materials. Prior to the proposed ADA requirements becoming law, there needs to be a discussion about expectations of how well these facilities are likely to be maintained with a clear understanding that all railings, signal devices, and surface treatments may not be fully functional at all times. Anything that puts the public in an unsafe condition is something that we must attend to, but if resources are strained we must compare fixing a system that interacts with hundreds or thousands of people above a system or device that substantively interacts with less than a dozen people. If cost is not considered at this time and guidelines are put forward that have cost prohibitive facilities as requirements, it is likely that pedestrian accommodation may be removed from new projects and less desirable improvements will be made to the existing network.
Liability
The guidelines have surfaced the issue of liability. It has been noted in the Mn/DOT response that the guidelines are requesting designers to meet Access Board requirements at the expense of other guidelines and standards that are already in place and enforceable. At this time designers are not being provided guidance on how to negotiate or balance conflicts and that will leave a situation where designers may simply choose not to include treatments. This gap will also invite a wide range of interpretation between the different types of guidance that is available to designers and will subsequently erode the uniformity and predictability that is being sought by Draft Guidelines for Accessible Public Rights of Way. As in the matter of cost the Access Board defers to the Department of Justice once the guidelines are in place, but there are many issues that should be addressed at this stage so that all users of the transportation system will be represented.
In closing Mn/DOT is seeking guidelines that will allow us to improve access within our transportation system and maintain balance between financial, cultural, and operational needs. The Access Board must consider how to responsibly recommend guidelines that can be implemented and will serve the needs of all users. Refinement of the guidelines is clearly needed to reach an acceptable balance point.
General Recommendations
Guideline Usability
To improve the overall usability of the guidelines, the following recommendations are made:
1. Use full citations when there is a cross-reference to another document so users can understand and quickly find the information referenced.
2. Future iterations should have more extensive graphics to illustrate the situations that are being described.
3. Conform to industry practice. (i.e. express grades as a percentage with rise over run in parentheses.)
4. Follow the federal standard for expressing units with metric units first, followed by English units in parentheses (e.g., 3.6 m (12 ft)). To provide additional clarity, Mn/DOT also bolds the English unit in its manuals.
5. Use decimals instead of fractions (e.g., 2.5 rather than 2½).
6. Use consistent unit convention (e.g., inch instead of ")
7. Please provide an indication of what sort of documentation needs to be kept if the implemented design is challenged.
8. The guidelines do not explicitly state that they are design minimums. Perhaps, this is a topic that will be addressed once the guidelines are integrated into ADAAG, but as a stand-alone piece, the guidelines invite the interpretation that they are maximum specifications for facilities. This assumption should not be allowed to stand since there are many instances where facilities should be designed above the minimum recommendation.
Section Analysis
1101 Application and Administration
Section 1101.3 Defined Terms
There are several concerns with terms used within the guidelines because definitions are not clear or unnecessarily deviate from common industry definition. Specific concerns are as follows:
. Blended Transition: Add a definition for this term in this section. The intent of the term is not clear, because a definition is not provided.
. Crosswalk: Simplify the definition. Potential language could be as follows:
o Crosswalk - (1) That portion of a roadway ordinarily included with the connection of sidewalks at intersections; (2) Any portion of a roadway distinctly indicated for pedestrian crossing by lines or other markings on the surface.
. Dynamic Envelope: This is not a standard industry term and needs definition.
. Pedestrian Clearance Interval: A definition is requested for this term. The suggested language is: the interval following the walk interval, normally symbolized by a flashing "Hand" or "Don't Walk."
. Ramp: The following definition is proposed: a sidewalk with a slope greater than 5%, but not exceeding 8.33%.
. Running Slope: For clarity, it is requested that this term be removed and that the term "grade" be used exclusively.
. Superelevation: For clarity, it is requested that this term be removed and that the term "cross slope" be used exclusively.
. Technically Infeasible: Add a definition for this term in this section. The intent and appropriate application of the term is not clear, because a definition is not provided.
1102 Scoping Requirements
Section 1102.2 Alterations
Guideline Language: Where existing elements or spaces in the public right-of-way are altered, each altered element or space shall comply with the applicable provisions of Chapter 11.
EXCEPTION: An alteration where compliance is technically infeasible, the alteration shall comply to the maximum extent feasible.
Requested Change: 1. Additional clarity needs to be provided for the thresholds of alteration either through expanded language in the proposed guidelines or a reference to already existing language.
2. It is recommended that the explanation of technically infeasible found in section 4.1.6 of the July 26, 1991 Federal Register Part III, 28 CFR, Part 36 be restated here along with the exceptions that are within the purview of these guidelines.
Suggested Language: No recommendations.
Justification: The first change is needed to create clarity regarding when the guidelines should be used. As the guidelines are currently written it is unclear as to what types of projects the ADA requirements apply. Mn/DOT's view is that the maintenance and minor improvement categories where the objective is to keep a facility smooth and open to traffic should be excluded. The second change is requested to provide a clear definition and guidance on the applicability of "technically infeasible" in relation to the guidelines. Given the volume of physical area that right-of-way covers, it would be reasonable to explicitly expand the definition of "technically infeasible" to include environmental site constraints and adverse environmental, social, community, and transportation system user impacts.
Section 1102.5.2 Post-Mounted Objects
Guideline Language: Free-standing objects mounted on posts or pylons shall overhang circulation paths 305 mm (4 in) maximum when located 685 mm (27 in) minimum and 2030 mm (80 in) maximum above the finish floor or ground. Where a sign or other obstruction is mounted between posts or pylons is greater than 305 mm (12 in), the lowest edge of such sign or obstruction shall be 685 mm (27 in) maximum or 2030 mm (80 in) minimum above the finish floor or ground.
EXCEPTION: This requirement shall not apply to sloping portions of handrails serving stairs and ramps.
Requested Change: Reword.
Suggested Language: Free-standing objects mounted on posts or pylons shall overhang circulation paths 100 mm (12 in) maximum when located 685 mm (27 in) minimum and 2030 mm (80 in).
Justification: The suggested change would result in uniform interpretation and application of the proposed guidelines between other guidelines already in force. The 12-inch maximum was established in 1991 under section 4.4.1 of the July 26, 1991 Federal Register, Part III, 28 CFR, Part 36 and is included in the ADAAG Section 307 referenced below. This guideline change will allow for uniform design of integrated roadway and multi-use projects and the development of uniform design standards for both site and roadway facilities.
307 Protruding Objects
307.1 General. Protruding objects shall comply with 307.
307.3 Post-mounted Objects. Free-standing objects mounted on posts or pylons shall overhang 305 mm (12 in) maximum when located 685 mm (27 in) minimum and 2030 mm (80 in) maximum above the floor or ground. Where a sign or other obstruction is mounted between posts or pylons and the clear distance between the posts or pylons is greater than 305 mm (12 in), the lowest edge of such sign or obstruction shall be 685 mm (27 in) maximum or 2030 mm (80 in) minimum above the floor or ground.
Section 1102.7.1 Bus Route Identification
Guideline Language: Bus route identification signs shall comply with 703.5.1 through 703.5.4, and 703.5.7 and 703.5.8. In addition, to the maximum extent practicable, bus route identification signs shall comply with 703.5.5. Bus route identification signs located at bus shelters shall provide raised and Braille characters complying with 703.2, and shall have rounded corners.
EXCEPTIONS:
1. Bus schedules, timetables and maps that are posted at the bus stop or bus shelter shall not be required to comply with 1102.7.
2. Signs shall not be required to comply with ADAAG Section 703.2 where audible signs are user or proximity-actuated or are remotely transmitted to a portable receiver carried by an individual.
Requested Change: Delete text referencing non-existing sections of the proposed guideline changes in ADAAG Section 703.
Suggested Language: Bus route identification signs shall comply with ADAAG Sections 703.5.1 through 703.5.4. Bus route identification signs located at bus shelters shall provide raised and Braille characters complying with ADAAG Section 703.2, and shall have rounded corners.
Justification: Section 703.5.5, 703.5.7, and 703.5.8 are not published on the Access Board Web site. Until this text is available for review, references to these sections should be deleted due to the inability of the public to provide adequate review of conditions and impacts.
Section 1102.10 Stairs
Guideline Language: Where provided, stairs shall comply with 504. Stair treads shall have a 51mm (2 in
Requested Change Delete the requirement for color strip.
Suggested Language: Where provided, stairs shall comply with ADAAG Section 504.
Justification: The existing standardized handrail design in accordance with ADAAG Section 504 extends horizontally at the top, bottom and landings of the stairs to delineate the edge of a transition change (edge of stair system). This is the most effective tool to communicate stair locations to a disabled person at all times of day and in all weather conditions. If necessary modify the handrail design guidelines to better communicate the location of the stair system. The addition of a strip of contrasting color is not justified and cannot be adequately maintained with the limited resources available.
The ability to develop a design solution that will meet both public safety and maintenance considerations, without creating a high level of liability, is highly questionable. Any system not maintained will present a liability for the transportation agencies.
Paint: non-permanent, often slippery when wet, high cost to maintain.
Nosing Material: often slippery when wet, a mix of materials allows a point of moisture and salt infiltration that will shorten the life of the structure.
Adhesives: non-permanent, maybe slippery when wet or snow covered, high cost to maintain, frequently delaminates in heat and cold conditions creating loose edges/trippers.
Visibility in snow conditions: not visible under snow cover.
Visibility at night without lighting:
The use of a well-designed handrail system is more useful and visible in all conditions and fully provides a reasonable accommodation for individuals of all abilities.
Context Sensitive Design/Aesthetic Considerations
A color edge strip of high contrast will visually dominate the setting and negatively impact community design objective to blend roadway elements sympathetically with architectural elements and the natural environment.
Section 1102.13 Bus Stops.
Guideline Language: Bus boarding and alighting areas shall comply with 810.2. Bus shelters shall comply with section 810.3.
Requested Change: Delete information referencing non-existing sections of the proposed guideline changes in Sections 810.2 and 810.3 of the ADAAG.
Suggested Language: Not Applicable.
Justification: Sections 810.2 and 810.3 of the ADAAG are not published on the Access Board Web site. Until this text is available for review all references to these sections should be deleted due to the inability of the public to provide adequate review of conditions and impacts.
Section 1102.14 On-Street Parking
Guideline Language: Where on-street parking is provided, at least one accessible on-street parking space shall be located on each block face and shall comply with 1109.
Requested Change: 1.Reword the original statement with additional text to allow for alternative compliance with the objectives of close easy access.
2.Clarify the definition of a block.
3. Clearly state the intent of the Access Board for this requirement to apply only to commercial areas.
Suggested Language: Where on-street parking is designated by striping or parking meters, on-street accessible parking stalls shall be uniformly distributed along the block faces at a ratio in compliance with Table 208.2 of the ADAAG and shall comply with 1109.
EXCEPTION: Accessible public off-street parking is provided within the block at a ratio of one parking stall per 25, with a minimum of one parking space for the total of all public parking spaces available per block, for both off-street and on-street parking.
Justification: Require On-Street Parking Only in High Use, Designated Public Parking Areas.
This requirement seems to be better targeted to designated parking, striped parking and metered parking. The requirement for one parking space along each curb face in all locations where parking is provided seems excessive. In many cities parking is allowed/provided in all residential areas. On-street parking spaces should not be required in non-commercial areas.
Proposed Distribution of On-Street Parking Seems Excessive
Mn/DOT agrees that a reasonable amount of On-Street parking needs to be provided, however, physical constraints must be considered. The size of a block varies by region and local urban design applications. Blocks in many Midwest communities provide no more than 6 parallel parking stalls per block face due to the curb space reserved for bus stops, driveways, passenger loading zones, service entrances and no parking zones such as at fire hydrants and turn lanes. For many communities this will reduce local parking supply for the general population by more than 17%. This ratio can be as high as 4 times or more than are required for private businesses and public facilities as specified in Table 208.2 of the ADAAG.
The number and type of businesses served by on-street parking also varies widely based on local zoning. For these reasons, use of a minimum criterion of two per block and a ratio of the total parking stalls available is recommended to establish the number of On-Street Parking spaces required.
Provide Local Governments with Design/Location Flexibility to meet the objectives
Managed parking is a local government function related to "zoning". It seems reasonable to allow for off-street parking within the same area that is designated as accessible parking only (perhaps in parking ramps). Given the grade and cross slope of many roadways, on-street parking spaces will often exceed the desired surface slope 2% (1:48) for the access aisle.
1102.15 Passenger Loading Zones
Guideline Language: Where passenger loading zones are provided, they shall connect to a pedestrian access route and shall provide a minimum of one passenger loading zone in every continuous 100 linear feet (30 m) of loading zone space, or fraction thereof, complying with 302, 503.2, 503.3, and 503.5.
Requested Change: Rewrite section and/or add an exception.
Suggested Language: EXCEPTION: Passenger loading zones are not reserved exclusively for disabled persons and shall not be identified by signage.
Justification: In reviewing this issue with Access Board staff, it is not intended that the passenger loading zones are reserved for exclusive use by disabled persons; however, the text makes this unclear and a conflict exists within other areas of the proposed draft ADA Guidelines Section 1-10.
1103 Pedestrian Access Route
Section 1103.1 General
Guideline Language: Pedestrian access routes shall connect to elements required to be accessible and shall comply with 1103.
Requested Change: Rephrase for better understanding.
Suggested Language: Pedestrian access routes shall connect elements that are required to be accessible and shall comply with Section 1103.
Justification: Not Applicable
Section 1103.4 Cross Slope
Guideline Language: The cross slope of the pedestrian access route shall be 2% (1:48) maximum.
Requested Change: Rephrase and add exception.
Suggested Language: The maximum cross slope of pedestrian access routes shall be 2% (1:48). EXCEPTION: The maximum cross slope of a crosswalk can exceed 2% (1:48) when a disruption in the roadway profile is created that consequently creates a safety hazard. There shall be no cross-slope requirements for midblock crossings.
Justification: Meeting the 2% (1:48) slope requirement would often introduce objectionable profile variations into the roadway, and may even become a safety hazard for motorists and bicyclists.
The proposed slope will impact our ability to drain intersections. The larger the intersection, the more difficult drainage becomes. The introduction of a flat grade would require extensive transitions in and out of them, especially at high-speed intersections. If further restrictions are in place, the design would result in a very rough ride through the intersection including vaulting and dragging of trailers and/or hitches.
Because this maximum cross slope may create a bump in the road, vehicle contact with the pavement will be reduced, thus reducing braking and maneuvering ability.
Section 1103.5 Grade
Guideline Language: The grade of the pedestrian access route within a sidewalk shall not exceed the grade established for the adjacent roadway.
EXCEPTION: The grade of a pedestrian access route shall be permitted to be steeper than the grade of the adjacent roadway, provided that the pedestrian access route is less than 1:20
Requested Change: Change wording to clarify.
Suggested Language: The grade of the pedestrian access route within a sidewalk shall not exceed the grade established for the adjacent roadway, even if the roadway is greater than 5% (1:20).
EXCEPTION: The permissible grade of a pedestrian access route may be steeper than the grade of the adjacent roadway, provided that the pedestrian access route is less than 5% (1:20), or complies with Section 405, "Ramps" of the ADAAG.
Justification: Not Applicable
Section 1103.6 Surfaces
Guideline Language: The surfaces of the pedestrian access route shall comply with 302.
Requested Change: Change wording to clarify.
Suggested Language: The surfaces of pedestrian access routes shall comply with Section 302, Floor and Ground Surfaces of the ADAAG.
Justification: A full citation of other referenced guidelines is needed for clarity and uniform application of guidelines.
Section 1103.8 Changes in Level
Guideline Language: Changes in level shall comply with 303. Changes in level shall be separated horizontally 30 inches
EXCEPTION: The horizontal separation requirement shall not apply to detectable warnings.
Requested Change: Change wording to clarify.
Suggested Language: Changes in level shall comply with ADAAG Section 303 and shall be separated horizontally by a minimum of 760 mm (30 in).
EXCEPTION: The horizontal separation requirement shall not apply to detectable warnings.
Justification: A full citation of referenced guidelines is needed for clarity and uniform application of guidelines. Additionally, the concerns raised in the AASHTO response regarding maintenance and oversight of this treatment should also be considered.
1104 Curb Ramps and Blended Transitions
Section 1104.2.1 Perpendicular Curb Ramps
Guideline Language: Perpendicular curb ramps shall comply with 1104.2.1, and shall have a running slope that cuts through the curb at right angles or meets the gutter grade break at right angles.
Requested Change: Include language from the discussion section emphasizing that this is a "should" rather than a "shall" condition.
Suggested Language: Where conditions permit, it is preferable to have separate curb ramps at a corner instead of a single ramp. Perpendicular curb ramps shall comply with 1104.2.1, and shall have a grade that cuts through the curb at right angles or meets the gutter grade break at right angles.
Justification: There are many space constraints at intersections that may not always allow for the inclusion of perpendicular curb ramps. The options need to be clear to designers.
Section 1104.2.2 Parallel Curb Ramps
Guideline Language: Parallel curb ramps shall comply with 1104.2.2, and shall have a grade that is in-line with the direction of sidewalk travel.
Requested Change: Rephrase to include language for safety consideration.
Suggested Language: In limited situations where safety will not be further compromised parallel curb ramps shall comply with 1104.2.2, and shall have a grade that is in-line with the direction of sidewalk travel.
Justification: Parallel ramps can be hazardous in northern climates when a grade is introduced in-line with the main direction of travel.
Section 1104.2.3 Blended Transitions
Guideline Language: Blended transitions shall comply with 1104.3, and shall have running and cross slopes of 1:48
Requested Change: Rewrite section to qualify that blended transitions should not be recommended in many circumstances due to a variety of safety concerns.
Suggested Language: None recommended.
Justification: The language of the guidelines should be flexible and allow designers to deal with safety issues on a case by case basis.
Section 1104.3.3 Surfaces
Guideline Language: Surfaces of curb ramps, blended transitions, and landings shall comply with 302. Gratings, access covers, and other appurtenances shall not be located on curb ramps, landings, blended transitions, and gutter areas within the pedestrian access route.
Requested Change: Change from a "shall" to a "should" condition.
Add third qualifying sentence.
Suggested Language: In alteration and reconstruction projects, access covers and other appurtenances should be avoided on curb ramps, etc. Any access covers that must remain shall be flush and free of vertical variation 6 mm (0.25 in) or horizontal gaps of 13 mm (0.50 in).
Justification: Prohibition of gratings, access covers and other appurtenances in curb ramps, landings and blended transitions is too restrictive and impractical at some intersections when it seems that the real intent is only to provide an accessible pedestrian route free of hazards. A reasonable and practical option is to allow for access covers that are flush and without vertical variations exceeding 6 mm (0.25 in) or horizontal openings exceeding 13 mm (0.50 in).
Section 1104.3.7 Clear Space
Guideline Language: Beyond the curb line, a clear space of 48 inches
Requested Change: Change from a "shall" condition to a "preferred" condition.
Suggested Language: Beyond the curb line, a clear space of 1120 mm (48 in) minimum by 1120 mm (48 in) minimum is recommended within the width of the crosswalk and wholly outside the parallel vehicle travel lane.
Justification: Requiring a 1.2 m (48 in) clear space beyond the curb may be very difficult and costly to achieve at many intersections constrained by adjacent building development, etc. The justification for this requirement should be re-evaluated. This proposed requirement necessitates a 1.2 m (48 in) minimum shoulder or reaction distance in sections where only a 0.6 m (24 in) reaction distance is normally required. The likely use of the intended clear space by turning vehicles would present a safety problem for pedestrians if they were not staying on the sidewalk until it is permissible to cross. The clear space may provide a dangerously false sense of security for the pedestrian and even with striping, it is likely to be disregarded or misunderstood by motorists.
1105 Pedestrian Crossings
Section 1105.2.1 Width
Guideline Language: Marked crosswalks shall be 96 inches
Requested Change: Reword to reflect current MUTCD practice.
Suggested Language Marked crosswalks shall be a minimum of 1830 mm (72 in) wide. A 2440 mm (96 in) width is desirable.
Justification: Because it is possible that the 2440 mm (96 in) crosswalk would create a problem with the existing loop detector systems if moved toward the stop bar, the additional width would likely move pedestrians closer to the through traffic. The most frequently used sidewalk width in Minnesota is 1525 mm (60 in). Additionally, there is no clear benefit derived from providing a wider crosswalk.
Section 1105.2.2 Cross Slope
Guideline Language: The cross slope shall be 1:48
EXCEPTION: This requirement shall not apply to mid-block crossings.
Requested Change: Change from a "shall" to a "desired" condition.
Add an additional exception.
Suggested Language: The maximum cross slope of the pedestrian access route shall be 2% (1:48).
EXECPTION: The maximum cross slope of a crosswalk can exceed 2% (1:48) only if it does not cause a disruption to the roadway profile that would consequently create a safety hazard.
EXCEPTION: This requirement shall not apply to mid block crossings.
Justification: For profile grades greater than 2% (1:48) the designer needs to provide a flat or "tabled area" through the intersection to meet the required cross slope. To do this on a high-speed roadway will result in a forced profile grade with short vertical curves. Automobile drivers will feel a weightlessness effect going over such a profile. This same effect on trucks could create a very serious safety hazard. Criteria need to be developed as to when and where this should be applied. As the guidelines are currently presented, a designer would have a serious conflict in applying this criteria.
Section 1105.2.3 Running slope
Guideline Language: The running slope shall be 1:20
Requested Change: Increase the running maximum running slope to 6% (1:16).
Suggested Language: The grade shall be 6% (1:16) maximum measured parallel to the direction of pedestrian travel in the crosswalk for a maximum length of 38 feet
Justification: Using a 1:16
Section 1105.3 Pedestrian Signal Phase Timing
Guideline Language: All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 0.91 m/s (3.0 ft/s) maximum. The total crosswalk distance used in calculating pedestrian signal phase timing shall include the entire length of the crosswalk plus the length of the curb ramp.
Requested Change: Use the proposed pedestrian signal timing on pedestrian crossings where such timing does not force an increase in cycle length above that required using current pedestrian timing. Where the proposed pedestrian signal timing would force an increase in the cycle length, the proposed timing should only be used upon request by the public or the municipality and after an engineering study has shown there is an actual need for the extended time.
Justification: Pedestrian timing requirements are often a controlling factor of the cycle length that can be run at an intersection. Extending the pedestrian timing requirements will require longer than optimum cycle lengths at many or most intersections, resulting in an increase in vehicle delay, pollution, and fuel usage and also a delay to pedestrians waiting to cross. Increases in congestion have been associated with reduced safety. If this were to be implemented at every intersection in the US, the resulting detriment to travelers and the environment would be staggering.
Additionally, with a longer pedestrian clearance time, pedestrians will soon learn that they can still easily make it across the street even if the "Don't Walk" is already flashing. This will encourage pedestrians to begin crossing the street during the flashing "Don't Walk", which is illegal and unsafe. Pedestrians who need more time to cross can currently have more time by starting to cross at the beginning of the walk period. The clearance time assumes pedestrians start walking at the very end of the walk period.
A computerized traffic simulation/optimization program (Synchro) calculated the impact of changing from our current pedestrian timing to the proposed timing at 5 of our signalized intersections to be as follows:
Total signal delay: increased 22 - 23%
Stops: increased 6 - 10%
Average speed: decreased 9-11%
Fuel consumed: increased 5 - 9%
Section 1105.4.2 Detectable Warnings
Guideline Language: Medians and refuge islands shall have detectable warnings complying with 1108. Detectable warnings at cut-through islands shall be separated by a 24-inch (610mm) minimum length of walkway without detectable warnings.
EXCEPTION: Detectable warnings shall not be required on cut-through islands where the crossing is controlled by signals and is timed for full crossings.
Requested Change: Reword exception.
Suggested Language: EXCEPTION: Detectable warnings shall not be required on cut-through islands where the crossing is controlled by signals and is timed for full crossings or when the median is four feet or less.
Justification: In situations where a four foot median is used, the Detectable Warning Surface would provide no benefit, since there is no break in the surface for the entire width of median.
Section 1105.5 Pedestrian Overpasses and Underpasses
Guideline Language: Pedestrian overpasses and underpasses shall comply with 1105.5.
Requested Change: Add an exception to clarify that this guideline applies to the intersection of two sidewalk systems connecting services, and does not apply to trails and paths intersecting with sidewalks.
Suggested Language: Pedestrian overpasses and underpasses shall comply with 1105.5.
EXCEPTION: Applies to sidewalks only.
Justification: There are numerous trails and paths, designed for multiple non-motorized user groups, including bicycles and pedestrians, which are exempt from these guidelines. Clarification is required to ensure appropriate application of the guidelines.
Section 1105.5.3 Approach
Guideline Language: Where the approach exceeds 1:20
Requested Change: Change provision for elevators from a "shall" condition to a "may" condition.
Reconsider the 60 inches
Suggested Language: Where the slope of the ramp exceeds 5% (1:20), the approach shall be a ramp 1220 mm (48 in) minimum in width and shall comply with Section 405 of the ADAAG. Where the rise of a ramped approach exceeds 2440 mm (96 in), an elevator complying with ADAAG Section 407, or a limited-use/limited-application elevator complying with ADAAG Section 408, may be provided.
Justification: Need not Justified:
Pedestrian bridges are a supplement to other forms of transportation already available in the community. Because of the availability of alternative modes, such as vehicles and special transit services, within a community an elevator should not be mandatory unless it is the only reasonable route available between public services.
Construction Cost:
The high construction costs of the elevators will substantially increase the cost of a pedestrian bridge for its owners. The outcome of the increased cost is that the benefit/cost ratio of a bicycle/pedestrian bridge with an elevator will not allow transportation agencies to justify the construction of a bicycle/pedestrian bridge with an elevator except in the most extreme locations. Additionally, the safety value that these bridges provide to the general public will be denied to everyone if pedestrian overpasses and underpasses become cost prohibitive to build.
In cold regions such as Minnesota, an elevator enclosure may be required increasing the cost of the elevator and enclosure well above the cost of the pedestrian bridge.
Operations Maintenance:
To meet the proposed requirement will also demand significant cost in the area of operation and maintenance. Most transportation agencies will need to contract this service out due to expertise and licensing required to service this equipment which will reduce flexibility with already limited funding. Additionally, a high level of vandalism and misuse by individuals without disabilities is very likely to occur at these unsupervised facilities thereby increasing maintenance and liability costs.
No documentation was provided to indicate that the reliability of elevators in cold climate that are fully exposed to all weather conditions, which will exist on the right-of-way, is available or that they have been tested to operate with minimal failure in severe summer and winter, snow and ice conditions. Research on these topics is requested before developing a requirement
Personal Safety and security:
Surveillance and security systems will be required by agencies to monitor activity in the elevators. Most public elevators are monitored with cameras to avoid assaults, etc. This will require extensive infrastructure, staff, and contract funds to perform this monitoring.
Liability:
The investment of significant personnel and funding resources are required to keep elevators in operation and to respond to equipment failures. Given Minnesota's wide range of climatic conditions a user would be placed at a great health risk if an elevator system stalls and they became trapped in a stalled elevator for even a short period of time in sub-zero temperatures or over 100 degree
Section 1105.6.1 Separation
Guideline Language: Continuous barriers shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited. Where railings are used, they shall have a bottom rail 15 inches
Requested Change: Clarify what materials and treatments may be considered for the development of a continuous barrier.
Remove requirement for a continuous barrier.
Suggested Language: A continuous grass berm shall be provided along the street of the sidewalk where pedestrian crossing is prohibited.
Justification: Requiring a physical separation seems to be an unreasonable requirement to apply only to roundabouts. There are many street configurations that are not normal perpendicular intersections and railings are not required for them. Most roundabout designs have grass berms around them so visually impaired persons can detect when leaving the sidewalk.
Section 1105.6.2 Signals
Guideline Language: A pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the crosswalk, including the splitter island. Signals shall clearly identify which crosswalk segment the signal serves.
Requested Change: Remove the requirements for pedestrian activated traffic signal and research this issue. Research might include evaluation of surface treatments to help a visually impaired person detect an approaching vehicle.
Suggested Language: No language is recommended at this time.
Justification: Minnesota requires motorists to yield to pedestrians in the crosswalk, as do most states. The crosswalk is set back one car length, which helps to make the crosswalk perpendicular to the roadway. In addition with this placement the pedestrian is crossing in front of the driver as they approach before the driver starts to prepare for the merge. Roundabouts have low-speed traffic with good visibility of the crosswalk areas. This concept also has some of the lowest collision rates of any traffic control device. There is no accident history to support a pedestrian activated signal system.
There are a number of advantages that roundabouts have for pedestrians. First, the number of conflict points is much lower. A pedestrian at a roundabout has 2 conflict points (entering and exiting right turners) compared with 6 conflicts at a standard four-leg intersection. No hazardous left-turn movements are present. Second, severe crashes caused by inattentive driving are eliminated. Crashes that occur when motorists run red lights, ignore stop signs, and make right turns on red do not happen at roundabouts. The design forces a driver to slow down and pay attention. Third, pedestrian exposure to traffic is much lower because the crossings are shorter. The splitter islands at the roundabout approaches allow people to cross one lane of slow-moving traffic at a time, instead of four lanes of traffic that would likely be traveling very fast through a signalized intersection. A pedestrian activated signal requirement would certainly discourage the use of roundabouts and those benefits would be lost to the pedestrian.
Section 1105.7 Turn Lanes at Intersections
Guideline Language: Where pedestrian crosswalks are provided at right-or left-turn slip lanes, a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island.
Requested Change: Eliminate pedestrian activated signal requirement.
Use the more common industry term of "free rights" rather than "slip lanes".
Suggested Language: Where pedestrian crosswalks are provided at free right turns, a painted crosswalk shall be provided.
Justification: The proposed language would require accessible pedestrian signals at locations where there are currently no signals, accessible or not. See the previous comment supporting the installation of accessible pedestrian signals only upon request and with an engineering study. Some of these locations may have no pedestrian activity of any sort and would not require any pedestrian signals, accessible or not, except for this requirement. Guidance as to where this criterion would be applied should be developed.
Also, to put in the pedestrian signals would also require installation of vehicle indications on these lanes, requiring all vehicles turning right to stop on red. Currently, there are yield sign controls on these lanes. At a location where no pedestrians are present, requiring every vehicle to stop at a new red signal indication will create significant delays, pollution, and fuel consumption.
The issue of signalizing free-right movement needs research that addresses the placement of signal heads and stop bars that will be visible to motorists and the development of warrants for the application of the free-right island. Signalized intersections, even with pedestrian indications, do not ensure the safety of pedestrians in the crosswalk. Adding signal control to the free-right will confuse drivers and induce a false sense of security for pedestrians. Unless a significant pedestrian demand is present, this could add the potential for massive violations.
1106 Accessible Pedestrian Signal Systems (APS)
Section 1106.2 Pedestrian Signal Devices
Guideline Language Each crosswalk with pedestrian signal indication shall have a signal device, which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device and shall comply with 1106.3.
Requested Change: Change "shall" condition to "should" and "may" condition to allow for the use of engineering judgement to determine need on a case by case basis or remove the requirement. If the requirement is retained, additional guidance on determining when to install APS is needed.
Suggested Language: Each crosswalk with pedestrian signal indication should have a signal device that may include audible and vibrotactile indications of the WALK interval where needed. Where a pedestrian pushbutton is provided, it should be integrated into the signal device and comply with 1106.3.
Justification: The recommendation to change the requirement from "shall" to "should" is based upon the fact that there is not clear agreement that APS is warranted for all situations. In Minnesota there is not consensus among people who are visually impaired as to whether the accessible pedestrian indications are an improvement or a hindrance in crossing the roadway. One strong point of view that has been conveyed to Mn/DOT is that the accessible pedestrian systems mask the primary cue created by the sound of traffic, reducing accessibility for some users. However, there is consensus among persons who are visually impaired that accessible pedestrian signals need not be installed at all locations and that guidelines can be developed to identify appropriate locations based on requests and engineering studies.
Section: 1106.2.1 Location
Existing Language: Pedestrian signal devices shall be located 60 inches
EXCEPTION: The minimum distance from other signal devices shall not apply to signal devices located in medians and islands.
Requested Change: Change these distances to goals, with shorter distances as the minimum requirement.
Suggested Language: No language recommended.
Justification: Due to wide variation in the geometry and constraints found at each intersection, there are likely to be many instances where the implementation of such precise requirements will be infeasible, especially in reconstruction projects.
Section 1106.4 Directional and Information Signs
Guideline Language: Pedestrian signal devices shall provide tactile and visual signs on the face of the device or its housing or mounting indicating crosswalk direction and the name of the street containing the crosswalk served by the pedestrian signal.
Requested Change: All sign designs should be in conformance with the Manual on Uniform Traffic Control Devices (MUTCD).
Suggested Language: See the MUTCD for language and specifications.
Justification: Uniformity is essential in the design and application of traffic control devices to ensure user safety. Recommendations that deviate from recognized standards compromise that safety.
1107 Street Furniture
Section 1107.2 Clear Floor or Ground Space
Guideline Language: Street furniture shall have clear floor or ground space complying with 305 and shall be connected to the pedestrian access route. The clear floor or ground space shall overlap the pedestrian access route by 12 inches
Requested Change: Reword second sentence for clarity.
ADAAG Section 305.2 requires a 2% (1:48) slope on the clear floor and ground space that can be accommodated in the sidewalk cross slope direction but not the direction of the grade of the sidewalk. Create an exception to document this.
Suggested Language: The clear floor or ground space may overlap the pedestrian access route by 305 mm (12 in) maximum.
EXCEPTION: The slope of the clear floor or ground may be steeper than 2% (1:48) in the direction of the running slope for the sidewalk, but shall not exceed the grade established for the adjacent roadway.
Justification The text of the second sentence is confusing. It seems to read as a requirement for the clear floor or ground space to overlap into the pedestrian access route without stating why an overlap would be desirable. It is more appropriate to minimize the overlap to no more than 305 mm (12 in) as long as access to the furniture is compliant with appropriate provisions for this guideline.
Clarification and Exception required for 2% (1:48) slope on clear floor or ground
It is critical to point out the proposed exception to Section 305.2 of the ADAAG because it will be technically infeasible to meet the 2% (1:48) slope in the direction of the grade of the sidewalk in the same way that it is infeasible for sidewalks to meet the 5% (1:20) maximum slope requirements.
Section 1107.4.1 Single Telephone
Guideline Language: Where a single public telephone is provided, it shall comply with 704.2 and 704.4.
Requested Change It is strongly recommended that a separate process be initiated to seek legislation that will place and fund the implementation of this guideline with the Public Communications Commission/Public Pay Phone Companies for all public pay phones in the nation.
Add an exception to allow compliance with ADAAG Sections 704.2 and 704.4. The exception will allow for the necessary design for Clear Floor and Ground Space found in section 1107.2
Suggested Language: EXCEPTION: The slope of the clear floor or ground space may be steeper than 2% (1:48) in the direction of the grade for the sidewalk, but shall not exceed the grade established for the adjacent roadway.
Justification This requirement may reduce the total number of public phones installed due to the requirement to provide electrical services and maintain the equipment.
TTY equipment is often purchased and owned directly by the transportation agency, not leased from the phone companies, due to cost of equipment over time. Historically, many smaller phone companies have not offered leasing or maintenance of this equipment. Maintenance of the equipment is problematic in that only the phone company operating the public pay phone has the legal authority to connect and disconnect TTY equipment into the public phone systems. It is impossible for transportation agency staff to effectively maintain this equipment on public phones on right-of-way.
For this reason it is strongly recommended that a separate process be initiated to seek federal legislation requiring the public pay phone companies to provide this service in accordance with these guidelines and collect a public surtax to cover the cost.
See the Following Sections for Additional Comments for this Item
1107.2 Clear Floor or Ground Space: Justification: Clarification and Exception required for 2% (1:48) slope on clear floor or ground space.
Section 1107.4.2 Multiple Telephones
Guideline Language: Where a bank of public telephones is provided, at least one telephone shall comply with 704.2, and at least one additional telephone shall comply with 704.4.
Requested Change: See comments for 1107.4.2 above for references to Sections 704.2 and 704.4 of the ADDAG.
Add a definition for "a bank of public telephones".
Add exception.
Suggested Language: No language is recommended at this time for "a bank of public telephones".
EXCEPTION: The slope of the clear floor or ground space may be steeper than 2% (1:48) in the direction of the running slope for the sidewalk, but shall not exceed the grade established for the adjacent roadway.
Justification: See comments provided under Justification for sections:1107.2 Clear Floor or Ground Space and 1107.4.1 Single Telephone.
Section 1107.5 Public Toilet Facilities
Existing Language: Permanent or portable public toilet facilities shall comply with 603. At least one fixture of each type provided shall comply with 604 through 610. Operable parts, dispensers, receptacles, or other equipment shall comply with 309.
EXCEPTION: Where multiple single-user toilet facilities are clustered at a single location, at least 5 percent , but no fewer than one single-user toilet at each cluster shall comply with 603 and shall be identified by the International Symbol of Accessibility complying with 703.7.2.1.
Requested Change: Delete reference to the Sections of the ADAAG that are not appropriate for roadside toilets. These sections include 607-608 referring to tubs and showers and Section 610 referring to tub and shower seats.
Suggested Language: Permanent or portable public toilet facilities shall comply with ADAAG Section 603. At least one fixture of each type provided shall comply with ADAAG Sections 604 through 606 and 609.
Justification: Transportation agencies do not provide mixed-use facilities (living or service spaces with showers) on the right-of-way that are not already covered under other sections of the building and site facilities chapter of the ADA guidelines
Section 1107.6 Tables, Counters, and Benches
Guideline Language: Tables, counters, and benches shall comply with 1107.6
Requested Change: Reword.
Suggested Language: Stationary tables, counters, and benches shall comply with 1107.6.
Justification: Designate that this guideline applies to stationary (fixed location) furniture only. Non-fixed objects of this type (often temporarily placed) are highly movable by one or two persons because they are small and lightweight. It is impossible to control the location of and accessibility to movable benches and tables, etc.
Section 1107.6.1 Tables
Guideline Language: Where tables are provided in a single location, at least 5 percent but no less than one, shall comply with 902.
Requested Change: Add an exception.
Suggested Language: EXCEPTION: The slope of the clear floor or ground may be steeper than 2% (1:48) in the direction of the grade of the sidewalk, but shall not exceed the grade established for the adjacent roadway.
Justification: See the Following Sections for Additional Comments for this Item
1107.2 Clear Floor or Ground Space: Justification: Clarification and Exception required for 2% (1:48) grades on clear floor or ground space.
Section 1107.6.2 Counters
Guideline Language: Where provided, counters shall comply with 904.
Requested Change: Add an exception.
Suggested Language: EXCEPTION: The slope of the clear floor or ground may be steeper than 2% (1:48) in the direction of the grade of the sidewalk, but shall not exceed the grade established for the adjacent roadway.
Justification See the Following Sections for Additional Comments for this Item
1107.2 Clear Floor or Ground Space: Justification: Clarification and Exception required for 2% (1:48) slope on clear floor or ground space.
Section 1107.6.3 Benches
Guideline Language: Where benches without tables are provided at a single location, at least 50 percent, but no fewer than one, shall comply with 903 and shall have an armrest on at least one end.
Requested Change: Add an exception
Suggested Language: Where benches without tables are provided at a single location, at least 20%, but no fewer than one, shall comply with Section 903 of the ADAAG.
EXCEPTION: The slope of the clear floor or ground may be steeper than 2% (1:48) in the direction of the grade of the sidewalk, but shall not exceed the grade established for the adjacent roadway.
Justification: Design flexibility should allow for the use of benches without backs mixed with benches with backs at a ratio of 1:5
Unless unique conditions exist that justify conflicting guideline requirements for the same element within the ADA, guideline chapters should be uniform to avoid inconsistencies in design application and enable uniformity in enforcement.
1108 Detectable Warning Surfaces
Section 1108.1 General
Guideline Language: Detectable warnings shall consist of a surface of truncated domes aligned in a square grid pattern and shall comply with 1108.
Requested Change: Omit the requirement pending further study.
Suggested Language: Delete section and all related references.
Justification: Numerous comments have been brought forward regarding the maintenance of these facilities in cold weather climates. In particular, there is concern that the complete and timely clearing of the facilities after a snow event may not be possible and could create a hazardous situation for all users and become a liability risk. At this time, it is recommended that the Access Board sponsor additional research to develop best practices regarding the maintenance of truncated domes.
Concern has also been raised about how the use of truncated domes impacts skateboarders, scooter and in-line skate users. Research sponsored by the State of Florida with Charlie Zeeger P.E. as principle investigator, has shown that truncated domes consistently "down" this user group as they attempt to navigate the truncated domes. The result is that accommodation of one user group occurs at the expense of another, and communities are being asked to knowingly create a hazardous condition, which may not be legally defensible. This is not an acceptable or appropriate situation and it is strongly recommended that the Access Board continue to research other treatments that will allow for the accommodation of all user groups.
1109 On Street Parking
Section 1109.1 General
Guideline Language: Car and van on-street parking spaces shall comply with 1109.
Requested Change The Access Board should develop a paragraph specifying when a van space should be provided instead of a car space.
Suggested Language: No language is being recommended at this time.
Justification: Equal access cannot be guaranteed to all user types if a reasonable ratio of van spaces is not provided in the urban areas. A distribution based on Parallel Parking Spaces (access aisle at least 1.5 m (5 ft) vs. Perpendicular or Angled Parking Spaces (Where an access aisle is 2.4 m (8 ft) is insufficient. This is an unreasonable approach to providing reasonable accommodations because it does not ensure that a van stall will be provided within a multi-block area. At this time the ADAAG requires the van stalls have a 2.4 m (8 ft) aisle.
Section 1109.2 Parallel Parking Spaces.
Guideline Language: An access aisle at least 60 inches
EXCEPTION: An access aisle is not required where the width of the sidewalk between the extension of the normal curb and boundary of the public right-of-way is less than 14 feet
Requested Change: Add text to reflect bicycle safety concerns.
Due to environmental and existing road conditions it is not reasonable to develop a 2% (1:48) level access aisle at all locations.
Provide exceptions.
Suggested Language: The access aisle shall not encroach on the vehicular travel lane or on the bicycle travel lane.
1. EXCEPTION: An access aisle is not required where the width of the sidewalk between the extension of the normal curb and boundary of the public right-of-way is less than 4874 mm (16 ft). When an access aisle is not provided, the parking space shall be located at the end of the block face.
2. EXCEPTION: Although the access aisles are also used for wheelchair transfer to and from vehicles, the slope may be steeper than 2% (1:48) but shall not exceed the grade established for the adjacent roadway.
Justification: Bicycle Safety
It is critical that designated bicycle lanes are not impacted or eliminated.. This significant and growing transportation mode is designed as a network, with selected routes based on demand and safety accommodations for the rider. Roadway alterations that affect the system or safety design of these facilities will have a negative effect on the safety of bicyclists.
Safety for Visually Impaired Pedestrians
Moving the curb in to allow for an access aisle along side of a car appears to help one group and create a problem for another. A person, who is visually impaired, walking parallel to the roadway on the sidewalk, will find the proposed concept confusing. People who are visually impaired tend to walk near the inside edge of the walk, however, jogs in the walk may introduce problems.
Clarification and Exception required for 2% (1:48) slope on access aisle
The proposed exception to ADAAG Section 502.3 is critical because it will be technically infeasible to meet the 2% (1:48) slope requirement in on-street parking accommodations in the same way that it is infeasible for sidewalks to meet the 5% (1:20) maximum slope requirements.
Width of Public Right-Of-Way must be 16 Feet
The 14-foot exception is not adequate and should be 4.6 m (15 ft). The rebuild to accommodate an accessible stall requires 1.5 m (5 ft) of sidewalk converted to access aisle at street level, plus a 1.8 m (6 ft) for a curb ramp using the perpendicular ramp, plus 1.2 m (4 ft) of landing/clear route at the top of the ramp. The total requirement to meet these minimums is 4.6 m (15 ft).
Parking at End of Block
Proposed guidelines state that where the right-of-way width for an access aisle is not provided, the parking space may be placed at the end of the block, which is where they are now typically located and signed. This is generally a reasonable alternative.
Water and Drainage Impact on Accessible Stall when Curb Line is Altered
Depending on roadway grade, cross slopes volume of and design for surface water removal, modifications to the curb alignment to accommodate the 1.5 m (5 ft) access aisle may adversely impact the access aisle, ramps or blended transitions with excess amounts of pooled water and in winter, ice. When the roadway, due to existing roadway constraints, utility locations and environmental conditions, cannot be designed to remove water from the on-street parking stall, an alternative parking accommodation, such as "Parking at the End of Block", should be allowed. This is especially critical in northern climates.
Winter Condition Snow Removal
Roadway plows cannot remove snow from an indented access aisle. Snow removal will be considered a secondary priority - delayed until after the major snow event is over and snow emergency work for main roads is complete. Northern states that have a substantial amount of snow over a long season, should be allowed to develop off-street parking facilities that will be plowed more quickly than the individual remote stalls could be.
Section 1109.3 Perpendicular or Angled Parking Spaces
Guideline Language: Where perpendicular or angled parking is provided, an access aisle 96 inches
Requested Change: The elements/conditions stated in this paragraph and additional information that is more comprehensive and clearly written already exists in ADAAG Sections 502.3 through 502.6. Access aisles should comply with ADAAG Sections 502.3 through 502.6 and specifically include an exception to ADAAG Section 502 requirements for slope.
Some exceptions should be provided so that reasonable percentages of the total available parking spaces and distribution for close access are considered and applied.
Suggested Language: Where perpendicular or angled parking is provided, an access aisle of 2440 mm (96 in) wide minimum shall be provided. It shall comply with ADAAG Sections 502.3 through 502.6 and shall connect to a pedestrian access route serving the space.
EXEMPTION: Although the access aisles are also used for wheelchair transfer to and from vehicles, the slope may be steeper than 2% (1:48) but shall not exceed the grade established for the adjacent roadway.
EXCEPTION: Reductions of parking capacity by over 10% are not required as long as a minimum of two accessible parking spaces per block are provided.
Justification Clarification and Exception required for 2% (1:48) slope on access aisle
The proposed exception to ADAAG Section 502.3 is important because it will be technically infeasible to meet the 2% (1:48) slope requirement in on-street parking accommodations in the same way that it is infeasible for sidewalks to meet the 5% maximum slope requirements.
In cases where the access aisle for on-street parking exceeds a slope of 2% (1:48), alternative parking accommodations should be considered to replace the one parking stall per block face requirement so that the parking stalls provided will better meet the objective of providing access for all.
Proposed Distribution of On-Street Parking Seems Excessive
The required access aisle is equal to the size of an average parking stall. This will result in a net reduction of two general parking stalls per block face. In some communities, this may excessively reduce the availability of general population on-street parking. Reduction of parking capacity by over 10% should not be required so long as a minimum of two accessible parking spaces per block are provided.
Section 1109.4 Curb Ramps or Blended Transition
Guideline Language: A curb ramp or blended transition complying with 1104 shall connect the access aisle to the pedestrian access route.
Suggested Language: See comments for 1104.
Justification: See comments for 1104
Section 1109.5 Obstructions
Guideline Language: There shall be no obstructions on the sidewalk adjacent to and for the full length of the space. EXCEPTION: This provision shall not apply to parking signs complying with 1109.6 and parking meters complying with 1109.7.2.
Requested Change: Modify this section to provide for 0.6 m (2 ft) clearance to the curb along the parking space.
Suggested Language: No language is suggested at this time.
Justification: Elimination of All Obstructions Seems Excessive
There seems to be no logical reason for the ban on obstructions abutting the parking space. A 0.6 m (2 ft) clearance to accommodate door swing seems appropriate; however the elimination of all obstructions seems excessive. Space for unloading is part of the access aisle space requirements. Features such as light poles, trees and other street-scaping in the area that abuts the space but are outside a 0.6 m (2 ft) clear zone will not adversely affect the usefulness of the parking space. These features are important to the overall use, safety, and appearance of the street.
Section 1109.7.3 Displays and Information
Guideline Language: Displays and information shall be visible from a point located 1015 mm (40 in
Requested Change The wording of this section is somewhat unclear and no size is required for text.
Suggested Language Revise section to provide intended guidance.
Justification: Not Applicable
1111 Alternate Circulation Path
Section 1111.1 General
Guideline Language: Alternate circulation paths shall comply with 1111.
Requested Change: The inclusion of any other sections that must be adhered to regarding surfaces, cross slope, grades, etc.
Change "Alternate Circulation Path" to "Pedestrian Detour".
Suggested Language: Not applicable.
Justification: The clarification is necessary to set the baseline for the expected level of service and provide assistance to designers in the determination of the appropriate location of the alternate circulation path.
Pedestrian detour is preferred because it is an established and recognized term within the transportation industry.
Section 1111.3 Location
Guideline Language: The alternate circulation path shall parallel the disrupted access route, on the same side of the street.
Requested Change: Add exception.
Suggested Language: A pedestrian detour shall be parallel to the pedestrian access route on the same side of the street.
EXCEPTION: When a parallel path on the same side of the street is not technically feasible, pedestrians will be routed to the nearest facility. The pedestrian detour shall have adequate access and notification.
Justification: In construction zones it is not always desirable or safe to walk next to the construction site. Access for construction equipment and materials, the availability of right-of-way, and the safety of workers and pedestrians must be factored into the final determination in the creation of a pedestrian detour.
Jeffrey S. Polenske, P.E., October 28, 2002
In June 2002, the Federal Access Board released its "Draft Guidelines for Accessible Public Rights-of-Way" as part of the review process required to adopt these guidelines and, in the future, make them law. Attached please find the City of Milwaukee's comments regarding the "Draft Guidelines for Accessible Public Rights-of-Way".
If you have any questions, please contact Jeffrey Dillon, of my staff, at [...].
Very truly yours,
Jeffrey S. Polenske, P.E.
City Engineer
Comments on the Draft Guidelines for Accessible Public Rights-of-Way
1) In Section 1101.3 Defined Terms the definition for Street Furniture is too broad, "elements.. .that are intended for use by pedestrians" could include handrails, benches, bus shelters, stairs, ramps, sidewalks, etc. The street furniture definition should define the way pedestrians will use these elements versus other elements such as sidewalks or curb ramps.
In addition, please include definitions for Alternate Circulation Path and Blended Transition in this section.
2) In Section 1102.2.2 Alterations, exceptions for compliance in making alterations in the right-of-way are allowed to be below the standard set by these guidelines if it is technically infeasible to fully comply. So, what does "technically infeasible" mean and who decides what is "technically infeasible"? Cost affects many, if not most, decisions made in City of Milwaukee street designs. Will cost be an allowable criterion when considering whether an alteration is "technically infeasible"? Perhaps the Access Board or some other entity should provide a guideline to provide a measure of when an alteration is "technically infeasible" and when partial compliance is allowed? Such a guideline may better help communities in making decisions about alterations.
3) Section 1102.14 On-Street Parking, as written, appears to call for one designated parking space per block face. Currently, the City of Milwaukee will install an accessible loading zone per request. Requiring a designated parking space on every block face will add a significant cost to the City and, in addition, may limit the City's ability to be flexible in terms of installing accessible loading zones where they are most useful. Further comments on On-Street Parking can be found below.
4) Section 1102.3 Alternate Circulation Path Street construction zones are inherently dangerous even for able-bodied pedestrians. It is not unusual to have to close pedestrian access on one side of the street during construction. In such situations, it may be impossible to provide an Alternate Circulation Path on the same side of the street.
5) In Section 1103.3 Clear Width it is unclear if the clear width is referring to the width between the front of walk and the back of curb or if this is the minimum width of the sidewalk. Does this mean that sidewalk, especially in terms of new construction, can be built without any space between the back of curb and the front of walk?
6) In Section 1103.4 Cross Slope the entire pedestrian access route, including sidewalks, street crossings, and, in addition, other elements would only be allowed to have a cross slope of 1:48
Another concern regarding cross slope of the pedestrian access route has to do with the inherent restriction against depressed driveways. The City of Milwaukee uses depressed driveways frequently to prevent damage to vehicles. Many of the suggestions made in the book Designing Sidewalks and Trails for Access, Part 2 for designing without the use of depressed driveways would not be feasible or practical in terms of future maintenance.
7) In Section 1104.2 Types Please define the term blended transition.
8) Section 1104 Curb Ramps and Blended Transitions Two separate curb ramps rather than a single ramp that opens diagonally into the intersection is recommended. However, State of Wisconsin statues dictate the placement of a diagonal ramp as the location of first choice; and the City of Milwaukee completed a costly multiyear initiative to comply with this directive. Without a source of additional funding, the replacement of the diagonal ramp with two parallel ramps would only be accomplished with street paving projects. As such, it could take decades before total conversion is complete.
In terms of semantics, in this section, the terms parallel and perpendicular should be more clearly defined as to the axis used to determine what is parallel or perpendicular.
9) In Section 1105.2.2 Cross Slope it would be impossible to ensure that the pedestrian access route would meet this requirement as it crosses an intersection. Forcing a cross walk to have a cross slope no greater than 1:48
10) Section 1105.3 Signal Phase Timing. Changing walking speed from the current 4.0 feet
11) Section 1105.4 Medians and Pedestrian Refuge Islands. Requires median islands to be six feet or larger in width. Milwaukee has roadways with 4-foot wide medians and numerous small refuge islands that will not meet this criterion.
12) Section 1105.5.3 Pedestrian Overpasses and Underpasses The requirement of an elevator where ever the difference in grade between the approach and the overpasses or underpasses exceeds 60 inches
13) Section 1105.6 Roundabouts. Roundabouts require pedestrians to select a safe gap in the traffic flow and motorists to yield the right of way, which can result in pedestrian accessibility problems. Roundabouts, however, are customarily installed in lieu of the traffic signal. We recommend that further study be undertaken on the safety of pedestrian movements in roundabouts prior to mandating that pedestrian activated signals be provided at each crosswalk in a roundabout and the placement of a continuous barrier along the street side of the sidewalk.
14) Section 1105.7 Turn Lanes at Intersections Right turn by-pass lanes at intersections are often controlled with either stop signs or yield signs. The proposed guidelines would mandate installation of pedestrian activated signals. We are unaware of any studies showing increased pedestrian injuries resulting from vehicle collisions at right turn bypass crossings that would warrant this installation.
15) Section 1106.2 Pedestrian Signal Devices. We have worked with the blind community in Milwaukee to provide audible pedestrian signals at locations adjacent to facilities that serve the blind and have higher numbers of visually impaired pedestrians crossing. The requirement to provide audible signals at every intersection seems excessive.
16) Section 1108.2.1 Curb Ramps and Blended Transitions outlines the requirement for the installation of a detectable warning surface at a curb ramp or a blended transition. Currently, truncated domes are considered to be the preference this type of surface. Truncated domes would pose problems for the City of Milwaukee on several fronts. There are serious concerns regarding increased difficulty in removing snow and ice because of the installation of truncated domes. In addition, maintenance of curb ramps with truncated domes is also of concern in that there is no information on how well the domes survive freeze/thaw cycles, salt from snow clearing operations, and the clearing of snow or ice from the curb ramp surface. Truncated domes would add a significant maintenance cost that the City of Milwaukee may not be able to meet. In addition, curb ramps with truncated domes that have broken or chipped off the sidewalk surface, may pose a safety hazard themselves.
17) Section 1109 On-Street Parking. Wisconsin state statutes permit a vehicle with handicap plates and/or placard to be parked in any legal parking space in excess of the posted time limit and without payment of any meter fee. The draft guidelines would require at least one accessible parking space on each block face. An access aisle at least five feet in width that does not encroach into the vehicular travel lane shall be provided to serve the space. Wherever the sidewalk width is greater than 14 feet
Jay Grossman P.E., October 11, 2002
I am concerned about two of the proposed changes, first concerning crosswalks: Limiting the crosswalk cross slope to 2% at intersections, and hence the roadway's profile grade to that same level, will significantly increase the cost of infrastructure improvements. Even here in flat Indiana, it is not unusual to have profile grades over 2% through an intersection. I would suggest that 5% (1:20) is a better number, consistent with current maximum grades on major routes.
As pedestrian accessible routes at mid-block are apparently all right with a cross slope that matches the road profile grade, whatever it may be, perhaps a more tempered approach to cross slopes at intersections is appropriate.
The grading required to flatten out an intersection will be extensive as vertical curvature requirements for roads don't allow for abrupt changes. Using Indiana design standards, at a 35 mph design speed typical in urban areas, flattening a 5% slope out to 2% at an intersection will require reconstruction of 180 feet
My second concern is with roundabouts. First, the requirement for a barrier on the street side of the sidewalk seems unfounded. In lengthy reading on roundabouts in other countries, who have 30 or more years of experience using them, providing a physical barrier for detectability was never mentioned as having been a safety concern. As a detectable pattern at ground level is sufficient at a crosswalk or train station platform, why is the edge of a roundabout any more dangerous? Traffic in a roundabout generally circulates at 15 mph, much less than the 35-40 mph of traffic rushing for a green light at a signalized intersection.
If a pedestrian steps over a curb into a roundabout, there is a much better chance that motorists will have a chance to stop or swerve than when a pedestrian steps into a crosswalk at a signal just as the light changes and a motorist is speeding to make the light. Furthermore, the accident data I have seen has never shown any instances of accidents involving pedestrians inadvertently straying into the circulatory roadway. Is it prudent to protect against a type of accident that has never occurred?
Finally, the requirement for pedestrian activated signals at roundabout crossings also seems extreme. As stated before, traffic at roundabouts is going much slower than that at signals on a green phase, and the accident data reflect how these lower speeds affect safety. Watching a video of a roundabout at Michigan State University shows how, with 5000 pedestrian crossings a day, roundabout crosswalks are generally safer than those at signals. When a pedestrian steps into the crosswalk traffic has time, and does, slow to allow them to cross. Observing roundabouts in Colorado showed the same yielding to pedestrians in the crosswalks by traffic.
A colleague participated in a visual impairment understanding exercise at a roundabout in Wisconsin. Blindfolded and with a cane, after a couple of tries with a guide, he was able to learn to listen for traffic and safely cross the roundabout approaches without aid. If a person blindfolded for less than half an hour can learn to cross safely at roundabouts, is it unreasonable to think those with permanent disabilities can learn to do the same?
Thank you for the opportunity to comment,
Jay Grossman P.E.
Patrick G. Rivera, October 3, 2002
Attached are comments on the recently released Draft Guidelines on accessibility of public rights-of-way from the City and County of San Francisco, Department of Public Works, Bureau of Engineering, Streets & Highways Section. Thank you for the opportunity to allow us to comment.
Patrick G. Rivera
City and County of San Francisco
Department of Public Works
Bureau of Engineering
Streets & Highways Section, Manager
Re: Comments on the Draft Guidelines on Accessible Public Rights-of-Way as Proposed by the Access Board
I understand that you are accepting comments on the recently released Draft Guidelines on accessibility of public rights-of-way now being considered by the Access Board. Below comments from the City and County of San Francisco, Department of Public Works, Streets & Highways Section. Note that these comments do not represent the entire Department's comments but only one design section. There may be other sections with in the Department submitting comments.
1102 Scoping Requirements:
In 1102.2 there are discussions indicating compliance requirements, exceptions due to technical infeasibilities etc. However, there is no clear guidance to what extent an ADA compliant alteration is necessary for locally funded projects. In other words the cost impact is not discussed. Case in point. As part of a traffic signal upgrade project, we're required to install curb ramps. However, the cost to install the curb ramp component is almost as much as the traffic signal upgrade component. We have been unable to determine what dollar amount increase is considered hardship or what percentage cost increase on a project due to ADA requirements are reasonable. 1104 Curb Ramps and Blended Transitions
1104.2.1
Even though it's stated in 1104.3.2, it's best to include it in this section as well.
1104.2.1.1 Cross Slope
In the City and County of San Francisco the street and sidewalk grades range from 2% to 22%. This section states that the running slope shall be 1:48
1104.2.1.4 Flares
Flares with 10% slope measured along the curb line may create a steep wing when a curb ramp is constructed parallel to the crosswalk at a skewed intersection.
1104.2.2.1 Running Slope
"Parallel curb ramps shall not be required to exceed 15 feet
1104.3.2 Detectable Warnings
If detectable warnings (truncated domes as in 1108) would be required for all curb ramps regardless of the slope, then is the color contrast of the curb ramp required by the CA State Title 24 be required.
1104.3.3 Surfaces
The prohibition of gratings, storm drains, utility and sewer access covers on ramps, and landings, transitions and gutters within the pedestrian access route will be challenging to comply with. The question is: Are we required to relocate catch basins, manhole covers, drains etc? Even if such existing facilities are to be accepted as preexisting condition or exceptions, the addition of new truncated domes will be very challenging.
1104.3.6 Counter Slopes
The requirement of 1:20
1104.3.7 Clear Space
The roadway next to the curb on major routes may be a vehicle travel lane during "rush hour" times. The requirement of a 4' by 4' clear space at bottom of ramp outside the parallel vehicle travel lane conflicts with current traffic routing.1105 Pedestrian Crossings
1105.2.2 Cross Slope
1105.2.3 Running Slope
In the City and County of San Francisco the street and sidewalk grades range from 2% to 22%. In 1105.2.2 the maximum cross slope of 1:48
1108.2.1 Curb Ramps and Blended Transitions
Many ramps are located along the radius of the curb return, so the ramp bottom at the curb line is curved and not perpendicular to the path of travel. Custom design and production of a pre-cast or cast-in-place surface with truncated domes that fit these irregular areas will be difficult. A solution would be to increase the maximum distance to the curb line from 8 inches to 12 inches
The above comments do not represent a complete list of comments from the City and County of San Francisco. You may be receiving additional comments from other Departments and Agencies. I would like to thank you for allowing the Engineer's in my Section and me the opportunity to comment on the draft guidelines. Please add me to your e-mail list regarding this topic.
Sincerely,Patrick G. Rivera
City and County of San Francisco
Department of Public Works
Bureau of Engineering
Streets & Highways Section, Manager
Alonzo Liñán, P.E., November 1, 2002
City of Olathe
Re: Draft guidelines on accessible public right-of-way proposed by the U.S. Access Board.
Dear Mr. Windley:
Since the Rehabilitation Act of 1973, the city of Olathe has endeavored to maximize accessibility of city programs and facilities to all segments of our population. The city of Olathe has also incorporated the additional requirements of the Disability Act of 1990 and it subsequent revisions. All of these actions have been successful in removing barriers for the disabled and has provided access to all parts of the community to public services, programs and facilities. To date, none of these actions have resulted in a decrease of access to other segments of the community nor has it compromised the safety of other customers in our community.
Several of the proposed guidelines require pedestrian activated traffic signals at many locations. This blanket requirement for the placement of traffic signals in contrary to the MUTCD where at least some minimum warrant has to be met. Without at least minimum warrants, traffic signals will soon go the way of "Children At Play" and "Neighborhood Watch" signs. There will be so many traffic signals that when they are actually needed, they will be ignored. This is a very serious safety issue for the entire population.
The proposed draft guidelines will push communities like ours into a position of not providing facilities or services because of the cost of maintenance, rehabilitations and reconstructions as well as its impact on safety. In short, the Access Board's attempt to provide access for all people, at all times, for all programs, at all facilities, may deny access and services to all citizens of the community so that there will not be a "discriminated group". In the end, everyone will be treated equally as communities exercise their discretionary powers to not make improvements beyond a certain level.
Finally, I feel that many of these proposals are premature as statistical information is not available to draw conclusions from nor is there consensus between The National Federation of the Blind or the American Council of the Blind on many of these issues.
I hope the following comments illustrate these views.
Section 1102.2.2; Additions and Alternations - "Compliance in alterations is required except where it is 'technically infeasible.'"
My concern is that, as an engineer, the only thing that makes something "technically infeasible" is money and politics. This needs to be better defined.
"...such work might be technically feasible at other locations where acquiring right-of-way is practicable."
"Practicable" needs to be defined as well. Cities can use imminent domain, but the political ramifications of doing so for a sidewalk may force policy makers to avoid the project.
Section 1102.3; Alternate Circulation Path - "...call[s] for alternate circulation path are where pedestrian access routes are temporarily blocked by construction, alteration, maintenance, or other temporary conditions...(on the same side of the street parallel to the disrupted pedestrian access route)."
The concern is "or other temporary conditions". First, this needs to be more narrow in definition as snow can be considered a temporary condition. I would also suggest that the barrier requirement be changed to allow for barricades with modifications for the disabled.
Second, since an alternate path has to be parallel and on the same side, this may require easements to construct a temporary surface "to the outside". This speaks to a significant cost increase to repair or replace some sidewalk. If the sidewalk is on a 4 lane road and no easements or right-of-way exists "to the outside", then taking the outside lane of traffic may be the only other choice. But then you run into a curb, slope limits, additional traffic control... Regardless, a 30 minute job could now take hours.
In either case, the city will be faced with either increased costs for easements or potential reduced safety on the street by putting peds in the street; both of which may lead a city to determine that sidewalks may not be maintainable and, therefore, either removed or not put in.
Section 1102.4; Pedestrian Access Route - "...refers to the portion of the public right-of-way that serves as an accessible route."
What provision is there for sidewalks that are in easements? Does this proposed document extend into private property for public use but is not right-of-way? Does this unintentionally obviate easements for sidewalks in the future?
Section 1102.5; Protruding Objects - "...limited to a 4 inch
This could lead to a lot of unintended prohibitions. Examples include call boxes, pole mounted controllers, streetlight controllers, directional and informational signs...
Section 1102.12; Vertical Access - "Elevators are not required by these guidelines except at certain pedestrian overpasses and underpasses with elevation changes greater than 60 inches
Aside from the obvious maintenance and security issues, this will clearly prohibit any municipality from seriously considering any pedestrian over/underpasses.
Section 1102.14; On-Street Parking - "[For parallel parking] an access isle at 60 inches
This is too broad of a statement and is unreasonable for every block face. Is this just for downtown blocks or residential blocks as well? What is considered a block? This seems to ignore the curvilinear nature of suburban street design if it includes residential streets. This also assumes that there is a need for this specific number of parking; "blocks" can have more or less need. This also assumes that there are "parking stalls" already marked. This is certainly not the case in residential areas.
Logistically, this will come at a cost of at least three other parking stalls, if not more, and will negatively impact the sidewalk system. If the presumption is that a driver can pull next to the new curb so that the driver can utilize the additional 60 inches
The drainage will be severely affected as well. While the slope can be maintained for street drainage at the original curb line, this introduces ADA slope and transition issues to connect to a relocated sidewalk. The now relocated sidewalk becomes an unexpected variable for the blind and as such becomes a safety issue.
This one just needs to be dropped.
Section 1105.2.1; Pedestrian Crosswalk Width - "...shall be 96 inches
This is in inconsistent with the MUTCD which requires only 72 inches
Section 1105.2.2; Pedestrian Crosswalk Slope - "...slope shall be 1:48
This maximum cross slope will require "tables" at each intersection which will degrade the ride-ability of vehicular traffic and may compound grade problems in mid-block sections of steep roadways.
Section 1105.3; Pedestrian Signal Phase Timing - "All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
This is extremely unreasonable. The MUTCD indicates 4.0 f/s with the freedom to reduce as needed. To require 3 f/s and increasing the distance to include ramp lengths engender disrespect for the pedestrian indications as pedestrians will watch the flashing Don't Walk continue for as much as 15 to 20 seconds
Section 1105.6; Roundabout
This is a principle example of how the proposed accessibility measures will come at the cost of safety on the street. It is my hope that these "proposals" are only published to generate discussion and are not truly seen as reasonable.
Section 1105.6.1; [Roundabout] Separation- "Continuous barriers shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited."
This is not consistent with other street designs and conditions. If the attempt is to prohibit the blind pedestrian from inadvertently crossing, then "regular" curves in the road become suspect. I find it difficult to accept that the blind pedestrian would consider "jaywalking"; which is what would be required if they were on any other curved street.
Section 1105.6.2; [Roundabouts] Signals - "A pedestrian activated traffic signal...shall be provided for each segment of the crosswalk, including the splinter island."
It appears form the discussion that there is a view that roundabouts are intrinsically unsafe for pedestrians. There is no documented proof that indicates that roundabouts are unsafe for pedestrians. It seems that this proposal is an attempt to pass judgement on the appropriateness of a traffic control device and recommend remedial actions without the benefit of any statistical data. If this gets adopted as written, it will effectively remove roundabouts as a traffic control and flow option as any traffic benefit will be negated with the presence of traffic signals.
So, again, in an attempt to provide access for all people, at all times, for all programs, at all facilities, cities will be forced to not make these improvements because of the cost, or not make these improvements because of the reduced or no benefit, or live with the more dangerous condition of following these rules and increase rear-end accidents, increase delay, increase air pollution, increase driver frustration...
The bottom line is that every traffic control device can be dangerous if not used properly and roundabouts are no different. The difference with roundabouts is that there are fewer conflict points, slower traffic, and less severe crashes. The addition would again negate all of these benefits and would make the intersection very complex for any pedestrian and driver.
Section 1105.7; Turn Lanes at Intersections - "Where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal...shall be provided for each segment of the...crosswalk..."
What's a slip lane? If free-flow turn lanes are at issue, then there are literally thousands of existing "slip" lanes, both at signalized and un-signalized intersections. This is a common design element this requirement would essentially eliminate slip lane design from intersections.
Again, not until now have access accommodations resulted in a decrease of access and safety to other segments of the community.
Sincerely,
Alonzo Liñán, P.E.
Traffic Division Manager
City of Olathe