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
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
RE: Detectable warnings or truncated domes
As the Director of Denver's Commission I'm concerned about the impact of re-implementing the requirement for truncated domes at curb ramps. Our experience with this issue 10 years ago was that, in our climate, the domes were: extremely difficult to maintain, damaged easily, difficult to repair, and created an obstacle. We also had difficulty finding an agreeable position among individuals in our disabled community on this issue as well.
With this in mind, we (the Commission and City) set out with a goal to create a curb ramp standard that complied with the requirements of the Americans with Disabilities Act (ADA) and at the same time satisfied the major concerns of our disabled community. After months of development and negotiation we focused on a design that we felt met our goal. Our standard provides tactile warning and direction by the use of grooves. There is also color contrast, proper slope ratios, compliant width, and maintenance is no different than that of a basic sidewalk.
Since the ADA was established this City has worked hard at complying with its guidelines and installing a curb ramp that is functional. Our curb ramps are installed whenever there is new construction, repair to existing pedestrian paths of travel, or requested through our "curb ramp request line". Needless to say, our curb ramp standard is very extensive throughout our city. Individuals look for it, feel for it, and identify with it for an accessible path of travel. Incorporating a new standard would only create confusion.
The City and County of Denver is considered to be one of the most accessible cities in the country. Part of this accolade is due to our extensive and consistent use of our curb ramp standard throughout the City. Our standard has also been duplicated and incorporated in other municipalities as well.
I urge the Access Board to seriously consider the impact of truncated domes at this juncture in time. Years have been spent not only by this City, but others as well; establishing standards and installing curb ramps. We want to continue in the direction that we initiated 10 years ago. We feel our curb ramp standard provides exceptional accessibility and serves the disabled community and others well. Providing a curb ramp that is functional to use and expected.
Thank you,
Ed Neuberg
Director, Denver Commission for People with Disabilities
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.
John Dempsey, October 23, 2002
I support the installation of detectable warnings (truncated domes) at curb ramps and increased access to accessible pedestrian signals. It is my understanding that the current ruling on this only covers new construction and alterations. I feel that although this is an important step in the right direction, it does not address existing curb ramps and signals. Does this mean that any city in the US that had a curb ramp on a busy street is not required to put in the domes because it was a "preexisting curb ramp"? I hope this is not the case. I know that the Access-Board has recommended to the States to put in the Warning Systems regardless, and some states have taken a proactive approach to this, but the majority have not. I currently reside in the state of Alabama and also spend a great deal of time in Mississippi. I contacted the Alabama DOT who was very helpful. They gave good answers to my questions, were knowledgeable about the ruling and seemed to be genuine in their concerns. Mississippi on the other hand was a different story. I talked to a Jimmy Brumfield, he is the Director of Materials Division Miss. DOT. Mr. Brumfield was very defensive and uncooperative, basically telling me that the state had no plans to follow the guidelines and probably wouldn't. I guess he is a great example of why Mississippi is consistently rated the worst state in the US in almost every category. Mr. Windley you have your work cut out for you if you have to deal with people like him. I just hope to G-D that no one gets killed in Jackson, MS because of their backward mentality. The bottom line is if preexisting ramps are not retrofitted with the detectable warnings then why do it at all. Thanks and good luck.
John Dempsey
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.
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
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
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
--------------------------------------------------------------------------------
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.
Michael A. Whipple, October 28, 2002
City of Sacarmento, Department of Public Works
To: Access Board
From: Michael A. Whipple, Public Works ADA Coordinator
Re: Public comments for draft Public Rights-of-Way Guidelines
I would like to submit the following comments regarding the Draft Guidelines for Accessible Public Rights-of-Way.
1102.3 Alternate Circulation Path
This would be a very cost prohibiting guideline when imposed as in the draft guidelines. It is not practical and/or cost effective to provide an alternate circulation path as stated in this section and section1111. Our City does provide an alternate circulation path when construction, maintenance or similar situations is going to impede the normal circulation path for any considerable amount of time. On the other hand it will increase the cost of our curb ramp program beyond the $5 million we spend annually now. Our program hardly ever blocks a whole intersection at one time to install a new curb ramp. An individual can cross the street and proceed on their way during the 4 days we are working on the new curb ramp(s). To have a contractor comply with what is being proposed would mean they would have to have many of the types of barricades required and then they would have to have a crew, which was just moving barricades on a daily basis. This also implies that at all locations there is the room to provide this alternate path and then you still have the problem of using some type of portable ramps to get people from the street to the sidewalk or vice versa. This would also impact areas where the sidewalk was not contiguous with the street and a garden/landscaping strip had to be crossed to get back to the sidewalk. This would then also impact the parking along the street as each space next to the corner would have to be blocked off and this would need to be done daily for one to seven blocks. As this picture unfolds it can be seen that many things would be impacted and another alternative for an alternate circulation path would need to be added to the guidelines.
This might be able to be worked out better if Section 1111.3 Location was reworked. A time limit for the amount of days an alternate circulation path would be needed could also solve this problem. This would mean something like if the regular circulation path is not available for 7 or more days and no alternate circulation path within a two block radius is provided then you would use the proposed guidelines. This section will have a large financial impact on doing curb ramps alone and with many cities already not up to speed this really could slow down reconstruction or retrofitting of curb ramps not to mention other areas it will impact that are not seen at this time.
1102.14 On-Street Parking
This guideline will not provide the needed parking for people with disabilities but will increase the placard abuse that is seen around the country and especially here in California. This guideline will also decrease regular on-street parking spaces in areas where a parking garage or lot is near and they (garages and lots) provide a number of disabled parking spaces. This would have an impact on cities in their downtown areas where parking is usually at a premium. Along with this guideline comes the new requirements for a curb ramp when the disabled space is parallel to the curb and the 60-inch access isle. The curb ramp issue can add a large expense to the entities already trying to pay for the curb ramps they are doing on the corners. This scenario could make an entity choose between curb ramps at the corner and whether they are single or dual and the curb ramp at the disabled parking space on that block face. The other area is the access isle and how that will impact the flow of traffic when you have one parking spot along the street, which sticks out five feet more than the rest. Also, what would happen when you have to provide the disabled parking spaces on each side of the street? You could have two scenarios with this street; 1) If both spaces where opposite each other on the street you would in essence create a bottle neck situation where lanes have to narrow to allow for the extra 10 feet
Before moving on to the next comment I would like to make a statement about our Visual Community here in Sacramento. We have a strong, vocal and actively involved visual community representing both sides of the blind philosophies. The Council and the Federation make sure that at any meetings that are held in the Sacramento area they both have representatives there to make sure that their philosophies are heard and taken into consideration. The City of Sacramento takes a stand with these two organizations stating they represent a percentage of the visual community and I take the position that I represent the rest of those people out there who do not belong to one or the other of these groups. So what we try to achieve here is a balance for both sides and use our philosophy of "Trying to achieve the greatest amount of accessibility for the largest amount of people".
1104.3.2 Detectable Warnings
I would like to preface this comment section with the fact that we are in California so we have the requirement to put truncated domes on curb ramps with slopes less than 6.67% (1:15). Within the City of Sacramento we have adopted this as one of our standards for curb ramps. So if the Access Board uses the new revised ADA (when it finally becomes enforceable) and does not require truncated domes we will still be putting them on curb ramps with slopes less than 6.67% (1:15).
I write the above paragraph because we did three days of field study with people representing all major disabilities and it was agreed that the State truncated dome section was a good compromise and pleased the Council, Federation and the folks with mobility types of disabilities. It is felt that it is not cost effective to put truncated domes on all curb ramps in all locations. It is felt that the California requirement is a good compromise and that this standard should be adopted or given strong consideration when this section is completed. Through our work with truncated domes we know that it can cost between $400 and $1000 extra to put the truncated domes on curb ramps. If you take the average cost of these figures, $700, when we do a minimum of 1,500 curb ramps a year we are adding an additional $1 million dollars if we had to do truncated domes on all curb ramps. That might almost be enough to be considered a financial burden on our available dollars.
We also believe the new requirements for the spacing and sizing of truncated domes will have an impact on the entire disabled community. It has taken the Access Board enough years to get people to consider using truncated domes again it is not the time to be changing the spacing requirements. Our visual community does not like the minimum and maximum spacing because you would have all sorts of different truncated domes along a pedestrian access route and it could cause disorientation, sprained ankles or some unknown problem on the truncated dome plates when the larger spacing is used which would have more slippage in the field area because it gets larger. Also when using the larger spacing between domes it does not guarantee people in wheelchairs will be able to line up their wheels because they come in all sizes and shapes so it is not guaranteed that the wheels would roll between the truncated domes. If this requirement was put into the new chapter we might find ourselves back at the drawing board deciding whether truncated domes are safe or not and thus having another suspension.
1105.6 Roundabouts
We do not agree with the pedestrian traffic signals for Roundabouts. This defeats the purpose of the Roundabout and can be more dangerous to the pedestrians. I do not need to go into the studies or statistics as I have seen them quoted plenty of times in comments already received. It is important to note in these statistics that there is more safety with a Roundabout without pedestrian signals than one with. It would be more prudent for the access board to be requiring truncated domes at these locations, crosswalks and midcrossing pedestrian safety areas, despite slopes, than the pedestrian activated signal.
1106 Accessible Pedestrian Signal Systems
There is so much controversy on whether these devices help or hinder that more research needs to be done. We do not agree that all pedestrian signals should have some type of ped-activated signal. This area needs much more study and then put back out with a new set of proposed guidelines for comment. What is listed in this draft is overwhelming and not yet proved as long lasting working devices. I am talking about the audible, vibrotactile or locator tones devices just to mention a few. I don't believe the Access Board wants to get into another situation like the early truncated domes.
1108 Detectable Warning Surfaces
We have already made comment on this area but would just like to reiterate the importance of keeping the current truncated dome requirements for size and spacing. When a manufacturer has the ability to use sizes or spacing from X to Y then there will not be any consistency with the truncated domes being used. This seems like we are taking a step backwards and will just end up having truncated domes go on suspension again until the new spacing can be tested and shown that it is safe. The new sizing and spacing should not be adopted. Let us try to work with the visual community to find a common ground and at least use the requirements for size and spacing we now have.
Robert Gorski, October 29, 2002
Dear U.S. Access Board:
I write to comment on 4 areas of the proposed guidelines for Public Rights-Of-Way (PROW): roundabouts, truncated domes on curb ramps, accessible pedestrian signals, and scoping for on-street parallel parking.
ROUNDABOUTS The wording of section 1105.6.1 needs clarification. Requiring barriers "along the street side of the sidewalk where crossing is prohibited" includes locations were a strip of parkway grass or bushes or flowers lies between the sidewalk and the curb. I find it hard to believe that barriers are needed as such locations.
To comply with section 1105.6.1 "splitter islands" would have to be totally surrounded by a barrier except for where the pedestrian way crossed the island. I believe that the degree of safety that should be sought for could be provided more simply and at less cost by having barriers along both sides of the pedestrian way that crosses through the island. Where the rest of the island contained a parkway, no barrier would be required.
How will section 1105.6.1 as written apply to roundabouts where the pedestrian crosswalks are not located at or near the circular "rim" of the roundabout, but further away and down the streets that lead into the roundabout. For what distance must the continuous barrier "along the street side of the sidewalk" extend? Section 1105.6.1 as written does not say.
Would truncated domes comply with section 1105.6.1's requirements for a "continuous barriers?"
This section, despite the few words that comprise it, deserves much thought.
Also, the photograph that the U.S. Access Board uses to illustrate a traffic roundabout does not have pedestrian barriers. If no roundabout with barriers exists, I recommend the Board get one established, see that it works the way you want it to work, and then photograph it.
TRUNCATED DOMES ON CURB RAMPS I recommend the U.S. Access Board arrive at a conclusion over this long standing issue similar to the California State Building Code. Truncated domes are needed by most blind individuals only where the slope is too gentle to be a cue by itself. It is unnecessary to have truncated domes on all curb ramps.
Additionally, truncated domes on curb ramps with greater than gentle slopes become a problem for wheelchair users, walker uses, and many semi-ambulatory pedestrians. On greater than gentle slopes, truncated domes become a rough, uneven surface that interferes with balance for semi-ambulant individuals and, for others, with maintaining control over mobility aids - particularly rigid-frame wheelchairs with solid rubber tires.
Installing truncated domes on a slope significantly increases the bumpiness of the ride for wheelchair and walkers users. For some, the ride will be more than an unpleasant annoyance, it will be physically painful. Here in the city of Pasadena, California, I have encountered over the years several wheelchair users who complain of joint pain when they roll over level sidewalk that has been textured to appear historic, and the unevenness of this surface does not approach the awkward bumpiness people will experience if they must negotiate curb ramps with truncated domes.
I myself use a power wheelchair and have experience with truncated domes, and if they are installed on new and altered curb ramps with greater than gentle slopes, the U.S. Access Board will be forcing me back to the 1960s, when I wheeled about and crossed streets by using driveways near intersections and then either "jay rolling" across the street to another driveway, or traveling along the gutter, crossing the street inside the crosswalk, and then traveling along another gutter to a driveway at which I could gain access again to the public sidewalk. Granted, driveways have lips that are bumpy, but that is only one bump and not a flight of bumps, like I will encounter if truncated domes are installed on all new and altered curb ramps.
Also, I submit that truncated domes on curb ramps at greater than gentle slopes do not comply with existing ADAAG Appendix A4.5.1 which advises (in part) that an accessible pathway must have a surface that is "stable and regular," and that "irregular surfaces such as cobblestones can significantly impede wheelchair movements." I would like to add that even when a cobblestone surface is "regular," it remains a surface to avoid.
Lastly, consider this hypothetical situation: A wheelchair user, a user of a walker with small front wheels, and a semi-ambulant person all cross a street and face a choice of two curb ramps leading up to the public sidewalk. One curb ramp has truncated domes on it and the other does not. Which individuals will choose the ramp without domes? The answer, I submit, is all of them because no one in their right mind wants to ascend a ramp of bumps.
ACCESSIBLE PEDESTRIAN SIGNALS I support the provision on APS devices at street intersections. At the same time, I recommend that the provision on locator tones be changed to require these tones only where the APS devices are located an atypical distance from the street corner where they are installed.
In Pasadena, the municipal government three years ago installed APS devices at a very busy intersection in a commercial district. The devices have vibrating arrows, audible messages, and Braille and raised character street labels and are mounted on light standards at a distance from the crosswalk that is typical. The devices do not have locator tones and do not use chirps and beeps as signals. The local government has received positive feedback from several blind individuals who reside in the city. Moreover, in the year 2000 a public celebration of the 10th anniversary of the ADA brought visitors with disabilities to the downtown area and there were reports of blind visitors being pleased by the APS devices.
Two years ago, administrators at the California Institute of Technology contacted the local government and offered to purchase APS devices if the city would install and maintain them at two intersections near the Institute. Motivating the Institute was a desire to assist two employees with vision impairments cross busy streets which were part of each employee's walking path to the Institute.
ON-STREET PARALLEL PARKING I recommend that the scoping provision be significantly reduced. The current provision is a "one size fits none" solution to the problem of inaccessible street parking. The different lengths of city and especially suburban blocks, the frequency with which parallel parking options are used on different streets, and the presence of nearby off-street parking are all legitimate factors in determining a scoping provision for accessible on-street parking.
And what about streets where parking is permitted only within a small portion of the block face? How can a scoping provision legitimately require two accessible spaces in that situation?
Lastly, this scoping provision would seem in many instances to result in a greater percentage of accessible parking spaces per total number of spaces available than is required by the ADAAG scoping provision for accessible spaces at parking lots.
No matter how the final scoping provision is written, the current provision in the proposed guidelines is having a deleterious effect at the present time in California, where state law permits municipalities to designate parking spaces as reserved for disabled individuals by painting the curb blue. Awareness of the PROW guidelines having specifications for accessible on-street parking spaces has caused parking administrators in Pasadena and at least a handful of other localities to deny requests from disabled people for "blue curb" parking spaces. Such requests typically are from disabled people needing convenient access to their homes, places of worship, schools attended by their children, and other critical sites.
Requests are being denied because parking administrators fear that blue curb spaces are out of compliance with what will likely be a coming provision in the ADAAG. I hope the Access Board agrees that blue curb spaces can be provided at the present time without having to be removed if a provision for accessible on-street parking becomes part of the ADAAG. Further, I hope the Board also agrees that even if a provision for accessible on-street parking becomes effective, blue curb spaces can continue to be provided as long as this is not done in lieu of complying with provisions in the ADAAG.
I urge the Access Board to announce that the proposed provision on accessible on-street parking does not invalidate nor put into jeopardy blue curb parking spaces.
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.
Michael Mankin, October 28, 2002
Michael Mankin, Chief
Office of Universal Design
State of California
Division of the State Architect
COMMENTS OF THE CALIFORNIA DIVISION OF THE STATE ARCHITECT
REGARDING DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY
The California Division of the State Architect (DSA) is pleased to submit the following comments on the Draft Guidelines for Accessible Public Rights-Of-Way, which were issued on June 17, 2002.
Additions and Alterations 1102.2
The scoping of this section is unclear and leaves a high degree of digression as to the level of accessibility provided by the covered entity. The preamble to the guideline states:
"For less extensive projects, limited improvements to accessibility would generally be expected. For example, if an existing portion of sidewalk along a block face were rebuilt or replaced, at a minimum the new portion of sidewalk would be subject to specifications for sidewalks, including those for curb ramps and surfacing, among other things. However, compliance with these guidelines would not extend to untouched sections of sidewalk outside the planned alterations."
In California, we require that the area of alteration be made accessible, and a path of travel to the altered area. The "path of travel" provisions in Title III of the ADA were modeled after the scoping provisions of the California Building Code. We suggest greater specificity in this regard, and request justification for the lack of clarity. In all cases, the area of alteration should be made accessible, with the path of travel subject to the 20% disproportionate cost criteria established by the Department of Justice.
Minimum Clear Width 1103.3
We support 48" as the minimum width dimension for a pedestrian access route. California has used 48" as a standard since 1982. This dimension however will not allow for the passing of two wheelchairs. We recommend that pullouts be included every 400 feet
Walks with continuous gradients.
All walks with continuous gradients shall have level areas at least 5 feet
Alternate Circulation Path 1102.3, 1111
We support the requirement for alternate circulation paths when pedestrian routes are temporarily blocked due to construction, alteration, maintenance, etc. A note should be added to clarify that this section also applies when doing accessibility-related projects. For example, jurisdictions replacing curb ramps as part of a resurfacing project, or as part of implementing an ADA transition plan should provide temporary ramps in order to assure access to the public right of way. In California, we require a minimum clear width of 48" (rather than the 36" recommended in the guidelines), for alternate circulation paths. We believe the additional 12" is necessary to provide an accessible environment. This has been required for the past 22 years without any difficulty based on space constraints. Therefore we are recommending that the Board require a clear width of 48" consistent with the minimum clear width for a pedestrian access route.
Barricades 1111.6
We support the requirement to install rigid construction barricades. Many jurisdictions, such as the City and County of San Francisco have developed independent policies that require barricades. The San Francisco program has been highly successful and has created a safer environment for all pedestrians.
Surfaces 1103.6
We are disappointed that the proposed requirement for a "vibration free zone" has not been included in the draft guidelines. We have observed a number of instances where the choice of surfacing materials has rendered the project inaccessible. For example, using cobblestones in historic districts, or to create the illusion of historicity, creates a highly inaccessible environment for wheelchair users. Likewise, wood decking, which is used to construct old western style boardwalks can often cup and separate, rendering the surface inaccessible. We request justification as to why the board would not consider reinstating the "vibration free" provision into the final guidelines.
Surface Gaps at Railroad Crossings 1103.7
We do not support allowing a 2-1/2" to 3" gap at railroad crossings, and request justification for such a hazardous condition for wheelchair users and semi-ambulant people who use walkers or crutches. It has been our experience in California that once a regulation passes, industry can usually find a way to meet the standard. For example, California was one of the 1st states to require access to card readers at gas pumps and ATM machines, many years before the ADA. Industry argued that it could not be done; yet when the regulations took effect, compliant designs were developed. We would support some grace period in order to allow technologies for rail crossings to be tested; however to remove the ½" maximum requirement completely is not warranted.
Curb Ramps and Blended Transitions 1102.6, 1104
We support the use of parallel curb ramps whenever possible. For new construction, installing parallel ramps would rarely be a problem. We agree that perpendicular ramps are sometimes necessary for existing conditions. The guidelines should require parallel curb ramps for all new installations and allow perpendicular ramps only for alterations or when installing parallel ramps would be technically infeasible.
Parallel Curb Ramps 1104.2.2
California specifies a parallel ramps with 1:12
Stairs 1102.10.
We support the proposal to require a 2-inch visually contrasting strip along each tread nosing which is very important for persons with visual impairments. Especially in high/low lighting conditions, unmarked stair treads pose a significant danger to persons with low vision. California has required this at exterior and interior stairs since 1982. We have found it to be a highly effective accessibility measure. We agree with the proposed amendment submitted by the California Council of the Blind, 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."
Detectable Warnings 1104.3.2
We support the use of detectable warnings on curb ramps and specifically the in-line v. diagonal dome design. California has required detectable warnings since April 1, 1994. California did not remove the requirement from the Building Code when the federal suspension took effect. We require detectable warnings on curb ramps when the slope of the ramp is 1:15
Other Requirements for Curb Ramps and Blended Transitions
Surfaces 1104.3.3
We agree with the requirement to prohibit the placement of gratings, storm drain, utility and sewer access covers and similar fixtures on ramps, landings, etc. for all newly constructed facilities. For existing facilities were alterations are occurring, it can be prohibitively expensive to relocate these elements outside of the ramp area. We have allowed utility covers successfully on ramps, providing the cover material meets the requirements for ground surfaces and poses no hazard. We urge the board to limit this requirement to new construction.
Pedestrian Overpasses and Underpasses
1005.5.3 Approach
We do not agree, and request justification that an elevator should be the only means to accomplish elevation changes greater than 60". In some areas, such as park and recreation areas and other remote or natural settings, an inclined pathway that is more universally usable by bicycles, strollers, etc to accomplish the change in grade. We have some safety concerns with exclusively requiring elevators, particularly in unmonitored areas.
Crosswalks 1105.2.
We agree with the requirement that marked crosswalks have a width of 96 inches
Vertical Access 1102.12.
We agree with the proposal to require that vertical access elevators and lifts remain unlocked. This will insure that access to the disabled is as readily available as it to the general public.
Medians and Pedestrian Refuge Islands 1105.4.
We agree with the proposal to align the edge of the cut through in the direction of the crosswalk for a length of 24" minimum. Edges provide a directional orientation reference point for persons who are blind or visually impaired.
Accessible Pedestrian Signal Systems 1102.8, 1106
We agree that audible signal devices should be provided at all signalized intersections. Many cities in California have used audible pedestrian signals, including Oakland, CA, which has had a program in place since 1984. Audible signals not only assist people with visual impairments, but also are very popular with senior citizens who feel safer crossing intersections equipped with this technology.
Street Furniture 1102.9, 1107
We support the requirements to provide access to street furniture.
Public Toilet Facilities 1107.5
We agree that public toilet facilities should be accessible. We disagree with, and request justification for the 5% cap on the number of accessible units provided. Providing only 5% accessible clustered toilets means that persons with disabilities who use mobility devices must wait much longer for the use of the few accessible portable toilets while the general public has many more options. For the past 32 years, California has required that all newly constructed restroom facilities be accessible.
Detectable Warning Surfaces 1108
We support the proposed guidelines for detectable warnings with the modifications discussed previously under curb ramps.
On Street Parking 1109
We support the proposal to provide on-street accessible parking.
Call Boxes 1110.6.2
We strongly support the use of TTY's on emergency call boxes. It is critical for all people to have the ability to convey the nature of the emergency and to receive specific instructions from the dispatcher. Emergency telephones with integrated TTY's are commercially available and in use in many locations today.