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
EXCEPTION 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.
Arthur T. Leahy, October 24, 2002
The Orange County Transportation Authority (OCTA) is pleased to respond to the Architectural and Transportation Barriers Compliance Board's (Access Board) draft guidelines addressing accessibility in the public right-of-way.
OCTA is the primary provider of public transportation services in Orange County, California and operates in an area of 797 square miles, serving 34 cities, unincorporated areas and 2.8 million residents. Fixed route transit services provided by OCTA form the basic countywide network of local, rail connector, and express routes consisting of more than 6,500 bus stops along 77 bus routes.
Since 1992, OCTA has worked closely with its Special Needs in Transit Advisory Committee, a citizens group which advises OCTA on issues relating to transit and paratransit services. In concert with that Committee and over the last ten years, OCTA has made significant capital investments in its shelters, stops, buses, and call boxes to comply with the federal Americans with Disabilities Act (ADA). These investments include:
. Since 1996, OCTA has provided over $5 million to many of its region's 34 cities to remodel bus shelters to make them ADA compliant and in the next five years, plans to expend over $5 million more.
. OCTA recently completed a major retrofit of its 1,300 freeway emergency call boxes to install teletypewriter devices and achieve ADA compliance at a cost of over $3 million.
. Since 1994, OCTA has funded the ACCESS program which provides shared-ride paratransit service for those unable to use the regular, fixed route bus service because of functional limitations caused by a disability at a cost of approximately $21 million annually.
While OCTA has made significant progress in meeting and exceeding the requirements of current ADA regulations in its bus fleet, emergency call boxes, and bus stops, we believe that the Access Board's draft guidelines for the construction or reconstruction of bus shelters, curbs, and street crossings could negatively affect future city and county construction. Further, the proposed standards for bus route identification are particularly burdensome to OCTA. Our specific comments on these two areas of concern are addressed as follows:
Construction Standards
OCTA is concerned that some of the standards listed in the guidelines could have a dampening effect on new construction or alterations either because they would be cost prohibitive or because local governmental entities would not be able to comply with the guidelines for practical reasons. The specific areas identified as problematic include:
Section 1103.3 Minimum Clear Width specifies a minimum clear width of 48 inches
Section 1102.6 Curb Ramps and Blended Transitions would require that transitions connecting pedestrian access routes to street crossings to be located within the width of each crosswalk. Separate curb ramps to both crosswalks at a corner instead of a single ramp at the diagonal apex may be preferable but are generally not practical on urban streets due to storm drain inlets, utility poles, and signal standards. The costs of moving these facilities can run into the thousands of dollars and significantly add to the overall project expense.
Section 1104.3.3-1104.3.7 Other Requirements for Curb Ramps and Blended Transitions would prohibit the placement of gratings, storm drain utility and sewer access covers, and similar fixtures on ramps, landings, transitions, and portions of the gutter within the pedestrian access route. As the guidelines apply not only to new construction but to alterations of existing facilities, the costs associated with moving these facilities, as stated before, can run into the thousands of dollars and are not always practical. Even new construction may at times not be operationally or economically viable if the Access Board's draft guidelines must be followed in every instance.
Bus Route Identification
Section 1102.7.1 Bus Route Identification requires bus route identification signs located at bus shelters to have raised and Braille characters. While OCTA does not own and is not responsible for the bus rights-of-way and shelters maintained throughout the county, it does maintain bus signs noting the route numbers at the stops.
We agree with the letter sent to you by the American Public Transportation Association (APTA) dated October 28, 2002 in
In lieu of the above requirement, we recommend another way of addressing this issue would be a requirement to identify the bus stop by the name of the bus service company (i.e. Orange County Transportation Authority) along with an individualized bus stop identification number (i.e. #1640) written in Braille and posted on the bus stop. These signs would only need to be posted once no matter how many times the routes or bus numbers changed. Information on the bus routes, times, frequency, etc. could then be obtained via a telephone call identifying the bus stop identification number. OCTA is currently working on implementing such a system now in Orange County.
If you or your staff has any questions regarding OCTA's comments on the Access Board's draft guidelines, please call Sue Zuhlke, Manager of Government Relations, at [ ... ].
Sincerely,
Arthur T. Leahy
Chief Executive Officer
ATL:crm
c: California League of Cities
California State Association of Counties
Douglas J. Cross, October 28, 2002
AC Transit
Alameda-Contra Costa Transit District, Oakland, California
RE: Draft Guidelines for Accessible Public Rights-of-Way
Dear Mr. Windley:
AC Transit is writing to respond to the Access Board's draft ADAAG guidelines for accessibility in public rights-of-way. AC Transit is the public transit system in the San Francisco East Bay area, operating a fleet of 800 buses and 180 paratransit vehicles. We serve a diverse population that includes many individuals with disabilities. Our service area is home to many disability-oriented advocacy and service organizations, with constituencies at the local, state, national, and international levels. AC Transit's Accessibility Advisory Committee (AAC) has been a pioneering leader in consumer advocacy for local public transportation systems.
1102.7.1 Bus Route Identification: We do not agree that Braille/raised print route identifications should be required at bus shelters. In our area, shelters are provided and controlled by municipalities, not the transit system. In the Bay Area, Braille/raised print identifiers are usually placed on bus stop sign poles, by the transit system. They are not directly associated with shelters, which are sometimes placed for advertising visibility, not for transit ridership reasons.
AC Transit has nearly 7,000 stops. It is common for transit agencies, including AC Transit, to change schedules and routes often. Braille/raised print signs which must be customized for certain bus stops are expensive to make, and even more expensive to keep current. They are much more involved than stop sign decals, which can be changed easily. Local transit systems have limited field staff, and cannot be expected to handle the cost and complexity of maintaining tactile signage, without additional resources.
AC Transit is currently experimenting with bus route numbers in Braille/raised print on selected route information signs. We foresee adopting a tactile signage standard that will provide for route numbers at bus stops where there are multiple bus stop poles. This situation exists at transit centers, rail station transfer locations, and major downtown transfer locations. Some of these have shelters, and some do not.
AC Transit is considering a universal identifier for all other bus stops, most likely saying simply "Bus". This type of sign is in use by many transit systems, and has been found useful to blind passengers, where a variety of poles and posts can make finding the bus stop confusing. The AC Transit AAC agrees with management that full "route identifier" signs should not be required at all stops, or those with shelters, and that the simple "universal identifier" may be a more reasonable ADAAG requirement.
In any case, the proposed ADAAG requirement is unclear. It should state more specifically what information is required, at a minimum. Many transit systems have information about destinations, frequency, time span, and other items on route signs. This amount of information would not fit on the narrow type of Braille/raised print signs AC Transit and other Bay Area transit systems are using, which must fit on a vertical signpost, without creating a hazard for pedestrians. Our plans are to provide only the route number or letter as the "route identifier".
1103.3 Pedestrian Access Route Clear Width: Sidewalk width is not a factor under the control of most transit systems, including AC Transit. Our staff feels that it is reasonable to require adequate sidewalk space where feasible. We would be wary, however, of any interpretation that would preclude the placement of bus stops at new or re-built locations that did not comply. While we work cooperatively with local municipalities to provide facilities that support transit usage, we ultimately cannot control them. We are also sensitive to the potential problems pointed out in the American Public Transportation Association's (APTA) letter to you of Oct. 28, 2002. One issue is that such a provision may discourage local jurisdictions from improving their sidewalks.
In reviewing the proposal, our advisory committee, the AAC, felt that the originally-contemplated width of 60" would be more appropriate than the final draft figure of 48", for reasons of promoting increased accessibility. Our staff pointed out that while this may be a worthy goal, it could create even more problems of the type mentioned in the APTA letter.
1104.3.2 Detectable Warnings: We support the proposed changes to the technical specifications of truncated dome detectable warnings. However, we think it is premature to expand the application of these warning features, due to several outstanding issues associated with their use.
In California, the state building code already provides for a different type of textural feature alerting pedestrians to the presence of curb ramps. There is also a potential for the proposed 24" application to be confused with rail (or Bus Rapid Transit) platform edges. If this requirement is pursued, the original concept of 36" for marking hazardous vehicular ways should be more strongly considered. In general, both our staff and AAC feel that more research and public input should be conducted before changing the existing guidelines.
We appreciate the opportunity to comment on this proposal and look forward to an NPRM that accommodates the comments of all affected parties. If you need any further information, please feel free to contact me at [...].
Sincerely,
Douglas J. Cross
Accessible Services Manager
Alan R. Zahradnik, October 28, 2002
Re: Comments on Draft Guidelines for Accessible Public Rights-of-Way
The Golden Gate Bridge, Highway and Transportation District (District) is pleased to respond to the Architectural and Transportation Barriers Compliance Board's (ATBCB) draft guidelines addressing accessibility in the public right-of-way.
District operates the Golden Gate Bridge and provides public bus, ferry, and paratransit services within the U.S. Highway 101 corridor between destinations in the counties of Marin, Sonoma, Contra Costa, and San Francisco, California. Golden Gate Transit (GGT) serves approximately 1200 bus stops and transit facilities within these four counties. These stops are located within the public right-of-way of over 22 different city and unincorporated county jurisdictions. In addition, GGT has over 30 years of experience providing public transit services, including cooperating with those agencies that have jurisdiction over the rights-of-way where these stops are located. Based on this experience, the District has the following comments regarding the draft guidelines:
1. Guideline No. 1102.7.1- Bus Route Identification:
This guideline provides that 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.
District Comment: ATBCB should remove the requirement for Braille and raised letter route identifications. It is common for transit agencies to change schedules and routes three and four times per year. Transit agencies also replace or install bus shelters often. In order for signs to be made which withstand normal use, weather conditions, and
vandalism, it is necessary to make them of durable materials such as aluminum. This requires a separate die to be fabricated for each bus stop. Average costs of having dies fabricated begin at fifteen hundred dollars. The expense of fabricating signs and the logistics of installing/replacing Braille and raised letter signs would be prohibitive to transit authorities. Technological advances in the future may provide the opportunity to more practically address this issue compared to the regulation that is being proposed.
In addition, some stops have many routes serving one location. The proposed change, which would lower the mid-sign reach of 48 inches
2. Guideline No. 1103.3 - Pedestrian Access Route Clear Width: The guideline provides that the minimum clear width of a pedestrian access route be 48 inches
District Comment: The District believes it could be impractical to provide a total clear width of 54 inches
This paragraph may also preclude a transit system from installing a bus sign on a sidewalk that is less than 72 inches
3. Guideline Nos: 1104.3.2 Detectable Warnings. The guideline provides that detectable warning surfaces complying with guideline 1108 shall be provided, where a curb ramp, landing, or blended transition connects to a crosswalk.
1108.1 General. The guideline provides that detectable warnings shall consist of a surface of truncated domes aligned in a square grid pattern and shall comply with 1108.
1108.1.4 Size. The guideline provides that detectable warning surfaces shall extend 24 inches
District Comment: The District recommends the requirement for truncated domes at curb ramps, landings and blended transitions be removed from the guidelines. Truncated domes should only be used on transit platform edges. Truncated domes can set off muscle spasms for spinal injury citizens in wheelchairs. Use of truncated domes in curb ramps and crosswalks which are adjacent to light rail or commuter rail platforms may cause persons who are blind or partially sighted to become confused as to where they are and could lead to serious injury. An alternative tactile tile should be used in this application. If the provision is not removed, the minimum standard should be 36 inches
Thank you for the opportunity to comment on this proposal. District looks forward to a Notice of Proposed Rulemaking that considers and is responsive to the comments outlined above.
Very truly yours,
Alan R. Zahradnik
Planning Director