The minimum clear width of a pedestrian access route shall be 48 inches
(1220 mm), exclusive of the width of the curb
Leslie Salgado-Tamayo, October 28, 2002
Please find enclosed the comments we have on the Access Board's Draft Guidelines on Accessible Public Rights of Way. Please note that we have not commented on those items that do not affect our transit facilities. I hope that this is helpful to you in the process of preparing the new guidelines on public rights-of-way. Please call me at [...], should you have any questions or comments.
Sincerely,
Leslie Salgado-Tamayo
Chief, ADA and Special Projects,
Facilities Engineering Maryland Transit Administration
Maryland Transit Administration (MTA) - Comments on the
"Draft Guidelines for Accessible Public Rights-of-Way"
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.
MTA's comment
- What constitutes an "alteration"? We need more definite guidelines. This is not a new problem with ADAAG.
- We need a better definition of "maximum extent feasible". Is there a dollar amount? More guidance needed.
1102.3 Alternate Circulation Path. An alternate circulation path complying with1111 shall be provided whenever the existing pedestrian access route is blocked by construction, alteration, maintenance, or other temporary conditions.
MTA's comment
- Refer to comment under 1111.
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.
MTA's comment
- It is not clear if providing bus route identification signs, at bus shelters, in raised and Braille characters is required only where bus route identification signs in compliance with 703.5.5 are provided. If required, at bus shelters, what are the recommended placement locations, since shelters don't have doors?
1102.8 Pedestrian Crossings. Where a pedestrian crossing is provided, it shall comply with the applicable provisions of1105.
MTA's comment
- See comment under Section 1105.
1102.10 Stairs. Where provided, stairs shall comply with 504. Stair treads shall have a 2 inch
MTA's comment
- "2 inch
1103.3 Clear Width. The minimum clear width of a pedestrian access route shall be 48 inches
MTA's comment
- This increases the minimum clear width from 36 to 48 inches
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
MTA's comment
Allowing the 3-inch gap helps clear an ongoing problem where transit agencies provide their services via tracks owned by freight companies.
1104.2.1.3 Landing. A landing 48 inches
MTA's comment
- This reflects the new increased width of sidewalk (from 36 to 48 inches). This will result in increased construction costs and, in some cases require additional right-of-way. We recommend that you allow 36 inches
1104.2.2.3 Landing. A landing 48 inches
MTA's comment
- This reflects the new increased width of sidewalk (from 36 to 48 inches). This will result in increased construction costs and, in some cases require additional right-of-way. We recommend that you allow 36 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.
MTA's comment
- What constitutes a drop-off where a "barrier" would be required?
1104.3.2 Detectable Warnings. Detectable warning surfaces complying with1108 shall be provided, where a curb ramp, landing, or blended transition connects to a crosswalk.
MTA's comment
- This is a new requirement that will create tripping hazards and the resulting liability as well as increased maintenance costs.
1104.3.7 Clear Space. Beyond the curb line, a clear space of 48 inches
MTA's comment
- Diagram needed in order to better understand this requirement.
1105.2 Crosswalks. Crosswalks shall comply with 1105.2.
1105.2.1 Width. Marked crosswalks shall be 96 inches
MTA's comment
- This is an increase of two feet over MUTCD's 72 inch
1105.2.2 Cross Slope. The cross slope shall be 1:48
MTA's comment
- Meeting this requirement may be highly unrealistic when dealing with existing roads or parking lots that are being upgraded.
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 with1103.
1105.5.2 Running Slope. The running slope shall not exceed 1:20
1105.5.3 Approach. Where the approach exceeds 1:20
MTA's comment
- This new requirement will have major design, construction, maintenance and safety impacts on our agency. The need to have a limit to the maximum rise for a ramp is understandable. However, 60 inches
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.
MTA's comment
- Providing a 36 inch
William W. Millar, American Public Transportation Association, October 28, 2002
American Public Transportation Association
RE: Draft Guidelines for Accessible Public Rights-of-Way
The American Public Transportation Association (APTA) 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.
About APTA
APTA is a nonprofit international association of over 1,500 public and private member organizations including transit systems and commuter rail operators; planning, design, construction and finance firms; product and service providers; academic institutions, transit associations and state departments of transportation. APTA members serve the public interest by providing safe, efficient and economical transit services and products. Over ninety percent of persons using public transportation in the United States and Canada are served by APTA members.
Comments
APTA has been part of this rulemaking from its inception and will continue to participate in the development of guidelines related to accessibility in the public right-of-way. Indeed, since 1999, APTA has contributed its input to the Public Rights of Way Access Advisory Committee. Now, with the release of the draft guidelines, APTA has the following comments:
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.
Comment: Remove requirement for Braille and raised letter route identifications. It is common for transit agencies to change schedules and routes three or four times per year. Transit agencies also replace or install bus shelters often. For signs to 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; the average cost of having dies fabricated begins at fifteen hundred dollars. In short, the expense of fabricating signs and the logistics of installing/replacing Braille and raised letter signs would be prohibitive to transit authorities. We suggest that the Access Board explore ways that could more practically address this issue, including new technologies.
Some stops have up to 30 or more different vehicle routes stopping at one location. The proposed change, which would lower the mid-sign reach of 48 inches
1103.3 Pedestrian Access Route Clear Width. The minimum clear width of a pedestrian access route shall be 48 inches
Comment: It could be very impractical to provide a total clear width of 54", from face of curb to the back of the sidewalk, for the accessible route due to tight right-of-ways. Many sidewalks are about 42" wide with utility poles right in the middle. Some cities also have a 24" - 36" clear zone from the face of curb where no utility poles/trees/bus signs shall be installed. Adding the 24" utility-clear zone, plus the diameter of utility pole base (about 12"-18") to the 48" ADA clear width, the sidewalk width would be 84" wide. Any such sidewalk improvement would require acquiring property from adjacent owners, which will definitely increase project cost. Such a provision would discourage local jurisdictions from improving their sidewalks.
This paragraph also may preclude a transit system from installing a bus sign on a sidewalk with less than 72" (6 ft) wide (24" clear zone from face of curb and 48" ADA clear zone). We are also concerned about the definition on accessibility clearances around the bus stop or information sign. If the 48" ruling applies around the entire sign, this poses another significant problem.
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.
1108.1 General. Detectable warnings shall consist of a surface of truncated domes aligned in a square grid pattern and shall comply with 1108.
1108.1.4 Size. Detectable warning surfaces shall extend 24 inches
Comment: We recommend that truncated domes not be required at curb ramps, landings and blended transitions. In our view, truncated domes generally should only be used on transit platform edges. Truncated domes can set off muscle spasms for persons with spinal injuries in wheelchairs. Moreover, use of truncated domes in curb ramps, crosswalks, and blended transitions may cause persons with visual impairments to become confused as to where they are and could lead to serious injury. Currently, truncated domes are used at rail stations to indicate to persons with visual impairments to stop; in contrast, the guideline proposes to use truncated domes at curb ramps to indicate to a person with visual impairments to proceed. An alternative tactile tile must be used in this application. If the provision is not removed the minimum should be 36 inches
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.
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.
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.
Comment: The requirement for the alternate circulation path to be parallel to the disrupted pedestrian access route and on the same side of the street is very often not possible due to the nature of constructions projects which are causing the disruption. In situations where entire rights-of-way are being built or redesigned there is often no safe area to establish a pedestrian access route which meets this guideline. We recommend that the proposed guideline be changed to read that the alternate circulation path shall be located in the safest and most direct route feasible within the scope of the construction project.
Conclusion
We appreciate the opportunity to comment on this proposal and look forward to an NPRM that accommodates the comments of all affected parties. For further information, please contact Kristin O'Grady at [... ].
Sincerely yours,
William W. Millar, President
Wilma J. Smith, P.E., October 28, 2002
The City Of Arlington's comments are attached and come from the following:
Michael J. Hasler, PE, Director of Transportation
Wilma J. Smith, PE, Assistant Director of Transportation
David Boski, PE, Transportation Engineering Manager
Sholeh Karimi, PE, Transportation Engineering Manager
Paul Iwuchukwu, PE, Transportation Engineering Manager
Jill House, PE, Interim Assistant Director of Engineering
Lori A. Chapin, PE, Civil Engineer
Rey Gonzales, Traffic Operations Manager
Juanita Bridges, Transit Manager
Mike Blake, Traffic Signal Analyst
Thank you for giving us an opportunity to review the proposed guidelines and provide comments. If you have questions or require additional information, please contact me via email or phone at [...].
Wilma J. Smith, P.E.
Assistant Director of Transportation
City of Arlington
Mike Hasler's Comments
Additions and Alterations (1102.2)
Paragraph 2
Last sentence
Question: What if alteration is only a partial project where it doesn't "connect" to anything else? It doesn't make sense to have it comply when nothing else does on either side.
Minimum Clear Width (1103.3)
Paragraph 1
First sentence and Last two sentences
Comment: Larger than private SW's, widths between handicap spaces and most doorways
Surfaces (1103.6)
Paragraph 1
First sentence
What is the meaning of granite pavers?
Perpendicular Curb Ramps (1104.2.1)
Diagram
What is the minimum width?
Detectable Warnings (1104.3.2)
Paragraph 2
Second sentence
What is 2 feet
Mike Hasler's Comments
Page 2
Crosswalks (1105.2)
Paragraph 2
Last 2 sentences
Comment: No matter the impact on ROW, grades, access to adjacent property, drainage, walls cost, impact on vehicle speeds and occupants.
Pedestrian Signal Phase Timing (1105.3)
Paragraph 1
First sentence
Comment: 32 seconds
Vertical Access (1102.12)
Question: Any safety mechanism designed in case of power outage?
On-Street Parking (1102.14, 1109)
Paragraph 2
Second sentence
Statement can be achieved by indenting the curb line
Comment: But could also cause a grade problem or impediment.
1105.2.2 Cross Slope
Question: Perpendicular to pedestrians which is the direction of vehicle travel 2% slope on roadway?
1105.2.3 Running Slope
Comment: 5% cross slope
Memorandum
TO: Wilma J. Smith, P.E., Assistant Director of Transportation
From: Juanita Bridges, Transit Manager
Date: October 22, 2002
Subject: ADA Public ROW Guidelines Comments
The following are comments that I had regarding the "Draft Guidelines for Accessible Public Rights-of-Way".
Under the Discussion of Provisions section, I had the following comments:
1. General Scoping: New Construction, Alterations, and Additions 1102, there should be a distinction between "minor" and "major" alterations added. There should be an exception made to this provision if the total cost of the accessibility features exceeds the total cost of the alteration project.
2. Accessible Elements and Spaces: Scoping and Technical Requirements, Minimum Clear Width 1103.3, I believe that the minimum clear width should be 36 inches
3. Accessible Elements and Spaces: Scoping and Technical Requirements, Surface Gaps at Rail Crossings 1103.7, the guideline does not clarify if the local authority or the rail road is responsible for complying with the gap and the detectable warning requirements. The local authority, in most cases, does not own or have control over the train tracks or the ground surface adjacent to the tracks.
4. Accessible Elements and Spaces: Scoping and Technical Requirements, Common Elements 1104.3, the minimum clear width should be reduced from 48 inches to 36 inches
5. Accessible Elements and Spaces: Scoping and Technical Requirements, Detectable Warnings 1104.3.2, the guideline specifies that truncated domes be used as the minimum standard detectable warning device, however, truncated domes are a severe tripping hazard for visually impaired people.
6. Accessible Elements and Spaces: Other Requirements for Curbs, Ramps and Blended Transitions 1104.3.3 - 1104.3.7, in the last bullet, it specifies a clear space of 48 x 48 inches
7. Pedestrian Crossings: Crosswalks 1105.2, the crosswalk width should be the same as the MUTCD - 72 inches
8. Accessible Pedestrian Signal Systems 1102.8, 1106, it specifies, at intersections that allow pedestrian traffic, walk indicators should include additional audible and tactile indicators. I believe this should only be required at intersections that have marked pedestrian crosswalks and not at every intersection. Another option would be to require them at intersections that have crosswalks and/or sidewalks that allow pedestrian foot traffic. However, to require them at every intersection is unreasonable and cost prohibitive.
Under the Text of Draft Guidelines section, I had the following comments:
1. 1102.10 Stairs, the contrasting color strip should be marked with a contrasting color tone and not just a different color because visually impaired persons may not see color, but can more easily distinguish differences in color tone.
2. 1103.3 Clear Width, the minimum clear width should be 36 inches
3. 1104.2.1.3 Landing, a landing should be a minimum of 36 by 36 inches
4. 1104.2.2.3 Landing, a landing should be a minimum of 36 by 36 inches
5. 1104.3.1 Width, again the minimum width should be 36 inches
6. 1104.3.7 Clear Space, the minimum width should be 36 by 36 inches
7. 1108 Detectable Warning Surfaces, General, truncated domes are not a good device to use as a tactile warning device. For visually impaired persons, truncated dome can be a tripping hazard.
If you have any questions or need additional information, please let me know.
Thanks!
RESPONSES TO DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY DATED JUNE 17, 2002
DISCUSSION OF PROVISIONS
Additions and Alterations (1102.2)
1. Definition for "substantial reconstruction" open to subjectivity
2. Definition for "limited improvements" open to subjectivity
3. Who defines "technically infeasible"?
4. Who makes the determination on a case by case basis?
5. What is the potential cost for delays during the evaluation?
6. Delays and requirements will increase overall cost of doing business in public rights-of-way significantly
Surface Gaps at Rail Crossings ( 1103.7)
1. Detectable warnings for each track approach within the railroad rights-of-way would be whose responsibility to install and maintain?
Curb Ramps and Blended Transitions (1102.6, 1104)
1. The dual ramp requirement causes several issues at existing intersections and even more issues at new intersections. At existing intersections, not only will existing storm drains and utility poles pose a problem, but also where dual curb ramps can be installed a visibility issue for vehicular traffic will exist. Dual ramps force the installation at the terminus of a curb return. In turn, the crosswalk and stop bar have to match the curb ramps; therefore, installation of a 96" cross walk, 24" stop bar and the necessary spacing between will force the vehicle stop point behind the current visibility clips at intersections.
Perpendicular Curb Ramps (1104.2.1)
1. 48" X 48" level landings at the top of ramps will require additional rights-of-way purchases to accommodate. Clear space requirements will increase this need at intersections as well.
Detectable Warnings (1104.3.2)
1. Depending on the application, the truncated domes may still cause problems for wheel chair users.
Informational Signs and Warning Signs (1102.7.2)
1. It is unclear what the expectation is from the new guidelines as to what these signs are expected to provide for visually impaired pedestrians.
Pedestrian Crossing (1102.8, 1105)
1. Profile grades of 2 percent at intersection crosswalks are normally reasonable; however, in street conditions that have over 5 percent continuous grade, this requirement will have an overwhelming affect on construction cost for new and existing intersections.
Roundabouts (1105.6)
1. This guideline will all but eliminate the use of this method of continuous flow application due to cost and the fact that continuous flow would no longer be attainable.
Lori Chapin has reviewed the new ADA regulations you sent Keith from our perspective. For the most part, the new regulations would help clear up some issues from our perspective, assuming they would also be incorporated into the Texas Accessibility Standards which is what TDLR enforces. The few items we would like to include in comments you forward back to TEXITE or whatever procedure has been set up are attached. Please give me or Lori a call if you have questions. Thanks.