The surfaces of the pedestrian access route shall comply with 302
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
Rodney T. Andrade, August 14, 2002
Gentlepersons:
By way of introduction, MacKay & Somps is company that has specialized in providing private and public clients with planning, engineering and surveying services for land development and public works projects for about 50 years. We are consistently ranked in the 200's of the Engineering News Record's top 500 design firms in the country.
The following constitutes our company's comments on the above referenced Draft
Guidelines:
1. It is presumed that not all public street systems must comply with the criteria proposed, rather compliance is required for designated "Pedestrian Access Routes" only. Clarification of when "Pedestrian Access Routes" are required is very important since the design criteria proposed will be very difficult to achieve on many projects. Requiring local agencies to officially determine those routes that qualify as "Pedestrian Access Routes" should be considered. Specific guidelines (with examples) as to how Pedestrian Access Routes are identified is a significant issue. For instance, would a Pedestrian Access Route be required to connect a bus stop to a private (HOA owned) swimming pool complex? If so, what if the complex is some distance from the bus stop? If so, must the Pedestrian Access Route connect the pool facility to all bus stops or just one? What about a small park site in hillside areas where compliance is impossible? We fear that lack of detailed guidance in this regard will lead to local agencies requiring that all public streets comply with these standards which will be an impossible situation.
2. Private land development projects typically involve the construction of public streets and often have a quite extensive and time-consuming approval process with which to comply. Often project planning and design is underway for many years before construction is allowed to proceed. Will the Board allow projects involved in the midst of these planning and design efforts to avoid having to comply with the design criteria proposed? Some "grandfathering" of projects must be considered.
3. For many years local agency public works standards have required that "accessibility" be incorporated in all public street construction. This effort is most evident by the installation of accessible ramps at every new curb return constructed. Assuming that the proposed standards apply to "Pedestrian Access Routes" only, should current standards continue to apply to other public streets? This will introduce a situation where different standards apply to different streets, potentially a confusing (for the public) situation. How will a "user" identify in the field which route complies with the new standards?
4. Should horizontal alignment standards be included in the document (consider meandering sidewalks or walks that jog 90% around driveways)?
5. Public works standard sidewalk cross slopes (as well as other infrastructure elements like cross slopes) are typically 2%. We suggest the 1:48
6. The requirement for no more than a 1:48
7. The proposed standards do not allow grade breaks "at gutter areas within the Pedestrian Access Route". We assume that this precludes grade breaks in the gutter where the Pedestrian Access Route crosses the gutter at a curb ramp. It is not reasonable that no grade breaks be allowed. Rather, how much of a grade break can be tolerated (1%?) should be evaluated.
8. We do not understand how crosswalk requirements would apply to unmarked crossing wherever pedestrian travel across the roadway is not prohibited.
9. We do not think limiting the ramp height at over-crossings or under-crossings to 60 inches
10. Please clarify the requirement for signals at "right or left turn slip lanes". We assume this criteria applies where free right or left turns are allowed without stopping at an intersection and not where standard deceleration lanes are constructed.
11. Parking is required at the rate of one space per "block face". Blocks (space between intersections) vary substantially so we suggest a maximum spacing be defined. Also, we assume that this parking is required along a Pedestrian Access Routes only. Please clarify.
12. Current ADA standards allow private development in hillside areas to be exempted from requirements. It is suggested that, since land development projects in hillside areas normally include public streets, this type of an exemption from public right of way accessibility standards be established.
13. The draft includes various graphics which would be much more helpful if dimensional requirements and maximum slopes were shown on the graphics.
14. We suggest that traffic signal timing requirements be reviewed by professional traffic engineers as to it's impact on municipal traffic systems.
Thank you in advance for your thoughtful consideration of our comments.
Best regards,
Rodney T. Andrade
Mackay & Somps
Victor M. Mendez, P.E., October 21, 2002
Arizona Department of Transportation
Intermodal Transportation Division
RE: COMMENTS ON AMERICANS WITH DISABILITIES ACT DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY
Dear Mr. Windley:
The Arizona Department of Transportation (ADOT) has reviewed the Americans With Disabilities Draft Guidelines for Accessible Rights-of-Way published on 17 Jun 2002. ADOT endorses the Board's aim of ensuring that access for persons with disabilities is provided wherever a pedestrian way is newly built or altered, and that the same degree of convenience, connection, and safety afforded the public generally be available to pedestrians with disabilities.
Noting our endorsement of the Board's aim, we have taken the time to comment on each of the sections and sub sections to the draft guidelines in hope of assisting in the rulemaking process. The comments are enclosed for consideration by the Architectural and Transportation Barriers Compliance Board. We understand that the Board will review all the comments submitted prior to continuing with the proposed rulemaking.
Please contact Kenneth Cooper at [...] if you or the Board have any questions or if you wish to discuss the comments.
Sincerely yours,
Victor M. Mendez, P.E.
Director
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COMMENTS FROM ARIZONA DEPARTMENT OF TRANSPORTATION
AMERICANS WITH DISABILITIES ACT
DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY
PUBLISHED JUNE 17, 2002
General Comments:
A. The Arizona Department of Transportation (ADOT) supports the position expressed in the Introduction to the Draft Guidelines for Accessible Public Rights-of-Way that, "The guidelines do not require alterations or retrofits to existing public rights-of-way, but would apply where a pedestrian route or facility is altered as part of a planned project to improve existing public rights-of-way.";
B. ADOT recommends the inclusion of graphics to help clarify and explain the guidelines; and
C. ADOT strongly recommends that maximum crosswalk, landing, and ramp slopes be redefined to take into account the grade of the adjacent facility. It may be technically infeasible and poor engineering practice to provide running and/or cross slopes of 1:48
Sec. 1101 Application and Administration
Sec. 1101.1 General: For the purposes of these requirements, the terms listed in section 1101.3 shall have the indicated meaning.
ADOT has "No comment" on this section.
Sec. 1101.2 Referenced Standards
Recommend that the following manuals also be included by reference into the guidelines as they provide nationally accepted guidance regarding the design of roadways and pedestrian facilities:
A. American Association of State Highway and Transportation Officials (AASHTO), A Policy on Geometric Design of Highways and Streets 2001;
B. AASHTO, Roadside Design Guide 2002; and
C. Federal Highway Administration, Highway Design Handbook For Older Drivers and Pedestrians 2001.
Sec. 11012.1 MUTCD: Copies of the referenced standards may be obtained on-line from the Federal Highway Administration at http://mutcd.fhwa.dot.gov. MUTCD 2000-Millennium Edition Manual on Uniform Traffic Control Devices.
The Arizona Department of Transportation (ADOT) supports the inclusion of the Manual on Uniform Traffic Control Devices (MUTCD) into the guidelines by reference.
Sec. 1101.3 Defined Terms:
ADOT requests a definition be added that clarifies where slope maximum and minimum values are provided, "maximum" and "minimum" refer to the steepness of the slope.
Accessible Pedestrian Signal. A device that communicates information about the pedestrian WALK phase in non-visual format.
Accessible Route. A continuous, unobstructed path that complies with Chapter 4.
Channelizing Island. Curbed or painted area outside the vehicular path that is provided to separate and direct traffic movement, which also may serve as a refuge for pedestrians.
Cross Slope. The slope that is perpendicular to the direction of travel.
This is usually called superelevation on curves in the public right-of-way (see superelevation).
ADOT requests clarification of this definition as the second sentence is not wholly correct. Curves in the public right-of-way may have a normal crown and not be superelevated. Superelevation usually occurs, but not exclusively, in rural settings and where the prevailing speed is greater than 35 miles per hour.
Crosswalk. That part of a roadway at an intersection that is included within the extensions of the lateral lines of the sidewalks on opposite sides of the roadway, measured from the curbline or, in the absence of curbs, from the edges of the roadway or, in the absence of a sidewalk on one side of the roadway, the part of the roadway included within the extension of the lateral lines of the sidewalk at right angles to the centerline. Also, any portion of a roadway at an intersection or elsewhere that is distinctly indicated for pedestrian crossing by lines or other markings on the surface.
ADOT requests clarification of this definition as it appears to conflict with the requirements for crosswalk width as detailed in Sec. 1105.2.1 Width since existing sidewalks are often less than ninety-six inches (96-in) in width. Sidewalks location is quite variable in relation to the curb line while the location of the crosswalk should be established beyond the stop bar, if present, and stop bar location is a function of the radius of the intersection. Therefore, ADOT recommends that the location of the crosswalk not be defined in relation to the sidewalk location.
Curb Line. A line at the face of the curb that marks the transition between the sidewalk and the gutter or roadway.
Curb Ramp. A ramp cutting through a curb or built up to it.
Detectable Warning. A surface feature built in or applied to walking surfaces or other elements to warn of hazards on a circulation path. Dynamic Envelope. The clearance required for a rail vehicle and its cargo overhang due to any combination of loading, lateral motion, or suspension failure.
Element. An architectural or mechanical component of a building, facility, space, site or public right-of-way.
Facility. All or any portion of buildings, structures, improvements, elements and pedestrian or vehicular routes located on a site or in a public right-of-way.
Grade. (See running slope).
Grade Break. The meeting line of two adjacent surfaces of different slope (grade).
Locator Tone. A repeating sound that identifies the location of the pedestrian push button.
Pedestrian Access Route. An accessible corridor for pedestrian use within the public right-of-way.
Public Right-of-Way. Land or property, usually in a corridor, that is acquired for or devoted to transportation purposes.
ADOT recommends adding the phrase "and under the jurisdiction of a public agency." As written, the definition could also define parking lots or private transportation facilities such as found in gated communities.
Roundabout. A circular intersection that has yield control of entering traffic, channelized approaches, counterclockwise circulation, and appropriate geometric curvature to limit travel speeds on the circulatory roadway.
Running Slope. The slope that is parallel to the direction of travel expressed as a ratio of rise to run. In the public right-of-way, this is usually called grade, and is expressed in percent.
Sidewalk. That portion of a public right-of-way between the curb line or lateral line of a roadway and the adjacent property line that is improved for use by pedestrians.
Recommend replacing the word "lateral" with "edge" and the term "adjacent property" with "right-of-way".
Splitter Island. A flush or raised island that separates entering and exiting traffic in a roundabout.
Street Furniture. Elements in the public right-of-way that are intended for use by pedestrians.
Superelevation. Cross slope on a curie in the roadway (see cross slope).
Recommend deletion of this term.
Walk Interval. That phase of a traffic signal cycle during which the pedestrian is to begin crossing, typically indicated by a WALK message or the walking person symbol and its audible equivalent.
Sec. 1102 Scoping Requirements
Sec. 1102.1 General: All areas of newly designed and newly constructed facilities in public rights- of-way and altered portions of existing facilities in public rights-of-way shall comply with Chapter 11.
ADOT supports the position that the new guidelines apply to areas of newly designed and constructed facilities in public rights-of-way and requires provision of sidewalks, street crossings, street furniture, parking, or other pedestrian elements only where they are provided as part of construction or improvement projects. ADOT supports clarification of the guideline explicitly stating that pavement-surface treatment projects such as seal coats, friction-course overlays, and mill-and-replace projects not be considered as construction or improvements triggering compliance with these guidelines.
Sec. 1102.2 Existing Public Rights-of-Way. Additions to existing public rights-of-way shall comply with 1102.2.1. Alterations to existing public rights-of-way shall comply with 1102.2.2.
Sec. 1102.2.1 Additions: Each addition to an existing public right-of-way shall comply with the applicable provisions of Chapter 11. Where the addition connects with existing construction, the connection shall comply with 1102.2.2.
ADOT has "No comment" on this section.
Sec. 1102.2.2 Alterations: Where existing elements or spaces in the public right-of-way are altered, each altered element or space shall comply with the applicable provisions of Chapter 11.
EXCEPTION: In alterations, where compliance with applicable provisions is technically infeasible, the alteration shall comply to the maximum extent feasible.
ADOT supports the position that the guidelines apply to alterations to existing facilities only in relation to the scope of the project. We think the term "technically infeasible" should be expanded to clearly include consideration of site conditions and topography. We also support the position that lack of existing public right-of-way may be a sufficient reason to prevent the widening of sidewalks and would like to see language in the guideline relieving agencies of any obligation to purchase additional right-of-way. ADOT could support sidewalk widening through the use of no-cost, dedicated pedestrian easements over private land. ADOT also supports the position that new facilities should smoothly transition into older ones.
Sec. 1102.2.2.1 Extent of Application: An alteration of an existing element, space, or area of a public right-of-way shall not impose a requirement for accessibility greater than required for new construction.
ADOT supports the position that an alteration of an existing area of a public right-of-way shall not impose a requirement for accessibility greater than required for new construction.
Sec. 1102.2.2.2 Prohibited Reduction in Access. An alteration that decreases or has the effect of decreasing the accessibility of a public right-of-way or site arrival points to buildings or facilities adjacent to the altered portion of the public right-of-way, below the requirements for new construction at the time of the alteration is prohibited.
ADOT supports the position that an alteration shall not decrease the accessibility of a public right-of-way below the requirement for new construction at the time of the alteration.
Sec. 1102.3 Alternate Circulation Path: An alternate circulation path complying with 1111 shall be provided whenever the existing pedestrian access route is blocked by construction, alteration, maintenance, or other temporary conditions.
ADOT strongly opposes adoption of this section as written. The current language could require the construction of an alternative circulation path for situations such as the short-term maintenance of the sidewalk or adjacent road. See Section 1111 Alternate Circulation Path for further comments. Compliance would present an unacceptable burden upon the State and local jurisdictions, and the motoring public without a commensurate benefit to pedestrians.
Sec. 1102.4 Sidewalks: Where sidewalks are provided, they shall contain a continuous pedestrian access route complying with 1103. The pedestrian access route shall connect to elements required to comply with Chapter 11.
ADOT supports the position that where sidewalk is provided it should contain a continuous pedestrian access route (PAR) connecting to elements required to comply with Chapter 11.
Sec. 1102.5 Protruding Objects: Protruding objects on sidewalks and other pedestrian circulation paths shall comply with 1102.5 and shall not reduce the clear width required for pedestrian accessible routes.
ADOT has "No comment" on this section.
Sec. 1102.5.1 Protrusion Limits. Objects with leading edges more than 27 inches
EXCEPTION: Handrails shall be permitted to protrude 4-1/2 inches
ADOT has "No comment" on this section.
Sec. 1102.5.2 Post-Mounted Objects: Free-standing objects mounted on posts or pylons shall overhang circulation paths 4 inches
EXCEPTION: This requirement shall not apply to sloping portions of handrails serving stairs and ramps.
ADOT requests clarification of this guideline in the form of a graphic representation. It appears that the last sentence contradicts guidance given in the first sentence by allowing the lowest edge of a sign to be mounted at 27 inches
Sec. 1102.5.3 Reduced Vertical Clearance: Guardrails or other barriers shall be provided where the vertical clearance is less than 80 inches
EXCEPTION: Door closers and door stops shall be permitted to be 78 inches
ADOT requests clarification of this proposed guideline. Does the term "guardrail" refer to vehicular w-beam or thrie beam, or is it a pedestrian-type barrier? Regardless of the definition, we are concerned that guardrail installed at twenty-seven inches (27 in), adjacent to the PAR, could constitute a tripping hazard for the visually impaired.
Sec. 1102.6 Curbs and Blended Transitions: A curb ramp or blended transition complying with 1104, or a combination of curb ramps and blended transitions, shall connect the pedestrian access routes to each street crossing within the width of each crosswalk
ADOT supports the proposed guideline requiring that curb ramps be placed in-line with the crosswalk they serve; curb cuts at the mid-point of the curb radius will normally not be allowed. This may effectively double the number, and cost, of curb ramps required on construction projects, but the total cost of such ramps is minimal in terms of the larger project. We note however that sound engineering judgment may dictate the use of only one ramp at a particular intersection due to site geometry and conditions.
Sec. 1102.7 Pedestrian Signs: Signs for pedestrian use shall comply with 1102.7.
ADOT supports the proposed guideline as written. It reiterates guidance given in the MUTCD.
Sec. 1102.7.1 Bus Route Identification: Bus route identification signs shall comply with 703.5.1 through 703.5.4, and 703.5.7 and 703.5.8. In addition, to the maximum extent practicable, bus route identification signs shall comply with 703.5.5. Bus route identification signs located at bus shelters shall provide raised and Braille characters complying with 703.2, and shall have rounded corners.
EXCEPTIONS.
1. Bus schedules, timetables and maps that are posted at the bus stop or bus shelter shall not be required to comply with 1102.7.
2: Signs shall not be required to comply with 703.2 where audible signs are user- or proximity-actuated or are remotely transmitted to a portable receiver carried by an individual. (Sec. 703 Signs can be found on the Access Board website at http://www. access-board.gov/ada-aba/htm l/tech-0 7. html).
ADOT has "No comment" on this section.
Sec. 1102.7.2 Informational Signs and Warning Signs: Informational signs and warning signs shall comply with 703.5.
ADOT has "No comment" on this section.
Sec. 1102.8 Pedestrian Crossings: Where a pedestrian crossing is provided, it shall comply with the applicable provisions of 1105. Where pedestrian signals are provided at a pedestrian crossing, they shall comply with 1106.
ADOT strongly opposes this guideline. See Sec. 1105 Pedestrian Crossings for further comment.
Sec. 1102.9 Street Furniture: Street furniture that is intended for use by pedestrians and installed on or adjacent to a sidewalk shall comply with 309 and 1107. (Sec. 309 Operable Parts can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-03.html)
ADOT has "No comment" on this section.
Sec. 1102.10 Stairs: Where provided, stairs shall comply with 504. Stair treads shall have a 2 inch
ADOT has "No comment" on this section.
Sec. 1102.11 Handrails: Where provided, handrails shall comply with 505. (Sec. 505 Handrails can be found on the Access Board website at http.//www.access-board.gov/ada-aba.html/tech-05.hmtl)
ADOT has "No comment" on this section.
Sec. 1102.12 Vertical Access: Where provided elevators shall comply with 407, limited use/limited-application elevators shall comply with 408, and platform lifts shall comply with 410. Vertical access shall remain unlocked during the operating hours of the facility served (Sections 407, 408 & 410 can be found on the Access Board website at http://www. access-board.gov/ada-aba/html/tech-04.hmtl)
ADOT has "No comment" on this section.
Sec. 1102.13 Bus Stops. Bus boarding and alighting areas shall comply with 810.2. Bus shelters shall comply with 810.3. (Sections 810.2 & 810.3 can be found on the Access Board website at http://www. access-board.gov/ada-aba/html/tech-08.html)
ADOT has "No comment" on this section.
Sec. 1102.14 On-Street Parking: Where on-street parking is provided, at least one accessible on-street parking space shall be located on each block face and shall comply with 1109.
ADOT strongly opposes this guideline. See Sec. 1109 On-Street Parking for further comments.
Sec. 1102.15 Passenger Loading Zones: Where passenger loading zones are provided, they shall connect to a pedestrian access route and shall provide a minimum of one passenger loading zone in every continuous 100 linear feet (30 m) of loading zone space, or fraction thereof complying with 302, 503.2, 503.3, and 503.5.
ADOT has "No comment" on this section.
Sec. 1102.16 Call Boxes: Where provided, call boxes shall comply with 1110.
See Sec. 1110 Call Boxes for comments.
Sec. 1103 Pedestrian Access Route
Sec. 1103.1 General: Pedestrian access routes shall connect to elements required to be accessible and shall comply with 1103.
ADOT supports the proposed guideline as written.
Sec. 1103.2 Components: Pedestrian access routes shall consist of one or more of the following components: walking surfaces, ramps, curb ramps, blended transitions, crosswalks, pedestrian overpasses and underpasses, elevators, and platform h/is. All components of a pedestrian access route shall comply with the applicable portions of this chapter.
ADOT has "No comment" on this section.
Sec. 1103.3 Clear Width: The minimum clear width of a pedestrian access route shall be 48 inches
ADOT supports the proposed guideline as written.
Sec. 1103.4 Cross Slopes: The cross slope of the pedestrian access route shall be 1:48
ADOT supports the goal of the proposed guideline, but requests clarification of how the term "technically infeasible" will be applied to pedestrian access routes in areas with greater than a two percent (2%) grade.
Sec. 1103.5 Grade: The grade of the pedestrian access route within a sidewalk shall not exceed the grade established for the adjacent roadway.
EXCEPTION: The running slope of a pedestrian access route shall be permitted to be steeper than the grade of the adjacent roadway, provided that the pedestrian access route is less than 1:20
ADOT cannot support the proposed guideline because the exception requires the maximum running slope of the PAR to be less than 1:20
Sec. 1103.6 Surfaces: The surfaces of the pedestrian access route shall comply with 302. (Sec. 302 Floor or Ground Surfaces can be found on the Access Board website at http://www. access- board.gov/ada-aba/htm l/tech-03.hmtl).
ADOT supports the proposed guideline as written.
Sec. 1103.7 Surface Gaps at Rail Crossings.' Where the pedestrian access route crosses rail systems at grade, the horizontal gap at the inner edge of each rail shall be constructed to the minimum dimension necessary to allow passage of railroad car wheel flanges and shall not exceed 2-'/2 inches
EXCEPTION: On tracks that carry freight, a maximum horizontal gap of 3 inch
ADOT has "No comment" on this section.
Sec. 1103.7.1 Detectable Warnings: Where rail systems cross pedestrian facilities that are not shared with vehicular ways, a detectable warning shall be provided in compliance with 1108.
ADOT supports the proposed guideline as written.
Sec. 1103.8 Changes in Level.' Changes in level shall comply with 303. Changes in level shall be separated horizontally 30 inches
ADOT requests clarification of this guideline. What is meant by "Changes in level shall be separated horizontally 30 inches
Sec. 1103.8.1 Rail Crossings.' Where the pedestrian access route crosses rail systems at grade, the surface of the pedestrian access route shall be level and flush with the top of the rail at the outer edge and between the rails.
ADOT supports the proposed guideline as written.
Sec. 1104 Curb Ramps and Blended Transitions
Sec. 1104.1 General.' Curb ramps and blended transitions shall comply with 1104.
ADOT has "No comment" on this section.
Sec. 1104.2 Types: Perpendicular curb ramps shall comply with 1104.2.1 and 1104.3; parallel curb ramps shall comply with 1104.2.2 and 1104.3; blended transitions shall comply with 1104.2.3 and 1104.3.
ADOT cannot support this section because it does not include provision for curb ramps that are in-line with a crosswalk, but neither perpendicular nor parallel. Good engineering practice may include design and construction of non-perpendicular and non-parallel curb ramps.
Sec. 1104.2.1 Perpendicular Curb Ramps: Perpendicular curb ramps shall comply with 1104.2.1, and shall have a running slope that cuts through the curb at right angles or meets the gutter grade break at right angles.
ADOT supports this guideline as written.
Sec. 1104.2.1.1 Running Slope: The running slope shall be 1:48
ADOT cannot support this guideline as written because it ignores the possibility of site-specific conditions which could result in running slopes greater than 1:12
Sec. 1104.2.1.2 Cross Slope: The cross slope shall be 1:48
EXCEPTION: This requirement shall not apply to mid-block crossings.
ADOT cannot support this guideline and requests that the guideline be reworded to allow the cross slope to match the existing roadway grade. The proposed guideline has an unanticipated and unacceptable consequence when a curb ramp is provided on a facility with greater than a 1:48
Sec. 1104.2.1.3 Landing: A landing 48 inches
EXCEPTION: Running and cross slope requirements shall not apply to mid-block crossings.
ADOT supports the requirement for a minimum of a 48-inch by 48-inch landing at the top of the curb ramp. However, we cannot support the guideline language for maximum running and cross slopes of 1:48
Sec. 1104.2.1.4 Flares: Flared sides with a slope of 1:10
ADOT cannot support the proposed guideline as written because it ignores site-specific conditions that might require a flare slope of greater than 1:10
Sec. 1104.2.2 Parallel Curb Ramps: Parallel curb ramps shall comply with 1104.2.2, and shall have a running slope that is in-line with the direction of sidewalk travel.
ADOT supports this guideline.
Sec. 1104.2.2.1 Running Slope: The running slope shall be 1:48
EXCEPTION: A parallel curb ramp shall not be required to exceed 15 fret (4570 mm) in length.
ADOT cannot support this guideline as written as it would require extensive engineering and construction efforts in areas where the sidewalk and PAR were adjacent to a roadway with a grade greater than eight and one-third percent (8.33%). We do support a maximum ramp length of fifteen feet (15 ft).
Sec. 1104.2.2.2 Cross Slope: The cross slope shall be 1:48
ADOT cannot support this guideline as written as it ignores site-specific conditions that could result in the cross slope being greater than 1:48
Sec. 1104.2.2.3 Landing: A landing 48 inches
EXCEPTION: Running and cross slope requirements shall not apply to mid- block crossings.
ADOT supports the guideline requirement for a minimum 48-inch by 48-inch landing at bottom of the parallel ramp. However, we oppose the guideline for maximum running and cross slopes of 1:48
Sec. 1104.2.2.4 Diverging Sidewalks: Where a parallel curb ramp does not occupy the entire width of a sidewalk, drop-offs at diverging segments shall be protected with a barrier.
ADOT supports the proposed guideline as written, but requests clarification of what constitutes a "barrier".
Sec. 1104.2.3 Blended Transitions: Blended transitions shall comply with 1104.3, and shall have running and cross slopes of 1:48
ADOT cannot support the guideline because of its call for maximum running and cross slopes of 1:48
Sec. 1104.3 Common Elements: Curb ramps and blended transitions shall comply with 1104.3.
Sec. 1104.3.1 Width: The clear width of landings, blended transitions, and curb ramps, excluding flares, shall be 48 inches
ADOT supports the proposed guideline as written.
Sec 1104.3.2 Detectable Warnings: Detectable warning surfaces complying with 1108 shall be provided, where a curb ramp, landing, or blended transition connects to a crosswalk.
ADOT supports the proposed guideline, noting however the comments we've provided pertaining to Sec. 1108 Detectable Warning Surfaces.
Sec. 1104.3.3 Surfaces: Surfaces of curb ramps, blended transitions, and landings shall comply with 302. Gratings, access covers, and other appurtenances shall not be located on curb ramps, landings, blended transitions, and gutter areas within the pedestrian access route.
ADOT requests a rewording of second sentence of this guideline to acknowledge that circumstances will occur that may require the placement of gratings, access covers, and other appurtenances within the PAR.
Sec. 1104.3.4 Grade Breaks: Grade breaks shall not be permitted on curb ramps, blended transitions, landings, and gutter areas within the pedestrian access route. Surface slopes that meet at grade breaks shall be flush.
ADOT requests clarification of the last sentence and what is meant by "surface slopes" and how they shall be "flush".
Sec. 1104.3.5 Changes in Level: Vertical changes in level shall not be permitted on curb ramps, blended transitions, landings, or gutter areas within the pedestrian access route.
ADOT requests clarification of "vertical changes in level".
Sec. 1104.3.6 Counter Slopes: The counter slope of the gutter area or street at the foot of a curb ramp or blended transition shall be 1:20
ADOT requests that definition of the term "counter slope" be provided.
Sec. 1104.3.7 Clear Space: Beyond the curb line, a clear space of 48 inches
ADOT strongly opposes this guideline. This guideline would result in an increase in the roadway width by forty-eight inches (48 in) on each side of the road at every ramp location for a total of ninety-six (96 in
Sec. 1105 Pedestrian Crossings
Sec. 1105.1 General: Pedestrian crossings shall comply with 1105.
Sec. 1105.2 Crosswalks: Crosswalks shall comply with 1105.2.
Sec. 1105.2.1 Width: Marked crosswalks shall be 96 inches
ADOT cannot support the proposed guideline as written because it mandates a minimum width contrary to that called for in the MUTCD. Section 3B.17 Crosswalk Width of the MUTCD calls for a minimum width of six feet (6 ft), which is research based. Nothing has been presented to show the necessity of widening a crosswalk to eight feet (8 ft).
Sec. 1105.2.2 Cross Slope: The cross slope shall be 1.48 maximum measured perpendicular to the direction of pedestrian travel.
EXCEPTION: This requirement shall not apply to mid-block crossings.
ADOT strongly opposes this guideline. The effect of this guideline could be monumental in locations where the longitudinal grade of the roadway exceeds two percent (2%, 1:48
Sec. 1105.2.3 Running Slope: The running slope shall be 1.20 maximum measured parallel to the direction of pedestrian travel in the crosswalk
ADOT cannot support this guideline as it would have a negative effect on the placement of marked pedestrian crossings on roadways with grades steeper than five percent (5%, 1:20
Sec. 1105.3 Pedestrian Signal Phase Timing: All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3. 0 feet
ADOT cannot support this guideline as it would impact the pedestrian signal phase timing of almost every traffic signal in the State and two of the consequences would be overwhelming. First, almost every traffic signal in Arizona would have to be re-timed to account for the increase in pedestrian travel length. The current MUTCD guidelines for pedestrian signal phase timing allow the length to be measured from the curb face to the center of the furthest through travel lane. This guideline would add a minimum of fourteen feet (14 ft) to the length which equates to a minimum addition of 4.67 seconds
Sec. 1105.4 Medians and Pedestrian Refuge Islands: Medians and pedestrian refuge islands in crosswalks shall comply with 1105.4 and shall be cut through level with the street or have curb ramps complying withllO4 and shall contain a pedestrian access route complying with 1103. Where the cut-through connects to the street, edges of the cut-through shall be aligned with the direction of the crosswalk for a length of 24 inches
ADOT cannot support this guideline because the language in Sec. 1104 Curb Ramps is already overly restrictive at locations with roadway grade is greater than two percent (2%) (see comment for Sec. 1104.2.1.2 Cross Slope, above).
Sec. 1105.4.1 Length: Where signal timing is inadequate for full crossing of all traffic lanes or where the crossing is not signalized, cut-through medians and pedestrian refuge islands shall be 72 inches
ADOT cannot support this guideline as our current standard width for medians at intersections is forty-eight inches (48 in).
Sec. 1105.4.2 Detectable Warnings: Medians and refuge islands shall have detectable warnings complying with 1108. Detectable warnings at cut-through islands shall be separated by a 24 inch
EXCEPTION: Detectable warnings shall not be required on cut-through islands where the crossing is controlled by signals and is timed for full crossing.
ADOT cannot support this guideline as our current standard width for medians at intersections is forty-eight inches (48 in
Sec. 1105.5 Pedestrian Overpasses and Underpasses: Pedestrian overpasses and underpasses shall comply with 1105.5.
Sec. 1105.5.1 Pedestrian Access Route: Pedestrian overpasses and underpasses shall contain a pedestrian access route complying with 1103.
ADOT supports the proposed guideline as written.
Sec. 1105.5.2 Running Slope: The running slope shall not exceed 1:20
ADOT cannot support the proposed guideline as written as it could require the running slope of the PAR to be independent of the longitudinal grade of the adjoining roadway. To require a PAR running slope less than 1:20
Sec. 1105.5.3 Approach: Where the approach exceeds 1:20
ADOT supports the part of the guideline pertaining to minimum ramp width. We strongly oppose that part calling for a limited-use/limited-application or standard elevator where the rise of the ramped approach exceeds sixty inches (60 in). We are deeply concerned that about the safety of pedestrians using such elevators and think it inadvisable to install elevators if we cannot guarantee pedestrian security. In Arizona there are also regular, but unplanned interruptions in electrical service due to electrical storms in the summer and snow storms in the winter. These interruptions could trap people in the elevators without any simple means of extricating them until power is restored. Equally as important in our opposition to the requirement for elevators are their exorbitant costs and the notion we should provide a facility for disabled pedestrians which is well beyond what we'd provide for pedestrian traffic in general.
Sec. 1105.5.4 Stairs: Stairs shall comply with 504. (Sec. 504 Stairways can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-05.hmtl)
ADOT has "No comment" on this section.
Sec. 1105.5.5 Escalators: Escalators shall comply with 810.9.
ADOT has "No comment" on this section.
Sec. 1105.6 Roundabouts: Where pedestrian crosswalks and pedestrian facilities are provided at roundabouts, they shall comply with 1105.6.
Sec. 1105.6.1 Separation: Continuous barriers shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited. Where railings are used, they shall have a bottom rail 15 inches
ADOT strongly opposes this guideline as written because of its possible negative impacts on motorist and pedestrian safety. If handrail is used as a barrier on sidewalks abutting the curb it could present a spearing hazard to motorists. Other types of barrier could present tripping hazards to pedestrians if placed lower than twenty-seven inches (27 in) and a sight restriction to motorists if places above that point. We would like to know why sidewalk at a roundabout is being treated differently from that at any other street intersection?
Sec. 1105.6.2 Signals: A pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the crosswalk, including the splitter island. Signals shall clearly identify which crosswalk segment the signal serves.
ADOT cannot support this guideline as written. It is inadvisable to promulgate a guideline that would mandate the installation of any traffic control signal without an engineering study to confirm the need for such a signal. Warrants for installation of a signal would investigate such variables as sight distance, traffic volume, pedestrian volume, vehicle speed, and vehicle gap.
Sec. 1105.7 Turn Lanes at Intersections: Where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island.
ADOT cannot support this guideline as written. We request a definition for the term "slip lane" be added to Sec. 1101.3 Terms. Within the Arizona highway system unrestricted right turns are sometimes provided at freeway ramps to handle the volume of exiting traffic. The installation of a signal could cause a dangerous situation where off-ramp traffic would back up onto the freeway. Again, without a case-by-case engineering study, as detailed in the MUTCD, it would be inadvisable to mandate installation of a signal at these locations.
Sec. 1106 Accessible Pedestrian Signal Systems
Sec. 1106.1 General: Pedestrian signal systems shall comply with 1106.
Sec. 1106.2 Pedestrian Signal Devices: Each crosswalk with pedestrian signal indication shall have a signal device which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device and shall comply with 1106.3.
ADOT strongly opposes this guideline as written. We see no added value to implementing this guideline, and a possible increased liability due to system failure and application inconsistency.
Sec. 1106.2.1 Location: Pedestrian signal devices shall be located 60 inches
EXCEPTION: The minimum distance from other signal devices shall not apply to signal devices located in medians and islands.
ADOT cannot support the proposed guideline as written because locating all traffic control devices should be done as part of a site-specific engineering study. We think it would be poor engineering practice to utilize this guideline without an investigation of the site and analysis thereof.
Sec. 1106.2.2 Reach and Clear Floor or Ground Space: Pedestrian signal devices shall comply with 308. A clear floor or ground space complying with 305 shall be provided at the signal device and shall connect to or overlap the pedestrian access route. (Sec. 308 Reach Ranges and Sec. 305 Knee and Toe Clearance can be found on the Access Board website at http://www. access-board.gov/ada-aba/html/tech-03.html)
ADOT has "No comment" on this section.
Sec. 1106.2.3 Audible Walk Indication: The audible indication of the WALK interval shall be by voice or tone.
ADOT cannot support this guideline as written. Because of the number of different languages spoken in Arizona it would be technically infeasible to provide any message, in every language, in a timely manner. To arbitrarily decide not to offer the message in a particular language could also leave this Department open to charges of not providing equal access to public services. Also, as noted above, advocacy groups for the visually impaired have not achieved a clear consensus regarding the need for and design of audible and vibrotactile indications.
Sec. 1106.2.3.1 Tones: Tones shall consist of multiple frequencies with a dominant component at 880 Hz. The duration of the tone shall be 0.15 seconds
ADOT has "No comment" on this section.
Sec. 1106.2.3.2 Volume: Tone or voice volume measured at 36 inches
ADOT cannot support this section of the guidelines because the sound level produced could be considered a nuisance, particularly in the evening hours and at locations in residential neighborhoods.
Sec. 1106.3 Pedestrian Pushbuttons: Pedestrian pushbuttons shall comply with 1106.3.
Sec. 1106.3.1 Operation. Pedestrian pushbuttons shall comply with 309.4. (Sec. 309.4 Operation can be found on the Access Board website at http://www.access board.gov/ada-aba/html/tech-03.hmtl)
ADOT has "No comment" on this section.
Sec. 1106.3.2 Locator Tone. Pedestrian pushbuttons shall incorporate a locator tone at the pushbutton. Locator tone volume measured at 36 inches
ADOT cannot support the proposed guideline because the sound level produced could be considered a nuisance, particularly in the evening hours and at locations in residential neighborhoods.
Sec. 1106.3.3 Size and Contrast. Pedestrian pushbuttons shall be a minimum of 2 inches
ADOT supports the proposed guideline as written.
Sec. 1106.3.4 Optional Features: An extended button press shall be permitted to activate additional features. Buttons that provide additional features shall be marked with three Braille dots forming an equilateral triangle in the center of the pushbutton.
ADOT has "No comment" on this section.
Sec. 1106.4 Directional Information and Signs. Pedestrian signal devices shall provide tactile and visual signs on the face of the device or its housing or mounting indicating crosswalk direction and the name of the street containing the crosswalk served by the pedestrian signal.
ADOT cannot support this section as the name of streets served by a particular crosswalk is not currently provided at any location. Each location would require costly, custom-made signs which would have to be replaced if damaged or otherwise vandalized.
Sec. 1106.4.1 Arrow: Signs shall include a tactile arrow aligned parallel to the crosswalk direction. The arrow shall be raised 1/32 inch
ADOT can support this guideline.
Sec. 1106.4.2 Street Name. Signs shall include street name information aligned parallel to the crosswalk direction and complying with 703.2. (Sec. 703.2 Characters That Are Both Tactile and Visual can be found on the Access Board website at http://www.access board.gov/ada-aba/html/tech-07.html)
ADOT cannot support this section of the guidelines because it puts an unreasonable burden on the State and other jurisdictions to produce costly, custom-made signs for each location.
Sec. 1106.4.3 Crosswalk Configuration: Where provided, graphic indication of crosswalk configuration shall be tactile and shall comply with 703.5.1. (Sec. 703.2 Location can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-07.hmtl)
ADOT can support this section as long as there is no requirement to provide graphic indication of the crosswalk configuration.
Sec 1107 Street Furniture
Sec. 1107.1 General: Street furniture shall comply with 1107.
Sec. 1107.2 Clear Floor or Ground Space: Street furniture shall have clear floor or ground space complying with 305 and shall be connected to the pedestrian access route. The clear floor or ground space shall overlap the pedestrian access route 12 inches
ADOT support this section of the guidelines.
Sec. 1107.3 Drinking Fountains: Where drinking fountains are provided, they shall comply with 602. (Sec. 602 Drinking Fountains and Water Coolers can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-06.hmtl)
ADOT has "No comment" on this section.
Sec. 1107.4 Public Telephones: Where public telephones are provided, they shall comply with 1107.4.
ADOT has "No comment" on this section.
Sec. 1107.4.1 Single Telephone: Where a single public telephone is provided, it shall comply with 704.2 and 704.4. (Sec. 704.2 Wheelchair Accessible Telephones and Sec. 704.4 TTYs can be found on the Access Board website at http://www.access board.gov/ada-aba/html/tech-07.html)
ADOT has "No comment" on this section.
Sec. 1107.4.2 Multiple Telephones: Where a bank of public telephones is provided, at least one telephone shall comply with 704.2, and at least one additional telephone shall comply with 704.4.
ADOT has "No comment" on this section.
Sec. 1107.4.3 Volume Controls: A 11 public telephones shall provide volume controls complying with 704.3. (Sec. 704.3 Volume Control Telephones can be found on the Access Board website at http.//www. access-board.gov/ada-aba/html/tech-0 7.html)
ADOT supports the proposed guideline as written.
Sec. 1107.5 Public Toilet Facilities: Permanent or portable public toilet facilities shall comply with 603. At least one fixture of each type provided shall comply with 604 through 610. Operable parts, dispensers, receptacles, or other equipment shall comply with 309.
EXCEPTION: Where multiple single-user toilet facilities are clustered at a single location, at least 5 percent, but no fewer than one single-user toilet at each cluster shall comply with 603 and shall be identified by the International Symbol of Accessibility complying with 703.7.2.1. (Sec. 603 Toilet and Bathing Rooms and Sections 604 through 610 can be found on the Access Board website at http.//www.access-board.gov/ada-aba/html/tech-06.html, Sec. 309 Operable Parts at http.//www.access-board.gov/ada-aba.html/tech-03.html and Sec. 703.7.2.1 Finish and Contrast at http.//www. access-board.gov/ada-aba/html/tech-07.html.)
ADOT has "No comment" on this section.
Sec. 1107.6 Tables, Counters, and Benches: Tables, counters, and benches shall comply with 1107.6.
Sec. 1107.6.1 Tables: Where tables are provided in a single location, at least 5 percent but no fewer than one, shall comply with 902. (Sec. 902 Dining Surfaces and Work Surfaces can be found on the Access Board website at http.//www.access-board.gov/ada-aba/html/tech-09.hmtl)
ADOT has "No comment" on this section.
Sec. 1107.6.2 Counters: Where provided, counters shall comply with 904. (Sec. 904 Sales and Service Counters can be found on the Access Board website at http://www. access-board.gov/ada-aba/html/tech-09.hmtl)
ADOT has "No comment" on this section.
Sec. 1107.6.3 Benches: Where benches without tables are provided at a single location, at least 50 percent, but no fewer than one, shall comply with 903 and shall have an armrest on at least one end (Sec. 903 Benches can be found on the Access Board website at http://www. access-board.gov/ada-aba.html/tech-09.hmtl)
ADOT has "No comment" on this section.
Sec 1108 Detectable Warning Surfaces
Sec. 1108.1 General: Detectable warnings shall consist of a surface of truncated domes aligned in a square grid pattern and shall comply with 1108.
ADOT cannot support this guideline because it would restrict the free market development of truncated dome systems by prohibiting the diamond pattern. While the argument arises that the square pattern is friendlier to vibration- sensitive people, there is no research on the possible number of individuals affected. Depending on the dimensions used in the square or diamond pattern and the width of the wheelchair, its wheels will either hit or miss the truncated domes. Therefore, we see no reason to favor one pattern over another in the rulemaking process.
Sec. 1108.1.1 Dome Size: Truncated domes in a detectable warning surface shall have a base diameter of 0.9 inches
ADOT supports the proposed guideline as written.
Sec. 1108.1.2 Dome Spacing: Truncated domes in a detectable warning surface shall have a center-to-center spacing of 1.6 inches
ADOT supports this guideline while recommending removal of reference to "square grid" from the last sentence (see comment on Sec. 1108.1 General, above).
Sec. 1108.1.3 Contrast: Detectable warning surfaces shall contrast visually with adjacent walking surfaces either light-on-dark, or dark-on-light.
ADOT supports the proposed guideline as written.
Sec. 1108.1.4 Size: Detectable warning surfaces shall extend 24 inches
ADOT supports the proposed guideline as written.
Sec. 1108.2 Location
Sec. 1108.2.1 Curb Ramps and Blended Transitions: The detectable warning surface shall be located so that the edge nearest the curb line is 6 inches
ADOT supports the proposed guideline as written.
Sec. 1108.2.2 Rail Crossings: The detectable warning surface shall be located so that the edge nearest the rail crossing is 6 inches
ADOT supports the proposed guideline, but recommends the term "vehicle dynamic envelope" be used consistent with the term "dynamic envelope" as shown in Sec. 1103 Terms.
Sec. 1108.2.3 Platform Edges: Detectable warning surfaces at platform boarding edges shall be 24 inches
ADOT has "No comment" on this section.
Sec 1109 On-Street Parking
Sec. 1109.1 General: Car and van on-street parking spaces shall comply with 1109.
ADOT has "No comment" on this section.
Sec. 1109.2 Parallel Parking Spaces: An access aisle at least 60 inches
EXCEPTION: An access aisle is not required where the width of the sidewalk between the extension of the normal curb and boundary of the public right-of-way is less than 14 feet
ADOT requests further clarification of this guideline before deciding whether we support it.
Sec. 1109.3 Perpendicular or Angled Parking Spaces: Where perpendicular or angled parking is provided, an access aisle 96 inches
ADOT cannot support this guideline as written because the incremental value of a ninety-six (96-in) wide access aisle over the currently used sixty-inch (60-in) wide access aisle has not been established.
Sec. 1109.4 Curb Ramps or Blended Transitions: A curb ramp or blended transition complying with 1104 shall connect the access aisle to the pedestrian access route.
ADOT supports this guideline in concept, noting however the comments regarding the 1:48
Sec. 1109.5 Obstructions. There shall be no obstructions on the sidewalk adjacent to and for the full length of the space.
EXCEPTION: This provision shall not apply to parking signs complying with 1109.6 and parking meters complying with 1109.7.2.
ADOT supports the proposed guideline as written.
Sec. 1109.6 Signs: Parking spaces shall be designated as reserved by a sign complying with 502.6. Signs shall be located at the head or foot of the parking space so as not to interfere with the operation of a side lift or a passenger side transfer. (Sec. 502 Parking Spaces can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-05.hmtl)
ADOT supports the proposed guideline as written.
Sec. 1109.7 Parking Meters: Where parking meters are provided, they shall comply with 1109.7.
ADOT supports the proposed guideline as written.
Sec. 1109.7.1 Operable Parts. Operable parts shall comply with 309. (Sec. 309 Operable Parts can be found on the Access Board website at http://www.access board.gov/ada-aba/html/tech-03.hmtl)
ADOT supports the proposed guideline as written.
Sec. 1109.7.2 Location: A parking meter shall be located at the head or foot of the parking space so as not to interfere with the operation of a side l or a passenger side transfer.
EXCEPTION: Where parking meters are not provided at the space, but payment for parking in the space is included in a centralized collection box or paying station, the space shall be connected to the centralized collection point with a pedestrian access route.
ADOT supports the proposed guideline as written.
Sec. 1109.7.3 Displays and Information.' Displays and information shall be visible from a point located 40 inches
ADOT supports the proposed guideline as written.
Sec. 1110 Call Boxes
Sec. 1110.1 General: Call boxes shall comply with 1110.
ADOT has "No comment" on this section..
Sec. 1110.2 Operable Parts: Operable parts shall comply with 308 and 309.4. Where provided, labeling shall comply with 703.2 and 703.3. (Sec. 703 Signs can be found on the Access Board website at http.//www.access-board.gov/ada-aba/html/tech-07.hmtl)
EXCEPTION: Mechanically operated systems in which the signal is initiated by a lever pull shall be permitted to have an activating force of 12 lbf
ADOT supports the proposed guideline as written.
Sec. 1110.3 Turning Space: A turning space complying with 304 shall be provided at the controls. (Sec. 304 Wheelchair Turning Space can be found on the Access Board website at http.//www. access-board.gov/ada-aba/htm l/tech-03.hmtl
ADOT supports the proposed guideline as written.
Sec. 1110.4 Edge Protection: Edge protection complying with 405.9.2 shall be provided where the area at the call box is adjacent to an abrupt level change. (Sec. 405.9.2 Curb or Barrier can be found on the Access Board website at http://www.access-board.gov/ada-aba.html/tech-04.hmtl)
ADOT supports the proposed guideline, but would request further clarification regarding the terms "abrupt level change" and "edge protection".
Sec. 1110.5 Motor Vehicle Turnouts: Where provided, a motor vehicle turnout shall have a minimum paved area of 16 feet
ADOT supports the basic guideline, but question the requirement of a sixteen-foot (1 6-ft) wide paved area. Provision of a thirteen-foot (1 3-fl) wide paved area is sufficient to provide for an eight-foot (8-ft) wide parking space and a five-foot (5-fl) wide access and the incremental value of an eight-foot (8-ft) wide access route has not been established route (see comment for Sec. 1109.2 Parallel Parking Spaces, above).
Sec. 1110.6 Two- Way Communication: Where provided, two-way voice communication shall comply with 1110.6, 708.2 and 708.3. (Sec. 708 Two-Way Communication Systems can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-07.hmtl)
ADOT has "No comment" on this section.
Sec. 1110.6.1 Volume Controls: Volume controls complying with 704.3 shall be provided (Sec. 704.3 Volume Control Telephones can be found on the Access Board website at http.//www. access-board.gov/ada-aba/html/tech-07.hmtl)
ADOT has "No comment" on this section..
Sec. 1110.6.2 TTY A TTY complying with 704.4 shall be provided (Sec. 704.4 TTYs can be found on the Access Board website at http://www.access-board.gov/ada-aba.html/tech-07.hmtl)
ADOT has "No comment" on this section.
Sec. 1111 Alternate Circulation Path
Sec. 1111.1 General: Alternate circulation paths shall comply with 1111.
ADOT supports the proposed guideline as written.
Sec. 1111.2 Width: The alternate circulation path shall have a width of36 inches
ADOT strongly supports the guideline requirement for the alternate circulation path minimum width of thirty-six inches (36 in).
Sections 1111.3 Location: The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street.
ADOT strongly opposes this guideline's requirement for the "Alternate Circulation Path" to be located on the same side of the street as the disrupted PAR. This provision would impose a central-planning approach to traffic control for construction and maintenance operations, and would negatively impact pedestrian comfort and safety while creating an unreasonable burden upon State and local agencies. This provision does not appear to consider the following: A) the length of time a project is underway; B) the type and nature of the project; C) the probable negative impact upon the other users of the transportation facility due to reduced roadway capacity; D) the advisability of and risk inherent in moving pedestrians adjacent to construction or maintenance operations; E) the impact of noise on the pedestrian; nor F) the impact to construction programs, in terms of time and money spent on meeting this guideline.
This proposed guideline is also contrary to guidance provided by the Manual on Uniform Traffic Control Devices (MUTCD), Section 6D.O I Pedestrian Considerations This section of the MUTCD delineates three considerations, of which the first two address this matter. They are as follows:
A. Pedestrians should not be led into conflicts with work site vehicles, equipment, and operations. and
B. Pedestrians should not be led into conflicts with vehicles moving through or around the work site.
Further clarification is provided in the MUTCD on page 6D- 1 as, "Pedestrians should be appropriately directed with advance signing that encourages them to cross to the opposite side of the roadway." (emphasis added) and 6D-2 as, "Whenever it is feasible, closing off the work site from pedestrian intrusion may be preferable to channelizing pedestrian traffic along the site with temporary traffic control devices such as cones, tubular markers, barricades and drums, or other suitable fencing."
Sec. 1111.4 Protection: The alternate circulation path shall comply with 307 and shall be protected with a barricade complying with 1111.6 to separate the pedestrian access route and alternate circulation path from any adjacent construction, drop-offs, openings, or other hazards.
ADOT cannot support this guideline because the Alternate Circulation Path should not be adjacent to construction or maintenance operations (see comment on Sec. 1111.3 Location, above).
Sec. 1111.5 Signs: Signs complying with 703.5 shall be provided at both the near side and the far side of the intersection preceding a disrupted pedestrian access route. . (Sec. 703.5 Braille can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-07.hmtl)
ADOT strongly supports the placement of signs, at both the near side and far side of the intersections preceding a disrupted PAR, encouraging all pedestrians to cross to the opposite side of the roadway wherever possible (see comment on Sec. 1111.3 Location, above).
Sec. 1111.6 Barricades: Barricades shall be continuous, stable, and non-flexible and shall consist of a solid wall or fence or a Type II or Type III barricade as specified in MUTCD section 6F-60 with the bottom or lower rail 1-1/2 inches
ADOT cannot support this guideline as written because no temporary barricade system is totally "non- flexible"; temporary barricades differ by how much rigidity they provide. The proposed guideline would also prohibit the use of both Type II and Type III temporary barricades to define the alternative circulation path because they use "T-type" supports that would encroach into the path. Temporary concrete barrier (TCB), which can move up to three feet (3 ft) laterally when struck, would meet most of the intent of this guideline, however, TCB should not be used arbitrarily. Sound engineering judgment should be used to determine, on a case-by-case basis, the advisability of introducing another hazard (the TCB itself) onto the project. Indiscriminate use of TCB could put the public's health, safety, and welfare at risk.
J. Tom Coleman Jr., October 25, 2002
Georgia Department of Transportation
Subject: Comments on the proposed "Guidelines for Accessible Public Rights-of-Way"
Dear Mr. Windley:
The Georgia Department of Transportation (GDOT) completely agrees with the concept of the ADA that no person should be denied services because that person has a disability. The GDOT has reviewed the proposed "Guidelines for Accessible Public Rights-of-Way" dated June 17, 2002. Based on the review, some of the requirements should be given further consideration before implementation.
The GDOT has also reviewed the AASHTO comments on the proposed ADA guidelines and agree with their recommendations. The GDOT comments were developed independently but address many of the same issues.
Several of the proposed requirements will have major impacts on project design on required Rights-of-Way. If the plans for a project are near completion, the plans would need to be changed, the Environmental Document would need to be reevaluated and additional R/W would need to be acquired which will result in a considerable delay in letting the project for construction. When the text of the document has been finalized, the required implementation date should be given careful consideration.
Attached are the GDOT comments on the proposed ADA guidelines for public Rights-of-Way.
Sincerely,
Signed by Commissioner Coleman
J. Tom Coleman Jr.
Commissioner
Attachments
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Comments on the Proposed ADA Guidelines for Accessible Public R/W
The Georgian Department of Transportation (GDOT) completely agrees with the concept of the ADA that no person should be denied services because that person has a disability. However, the proposed "Guidelines for Accessible Public Rights-of-Way" dated June 17,2002 specify some requirements that we feel should be given further consideration before implementation.
The GDOT has reviewed the AASHTO comments on the Proposed ADA Guidelines and agrees with their recommendations. The GDOT comments were developed independently but address many of the same issues.
Overview:
Several of the major issues are addressed in general in the Synopsis. More specific comments are addressed in the responses to the individual sections.
The ACCESS BOARD has received many comments that have been posted on their website.
The comments seemed to fit into two categories. The first type response was from persons with disabilities or groups representing persons with disabilities. These comments were generally short and contained references to specific items. Sometimes the comments were in support of or opposed to an item. For example, the visually impaired groups generally supported the detectable warnings at the bottom of the ramps and the groups representing persons with mobility and balance disabilities considered the detectable warnings a tripping hazard to walkers and an inconvenience to persons in wheelchairs. The varied responses from the persons with different viewpoints indicate that there is no solution that satisfies all users in all situations.
The second type of response was from persons or groups that will implement the design requirements. These responses were generally longer and pointed out that many of the requirements would have consequences that the Access Board and the individual members of the Board had not intended or anticipated. Often these responses could be summarized by the following statement: Change the "design requirements" to "design recommendations." This will allow the Engineer to consider all the factors influencing the area in the design of the project.
Following the same thought, as written the only allowable reason for not meeting ALL the design requirements is if it is "Technically Infeasible" to meet the requirements. (And this is only allowed on "alterations", new construction must meet all the Design Requirements.) Technically Infeasible is not defined in the ROW section but a definition is needed. Also, the DOJ Title II Technical Assistance Manual specifically states that when determining Technical Infeasibility, cost is not to be considered. When a roadway type project is being constructed on the R/W, and enough money is available, anything can be built, therefore nothing is technically infeasible. In a slight contradiction, the DOJ CFR states that if you have to remove a load bearing wall in a building then complying with the design requirements is Technically Infeasible. More guidance is required.
The Dept. of Justice, Housing and Urban Development, Dept. of Interior, Dept. of Labor and possibly other agencies have included guidance for not meeting the ADA design requirements in their respective CFRs. Some of the guidance is not in complete agreement but generally they allow deviation from the Design Requirements due to "Technical Infeasibility", "Conflicts with existing law to protect historic resources", "Disproportionality" of the cost of satisfying all the ADA design requirements with the project cost, "Undue Administrative Burden", "Undue Financial Burden" and "Fundamental Alteration of the Nature of the Service". The various CFRs generally require that the head of the agency approve the deviation from the Design Requirements. The FHWA CFR simply states that "wheel chair ramps and other features that may be required to meet ADA are required". The FHWA is the agency that oversees most federal monies spent on public R/W. The FHWA has not provided any usable guidance (that the ADA required them to provide by 1992) on when exceptions to the ADA Design Requirements are justified therefore, the guidance must be included in this document. Also, it is unclear whether guidance included it this document or guidance included in the various CFRs will control.
To follow up on the "unintended consequences" of these requirements, if cost cannot be considered when determining technical infeasibility and if the design parameters are adopted exactly as written, many urban projects will not be built. The disruption to the adjacent properties and the surrounding communities will be too severe. The end result of these requirements (to provide a high level of accessibility) will be less accessibility in areas that would have been improved. The changes to the proposed ADA Design Requirements that the GDOT proposes are to ensure that this is not the result of the ADA Design Requirements.
Whether or not cost can be DIRECTLY considered when determining whether it is necessary to comply with the ADA Design Requirements, the cost of compliance WILL be considered. The funding of projects for new roadways and roadway improvements may seem to be infinite to persons not familiar with the magnitude of these projects, however there is a limited amount of money available and an infinite demand for these funds. Also, the funding is usually divided into categories and specified for certain uses. (For example, resurfacing, intersection improvement, Interstate Highways, bridge rehabilitation, etc.) If one project is very costly, either the project will not be constructed or other projects in that funding category will not be constructed in order to fund the project that is constructed.
The GDOT believes that the intent of the ADA was to provide better access (and service) to everyone (including persons with disabilities), not lower the level of access (and service) to everyone equally.
There is an article in the 9/19/02 edition of the Govt. Computer News about problems providing GIS maps over the Internet. The information has to be provided in usable form to all users to comply with Section 508 of the 1998 ADA Amendment. It would be unfortunate (but not unexpected) if this service was withheld from all citizens in order to comply with the ADA. There is no technology available for blind users to obtain the same information (in an easily useable format) that sighted users obtain, therefore the result may be less service for everyone. (Including the blind person that previously had a sighted friend or family member obtain and interpret the information.)
The ADA does not require that sidewalks be included in roadway projects but if sidewalks are provided the ADA requires that they must be useable by all users. If this premise is used to judge the requirements listed in the "Guidelines for Accessible Public Rights-of-Way", some of the requirements do not appear to fall under ADA regulation. For example, requirements for traffic signals where none would be required except by these guidelines. The GDOT recommends that all the requirements be reviewed and any requirements that are not definitely issues covered by the ADA be removed or changed to recommendations.
There appear to be some discrepancies in the commentary and between the commentary and the proposed text. For example: Commentary 1102.1 "The draft guidelines would not require the provision of sidewalks, street crossings, street furniture, parking or other pedestrian elements where none are intended." Commentary 1105.2 - Crosswalks - "?specifications apply to both marked and unmarked crossings, wherever pedestrian travel is not prohibited." TEXT 1102.1 "All areas of newly designed and newly constructed facilities in public rights-of-way and altered portions of existing facilities ? shall comply with Chapter 11.
The final document should be clear and concise. The commentary provided should clarify and provide examples for the Design Requirements. All discrepancies in the commentary (from the text of the requirements) should be omitted or clearly noted as minority opinions.
There are also some discrepancies between the proposed Chapter 11 requirements the previous sections (Ramps are also addressed in Chapter 405 and Curb Ramps are also addressed in Chapter 406). If the requirements are different on public R/W it should be noted in the other chapters whenever there is a difference.
Several of the design requirements for cross slope, grade breaks, etc. are covered in "1103 Pedestrian Access Route". The same requirements are duplicated other sections (ramps, transitions, crosswalks etc.). Consider eliminating the requirements from the other sections since by definition these areas are part of the "Pedestrian Access Route".
The guideline commentary stated "guidelines depart from the advisory committee's report in several areas, which are detailed in the following discussion." There are several items that differ from the Jan. 2001 report in the proposed text that are not discussed. (Possibly "Changes in level" (1103.8) should be "Grade Breaks" and "Grade Breaks" (1104.3.40) should be omitted.)
As an aside: There was an ADA seminar presented in Atlanta last year. Several of members of the Public R/W committee were present. Several questions were posed about the effect of implementing various design parameters. A common answer was "Oh, you would not have to meet that requirement, it isn't reasonable in that case". As written, the requirements do not allow for that solution. The only acceptable solution is "MEET THE DESIGN PARAMETERS".
The SCOPING REQUIREMENTS section needs to be expanded and clarified. Chapter 1102.2.2 states "Where existing elements or spaces in the public R/W are altered, each altered element shall comply with the applicable provisions of Chapter 11."
When a road is resurfaced the crosswalks are altered. This provision requires the cross slope to be less that 2.08% in the crosswalk. This requires that the intersection be "tabletopped" and requires vertical grade changes all of the approach roadways. This requirement will essentially prohibit any resurfacing projects in urban areas where any existing grade or crossslope in the intersection exceeds 2%. (Even if the project would remove severe ruts, vertical lips, and potholes in the crosswalk that make the existing crosswalk unusable for pedestrians with disabilities.)
The "tabletopping requirement will have severe negative impacts on all projects where the natural terrain slopes exceed 2%.
The commentary on 1105.2 - Crosswalks - that states that "?specifications apply to both marked and unmarked crossings, wherever pedestrian travel is not prohibited." If this is intended to be a true statement, it should be reconsidered. Other sections require a pedestrian activated signal where a right turn slip lane is present. A "slip lane" definition should be added but the figures show a right turn movement separated by an island. This would require a traffic signal at nearly every intersection on a multilane road. Also, when a business obtains a driveway access permit on a corner, GDOT requires the addition of a right turn lane. This provision would also require a signal at the intersection (which the developer would be happy to do since it would increase the value of his business). The MUTCD has very specific warrants for the installation of signals that are based on years of experience to provide the best compromise between motorist safety, pedestrian safety and overall usability of the Rights-of-Way. If the Access Board decides that these warrants should be ignored, the decision to ignore them should be based on documented research.
Most GDOT projects are "alterations" in some (or many) respects. For instance even a new roadway on a new location generally follows the existing terrain and crosses existing roads that have homes and businesses near the newly created intersection (or interchange). In the design process we attempt to minimize the impact on these homes and businesses while providing a road that is safe for the traveling public.
As written, the guidelines only allow a deviation from the design parameters when the project is an "alteration" (or where an "addition" project connects with existing construction) and when it is "technically infeasible" to meet the requirement. (Although the Chapter 2 Scoping Requirements in the ABA/ADA final draft commentary (p16) mentions "disproportionality" it is not mentioned in the actual text.)
Additional guidance on what is "technically infeasible" should be provided. When building a road it is usually "technically feasible" to do anything if enough money is available.
The 1999 publication "Accessible Rights of Way, A Design Guide" has a more realistic approach for not meeting the ADA design requirements. "Technically Infeasible", "Fundamental Alteration of the Nature of the Project" and "Undue Burden" were mentioned as justification for not fully complying with the design requirements.
Note that the GDOT has a finite amount of money available. If complying with all of the ADA design parameters adds excessive cost to a project then fewer projects will be built. The overall effect will be fewer projects constructed and fewer accessibility improvements therefore there will be less overall benefit provided to disabled users. (For example, table-topping an intersection in a lightly populated area as part of a major roadway reconstruction project could easily cost an additional $ 2 million on a $20 million contract. That $ 2 million could upgrade 2 or 3 intersections in a highly urbanized area with large numbers of pedestrians.)
The CFR for the Dept. of Justice, Labor, HUD give guidelines on when exceptions to the ADA design parameters are justified. (But the justifications are not the same.) In order to provide consistency in implementing these requirements this information should be included in the Accessibility Guidelines.
For example:
CFR 35.150 states:
A public entity shall operate each service, program, or activity so that the service, program, or activity, when viewed in its entirety, is readily accessible to and usable by individuals with disabilities. This paragraph does not --
(1) Necessarily require a public entity to make each of its existing facilities accessible to and usable by individuals with disabilities;
(2) Require a public entity to take any action that would threaten or destroy the historic significance of an historic property; or
(3) Require a public entity to take any action that it can demonstrate would result in a fundamental alteration in the nature of a service, program, or activity or in undue financial and administrative burdens. In those circumstances where personnel of the public entity believe that the proposed action would fundamentally alter the service, program, or activity or would result in undue financial and administrative burdens, a public entity has the burden of proving that compliance with § 35.150(a) of this part would result in such alteration or burdens. The decision that compliance would result in such alteration or burdens must be made by the head of a public entity or his or her designee after considering all resources available for use in the funding and operation of the service, program, or activity, and must be accompanied by a written statement of the reasons for reaching that conclusion. If an action would result in such an alteration or such burdens, a public entity shall take any other action that would not result in such an alteration or such burdens but would nevertheless ensure that individuals with disabilities receive the benefits or services provided by the public entity.
The GDOT recommends the wording in this section be expanded to address situations where it is not necessary to meet all the design requirements and included in these guidelines. This section should describe and give guidance on "Technically Infeasible", "Fundamental Alteration of the Nature of the Project", "Undue Burden", Undue Financial Burden", and "Disproportionality". The section should also address how to handle conflicts with other Federal laws that deal with preserving historical and archeological sites, wetlands, and other natural resources. This section should also address the level of documentation and level of approval required.
Making the design parameters "recommendations" instead of "requirements" would solve many of these problems.
As written it is not defined precisely where pedestrians must be accommodated on the public R/W. This should be addressed.
GDOT Commentary: It seems that the disruption to the surrounding area, cost, and impacts on the safety of the motorists should be weighed against the need for pedestrian accommodation. This should be an Engineering Decision not a mandated requirement. The GDOT often uses curb and gutter and sidewalks to minimize the R/W requirements (or stay on existing R/W) not to provide pedestrian accommodations. Without relaxation of the design requirements (or allowing engineering judgement) many projects will not be built. The projects improve usability (even though they might not meet all the design requirements) for disabled users.
When the text of the document has been finalized, the required implementation date should be given careful consideration. Several of the proposed requirements will have major impacts on the design of the project and on the required Rights-of-Way. A lead time of 2 years would not be unreasonable for full compliance with some of the proposed requirements. This would allow time to reevaluate the Environmental Document, change the plans and acquire the additional Rights-of-Way.
The following is the Text of the Draft Guidelines for Accessible Public Rights-of-Way with GDOT comments and recommended changes noted.
1101 Application and Administration (referenced standards and defined terms)
1102 Scoping Requirements
1103 Pedestrian Access Route
1104 Curb Ramps and Blended Transitions
1105 Pedestrian Crossings
1106 Accessible Pedestrian Signal Systems
1107 Street Furniture
1108 Detectable Warning Surfaces
1109 On-Street Parking
1110 Call Boxes
1111 Alternate Circulation Path
1101 Application and Administration
1101.1 General. For the purposes of these requirements, the terms listed in section 1101.3 shall have the indicated meaning.
1101.2 Referenced Standards.
1101.2.1 MUTCD. Copies of the referenced standards may be obtained on-line from the Federal Highway Administration at http://mutcd.fhwa.dot.gov/.
MUTCD 2000-Millennium Edition Manual on Uniform Traffic Control Devices.
GDOT Comment - Add AASHTO 2001 Design Guide to the list on standards
1101.3 Defined Terms.
GDOT Comments -
Add definitions for:
Slip Ramp
Perpendicular Curb Ramp
Parallel Curb Ramp
Addition
Alteration
Blended Transition
Technically infeasible
Disproportionality
Undue Financial Burden
Undue Administrative Burden
Fundamental Alteration of the Nature of the Project
Agency that approves ADA design requirements exceptions
GDOT Recommended Definitions -
New facility: A new roadway on new alignment where the horizontal or vertical alignment, or crossslope are not controlled by an existing facility.
Alteration: A project or portion of a project where the horizontal or vertical alignment or crossslope of the roadway are controlled by an existing facility is an "alteration". No alterations may be done that have the effect of decreasing accessibility.
Fundamental alteration in the nature of a project: An improvement that changes the basic concept for the project.
Program Accessibility: If the facility is accessible to people with disabilities through another method or alternative routes, the facility may not be required to comply with all ADA design parameters. Note that curb cut ramps are specifically named as a required element and cannot be excluded.
Undue financial burden: If the cost of providing or maintaining a facility that fully complies with ADA design parameters is prohibitively expensive or the required future funding is not guaranteed, full compliance with the ADA design parameters may be considered an undue financial burden.
For small projects, if complete compliance with the ADA design parameters adds over 20% to the total cost of the project, complete compliance is not required (but should be considered). However, the facilities shall be improved to the maximum extent possible using the 20% additional costs.
For large projects, if complete compliance with the ADA design parameters adds over 20% to the cost of the area of the project where the improvement is needed, complete compliance is not required (but should be considered). However, the facilities shall be improved to the maximum extent possible using the 20% additional costs. (This is intended to address major alteration projects where small areas are not in compliance with the ADA design parameters.)
Disproportional: If the cost of constructing a project (or portion of a project) that fully complies with ADA design parameters is prohibitively expensive full compliance with the ADA design parameters may be considered Disproportional.
For small projects, if complete compliance with the ADA design parameters adds over 20% to the total cost of the project, complete compliance is not required (but should be considered). However, the facilities shall be improved to the maximum extent possible using the 20% additional costs.
For large projects, if complete compliance with the ADA design parameters adds over 20% to the cost of the area of the project where the improvement is needed, complete compliance is not required (but should be considered). However, the project shall meet the ADA Design Requirements to the maximum extent possible using the 20% additional costs. (This is intended to address major projects where small areas are not in compliance with the ADA design parameters.)
Technically infeasible: If complying with the ADA design parameters require that the roadway alignment, grade, sight distance or clear zone not to meet AASHTO desirable requirements then complying with ADA design parameters is "technically infeasible".
Conflicts with other laws that protect historical, cultural, or natural resources make complying with ADA design parameters "technically infeasible".
Note that if complete compliance is "technically infeasible" the facility shall be modified to comply with ADA design parameters to the "maximum extent possible".
Accessible Pedestrian Signal. A device that communicates information about the pedestrian WALK phase in non-visual format.
Accessible Route. A continuous, unobstructed path that complies with Chapter 4.
GDOT Comment:
The definition of Accessible Route should be clarified. It is not clear whether shoulders are an "accessible route" on a road with no curb and gutter and/or no sidewalk.
Channelizing Island. Curbed or painted area outside the vehicular path that is provided to separate and direct traffic movement, which also may serve as a refuge for pedestrians.
Cross Slope. The slope that is perpendicular to the direction of travel. This is usually called superelevation on curves in the public right-of-way (see superelevation).
Crosswalk. That part of a roadway at an intersection that is included within the extensions of the lateral lines of the sidewalks on opposite sides of the roadway, measured from the curbline or, in the absence of curbs, from the edges of the roadway or, in the absence of a sidewalk on one side of the roadway, the part of the roadway included within the extension of the lateral lines of the sidewalk at right angles to the centerline. Also, any portion of a roadway at an intersection or elsewhere that is distinctly indicated for pedestrian crossing by lines or other markings on the surface.
GDOT Comment:
The definition of crosswalk appears to say that a crosswalk is only present if there is sidewalk present or if there is a "marked" crosswalk. While this definition makes it easier to comply with the ADA Design Requirements, it appears to conflict with the text of in other sections of the requirements and with the commentary.
Curb Line. A line at the face of the curb that marks the transition between the sidewalk and the gutter or roadway.
Curb Ramp. A ramp cutting through a curb or built up to it.
Detectable Warning. A surface feature built in or applied to walking surfaces or other elements to warn of hazards on a circulation path.
Dynamic Envelope. The clearance required for a rail vehicle and its cargo overhang due to any combination of loading, lateral motion, or suspension failure.
Element. An architectural or mechanical component of a building, facility, space, site or public right-of-way.
Facility. All or any portion of buildings, structures, improvements, elements and pedestrian or vehicular routes located on a site or in a public right-of-way.
Grade. (See running slope).
Grade Break. The meeting line of two adjacent surfaces of different slope (grade).
Locator Tone. A repeating sound that identifies the location of the pedestrian push button.
Pedestrian Access Route. An accessible corridor for pedestrian use within the public right-of-way.
GDOT Recommended Definition
Pedestrian Access Route. An accessible route, designated by the responsible agency, for pedestrian use within the public right-of-way.
This will allow the "rural" projects to be excluded from ADA requirements.
Public Right-of-Way. Land or property, usually in a corridor, that is acquired for or devoted to transportation purposes.
Roundabout. A circular intersection that has yield control of entering traffic, channelized approaches, counterclockwise circulation, and appropriate geometric curvature to limit travel speeds on the circulatory roadway.
Running Slope. The slope that is parallel to the direction of travel expressed as a ratio of rise to run. In the public right-of-way, this is usually called grade, and is expressed in percent.
Sidewalk. That portion of a public right-of-way between the curb line or lateral line of a roadway and the adjacent property line that is improved for use by pedestrians.
GDOT Comment:
What does "improved for use by pedestrians" mean? We are concerned that this could be interpreted to mean shoulders on "rural" projects or the flat graded area behind the curb if no concrete sidewalk is present.
This definition is critical. For instance if the paved shoulder is a "sidewalk", the ADA design requirements apply to rural projects. The GDOT requires separate right turn lanes on multilane rural roads at all intersections as a safety feature to allow the right turning traffic to move out of the high speed travel lanes. These requirements would mandate that pedestrian activated signals with locator tones be provided at essentially all intersections.
Splitter Island. A flush or raised island that separates entering and exiting traffic in a roundabout.
Street Furniture. Elements in the public right-of-way that are intended for use by pedestrians.
Superelevation. Cross slope on a curve in the roadway (see cross slope).
Walk Interval. That phase of a traffic signal cycle during which the pedestrian is to begin crossing, typically indicated by a WALK message or the walking person symbol and its audible equivalent.
1102 Scoping Requirements
1102.1 General. All areas of newly designed and newly constructed facilities in public rights-of-way and altered portions of existing facilities in public rights-of-way shall comply with Chapter 11.
GDOT Recommended wording:
1102.1 General. All areas of newly designed and newly constructed facilities in public rights-of-way and altered portions of existing facilities in public rights-of-way that include provisions for pedestrians shall comply with Chapter 11.
GDOT Comment:
The SCOPING REQUIREMENTS need to be expanded and clarified. If the exceptions recommended in 1102.2.2 (specifically Fundamental Alteration of the Nature of a Project are not allowed, when a road is resurfaced the crosswalks are altered. This provision requires the cross slope to be less that 2.08% in the crosswalk. This requires that the intersection be "tabletopped" and requires vertical grade changes all of the approach roadways. This requirement will essentially prohibit any resurfacing projects in urban areas where any existing grade or crossslope in the intersection exceeds 2%. (Even if the project would remove severe ruts, vertical lips, and potholes in the crosswalk that make the existing crosswalk unusable for pedestrians with disabilities.)
The same situation will exist if a traffic signal needs to be upgraded. As written, a signal could not be upgraded to allow for protected pedestrian movements without "tabletopping" the intersection.
1102.2 Existing Public Rights-of-Way. Additions to existing public rights-of-way shall comply with 1102.2.1. Alterations to existing public rights-of-way shall comply with 1102.2.2.
1102.2.1 Additions. Each addition to an existing public right-of-way shall comply with the applicable provisions of Chapter 11. Where the addition connects with existing construction, the connection shall comply with 1102.2.2.
1102.2.2 Alterations. Where existing elements or spaces in the public right-of-way are altered, each altered element or space shall comply with the applicable provisions of Chapter 11.
GDOT Comment: Define Spaces as used above.
EXCEPTION: In alterations, where compliance with applicable provisions is technically infeasible, the alteration shall comply to the maximum extent feasible.
GDOT Recommended Wording
EXCEPTION: In alterations, the project shall comply with applicable provisions unless the following applies. If full compliance is not required, the alteration shall comply to the maximum extent feasible.
A public entity shall operate each service, program, or activity and construct each project so that the service, program, or activity, and constructed project when viewed in its entirety, is readily accessible to and usable by individuals with disabilities. This paragraph does not --
(1) Necessarily require a public entity to make all areas of its existing facilities accessible to and usable by individuals with disabilities; or
(2) Require a public entity to take any action that would threaten or destroy the historic significance of an historic property; or that conflict with other laws that protect natural or archeological resources or cemeteries; or
(3) Require a public entity to take any action that is technically infeasible; or
(4) Require a public entity to take any action that it can demonstrate would result in a fundamental alteration in the nature of a service, program, or activity or in undue financial and administrative burdens or in a fundamental alteration of the nature of the project. Also, if the additional cost of fully complying with the ADA Design Requirements exceeds 20% of the cost of the project in the area affected by the improvement, full compliance may be considered "Disproportional" to the cost of constructing that area of the project. In those circumstances where personnel of the public entity believe that the proposed action would fundamentally alter the project, service, program, or activity, or the cost is disproportional or would result in undue financial and administrative burdens, a public entity has the burden of proving that compliance would result in such alteration or burdens. The decision that compliance would result in such alteration or burdens must be made by the head of a public entity or his or her designee after considering all resources available for use in the funding and operation of the service, program, or activity, and must be documented by a written statement of the reasons for reaching that conclusion. If an action would result in such an alteration or such burdens, a public entity shall take any other action that would not result in such an alteration or such burdens but would nevertheless ensure that individuals with disabilities receive the benefits or services provided by the public entity.
1102.2.2.1 Extent of Application. An alteration of an existing element, space, or area of a public right-of-way shall not impose a requirement for accessibility greater than required for new construction.
1102.2.2.2 Prohibited Reduction in Access. An alteration that decreases or has the effect of decreasing the accessibility of a public right-of-way or site arrival points to buildings or facilities adjacent to the altered portion of the public right-of-way, below the requirements for new construction at the time of the alteration is prohibited.
GDOT Comment: As worded it appears redundant. The GDOT wording states that regardless of what exceptions may be approved the accessibility cannot be less that before the project was constructed.
GDOT Recommended wording:
1102.2.2.2 Prohibited Reduction in Access. An alteration that decreases or has the effect of decreasing the accessibility of a public right-of-way or site arrival points to buildings or facilities adjacent to the altered portion of the public right-of-way is prohibited.
1102.3 Alternate Circulation Path. An alternate circulation path complying with 1111 shall be provided whenever the existing pedestrian access route is blocked by construction, alteration, maintenance, or other temporary conditions.
GDOT Comment: The amount of time of the closure and the expected pedestrian usage should be a factor. As written this would require a pedestrian bridge to be constructed if the entire bridge had to be closed for just 10 minutes.
See other comments on 1111
1102.4 Sidewalks. Where sidewalks are provided, they shall contain a continuous pedestrian access route complying with 1103. The pedestrian access route shall connect to elements required to comply with Chapter 11.
1102.5 Protruding Objects. Protruding objects on sidewalks and other pedestrian circulation paths shall comply with 1102.5 and shall not reduce the clear width required for pedestrian accessible routes.
1102.5.1 Protrusion Limits. Objects with leading edges more than 27 inches
EXCEPTION: Handrails shall be permitted to protrude 4-1/2 inches
1102.5.2 Post-Mounted Objects. Free-standing objects mounted on posts or pylons shall overhang circulation paths 4 inches
EXCEPTION: This requirement shall not apply to sloping portions of handrails serving stairs and ramps.
1102.5.3 Reduced Vertical Clearance. Guardrails or other barriers shall be provided where the vertical clearance is less than 80 inches
EXCEPTION: Door closers and door stops shall be permitted to be 78 inches
1102.6 Curb Ramps and Blended Transitions. A curb ramp or blended transition complying with 1104, or a combination of curb ramps and blended transitions, shall connect the pedestrian access routes to each street crossing within the width of each crosswalk.
1102.7 Pedestrian Signs. Signs for pedestrian use shall comply with 1102.7.
1102.7.1 Bus Route Identification. Bus route identification signs shall comply with 703.5.1 through 703.5.4, and 703.5.7 and 703.5.8. In addition, to the maximum extent practicable, bus route identification signs shall comply with 703.5.5. Bus route identification signs located at bus shelters shall provide raised and Braille characters complying with 703.2, and shall have rounded corners.
EXCEPTIONS 1: Bus schedules, timetables and maps that are posted at the bus stop or bus shelter shall not be required to comply with 1102.7.
2: Signs shall not be required to comply with 703.2 where audible signs are user- or proximity-actuated or are remotely transmitted to a portable receiver carried by an individual.
1102.7.2 Informational Signs and Warning Signs. Informational signs and warning signs shall comply with 703.5.
1102.8 Pedestrian Crossings. Where a pedestrian crossing is provided, it shall comply with the applicable provisions of 1105. Where pedestrian signals are provided at a pedestrian crossing, they shall comply with 1106.
1102.9 Street Furniture. Street furniture that is intended for use by pedestrians and installed on or adjacent to a sidewalk shall comply with 309 and 1107.
1102.10 Stairs. Where provided, stairs shall comply with 504. Stair treads shall have a 2 inch
1102.11 Handrails. Where provided, handrails shall comply with 505.
1102.12 Vertical Access. Where provided elevators shall comply with 407, limited-use/limited-application elevators shall comply with 408, and platform lifts shall comply with 410. Vertical access shall remain unlocked during the operating hours of the facility served.
1102.13 Bus Stops. Bus boarding and alighting areas shall comply with 810.2. Bus shelters shall comply with 810.3.
GDOT comment: The bus stop locations are determined (and often changed) by the local transit authority. The GDOT does not have control on where these are placed and often the bus stops a several locations along a block. In many areas that have bus service there is not space available to provide these landings at all bus stops without severe disruption of the community. Consider requiring one accessible bus landing per block or every ¼ mile.
1102.14 On-Street Parking. Where on-street parking is provided, at least one accessible on-street parking space shall be located on each block face and shall comply with 1109.
GDOT Comment: The requirement will generally be achievable. However many of the small towns in Georgia are built with a small square. The blocks are very short and the sidewalks are often elevated. In this situation the addition of the accessible parking space (and an access route to the elevated sidewalk) would eliminate most or all the remaining spaces in the block. This would effectively put the businesses on the Town Square out of business. Often the entrances to the businesses are not accessible from the sidewalk due to steps. This requirement would provide access to the sidewalk in front of the businesses but would not provide access to the business.
This is another example of where "Engineering Judgement" should be used instead of a mandated requirement.
1102.15 Passenger Loading Zones. Where passenger loading zones are provided, they shall connect to a pedestrian access route and shall provide a minimum of one passenger loading zone in every continuous 100 linear feet (30 m) of loading zone space, or fraction thereof, complying with 302, 503.2, 503.3, and 503.5.
1102.16 Call Boxes. Where provided, call boxes shall comply with 1110.
1103 Pedestrian Access Route
1103.1 General. Pedestrian access routes shall connect to elements required to be accessible and shall comply with 1103.
1103.2 Components. Pedestrian access routes shall consist of one or more of the following components: walking surfaces, ramps, curb ramps, blended transitions, crosswalks, pedestrian overpasses and underpasses, elevators, and platform lifts. All components of a pedestrian access route shall comply with the applicable portions of this chapter.
1103.3 Clear Width. The minimum clear width of a pedestrian access route shall be 48 inches
1103.4 Cross Slope. The cross slope of the pedestrian access route shall be 1:48
Also, see comments on crosswalks (which are a part of the pedestrian access route).
The requirement for a 1:48
1103.5 Grade. The grade of the pedestrian access route within a sidewalk shall not exceed the grade established for the adjacent roadway.
EXCEPTION: The running slope of a pedestrian access route shall be permitted to be steeper than the grade of the adjacent roadway, provided that the pedestrian access route is less than 1:20
1103.6 Surfaces. The surfaces of the pedestrian access route shall comply with 302.
1103.7 Surface Gaps at Rail Crossings. Where the pedestrian access route crosses rail systems at grade, the horizontal gap at the inner edge of each rail shall be constructed to the minimum dimension necessary to allow passage of railroad car wheel flanges and shall not exceed 2-½ inches (64 mm).
EXCEPTION: On tracks that carry freight, a maximum horizontal gap of 3 inch
1103.7.1 Detectable Warnings. Where rail systems cross pedestrian facilities that are not shared with vehicular ways, a detectable warning shall be provided in compliance with 1108.
1103.8 Changes in Level. Changes in level shall comply with 303. Changes in level shall be separated horizontally 30 inches
GDOT Comment: 303 allows a ¼" max vertical lip, ¼" to ½" beveled on 1:2
EXCEPTION: The horizontal separation requirement shall not apply to detectable warnings.
GDOT Comment: What horizontal separation requirement? It is unclear what this means even if a horizontal separation requirement is specified.
1103.8.1 Rail Crossings. Where the pedestrian access route crosses rail systems at grade, the surface of the pedestrian access route shall be level and flush with the top of the rail at the outer edge and between the rails.
1104 Curb Ramps and Blended Transitions
1104.1 General. Curb ramps and blended transitions shall comply with 1104.
1104.2 Types. Perpendicular curb ramps shall comply with 1104.2.1 and 1104.3; parallel curb ramps shall comply with 1104.2.2 and 1104.3; blended transitions shall comply with 1104.2.3 and 1104.3.
1104.2.1 Perpendicular Curb Ramps. Perpendicular curb ramps shall comply with 1104.2.1, and shall have a running slope that cuts through the curb at right angles or meets the gutter grade break at right angles.
1104.2.1.1 Running Slope. The running slope shall be 1:48
1104.2.1.2 Cross Slope. The cross slope shall be 1:48
EXCEPTION: This requirement shall not apply to mid-block crossings.
1104.2.1.3 Landing. A landing 48 inches
EXCEPTION: Running and cross slope requirements shall not apply to mid-block crossings.
EDITORIAL COMMENT: The cross slope and running grade requirements do not apply at mid-block crossings 1104.2.1.3). If "Engineering Judgement" cannot be used, all pedestrian crossings at intersections can be prohibited and mid-block crossings provided. Is this the intention of these requirements?
1104.2.1.4 Flares. Flared sides with a slope of 1:10
1104.2.2 Parallel Curb Ramps. Parallel curb ramps shall comply with 1104.2.2, and shall have a running slope that is in-line with the direction of sidewalk travel.
1104.2.2.1 Running Slope. The running slope shall be 1:48
EXCEPTION: A parallel curb ramp shall not be required to exceed 15 feet
1104.2.2.2 Cross Slope. The cross slope shall be 1:48
1104.2.2.3 Landing. A landing 48 inches
GDOT Comment: This is a major problem. See comments on crosswalk cross slope 1105.2.2. Since this area at the edge of the curb, this can sometimes be accomplished by increasing the radii at the corners to get this are away form the travel lanes to allow room for warping the slope, but this increases the length of the crosswalk. Consider that this will require tradeoffs for the pedestrian.
EXCEPTION: Running and cross slope requirements shall not apply to mid-block crossings.
1104.2.2.4 Diverging Sidewalks. Where a parallel curb ramp does not occupy the entire width of a sidewalk, drop-offs at diverging segments shall be protected with a barrier.
1104.2.3 Blended Transitions. Blended transitions shall comply with 1104.3, and shall have running and cross slopes of 1:48
1104.3 Common Elements. Curb ramps and blended transitions shall comply with 1104.3.
1104.3.1 Width. The clear width of landings, blended transitions, and curb ramps, excluding flares, shall be 48 inches
1104.3.2 Detectable Warnings. Detectable warning surfaces complying with 1108 shall be provided, where a curb ramp, landing, or blended transition connects to a crosswalk.
1104.3.3 Surfaces. Surfaces of curb ramps, blended transitions, and landings shall comply with 302. Gratings, access covers, and other appurtenances shall not be located on curb ramps, landings, blended transitions, and gutter areas within the pedestrian access route.
1104.3.4 Grade Breaks. Grade breaks shall not be permitted on curb ramps, blended transitions, landings, and gutter areas within the pedestrian access route. Surface slopes that meet at grade breaks shall be flush.
GDOT comment: Where did this come from? It appears to be impossible to meet this requirement unless the entire intersection is on the same slope (no crown in the roadways). Also, does flush mean less than the 1/4" vertical lip allowed in the pedestrian access route?
1104.3.5 Changes in Level. Vertical changes in level shall not be permitted on curb ramps, blended transitions, landings, or gutter areas within the pedestrian access route.
GDOT comment: If the intent is to require no vertical lips (0" allowable) in these areas it is impossible to meet. If the ¼" allowed in the pedestrian access path it is OK this requirement is redundant.
1104.3.6 Counter Slopes. The counter slope of the gutter area or street at the foot of a curb ramp or blended transition shall be 1:20
GDOT comment: This is OK but it is not what the 2001 report recommended. A definition or picture of "counter slope" would be good.
1104.3.7 Clear Space. Beyond the curb line, a clear space of 48 inches
GDOT comment: The 4x4 clear area is required to begin beyond the curb line. Since the gutter slope only is required to be 5% or less in this area, Can the 4x4 area can include the gutter if the gutter slope is 2.08%? This should be clarified.
1105 Pedestrian Crossings
1105.1 General. Pedestrian crossings shall comply with 1105.
1105.2 Crosswalks. Crosswalks shall comply with 1105.2.
1105.2.1 Width. Marked crosswalks shall be 96 inches
1105.2.2 Cross Slope. The cross slope shall be 1:48
GDOT comment: This is a major problem, especially if reasonable grounds for exceptions are not provided. This requires "tabletopping" the intersection and adjusting the grades on the approaches. If one of the roads is in a curve where the superelevation is greater than 2.08% it requires a change in the horizontal alignment.
GDOT recommendation: Change "The cross slope shall" to "When practical the cross slope should".
EXCEPTION: This requirement shall not apply to mid-block crossings.
1105.2.3 Running Slope. The running slope shall be 1:20
GDOT comment: This is a problem, especially if reasonable grounds for exceptions are not provided and the cross slope requirements are changed. If the cross slope requirements are not change this requirement is meaningless and will not control. This requires changing the grade in the intersection and adjusting the grades on the approaches to less than 5 %. If one of the roads is in a curve where the superelevation is greater than 5% it requires a change in the horizontal alignment.
GDOT recommendation: Change "The running slope shall" to "When practical the cross slope should".
1105.3 Pedestrian Signal Phase Timing. All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
GDOT comment: Currently the GDOT normally uses 3.5 fps that was recommended in the Jan. 2001 report. The speed is reviewed on a case by case basis and 3.0 fps or sometime less is used depending on the type of the pedestrians at the intersection. It is possible to set the signal timing for a pedestrian speed of 3 feet
1105.4 Medians and Pedestrian Refuge Islands. Medians and pedestrian refuge islands in crosswalks shall comply with 1105.4 and shall be cut through level with the street or have curb ramps complying with 1104 and shall contain a pedestrian access route complying with 1103. Where the cut-through connects to the street, edges of the cut-through shall be aligned with the direction of the crosswalk for a length of 24 inches
1105.4.1 Length. Where signal timing is inadequate for full crossing of all traffic lanes or where the crossing is not signalized, cut-through medians and pedestrian refuge islands shall be 72 inches
GDOT Comment: The 6 foot
1105.4.2 Detectable Warnings. Medians and refuge islands shall have detectable warnings complying with 1108. Detectable warnings at cut-through islands shall be separated by a 24 inch
EXCEPTION: Detectable warnings shall not be required on cut-through islands where the crossing is controlled by signals and is timed for full crossing.
1105.5 Pedestrian Overpasses and Underpasses. Pedestrian overpasses and underpasses shall comply with 1105.5.
1105.5.1 Pedestrian Access Route. Pedestrian overpasses and underpasses shall contain a pedestrian access route complying with 1103.
1105.5.2 Running Slope. The running slope shall not exceed 1:20
1105.5.3 Approach. Where the approach exceeds 1:20
GDOT Comment: The requirement to require elevators at pedestrian overpasses / underpasses where the total rise / fall of the ramps is over 60 inches
1105.5.4 Stairs. Stairs shall comply with 504.
1105.5.5 Escalators. Escalators shall comply with 810.9.
1105.6 Roundabouts. Where pedestrian crosswalks and pedestrian facilities are provided at roundabouts, they shall comply with 1105.6.
GDOT Comment: The GDOT agrees that it is a challenge for a pedestrian (especially a vision-impaired pedestrian) to cross a roundabout. However adding pedestrian signals to the roundabout not only decreases the capacity of the intersection it violates driver expectations and provides the pedestrians with a false since of security. The GDOT feels that this requirement would increase vehicular accidents (mostly rear-end collisions) and increase pedestrians accidents. The only advantage to it would be that the driver could be charged with running a traffic light in addition to failing to yield to a pedestrian. As an aside, the definition of roundabout states "an intersection that has yield control?". If this requirement is implemented the definition is wrong.
1105.6.1 Separation. Continuous barriers shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited. Where railings are used, they shall have a bottom rail 15 inches
1105.6.2 Signals. A pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the crosswalk, including the splitter island. Signals shall clearly identify which crosswalk segment the signal serves.
1105.7 Turn Lanes at Intersections. Where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island.
If the discussion in the commentary that states crosswalks are wherever pedestrians crossing are not prohibited is true, the requirement for a pedestrian actuated signal at right and left turn slip lanes should be reconsidered. On most multilane roads the GDOT constructs right turn lanes to allow the turning traffic to get out of the through lanes. This is done to reduce accidents by providing a safer right turn. As written, this requires a pedestrian activated signal (even if a pedestrian is at the intersection just once every 6 months). This is not only very costly and provides very little benefit; it violates driver expectations and will result in increased accidents and probably increase pedestrian accidents. (see roundabout discussion)
Another consideration for not providing the pedestrian activated signal at all slip lanes and roundabouts: In some area of the state, persons (and sometimes organized groups of persons) solicit handouts at intersections. These persons benefit from stopped traffic. The pedestrian signal would continually be activated by these persons (resulting in traffic congestion) even if no pedestrian was attempting to use the crosswalk.
1106 Accessible Pedestrian Signal Systems
1106.1 General. Pedestrian signal systems shall comply with 1106.
The signal that re
1106.2 Pedestrian Signal Devices. Each crosswalk with pedestrian signal indication shall have a signal device which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device and shall comply with 1106.3.
1106.2.1 Location. Pedestrian signal devices shall be located 60 inches
EXCEPTION: The minimum distance from other signal devices shall not apply to signal devices located in medians and islands.
1106.2.2 Reach and Clear Floor or Ground Space. Pedestrian signal devices shall comply with 308. A clear floor or ground space complying with 305 shall be provided at the signal device and shall connect to or overlap the pedestrian access route.
1106.2.3 Audible Walk Indication. The audible indication of the WALK interval shall be by voice or tone.
1106.2.3.1 Tones. Tones shall consist of multiple frequencies with a dominant component at 880 Hz. The duration of the tone shall be 0.15 seconds
1106.2.3.2 Volume. Tone or voice volume measured at 36 inches
1106.3 Pedestrian Pushbuttons. Pedestrian pushbuttons shall comply with 1106.3.
1106.3.1 Operation. Pedestrian pushbuttons shall comply with 309.4.
1106.3.2 Locator Tone. Pedestrian pushbuttons shall incorporate a locator tone at the pushbutton. Locator tone volume measured at 36 inches
1106.3.3 Size and Contrast. Pedestrian pushbuttons shall be a minimum of 2 inches
1106.3.4 Optional Features. An extended button press shall be permitted to activate additional features. Buttons that provide additional features shall be marked with three Braille dots forming an equilateral triangle in the center of the pushbutton.
1106.4 Directional Information and Signs. Pedestrian signal devices shall provide tactile and visual signs on the face of the device or its housing or mounting indicating crosswalk direction and the name of the street containing the crosswalk served by the pedestrian signal.
1106.4.1 Arrow. Signs shall include a tactile arrow aligned parallel to the crosswalk direction. The arrow shall be raised 1/32 inch
1106.4.2 Street Name. Signs shall include street name information aligned parallel to the crosswalk direction and complying with 703.2.
1106.4.3 Crosswalk Configuration. Where provided, graphic indication of crosswalk configuration shall be tactile and shall comply with 703.5.1.
1107 Street Furniture
1107.1 General. Street furniture shall comply with 1107.
1107.2 Clear Floor or Ground Space. Street furniture shall have clear floor or ground space complying with 305 and shall be connected to the pedestrian access route. The clear floor or ground space shall overlap the pedestrian access route 12 inches
1107.3 Drinking Fountains. Where drinking fountains are provided, they shall comply with 602.
1107.4 Public Telephones. Where public telephones are provided, they shall comply with 1107.4.
1107.4.1 Single Telephone. Where a single public telephone is provided, it shall comply with 704.2 and 704.4
1107.4.2 Multiple Telephones. Where a bank of public telephones is provided, at least one telephone shall comply with 704.2, and at least one additional telephone shall comply with 704.4.
1107.4.3 Volume Controls. All public telephones shall provide volume controls complying with 704.3.
1107.5 Public Toilet Facilities. Permanent or portable public toilet facilities shall comply with 603. At least one fixture of each type provided shall comply with 604 through 610. Operable parts, dispensers, receptacles, or other equipment shall comply with 309.
EXCEPTION: Where multiple single-user toilet facilities are clustered at a single location, at least 5 percent, but no fewer than one single-user toilet at each cluster shall comply with 603 and shall be identified by the International Symbol of Accessibility complying with 703.7.2.1.
1107.6 Tables, Counters, and Benches. Tables, counters, and benches shall comply with 1107.6.
1107.6.1 Tables. Where tables are provided in a single location, at least 5 percent but no fewer than one, shall comply with 902.
1107.6.2 Counters. Where provided, counters shall comply with 904.
1107.6.3 Benches. Where benches without tables are provided at a single location, at least 50 percent, but no fewer than one, shall comply with 903 and shall have an armrest on at least one end.
1108 Detectable Warning Surfaces
1108.1 General. Detectable warnings shall consist of a surface of truncated domes aligned in a square grid pattern and shall comply with 1108.
1108.1.1 Dome Size. Truncated domes in a detectable warning surface shall have a base diameter of 0.9 inches
1108.1.2 Dome Spacing. Truncated domes in a detectable warning surface shall have a center-to-center spacing of 1.6 inches
1108.1.3 Contrast. Detectable warning surfaces shall contrast visually with adjacent walking surfaces either light-on-dark, or dark-on-light.
1108.1.4 Size. Detectable warning surfaces shall extend 24 inches
1108.2 Location.
1108.2.1 Curb Ramps and Blended Transitions. The detectable warning surface shall be located so that the edge nearest the curb line is 6 inches
1108.2.2 Rail Crossings. The detectable warning surface shall be located so that the edge nearest the rail crossing is 6 inches
1108.2.3 Platform Edges. Detectable warning surfaces at platform boarding edges shall be 24 inches
1109 On-Street Parking
1109.1 General. Car and van on-street parking spaces shall comply with 1109.
1109.2 Parallel Parking Spaces. An access aisle at least 60 inches
GDOT comment: The vehicular travel lane should not include the bike lane, if present.
EXCEPTION: An access aisle is not required where the width of the sidewalk between the extension of the normal curb and boundary of the public right-of-way is less than 14 feet
1109.3 Perpendicular or Angled Parking Spaces. Where perpendicular or angled parking is provided, an access aisle 96 inches
1109.4 Curb Ramps or Blended Transition. A curb ramp or blended transition complying with 1104 shall connect the access aisle to the pedestrian access route.
1109.5 Obstructions. There shall be no obstructions on the sidewalk adjacent to and for the full length of the space.
EXCEPTION: This provision shall not apply to parking signs complying with 1109.6 and parking meters complying with 1109.7.2.
1109.6 Signs. Parking spaces shall be designated as reserved by a sign complying with 502.6. Signs shall be located at the head or foot of the parking space so as not to interfere with the operation of a side lift or a passenger side transfer.
1109.7 Parking Meters. Where parking meters are provided, they shall comply with 1109.7.
1109.7.1 Operable Parts. Operable parts shall comply with 309.
1109.7.2 Location. A parking meter shall be located at the head or foot of the parking space so as not to interfere with the operation of a side lift or a passenger side transfer.
EXCEPTION: Where parking meters are not provided at the space, but payment for parking in the space is included in a centralized collection box or paying station, the space shall be connected to the centralized collection point with a pedestrian access route.
1109.7.3 Displays and Information. Displays and information shall be visible from a point located 40 inches
1110 Call Boxes
1110.1 General. Call boxes shall comply with 1110.
1110.2 Operable Parts. Operable parts shall comply with 308 and 309.4. Where provided, labeling shall comply with 703.2 and 703.3.
EXCEPTION: Mechanically operated systems in which the signal is initiated by a lever pull shall be permitted to have an activating force of 12 lbf
1110.3 Turning Space. A turning space complying with 304 shall be provided at the controls.
1110.4 Edge Protection. Edge protection complying with 405.9.2 shall be provided where the area at the call box is adjacent to an abrupt level change.
1110.5 Motor Vehicle Turnouts. Where provided, a motor vehicle turnout shall have a minimum paved area of 16 feet
1110.6 Two-Way Communication. Where provided, two-way voice communication shall comply with 1110.6, 708.2 and 708.3.
1110.6.1 Volume Controls. Volume controls complying with 704.3 shall be provided.
1110.6.2 TTY. A TTY complying with 704.4 shall be provided.
1111 Alternate Circulation Path
1111.1 General. Alternate circulation paths shall comply with 1111.
Also see comment in 1102.3
1111.2 Width. The alternate circulation path shall have a width of 36 inches
1111.3 Location. The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street.
GDOT comment: This should be a recommendation and subject to Engineering judgement. This will require additional easement and may cause additional displacements. Providing a pedestrian route on the same side of the road for a few hours, weeks or months should be weighed against the community impacts. Especially since many existing sidewalks were built to avoid taking homes and there is limited pedestrian usage.
This requirement may reduce the overall safety to the pedestrians since it will provide path near the construction equipment.
On a project where existing bridges with sidewalk on both sides are being widened, this requirement will require pedestrian accommodations on both sides, which will often require a temporary pedestrian bridge (or 2 temporary bridges).
1111.4 Protection. The alternate circulation path shall comply with 307 and shall be protected with a barricade complying with 1111.6 to separate the pedestrian access route and alternate circulation path from any adjacent construction, drop-offs, openings, or other hazards.
GDOT comment: This needs clarification. In the permanent condition the pedestrian on the sidewalk is only protected from traffic by curb(2 feet
1111.5 Signs. Signs complying with 703.5 shall be provided at both the near side and the far side of the intersection preceding a disrupted pedestrian access route.
1111.6 Barricades. Barricades shall be continuous, stable, and non-flexible and shall consist of a solid wall or fence or a Type II or Type III barricade as specified in MUTCD section 6F-60 with the bottom or lower rail 1-1/2 inches
David R. Smith, September 25, 2002
You may recall meeting with a group of persons from the segmental paving industry a while ago concerning proposed research on the interaction of wheelchairs and pavement. The results of that research are attached.
Please enter the attached letter [below] and researchreport [PDF version] (23 pages) into the public comment on the draft ADAAG for the public right of way.
Please direct questions about the letter or report to my attention.
Thank you for your time and efforts.
Sincerely,
David R. Smith, Technical Director
Interlocking Concrete Pavement Institute
September 25, 2002
Mr. Thurman M. Davis, Sr., Chair
Members of the U.S. Architectural and Transportation
Barriers Compliance Board
1331 F Street NW Suite 1000
Washington, DC 20004-1111
Re: Public Comment on The Americans with Disabilities Act (ADA) Accessibility Guidelines for Buildings and Facilities; Architectural Barriers Act (ABA) Accessibility Guidelines; Public Right of Way
Dear Mr. Thurman and Board Members:
Thank you for the opportunity to comment on the subject accessibility design guidelines for the public right-of-way. The following is from the Interlocking Concrete Pavement Institute (ICPI), The Brick Industry Association (BIA), and the National Concrete Masonry Association (NCMA). These organizations represent manufacturers of segmental pavers made from concrete and clay. These organizations represent industries that produced approximately 450 million square feet of segmental paving in 2001.
We are asking the Access Board to accept concrete and clay segmental paving systems as suitable surfaces for the proposed 48 in
On January 10, 2001, the Public Rights-of-Way Access Advisory Committee (PROWAAC) commissioned by the Access Board released a report entitled, Building a True Community. The Committee's report proposed a 60 in
The report proposed (p. 45) making the pedestrian access route "as free of jointed surfaces and as visually uniform as possible." It further advised on the need "to eliminate, to the greatest extent possible, surfaces that cause the front end of a wheelchair to vibrate or bounce as one travels across the surface." It further cited an existing FHWA publication, Designing Sidewalks and Trails for Access, as support. With little supporting data, the FHWA guidebook identified segmental paving as (1) increasing the amount of work for wheelchair users, (2) creating a bumpy ride for wheelchair users, and (3) possibly creating tripping hazards due to differential settlement. For these reasons brick and cobblestone were not recommended by the FHWA for sidewalk and trail design.
Page 39 of the PROWAAC report identified a need for research on the measurement of the rolling vibration of pedestrian surfaces. A need was expressed for investigations into surface roughness, surface wavelength (vibration), and wheelchair features. The need for research is given further discussion in the commentary section of the subject proposed ADAAG for the public right-of-way.
On July 17, 2002, the Federal Register announced the release of the draft ADAAG for the public right-of-way for public review. Concerning Section 1103 Pedestrian Access Route, we applaud the Access Board for not taking action on determination of approved surfaces for the proposed 48 in
The commentary in the draft on Surfaces 1103.6 notes that research was recommended on the relationships between surface roughness and wheeled mobility aids, as well as on the development of measurement protocols. In light of the need for research, we were pleased to see that no requirement for surface smoothness was included in the proposed ADAAG for the public right-of-way. In response to this need, the ICPI, BIA, and NCMA have taken a leadership role by jointly funding research on surface smoothness of pavements. The results can assist the Access Board in developing guidelines for smoothness and these are presented below. We were also pleased to read the commentary on Changes in Level (1103.8) that did not "rule out the use of bricks of other small pavers that are installed in a manner that provides a relatively flush surface and that are properly maintained." Research
The need for a better understanding of interaction between wheelchairs and segmental paving challenged us to conduct research. The ICPI, BIA and NCMA engaged the University of Pittsburgh, Department of Rehabilitation Science & Technology to investigate the interaction of segmental pavement surfaces with manual and electric powered wheelchairs. Professor Rory A. Cooper, Ph.D. was the principal investigator. He is considered the leader in wheelchair design, testing, and the development of that industry's standards. You may wish to review his curriculum vitae on the web at http://www.shrs.pitt.edu/temp/rst/about/faculty/cooper.html. A copy of his research report is attached to this public comment in pdf format.
We would like to summarize the report and provide some recommendations. In March 2002, six test pavements were built outdoors adjacent to Professor Cooper's facility, the Human Engineering Research Laboratory at the Veterans Administration Hospital in Pittsburgh. Each test pavement was 4 ft
The chamfer is the beveled surface around the top edge of a paver. Its dimension is a critical factor in surface vibration. Its dimension is measured from the place where it begins to angle away from the top surface to the outside edge of the paver. (See the figure below.) It is molded into the paver for the purpose of reducing chipping during transit and installation, as well as facilitating removal of surface runoff. Chamfers are also beneficial for increasing slip and skid resistance.
The design of the experiment included an instrumented manual wheelchair traveling at 1 m/s (typical walking speed) and an instrumented powered wheelchair traveling at 1 m/sec and 2 m/s (cruise speed). Instrumentation consisted of accelerometers at the footrest and on the seat of each wheelchair.
There are many wheelchairs on the market and those selected for use in this research were considered typical to those in service. Ten unimpaired persons 23 to 55 in
The purpose of the experiment: (1) Measure the accelerations (vibration) including peak accelerations; (2) Through extrapolation of the data, compare the accelerations to the vibration exposure limits found in ISO 2631, Evaluation of Human Exposure to Whole-Body Vibration. This standard sets limits to the number or minutes and frequencies of vibration (hertz) to which the human body can be exposed. (3) Test for any significant difference in the work required to traverse each surface with a manual wheelchair. This was done with the same device specified in ASTM F 1951, Standard Specification for Determination of Accessibility of Surface Systems Under and Around Playground Equipment. The tests were done during the summer of 2002.
Research Results
The results found that there was no difference in the amount of work required to traverse any of the surfaces. For the manual wheelchair moving at 1m/sec, peak accelerations were found to be lower than those from the poured concrete surface, except for the concrete pavers with 8 mm wide chamfers. A similar pattern emerged in that overall vibration was lower among the paver surfaces than the poured concrete surface, except the paver with 8 mm chamfers which had mixed results.
For the electric powered wheelchair moving at 1 m/s, the poured concrete surface generated higher peak accelerations compared to the concrete and clay pavers with no chamfer and the clay paver with a 4 mm chamfer. Again, with the exception of the pavers having 8 mm wide chamfers, all other segmental pavements produced lower vibrations than the poured concrete surface. The poured surface and the concrete pavers with an 8 mm chamfer generated similar vibrations.
For the powered wheelchair at 2 m/s (cruise speed), the results were similar to moving at 1 m/s. The poured concrete surface generated higher peak accelerations compared to the concrete and clay pavers with no chamfers, and the clay paver with a 4 mm chamfer. Similar to the 1 m/s velocity, at 2 m/s, all pavers except those with 8 mm wide chamfers produced lower vibrations than the poured concrete surface. The poured surface and the concrete pavers with an 8 mm chamfer generated similar vibrations.Comparison to ISO 2631
ISO 2631 specifies vibration exposure limits to human body for 8 hours. First, the standard doesn't account for recovery periods. It assumes that exposure is for a continuous 8 hours. This standard must be compared to the behavior of wheelchair operation that is quite different. There are likely to be very few wheelchair users that travel for 8 hours with no stopping.
In support of this observation, Dr. Cooper references behavioral studies that show that users of electric powered wheelchairs move in them a total of about 3 hours a day. Those that use manual powered wheelchairs generally are moving between 2 and 3 hours per day. Furthermore, electric powered wheelchairs are more prevalent for outside use on the pedestrian access route. Table 3 excerpted from the report demonstrates that the surfaces tested fit within these time frames for normal daily use of manual and powered wheelchairs. All surfaces meet the typical daily exposures with the exception of the pavers with 8 mm wide chamfers.
Table 3. Comparison to ISO 2631 exposure limits.
Recommendations
The report recommends that all pavers except that with an 8 mm chamfer are acceptable for use in the pedestrian access route. The report further states that the pavers with an 8 mm chamfer gave mixed results and may need further study. We agree with the findings and report. We would like to underscore the point that pavers with 8 mm wide chamfer is larger than most chamfered pavers and was used for the purpose of providing an extreme gap between pavers. The typical chamfer dimension ranges between 4 and 6 mm. Therefore, most chamfered pavers in use would generate lower vibrations than evidenced in the report, and a higher capacity for exposure time when evaluated according to ISO 2361.
With the support of Dr. Cooper's report, we have demonstrated that the most common types of segmental paving are acceptable for pedestrian access route and for the proposed reduced vibrations zone. Clearly, the chamfer width is a key factor in keeping vibrations near or below that of typical jointed, poured concrete sidewalk surfaces. The results indicate that the number of joints in a sidewalk have little impact on smoothness and vibration. Rather, joint widths have a substantial influence. Other factors affect smoothness such as lippage (vertical displacement), the quality of the construction materials and procedures, as well as maintenance and repair of the surface during its use.
Dr. Cooper's report has some positive implications for the future of ADAAG for the public right-of-way. First, he uses established research methods and analytical tools that can be applied to other surfaces and wheelchairs. Second, these methods could be a basis for establishing surfaces acceptable for use in the pedestrian access zone and proposed reduced vibration zone. Third, these methods could be the basis for developing a portable, inexpensive measurement device for making such assessments. Dr. Cooper has expressed an interest in developing a prototypical device. Such research and development would advance the objective identifying measurable technical specifications.
Our final and strongest recommendation is to maintain Section 1103 as drafted. We would request that Dr. Cooper's research report be referenced in notes or commentary that might accompany the final guidelines. Finally, we would be interested in reviewing the possibility of participating in research aimed at developing measurement methods and specifications for surface smoothness.
Thank you for your time and consideration.
Sincerely,
Charles A. McGrath. CAE
Executive Director
Interlocking Concrete
Pavement Institute
Richard Jennison
President
Brick Industry Association
Mark Hogan, P.E.
President
National Concrete
Masonry Association
Attachment - report [PDF version]
cc: Jerry Markesino, City of Portland, OR, Office of Transportation, PROWAAC Chair
Don Brandon, State of Alaska, PROWAAC Subcommittee Chair on Sidewalks
Paul Church, Disability Rights Education Defense Fund, PROWAAC Subcommittee on Sidewalks, Surfaces Working Group
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.