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
RE: Detectable warnings or truncated domes
As the Director of Denver's Commission I'm concerned about the impact of re-implementing the requirement for truncated domes at curb ramps. Our experience with this issue 10 years ago was that, in our climate, the domes were: extremely difficult to maintain, damaged easily, difficult to repair, and created an obstacle. We also had difficulty finding an agreeable position among individuals in our disabled community on this issue as well.
With this in mind, we (the Commission and City) set out with a goal to create a curb ramp standard that complied with the requirements of the Americans with Disabilities Act (ADA) and at the same time satisfied the major concerns of our disabled community. After months of development and negotiation we focused on a design that we felt met our goal. Our standard provides tactile warning and direction by the use of grooves. There is also color contrast, proper slope ratios, compliant width, and maintenance is no different than that of a basic sidewalk.
Since the ADA was established this City has worked hard at complying with its guidelines and installing a curb ramp that is functional. Our curb ramps are installed whenever there is new construction, repair to existing pedestrian paths of travel, or requested through our "curb ramp request line". Needless to say, our curb ramp standard is very extensive throughout our city. Individuals look for it, feel for it, and identify with it for an accessible path of travel. Incorporating a new standard would only create confusion.
The City and County of Denver is considered to be one of the most accessible cities in the country. Part of this accolade is due to our extensive and consistent use of our curb ramp standard throughout the City. Our standard has also been duplicated and incorporated in other municipalities as well.
I urge the Access Board to seriously consider the impact of truncated domes at this juncture in time. Years have been spent not only by this City, but others as well; establishing standards and installing curb ramps. We want to continue in the direction that we initiated 10 years ago. We feel our curb ramp standard provides exceptional accessibility and serves the disabled community and others well. Providing a curb ramp that is functional to use and expected.
Thank you,
Ed Neuberg
Director, Denver Commission for People with Disabilities
Patrick G. Rivera, October 3, 2002
Attached are comments on the recently released Draft Guidelines on accessibility of public rights-of-way from the City and County of San Francisco, Department of Public Works, Bureau of Engineering, Streets & Highways Section. Thank you for the opportunity to allow us to comment.
Patrick G. Rivera
City and County of San Francisco
Department of Public Works
Bureau of Engineering
Streets & Highways Section, Manager
Re: Comments on the Draft Guidelines on Accessible Public Rights-of-Way as Proposed by the Access Board
I understand that you are accepting comments on the recently released Draft Guidelines on accessibility of public rights-of-way now being considered by the Access Board. Below comments from the City and County of San Francisco, Department of Public Works, Streets & Highways Section. Note that these comments do not represent the entire Department's comments but only one design section. There may be other sections with in the Department submitting comments.
1102 Scoping Requirements:
In 1102.2 there are discussions indicating compliance requirements, exceptions due to technical infeasibilities etc. However, there is no clear guidance to what extent an ADA compliant alteration is necessary for locally funded projects. In other words the cost impact is not discussed. Case in point. As part of a traffic signal upgrade project, we're required to install curb ramps. However, the cost to install the curb ramp component is almost as much as the traffic signal upgrade component. We have been unable to determine what dollar amount increase is considered hardship or what percentage cost increase on a project due to ADA requirements are reasonable. 1104 Curb Ramps and Blended Transitions
1104.2.1
Even though it's stated in 1104.3.2, it's best to include it in this section as well.
1104.2.1.1 Cross Slope
In the City and County of San Francisco the street and sidewalk grades range from 2% to 22%. This section states that the running slope shall be 1:48
1104.2.1.4 Flares
Flares with 10% slope measured along the curb line may create a steep wing when a curb ramp is constructed parallel to the crosswalk at a skewed intersection.
1104.2.2.1 Running Slope
"Parallel curb ramps shall not be required to exceed 15 feet
1104.3.2 Detectable Warnings
If detectable warnings (truncated domes as in 1108) would be required for all curb ramps regardless of the slope, then is the color contrast of the curb ramp required by the CA State Title 24 be required.
1104.3.3 Surfaces
The prohibition of gratings, storm drains, utility and sewer access covers on ramps, and landings, transitions and gutters within the pedestrian access route will be challenging to comply with. The question is: Are we required to relocate catch basins, manhole covers, drains etc? Even if such existing facilities are to be accepted as preexisting condition or exceptions, the addition of new truncated domes will be very challenging.
1104.3.6 Counter Slopes
The requirement of 1:20
1104.3.7 Clear Space
The roadway next to the curb on major routes may be a vehicle travel lane during "rush hour" times. The requirement of a 4' by 4' clear space at bottom of ramp outside the parallel vehicle travel lane conflicts with current traffic routing.1105 Pedestrian Crossings
1105.2.2 Cross Slope
1105.2.3 Running Slope
In the City and County of San Francisco the street and sidewalk grades range from 2% to 22%. In 1105.2.2 the maximum cross slope of 1:48
1108.2.1 Curb Ramps and Blended Transitions
Many ramps are located along the radius of the curb return, so the ramp bottom at the curb line is curved and not perpendicular to the path of travel. Custom design and production of a pre-cast or cast-in-place surface with truncated domes that fit these irregular areas will be difficult. A solution would be to increase the maximum distance to the curb line from 8 inches to 12 inches
The above comments do not represent a complete list of comments from the City and County of San Francisco. You may be receiving additional comments from other Departments and Agencies. I would like to thank you for allowing the Engineer's in my Section and me the opportunity to comment on the draft guidelines. Please add me to your e-mail list regarding this topic.
Sincerely,Patrick G. Rivera
City and County of San Francisco
Department of Public Works
Bureau of Engineering
Streets & Highways Section, Manager