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
American Institute of Architects, October 28, 2002
The American Institute of Architects
Introduction
The American Institute of Architects, founded in 1857, is the professional organization for more than 70,000 licensed architects and associated professionals. With headquarters in Washington, D.C., and more than 300 state and local chapters worldwide, the AIA seeks to promote a more humane built environment through education, government advocacy, community redevelopment, and public outreach activities.
As part of its commitment to making the built environment fully accessible for the safe, enjoyable use of everyone, the AIA supports the goal of the Draft Guidelines.General CommentsAccessible Pathways to and through the Built Environment
AIA architects recognize the value of developing a network of accessible pathways to and through the built environment, including those in the public rights-of-way, within a site, and within buildings and facilities. Accessible pedestrian routes, approaches, and entrances are often important aspects of an architect's design of a building or space, and development of a seamless pedestrian path is a desirable goal.Clarity and Certainty
The AIA advocates clear and certain guidance to help ensure compliance with the ADA.
Clearly written, concise guidelines will help ensure that architects understand the requirements of ADAAG and, even more important, will provide them with a high degree of certainty that their designs meet its accessibility standards. The AIA urges the U.S. Architectural and Transportation Barriers Compliance Board (Access Board) to continue to strive for clarity and certainty in the ADAAG.Curb Ramps
The Draft Guidelines are inconsistent in their treatment of curb ramps. In particular, the draft is inconsistent in the way it handles the allowable slopes for parallel curb ramps and perpendicular curb ramps running parallel to street grades. The maximum-length exception for parallel curb ramps is not applied to perpendicular curb ramps. When the direction of street grade is parallel to the curb ramp, however, it should not matter which type of curb ramp is used. Both should be required to have the same maximum required distance. Otherwise, to stay within the maximum slope requirements, a curb ramp would have to be extremely long.Grade of Pedestrian Access Routes
The Draft Guidelines prohibit slopes on pedestrian access routes from exceeding the grade established for the adjacent roadway. However, where parallel or perpendicular curb ramps are installed in line with the direction of sidewalk travel, the curb ramp on the uphill side of a landing at mid-block and the perpendicular curb ramp on the uphill side of an intersecting street will have to exceed the grade of the adjacent street. Exceeding the grade of the street is necessary in order to overcome the difference in elevation from the street to the top of the curb/sidewalk.Changes in Level
The Draft Guidelines address the issue of changes in level in several places. The current ADAAG acknowledges the reality of changes in level, addresses how they should be accomplished, and provides minimum acceptable standards for accessible floor and ground surfaces. In contrast, the Draft Guidelines prohibit changes in level in most areas.
The Draft Guidelines do not permit changes in level along accessible routes more often than every 30 inches
The Draft Guidelines also prohibit changes in level to regulate the unevenness of the surface, although the Access Board has decided this is premature until measurable technical specifications are identified. The discussion says, "this would not rule out the use of bricks or other small pavers, installed in a manner that provides a relatively flush surface and that are properly maintained." This assumption is inaccurate. Particularly in exterior applications, installing unit pavers without a change of level within a 30-inch zone would be almost impossible. The pavers would have to be installed with extreme precision, and the joints would have to be grouted exactly flush with the top of the pavers. In addition, such materials and the supporting substrates are subject to movement due to changes in temperature and moisture content, as well as inherent differences in the materials. It is unrealistic and unreasonable to expect that such a surface could be maintained in a "perfectly" smooth condition.
Vertical changes in level at curb ramps, blended transitions, landings, and gutter areas along pedestrian routes are also prohibited in the Draft Guidelines. This requirement would prohibit the use of any material whose texture had even the smallest groove or crack and would essentially eliminate the use of many materials. Unit pavers, for example, could not be used because they would create tremendous problems in trying to achieve and maintain perfect flatness. Even scored concrete would not be allowed under this requirement, regardless of how narrow the score. Square, metal utility covers measuring less than 30 inches by 30 inches
Whereas the current ADAAG specifies minimum requirements, the Draft Guidelines?by allowing no changes in level and requiring perfectly flat surfaces?up the ante considerably by moving to optimum requirements.Pedestrian Overpasses and Underpasses
The requirements for pedestrian overpasses and underpasses in the Draft Guidelines are linked to the rise of the ramped approach. The vague terms used in the guidelines do not define the "approach" and do not appear to consider the distance over which the approach might span. There are no such limitations on ramp rise in other areas of the built environment. Elevators are expensive to install and maintain in such environments. Moreover, elevators in unsupervised public areas are subject to vandalism and may pose a security threat by providing hiding spaces for criminals. Given these problems, it is unlikely that pedestrian overpasses and underpasses will be built.Conclusion
Accessibility in the public rights-of-way is an important and highly complex subject. It is important that the impact of regulations be completely understood before development of a final rule. It is equally important that requirements be written in clear and concise language in order to achieve the desired accessibility without misinterpretations and misunderstandings.Comments to Specific Text
The following table includes comments to the specific text of the Draft Guidelines.
Draft Guidelines for
Accessible Public Rights-of-Way The American Institute of Architects Comments
1101 Application and Administration
1101.1 General. For the purposes of these requirements, the terms listed in section 1101.3 shall have the indicated meaning.
1101.2 Referenced Standards.
1101.2.1 MUTCD. Copies of the referenced standards may be obtained on-line from the Federal Highway Administration at http://mutcd.fhwa.dot.gov. The reference to where it can be obtained is not necessary in a code. This is good commentary information.
MUTCD 2000-Millennium Edition Manual on Uniform Traffic Control Devices.
1101.3 Defined Terms.
Accessible Pedestrian Signal. A device that communicates information about the pedestrian WALK phase in non-visual format.
Accessible Route. A continuous, unobstructed path that complies with Chapter 4. This definition is superior to the one in the 2 April 02 draft ADAAG.
Channelizing Island. Curbed or painted area outside the vehicular path that is provided to separate and direct traffic movement, which also may serve as a refuge for pedestrians. Delete the last part of the definition?"which also may serve as a refuge for pedestrians." This is clearly not what defines the channelizing island and should be left to commentary.
Cross Slope. The slope that is perpendicular to the direction of travel. This is usually called superelevation on curves in the public right-of-way (see superelevation). The added text about superelevation is advisory and as such unfit for the definition. Recommendation: Place this text in a commentary if there is value in the explanation. Also, see comment under definition of "Superelevation."
Crosswalk. That part of a roadway at an intersection that is included within the extensions of the lateral lines of the sidewalks on opposite sides of the roadway, measured from the curbline or, in the absence of curbs, from the edges of the roadway or, in the absence of a sidewalk on one side of the roadway, the part of the roadway included within the extension of the lateral lines of the sidewalk at right angles to the centerline. Also, any portion of a roadway at an intersection or elsewhere that is distinctly indicated for pedestrian crossing by lines or other markings on the surface. This definition is unnecessarily confusing.
There is no need to introduce a new term, "roadway," when ADAAG already has a defined term "vehicular way."
"Lateral lines of the sidewalk" is not a common term and is confusing. It might be clearer to say the "edges of the sidewalk," if that is what is meant.
It is unclear why the measurement method is given in the definition. This might be pertinent in some technical criteria and, if so, should be included in the technical provisions, not the definition. However, no place was found in this document where the measurement of the crosswalk was needed.
In addition, the measurement method is included in the middle of the definition, breaking the thought of what defines a crosswalk.
The phrase "?within the extension of the lateral lines of the sidewalk at right angles to the centerline" is unclear. Right angles to the centerline of what?
The last sentence is too open-ended. If this is intended to capture mid-block crosswalks, a new definition should be added. If it is intended to capture all marked crosswalks, then it will likely negate the rest of the definition when it is applied in the real world. For example, the intersection could have a meandering marked path across the intersection that is outside the area of the defined crosswalk, and it would qualify under this part of the definition as a crosswalk.
Proposed definition:
Crosswalk: That part of the vehicular way that is included within the projection of the line of the sidewalk edges across the intersection. Where sidewalks occur on both sides of the intersection, the imaginary lines connect the sidewalk edges across the intersection.
Alternate proposal:
Crosswalk: That part of a vehicular way at an intersection that is included within the imaginary lines connecting sidewalk edges across the vehicular way. In the absence of a sidewalk on one side of the roadway, it is the part of the vehicular way that is included in the projection of the line of the sidewalk edges across the intersection.
Curb Line. A line at the face of the curb that marks the transition between the sidewalk and the gutter or roadway. The definition of curb line needs clarification. Is this line the top back of the curb, the top front, or the toe of the curb? Some curb faces are sloped, raising the question of where the curb line falls.
Curb Ramp. A ramp cutting through a curb or built up to it. A transition at a curb that has a running slope of less than 1:20
A curb ramp is a feature that is more commonly understood than a "blended transition," which is not defined. Recommend defining blended transition, at least in commentary.
Detectable Warning. A surface feature built in or applied to walking surfaces or other elements to warn of hazards on a circulation path.
Dynamic Envelope. The clearance required for a rail vehicle and its cargo overhang due to any combination of loading, lateral motion, or suspension failure. The suspension failure is a little perplexing. Isn't that covered under lateral motion? If not, how is it an enforceable part of the guidelines? Does the envelope include the area of trains that have derailed due to suspension failure? If this is not a necessary part of the definition, it is best deleted or moved into commentary.
Element. An architectural or mechanical component of a building, facility, space, site or public right-of-way. See comments at right-of-way.
Facility. All or any portion of buildings, structures, improvements, elements and pedestrian or vehicular routes located on a site or in a public right-of-way. See comments at right-of-way.
Grade. (See running slope). The term "grade" is probably not necessary in this document, but if found to be necessary, consistency of use will be extremely important. If it is necessary, then it should be differentiated from the term "running slope" by definition. Grade is commonly used by industry for sitework and roadwork. So, if it is necessary to use the term, define it as the slope or running slope of the vehicular way, whichever is appropriate. As shown here, it appears to include only the running slope and not the cross slope. It is unclear how that can be, at an intersection where the running slope of two streets cross, but nonetheless, the definition should be separated from "running slope," which is typically used for the sidewalk or pedestrian access route. Another problem with identifying this term with a running slope is the following definition of "grade break," which is not limited to running slope.
In addition, the term should not be used for other purposes in the rule. For example, the term "grade" is used with a completely different meaning in two places?sections 1103.7 and 1103.8.1?in the draft guidelines. Another term should be used here.
Grade Break. The meeting line of two adjacent surfaces of different slope (grade). "Grade" now becomes the same as any slope, not just running slopes. See comments to the definition of "Grade."
Locator Tone. A repeating sound that identifies the location of the pedestrian push button. A message that says "the button is on the other side of the intersection" satisfies this definition, though clearly not the intended result.
Alternative text:
Locator Tone. A repeating sound originating from a location adjacent to the pedestrian push button for purposes of identifying the location of the pedestrian push button.
Pedestrian Access Route. An accessible corridor for pedestrian use within the public right-of-way. The term "corridor" adds unnecessary questions to the definition. Corridors in buildings have space defining walls. Corridors in transportation planning have a definition relating to roadways (as used in the next definition). Recommendation: For clarity, use a more common term such as path, pathway, or route. A term commonly used for the setting will help avoid questions about what is meant.
Recognizing that there has been a huge effort not to use the term "accessible route" in this document, it is still a logical term that simply has different technical criteria in the public right-of-way.
Public Right-of-Way. Land or property, usually in a corridor, that is acquired for or devoted to transportation purposes. ADA in general and ADAAG in particular are rather loose in the use of the word "public." Does this imply that the public owns the underlying property? Or simply has an easement? Alternatively, this could be read to suggest that it is the public who has the right of transportation, or it could be read that he who acquires has the right of transportation. The word "transportation" carries the strong suggestion (almost to the point of being a necessary part of the definition of the word) that something is carried. This tends to exclude pedestrian sidewalks from the definition of public right-of-way.
As written, the definition could include many things that are not intended, such as bicycle paths, skateboard parks, etc.
"Land" is a subset of "property," so why use both words?
The "usually in a corridor" is advisory text unfit for a definition. Many people will not understand the term "corridor" in this context, particularly since the term as used here has a different meaning than the one used in the definition of "Pedestrian Access Route."
This definition could include land that a property owner buys from his neighbor for transporting timber to the highway.
This definition is crucial to scoping the regulation, but without better coordination with the definition of site it will weaken accessibility. The proposed definition describes something that can exist on sites, so using the rule that the specific requirements trump the general requirements, it follows that designers will be permitted to use the weaker requirements of rights-of-way where previously they were required to provide a higher level of accessibility.
Roundabout. A circular intersection that has yield control of entering traffic, channelized approaches, counterclockwise circulation, and appropriate geometric curvature to limit travel speeds on the circulatory roadway.
Running Slope. The slope that is parallel to the direction of travel expressed as a ratio of rise to run. In the public right-of-way, this is usually called grade, and is expressed in percent. Delete the phrase "expressed as a ratio of rise to run" and the second sentence as advisory material inappropriate for a definition.
Again, the term "grade" appears as running slope only. See comments to definitions of "Grade" and "Grade Break."
Sidewalk. That portion of a public right-of-way between the curb line or lateral line of a roadway and the adjacent property line that is improved for use by pedestrians. This is poor code drafting, because the intent of the designer is the triggering condition. If the designer improved the shoulder of the road to make life easier for the snowplow, it is not a sidewalk even though it looks like a sidewalk and its use by pedestrians is tolerated.
In addition, it can be read in two different ways: It can be read to be only the improved portion of that area, or the entire area if any of it is improved. Clarification of this definition is critical to the definition of "Crosswalk," as well as the technical criteria for on-street parking in Section 1109.2 (Exception).
Splitter Island. A flush or raised island that separates entering and exiting traffic in a roundabout.
Street Furniture. Elements in the public right-of-way that are intended for use by pedestrians. This definition might be too broad. There can be many things intended for use by pedestrians that would also be defined as elements, such as pedestrian push buttons and pedestrian overpasses. Yet those are not intended to be covered by the definition of street furniture. It might be best simply to delete the definition.
Superelevation. Cross slope on a curve in the roadway (see cross slope). Delete definition. The term is not used in this document, except in commentary in the definition of the term "Cross Slope." Inclusion of a definition that is not used in the technical requirements is inappropriate.
Walk Interval. That phase of a traffic signal cycle during which the pedestrian is to begin crossing, typically indicated by a WALK message or the walking person symbol and its audible equivalent.
The term "Walk Interval" logically includes the time interval for walking all the way across an intersection, or at least to a refuge island. However, that is not what the definition says. This causes confusion. The definition, coupled with the technical provisions where the term is used, appears to define a specific time to start the walk across the intersection. After that interval it is not safe to start. For the blind this is an important feature of the signal.
Because the term does not indicate the definition, it is confusing. Recommend a new term that is indicative of the definition, such as:
Start Walk Phase: That time interval of a traffic signal cycle . . . etc.
1102 Scoping Requirements
1102.1 General. All areas of newly designed and newly constructed facilities in public rights-of-way and altered portions of existing facilities in public rights-of-way shall comply with Chapter 11. Most newly constructed public rights-of-way are designed and constructed by ADA title III entities, while most alteration projects are conducted by ADA title II entities.
Due to a window between the effective dates for various parts of the original ADAAG through which projects could have avoided ADA compliance, the original ADAAG took the nonsensical position that an addition was some sort of alteration. This window has long since closed, so there is no good reason to continue with that approach.
Additions should be treated as new construction. An addition should not be treated as an alteration, like the approach taken by the current ADAAG 4.1.5.
The form of the charging statements is not consistent with the remainder of ADAAG.
Replace 1102.1 through 1102.2.2 with:
1102.1 General. Rights-of-way shall comply with Chapter 11.
1102.2 Existing Public Rights-of-Way. Additions to existing public rights-of-way shall comply with 1102.2.1. Alterations to existing public rights-of-way shall comply with 1102.2.2. See Comment to 1102.1.
1102.2.1 Additions. Each addition to an existing public right-of-way shall comply with the applicable provisions of Chapter 11. Where the addition connects with existing construction, the connection shall comply with 1102.2.2. See Comment to 1102.1. The only valid piece in this section is the guidance given on how to deal with the interface of new additions to the existing construction.
1102.2.2 Alterations. Where existing elements or spaces in the public right-of-way are altered, each altered element or space shall comply with the applicable provisions of Chapter 11. See Comment to 1102.1.
EXCEPTION: In alterations, where compliance with applicable provisions is technically infeasible, the alteration shall comply to the maximum extent feasible. Delete because the general text at ADAAG 202.3 controls this.
1102.2.2.1 Extent of Application. An alteration of an existing element, space, or area of a public right-of-way shall not impose a requirement for accessibility greater than required for new construction. Delete because the general text at ADAAG 202.3.2 controls this.
1102.2.2.2 Prohibited Reduction in Access. An alteration that decreases or has the effect of decreasing the accessibility of a public right-of-way or site arrival points to buildings or facilities adjacent to the altered portion of the public right-of-way, below the requirements for new construction at the time of the alteration is prohibited. Delete because the general text at ADAAG 202.3.1 controls this.
This is particularly confusing and open-ended. In an alteration, if, in order to make a sidewalk accessible, one would decrease the accessibility of the site arrival point, this section would prohibit that.
However, if by making the same site arrival point accessible will make the sidewalk less accessible than the requirements for new construction, this section would prohibit that as well. This leaves the designers in the position of not being able to meet the rule either way. And someone will be required to make a decision about which is the most important piece of the route to be accessible. For example, it might have to be decided whether the cross slope of the sidewalk becomes too steep or the landing at the building door includes a step.
1102.3 Alternate Circulation Path. An alternate circulation path complying with 1111 shall be provided whenever the existing pedestrian access route is blocked by construction, alteration, maintenance, or other temporary conditions. Delete, because it is an operational issue better contained in the regulations issued by DOJ, DOT, DOD, HUD, GSA, and USPS.
1102.4 Sidewalks. Where sidewalks are provided, they shall contain a continuous pedestrian access route complying with 1103. The pedestrian access route shall connect to elements required to comply with Chapter 11.
1102.5 Protruding Objects. Protruding objects on sidewalks and other pedestrian circulation paths shall comply with 1102.5 and shall not reduce the clear width required for pedestrian accessible routes. Delete all of 1102.5 because ADAAG 204 controls this issue.
1102.5.1 Protrusion Limits. Objects with leading edges more than 27 inches
EXCEPTION: Handrails shall be permitted to protrude 4-1/2 inches
1102.5.2 Post-Mounted Objects. Free-standing objects mounted on posts or pylons shall overhang circulation paths 4 inches
EXCEPTION: This requirement shall not apply to sloping portions of handrails serving stairs and ramps. See above
1102.5.3 Reduced Vertical Clearance. Guardrails or other barriers shall be provided where the vertical clearance is less than 80 inches
EXCEPTION: Door closers and door stops shall be permitted to be 78 inches
1102.6 Curb Ramps and Blended Transitions. A curb ramp or blended transition complying with 1104, or a combination of curb ramps and blended transitions, shall connect the pedestrian access routes to each street crossing within the width of each crosswalk.
1102.7 Pedestrian Signs. Signs for pedestrian use shall comply with 1102.7.
1102.7.1 Bus Route Identification. Bus route identification signs shall comply with 703.5.1 through 703.5.4, and 703.5.7 and 703.5.8. In addition, to the maximum extent practicable, bus route identification signs shall comply with 703.5.5. Bus route identification signs located at bus shelters shall provide raised and Braille characters complying with 703.2, and shall have rounded corners. Delete all material covered elsewhere in ADAAG (e.g., signs are now in 810.4 in
EXCEPTIONS 1: Bus schedules, timetables and maps that are posted at the bus stop or bus shelter shall not be required to comply with 1102.7. Delete?see above.
2: Signs shall not be required to comply with 703.2 where audible signs are user- or proximity-actuated or are remotely transmitted to a portable receiver carried by an individual. Move to 810.4 (Draft ADAAG number)
1102.7.2 Informational Signs and Warning Signs. Informational signs and warning signs shall comply with 703.5. Delete
1102.8 Pedestrian Crossings. Where a pedestrian crossing is provided, it shall comply with the applicable provisions of 1105. Where pedestrian signals are provided at a pedestrian crossing, they shall comply with 1106. "Pedestrian crossings" is an undefined term. How can one know if one is provided? Should define the term and include what is being crossed.
1102.9 Street Furniture. Street furniture that is intended for use by pedestrians and installed on or adjacent to a sidewalk shall comply with 309 and 1107. Delete the phrase "that is intended for use by pedestrians," since this text is part of the definition. The phrase "or adjacent" is problematic because the land adjacent may be outside the right-of-way, thus violating the definition and illegally requiring work on property not under the control of the entity responsible for the right-of-way.
1102.10 Stairs. Where provided, stairs shall comply with 504. Stair treads shall have a 2 inch
1102.11 Handrails. Where provided, handrails shall comply with 505.
1102.12 Vertical Access. Where provided elevators shall comply with 407, limited-use/limited-application elevators shall comply with 408, and platform lifts shall comply with 410. Vertical access shall remain unlocked during the operating hours of the facility served. Delete because ADAAG 407 controls this issue. Delete the hours of service material as better suited to the adopting agency's regulation.
1102.13 Bus Stops. Bus boarding and alighting areas shall comply with 810.2. Bus shelters shall comply with 810.3. Delete
1102.14 On-Street Parking. Where on-street parking is provided, at least one accessible on-street parking space shall be located on each block face and shall comply with 1109. There is no substantiation given for a parking space on every block face. The ratio of the number of accessible parking spaces to the overall number of on-street parking spaces in the area varies with the length of the block face and type of parking. There is no credit given to public off-street parking made available, for example, by a city. There is no exception given for blocks that feature nothing but a parking garage containing a number of accessible parking spaces. Many businesses provide parking garages with accessible spaces for their clients. The requirement to provide an accessible parking space on each block face needs further study.
As stated in earlier comments, most streets are developed by Title III entities for residential areas. It does not seem logical to require accessible on-street parking on each block face for these areas as well. The effects of this requirement and the justification for the numbers need further clarification.
1102.15 Passenger Loading Zones. Where passenger loading zones are provided, they shall connect to a pedestrian access route and shall provide a minimum of one passenger loading zone in every continuous 100 linear feet (30 m) of loading zone space, or fraction thereof, complying with 302, 503.2, 503.3, and 503.5. Delete. This is already covered in ADAAG.
1102.16 Call Boxes. Where provided, call boxes shall comply with 1110.
1103 Pedestrian Access Route
1103.1 General. Pedestrian access routes shall connect to elements required to be accessible and shall comply with 1103. This could be confused as scoping and as requiring pedestrian access routes where pedestrian routes are not planned. This needs to be clarified.
1103.2 Components. Pedestrian access routes shall consist of one or more of the following components: walking surfaces, ramps, curb ramps, blended transitions, crosswalks, pedestrian overpasses and underpasses, elevators, and platform lifts. All components of a pedestrian access route shall comply with the applicable portions of this chapter.
1103.3 Clear Width. The minimum clear width of a pedestrian access route shall be 48 inches
1103.4 Cross Slope. The cross slope of the pedestrian access route shall be 1:48
1103.5 Grade. The grade of the pedestrian access route within a sidewalk shall not exceed the grade established for the adjacent roadway. The grade and the running slope are the same. See comments to definition of "Grade."
See General Comment at the beginning of this paper regarding limitations on pedestrian access routes and how they cannot comply with this at curb ramps.
This requirement is an absolute that precludes making the pedestrian access route more accessible by increasing or decreasing the slope. If the roadway is dead level or negative, there is no reason the slope of the pedestrian access route should not exceed the slope of the roadway.
In addition, the approach to a pedestrian underpass could warrant exceeding the adjacent roadway to accomplish the additional height to take the accessible pedestrian route over something.
EXCEPTION: The running slope of a pedestrian access route shall be permitted to be steeper than the grade of the adjacent roadway, provided that the pedestrian access route is less than 1:20
Consider again the place where most new streets are built: the residential development. Again, if there is reason to have the sidewalk any steeper than the roadway, you will end up with ramps and handrails along the street in front of the houses. Or, more likely, you will not have any sidewalks in the development.
1103.6 Surfaces. The surfaces of the pedestrian access route shall comply with 302.
1103.7 Surface Gaps at Rail Crossings. Where the pedestrian access route crosses rail systems at grade, the horizontal gap at the inner edge of each rail shall be constructed to the minimum dimension necessary to allow passage of railroad car wheel flanges and shall not exceed 2-½ inches (64 mm). The term "grade" is used here in a manner different than the definition. See comments to definition of "Grade."
EXCEPTION: On tracks that carry freight, a maximum horizontal gap of 3 inch
1103.7.1 Detectable Warnings. Where rail systems cross pedestrian facilities that are not shared with vehicular ways, a detectable warning shall be provided in compliance with 1108. This could be read to require detectable warnings at pedestrian overpasses and underpasses.
1103.8 Changes in Level. Changes in level shall comply with 303. Changes in level shall be separated horizontally 30 inches
Note also that even unit pavers that are 30 X 30 inches
EXCEPTION: The horizontal separation requirement shall not apply to detectable warnings. Here is a real conflict in thinking. The guideline states that there can be no changes in level, not even a very narrow scored line in the concrete, yet it mandates changes in level at every curb ramp and intersection of a pedestrian access route and rail crossing with the inclusion of detectable warnings.
1103.8.1 Rail Crossings. Where the pedestrian access route crosses rail systems at grade, the surface of the pedestrian access route shall be level and flush with the top of the rail at the outer edge and between the rails. The term "grade" is used here in a manner different from the definition. See comments to definition of "Grade."
1104 Curb Ramps and Blended Transitions
1104.1 General. Curb ramps and blended transitions shall comply with 1104.
1104.2 Types. Perpendicular curb ramps shall comply with 1104.2.1 and 1104.3; parallel curb ramps shall comply with 1104.2.2 and 1104.3; blended transitions shall comply with 1104.2.3 and 1104.3.
1104.2.1 Perpendicular Curb Ramps. Perpendicular curb ramps shall comply with 1104.2.1, and shall have a running slope that cuts through the curb at right angles or meets the gutter grade break at right angles. A grade break occurs when two slopes meet. A running slope doesn't "meet the grade break" but rather meets the gutter. The meeting of the ramp slope and the gutter slope forms the grade break.
Delete "grade break" in the last sentence.
This section is in direct conflict with1104.3 Common Elements, which prohibits grade breaks in gutter areas.
Note also that "Perpendicular Curb Ramp" is not defined except by these technical criteria. There is no obvious difference to distinguish it from a "parallel curb ramp." See comments to Section 1104.2.2 Parallel Curb Ramps.
1104.2.1.1 Running Slope. The running slope shall be 1:48
There should be an exception for running slopes at mid-block crossings in accordance with the exception at 1104.2.1.3.
1104.2.1.2 Cross Slope. The cross slope shall be 1:48
EXCEPTION: This requirement shall not apply to mid-block crossings.
1104.2.1.3 Landing. A landing 48 inches
EXCEPTION: Running and cross slope requirements shall not apply to mid-block crossings. This exception appears to be misplaced. It appears that there should be a separate exception for running and cross slopes beneath their respective sections.
1104.2.1.4 Flares. Flared sides with a slope of 1:10
1104.2.2 Parallel Curb Ramps. Parallel curb ramps shall comply with 1104.2.2, and shall have a running slope that is in-line with the direction of sidewalk travel.
1104.2.2.1 Running Slope. The running slope shall be 1:48
EXCEPTION: A parallel curb ramp shall not be required to exceed 15 feet
1104.2.2.2 Cross Slope. The cross slope shall be 1:48
1104.2.2.3 Landing. A landing 48 inches
EXCEPTION: Running and cross slope requirements shall not apply to mid-block crossings.
1104.2.2.4 Diverging Sidewalks. Where a parallel curb ramp does not occupy the entire width of a sidewalk, drop-offs at diverging segments shall be protected with a barrier.
1104.2.3 Blended Transitions. Blended transitions shall comply with 1104.3, and shall have running and cross slopes of 1:48
1104.3 Common Elements. Curb ramps and blended transitions shall comply with 1104.3.
1104.3.1 Width. The clear width of landings, blended transitions, and curb ramps, excluding flares, shall be 48 inches
1104.3.2 Detectable Warnings. Detectable warning surfaces complying with 1108 shall be provided, where a curb ramp, landing, or blended transition connects to a crosswalk. There has been much testimony and debate regarding the benefits and necessity of detectable warnings. Before there is a requirement for detectable warnings to be provided in so many places, the Board should be certain that it is not creating a less accessible walking surface for anyone. Some people have to drag their feet when they walk, and this document is riddled with requirements prohibiting level changes for people who use wheelchairs. It is counterintuitive that such opposing requirements are both so important, and yet both are required in the same location within the pedestrian access route.
1104.3.3 Surfaces. Surfaces of curb ramps, blended transitions, and landings shall comply with 302. Gratings, access covers, and other appurtenances shall not be located on curb ramps, landings, blended transitions, and gutter areas within the pedestrian access route.
1104.3.4 Grade Breaks. Grade breaks shall not be permitted on curb ramps, blended transitions, landings, and gutter areas within the pedestrian access route. Surface slopes that meet at grade breaks shall be flush. Another misuse of the term "grade break." The first sentence says that grade breaks are not permitted, and then says that surface slopes that meet at grade breaks must be flush. This is either a conflict or, at best, confusing because it can be read to mean that it is the same area. For example, a grade break is not allowed in a gutter area, which can be considered an area with a surface, which would then be allowed, but regulated by the last sentence. If surface slopes are other than the listed areas, then that term should be defined and addressed in a new section. And if the problem with them is vertical changes in level, then that should be addressed in 1104.3.5. Otherwise the idea of "flush" is unclear in this application.
Another conflict is that grade breaks are not allowed on curb ramps. Built-up curb ramps that have flares will by their nature have grade breaks at the sides where the flare meets the running slope of the ramp. The definition of ramp causes the flare to be considered a ramp, where a pedestrian circulation path crosses the curb ramp, as allowed by 1104.2.1.4.
1104.3.5 Changes in Level. Vertical changes in level shall not be permitted on curb ramps, blended transitions, landings, or gutter areas within the pedestrian access route. How is it that curb ramps and blended transitions are not allowed to have even the slightest vertical changes in level, but are required to have detectable warnings, which by definition consist of a bunch of level changes. This is counterintuitive.
1104.3.6 Counter Slopes. The counter slope of the gutter area or street at the foot of a curb ramp or blended transition shall be 1:20
This is a conflict.
1104.3.7 Clear Space. Beyond the curb line, a clear space of 48 inches
A clear space of 48 inches
Also, it is unclear what the "parallel" vehicle travel lane is. Parallel to what?
1105 Pedestrian Crossings "Pedestrian crossings" is an undefined term.
1105.1 General. Pedestrian crossings shall comply with 1105. "Pedestrian crossings" is an undefined term.
1105.2 Crosswalks. Crosswalks shall comply with 1105.2.
1105.2.1 Width. Marked crosswalks shall be 96 inches
1105.2.2 Cross Slope. The cross slope shall be 1:48
The requirement for a crosswalk to have a minimal cross slope will increase the width of every intersection in sloping terrain, because of the need to create this tabletop effect.
EXCEPTION: This requirement shall not apply to mid-block crossings. If it is acceptable to have a cross slope at the mid-block crossing, why not at the intersection? The establishment of crosswalks at mid-block seems to have different requirements because of their effect on vehicular traffic safety. This certainly needs to be a consideration at intersections as well.
1105.2.3 Running Slope. The running slope shall be 1:20
As this tabletop and running slope limitation continues for intersection after intersection up a hill or mountain, it will require that the hill or mountain be removed to a large degree. Otherwise, at some point, the natural slope will depart from the street grade, separating the adjacent sites from the sidewalk/street by a vertical barrier.
1105.3 Pedestrian Signal Phase Timing. All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
What effect will longer crossing times?and the concomitant increases in engine idling time and vehicle trip times?have on clean air requirements?
1105.4 Medians and Pedestrian Refuge Islands. Medians and pedestrian refuge islands in crosswalks shall comply with 1105.4 and shall be cut through level with the street or have curb ramps complying with 1104 and shall contain a pedestrian access route complying with 1103. Where the cut-through connects to the street, edges of the cut-through shall be aligned with the direction of the crosswalk for a length of 24 inches
1105.4.1 Length. Where signal timing is inadequate for full crossing of all traffic lanes or where the crossing is not signalized, cut-through medians and pedestrian refuge islands shall be 72 inches
1105.4.2 Detectable Warnings. Medians and refuge islands shall have detectable warnings complying with 1108. Detectable warnings at cut-through islands shall be separated by a 24 inch
EXCEPTION: Detectable warnings shall not be required on cut-through islands where the crossing is controlled by signals and is timed for full crossing.
1105.5 Pedestrian Overpasses and Underpasses. Pedestrian overpasses and underpasses shall comply with 1105.5.
1105.5.1 Pedestrian Access Route. Pedestrian overpasses and underpasses shall contain a pedestrian access route complying with 1103.
1105.5.2 Running Slope. The running slope shall not exceed 1:20
1105.5.3 Approach. Where the approach exceeds 1:20
1105.5.4 Stairs. Stairs shall comply with 504. For buildings, the only stairs that are required by ADAAG 210 to comply with 504 are those used in the accessible means of egress. If an accessible pedestrian route is provided by ramps or elevators, it does not seem that the stairs in these locations should be required to meet 504.
1105.5.5 Escalators. Escalators shall comply with 810.9.
1105.6 Roundabouts. Where pedestrian crosswalks and pedestrian facilities are provided at roundabouts, they shall comply with 1105.6.
1105.6.1 Separation. Continuous barriers shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited. Where railings are used, they shall have a bottom rail 15 inches
1105.6.2 Signals. A pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the crosswalk, including the splitter island. Signals shall clearly identify which crosswalk segment the signal serves.
1105.7 Turn Lanes at Intersections. Where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island. Crosswalk is a defined term that seems to indicate that there is a crosswalk at every intersection that has a sidewalk on any part of the intersection. That definition does not mention the use by pedestrians. The term "pedestrian crosswalk" is not defined. See earlier comment about the term "pedestrian crossing."
It is unclear whether this is for crossing the slip lane or for crossings that parallel the direction of the slip lane.
1106 Accessible Pedestrian Signal Systems
1106.1 General. Pedestrian signal systems shall comply with 1106.
1106.2 Pedestrian Signal Devices. Each crosswalk with pedestrian signal indication shall have a signal device which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device and shall comply with 1106.3.
1106.2.1 Location. Pedestrian signal devices shall be located 60 inches
The control face must face the intersection, so people standing in front of it will have their backs to the intersection. With the face of the device facing the intersection, it is unclear how it will also be parallel to the direction of the crosswalk it serves.
Ten feet from other signal devices seems like a lot when the right-of-way might not be that wide.
EXCEPTION: The minimum distance from other signal devices shall not apply to signal devices located in medians and islands.
1106.2.2 Reach and Clear Floor or Ground Space. Pedestrian signal devices shall comply with 308. A clear floor or ground space complying with 305 shall be provided at the signal device and shall connect to or overlap the pedestrian access route.
1106.2.3 Audible Walk Indication. The audible indication of the WALK interval shall be by voice or tone.
1106.2.3.1 Tones. Tones shall consist of multiple frequencies with a dominant component at 880 Hz. The duration of the tone shall be 0.15 seconds
1106.2.3.2 Volume. Tone or voice volume measured at 36 inches
1106.3 Pedestrian Pushbuttons. Pedestrian pushbuttons shall comply with 1106.3.
1106.3.1 Operation. Pedestrian pushbuttons shall comply with 309.4.
1106.3.2 Locator Tone. Pedestrian pushbuttons shall incorporate a locator tone at the pushbutton. Locator tone volume measured at 36 inches
1106.3.3 Size and Contrast. Pedestrian pushbuttons shall be a minimum of 2 inches
1106.3.4 Optional Features. An extended button press shall be permitted to activate additional features. Buttons that provide additional features shall be marked with three Braille dots forming an equilateral triangle in the center of the pushbutton.
1106.4 Directional Information and Signs. Pedestrian signal devices shall provide tactile and visual signs on the face of the device or its housing or mounting indicating crosswalk direction and the name of the street containing the crosswalk served by the pedestrian signal.
1106.4.1 Arrow. Signs shall include a tactile arrow aligned parallel to the crosswalk direction. The arrow shall be raised 1/32 inch
1106.4.2 Street Name. Signs shall include street name information aligned parallel to the crosswalk direction and complying with 703.2. With all of the requirements for push buttons, arrows, signs, and street names, as well as distances from other devices, the area at the intersection could become cluttered with items that will possibly block the view of motorists, a safety problem that could jeopardize pedestrians as well as motorists. Consideration should be made for the clutter that might occur.
1106.4.3 Crosswalk Configuration. Where provided, graphic indication of crosswalk configuration shall be tactile and shall comply with 703.5.1.
1107 Street Furniture
1107.1 General. Street furniture shall comply with 1107.
1107.2 Clear Floor or Ground Space. Street furniture shall have clear floor or ground space complying with 305 and shall be connected to the pedestrian access route. The clear floor or ground space shall overlap the pedestrian access route 12 inches
1107.3 Drinking Fountains. Where drinking fountains are provided, they shall comply with 602.
1107.4 Public Telephones. Where public telephones are provided, they shall comply with 1107.4.
1107.4.1 Single Telephone. Where a single public telephone is provided, it shall comply with 704.2 and 704.4
1107.4.2 Multiple Telephones. Where a bank of public telephones is provided, at least one telephone shall comply with 704.2, and at least one additional telephone shall comply with 704.4.
1107.4.3 Volume Controls. All public telephones shall provide volume controls complying with 704.3.
1107.5 Public Toilet Facilities. Permanent or portable public toilet facilities shall comply with 603. At least one fixture of each type provided shall comply with 604 through 610. Operable parts, dispensers, receptacles, or other equipment shall comply with 309.
EXCEPTION: Where multiple single-user toilet facilities are clustered at a single location, at least 5 percent, but no fewer than one single-user toilet at each cluster shall comply with 603 and shall be identified by the International Symbol of Accessibility complying with 703.7.2.1.
1107.6 Tables, Counters, and Benches. Tables, counters, and benches shall comply with 1107.6.
1107.6.1 Tables. Where tables are provided in a single location, at least 5 percent but no fewer than one, shall comply with 902.
1107.6.2 Counters. Where provided, counters shall comply with 904. It is unclear where counters might occur in a public right-of-way. The guidelines should not attempt to address temporary vendor operations, but only the permanent street furniture.
1107.6.3 Benches. Where benches without tables are provided at a single location, at least 50 percent, but no fewer than one, shall comply with 903 and shall have an armrest on at least one end. It is unclear why 50% of the benches should comply with the provisions of 903. Also, there is no reason given in the discussion why an armrest is required on 50% of the benches in the public right-of-way, when these have not been and are not required in ADAAG.
1108 Detectable Warning Surfaces
1108.1 General. Detectable warnings shall consist of a surface of truncated domes aligned in a square grid pattern and shall comply with 1108. Delete because this material is covered elsewhere in ADAAG.
Note also that the requirement that the domes be on a square grid is nearly meaningless. A square grid can be applied over the domes at an angle and they would meet the provision. A square grid can be applied over the domes with only certain domes hitting on the grid and, because the grid is moved over the domes, the other domes meet the grid. Some domes might be aligned by a square grid of one size and the other domes aligned to a different size square grid.
1108.1.1 Dome Size. Truncated domes in a detectable warning surface shall have a base diameter of 0.9 inches
1108.1.2 Dome Spacing. Truncated domes in a detectable warning surface shall have a center-to-center spacing of 1.6 inches
1108.1.3 Contrast. Detectable warning surfaces shall contrast visually with adjacent walking surfaces either light-on-dark, or dark-on-light. Delete because this material is covered elsewhere in ADAAG.
1108.1.4 Size. Detectable warning surfaces shall extend 24 inches
1108.2 Location.
1108.2.1 Curb Ramps and Blended Transitions. The detectable warning surface shall be located so that the edge nearest the curb line is 6 inches
1108.2.2 Rail Crossings. The detectable warning surface shall be located so that the edge nearest the rail crossing is 6 inches
1108.2.3 Platform Edges. Detectable warning surfaces at platform boarding edges shall be 24 inches
1109 On-Street Parking
1109.1 General. Car and van on-street parking spaces shall comply with 1109.
1109.2 Parallel Parking Spaces. An access aisle at least 60 inches
EXCEPTION: An access aisle is not required where the width of the sidewalk between the extension of the normal curb and boundary of the public right-of-way is less than 14 feet
1109.3 Perpendicular or Angled Parking Spaces. Where perpendicular or angled parking is provided, an access aisle 96 inches
1109.4 Curb Ramps or Blended Transition. A curb ramp or blended transition complying with 1104 shall connect the access aisle to the pedestrian access route. This will likely result in a curb ramp cutting into the sidewalk, which will require additional right-of-way space.
1109.5 Obstructions. There shall be no obstructions on the sidewalk adjacent to and for the full length of the space. This does not make sense for perpendicular or angled parking (i.e., the parking space is not parallel to the sidewalk, and the access aisle is connected to the pedestrian access route).
EXCEPTION: This provision shall not apply to parking signs complying with 1109.6 and parking meters complying with 1109.7.2. If the obstructions are a problem for the parallel parked cars, why wouldn't the signs and parking meters be obstructions?
1109.6 Signs. Parking spaces shall be designated as reserved by a sign complying with 502.6. Signs shall be located at the head or foot of the parking space so as not to interfere with the operation of a side lift or a passenger side transfer. Delete "so as not to interfere with the operation of a side lift or a passenger side transfer." This is commentary.
1109.7 Parking Meters. Where parking meters are provided, they shall comply with 1109.7.
1109.7.1 Operable Parts. Operable parts shall comply with 309.
1109.7.2 Location. A parking meter shall be located at the head or foot of the parking space so as not to interfere with the operation of a side lift or a passenger side transfer. Delete "so as not to interfere with the operation of a side lift or a passenger side transfer." This is commentary.
EXCEPTION: Where parking meters are not provided at the space, but payment for parking in the space is included in a centralized collection box or paying station, the space shall be connected to the centralized collection point with a pedestrian access route.
1109.7.3 Displays and Information. Displays and information shall be visible from a point located 40 inches
1110 Call Boxes
1110.1 General. Call boxes shall comply with 1110.
1110.2 Operable Parts. Operable parts shall comply with 308 and 309.4. Where provided, labeling shall comply with 703.2 and 703.3.
EXCEPTION: Mechanically operated systems in which the signal is initiated by a lever pull shall be permitted to have an activating force of 12 lbf
1110.3 Turning Space. A turning space complying with 304 shall be provided at the controls. Most of these devices will be located in remote areas along a highway. An accessible pedestrian route to the device is not likely to be there. Why require a turning space? Why not a simple pull-in and back-out clear floor space?
1110.4 Edge Protection. Edge protection complying with 405.9.2 shall be provided where the area at the call box is adjacent to an abrupt level change. "Adjacent to an abrupt level change" needs to be clarified. An abrupt level change is a compliant ¼-inch vertical change in level. An abrupt change in level can also mean a rock wall in front of the area. An abrupt change in level can also be the curb that is provided for edge protection. If it means a substantial drop off, then say that.
In addition, what is meant by "the area at the call box is adjacent"? This gives no guidance as to what is under consideration. The turning space required at 1110.3 probably is the area of concern.
1110.5 Motor Vehicle Turnouts. Where provided, a motor vehicle turnout shall have a minimum paved area of 16 feet
1110.6 Two-Way Communication. Where provided, two-way voice communication shall comply with 1110.6, 708.2 and 708.3. The only two-way communications systems within right-of-ways appear to be pay phones and duress call boxes. Does this mean that every pay phone in the right-of-way must have a TTY? Most duress call boxes do not support free-form communication for those who hear, so why is a TTY necessary?
1110.6.1 Volume Controls. Volume controls complying with 704.3 shall be provided.
1110.6.2 TTY. A TTY complying with 704.4 shall be provided.
1111 Alternate Circulation Path Please note that circulation paths are not regulated for running or cross slopes, so this section greatly lowers the level of accessibility that must be provided.
1111.1 General. Alternate circulation paths shall comply with 1111.
1111.2 Width. The alternate circulation path shall have a width of 36 inches
1111.3 Location. The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street. Why on the same side of the street? If the disruption that triggered a need for an alternate circulation path is the replacement of the old sidewalk, why force the city to lose a travel lane?
1111.4 Protection. The alternate circulation path shall comply with 307 and shall be protected with a barricade complying with 1111.6 to separate the pedestrian access route and alternate circulation path from any adjacent construction, drop-offs, openings, or other hazards. Delete reference to 307, because all circulation paths are already obliged to follow 307. Delete the phrase "pedestrian access route," because this section concerns alternate circulation paths. Justify the requirement that barricades be provided at drop-offs adjacent to alternate circulation paths when regular circulation paths are not similarly regulated.
Further, as worded this will require barricades along all curbs, thereby forcing parkers to walk in traffic until they reach an intersection before they can join the sidewalk.
1111.5 Signs. Signs complying with 703.5 shall be provided at both the near side and the far side of the intersection preceding a disrupted pedestrian access route. The "near side and the far side of the intersection" is confusing. Where is that? Could it be said as "both sides of the intersection, preceding, and on the same side of the street as a disrupted pedestrian access route"?
1111.6 Barricades. Barricades shall be continuous, stable, and non-flexible and shall consist of a solid wall or fence or a Type II or Type III barricade as specified in MUTCD section 6F-60 with the bottom or lower rail 1-1/2 inches
RE: Detectable warnings or truncated domes
As the Director of Denver's Commission I'm concerned about the impact of re-implementing the requirement for truncated domes at curb ramps. Our experience with this issue 10 years ago was that, in our climate, the domes were: extremely difficult to maintain, damaged easily, difficult to repair, and created an obstacle. We also had difficulty finding an agreeable position among individuals in our disabled community on this issue as well.
With this in mind, we (the Commission and City) set out with a goal to create a curb ramp standard that complied with the requirements of the Americans with Disabilities Act (ADA) and at the same time satisfied the major concerns of our disabled community. After months of development and negotiation we focused on a design that we felt met our goal. Our standard provides tactile warning and direction by the use of grooves. There is also color contrast, proper slope ratios, compliant width, and maintenance is no different than that of a basic sidewalk.
Since the ADA was established this City has worked hard at complying with its guidelines and installing a curb ramp that is functional. Our curb ramps are installed whenever there is new construction, repair to existing pedestrian paths of travel, or requested through our "curb ramp request line". Needless to say, our curb ramp standard is very extensive throughout our city. Individuals look for it, feel for it, and identify with it for an accessible path of travel. Incorporating a new standard would only create confusion.
The City and County of Denver is considered to be one of the most accessible cities in the country. Part of this accolade is due to our extensive and consistent use of our curb ramp standard throughout the City. Our standard has also been duplicated and incorporated in other municipalities as well.
I urge the Access Board to seriously consider the impact of truncated domes at this juncture in time. Years have been spent not only by this City, but others as well; establishing standards and installing curb ramps. We want to continue in the direction that we initiated 10 years ago. We feel our curb ramp standard provides exceptional accessibility and serves the disabled community and others well. Providing a curb ramp that is functional to use and expected.
Thank you,
Ed Neuberg
Director, Denver Commission for People with Disabilities
John Dempsey, October 23, 2002
I support the installation of detectable warnings (truncated domes) at curb ramps and increased access to accessible pedestrian signals. It is my understanding that the current ruling on this only covers new construction and alterations. I feel that although this is an important step in the right direction, it does not address existing curb ramps and signals. Does this mean that any city in the US that had a curb ramp on a busy street is not required to put in the domes because it was a "preexisting curb ramp"? I hope this is not the case. I know that the Access-Board has recommended to the States to put in the Warning Systems regardless, and some states have taken a proactive approach to this, but the majority have not. I currently reside in the state of Alabama and also spend a great deal of time in Mississippi. I contacted the Alabama DOT who was very helpful. They gave good answers to my questions, were knowledgeable about the ruling and seemed to be genuine in their concerns. Mississippi on the other hand was a different story. I talked to a Jimmy Brumfield, he is the Director of Materials Division Miss. DOT. Mr. Brumfield was very defensive and uncooperative, basically telling me that the state had no plans to follow the guidelines and probably wouldn't. I guess he is a great example of why Mississippi is consistently rated the worst state in the US in almost every category. Mr. Windley you have your work cut out for you if you have to deal with people like him. I just hope to G-D that no one gets killed in Jackson, MS because of their backward mentality. The bottom line is if preexisting ramps are not retrofitted with the detectable warnings then why do it at all. Thanks and good luck.
John Dempsey
Michael Mankin, October 28, 2002
Michael Mankin, Chief
Office of Universal Design
State of California
Division of the State Architect
COMMENTS OF THE CALIFORNIA DIVISION OF THE STATE ARCHITECT
REGARDING DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY
The California Division of the State Architect (DSA) is pleased to submit the following comments on the Draft Guidelines for Accessible Public Rights-Of-Way, which were issued on June 17, 2002.
Additions and Alterations 1102.2
The scoping of this section is unclear and leaves a high degree of digression as to the level of accessibility provided by the covered entity. The preamble to the guideline states:
"For less extensive projects, limited improvements to accessibility would generally be expected. For example, if an existing portion of sidewalk along a block face were rebuilt or replaced, at a minimum the new portion of sidewalk would be subject to specifications for sidewalks, including those for curb ramps and surfacing, among other things. However, compliance with these guidelines would not extend to untouched sections of sidewalk outside the planned alterations."
In California, we require that the area of alteration be made accessible, and a path of travel to the altered area. The "path of travel" provisions in Title III of the ADA were modeled after the scoping provisions of the California Building Code. We suggest greater specificity in this regard, and request justification for the lack of clarity. In all cases, the area of alteration should be made accessible, with the path of travel subject to the 20% disproportionate cost criteria established by the Department of Justice.
Minimum Clear Width 1103.3
We support 48" as the minimum width dimension for a pedestrian access route. California has used 48" as a standard since 1982. This dimension however will not allow for the passing of two wheelchairs. We recommend that pullouts be included every 400 feet
Walks with continuous gradients.
All walks with continuous gradients shall have level areas at least 5 feet
Alternate Circulation Path 1102.3, 1111
We support the requirement for alternate circulation paths when pedestrian routes are temporarily blocked due to construction, alteration, maintenance, etc. A note should be added to clarify that this section also applies when doing accessibility-related projects. For example, jurisdictions replacing curb ramps as part of a resurfacing project, or as part of implementing an ADA transition plan should provide temporary ramps in order to assure access to the public right of way. In California, we require a minimum clear width of 48" (rather than the 36" recommended in the guidelines), for alternate circulation paths. We believe the additional 12" is necessary to provide an accessible environment. This has been required for the past 22 years without any difficulty based on space constraints. Therefore we are recommending that the Board require a clear width of 48" consistent with the minimum clear width for a pedestrian access route.
Barricades 1111.6
We support the requirement to install rigid construction barricades. Many jurisdictions, such as the City and County of San Francisco have developed independent policies that require barricades. The San Francisco program has been highly successful and has created a safer environment for all pedestrians.
Surfaces 1103.6
We are disappointed that the proposed requirement for a "vibration free zone" has not been included in the draft guidelines. We have observed a number of instances where the choice of surfacing materials has rendered the project inaccessible. For example, using cobblestones in historic districts, or to create the illusion of historicity, creates a highly inaccessible environment for wheelchair users. Likewise, wood decking, which is used to construct old western style boardwalks can often cup and separate, rendering the surface inaccessible. We request justification as to why the board would not consider reinstating the "vibration free" provision into the final guidelines.
Surface Gaps at Railroad Crossings 1103.7
We do not support allowing a 2-1/2" to 3" gap at railroad crossings, and request justification for such a hazardous condition for wheelchair users and semi-ambulant people who use walkers or crutches. It has been our experience in California that once a regulation passes, industry can usually find a way to meet the standard. For example, California was one of the 1st states to require access to card readers at gas pumps and ATM machines, many years before the ADA. Industry argued that it could not be done; yet when the regulations took effect, compliant designs were developed. We would support some grace period in order to allow technologies for rail crossings to be tested; however to remove the ½" maximum requirement completely is not warranted.
Curb Ramps and Blended Transitions 1102.6, 1104
We support the use of parallel curb ramps whenever possible. For new construction, installing parallel ramps would rarely be a problem. We agree that perpendicular ramps are sometimes necessary for existing conditions. The guidelines should require parallel curb ramps for all new installations and allow perpendicular ramps only for alterations or when installing parallel ramps would be technically infeasible.
Parallel Curb Ramps 1104.2.2
California specifies a parallel ramps with 1:12
Stairs 1102.10.
We support the proposal to require a 2-inch visually contrasting strip along each tread nosing which is very important for persons with visual impairments. Especially in high/low lighting conditions, unmarked stair treads pose a significant danger to persons with low vision. California has required this at exterior and interior stairs since 1982. We have found it to be a highly effective accessibility measure. We agree with the proposed amendment submitted by the California Council of the Blind, as follows:
"Where provided, stairs shall comply with 504. The upper approach as well as all stair treads shall have be clearly marked with a 2-inch (51 mm) wide strip of color contrasting with the tread and riser, dark on light or light on dark, the full width of the front edge of each tread."
Detectable Warnings 1104.3.2
We support the use of detectable warnings on curb ramps and specifically the in-line v. diagonal dome design. California has required detectable warnings since April 1, 1994. California did not remove the requirement from the Building Code when the federal suspension took effect. We require detectable warnings on curb ramps when the slope of the ramp is 1:15
Other Requirements for Curb Ramps and Blended Transitions
Surfaces 1104.3.3
We agree with the requirement to prohibit the placement of gratings, storm drain, utility and sewer access covers and similar fixtures on ramps, landings, etc. for all newly constructed facilities. For existing facilities were alterations are occurring, it can be prohibitively expensive to relocate these elements outside of the ramp area. We have allowed utility covers successfully on ramps, providing the cover material meets the requirements for ground surfaces and poses no hazard. We urge the board to limit this requirement to new construction.
Pedestrian Overpasses and Underpasses
1005.5.3 Approach
We do not agree, and request justification that an elevator should be the only means to accomplish elevation changes greater than 60". In some areas, such as park and recreation areas and other remote or natural settings, an inclined pathway that is more universally usable by bicycles, strollers, etc to accomplish the change in grade. We have some safety concerns with exclusively requiring elevators, particularly in unmonitored areas.
Crosswalks 1105.2.
We agree with the requirement that marked crosswalks have a width of 96 inches
Vertical Access 1102.12.
We agree with the proposal to require that vertical access elevators and lifts remain unlocked. This will insure that access to the disabled is as readily available as it to the general public.
Medians and Pedestrian Refuge Islands 1105.4.
We agree with the proposal to align the edge of the cut through in the direction of the crosswalk for a length of 24" minimum. Edges provide a directional orientation reference point for persons who are blind or visually impaired.
Accessible Pedestrian Signal Systems 1102.8, 1106
We agree that audible signal devices should be provided at all signalized intersections. Many cities in California have used audible pedestrian signals, including Oakland, CA, which has had a program in place since 1984. Audible signals not only assist people with visual impairments, but also are very popular with senior citizens who feel safer crossing intersections equipped with this technology.
Street Furniture 1102.9, 1107
We support the requirements to provide access to street furniture.
Public Toilet Facilities 1107.5
We agree that public toilet facilities should be accessible. We disagree with, and request justification for the 5% cap on the number of accessible units provided. Providing only 5% accessible clustered toilets means that persons with disabilities who use mobility devices must wait much longer for the use of the few accessible portable toilets while the general public has many more options. For the past 32 years, California has required that all newly constructed restroom facilities be accessible.
Detectable Warning Surfaces 1108
We support the proposed guidelines for detectable warnings with the modifications discussed previously under curb ramps.
On Street Parking 1109
We support the proposal to provide on-street accessible parking.
Call Boxes 1110.6.2
We strongly support the use of TTY's on emergency call boxes. It is critical for all people to have the ability to convey the nature of the emergency and to receive specific instructions from the dispatcher. Emergency telephones with integrated TTY's are commercially available and in use in many locations today.
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.
Brant Williams, P.E., October 28, 2002
Comments of the Draft Guidelines
Portland Office of Transportation
Brant Williams, P.E.
Director
1101 Application and Administration
1102 Scoping Requirements
1102.1 General. All areas of newly designed and newly constructed facilities in public rights-of-way and altered portions of existing facilities in public rights-of-way shall comply with Chapter 11.
1102.2 Existing Public Rights-of-Way. Additions to existing public rights-of-way shall comply with 1102.2.1. Alterations to existing public rights-of-way shall comply with 1102.2.2.
1102.2.1 Additions. Each addition to an existing public right-of-way shall comply with the applicable provisions of Chapter 11. Where the addition connects with existing construction, the connection shall comply with 1102.2.2.
PDOT COMMENT: Recommend that this term be deleted because it does not add any clarity to the draft regulation. Keep just two terms in this section: NEW CONSTRUCTION and ALTERATIONS.
1102.2.2 Alterations. Where existing elements or spaces in the public right-of-way are altered, each altered element or space shall comply with the applicable provisions of Chapter 11.
EXCEPTION: In alterations, where compliance with applicable provisions is technically infeasible, the alteration shall comply to the maximum extent feasible.
PDOT COMMENT: Both "technically infeasible" and "maximum extent feasible" need to be clearly stated in 1101.3 Defined Terms.
1102.5 Protruding Objects. Protruding objects on sidewalks and other pedestrian circulation paths shall comply with 1102.5 and shall not reduce the clear width required for pedestrian accessible routes.
PDOT COMMENT: The end phrase of the above sentence should be corrected to read " ... pedestrian access routes."
1102.5.2 Post-Mounted Objects. Free-standing objects mounted on posts or pylons shall overhang circulation paths 4 inches
PDOT COMMENTS: The proposed standard for a 4 inch
The second sentence is not clear in its application. We assume that the Board means that where signs have multiple posts or pylons that are spaced more that 12 inches
Some agencies utilize a vertical sign structure consisting of vertical, horizontal, and diagonal elements that are attached together to form a truss or frame. Signs can be mounted from the walking surface to the top of the structure. If this vertical sign structure is detectable, it should not be a problem for blind travelers.
EXCEPTION: This requirement shall not apply to sloping portions of handrails serving stairs and ramps.
1102.14 On-Street Parking. Where on-street parking is provided, at least one accessible on-street parking space shall be located on each block face and shall comply with 1109.
PDOT COMMENTS: This requirement means that at least one accessible on-street parking space be provided on every single newly constructed block face. This requirement is problematic for several reasons. First, using the measurement of "block face" as its basis will result in an inconsistent application of this requirement. The City of Portland typical block face is 200 feet
Secondly, given the small block sizes in Portland, the number of accessible parking spaces compared to the total number of spaces on the block face is excessive. Best case scenario in our downtown, we can provide 9 on-street parking spaces per block face. However, on average, this number is significantly less due to driveways, loading zones, curb extensions at corners, etc. The average is more likely to be around 6 spaces per block. Providing one accessible space for every 6 on-street spaces is again excessive. We would recommend that this rule be consistent with the requirements for private parking areas; i.e. a similar proportion of accessible on-street spaces to the total number of on-street spaces for both off-street and on-street parking areas.
Thirdly, as it reads, this rule includes all residential streets as well as other classifications of streets. This appears to be an oversight in writing the draft guidelines.
And lastly, the original Section 14 and the recommendations of PROWAAC limit this requirement to central business districts of cities. We recommend that this requirement be revised to include the provisions identified both in Section 14 and the PROWAAC report.
1103 Pedestrian Access Route
1103.8 Changes in Level. Changes in level shall comply with 303. Changes in level shall be separated horizontally 30 inches
PDOT COMMENT: This proposed standard needs to be more clearly defined in its application. Consider changing the term "changes in slope" because all surfaces in the public right-of-way are actually built on sloping surfaces. Very rarely in the outdoor environment would one encounter a truly "level" situation.
We assume that the Board is attempting to regulate the frequency of slope changes or "grade breaks" ( a more common term ) in the longitudinal Pedestrian Access Route.
EXCEPTION: The horizontal separation requirement shall not apply to detectable warnings.
1104 Curb Ramps and Blended Transitions
1104.1 General. Curb ramps and blended transitions shall comply with 1104.
1104.2 Types. Perpendicular curb ramps shall comply with 1104.2.1 and 1104.3; parallel curb ramps shall comply with 1104.2.2 and 1104.3; blended transitions shall comply with 1104.2.3 and 1104.3.
1104.2.1 Perpendicular Curb Ramps. Perpendicular curb ramps shall comply with 1104.2.1, and shall have a running slope that cuts through the curb at right angles or meets the gutter grade break at right angles.
PDOT COMMENTS: PROWAAC spend countless hours with the issue of directionality and it was discussed in 2 pages of the report to the Board. It was not fully resolved because the needs of the wheelchair users and blind travelers were at odds. The question that could not be resolved was as follows:
1. Should a perpendicular ramp be aligned with the direction of travel and benefit the blind and sighted travelers and create a potential problem for wheelchair users. OR
2. Should a perpendicular ramp be aligned at a right angle to the radius of a corner to the benefit of wheelchair users and lose a directionality for blind travelers.
There are many arguments for both cases depending upon which group is being viewed as receiving preferential treatment. The draft regulation gives preference to wheelchair users and has the following undesirable impacts:
. Ramp alignment at a right angle to the radius forces the ramp to be skewed from the direction of travel
. Blind travelers lose directionality that could have been provided if the ramp were aligned in the true direction of travel. [ We continuously receive comments from members of our blind community that ramps should be build to align with the straight direction of travel. ]
. Sighted travelers lose the benefit of the ramp and will encounter a portion of the curb on the ramp flare if they chose to travel in a straight line. This creates a tripping hazard for both sighted and low vision pedestrians.
. Ramp alignment on the radius creates a very complicated design and an extreme construction challenge and contributes significantly to the design and construction cost of each ramp.
. Ramp alignment on the radius calls for shifting the ramp a few feet left or right of the true direction of travel. This realignment does not improve cross-slope and warping problems. Most ramps will have some warping between the level landing and the street gutter because the outdoor environment is rarely level.
. Ramp alignment on the radius has a poor architectural appearance and violates "form" without contributing to improved "function."
. Wheelchair users need to take an out of direction travel path upon leaving the landing to proceed down the ramp and enter the crosswalk. They then need to make another direction change to align with the crosswalk direction of travel. This path of travel resembles an "S."
. Persons with limited mobility skills that tend to shuffle as they travel, will need to follow an "S" path of travel to utilize the benefit of a curb ramp and avoid the vertical rise of the curb in the flare section of a ramp when it is aligned on the axis of the radius
We feel that the Access Board should abandon the right angle with radius alignment requirement or better yet, support the ramps being aligned with the direction of travel. The very worst thing that could happen is that wheelchair users would make the smaller "S" path of travel as they proceeded down the ramp to allow the wheelchair to align the front caster wheels at a right angle with the street gutter. All other users, blind, low vision, persons with limited mobility skills, and sighted pedestrian would benefit from the ramp being aligned with the direction of travel.
1104.2.1.4 Flares. Flared sides with a slope of 1:10
PDOT COMMENT: The term slope is erroneous because in infers that one of the components is dead level. This does not happen in the public right-of-way because unlike the building environment where dead level is common, it rarely happens in the street area. PROWAAC discussed this issue extensively and came to the conclusion that the curbed portion of the flare needed to transition from the curb ramp base [ zero curb exposure ] to the top of the full curb [typically 6 inch
This provision can be rewritten as follows: "Curb ramp flares adjacent to curb ramps that are provided where a circulation path crosses the curb ramp, shall have the curb exposure, as measured along the gutterline, rise from zero-exposure at the ramp to full curb exposure on a ratio of 1 foot
1104.2.2 Parallel Curb Ramps. Parallel curb ramps shall comply with 1104.2.2, and shall have a running slope that is in-line with the direction of sidewalk travel.
1104.2.2.4 Diverging Sidewalks. Where a parallel curb ramp does not occupy the entire width of a sidewalk, drop-offs at diverging segments shall be protected with a barrier.
PDOT COMMENT: It would be far better to not allow this type of curb ramp design at intersections rather than require a continuous barrier. Since "barrier" is not defined, we will assume that it means a fence, handrail, roadway guardrail, raised landscape planter, or any other type of acceptable barrier. A schematic drawing would be helpful to understand this parallel ramp concept.
At a typical corner where a parallel ramp is used, this regulation would essentially divide the pedestrian area in half running parallel to the curb as it curves around a corner. Persons wanting to cross at the intersection must make a decision on the approach to the corner to chose the "low road" to the ramp or the "high road" to stay on the sidewalk and avoid the crossing. Those persons choosing to cross at the intersection must utilize the parallel curb ramp to reach the crosswalk. This means that all "crossers", disabled or not, will need to descend the ramp to the crosswalk.
The divided sidewalk will certainly cause problems for blind travelers because if they miss the parallel ramp, they could not reach the crosswalk because of the barrier. Likewise, if the blind traveler did not want to cross the street, the barrier could divert them down to street level at the crosswalk where they did not want to go.
This design is also unsafe in that it removes any means of escape for pedestrians in the event a vehicle cuts too close to the ramp. Without the barrier, pedestrians that recognize the danger of an approaching errant vehicle could move to the back of the sidewalk to avoid being injured. With the barrier, the pedestrian could not move out of harm's way. In fact, they would be trapped between the oncoming errant vehicle and the barrier.
In tangent areas, where isolated parallel ramps are the best design solution, such as access to an on-street disabled parking space from sidewalk level, it could be beneficial to utilize a barrier. There certainly other examples where a barrier would be helpful. However, the Access Board must answer the question: What persons are you attempting to protect? Blind persons using long canes will likely find the ramp and the adjacent curb and not be in danger. Sighted persons, including mobility device users, will see the ramp and the adjacent sidewalk. So who really needs the barrier? The fall into the parallel curb ramp would be the same as a fall from the curb at sidewalk level to the adjacent street level. But the Board is not recommending barriers between sidewalk level and street level.
1104.2.3 Blended Transitions. Blended transitions shall comply with 1104.3, and shall have running and cross slopes of 1:48
PDOT COMMENT: As we understand a blended transition, it is simply a large landing that runs parallel to the curb radius. This landing more resembles the landing used on a parallel curb ramp, only that is probably larger and is not necessarily served by a parallel ramp. It more typically models the street surface extended into the corner pedestrian area with a drainage slope pitched to the street.
Because of the running and cross slope limitations, this blended transitions could only fit if the street gutter grade were 2% or flatter. Further, because of drainage issues, this type of landing would rarely be used. This blended transition would afford little protection to pedestrians because it is level with the roadway and excludes barrier curbs.
We question why the Board would offer this as an accessibility improvement when it has so many limiting and detrimental characteristics.
1104.3 Common Elements. Curb ramps and blended transitions shall comply with 1104.3.
1104.3.4 Grade Breaks. Grade breaks shall not be permitted on curb ramps, blended transitions, landings, and gutter areas within the pedestrian access route. Surface slopes that meet at grade breaks shall be flush.
PDOT COMMENT: The PROWAAC report specifically recommended that where a curb ramp meets the street surface at the gutter, the two sloping surfaces must be flush so that there is not a vertical "lip" on the curb ramp. This may be implied in either 1104.3.4 or in 1104.3.5, but it is not clearly stated.
1104.3.7 Clear Space. Beyond the curb line, a clear space of 48 inches
PDOT COMMENT: We understand that this requirement will provide a 4' X 4' refuge area on the street pavement beyond the curb ramp where a pedestrian would not be struck by parallel traveling vehicles and bicycles. However, geometrically, this will not always work. Take the case of a small corner radius of 10' and a sidewalk built adjacent to the curb. A parallel ramp design is the only possible alternative. The bottom landing of the curb ramp is centered on the diagonal of the radius. It is then mathematically impossible to create the refuge area on the pavement and be wholly outside the parallel vehicle travel lane.
Since a parallel curb ramp already has a level landing / refuge within the sidewalk and adjacent to the street, we suggest that the clear space requirement be removed for all parallel curb ramps. If this condition is not removed, the Board will have automatically excluded parallel curb ramps at corners with a radius of less than 15'.
1105 Pedestrian Crossings
1105.1 General. Pedestrian crossings shall comply with 1105.
1105.2 Crosswalks. Crosswalks shall comply with 1105.2.
1105.2.1 Width. Marked crosswalks shall be 96 inches
1105.2.2 Cross Slope. The cross slope shall be 1:48
PDOT COMMENTS: This one sentence provision potentially has more impact that any other part of Chapter 11. Without directly stating it, this regulation will require that all future intersections be essentially flat. Construction of flat intersections and steep intersection approaches and departures are technically infeasible, extremely expensive, environmentally unsound, and are in conflict with safe roadway design.
The outdoor environment, all formed at the whim of Mother Nature, cannot be made to conform to the indoor environment that man builds. In Portland, as well as many other cities across this nation, we build streets with centerline grades that range from 0.5% to as much as 22%. We do this to make the developable land with the confines of our urban growth boundary available for its highest and best use. The Tualatin Mountains, within our city limits, rises more than 1000 feet
Even if the excessive cost factors were ignored and construction to meet these standards were attempted, the environmental damage would be staggering. To create a tabled or flat intersection in hilly terrain, calls for major excavations into uphill slopes and massive fill sections on downhill slopes. The combined work for a single intersection could involve the clear cutting of all vegetation and earth disturbances on at least 2 acres [ 87,120 square feet ] of land to create one intersection. The resultant "flat intersection" would have street slopes far steeper that if the roadway were build to conform to the natural grade of the existing terrain. Disabled persons could certainly be able to use the intersection but would not be able to get to the intersection or leave it because the roadway / sidewalk slopes would be too steep.
Flat intersection design requires the use of long vertical curves to smooth out longitudinal grade breaks. These curves are a function of the roadway speed, safe stopping sight distance, and roadway running slopes. The length of smoothing out one intersection will exceed the distance to the next intersection. This means that the next intersection must be moved farther away to make the running grades work with the flat intersections. In some cases, this flat intersection requirement has the effect of eliminating subdivisions on steep terrain because the land area cannot be reformed to fit the platting of lots and blocks because "accessible" intersections cannot be designed.
Roadway designers must take into consideration multiple variables that affect the safe usability of the facilities. These variables include, but are not limited to: horizontal alignment, vertical alignment, safe stopping sight distance, existing terrain, environment, design speeds, maximum grades, critical length of grades, and many others. Roadway alignments with numerous breaks because of successive intersections is poor design. Although it may be beneficial to reduce grades at intersections, attempting to make them "flat", is flawed design. The Green Book points out that "? the gradeline of the major highway should be carried through the intersection, and that of the crossroad should be adjusted to it. This design requires transition of the crown of the minor highway to an inclined cross section at its junction with the major highway." In other words, even on local streets, one street follows the natural gradeline downhill, and intersecting streets are warped to fit.
EXCEPTION: This requirement shall not apply to mid-block crossings.
1105.3 Pedestrian Signal Phase Timing. All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
PDOT Comment: This requirement could have severe consequences regarding the timing of signals, vehicular delays, overall congestion, and pollution levels.
In Portland, an intersection that is 60 ft
Complaints regarding traffic congestion are common in urban areas such as Portland. The reduction in the pedestrian crossing rate used to calculate the timing of traffic signals would undoubtedly result in increased congestion, and longer delays.
A couple of other unintended consequences of the slower crossing speed could include shorter "Walk" intervals (the "Walk" phase being shortened to help absorb the longer "Flashing Don't Walk phase), and pedestrian pushbuttons where none currently exist (to avoid serving the ped phase when no pedestrians are present). Pedestrians who push the pedestrian button and then proceed to cross the street when an adequate gap occurs are often long gone by the time the pedestrian phase is served. Providing shorter walk times at locations where pedestrians may be tempted to cross against the signal indication can help to reduce unnecessary delay to motorists.
We often hear complaints that the pedestrian crossing time is too short from pedestrians who do not understand the meaning of the pedestrian signal indications. Most pedestrians are more comfortable with the pedestrian signal timing after they are educated on the meaning of the signal indications. Most complaints are regarding the short "Walk" phases. Few people complain about the "Flashing Don't Walk" clearance intervals.
One other consequence of lengthened flashing don't walk intervals will be increased non-compliance by the majority of pedestrians. Today we already have a severe problem with pedestrians disregarding the pedestrian signals. Using the 3 fps rate for the flashing don't walk lengths will generate crossing intervals that can be easily met by over 95% of the population. Users will see this exceeding long length as unnecessary and pay even less attention to pedestrian signals.
It is our recommendation that the policy be modified to allow agencies to implement pedestrian crossing times based off of local knowledge using crossing speeds ranging from 3.0 fps for a disabled person to 4.0 fps for an average pedestrian. The City of Portland has already made accommodations for slower than average and disabled pedestrians at several signalized intersections, and would prefer to work directly with these groups to identify problem locations where pedestrian needs could be better met. This would allow us to balance the needs of ALL users of the ROW to maximize the safety and efficiency of the signal for all users.
1105.4 Medians and Pedestrian Refuge Islands. Medians and pedestrian refuge islands in crosswalks shall comply with 1105.4 and shall be cut through level with the street or have curb ramps complying with 1104 and shall contain a pedestrian access route complying with 1103. Where the cut-through connects to the street, edges of the cut-through shall be aligned with the direction of the crosswalk for a length of 24 inches
1105.4.1 Length. Where signal timing is inadequate for full crossing of all traffic lanes or where the crossing is not signalized, cut-through medians and pedestrian refuge islands shall be 72 inches
PDOT COMMENT: The meaning of this regulation is not clear and should be revised to say: "Where pedestrians are expected to wait because signal timing is inadequate for full crossing of the traffic lanes or where the crossing is not signalized and a pedestrian must wait for gaps in the vehicle traffic flow, a refuge area, 72 inches
1105.5 Pedestrian Overpasses and Underpasses. Pedestrian overpasses and underpasses shall comply with 1105.5.
PDOT COMMENT: This condition is not entirely clear to most readers. There are a number of situations that need to be evaluated before specific regulations can be set. Otherwise, the Access Board is attempting to force fit one solution to fit all situations. A sampling of common overpass / underpass situations is as follows:
. At-grade intersections where pedestrians are routed over a bridge structure. These are built in to provide pedestrian only access over a busy arterial street. A good example is the intersection of the Las Vegas Boulevard [ the Strip ] and Tropicana Boulevard in Las Vegas, NV. Four separate bridge structures exist to safely route pedestrians between the various casinos at this very busy street intersection. All have escalators and elevators.
. At-grade intersections where pedestrians are routed under the roadway through an underpass or tunnel. Portland used to have several of these pedestrian only tunnels beneath busy arterial streets. However, most have been closed because pedestrians felt unsafe using these isolated facilities.
. Grade separated intersections where one street is on a bridge structure and the other roadway or pedestrian route is below the bridge. In some situations, pedestrian connections are made using pedestrian stairways between the two levels. An example of this type of route exists in downtown San Antonio, TX along the "Riverwalk" where the San Antonio River frontage includes a pedestrian route.
. Grade separated intersections where one street is in a tunnel beneath the surface street. Again, in some situations where both streets have pedestrian sidewalks, the two levels may be connected with pedestrian stairways.
. Pedestrian only connections using stairways between roadways at different levels. These usually occur in areas with steep terrain. These stairways usually create a non-accessible "shortcut" to avoid a longer, more circuitous route on surface sidewalks.
. Pedestrian only connections that are made beneath or over multiple roadway bridge structures. These more resemble "catwalk" type bridges connected under or over larger bridges. These occasionally occur where a pedestrian route crosses a complex freeway interchange that includes multiple roadway bridges at different levels.
. Pedestrian only bridge structures over water, canyons, railroad facilities, and other obstacles.
. There are other possible combinations of roadways and pedestrian routes not discussed.
The Board needs to clearly define the conditions where elevators and escalators are needed. Consideration must be given to the purpose of the pedestrian route and a variety of other factors. Clearly, the pedestrian bridges in Las Vegas that carry thousands of daily pedestrian trips that avoid conflict with traffic volumes exceeding 50,000 cars per day should have both escalators and elevators. However, pedestrian stairways between streets in steep terrain, that carry less that 25 pedestrian trips per day, should not warrant the need for an elevator.
1105.5.3 Approach. Where the approach exceeds 1:20
PDOT COMMENT: This is a very broadly written requirement that requires the installation of elevators if the ramps at overpasses or underpasses exceed 60 inch
It appears that the Access Board is setting a requirement for the public right-of-way that does not exist for buildings. Elevators are being required in the outdoor environment when they are NOT REQUIRED in the indoor environment.
Elevators in buildings are the obvious mode of choice because they are build in a space that is typically secure and environmentally controlled. Elevators are the most cost efficient means to move persons between different levels. The benefit of an elevator in an interior space typically outweighs the cost of construction and maintenance. However, this is not the case for elevators in an outdoor environment.
Elevators in the public right-of-way are subject to multiple adverse conditions. These adverse conditions can easily affect the working parts of this type of machine and cause them to fail. Excessive heat or cold can damage or destroy hydraulic systems. Precipitation, in the form of rain, ice, or snow can stop moving parts with rust or ice seizure. Dust and debris in the outdoor environment can also stop moving parts from moving. Exterior elevators cannot always be secured and are subject to damage by vandalism, which in turn causes failures.
Interior elevators simple attach to the interior structure of the building. Exterior elevators are considerably more expensive because they need their own exterior structural support system.
We request that the Board reconsider this proposed requirement. The public right-of-way is not a square or rectangular space that is confined by exterior building walls. It is a longitudinal or linear space that affords public agencies the ability to make accessible connections using sidewalks and ramps. Public works agencies should be given the option to choose different options that provide accessible connections. Ramps and sidewalks could be used where space is available. Elevators and escalators could be used where space is severely constrained.
1105.6 Roundabouts. Where pedestrian crosswalks and pedestrian facilities are provided at roundabouts, they shall comply with 1105.6.
1105.6.1 Separation. Continuous barriers shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited. Where railings are used, they shall have a bottom rail 15 inches
PDOT COMMENTS: Continuous barriers need to be defined here or in section 1101.3 Defined Terms. Continuous barriers should include, and not be limited to: landscape buffers that do not contain a walkable surface as defined by 302.1, fences, pedestrian railings, and vehicular guardrails.
No guidance is provided regarding the boundary for where a roundabout intersection begins or ends and thus a barrier begins or ends. The nature of a roundabout intersection is similar to a curved section of roadway or a mid-block crossing. The requirement of a street-side barrier at a roundabout intersection to separate vision impaired pedestrians from the roadway seems arbitrary. The logical extension of such need for barrier would be to install barriers at the edge of every sidewalk which is adjacent to a street. No substantive argument or evidence has been provided that distinguishes a modern roundabout pedestrian crossing as inherently less safe than any other mid-block crossing design or intersection treatment, and thus warranting such barrier. Location of the pedestrian crossing can be accomplished with a depressed landing adjacent to the ramp that directs pedestrians into the marked crossing.
1105.6.2 Signals. A pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the crosswalk, including the splitter island. Signals shall clearly identify which crosswalk segment the signal serves.
PDOT COMMENT: The guideline appears to apply to all sizes and types of roundabouts with pedestrian facilities regardless of the level of auto or pedestrian traffic use. As roundabouts have so many different applications, with a similar variety of pedestrian environments, a single protocol without regard to traffic volume or the number of entry or exit lanes a pedestrian is expected to cross will unduly limit the modern roundabout's application due to the cost of this guideline. This would be unfortunate as modern roundabouts have a clear record of reducing total crashes and crash severity as compared to standard signalized traffic control. We suggest that the Board conduct additional research into the methods used in Australia and Europe, where modern roundabouts are used at high pedestrian use locations with regular frequency.
The guideline singles out the modern roundabout intersection control geometry without a clear argument or evidence of a safety need. The logical extension of this guideline is the need for pedestrian actuated signals at all intersections, regardless of traffic volume.
Signalizing each approach to a roundabout could also have several negative consequences including increased congestion, queues extending into the roundabout, rear-end accidents, and increased costs. Adding signals to each approach of a roundabout could easily add over $150,000 to the cost of the roundabout installation, not counting added annual maintenance and operation costs.
1105.7 Turn Lanes at Intersections. Where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island.
PDOT COMMENTS: The correct term for "slip lanes", as used by the AASHTO Policy on Geometric Design of Highways and Streets [ the Green Book ], is auxiliary lanes.
For right turn auxiliary lanes, traffic is not always controlled with signals. Below are some of the methods currently used in this application:
. Signal control of through traffic lanes and signal control of the auxiliary right turn lane.
. Signal control of the through lanes and "yield" control of the turn lane.
. Signal control of the through lanes and "stop" control of the turn lane.
. Stop control of the through lanes and "yield" control of the turn lane.
. No control of the through lanes and no control of the turn lane.
. Other combinations are possible.
The proposed regulation requires a pedestrian traffic signal for all situations without considering the variety of variables involved. The Board needs to study this further before setting a requirement that one solution fits all applications.
1106 Accessible Pedestrian Signal Systems
1106.1 General. Pedestrian signal systems shall comply with 1106.
1106.2 Pedestrian Signal Devices. Each crosswalk with pedestrian signal indication shall have a signal device which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device and shall comply with 1106.3.
PDOT COMMENTS: We do not believe that every signalized crosswalk with pedestrian signals needs to have accessible signals as well. In downtown Portland we have numerous small, yet closely spaced signalized intersections. Many of the crossing distances are less than 30 feet
That said, we also agree that many of our signalized intersections do need accessible signals. We just ask that the Board add language to allow exceptions where accessible signals would not be required. Wording for this exception could read something like the following: "An accessible signal may not be required if an engineering study shows that visually impaired pedestrians using skills taught by orientation and mobility specialists can easily use the crosswalk in question. Factors for not needing an accessible signal may include short crossing distances, simple signal phasing, other clear audible queues, and simple intersection geometrics. The engineering study must provide compelling reasons for not installing an accessible pedestrian signal."
1106.4 Directional Information and Signs. Pedestrian signal devices shall provide tactile and visual signs on the face of the device or its housing or mounting indicating crosswalk direction and the name of the street containing the crosswalk served by the pedestrian signal.
1106.4.2 Street Name. Signs shall include street name information aligned parallel to the crosswalk direction and complying with 703.2.
PDOT COMMENT: We strongly object to this requirement in that it is inconsistent with other requirements. Street name signs are not required at any other type of intersection. Use of a traffic signal at certain intersections to give traffic flow specific timed intervals of having the right-of-way is still only a form of traffic control. Stop controlled or yield controlled intersections are not much different, yet tactile signs for pedestrians are not required. If the Board wants to provide guidance information for blind travelers, then all intersections should have tactile signs that identify the street names.
1107 Street Furniture
1108 Detectable Warning Surfaces
PDOT COMMENTS: After spending $20,000 to test products, make over 100 installations, and conduct opinion surveys with more than 40 blind persons, we are not convinced that requiring detectable warnings at all curb ramps is good public policy.
Our findings indicate that blind persons could not depend upon the detectable warnings even if every ramp included them. Blind travelers use so many other cues to travel that detectable warning would only provide minor benefit. Most of the persons that we worked with were reasonably well trained and travel quite well without detectable warnings. The opinions of our blind public pertaining to detectable warnings are not any different than the comments received by the Board in response to the proposed draft guidelines. Many liked them, many did not.
From a cost perspective, installation of detectable warnings will be a very expensive endeavor. We found that it would cost between $25 - $30 per square foot of detectable warning surface. A single ramp installation would be at least $200. A typical intersection with 8 individual ramps will cost $1,600. Portland alone has 15,000 intersections. Over time we will spend $24 million (in equivalent 2002 dollars) to complete all of the detectable warning installations in Portland. The national investment in this effort will certainly exceed $10 Billion.
Based upon the input of our blind citizens, we support the discretionary application of detectable warnings only at certain locations. These locations include:
. On perpendicular curb ramps that have grades (slopes) flatter that 5%
. In advance of all active railroad tracks that cross the pedestrian access route of a sidewalk area
. At all other areas where the pedestrian sidewalk area is not clearly delineated from the roadway by curbs or other channelizing barriers.
We also found that detectable warnings were almost useless on all diagonal curb ramps and most ramps that were not aligned directly in-line with the direction of travel. Our blind traveling public seldom strayed off-course to even find diagonal curb ramps. Other types of ramps with radial alignments were easily found by long cane users as they detecting a curb on the flare of the ramp. None of our blind travelers wanted to waste their time searching for the detectable warning surface in these locations.
The Access Board needs to give greater consideration to this issue. It is very clear that some locations should have detectable warning. Most other locations do not need them. Portland would rather utilize members of our blind community to evaluate all questionable locations and would follow their guidance on whether detectable warnings should be installed or not. We feel that this would be a better alternative that having the nation needlessly spend billions of dollars for detectable warnings that provide no benefit to the users.
1108.2 Location.
1108.2.1 Curb Ramps and Blended Transitions. The detectable warning surface shall be located so that the edge nearest the curb line is 6 inches
PDOT COMMENT: Alignment of the detectable warnings is not discussed. Detectable warnings need have the square grid pattern aligned with the direction of travel.
On ramps that intersect the street surface on a radius, the detectable warning surface should also be correctly aligned for pedestrian travel but should not be required to exactly follow the radius of corner. Companies manufacture detectable warning products to meet the square grid pattern. These products cannot be installed to meet a horizontal curved area. An exception needs to be noted and a graphic provided.
1109 On-Street Parking
1110 Call Boxes
1111 Alternate Circulation Path
1111.1 General. Alternate circulation paths shall comply with 1111.
1111.2 Width. The alternate circulation path shall have a width of 36 inches
1111.3 Location. The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street.
PDOT COMMENTS: It is very shortsighted for the Access Board to decide that one alternative circulation path on the same side of the street will fit all situations. There are a variety of work zones in pedestrian areas that we encounter daily. Most could not accommodate a same side of street alternate circulation path. Sidewalk work zone examples include, but are not limited to:
1. Complete demolition and full reconstruction of roadways including the removal of all existing vehicular travel lanes, bike paths, furnishing zones, and sidewalks. All travelers are detoured to parallel alternate streets.
2. Similar to #1 above, but only half of the street width is being demolished and reconstructed at one time. All travelers are detoured to the opposite side of the street or to parallel streets.
3. Utility connections from the street to a building. This work zone crosses vehicle travel lanes, bike lane, furnishing zone, and sidewalk. The safety of all public users prevents access to the work zone. Users are shifted to the opposite side of the street.
4. Intersection closures for street paving. All users are detoured to parallel open streets.
5. Installation of curb ramps or new sidewalk facilities the prevent the public from using these facilities until the concrete has sufficiently cured.
6. New building construction which utilizes the full sidewalk width and portions of the street area. Pedestrians and vehicles are either moved to the opposite side of the street or detoured to parallel open streets.
We suggest that this condition be amended to read: "1111.3 Location. An alternate circulation path shall be provided to the disrupted pedestrian access route, on the same side of the street, on the opposite side of the street, or on a parallel street with a marked detour route.
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
Brian Black, Eastern Paralyzed Veterans Association, October 28, 2002
Comments of the Eastern Paralyzed Veterans Association
to the
U.S. Architectural and Transportation Barriers Compliance Board
on the Public Rights-of-Way Draft Guidelines
36 CFR Parts 1190 and 1191
[Docket No. 02-1]
RIN 3014-AA26
Submitted by:
Brian Black, Director
Building Codes and Standards
Eastern Paralyzed Veterans Association
Buffalo, New York
IntroductionThe Eastern Paralyzed Veterans Association (EPVA) is a non-profit organization dedicated to serving the needs of veterans with spinal cord injuries or disease who live in New Jersey, New York, Pennsylvania and Connecticut. EPVA has advocated for barrier-free design in our built environment since our founding in 1946.
With regard to the Americans with Disabilities Act Accessibility Guidelines, the Access Board (Board) is familiar with EPVA's commitment to improving the accessibility requirements established under federal law. An EPVA staff member has served as a Board member and was a participant in the Advisory Committee that drafted the report, "Building a True Community" on which these draft guidelines are based. Prior to that, EPVA served on the ADAAG Federal Advisory Committee that developed the draft "New ADAAG" that led to the new guidelines approved by the Board this fall. Additionally, an EPVA staff member serves with the Board representative on the ANSI Accredited Standard Committee A117 and works hand-in-hand with that representative to improve the accessibility requirements of the ICC International Building Code (IBC). With this background and commitment to accessibility, EPVA is pleased and encouraged that the Board has issued Draft Guidelines for Accessible Public Rights-of-Way, extending what is required for buildings and building sites into this area of the built environment.General Comments
The Board is familiar with the concept of "harmonization", in which the Board and its counterparts in the private sector - participants in the A117.1 and IBC development processes - have attempted to minimize the discrepancies between their respective accessibility requirements. Virtually all affected parties agree that standardized accessibility criteria, especially technical criteria, will serve not only persons with disabilities but the designers and owners of properties regulated by these requirements.
Accordingly, the biggest problem EPVA finds with the proposed ADAAG Chapter 11 is ironically that is not harmonized with the technical requirements of the draft ADAAG issued in April of this year. Diagonal curb ramps that are permitted on a building site would be prohibited in the public right-of-way while, conversely, parallel curb ramps on city sidewalks would arguably not be allowed at the local supermarket. Detectable warnings would be required at curb ramps on quiet residential streets, but not in a busy shopping center. ADAAG would specifically require an accessible route from an accessible parking space to a centralized collection box or collection station if the parking were located in the right-of-way, but not if the parking was in a private lot.
Having tried to harmonize the model codes and standards with the moving target of a 1999 ADAAG NPRM and a 2002 "final" ADAAG draft, EPVA understands that coordinating parallel developments of technical and scoping requirements can be difficult at best. We also appreciate that the Board approved the final ADAAG draft a few short weeks ago, and to make substantive changes to that document in an attempt to incorporate new or differing requirements in the proposed Chapter 11 could stall the issuance of the new ADAAG for months, if not years. But "a ramp is a ramp is a ramp", and the requirements for that ramp (and everything else) in the public right-of-way should, if possible, be consistent with what is required or permitted on a private building site.
The Board faces a dilemma that those of us dealing with the model codes and standards (including your staff) have been struggling with during this era of harmonization. On one hand, consistency between the national and federal accessibility requirements - and certainly consistency within ADAAG - is extremely important if the requirements are to be understood, adhered to, and enforced. Conversely, the "science of accessibility" should be permitted to advance, and improving the technical requirements for any given element should not be hindered simply because some earlier document contains provisions that are inconsistent with what we now know to be better for accessibility. (For example, the draft ADAAG provisions for assembly areas improve on the A117.1-1998 requirements, and the draft A117.1-2003 provisions build on the draft ADAAG requirements.) The Board has the responsibility of weighing the benefits of increased access for a particular element in the public right-of-way (such as curb ramps) versus the problems created by having different requirements for the same element, depending on whether that element in on a private building site or public street. Yours is not an enviable task.
EPVA has a number of concerns regarding the technical requirements in the proposed rights-of-way guidelines. We have also attempted to point out where differences between the proposed guidelines and the draft ADAAG may prove problematic.
One final point: The Board has dedicated hundreds of staff hours, joining a few of us in the private sector to try to convince both the A117.1 Committee and the voting membership of the International Code Council that harmonization is the right thing to do.
For EPVA, the harmonization argument has been a very effective way to increase the accessibility requirements in the model codes and standards. Resistance has been strong at times, with those who do not share our goals questioning why the codes and standards should change when the federal government seems unable or unwilling to do the same (given that the long-promised new ADAAG has yet to be finalized). This dynamic should be given considerable weight as the Board decides whether to increase accessibility for public rights-of-ways without making concomitant changes for building sites. "Harmonizing with the ADA" will become a weak argument if the Board cannot either harmonize with itself or provide compelling evidence that 1) similar elements in the public right-of-way are functionally different and should have different requirements, or 2) the chance to advance the "science of accessibility" through this proposal outweighs the problems a resulting conflict may cause.
Section-by-Section Analysis
1101.2 Referenced Standards. In its introductory comments, the Board mentions that the Federal Highway Administration is in the process of updating its Manual on Uniform Traffic Control Devices (MUTCD). The Board should only reference established and published reference standards, and should refer to the 2000 edition if the FHA has not completed this work.
1101.3 Defined Terms.
Sidewalk. This definition does not work. In some communities in the Northeast, residential lot lines extend to the curb line (or even into the center of the street), with easements given to install village sidewalks, utilities, water lines, etc. The portion between the curb line and the adjacent property line may be 0 inches
1102.10 Stairs. The requirement for color-contrasting tread markings has a number of problems. Foremost, this is not a requirement in the draft new ADAAG, and the suggestion that stairs on rights-of-way are different due to variable lighting conditions is not persuasive. Certainly, exterior stairs on building sites or stairs in a dark restaurant are no more discernable than stairs on a public right-of-way.
Maintenance of these markings on stair tread subject to exterior conditions is also problematic. Rain, ice, abrasion from mud and dirt encrusted shoes will subject these stairs to far more wear than that applied to interior exit stairs. Finally, stairs installed in the new construction or alteration of a public right-of-way may be used to replace the old stairs or sloped walk to a single family home. The New York State Department of Transportation requires this when is rebuilds a state roadway in a residential area, and those stairs often extend ten or more feet into a person's property. Under the maintenance of accessible features requirements certain to be imposed by the Department of Justice or Transportation when this section of ADAAG is eventually adopted, who will be responsible for maintaining these tread markings on private property?
1003 Pedestrian Access Route
1103.4 Cross Slope. In many urban and commercial areas in the Northeast, storefronts were built on a zero-lot line abutting the public sidewalk. Most older buildings are not accessible, though many have only a one-riser step to the front entrance. EPVA has been successful in working with many owners of such buildings to make the businesses accessible by asking the municipality to permit the removal of the existing sidewalk in front of the building entrance, then "warping" the sidewalk by pouring new concrete to consume the 4 to 6 inch
Requiring the entire width of a 48 inch
1103.8 Changes in Level. Changes in level that adjoin one another are not prohibited in the draft ADAAG, and in fact are fairly common in the built environment. A marble threshold to a tiled toilet room floor will typically have a ¼ inch vertical edge (to maintain the integrity and durability of the piece), then be beveled the additional 3/8 to 1/2 inch
1104 Curb Ramps and Blended Transitions
There is an internal inconsistency in this section. Section 1104.2.1.3 requires a landing at the top of a perpendicular curb ramp. Section 1104.2.2.3 requires a landing at the bottom of a ramp run. The issue is whether a curb ramp constitutes just the sloped section (suggested by 1104.2.1.3) or the entire system including any landings (suggested by 1104.2.2.3).
1104.3.3 Surfaces. EPVA believes the introduction of gratings, access covers, or other appurtenances into the sloped section of a ramp may make that ramp difficult to negotiate or dangerous to use. We also believe that, in new construction, these elements should not be located in ramp landings. However, in urban areas access covers for utilities or traffic lights are often located precisely where the upper landing of a curb ramp would be, and to prohibit their existence in this space could make the installation of a curb ramp at an inaccessible intersection prohibitive, if not impracticable. Also, this is not considered a problem in the draft ADAAG, and curb ramp designs that are permitted on building site should also be permitted in the right-of-way.
1105.5 Pedestrian Overpasses and Underpasses.
1105.5.3 Approach. This section permits the use of a ramp with a 60 inch
First, we cannot imagine an overpass or underpass where the total vertical rise would be less than 60 inches
The only practical way to provide accessible overpasses and underpasses is with elevators at both ends. We support the Board's decision to permit Limited Use/Limited Application elevators in addition to elevators complying with 407 in
1107 Street Furniture.
1107.5 Public Toilet Facilities. The exception for single-user toilet facilities clustered at a single location should only apply to portable facilities, where the amenities provided by the accessible and inaccessible units are similar. All permanent public toilet facilities should be accessible.
This would not be inconsistent with the cluster allowance found in draft ADAAG because, while single-use toilet facilities found in buildings typically provide the same amenities, this may not be true with street furniture facilities. At one time, a manufacturer in discussions to provide his units in New York City had inaccessible units that were self-cleaning, where the inaccessible units lacked this feature. Moreover, while "cluster" is a somewhat ambiguous term it is generally understood where a doctors' office has a group of single-use rooms or where a line of portable toilet units are put down for a street fair. It may not be so clear with permanent facilities that are "clustered" on a number of scattered blocks in a city -are two units, one on Fifth Avenue and 46
1108 Detectable Warning Surfaces
1108.1 General. The Board's Section-by-Section review indicates that an in-line grid pattern of truncated domes is responsive to the concerns regarding the impact of the domed surface on wheelchair maneuvering. This is not true if the lines are not oriented to the direction of travel, and this section should require that the square grid pattern provide dome lines parallel with the running slope of the ramp.
1108.2.1 Curb Ramps and Blended Transitions. The requirement for locating the detectable warning surface on a curb ramp between 6 and 8 inches
Should the Board decide to include a requirement for detectable warnings at curb ramps in the final guidelines, the 24-inch minimum strip of truncated domes should be located at the top of the ramp run. If this is sufficient to provide warnings at rail crossings and platform boarding edges, it is sufficient to warn someone walking down a city street that the expected curb ramp (and adjacent city street) is a stride or two away.
1109 On-street Parking
1109.3 Perpendicular or Angled Parking Spaces. Where angled parking is provided, the access aisle should be located on the passenger side of the accessible parking space. This is where most persons in wheelchairs transfer to and from automobiles and where lifts are located on vans. Unlike perpendicular parking spaces, angled parking spaces are extremely difficult to back into to be able to use an access aisle to the left of the accessible parking space.