ADAAG Right-of-way Draft

Section 1104.3 Common Elements

Curb ramps and blended transitions shall comply with 1104.3


Related Public Comments: 1 2

  1. Ed Neuberg, October 28, 2002

    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

  2. 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