Curb Ramps and Blended Transitions
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
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
Michael A. Whipple, October 28, 2002
City of Sacarmento, Department of Public Works
To: Access Board
From: Michael A. Whipple, Public Works ADA Coordinator
Re: Public comments for draft Public Rights-of-Way Guidelines
I would like to submit the following comments regarding the Draft Guidelines for Accessible Public Rights-of-Way.
1102.3 Alternate Circulation Path
This would be a very cost prohibiting guideline when imposed as in the draft guidelines. It is not practical and/or cost effective to provide an alternate circulation path as stated in this section and section1111. Our City does provide an alternate circulation path when construction, maintenance or similar situations is going to impede the normal circulation path for any considerable amount of time. On the other hand it will increase the cost of our curb ramp program beyond the $5 million we spend annually now. Our program hardly ever blocks a whole intersection at one time to install a new curb ramp. An individual can cross the street and proceed on their way during the 4 days we are working on the new curb ramp(s). To have a contractor comply with what is being proposed would mean they would have to have many of the types of barricades required and then they would have to have a crew, which was just moving barricades on a daily basis. This also implies that at all locations there is the room to provide this alternate path and then you still have the problem of using some type of portable ramps to get people from the street to the sidewalk or vice versa. This would also impact areas where the sidewalk was not contiguous with the street and a garden/landscaping strip had to be crossed to get back to the sidewalk. This would then also impact the parking along the street as each space next to the corner would have to be blocked off and this would need to be done daily for one to seven blocks. As this picture unfolds it can be seen that many things would be impacted and another alternative for an alternate circulation path would need to be added to the guidelines.
This might be able to be worked out better if Section 1111.3 Location was reworked. A time limit for the amount of days an alternate circulation path would be needed could also solve this problem. This would mean something like if the regular circulation path is not available for 7 or more days and no alternate circulation path within a two block radius is provided then you would use the proposed guidelines. This section will have a large financial impact on doing curb ramps alone and with many cities already not up to speed this really could slow down reconstruction or retrofitting of curb ramps not to mention other areas it will impact that are not seen at this time.
1102.14 On-Street Parking
This guideline will not provide the needed parking for people with disabilities but will increase the placard abuse that is seen around the country and especially here in California. This guideline will also decrease regular on-street parking spaces in areas where a parking garage or lot is near and they (garages and lots) provide a number of disabled parking spaces. This would have an impact on cities in their downtown areas where parking is usually at a premium. Along with this guideline comes the new requirements for a curb ramp when the disabled space is parallel to the curb and the 60-inch access isle. The curb ramp issue can add a large expense to the entities already trying to pay for the curb ramps they are doing on the corners. This scenario could make an entity choose between curb ramps at the corner and whether they are single or dual and the curb ramp at the disabled parking space on that block face. The other area is the access isle and how that will impact the flow of traffic when you have one parking spot along the street, which sticks out five feet more than the rest. Also, what would happen when you have to provide the disabled parking spaces on each side of the street? You could have two scenarios with this street; 1) If both spaces where opposite each other on the street you would in essence create a bottle neck situation where lanes have to narrow to allow for the extra 10 feet
Before moving on to the next comment I would like to make a statement about our Visual Community here in Sacramento. We have a strong, vocal and actively involved visual community representing both sides of the blind philosophies. The Council and the Federation make sure that at any meetings that are held in the Sacramento area they both have representatives there to make sure that their philosophies are heard and taken into consideration. The City of Sacramento takes a stand with these two organizations stating they represent a percentage of the visual community and I take the position that I represent the rest of those people out there who do not belong to one or the other of these groups. So what we try to achieve here is a balance for both sides and use our philosophy of "Trying to achieve the greatest amount of accessibility for the largest amount of people".
1104.3.2 Detectable Warnings
I would like to preface this comment section with the fact that we are in California so we have the requirement to put truncated domes on curb ramps with slopes less than 6.67% (1:15). Within the City of Sacramento we have adopted this as one of our standards for curb ramps. So if the Access Board uses the new revised ADA (when it finally becomes enforceable) and does not require truncated domes we will still be putting them on curb ramps with slopes less than 6.67% (1:15).
I write the above paragraph because we did three days of field study with people representing all major disabilities and it was agreed that the State truncated dome section was a good compromise and pleased the Council, Federation and the folks with mobility types of disabilities. It is felt that it is not cost effective to put truncated domes on all curb ramps in all locations. It is felt that the California requirement is a good compromise and that this standard should be adopted or given strong consideration when this section is completed. Through our work with truncated domes we know that it can cost between $400 and $1000 extra to put the truncated domes on curb ramps. If you take the average cost of these figures, $700, when we do a minimum of 1,500 curb ramps a year we are adding an additional $1 million dollars if we had to do truncated domes on all curb ramps. That might almost be enough to be considered a financial burden on our available dollars.
We also believe the new requirements for the spacing and sizing of truncated domes will have an impact on the entire disabled community. It has taken the Access Board enough years to get people to consider using truncated domes again it is not the time to be changing the spacing requirements. Our visual community does not like the minimum and maximum spacing because you would have all sorts of different truncated domes along a pedestrian access route and it could cause disorientation, sprained ankles or some unknown problem on the truncated dome plates when the larger spacing is used which would have more slippage in the field area because it gets larger. Also when using the larger spacing between domes it does not guarantee people in wheelchairs will be able to line up their wheels because they come in all sizes and shapes so it is not guaranteed that the wheels would roll between the truncated domes. If this requirement was put into the new chapter we might find ourselves back at the drawing board deciding whether truncated domes are safe or not and thus having another suspension.
1105.6 Roundabouts
We do not agree with the pedestrian traffic signals for Roundabouts. This defeats the purpose of the Roundabout and can be more dangerous to the pedestrians. I do not need to go into the studies or statistics as I have seen them quoted plenty of times in comments already received. It is important to note in these statistics that there is more safety with a Roundabout without pedestrian signals than one with. It would be more prudent for the access board to be requiring truncated domes at these locations, crosswalks and midcrossing pedestrian safety areas, despite slopes, than the pedestrian activated signal.
1106 Accessible Pedestrian Signal Systems
There is so much controversy on whether these devices help or hinder that more research needs to be done. We do not agree that all pedestrian signals should have some type of ped-activated signal. This area needs much more study and then put back out with a new set of proposed guidelines for comment. What is listed in this draft is overwhelming and not yet proved as long lasting working devices. I am talking about the audible, vibrotactile or locator tones devices just to mention a few. I don't believe the Access Board wants to get into another situation like the early truncated domes.
1108 Detectable Warning Surfaces
We have already made comment on this area but would just like to reiterate the importance of keeping the current truncated dome requirements for size and spacing. When a manufacturer has the ability to use sizes or spacing from X to Y then there will not be any consistency with the truncated domes being used. This seems like we are taking a step backwards and will just end up having truncated domes go on suspension again until the new spacing can be tested and shown that it is safe. The new sizing and spacing should not be adopted. Let us try to work with the visual community to find a common ground and at least use the requirements for size and spacing we now have.