Truncated domes in a detectable warning surface shall have a center-to-center spacing of 1.6 inches
(41 mm) minimum and 2.4 inches
(61 mm) maximum, and a base-to-base spacing of 0.65 inches
(16 mm) minimum, measured between the most adjacent domes on square grid
Frank Synoground, October 24, 2002
I would like to offer the following comments on the draft regulations and thank the committee for its considerable efforts. I am blind and am particularly interested in tactile warnings.
Detectable Warnings (1104.3.2)
Detectable warnings should only be required where the ramp slope was 1:15
In reference to sections as cited below:
1108.1 General.
Detectable warnings shall consist of a surface of truncated domes aligned in a square grid pattern and shall comply with 1108.
1108.1.1 Dome Size.
Truncated domes in a detectable warning surface shall have a base diameter of 0.9 inches
The above listed specifications would seem to eliminate or at least not acknowledge parallel tactile warnings that would act as wayfinding as well as warning. I am blind and consider wayfinding in some cases an important safety issue as well.
Frank Synoground
Portland, OR
Wilma J. Smith, P.E., October 28, 2002
The City Of Arlington's comments are attached and come from the following:
Michael J. Hasler, PE, Director of Transportation
Wilma J. Smith, PE, Assistant Director of Transportation
David Boski, PE, Transportation Engineering Manager
Sholeh Karimi, PE, Transportation Engineering Manager
Paul Iwuchukwu, PE, Transportation Engineering Manager
Jill House, PE, Interim Assistant Director of Engineering
Lori A. Chapin, PE, Civil Engineer
Rey Gonzales, Traffic Operations Manager
Juanita Bridges, Transit Manager
Mike Blake, Traffic Signal Analyst
Thank you for giving us an opportunity to review the proposed guidelines and provide comments. If you have questions or require additional information, please contact me via email or phone at [...].
Wilma J. Smith, P.E.
Assistant Director of Transportation
City of Arlington
Mike Hasler's Comments
Additions and Alterations (1102.2)
Paragraph 2
Last sentence
Question: What if alteration is only a partial project where it doesn't "connect" to anything else? It doesn't make sense to have it comply when nothing else does on either side.
Minimum Clear Width (1103.3)
Paragraph 1
First sentence and Last two sentences
Comment: Larger than private SW's, widths between handicap spaces and most doorways
Surfaces (1103.6)
Paragraph 1
First sentence
What is the meaning of granite pavers?
Perpendicular Curb Ramps (1104.2.1)
Diagram
What is the minimum width?
Detectable Warnings (1104.3.2)
Paragraph 2
Second sentence
What is 2 feet
Mike Hasler's Comments
Page 2
Crosswalks (1105.2)
Paragraph 2
Last 2 sentences
Comment: No matter the impact on ROW, grades, access to adjacent property, drainage, walls cost, impact on vehicle speeds and occupants.
Pedestrian Signal Phase Timing (1105.3)
Paragraph 1
First sentence
Comment: 32 seconds
Vertical Access (1102.12)
Question: Any safety mechanism designed in case of power outage?
On-Street Parking (1102.14, 1109)
Paragraph 2
Second sentence
Statement can be achieved by indenting the curb line
Comment: But could also cause a grade problem or impediment.
1105.2.2 Cross Slope
Question: Perpendicular to pedestrians which is the direction of vehicle travel 2% slope on roadway?
1105.2.3 Running Slope
Comment: 5% cross slope
Memorandum
TO: Wilma J. Smith, P.E., Assistant Director of Transportation
From: Juanita Bridges, Transit Manager
Date: October 22, 2002
Subject: ADA Public ROW Guidelines Comments
The following are comments that I had regarding the "Draft Guidelines for Accessible Public Rights-of-Way".
Under the Discussion of Provisions section, I had the following comments:
1. General Scoping: New Construction, Alterations, and Additions 1102, there should be a distinction between "minor" and "major" alterations added. There should be an exception made to this provision if the total cost of the accessibility features exceeds the total cost of the alteration project.
2. Accessible Elements and Spaces: Scoping and Technical Requirements, Minimum Clear Width 1103.3, I believe that the minimum clear width should be 36 inches
3. Accessible Elements and Spaces: Scoping and Technical Requirements, Surface Gaps at Rail Crossings 1103.7, the guideline does not clarify if the local authority or the rail road is responsible for complying with the gap and the detectable warning requirements. The local authority, in most cases, does not own or have control over the train tracks or the ground surface adjacent to the tracks.
4. Accessible Elements and Spaces: Scoping and Technical Requirements, Common Elements 1104.3, the minimum clear width should be reduced from 48 inches to 36 inches
5. Accessible Elements and Spaces: Scoping and Technical Requirements, Detectable Warnings 1104.3.2, the guideline specifies that truncated domes be used as the minimum standard detectable warning device, however, truncated domes are a severe tripping hazard for visually impaired people.
6. Accessible Elements and Spaces: Other Requirements for Curbs, Ramps and Blended Transitions 1104.3.3 - 1104.3.7, in the last bullet, it specifies a clear space of 48 x 48 inches
7. Pedestrian Crossings: Crosswalks 1105.2, the crosswalk width should be the same as the MUTCD - 72 inches
8. Accessible Pedestrian Signal Systems 1102.8, 1106, it specifies, at intersections that allow pedestrian traffic, walk indicators should include additional audible and tactile indicators. I believe this should only be required at intersections that have marked pedestrian crosswalks and not at every intersection. Another option would be to require them at intersections that have crosswalks and/or sidewalks that allow pedestrian foot traffic. However, to require them at every intersection is unreasonable and cost prohibitive.
Under the Text of Draft Guidelines section, I had the following comments:
1. 1102.10 Stairs, the contrasting color strip should be marked with a contrasting color tone and not just a different color because visually impaired persons may not see color, but can more easily distinguish differences in color tone.
2. 1103.3 Clear Width, the minimum clear width should be 36 inches
3. 1104.2.1.3 Landing, a landing should be a minimum of 36 by 36 inches
4. 1104.2.2.3 Landing, a landing should be a minimum of 36 by 36 inches
5. 1104.3.1 Width, again the minimum width should be 36 inches
6. 1104.3.7 Clear Space, the minimum width should be 36 by 36 inches
7. 1108 Detectable Warning Surfaces, General, truncated domes are not a good device to use as a tactile warning device. For visually impaired persons, truncated dome can be a tripping hazard.
If you have any questions or need additional information, please let me know.
Thanks!
RESPONSES TO DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY DATED JUNE 17, 2002
DISCUSSION OF PROVISIONS
Additions and Alterations (1102.2)
1. Definition for "substantial reconstruction" open to subjectivity
2. Definition for "limited improvements" open to subjectivity
3. Who defines "technically infeasible"?
4. Who makes the determination on a case by case basis?
5. What is the potential cost for delays during the evaluation?
6. Delays and requirements will increase overall cost of doing business in public rights-of-way significantly
Surface Gaps at Rail Crossings ( 1103.7)
1. Detectable warnings for each track approach within the railroad rights-of-way would be whose responsibility to install and maintain?
Curb Ramps and Blended Transitions (1102.6, 1104)
1. The dual ramp requirement causes several issues at existing intersections and even more issues at new intersections. At existing intersections, not only will existing storm drains and utility poles pose a problem, but also where dual curb ramps can be installed a visibility issue for vehicular traffic will exist. Dual ramps force the installation at the terminus of a curb return. In turn, the crosswalk and stop bar have to match the curb ramps; therefore, installation of a 96" cross walk, 24" stop bar and the necessary spacing between will force the vehicle stop point behind the current visibility clips at intersections.
Perpendicular Curb Ramps (1104.2.1)
1. 48" X 48" level landings at the top of ramps will require additional rights-of-way purchases to accommodate. Clear space requirements will increase this need at intersections as well.
Detectable Warnings (1104.3.2)
1. Depending on the application, the truncated domes may still cause problems for wheel chair users.
Informational Signs and Warning Signs (1102.7.2)
1. It is unclear what the expectation is from the new guidelines as to what these signs are expected to provide for visually impaired pedestrians.
Pedestrian Crossing (1102.8, 1105)
1. Profile grades of 2 percent at intersection crosswalks are normally reasonable; however, in street conditions that have over 5 percent continuous grade, this requirement will have an overwhelming affect on construction cost for new and existing intersections.
Roundabouts (1105.6)
1. This guideline will all but eliminate the use of this method of continuous flow application due to cost and the fact that continuous flow would no longer be attainable.
Lori Chapin has reviewed the new ADA regulations you sent Keith from our perspective. For the most part, the new regulations would help clear up some issues from our perspective, assuming they would also be incorporated into the Texas Accessibility Standards which is what TDLR enforces. The few items we would like to include in comments you forward back to TEXITE or whatever procedure has been set up are attached. Please give me or Lori a call if you have questions. Thanks.