Where perpendicular or angled parking is provided, an access aisle 96 inches
(2440 mm) wide minimum shall be provided at street level the full length of the parking space and shall connect to a pedestrian access route serving the space. Access aisles shall be marked so as to discourage parking in them
Bruce E. Taylor, P .E., October 25, 2002
Re: Request for Comments on the Draft Guidelines for Accessible Public Rights-of-Way.
The Oklahoma Department of Transportation has reviewed the proposed draft guidelines for accessible public rights of way, and subsequently reviewed the AASHTO recommendations relative to that guidance.
The Department concurs with responses conveyed in the " AASHTO Comments and Recommendations on the Draft Guidelines for Public Access", and fully supports the AASHTO efforts to address safety concerns and eliminate ambiguities within the proposed guideline language.
In addition, the Department would request that the Access Board adopt language that would allow the consideration of off-street parking as an alternative to ADA compliant on-street parallel parking. Proposed Section 1102.14, States;
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.
Further, Section 1109.2, Parallel Parking Spaces, states;
An access aisle at least 60 inches
Flexibility should be afforded the Engineer to allow off-s1Ieet accessible parking, where available, in a reduced vehicular environment common to most minor s1Ieets adjoining heavily traveled throroughfares. The Department would propose that the requirements of Section 1104.12 requiring one compliant parking space per block face, be removed, and Section 1109.2 be revised to read;
An access aisle at least 60 inches
The Department appreciates the opportunity to comment on the Draft Guidelines for Public Access. Should you have questions or comments, please advise.
Sincerely,
Bruce E. Taylor, P .E.
Chief Engineer
Oklahoma Department of Transportation
Norman Baculinao, P.E., PTOE, August 26, 2002
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
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - - - - -
1. This section needs to be clarified, i.e., where is the access isle located?, that is, " will it be on the driver side or passenger side?"
2. The following is more of a question/concern about this requirement:
In downtown areas where parking is premium, this requirement will make it very difficult to install parallel accessible parking spaces. If I understood it correctly, access isles typically accommodate "lifts" which is usually located on the passenger side. If this is the case, then areas with adequate sidewalk width do not need access isles because "lifts" can be placed directly onto the sidewalk, EXCEPT, for left-curb side of ONE-WAY streets.
On the other hand, those that would use access isles using a wheel chair, (or for those that gets the wheel chair from a trunk or the back of the automobile), then access isle would be needed.
3. The requirement for the exception is install the parking stall at the end of the block. I am assuming the intent is to shorten the distance to the nearest access ramp. If this is the case, then can we allow a mid-block location so long as a "curb-cut" or access ramp is built either at the front or rear of the parking stall???
In the City of Pasadena, we have deferred all requests for accessible parallel parking until the guidelines is adopted so we are very anxious about final approval of this document. .
I would really appreciate, if you could forward this comments to the right individual and hopely get a response back. Please feel free to call me for any clarifications regarding this comments.
Sincerely,
Norman Baculinao, P.E., PTOE
Traffic Engineering Manager
Department of Transportation, City of Pasadena
Barbara Barker, October 22, 2002
Attached is a summary of a staff report providing analysis of the draft guidelines for ADA provisions for "on-street handicap parking." This analysis is limited to the affects it would have on the Public on-street Parking Program provided in the Central Business Districts of Montgomery County, MD . Also included are 5 photos, attached as examples of desirable streetscaping in our County . It is my understanding that if the proposed guidelines had been in effect, when these streetscape project were built in the last two years, many of the amenities you see here could have never been provided in this manner.
This by no means represents the full extent of comments to be submitted by Montgomery County, Maryland on this proposal . But this summary is merely submitted to reflect my professional opinion (24 years planning for the operation of a public parking program) of the adverse affect this proposal will have on the parking industry and to show specifically how our Public Parking jurisdiction would be affected.
Thank you for the chance to submit my comments,
Barbara Barker,
Senior Planning Specialist
Traffic & Parking Services
As I mentioned, I believe our Department will be forwarding all of the "official" comments on behalf of Montgomery County, Maryland Public Works and Transportation Department. My comments are submitted as an opinion of a parking professional. Thanks.
ACCESSIBLE PUBLIC RIGHTS OF WAY MONTGOMERY COUNTY, MARYLAND - PUBLIC PARKING PROGRAM
The following analysis of the proposed draft guidelines for public R-O-W is limited to issues that arise from attempting to provide handicap on-street parking only as it affects parking in the Central Business Districts (CBDs) of Montgomery County, Maryland. This discussion is limited to public on-street parking, specifically as it relates to the Parking Districts and County policies within these Districts.
ASSESSMENT & COMMENTS
If the County is required to provide handicap spaces on-street, in the manner mandated by this change, there are three areas of consideration that will most affect the Public Parking Program in Montgomery County:
1. The method used for calculation of the number of handicap spaces to be provided on-street.
2. The physical requirements of the area to be designated as a handicap space.
3. Current policies in effect for Montgomery County's Public Parking System.
1. METHODS OF CALCULATION: HANDICAP ON-STREET PARKING
. The number of handicap spaces required, when the Access Board's method of allocation is used, far exceeds the number required if the Advisory Committee's (approximately 2%) method is used. And we suspect that the Board numbers far exceed the actual number of disabled patrons using parking spaces, since it would require 9 to 22% of all parking spaces to be designated for handicap use only.
. The percentage in excess of ADAAG is an unrealistic allocation, (See Table I) ranging from 350, 3.5 times to almost 5 times the number required by current ADA standards.
. Rather than allocating one space per block face, the decision on where to locate the spaces to be designated should be left to the individual jurisdictions, which can balance the accessibility requirement to the actual demand.
Table I
COMPARISON OF THE NUMBER OF ON-STREET
HANDICAP PARKING SPACES REQUIRED
1. Access Board Guidelines require provision of one handicap parking space for each block face.
2. Advisory Committee recommendations are for use of the ADAAG sliding scale ratio to be based on the total number parking spaces provided.
2. PHYSICAL REQUIREMENTS OF DESIGNATED HANDICAP SPACES
In Montgomery County's CBDs, the distances from building property lines to curb lines vary in width, typically from 4 feet to 12 feet
In Montgomery County all on-street parking is provided parallel to the roadway and curb. Most CBD sidewalks have less than 14 feet
If Committee recommendations are followed, the No Parking distance will be increased. In a discussion on vehicular obstructions (02.4.13), the Committee suggests "lengthening the no parking zone adjacent to a crosswalk, since wheelchair users and people of short stature may be hidden from a motorist's view by parked cars." This legislation would require wheelchair patrons to maneuver within the traffic flow for several minutes, placing them in a very dangerous situation. In addition, the lengthening of the No Parking zone can only be accomplished by further reducing the number of parking spaces available to the general public.
Where sufficient R-O-W does exist, the length of the indentation would have to make allowance not only for the length of the vehicle, but for a sufficient area of maneuverability around the vehicle to an access ramp provided within the indentation area (depicted in Fig. 61, Section 14.2 ADAAG). This would allow the disabled driver to safely gain access to the ramped segment of the indentation, without being exposed to the traffic flow. But it is clear that these indentations would have to be longer than just one car length, thus further eliminating additional on-street parking spaces available to the general public.
Obstructions
Attached to this document are five pictures that reflect the desirable streetscaping methods adopted by this County. In some cases, a reverse easement has been granted allowing landscaping and café tables and chairs to be placed adjacent to parking spaces, and 6 feet
In summary, even if the provision of one handicap space for each block face could be properly addressed, the physical constraints such as sidewalk space limitations, slope and terrain would make this allocation "technically infeasible" in most of the locations within our downtown CBDs.
3. MONTGOMERY COUNTY PUBLIC PARKING SYSTEM POLICIES
Montgomery County's policy is to provide designated accessible parking spaces for handicapped users in off-street public parking lots and garages. Designated handicap spaces provide free parking for those patrons whose vehicles display a handicap tag or permit. In addition, any metered space may be used, free of charge. This is also true for all on-street parking spaces in our CBDs.
The main consideration for not designating specific on-street handicap parking spaces is the extreme safety concerns. Our present policy allows handicapped patrons to park in the places best suited to their capabilities. Provision of designated handicap parking spaces, by the County traffic engineers, implies that these are safe locations for wheelchair patrons to enter and exit their vehicles. Since 98% of all our CBD pedestrian R-O-Ws are less than 14 feet
For this proposed legislation to mandate the installation of these spaces on-street, without the provision of direct access from the designated handicap space to the pedestrian routes (without use of the travel lane in a public roadway), creates extreme liability issues for the jurisdiction providing such designation. We believe that this could leave us open to law suits arguing that, by our designation of a handicap space at the end of a block, we have deemed it a safe location for maneuvering to an access ramp.
It makes perfect sense to provide on-street handicap parking spaces in areas where these standards are achievable; however, in our downtown CBD areas those would represent less than 2% of the block faces. Even provision of two handicap spaces together in one block makes more sense than attempting to accomplish the requirement on both sides of a given street.
It is also obvious from the examples presented in Table I, that the number of spaces to be provided on-street, using the Access Board Guidelines, is excessive. We would recommend that if the ADAAG required number of handicap spaces cannot be provided on-street in an indented area, the requirement be met in nearby off-street facilities. Perhaps a standard could be recommended that if an off-street facility is not available within a 2-3 block radius, the safest on-street space be provided to satisfy the ADAAG requirement for that area.
Barbara Barker
Senior Parking Planning Specialist
Montgomery County, Maryland
David T. Harden, October 25, 2002
CITY OF DELRAY BEACH
RE: Draft Guidelines for Accessible Public Rights-of-Way
The City of Delray Beach, Florida, has reviewed the Draft Guidelines for Accessible Public Rights-of-Way being proposed by the Architectural and Transportation Barriers Compliance Board and has the following comments/concerns:
Sec. 1102.14, 1109 ? Requiring one ADA accessible space per block face doesn't seem practical for smaller municipalities which have five (5) to eight (8) spaces per block. In many instances, this would require 20% of the public parking spaces designated as handicapped accessible. This percentage is excessive when compared to the requirements in parking lots and garages which starts at four percent (4%) and reduces to two percent (2%) for capacities between 501 and 1000 spaces.
Sec. 1109.2 ? The suggestion of the "bump-in" for parallel parking spaces with the thought that users needing access from the drivers side would park in the spaces against the curb assumes that drivers would be able to easily complete that maneuver. Realistically, on a two-lane roadway, the vehicle would have to impede traffic flow of the adjacent lane to achieve a great enough angle to use the space as suggested. Exiting the space would create similar hazards. To accommodate such a design would require the elimination of additional on-street spaces.
Sec. 1109.3 ? Required dimensions in the state of Florida currently exceed the national standard of an eight foot (8') space with a five foot (5') access panel by mandating the parking space to be twelve feet (12') wide with a five foot (5') access panel (17'). The proposal to have all on-street perpendicular or angled parking spaces to be van accessible requiring a 96" access panel (eight (8'), would result in twenty foot (20') wide spaces. Current Florida accessibility requirements exceed the proposed national standard by one foot (I). Perhaps the proposal should be reevaluated to provide a minimum width which would keep the state of Florida and others which might mirror Florida's guidelines, in compliance. A suggestion would to allow alternative designs which accommodate a total width of 17' with a minimum access panel of 5'.
Sec. 1109.5 ? Prohibiting any obstructions for the entire length of sidewalk adjacent to an accessible parallel space seems unreasonable. Determining a reasonably sized area, perhaps ten feet (10') at the center of the space, would accommodate the entering and exiting of vehicles while allowing for streetscape elements to remain or be installed. The primary concern would remain the unobstructed access to the pedestrian or walking system.
Sec. 1105.2 ? It seems unlikely that the widening of crosswalks to eight feet (8) to provide the physically challenged ample ability to get across streets would be as effective as the suggestion of the Board which is addressed in section 1105.3. It would seem that the adjustment of the pedestrian signal phase timing to a rate of 2.5 to 3 feet
In closing, the City of Delray Beach, Florida has a large senior and physically challenged population and is cognizant of the day-to-day challenges they face. Although not mandated, the City has installed numerous ADA accessible spaces throughout the downtown area (on-street parking and public parking lots) and continually monitors and addresses the needs of the community. I believe most municipalities share this philosophy.
Please take these comments and suggestions into consideration while realizing the impact on smaller municipalities that will be created through the adoption of these proposals as currently drafted.
Feel free to contact me at 561-243-7015 if I may be of any further assistance.
Sincerely,
David T. Harden
City Manager
Stephen N. Van Winkle, October 23, 2002
This letter is in response to the draft of the Access Board regarding the new ADA rules. Please note that the following comments represent the Administration's position of the City of Peoria, Illinois.
1. The Detectable Warning (DW) method of truncated domes and color differences does not provide value added when compared to the textured concrete used in Peoria. In Peoria, non-sighted pedestrians are appreciative of the textured concrete that is embossed as a raised grid-pattern in the wet concrete.
2. One ADA parking space per block face: In Illinois, motorists with ADA placard or license plates can park free of charge at any meter and can exceed the parking duration in time limit zones. High turn-over meters offer excellent opportunities for ADA access. Municipalities should be allowed flexibility in providing ADA on-street parking spaces. An average of space per block face is more flexible.
3. Parallel ADA Spaces to have 5 ft
4. Width of Marked Crosswalks: Requiring the 8 ft
If you desire additional input regarding these comments, please call.
Sincerely,
Stephen N. Van Winkle
Director of Public Works
John N. LaPlante, P.E., P.T.O.E., October 14, 2002
Attached are my comments on the Draft Guidelines for Accessible Public Rights-of-Way. Overall, I think this is an excellent and long overdue document. However, I do have a few very specific comments and recommendations that I urge be given careful consideration.
Please contact me at this e-mail address or you can call me at 773-792-9000 if you have any difficulty in opening this document or if you have any questions. Thank you this opportunity to comment on this important and valuable document.
John N. LaPlante, P.E., P.T.O.E.
Chief Traffic Engineer
TY Lin International, Inc.
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.
Need clarification regarding how accessible facilities "connect" to existing construction. Does the "connection" refer only to the sidewalk, or does it include the pedestrian signals and/or other features?
Recommend clarification of the types pf treatments necessary when "connecting" with existing construction.
1102.5.1 Protrusion Limits.
Objects with leading edges more than 27 inches
Some safety features within the right-of-way, such as fire hydrants, may not adhere to the protrusion requirements
1102.5.2 Post-Mounted Objects.
Free-standing objects mounted on posts or pylons shall overhang circulation paths 4 inches
1.) The existing ADAAG (Section 307.3) allows a 12-inch maximum overhang of post-mounted objects into the circulation path; thus, the 4-inch requirement in the draft guidelines is a significant restriction. 2.) Some features required in other sections of the guidelines, such as the street name requirement on Accessible Pedestrian Signal poles, may not meet these protrusion requirements.
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.
Consideration needs to be given as to when and how this will be implemented. Bus route identification signing is normally done by transit agencies and is completely independent of any other roadway or sidewalk improvements at a given location or along a route.
Recommend that consideration be given as to how this can be implemented separate from a sidewalk or roadway improvement.
1102.7.2 Informational Signs and Warning Signs.
Informational signs and warning signs shall comply with 703.5.
Signs at signal pushbuttons should also include Braille messages. Should not this note also be included here?
Recommend the following change: Informational signs and warning signs shall comply with 703.5. Signs located at accessible pushbuttons shall comply with 703.2.
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.
Providing 20 feet
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.
Providing 20 feet
1103.3 Clear Width.
The minimum clear width of a pedestrian access route shall be 48 inches
I would prefer a desirable minimum clear width of 60 inches
Revise wording to say: The minimum clear width shall be 60 inches
1104.2.1.1 Running Slope.
The running slope shall be 1:48
In hilly terrain, due to the slope of the sidewalk and/or the roadway, it may not be possible to provide a perpendicular curb ramp with a running slope between 1V:48H and 1V:12H.
Recommend adding the following text to Section 1104.2.2.1: "EXCEPTION: A perpendicular curb ramp shall not be required to exceed 15 feet
1104.2.1.2 Cross Slope.
The cross slope shall be 1:48
Constructing maximum 1V:48H cross slopes on perpendicular curb ramps will be very costly in areas of hilly terrain.
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.
I disagree with the suggestion to permit the use of a 1:15
Recommend no change to this section..
1104.3.7 Clear Space.
Beyond the curb line, a clear space of 48 inches
1.) Is this clear space required for a parallel curb ramp or is it redundant? 2.) From where is 'beyond the curb line' measured? Front or back of curb or other? In addition, in which direction from the curb line is it measured for each type of ramp -- toward the street or toward the sidewalk?
1.) Recommend that this clear space "beyond the curb line" not be required for parallel curb ramps as it would be a duplication of the landing space. 2.) Recommend clarification of where to measure clear space from for perpendicular curb ramps (assumed to be face of curb).
1105.2.1 Width.
Marked crosswalks shall be 96 inches
Why not use 8 feet
Recommend the following change: Marked crosswalks shall be 6 feet
1105.2.2 Cross Slope.
The cross slope shall be 1:48
Including every intersection along a constant grade street would result in extremely unsafe vehicular movements where there is no signal or when a traffic signal is green. This will likely lead to cars going out of control, and an out of control car is a risk to everyone, especially pedestrians both in the street and on adjacent sidewalks. I am absolutely opposed to this suggestion!
Recommend dropping this provision.
1105.3 Pedestrian Signal Phase Timing.
All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
While I agree that 4.0 ft/sec is too fast a walking speed, I cannot agree with lowering the speed to 3.0 ft/sec. This will result in 25% added delay to any signalized intersection where pedestrian crossing time governs. This delay would also apply to pedestrians wishing to cross the street, leading to the likelihood of pedestrians disobeying the ped signal. I suggest as a compromise solution, requiring a minimum total ped crossing time (Walk and Flashing Don't Walk) be based on 3.0 ft/sec and the Flashing Don't Walk be based on 3.5 ft/sec.
In addition, including the length of the ramp in the crossing distance can increase the crossing distance by as much as 12 feet
Recommend the following change: All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
1105.5.3 Approach.
Where the approach exceeds 1:20
Given the high cost of installing and maintaining elevators, particularly in outdoor locations and often not near a likely power source, the 60-inch rise seems unworkable.
Recommend some further research as to a more workable rise differential or some more reasonable exception included in this section.
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.
Traffic signals at roundabouts would completely eliminate both the traffic flow and traffic safety benefits of roundabouts, thus effectively precluding their use in any urbanized areas. Since they usually eliminate so many vehicular crashes, eliminating roundabouts does not seem to be a viable solution. However, I recognize that roundabouts are a very real problem for the visually impaired, as well as other less mobile pedestrians. This is particularly true at multi-lane roundabouts. We quickly need further research on how to enforce vehicular yielding at pedestrian crosswalks.
Recommend the following change for the time being: 1105.6.2 Signing. "Yield to Pedestrians" signs and visible pavement markings shall be provided for each segment of the crosswalk, including the splitter island.
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.
Similar to the roundabout discussion above, there are many locations where signalizing a separate turn lane is neither feasible nor safe. However, there are probably too many free flow turn lanes in urban areas that could and should be signalized. This is currently the subject of a new NCHRP study (Project 3-72) and the signalization recommendation should be deferred until that study is complete.
Recommend the following change for the time being: Where pedestrian crosswalks are provided at right or left turn slip lanes a "Yield to Pedestrians" sign or a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island.
1106.2.1 Location.
Pedestrian signal devices shall be located 60 inches
1.) Space limitations may make it difficult to place separate signal components at the required spacing. 2.) Clarify what is meant by "pedestrian signal device" -- Is this just the push-button, or does it include other items such as the auditory tone, pole, walk/don't walk signs, etc.? 3.) Is "control face" a recognized term for pedestrian signals? It appears to refer to the "walk/don't walk" panel. This section could be reworded for clarity.
1.) Recommend developing illustrative standard drawings for intersections using required spacings to determine feasibility and reasonability of spacing. 2.) Recommend defining "pedestrian control device" or rewording first sentence. 3.) Recommend rewording second sentence to state: "The face of the pedestrian signal should face the crosswalk it serves."
1109.2 Parallel Parking Spaces.
An access aisle at least 60 inches
Bike lanes should not be considered travel lanes with regard to the restriction that "the access aisle shall not encroach on the vehicular travel lane". And the use of inches to define street space implies a level of accuracy that is neither needed nor practical to achieve.
Recommend the following change: An access aisle at least 5 feet
1109.3 Perpendicular or Angled Parking Spaces.
Where perpendicular or angled parking is provided, an access aisle 96 inches
It appears that these requirements apply to all parking spaces, instead of only to the accessible spaces.
Recommend rewording beginning of section to state, "Where accessible perpendicular or angled parking is provided,?"
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.
It is unclear how far back on the sidewalk from the accessible parking space this restriction applies, i.e., how far back is "adjacent to...the space"?
Recommend clarifying verbiage.
Douglas Weiszhaar, October 25, 2002
Enclosed is the Minnesota Department of Transportation's (Mn/DOT) response to the Access Board's Draft Guidelines for Accessible Public Rights of Way. The response is a consensus position that has representation, comment, and involvement from all affected facets of Mn/DOT and its partners from the cities and counties.
Mn/DOT and its transportation partners have a distinguished history of working to make the transportation system accessible to all users and of working with communities to achieve the letter and the spirit embodied in the Americans with Disabilities Act. The comments enclosed are a continuation of that history and Mn/DOT's commitment to keep an open dialogue that allows us to responsibly build and maintain the best transportation system possible.
Sincerely,
Douglas Weiszhaar
Acting Commissioner
Minnesota Department of Transportation's
Response to the Access Board
on
Draft Guidelines for Accessible Public Rights of Way
October 25, 2002
General Discussion
The Minnesota Department of Transportation's (Mn/DOT) review of the Access Board's Draft Guidelines for Accessible Public Rights of Way, surfaced broader themes and concerns about the guidelines, which are discussed here.
Flexibility
The wide range of environments that will be encountered by designers within the public right of way was clearly not considered. The rigidity of the guidelines do not allow for engineering judgement and do not respect the cultural, environmental, and physical conditions that a designer must consider on a site by site basis. The current approach of the guidelines may result in poor design, dangerous conditions, a reduction of general services, and operational shortcomings unless flexibility is introduced.
Availability of Resources
There is great concern that the guidelines have been developed without a context that takes the cost of construction and ongoing maintenance into consideration. While it has been made clear that the Access Board views cost as an issue of implementation to be managed by the FHWA and the Department of Justice, guidelines cannot be responsibly developed without these topics being taken into consideration. Many who provided comments are working within a transportation system where resources are already severely taxed?
Like many similar large DOT maintenance organizations, Mn/DOT does not have the budget to do sufficient maintenance on its systems. Therefore, we must put activities that are legally or clearly public safety related at the top of our list when we prioritize resource expenditures - including personnel time and materials. Prior to the proposed ADA requirements becoming law, there needs to be a discussion about expectations of how well these facilities are likely to be maintained with a clear understanding that all railings, signal devices, and surface treatments may not be fully functional at all times. Anything that puts the public in an unsafe condition is something that we must attend to, but if resources are strained we must compare fixing a system that interacts with hundreds or thousands of people above a system or device that substantively interacts with less than a dozen people. If cost is not considered at this time and guidelines are put forward that have cost prohibitive facilities as requirements, it is likely that pedestrian accommodation may be removed from new projects and less desirable improvements will be made to the existing network.
Liability
The guidelines have surfaced the issue of liability. It has been noted in the Mn/DOT response that the guidelines are requesting designers to meet Access Board requirements at the expense of other guidelines and standards that are already in place and enforceable. At this time designers are not being provided guidance on how to negotiate or balance conflicts and that will leave a situation where designers may simply choose not to include treatments. This gap will also invite a wide range of interpretation between the different types of guidance that is available to designers and will subsequently erode the uniformity and predictability that is being sought by Draft Guidelines for Accessible Public Rights of Way. As in the matter of cost the Access Board defers to the Department of Justice once the guidelines are in place, but there are many issues that should be addressed at this stage so that all users of the transportation system will be represented.
In closing Mn/DOT is seeking guidelines that will allow us to improve access within our transportation system and maintain balance between financial, cultural, and operational needs. The Access Board must consider how to responsibly recommend guidelines that can be implemented and will serve the needs of all users. Refinement of the guidelines is clearly needed to reach an acceptable balance point.
General Recommendations
Guideline Usability
To improve the overall usability of the guidelines, the following recommendations are made:
1. Use full citations when there is a cross-reference to another document so users can understand and quickly find the information referenced.
2. Future iterations should have more extensive graphics to illustrate the situations that are being described.
3. Conform to industry practice. (i.e. express grades as a percentage with rise over run in parentheses.)
4. Follow the federal standard for expressing units with metric units first, followed by English units in parentheses (e.g., 3.6 m (12 ft)). To provide additional clarity, Mn/DOT also bolds the English unit in its manuals.
5. Use decimals instead of fractions (e.g., 2.5 rather than 2˝).
6. Use consistent unit convention (e.g., inch instead of ")
7. Please provide an indication of what sort of documentation needs to be kept if the implemented design is challenged.
8. The guidelines do not explicitly state that they are design minimums. Perhaps, this is a topic that will be addressed once the guidelines are integrated into ADAAG, but as a stand-alone piece, the guidelines invite the interpretation that they are maximum specifications for facilities. This assumption should not be allowed to stand since there are many instances where facilities should be designed above the minimum recommendation.
Section Analysis
1101 Application and Administration
Section 1101.3 Defined Terms
There are several concerns with terms used within the guidelines because definitions are not clear or unnecessarily deviate from common industry definition. Specific concerns are as follows:
. Blended Transition: Add a definition for this term in this section. The intent of the term is not clear, because a definition is not provided.
. Crosswalk: Simplify the definition. Potential language could be as follows:
o Crosswalk - (1) That portion of a roadway ordinarily included with the connection of sidewalks at intersections; (2) Any portion of a roadway distinctly indicated for pedestrian crossing by lines or other markings on the surface.
. Dynamic Envelope: This is not a standard industry term and needs definition.
. Pedestrian Clearance Interval: A definition is requested for this term. The suggested language is: the interval following the walk interval, normally symbolized by a flashing "Hand" or "Don't Walk."
. Ramp: The following definition is proposed: a sidewalk with a slope greater than 5%, but not exceeding 8.33%.
. Running Slope: For clarity, it is requested that this term be removed and that the term "grade" be used exclusively.
. Superelevation: For clarity, it is requested that this term be removed and that the term "cross slope" be used exclusively.
. Technically Infeasible: Add a definition for this term in this section. The intent and appropriate application of the term is not clear, because a definition is not provided.
1102 Scoping Requirements
Section 1102.2 Alterations
Guideline Language: 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: An alteration where compliance is technically infeasible, the alteration shall comply to the maximum extent feasible.
Requested Change: 1. Additional clarity needs to be provided for the thresholds of alteration either through expanded language in the proposed guidelines or a reference to already existing language.
2. It is recommended that the explanation of technically infeasible found in section 4.1.6 of the July 26, 1991 Federal Register Part III, 28 CFR, Part 36 be restated here along with the exceptions that are within the purview of these guidelines.
Suggested Language: No recommendations.
Justification: The first change is needed to create clarity regarding when the guidelines should be used. As the guidelines are currently written it is unclear as to what types of projects the ADA requirements apply. Mn/DOT's view is that the maintenance and minor improvement categories where the objective is to keep a facility smooth and open to traffic should be excluded. The second change is requested to provide a clear definition and guidance on the applicability of "technically infeasible" in relation to the guidelines. Given the volume of physical area that right-of-way covers, it would be reasonable to explicitly expand the definition of "technically infeasible" to include environmental site constraints and adverse environmental, social, community, and transportation system user impacts.
Section 1102.5.2 Post-Mounted Objects
Guideline Language: Free-standing objects mounted on posts or pylons shall overhang circulation paths 305 mm (4 in) maximum when located 685 mm (27 in) minimum and 2030 mm (80 in) maximum above the finish floor or ground. Where a sign or other obstruction is mounted between posts or pylons is greater than 305 mm (12 in), the lowest edge of such sign or obstruction shall be 685 mm (27 in) maximum or 2030 mm (80 in) minimum above the finish floor or ground.
EXCEPTION: This requirement shall not apply to sloping portions of handrails serving stairs and ramps.
Requested Change: Reword.
Suggested Language: Free-standing objects mounted on posts or pylons shall overhang circulation paths 100 mm (12 in) maximum when located 685 mm (27 in) minimum and 2030 mm (80 in).
Justification: The suggested change would result in uniform interpretation and application of the proposed guidelines between other guidelines already in force. The 12-inch maximum was established in 1991 under section 4.4.1 of the July 26, 1991 Federal Register, Part III, 28 CFR, Part 36 and is included in the ADAAG Section 307 referenced below. This guideline change will allow for uniform design of integrated roadway and multi-use projects and the development of uniform design standards for both site and roadway facilities.
307 Protruding Objects
307.1 General. Protruding objects shall comply with 307.
307.3 Post-mounted Objects. Free-standing objects mounted on posts or pylons shall overhang 305 mm (12 in) maximum when located 685 mm (27 in) minimum and 2030 mm (80 in) maximum above the floor or ground. Where a sign or other obstruction is mounted between posts or pylons and the clear distance between the posts or pylons is greater than 305 mm (12 in), the lowest edge of such sign or obstruction shall be 685 mm (27 in) maximum or 2030 mm (80 in) minimum above the floor or ground.
Section 1102.7.1 Bus Route Identification
Guideline Language: 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 ADAAG Section 703.2 where audible signs are user or proximity-actuated or are remotely transmitted to a portable receiver carried by an individual.
Requested Change: Delete text referencing non-existing sections of the proposed guideline changes in ADAAG Section 703.
Suggested Language: Bus route identification signs shall comply with ADAAG Sections 703.5.1 through 703.5.4. Bus route identification signs located at bus shelters shall provide raised and Braille characters complying with ADAAG Section 703.2, and shall have rounded corners.
Justification: Section 703.5.5, 703.5.7, and 703.5.8 are not published on the Access Board Web site. Until this text is available for review, references to these sections should be deleted due to the inability of the public to provide adequate review of conditions and impacts.
Section 1102.10 Stairs
Guideline Language: Where provided, stairs shall comply with 504. Stair treads shall have a 51mm (2 in
Requested Change Delete the requirement for color strip.
Suggested Language: Where provided, stairs shall comply with ADAAG Section 504.
Justification: The existing standardized handrail design in accordance with ADAAG Section 504 extends horizontally at the top, bottom and landings of the stairs to delineate the edge of a transition change (edge of stair system). This is the most effective tool to communicate stair locations to a disabled person at all times of day and in all weather conditions. If necessary modify the handrail design guidelines to better communicate the location of the stair system. The addition of a strip of contrasting color is not justified and cannot be adequately maintained with the limited resources available.
The ability to develop a design solution that will meet both public safety and maintenance considerations, without creating a high level of liability, is highly questionable. Any system not maintained will present a liability for the transportation agencies.
Paint: non-permanent, often slippery when wet, high cost to maintain.
Nosing Material: often slippery when wet, a mix of materials allows a point of moisture and salt infiltration that will shorten the life of the structure.
Adhesives: non-permanent, maybe slippery when wet or snow covered, high cost to maintain, frequently delaminates in heat and cold conditions creating loose edges/trippers.
Visibility in snow conditions: not visible under snow cover.
Visibility at night without lighting:
The use of a well-designed handrail system is more useful and visible in all conditions and fully provides a reasonable accommodation for individuals of all abilities.
Context Sensitive Design/Aesthetic Considerations
A color edge strip of high contrast will visually dominate the setting and negatively impact community design objective to blend roadway elements sympathetically with architectural elements and the natural environment.
Section 1102.13 Bus Stops.
Guideline Language: Bus boarding and alighting areas shall comply with 810.2. Bus shelters shall comply with section 810.3.
Requested Change: Delete information referencing non-existing sections of the proposed guideline changes in Sections 810.2 and 810.3 of the ADAAG.
Suggested Language: Not Applicable.
Justification: Sections 810.2 and 810.3 of the ADAAG are not published on the Access Board Web site. Until this text is available for review all references to these sections should be deleted due to the inability of the public to provide adequate review of conditions and impacts.
Section 1102.14 On-Street Parking
Guideline Language: 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.
Requested Change: 1.Reword the original statement with additional text to allow for alternative compliance with the objectives of close easy access.
2.Clarify the definition of a block.
3. Clearly state the intent of the Access Board for this requirement to apply only to commercial areas.
Suggested Language: Where on-street parking is designated by striping or parking meters, on-street accessible parking stalls shall be uniformly distributed along the block faces at a ratio in compliance with Table 208.2 of the ADAAG and shall comply with 1109.
EXCEPTION: Accessible public off-street parking is provided within the block at a ratio of one parking stall per 25, with a minimum of one parking space for the total of all public parking spaces available per block, for both off-street and on-street parking.
Justification: Require On-Street Parking Only in High Use, Designated Public Parking Areas.
This requirement seems to be better targeted to designated parking, striped parking and metered parking. The requirement for one parking space along each curb face in all locations where parking is provided seems excessive. In many cities parking is allowed/provided in all residential areas. On-street parking spaces should not be required in non-commercial areas.
Proposed Distribution of On-Street Parking Seems Excessive
Mn/DOT agrees that a reasonable amount of On-Street parking needs to be provided, however, physical constraints must be considered. The size of a block varies by region and local urban design applications. Blocks in many Midwest communities provide no more than 6 parallel parking stalls per block face due to the curb space reserved for bus stops, driveways, passenger loading zones, service entrances and no parking zones such as at fire hydrants and turn lanes. For many communities this will reduce local parking supply for the general population by more than 17%. This ratio can be as high as 4 times or more than are required for private businesses and public facilities as specified in Table 208.2 of the ADAAG.
The number and type of businesses served by on-street parking also varies widely based on local zoning. For these reasons, use of a minimum criterion of two per block and a ratio of the total parking stalls available is recommended to establish the number of On-Street Parking spaces required.
Provide Local Governments with Design/Location Flexibility to meet the objectives
Managed parking is a local government function related to "zoning". It seems reasonable to allow for off-street parking within the same area that is designated as accessible parking only (perhaps in parking ramps). Given the grade and cross slope of many roadways, on-street parking spaces will often exceed the desired surface slope 2% (1:48) for the access aisle.
1102.15 Passenger Loading Zones
Guideline Language: 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.
Requested Change: Rewrite section and/or add an exception.
Suggested Language: EXCEPTION: Passenger loading zones are not reserved exclusively for disabled persons and shall not be identified by signage.
Justification: In reviewing this issue with Access Board staff, it is not intended that the passenger loading zones are reserved for exclusive use by disabled persons; however, the text makes this unclear and a conflict exists within other areas of the proposed draft ADA Guidelines Section 1-10.
1103 Pedestrian Access Route
Section 1103.1 General
Guideline Language: Pedestrian access routes shall connect to elements required to be accessible and shall comply with 1103.
Requested Change: Rephrase for better understanding.
Suggested Language: Pedestrian access routes shall connect elements that are required to be accessible and shall comply with Section 1103.
Justification: Not Applicable
Section 1103.4 Cross Slope
Guideline Language: The cross slope of the pedestrian access route shall be 2% (1:48) maximum.
Requested Change: Rephrase and add exception.
Suggested Language: The maximum cross slope of pedestrian access routes shall be 2% (1:48). EXCEPTION: The maximum cross slope of a crosswalk can exceed 2% (1:48) when a disruption in the roadway profile is created that consequently creates a safety hazard. There shall be no cross-slope requirements for midblock crossings.
Justification: Meeting the 2% (1:48) slope requirement would often introduce objectionable profile variations into the roadway, and may even become a safety hazard for motorists and bicyclists.
The proposed slope will impact our ability to drain intersections. The larger the intersection, the more difficult drainage becomes. The introduction of a flat grade would require extensive transitions in and out of them, especially at high-speed intersections. If further restrictions are in place, the design would result in a very rough ride through the intersection including vaulting and dragging of trailers and/or hitches.
Because this maximum cross slope may create a bump in the road, vehicle contact with the pavement will be reduced, thus reducing braking and maneuvering ability.
Section 1103.5 Grade
Guideline Language: The grade of the pedestrian access route within a sidewalk shall not exceed the grade established for the adjacent roadway.
EXCEPTION: The grade 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
Requested Change: Change wording to clarify.
Suggested Language: The grade of the pedestrian access route within a sidewalk shall not exceed the grade established for the adjacent roadway, even if the roadway is greater than 5% (1:20).
EXCEPTION: The permissible grade of a pedestrian access route may be steeper than the grade of the adjacent roadway, provided that the pedestrian access route is less than 5% (1:20), or complies with Section 405, "Ramps" of the ADAAG.
Justification: Not Applicable
Section 1103.6 Surfaces
Guideline Language: The surfaces of the pedestrian access route shall comply with 302.
Requested Change: Change wording to clarify.
Suggested Language: The surfaces of pedestrian access routes shall comply with Section 302, Floor and Ground Surfaces of the ADAAG.
Justification: A full citation of other referenced guidelines is needed for clarity and uniform application of guidelines.
Section 1103.8 Changes in Level
Guideline Language: Changes in level shall comply with 303. Changes in level shall be separated horizontally 30 inches
EXCEPTION: The horizontal separation requirement shall not apply to detectable warnings.
Requested Change: Change wording to clarify.
Suggested Language: Changes in level shall comply with ADAAG Section 303 and shall be separated horizontally by a minimum of 760 mm (30 in).
EXCEPTION: The horizontal separation requirement shall not apply to detectable warnings.
Justification: A full citation of referenced guidelines is needed for clarity and uniform application of guidelines. Additionally, the concerns raised in the AASHTO response regarding maintenance and oversight of this treatment should also be considered.
1104 Curb Ramps and Blended Transitions
Section 1104.2.1 Perpendicular Curb Ramps
Guideline Language: 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.
Requested Change: Include language from the discussion section emphasizing that this is a "should" rather than a "shall" condition.
Suggested Language: Where conditions permit, it is preferable to have separate curb ramps at a corner instead of a single ramp. Perpendicular curb ramps shall comply with 1104.2.1, and shall have a grade that cuts through the curb at right angles or meets the gutter grade break at right angles.
Justification: There are many space constraints at intersections that may not always allow for the inclusion of perpendicular curb ramps. The options need to be clear to designers.
Section 1104.2.2 Parallel Curb Ramps
Guideline Language: Parallel curb ramps shall comply with 1104.2.2, and shall have a grade that is in-line with the direction of sidewalk travel.
Requested Change: Rephrase to include language for safety consideration.
Suggested Language: In limited situations where safety will not be further compromised parallel curb ramps shall comply with 1104.2.2, and shall have a grade that is in-line with the direction of sidewalk travel.
Justification: Parallel ramps can be hazardous in northern climates when a grade is introduced in-line with the main direction of travel.
Section 1104.2.3 Blended Transitions
Guideline Language: Blended transitions shall comply with 1104.3, and shall have running and cross slopes of 1:48
Requested Change: Rewrite section to qualify that blended transitions should not be recommended in many circumstances due to a variety of safety concerns.
Suggested Language: None recommended.
Justification: The language of the guidelines should be flexible and allow designers to deal with safety issues on a case by case basis.
Section 1104.3.3 Surfaces
Guideline Language: 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.
Requested Change: Change from a "shall" to a "should" condition.
Add third qualifying sentence.
Suggested Language: In alteration and reconstruction projects, access covers and other appurtenances should be avoided on curb ramps, etc. Any access covers that must remain shall be flush and free of vertical variation 6 mm (0.25 in) or horizontal gaps of 13 mm (0.50 in).
Justification: Prohibition of gratings, access covers and other appurtenances in curb ramps, landings and blended transitions is too restrictive and impractical at some intersections when it seems that the real intent is only to provide an accessible pedestrian route free of hazards. A reasonable and practical option is to allow for access covers that are flush and without vertical variations exceeding 6 mm (0.25 in) or horizontal openings exceeding 13 mm (0.50 in).
Section 1104.3.7 Clear Space
Guideline Language: Beyond the curb line, a clear space of 48 inches
Requested Change: Change from a "shall" condition to a "preferred" condition.
Suggested Language: Beyond the curb line, a clear space of 1120 mm (48 in) minimum by 1120 mm (48 in) minimum is recommended within the width of the crosswalk and wholly outside the parallel vehicle travel lane.
Justification: Requiring a 1.2 m (48 in) clear space beyond the curb may be very difficult and costly to achieve at many intersections constrained by adjacent building development, etc. The justification for this requirement should be re-evaluated. This proposed requirement necessitates a 1.2 m (48 in) minimum shoulder or reaction distance in sections where only a 0.6 m (24 in) reaction distance is normally required. The likely use of the intended clear space by turning vehicles would present a safety problem for pedestrians if they were not staying on the sidewalk until it is permissible to cross. The clear space may provide a dangerously false sense of security for the pedestrian and even with striping, it is likely to be disregarded or misunderstood by motorists.
1105 Pedestrian Crossings
Section 1105.2.1 Width
Guideline Language: Marked crosswalks shall be 96 inches
Requested Change: Reword to reflect current MUTCD practice.
Suggested Language Marked crosswalks shall be a minimum of 1830 mm (72 in) wide. A 2440 mm (96 in) width is desirable.
Justification: Because it is possible that the 2440 mm (96 in) crosswalk would create a problem with the existing loop detector systems if moved toward the stop bar, the additional width would likely move pedestrians closer to the through traffic. The most frequently used sidewalk width in Minnesota is 1525 mm (60 in). Additionally, there is no clear benefit derived from providing a wider crosswalk.
Section 1105.2.2 Cross Slope
Guideline Language: The cross slope shall be 1:48
EXCEPTION: This requirement shall not apply to mid-block crossings.
Requested Change: Change from a "shall" to a "desired" condition.
Add an additional exception.
Suggested Language: The maximum cross slope of the pedestrian access route shall be 2% (1:48).
EXECPTION: The maximum cross slope of a crosswalk can exceed 2% (1:48) only if it does not cause a disruption to the roadway profile that would consequently create a safety hazard.
EXCEPTION: This requirement shall not apply to mid block crossings.
Justification: For profile grades greater than 2% (1:48) the designer needs to provide a flat or "tabled area" through the intersection to meet the required cross slope. To do this on a high-speed roadway will result in a forced profile grade with short vertical curves. Automobile drivers will feel a weightlessness effect going over such a profile. This same effect on trucks could create a very serious safety hazard. Criteria need to be developed as to when and where this should be applied. As the guidelines are currently presented, a designer would have a serious conflict in applying this criteria.
Section 1105.2.3 Running slope
Guideline Language: The running slope shall be 1:20
Requested Change: Increase the running maximum running slope to 6% (1:16).
Suggested Language: The grade shall be 6% (1:16) maximum measured parallel to the direction of pedestrian travel in the crosswalk for a maximum length of 38 feet
Justification: Using a 1:16
Section 1105.3 Pedestrian Signal Phase Timing
Guideline Language: All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 0.91 m/s (3.0 ft/s) maximum. The total crosswalk distance used in calculating pedestrian signal phase timing shall include the entire length of the crosswalk plus the length of the curb ramp.
Requested Change: Use the proposed pedestrian signal timing on pedestrian crossings where such timing does not force an increase in cycle length above that required using current pedestrian timing. Where the proposed pedestrian signal timing would force an increase in the cycle length, the proposed timing should only be used upon request by the public or the municipality and after an engineering study has shown there is an actual need for the extended time.
Justification: Pedestrian timing requirements are often a controlling factor of the cycle length that can be run at an intersection. Extending the pedestrian timing requirements will require longer than optimum cycle lengths at many or most intersections, resulting in an increase in vehicle delay, pollution, and fuel usage and also a delay to pedestrians waiting to cross. Increases in congestion have been associated with reduced safety. If this were to be implemented at every intersection in the US, the resulting detriment to travelers and the environment would be staggering.
Additionally, with a longer pedestrian clearance time, pedestrians will soon learn that they can still easily make it across the street even if the "Don't Walk" is already flashing. This will encourage pedestrians to begin crossing the street during the flashing "Don't Walk", which is illegal and unsafe. Pedestrians who need more time to cross can currently have more time by starting to cross at the beginning of the walk period. The clearance time assumes pedestrians start walking at the very end of the walk period.
A computerized traffic simulation/optimization program (Synchro) calculated the impact of changing from our current pedestrian timing to the proposed timing at 5 of our signalized intersections to be as follows:
Total signal delay: increased 22 - 23%
Stops: increased 6 - 10%
Average speed: decreased 9-11%
Fuel consumed: increased 5 - 9%
Section 1105.4.2 Detectable Warnings
Guideline Language: Medians and refuge islands shall have detectable warnings complying with 1108. Detectable warnings at cut-through islands shall be separated by a 24-inch (610mm) minimum length of walkway without detectable warnings.
EXCEPTION: Detectable warnings shall not be required on cut-through islands where the crossing is controlled by signals and is timed for full crossings.
Requested Change: Reword exception.
Suggested Language: EXCEPTION: Detectable warnings shall not be required on cut-through islands where the crossing is controlled by signals and is timed for full crossings or when the median is four feet or less.
Justification: In situations where a four foot median is used, the Detectable Warning Surface would provide no benefit, since there is no break in the surface for the entire width of median.
Section 1105.5 Pedestrian Overpasses and Underpasses
Guideline Language: Pedestrian overpasses and underpasses shall comply with 1105.5.
Requested Change: Add an exception to clarify that this guideline applies to the intersection of two sidewalk systems connecting services, and does not apply to trails and paths intersecting with sidewalks.
Suggested Language: Pedestrian overpasses and underpasses shall comply with 1105.5.
EXCEPTION: Applies to sidewalks only.
Justification: There are numerous trails and paths, designed for multiple non-motorized user groups, including bicycles and pedestrians, which are exempt from these guidelines. Clarification is required to ensure appropriate application of the guidelines.
Section 1105.5.3 Approach
Guideline Language: Where the approach exceeds 1:20
Requested Change: Change provision for elevators from a "shall" condition to a "may" condition.
Reconsider the 60 inches
Suggested Language: Where the slope of the ramp exceeds 5% (1:20), the approach shall be a ramp 1220 mm (48 in) minimum in width and shall comply with Section 405 of the ADAAG. Where the rise of a ramped approach exceeds 2440 mm (96 in), an elevator complying with ADAAG Section 407, or a limited-use/limited-application elevator complying with ADAAG Section 408, may be provided.
Justification: Need not Justified:
Pedestrian bridges are a supplement to other forms of transportation already available in the community. Because of the availability of alternative modes, such as vehicles and special transit services, within a community an elevator should not be mandatory unless it is the only reasonable route available between public services.
Construction Cost:
The high construction costs of the elevators will substantially increase the cost of a pedestrian bridge for its owners. The outcome of the increased cost is that the benefit/cost ratio of a bicycle/pedestrian bridge with an elevator will not allow transportation agencies to justify the construction of a bicycle/pedestrian bridge with an elevator except in the most extreme locations. Additionally, the safety value that these bridges provide to the general public will be denied to everyone if pedestrian overpasses and underpasses become cost prohibitive to build.
In cold regions such as Minnesota, an elevator enclosure may be required increasing the cost of the elevator and enclosure well above the cost of the pedestrian bridge.
Operations Maintenance:
To meet the proposed requirement will also demand significant cost in the area of operation and maintenance. Most transportation agencies will need to contract this service out due to expertise and licensing required to service this equipment which will reduce flexibility with already limited funding. Additionally, a high level of vandalism and misuse by individuals without disabilities is very likely to occur at these unsupervised facilities thereby increasing maintenance and liability costs.
No documentation was provided to indicate that the reliability of elevators in cold climate that are fully exposed to all weather conditions, which will exist on the right-of-way, is available or that they have been tested to operate with minimal failure in severe summer and winter, snow and ice conditions. Research on these topics is requested before developing a requirement
Personal Safety and security:
Surveillance and security systems will be required by agencies to monitor activity in the elevators. Most public elevators are monitored with cameras to avoid assaults, etc. This will require extensive infrastructure, staff, and contract funds to perform this monitoring.
Liability:
The investment of significant personnel and funding resources are required to keep elevators in operation and to respond to equipment failures. Given Minnesota's wide range of climatic conditions a user would be placed at a great health risk if an elevator system stalls and they became trapped in a stalled elevator for even a short period of time in sub-zero temperatures or over 100 degree
Section 1105.6.1 Separation
Guideline Language: 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
Requested Change: Clarify what materials and treatments may be considered for the development of a continuous barrier.
Remove requirement for a continuous barrier.
Suggested Language: A continuous grass berm shall be provided along the street of the sidewalk where pedestrian crossing is prohibited.
Justification: Requiring a physical separation seems to be an unreasonable requirement to apply only to roundabouts. There are many street configurations that are not normal perpendicular intersections and railings are not required for them. Most roundabout designs have grass berms around them so visually impaired persons can detect when leaving the sidewalk.
Section 1105.6.2 Signals
Guideline Language: 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.
Requested Change: Remove the requirements for pedestrian activated traffic signal and research this issue. Research might include evaluation of surface treatments to help a visually impaired person detect an approaching vehicle.
Suggested Language: No language is recommended at this time.
Justification: Minnesota requires motorists to yield to pedestrians in the crosswalk, as do most states. The crosswalk is set back one car length, which helps to make the crosswalk perpendicular to the roadway. In addition with this placement the pedestrian is crossing in front of the driver as they approach before the driver starts to prepare for the merge. Roundabouts have low-speed traffic with good visibility of the crosswalk areas. This concept also has some of the lowest collision rates of any traffic control device. There is no accident history to support a pedestrian activated signal system.
There are a number of advantages that roundabouts have for pedestrians. First, the number of conflict points is much lower. A pedestrian at a roundabout has 2 conflict points (entering and exiting right turners) compared with 6 conflicts at a standard four-leg intersection. No hazardous left-turn movements are present. Second, severe crashes caused by inattentive driving are eliminated. Crashes that occur when motorists run red lights, ignore stop signs, and make right turns on red do not happen at roundabouts. The design forces a driver to slow down and pay attention. Third, pedestrian exposure to traffic is much lower because the crossings are shorter. The splitter islands at the roundabout approaches allow people to cross one lane of slow-moving traffic at a time, instead of four lanes of traffic that would likely be traveling very fast through a signalized intersection. A pedestrian activated signal requirement would certainly discourage the use of roundabouts and those benefits would be lost to the pedestrian.
Section 1105.7 Turn Lanes at Intersections
Guideline Language: 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.
Requested Change: Eliminate pedestrian activated signal requirement.
Use the more common industry term of "free rights" rather than "slip lanes".
Suggested Language: Where pedestrian crosswalks are provided at free right turns, a painted crosswalk shall be provided.
Justification: The proposed language would require accessible pedestrian signals at locations where there are currently no signals, accessible or not. See the previous comment supporting the installation of accessible pedestrian signals only upon request and with an engineering study. Some of these locations may have no pedestrian activity of any sort and would not require any pedestrian signals, accessible or not, except for this requirement. Guidance as to where this criterion would be applied should be developed.
Also, to put in the pedestrian signals would also require installation of vehicle indications on these lanes, requiring all vehicles turning right to stop on red. Currently, there are yield sign controls on these lanes. At a location where no pedestrians are present, requiring every vehicle to stop at a new red signal indication will create significant delays, pollution, and fuel consumption.
The issue of signalizing free-right movement needs research that addresses the placement of signal heads and stop bars that will be visible to motorists and the development of warrants for the application of the free-right island. Signalized intersections, even with pedestrian indications, do not ensure the safety of pedestrians in the crosswalk. Adding signal control to the free-right will confuse drivers and induce a false sense of security for pedestrians. Unless a significant pedestrian demand is present, this could add the potential for massive violations.
1106 Accessible Pedestrian Signal Systems (APS)
Section 1106.2 Pedestrian Signal Devices
Guideline Language 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.
Requested Change: Change "shall" condition to "should" and "may" condition to allow for the use of engineering judgement to determine need on a case by case basis or remove the requirement. If the requirement is retained, additional guidance on determining when to install APS is needed.
Suggested Language: Each crosswalk with pedestrian signal indication should have a signal device that may include audible and vibrotactile indications of the WALK interval where needed. Where a pedestrian pushbutton is provided, it should be integrated into the signal device and comply with 1106.3.
Justification: The recommendation to change the requirement from "shall" to "should" is based upon the fact that there is not clear agreement that APS is warranted for all situations. In Minnesota there is not consensus among people who are visually impaired as to whether the accessible pedestrian indications are an improvement or a hindrance in crossing the roadway. One strong point of view that has been conveyed to Mn/DOT is that the accessible pedestrian systems mask the primary cue created by the sound of traffic, reducing accessibility for some users. However, there is consensus among persons who are visually impaired that accessible pedestrian signals need not be installed at all locations and that guidelines can be developed to identify appropriate locations based on requests and engineering studies.
Section: 1106.2.1 Location
Existing Language: 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.
Requested Change: Change these distances to goals, with shorter distances as the minimum requirement.
Suggested Language: No language recommended.
Justification: Due to wide variation in the geometry and constraints found at each intersection, there are likely to be many instances where the implementation of such precise requirements will be infeasible, especially in reconstruction projects.
Section 1106.4 Directional and Information Signs
Guideline Language: 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.
Requested Change: All sign designs should be in conformance with the Manual on Uniform Traffic Control Devices (MUTCD).
Suggested Language: See the MUTCD for language and specifications.
Justification: Uniformity is essential in the design and application of traffic control devices to ensure user safety. Recommendations that deviate from recognized standards compromise that safety.
1107 Street Furniture
Section 1107.2 Clear Floor or Ground Space
Guideline Language: 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 by 12 inches
Requested Change: Reword second sentence for clarity.
ADAAG Section 305.2 requires a 2% (1:48) slope on the clear floor and ground space that can be accommodated in the sidewalk cross slope direction but not the direction of the grade of the sidewalk. Create an exception to document this.
Suggested Language: The clear floor or ground space may overlap the pedestrian access route by 305 mm (12 in) maximum.
EXCEPTION: The slope of the clear floor or ground may be steeper than 2% (1:48) in the direction of the running slope for the sidewalk, but shall not exceed the grade established for the adjacent roadway.
Justification The text of the second sentence is confusing. It seems to read as a requirement for the clear floor or ground space to overlap into the pedestrian access route without stating why an overlap would be desirable. It is more appropriate to minimize the overlap to no more than 305 mm (12 in) as long as access to the furniture is compliant with appropriate provisions for this guideline.
Clarification and Exception required for 2% (1:48) slope on clear floor or ground
It is critical to point out the proposed exception to Section 305.2 of the ADAAG because it will be technically infeasible to meet the 2% (1:48) slope in the direction of the grade of the sidewalk in the same way that it is infeasible for sidewalks to meet the 5% (1:20) maximum slope requirements.
Section 1107.4.1 Single Telephone
Guideline Language: Where a single public telephone is provided, it shall comply with 704.2 and 704.4.
Requested Change It is strongly recommended that a separate process be initiated to seek legislation that will place and fund the implementation of this guideline with the Public Communications Commission/Public Pay Phone Companies for all public pay phones in the nation.
Add an exception to allow compliance with ADAAG Sections 704.2 and 704.4. The exception will allow for the necessary design for Clear Floor and Ground Space found in section 1107.2
Suggested Language: EXCEPTION: The slope of the clear floor or ground space may be steeper than 2% (1:48) in the direction of the grade for the sidewalk, but shall not exceed the grade established for the adjacent roadway.
Justification This requirement may reduce the total number of public phones installed due to the requirement to provide electrical services and maintain the equipment.
TTY equipment is often purchased and owned directly by the transportation agency, not leased from the phone companies, due to cost of equipment over time. Historically, many smaller phone companies have not offered leasing or maintenance of this equipment. Maintenance of the equipment is problematic in that only the phone company operating the public pay phone has the legal authority to connect and disconnect TTY equipment into the public phone systems. It is impossible for transportation agency staff to effectively maintain this equipment on public phones on right-of-way.
For this reason it is strongly recommended that a separate process be initiated to seek federal legislation requiring the public pay phone companies to provide this service in accordance with these guidelines and collect a public surtax to cover the cost.
See the Following Sections for Additional Comments for this Item
1107.2 Clear Floor or Ground Space: Justification: Clarification and Exception required for 2% (1:48) slope on clear floor or ground space.
Section 1107.4.2 Multiple Telephones
Guideline Language: 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.
Requested Change: See comments for 1107.4.2 above for references to Sections 704.2 and 704.4 of the ADDAG.
Add a definition for "a bank of public telephones".
Add exception.
Suggested Language: No language is recommended at this time for "a bank of public telephones".
EXCEPTION: The slope of the clear floor or ground space may be steeper than 2% (1:48) in the direction of the running slope for the sidewalk, but shall not exceed the grade established for the adjacent roadway.
Justification: See comments provided under Justification for sections:1107.2 Clear Floor or Ground Space and 1107.4.1 Single Telephone.
Section 1107.5 Public Toilet Facilities
Existing Language: 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.
Requested Change: Delete reference to the Sections of the ADAAG that are not appropriate for roadside toilets. These sections include 607-608 referring to tubs and showers and Section 610 referring to tub and shower seats.
Suggested Language: Permanent or portable public toilet facilities shall comply with ADAAG Section 603. At least one fixture of each type provided shall comply with ADAAG Sections 604 through 606 and 609.
Justification: Transportation agencies do not provide mixed-use facilities (living or service spaces with showers) on the right-of-way that are not already covered under other sections of the building and site facilities chapter of the ADA guidelines
Section 1107.6 Tables, Counters, and Benches
Guideline Language: Tables, counters, and benches shall comply with 1107.6
Requested Change: Reword.
Suggested Language: Stationary tables, counters, and benches shall comply with 1107.6.
Justification: Designate that this guideline applies to stationary (fixed location) furniture only. Non-fixed objects of this type (often temporarily placed) are highly movable by one or two persons because they are small and lightweight. It is impossible to control the location of and accessibility to movable benches and tables, etc.
Section 1107.6.1 Tables
Guideline Language: Where tables are provided in a single location, at least 5 percent but no less than one, shall comply with 902.
Requested Change: Add an exception.
Suggested Language: EXCEPTION: The slope of the clear floor or ground may be steeper than 2% (1:48) in the direction of the grade of the sidewalk, but shall not exceed the grade established for the adjacent roadway.
Justification: See the Following Sections for Additional Comments for this Item
1107.2 Clear Floor or Ground Space: Justification: Clarification and Exception required for 2% (1:48) grades on clear floor or ground space.
Section 1107.6.2 Counters
Guideline Language: Where provided, counters shall comply with 904.
Requested Change: Add an exception.
Suggested Language: EXCEPTION: The slope of the clear floor or ground may be steeper than 2% (1:48) in the direction of the grade of the sidewalk, but shall not exceed the grade established for the adjacent roadway.
Justification See the Following Sections for Additional Comments for this Item
1107.2 Clear Floor or Ground Space: Justification: Clarification and Exception required for 2% (1:48) slope on clear floor or ground space.
Section 1107.6.3 Benches
Guideline Language: 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.
Requested Change: Add an exception
Suggested Language: Where benches without tables are provided at a single location, at least 20%, but no fewer than one, shall comply with Section 903 of the ADAAG.
EXCEPTION: The slope of the clear floor or ground may be steeper than 2% (1:48) in the direction of the grade of the sidewalk, but shall not exceed the grade established for the adjacent roadway.
Justification: Design flexibility should allow for the use of benches without backs mixed with benches with backs at a ratio of 1:5
Unless unique conditions exist that justify conflicting guideline requirements for the same element within the ADA, guideline chapters should be uniform to avoid inconsistencies in design application and enable uniformity in enforcement.
1108 Detectable Warning Surfaces
Section 1108.1 General
Guideline Language: Detectable warnings shall consist of a surface of truncated domes aligned in a square grid pattern and shall comply with 1108.
Requested Change: Omit the requirement pending further study.
Suggested Language: Delete section and all related references.
Justification: Numerous comments have been brought forward regarding the maintenance of these facilities in cold weather climates. In particular, there is concern that the complete and timely clearing of the facilities after a snow event may not be possible and could create a hazardous situation for all users and become a liability risk. At this time, it is recommended that the Access Board sponsor additional research to develop best practices regarding the maintenance of truncated domes.
Concern has also been raised about how the use of truncated domes impacts skateboarders, scooter and in-line skate users. Research sponsored by the State of Florida with Charlie Zeeger P.E. as principle investigator, has shown that truncated domes consistently "down" this user group as they attempt to navigate the truncated domes. The result is that accommodation of one user group occurs at the expense of another, and communities are being asked to knowingly create a hazardous condition, which may not be legally defensible. This is not an acceptable or appropriate situation and it is strongly recommended that the Access Board continue to research other treatments that will allow for the accommodation of all user groups.
1109 On Street Parking
Section 1109.1 General
Guideline Language: Car and van on-street parking spaces shall comply with 1109.
Requested Change The Access Board should develop a paragraph specifying when a van space should be provided instead of a car space.
Suggested Language: No language is being recommended at this time.
Justification: Equal access cannot be guaranteed to all user types if a reasonable ratio of van spaces is not provided in the urban areas. A distribution based on Parallel Parking Spaces (access aisle at least 1.5 m (5 ft) vs. Perpendicular or Angled Parking Spaces (Where an access aisle is 2.4 m (8 ft) is insufficient. This is an unreasonable approach to providing reasonable accommodations because it does not ensure that a van stall will be provided within a multi-block area. At this time the ADAAG requires the van stalls have a 2.4 m (8 ft) aisle.
Section 1109.2 Parallel Parking Spaces.
Guideline Language: 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
Requested Change: Add text to reflect bicycle safety concerns.
Due to environmental and existing road conditions it is not reasonable to develop a 2% (1:48) level access aisle at all locations.
Provide exceptions.
Suggested Language: The access aisle shall not encroach on the vehicular travel lane or on the bicycle travel lane.
1. 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 4874 mm (16 ft). When an access aisle is not provided, the parking space shall be located at the end of the block face.
2. EXCEPTION: Although the access aisles are also used for wheelchair transfer to and from vehicles, the slope may be steeper than 2% (1:48) but shall not exceed the grade established for the adjacent roadway.
Justification: Bicycle Safety
It is critical that designated bicycle lanes are not impacted or eliminated.. This significant and growing transportation mode is designed as a network, with selected routes based on demand and safety accommodations for the rider. Roadway alterations that affect the system or safety design of these facilities will have a negative effect on the safety of bicyclists.
Safety for Visually Impaired Pedestrians
Moving the curb in to allow for an access aisle along side of a car appears to help one group and create a problem for another. A person, who is visually impaired, walking parallel to the roadway on the sidewalk, will find the proposed concept confusing. People who are visually impaired tend to walk near the inside edge of the walk, however, jogs in the walk may introduce problems.
Clarification and Exception required for 2% (1:48) slope on access aisle
The proposed exception to ADAAG Section 502.3 is critical because it will be technically infeasible to meet the 2% (1:48) slope requirement in on-street parking accommodations in the same way that it is infeasible for sidewalks to meet the 5% (1:20) maximum slope requirements.
Width of Public Right-Of-Way must be 16 Feet
The 14-foot exception is not adequate and should be 4.6 m (15 ft). The rebuild to accommodate an accessible stall requires 1.5 m (5 ft) of sidewalk converted to access aisle at street level, plus a 1.8 m (6 ft) for a curb ramp using the perpendicular ramp, plus 1.2 m (4 ft) of landing/clear route at the top of the ramp. The total requirement to meet these minimums is 4.6 m (15 ft).
Parking at End of Block
Proposed guidelines state that where the right-of-way width for an access aisle is not provided, the parking space may be placed at the end of the block, which is where they are now typically located and signed. This is generally a reasonable alternative.
Water and Drainage Impact on Accessible Stall when Curb Line is Altered
Depending on roadway grade, cross slopes volume of and design for surface water removal, modifications to the curb alignment to accommodate the 1.5 m (5 ft) access aisle may adversely impact the access aisle, ramps or blended transitions with excess amounts of pooled water and in winter, ice. When the roadway, due to existing roadway constraints, utility locations and environmental conditions, cannot be designed to remove water from the on-street parking stall, an alternative parking accommodation, such as "Parking at the End of Block", should be allowed. This is especially critical in northern climates.
Winter Condition Snow Removal
Roadway plows cannot remove snow from an indented access aisle. Snow removal will be considered a secondary priority - delayed until after the major snow event is over and snow emergency work for main roads is complete. Northern states that have a substantial amount of snow over a long season, should be allowed to develop off-street parking facilities that will be plowed more quickly than the individual remote stalls could be.
Section 1109.3 Perpendicular or Angled Parking Spaces
Guideline Language: Where perpendicular or angled parking is provided, an access aisle 96 inches
Requested Change: The elements/conditions stated in this paragraph and additional information that is more comprehensive and clearly written already exists in ADAAG Sections 502.3 through 502.6. Access aisles should comply with ADAAG Sections 502.3 through 502.6 and specifically include an exception to ADAAG Section 502 requirements for slope.
Some exceptions should be provided so that reasonable percentages of the total available parking spaces and distribution for close access are considered and applied.
Suggested Language: Where perpendicular or angled parking is provided, an access aisle of 2440 mm (96 in) wide minimum shall be provided. It shall comply with ADAAG Sections 502.3 through 502.6 and shall connect to a pedestrian access route serving the space.
EXEMPTION: Although the access aisles are also used for wheelchair transfer to and from vehicles, the slope may be steeper than 2% (1:48) but shall not exceed the grade established for the adjacent roadway.
EXCEPTION: Reductions of parking capacity by over 10% are not required as long as a minimum of two accessible parking spaces per block are provided.
Justification Clarification and Exception required for 2% (1:48) slope on access aisle
The proposed exception to ADAAG Section 502.3 is important because it will be technically infeasible to meet the 2% (1:48) slope requirement in on-street parking accommodations in the same way that it is infeasible for sidewalks to meet the 5% maximum slope requirements.
In cases where the access aisle for on-street parking exceeds a slope of 2% (1:48), alternative parking accommodations should be considered to replace the one parking stall per block face requirement so that the parking stalls provided will better meet the objective of providing access for all.
Proposed Distribution of On-Street Parking Seems Excessive
The required access aisle is equal to the size of an average parking stall. This will result in a net reduction of two general parking stalls per block face. In some communities, this may excessively reduce the availability of general population on-street parking. Reduction of parking capacity by over 10% should not be required so long as a minimum of two accessible parking spaces per block are provided.
Section 1109.4 Curb Ramps or Blended Transition
Guideline Language: A curb ramp or blended transition complying with 1104 shall connect the access aisle to the pedestrian access route.
Suggested Language: See comments for 1104.
Justification: See comments for 1104
Section 1109.5 Obstructions
Guideline Language: 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.
Requested Change: Modify this section to provide for 0.6 m (2 ft) clearance to the curb along the parking space.
Suggested Language: No language is suggested at this time.
Justification: Elimination of All Obstructions Seems Excessive
There seems to be no logical reason for the ban on obstructions abutting the parking space. A 0.6 m (2 ft) clearance to accommodate door swing seems appropriate; however the elimination of all obstructions seems excessive. Space for unloading is part of the access aisle space requirements. Features such as light poles, trees and other street-scaping in the area that abuts the space but are outside a 0.6 m (2 ft) clear zone will not adversely affect the usefulness of the parking space. These features are important to the overall use, safety, and appearance of the street.
Section 1109.7.3 Displays and Information
Guideline Language: Displays and information shall be visible from a point located 1015 mm (40 in
Requested Change The wording of this section is somewhat unclear and no size is required for text.
Suggested Language Revise section to provide intended guidance.
Justification: Not Applicable
1111 Alternate Circulation Path
Section 1111.1 General
Guideline Language: Alternate circulation paths shall comply with 1111.
Requested Change: The inclusion of any other sections that must be adhered to regarding surfaces, cross slope, grades, etc.
Change "Alternate Circulation Path" to "Pedestrian Detour".
Suggested Language: Not applicable.
Justification: The clarification is necessary to set the baseline for the expected level of service and provide assistance to designers in the determination of the appropriate location of the alternate circulation path.
Pedestrian detour is preferred because it is an established and recognized term within the transportation industry.
Section 1111.3 Location
Guideline Language: The alternate circulation path shall parallel the disrupted access route, on the same side of the street.
Requested Change: Add exception.
Suggested Language: A pedestrian detour shall be parallel to the pedestrian access route on the same side of the street.
EXCEPTION: When a parallel path on the same side of the street is not technically feasible, pedestrians will be routed to the nearest facility. The pedestrian detour shall have adequate access and notification.
Justification: In construction zones it is not always desirable or safe to walk next to the construction site. Access for construction equipment and materials, the availability of right-of-way, and the safety of workers and pedestrians must be factored into the final determination in the creation of a pedestrian detour.
Kevin O'Reilly and Patrick E. Rodgers, October 7, 2002
OREGON PARALYZED VETERANS OF AMERICA
Dear Sirs:
Concerns and comments regarding the proposed "Assessable Public Right-of-Way.
We feel that there is a need to have consistence with the access rules, one source, not ADAA(I, ANSI, UFAS, UBC, Oregon State Statute, ECT, etc..
1101 Ambient Noise, Does this mean that my local train/jet/emergency vehicle and crosswalk will compete with each other any time of the day or night? (11062.3./1106.3.2)
1102.01 (New Construction) We are concerned that the phrase "The draft guidelines would not require the provision of sidewalks, streets crossings, street furniture, parking, or other pedestrian elements where none are intended." would lead to a great deal of access being not provided. This is not an issue in Oregon where we have Land Use Planning, but areas that do not it may be major issue.
1102.2 Additions and Alterations. The phrase "prorated" could be thorn in our side in Oregon. We bad to go a great deal of to effort to define 25%; I can't imagine what we will go thru defining "prorated"
1102.5.2 - Needs a better definition
1102.7 Exception #2 (ANSI) not needed, raised lettering for deaf.
1102.14 Parking, Do not agree with the 4 per block. In high-density city areas parking is already at a premium. We in Oregon have seen a dramatic increase in invalid Parking Placards do to the high expense of parking ($300 to $500 per month). Also the 4 per block could be an excessive number of spaces in these high-density areas.
1102.15 Loading Zones- does not match up with UBC 1105, which one will take president? I am obligated to follow UBC.
1103.3 Size-passing space, UBC 1109.4.2 requires 60 inches
1103.8 Refer to ANSI 303, which refers to 405, which states in 405.7 length to 60 inches
1103.8 Cross slope changed to 1:48
1104.2.1.3 Driveways, loading (48X48), Seems strange that landings are refereed to as
48" and 60".
1104.2,2.3 Is this to extend into the traffic way? And how do we handle the street crowning angles?
1105.3 3" per second? Was this done in a scientific manner? We question this rate of motion as being to fast for many people with mobility impairments. I rolled at speed that my friend, who had a stroke, walks at and I covered 42 fret in 20 seconds
1105.4 Does this mean that we can enforce Safety islands when existing streets are resurfaces and/or repaired?
1104.2.1.4 Flares. We feel that 1:10
1104.3.7 Over bike lanes? 1:20
1105.5 No Ref.
1106.2.3 Signals, See first item.
1108 Truncated domes, We are in favor of adding ANSI 705.3.3 to cover future technology i.e.; "Equivalent Delectability".
1109 Van size-Oregon law. We feel that some thing like ORS 447.223 (2)(b) "In addition, one in every eight assessable spaces, but not less then one shall be van assessable. A van assessable parking space shall be at least nine feet wide and shall have an adjacent access aisle that is at least eight feet wide". He name should also be changed to "Side Lift/Ramp Only" similar to Nevada Law.
1109 Angle- The side flare rules reference "1104" and "1104.2.1.4 Flares" 1:10
1109.7.1 Parking Meters -We are concerned with the "coin" insert requirement that requires "pinching". We feel there should be caution extended to local jurisdictions on parking meter rules.
1109.6 Placement- We feel that there two problems here, one Oregon Laws states clearly visible" to the Operator of the vehicle, where there is pedestrian hazard the sign should at a high enough not to be head hazard.
Thank you for your consideration;
Kevin O'Reilly, Advocacy Director
Patrick E. Rodgers, Advocate.
cc: Darrell Ackerman, ODC Access Comm. Chair
Maureen McCloskey, PVA Advocacy Director
Jeffrey S. Polenske, P.E., October 28, 2002
In June 2002, the Federal Access Board released its "Draft Guidelines for Accessible Public Rights-of-Way" as part of the review process required to adopt these guidelines and, in the future, make them law. Attached please find the City of Milwaukee's comments regarding the "Draft Guidelines for Accessible Public Rights-of-Way".
If you have any questions, please contact Jeffrey Dillon, of my staff, at [...].
Very truly yours,
Jeffrey S. Polenske, P.E.
City Engineer
Comments on the Draft Guidelines for Accessible Public Rights-of-Way
1) In Section 1101.3 Defined Terms the definition for Street Furniture is too broad, "elements.. .that are intended for use by pedestrians" could include handrails, benches, bus shelters, stairs, ramps, sidewalks, etc. The street furniture definition should define the way pedestrians will use these elements versus other elements such as sidewalks or curb ramps.
In addition, please include definitions for Alternate Circulation Path and Blended Transition in this section.
2) In Section 1102.2.2 Alterations, exceptions for compliance in making alterations in the right-of-way are allowed to be below the standard set by these guidelines if it is technically infeasible to fully comply. So, what does "technically infeasible" mean and who decides what is "technically infeasible"? Cost affects many, if not most, decisions made in City of Milwaukee street designs. Will cost be an allowable criterion when considering whether an alteration is "technically infeasible"? Perhaps the Access Board or some other entity should provide a guideline to provide a measure of when an alteration is "technically infeasible" and when partial compliance is allowed? Such a guideline may better help communities in making decisions about alterations.
3) Section 1102.14 On-Street Parking, as written, appears to call for one designated parking space per block face. Currently, the City of Milwaukee will install an accessible loading zone per request. Requiring a designated parking space on every block face will add a significant cost to the City and, in addition, may limit the City's ability to be flexible in terms of installing accessible loading zones where they are most useful. Further comments on On-Street Parking can be found below.
4) Section 1102.3 Alternate Circulation Path Street construction zones are inherently dangerous even for able-bodied pedestrians. It is not unusual to have to close pedestrian access on one side of the street during construction. In such situations, it may be impossible to provide an Alternate Circulation Path on the same side of the street.
5) In Section 1103.3 Clear Width it is unclear if the clear width is referring to the width between the front of walk and the back of curb or if this is the minimum width of the sidewalk. Does this mean that sidewalk, especially in terms of new construction, can be built without any space between the back of curb and the front of walk?
6) In Section 1103.4 Cross Slope the entire pedestrian access route, including sidewalks, street crossings, and, in addition, other elements would only be allowed to have a cross slope of 1:48
Another concern regarding cross slope of the pedestrian access route has to do with the inherent restriction against depressed driveways. The City of Milwaukee uses depressed driveways frequently to prevent damage to vehicles. Many of the suggestions made in the book Designing Sidewalks and Trails for Access, Part 2 for designing without the use of depressed driveways would not be feasible or practical in terms of future maintenance.
7) In Section 1104.2 Types Please define the term blended transition.
8) Section 1104 Curb Ramps and Blended Transitions Two separate curb ramps rather than a single ramp that opens diagonally into the intersection is recommended. However, State of Wisconsin statues dictate the placement of a diagonal ramp as the location of first choice; and the City of Milwaukee completed a costly multiyear initiative to comply with this directive. Without a source of additional funding, the replacement of the diagonal ramp with two parallel ramps would only be accomplished with street paving projects. As such, it could take decades before total conversion is complete.
In terms of semantics, in this section, the terms parallel and perpendicular should be more clearly defined as to the axis used to determine what is parallel or perpendicular.
9) In Section 1105.2.2 Cross Slope it would be impossible to ensure that the pedestrian access route would meet this requirement as it crosses an intersection. Forcing a cross walk to have a cross slope no greater than 1:48
10) Section 1105.3 Signal Phase Timing. Changing walking speed from the current 4.0 feet
11) Section 1105.4 Medians and Pedestrian Refuge Islands. Requires median islands to be six feet or larger in width. Milwaukee has roadways with 4-foot wide medians and numerous small refuge islands that will not meet this criterion.
12) Section 1105.5.3 Pedestrian Overpasses and Underpasses The requirement of an elevator where ever the difference in grade between the approach and the overpasses or underpasses exceeds 60 inches
13) Section 1105.6 Roundabouts. Roundabouts require pedestrians to select a safe gap in the traffic flow and motorists to yield the right of way, which can result in pedestrian accessibility problems. Roundabouts, however, are customarily installed in lieu of the traffic signal. We recommend that further study be undertaken on the safety of pedestrian movements in roundabouts prior to mandating that pedestrian activated signals be provided at each crosswalk in a roundabout and the placement of a continuous barrier along the street side of the sidewalk.
14) Section 1105.7 Turn Lanes at Intersections Right turn by-pass lanes at intersections are often controlled with either stop signs or yield signs. The proposed guidelines would mandate installation of pedestrian activated signals. We are unaware of any studies showing increased pedestrian injuries resulting from vehicle collisions at right turn bypass crossings that would warrant this installation.
15) Section 1106.2 Pedestrian Signal Devices. We have worked with the blind community in Milwaukee to provide audible pedestrian signals at locations adjacent to facilities that serve the blind and have higher numbers of visually impaired pedestrians crossing. The requirement to provide audible signals at every intersection seems excessive.
16) Section 1108.2.1 Curb Ramps and Blended Transitions outlines the requirement for the installation of a detectable warning surface at a curb ramp or a blended transition. Currently, truncated domes are considered to be the preference this type of surface. Truncated domes would pose problems for the City of Milwaukee on several fronts. There are serious concerns regarding increased difficulty in removing snow and ice because of the installation of truncated domes. In addition, maintenance of curb ramps with truncated domes is also of concern in that there is no information on how well the domes survive freeze/thaw cycles, salt from snow clearing operations, and the clearing of snow or ice from the curb ramp surface. Truncated domes would add a significant maintenance cost that the City of Milwaukee may not be able to meet. In addition, curb ramps with truncated domes that have broken or chipped off the sidewalk surface, may pose a safety hazard themselves.
17) Section 1109 On-Street Parking. Wisconsin state statutes permit a vehicle with handicap plates and/or placard to be parked in any legal parking space in excess of the posted time limit and without payment of any meter fee. The draft guidelines would require at least one accessible parking space on each block face. An access aisle at least five feet in width that does not encroach into the vehicular travel lane shall be provided to serve the space. Wherever the sidewalk width is greater than 14 feet