A parking meter shall be located at the head or foot of the parking space so as not to interfere with the operation of a side lift or a passenger side transfer
EXCEPTION: Where parking meters are not provided at the space, but payment for parking in the space is included in a centralized collection box or paying station, the space shall be connected to the centralized collection point with a pedestrian access route.
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
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
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