On-Street Parking
Daniel G. Cole, August 28, 2002
I am currently employed as a traffic engineer with the City of Ithaca. I recently read an article in "Parking Today" concerning new changes in on-street parking. I have the following comments concerning these proposed changes.
I do not think that requiring on-street handicap parking on every block that has metered spaces is a good idea. We have some very narrow streets in Ithaca. In order to provide parking to existing businesses we have often shoehorned parking into a seven (7) foot lane width in order to maintain opposing 10' travel lanes. This is not a safe accommodation for handicap motorists and if we were required to eliminate all of the parking because we couldn't meet the new ADA standards it would lead to the ruin of downtown - businesses would move to the suburbs and urban sprawl would accelerate creating longer trips for commuters, greater fuel consumption, and poorer overall air quality. Widening the streets would be impossible because many of the historic buildings in our city have been here long before the automobile.
Further the new proposals are another example of how the federal government seems to lack an overall unified transportation plan for this country. These new ADA requirements would conflict with current SHPO standards, MUTCD regulations, and current statewide practices of trying to improve air quality.
Perhaps better effects could be made in attempting to get handicap motorists to take public transportation.
Daniel G. Cole
I have reviewed the new draft for the ADA Guidelines which are available on your web site and I would like to comment about article 1109.7 that address on street parking meter.
In many cities around the US the on street parking for disables is a combination of more than one single issue for the disable community that need to use these parking spaces.
one of the issue and the most controversial one is parking payment for the use of the parking space. Although in many cities the disable user can park for free, their is a growing outrage be the community for the abuse of this privilege by authorize and unauthorized users. The disable community is the first to suffer from this issue and public outrage.
In some cities the disable community are willing to pay for on street parking providing that the local authority will regulate the issue and will provide means for a disable person to pay for parking considering his/her limitation.
In the city of Buffalo a comprehensive study was done by the City which contracted the services of URS consulting. Together with the disable community they found that their is a technology available in the market to be utilize by the disable. This solution, which will be implemented by October 2002, will not require the disable to use existing parking meter or central location meter box, but have the meter it their car (IN CAR PARKING METER) for display. Thus resolving the issue of access to the on street meter, with 100% reliability which will make the on street parking issue easy to the user. The municipality will not lose revenue from the new guidelines of on street parking.
If you would like to receive additional information please contact me
Yehuda Mor
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
Gerard J. Fuccillo, R.C.E., October 28, 2002
Subject: Comments to the Draft Guidelines on Accessible Public Rights of Way
My name is Gerard J. Fuccillo , and I have been a Registered Civil Engineer in California for the past 30 years, 23 of which have been as a Consultant City Engineer for a small city in California. I am familiar with accessibility regulations since the 1973 Uniform Building Code, as well as the current ADA regulations as they apply to building and public facility accessibility. In my experience, I have designed and reviewed quite a few street, intersection and sidewalk projects, including alterations to public facilities and retrofit curb and corner ramps.
I have reviewed the Draft Guidelines on Accessible Public Rights of Way, and I have some serious concerns in regard to the application of these guidelines to small rural cities and areas, especially those with significant terrain. I realize that the guidelines are intended to apply to only new construction, alterations and additions; however the Federal courts and Department of Justice have already determined that an alteration of as little as a resurfacing of a street brings on the ADA requirements at street corners.
Unless limitations are specifically applied with these final guidelines, I am sure that it won't be long before the guidelines are applied to entire existing street systems when anything is altered.
Generally, I have found that there are inherent impossibilities of compliance in some of the guidelines, as well as safety hazards to all, should certain of the guidelines be applied in steeper terrain. A strict application of the guidelines would be an extreme financial burden to rural cities and areas with steep terrain in terms of construction and reconstruction costs in efforts to comply, and in litigation costs for failure to comply with the impossible, or for creating a safety hazard for all. There needs to be some outright exceptions to the guidelines, or a clear definition of "technically infeasible" and "maximum extent feasible" and who determines these conditions. Otherwise, we will be creating a veritable retirement program for advocate attorneys and their expert witnesses at the expense of the public. If the determination of compliance is left to a case by case basis, rest assured, it will a court case by court case basis.
Specifically, I would like to comment in the following areas:
1. Street Grade vs Curb Ramps and Blended Transitions. The guidelines and sketches of Curb Ramps and Blended Transitions in the guideline commentary assume that the world is flat, or less than 1:48
However, when one of the streets at an intersection exceeds 2% running grade, the cross grade at the threshold between the street and sidewalk needs to exceed the 2% cross grade requirement, and follow the street grade in parallel or perpendicular curb ramps, or be a combination of the street grades in blended transitions. The detail for the Blended Transition, shows a corner where two sidewalks have converging grades; here it is easy to flatten the grade at the threshold corner. Unfortunately, this condition is present at only two of the corners of a four corner intersection of streets intersecting at grade. The other two corners will have diverging grades where the slope of the one street needs to blend to the grade of the other street over the threshold.
Up to about 5% street grade, the running grade requirement of 1:12
2. Tabling of Intersections, Crosswalk Cross Slope. The flattening of intersections to create a maximum 2% cross slope over a crosswalk is really not an option on existing street systems where streets intersect at over 2% grade. One would need to reconstruct all four legs of the intersection for quite some distance back from the intersection, depending upon the street grade, in order to taper the street grade to the 2% intersection slope. On existing street systems crosswalk cross grade needs to follow the running grade of the street.
Although tabling can be accommodated on complete new intersections and street systems, it would probably be unwise from a safety standpoint to flatten intersections on street grades over 5%. One would be creating a ski jump effect in the downhill direction, as well as visibility problems in the uphill direction on steeper grades. On steeper street systems with short blocks, the tabling could create out control vehicles in the downhill direction, as well as invisible crosswalks on the far side of the intersection to the uphill vehicle. The line of sight of a vehicle approaching the intersection in the uphill direction could very well be over the head of a pedestrian in the far side crosswalk, in the distance require to stop, on steep streets with sharp breaks in grade.
3. On Street Accessible Parking. The requirement for one accessible on street parking space per block face will result in inequity and extreme resentment in small cities and areas. In the small city I serve, we have short blocks, with only 6 to 8 on street parking spaces per block face. On street parking is very dear in small cities, and providing a ratio of 1:6
Additionally, on street grades in excess of 2%, one would be putting the handicapped driver in harm's way by providing on street accessible parallel parking. In small cities with narrow streets and right of ways, the exception to the access aisle (14' curbline to right of way) will be taken every time, thereby forcing the unloading area into the traveled way on grades in excess of 2%.
The very purpose of putting accessible spaces in parking lots is to provide a safe unloading area. Putting accessible spaces on street is counter to this purpose, especially where the street grade is in excess of 2%.
The requirement for on street accessible parking should be dropped or qualified to only where the street grade is 2% or less, and to angled or perpendicular parking only. In regard to the ratio, one should also count the many accessible spaces placed in public parking lots in a downtown area, and provide a ratio commensurate with overall handicapped population of an area versus the total population of that area.
In summary, it is hoped that the Access Board will consider the comments above and provide some definite exceptions and limitations to the application of the final guidelines to be adopted. The exceptions and limitations could be based upon population of an area. rural or urban, and of course, terrain. In as much as the ADA has established an accessible route standard of 5%, it would seem logical that 5% street grade should be the limitation of application of the guidelines. They could establish a simple 5% rule, i.e., where the street grade exceeds 5%, the guidelines do not apply.
Additionally, it is hoped that there is a engineering review of all of the details of the guidelines for safety and practicality prior to their adoption. Items like truncated cones and audible signals could actually result in safety hazards for all, and liability for the local jurisdiction. Sometimes I think we get caught up on the details, and lose sight of the overall safety and practicality of the regulations.
Very truly yours,
Gerard J. Fuccillo, R.C.E.
Robert Gorski, October 29, 2002
Dear U.S. Access Board:
I write to comment on 4 areas of the proposed guidelines for Public Rights-Of-Way (PROW): roundabouts, truncated domes on curb ramps, accessible pedestrian signals, and scoping for on-street parallel parking.
ROUNDABOUTS The wording of section 1105.6.1 needs clarification. Requiring barriers "along the street side of the sidewalk where crossing is prohibited" includes locations were a strip of parkway grass or bushes or flowers lies between the sidewalk and the curb. I find it hard to believe that barriers are needed as such locations.
To comply with section 1105.6.1 "splitter islands" would have to be totally surrounded by a barrier except for where the pedestrian way crossed the island. I believe that the degree of safety that should be sought for could be provided more simply and at less cost by having barriers along both sides of the pedestrian way that crosses through the island. Where the rest of the island contained a parkway, no barrier would be required.
How will section 1105.6.1 as written apply to roundabouts where the pedestrian crosswalks are not located at or near the circular "rim" of the roundabout, but further away and down the streets that lead into the roundabout. For what distance must the continuous barrier "along the street side of the sidewalk" extend? Section 1105.6.1 as written does not say.
Would truncated domes comply with section 1105.6.1's requirements for a "continuous barriers?"
This section, despite the few words that comprise it, deserves much thought.
Also, the photograph that the U.S. Access Board uses to illustrate a traffic roundabout does not have pedestrian barriers. If no roundabout with barriers exists, I recommend the Board get one established, see that it works the way you want it to work, and then photograph it.
TRUNCATED DOMES ON CURB RAMPS I recommend the U.S. Access Board arrive at a conclusion over this long standing issue similar to the California State Building Code. Truncated domes are needed by most blind individuals only where the slope is too gentle to be a cue by itself. It is unnecessary to have truncated domes on all curb ramps.
Additionally, truncated domes on curb ramps with greater than gentle slopes become a problem for wheelchair users, walker uses, and many semi-ambulatory pedestrians. On greater than gentle slopes, truncated domes become a rough, uneven surface that interferes with balance for semi-ambulant individuals and, for others, with maintaining control over mobility aids - particularly rigid-frame wheelchairs with solid rubber tires.
Installing truncated domes on a slope significantly increases the bumpiness of the ride for wheelchair and walkers users. For some, the ride will be more than an unpleasant annoyance, it will be physically painful. Here in the city of Pasadena, California, I have encountered over the years several wheelchair users who complain of joint pain when they roll over level sidewalk that has been textured to appear historic, and the unevenness of this surface does not approach the awkward bumpiness people will experience if they must negotiate curb ramps with truncated domes.
I myself use a power wheelchair and have experience with truncated domes, and if they are installed on new and altered curb ramps with greater than gentle slopes, the U.S. Access Board will be forcing me back to the 1960s, when I wheeled about and crossed streets by using driveways near intersections and then either "jay rolling" across the street to another driveway, or traveling along the gutter, crossing the street inside the crosswalk, and then traveling along another gutter to a driveway at which I could gain access again to the public sidewalk. Granted, driveways have lips that are bumpy, but that is only one bump and not a flight of bumps, like I will encounter if truncated domes are installed on all new and altered curb ramps.
Also, I submit that truncated domes on curb ramps at greater than gentle slopes do not comply with existing ADAAG Appendix A4.5.1 which advises (in part) that an accessible pathway must have a surface that is "stable and regular," and that "irregular surfaces such as cobblestones can significantly impede wheelchair movements." I would like to add that even when a cobblestone surface is "regular," it remains a surface to avoid.
Lastly, consider this hypothetical situation: A wheelchair user, a user of a walker with small front wheels, and a semi-ambulant person all cross a street and face a choice of two curb ramps leading up to the public sidewalk. One curb ramp has truncated domes on it and the other does not. Which individuals will choose the ramp without domes? The answer, I submit, is all of them because no one in their right mind wants to ascend a ramp of bumps.
ACCESSIBLE PEDESTRIAN SIGNALS I support the provision on APS devices at street intersections. At the same time, I recommend that the provision on locator tones be changed to require these tones only where the APS devices are located an atypical distance from the street corner where they are installed.
In Pasadena, the municipal government three years ago installed APS devices at a very busy intersection in a commercial district. The devices have vibrating arrows, audible messages, and Braille and raised character street labels and are mounted on light standards at a distance from the crosswalk that is typical. The devices do not have locator tones and do not use chirps and beeps as signals. The local government has received positive feedback from several blind individuals who reside in the city. Moreover, in the year 2000 a public celebration of the 10th anniversary of the ADA brought visitors with disabilities to the downtown area and there were reports of blind visitors being pleased by the APS devices.
Two years ago, administrators at the California Institute of Technology contacted the local government and offered to purchase APS devices if the city would install and maintain them at two intersections near the Institute. Motivating the Institute was a desire to assist two employees with vision impairments cross busy streets which were part of each employee's walking path to the Institute.
ON-STREET PARALLEL PARKING I recommend that the scoping provision be significantly reduced. The current provision is a "one size fits none" solution to the problem of inaccessible street parking. The different lengths of city and especially suburban blocks, the frequency with which parallel parking options are used on different streets, and the presence of nearby off-street parking are all legitimate factors in determining a scoping provision for accessible on-street parking.
And what about streets where parking is permitted only within a small portion of the block face? How can a scoping provision legitimately require two accessible spaces in that situation?
Lastly, this scoping provision would seem in many instances to result in a greater percentage of accessible parking spaces per total number of spaces available than is required by the ADAAG scoping provision for accessible spaces at parking lots.
No matter how the final scoping provision is written, the current provision in the proposed guidelines is having a deleterious effect at the present time in California, where state law permits municipalities to designate parking spaces as reserved for disabled individuals by painting the curb blue. Awareness of the PROW guidelines having specifications for accessible on-street parking spaces has caused parking administrators in Pasadena and at least a handful of other localities to deny requests from disabled people for "blue curb" parking spaces. Such requests typically are from disabled people needing convenient access to their homes, places of worship, schools attended by their children, and other critical sites.
Requests are being denied because parking administrators fear that blue curb spaces are out of compliance with what will likely be a coming provision in the ADAAG. I hope the Access Board agrees that blue curb spaces can be provided at the present time without having to be removed if a provision for accessible on-street parking becomes part of the ADAAG. Further, I hope the Board also agrees that even if a provision for accessible on-street parking becomes effective, blue curb spaces can continue to be provided as long as this is not done in lieu of complying with provisions in the ADAAG.
I urge the Access Board to announce that the proposed provision on accessible on-street parking does not invalidate nor put into jeopardy blue curb parking spaces.