index previous comment next comment

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

Parking District

Total No. On-Street Spaces

Average No. Spaces per Block Face

Total No. Block Faces

Spaces required per Access Board Guidelines (1)

Spaces required per ADA Accessibility Guidelines (2)

Difference (% in excess)

Bethesda

766

(487.5%)

Silver Spring

994

101

(405%)

Wheaton

391

(350%)

Montgomery

Hills

(400%)

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. This is less than the minimum width of 14 feet required by the Access Board, to accommodate the recessed parking space area suggested in the draft guidelines. The Access Board's proposed remedy raises extreme safety concerns. For R-O-Ws too narrow to include an indentation, they propose to locate a handicap space at the end of the block, closer to a curb ramp within the width of each crosswalk. "Closer to a curb ramp" does not address the question of how to safely access the ramp when no designated access route has been provided.

In Montgomery County all on-street parking is provided parallel to the roadway and curb. Most CBD sidewalks have less than 14 feet of R-O-W, therefore the handicap spaces would have to be located at the ends of the blocks. Handicap patrons would be required to use the vehicular travel lanes to access the ramps at the ends of the blocks. These end spaces are frequently 50-100 feet away from the ramps, creating an extremely unsafe situation for disabled users.

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 of pedestrian access route has been located alongside the storefronts. In addition, several streets have been streetscaped by County initiated projects. Once again, many amenities have been made available which would not have been allowed if the 60 or 72 inch unobstructed pedestrian access route were provided.

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 in width, most of these patrons would be required to exit their vehicles into the flow of traffic. Due to the ever-present danger posed by adjacent traffic this is not considered a safe action, and is in direct conflict with the policy, dictated by our County Attorney, which highly discourages the on-street designation of these spaces. An exception is made when an adjacent store caters specifically to handicapped individuals, such as the Universal Artificial Limb store in Silver Spring, and where no nearby off-street parking exists.

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