J. Tom Coleman Jr.

October 25, 2002

Georgia Department of Transportation

Subject: Comments on the proposed "Guidelines for Accessible Public Rights-of-Way"

Dear Mr. Windley:

The Georgia Department of Transportation (GDOT) completely agrees with the concept of the ADA that no person should be denied services because that person has a disability. The GDOT has reviewed the proposed "Guidelines for Accessible Public Rights-of-Way" dated June 17, 2002. Based on the review, some of the requirements should be given further consideration before implementation.

The GDOT has also reviewed the AASHTO comments on the proposed ADA guidelines and agree with their recommendations. The GDOT comments were developed independently but address many of the same issues.

Several of the proposed requirements will have major impacts on project design on required Rights-of-Way. If the plans for a project are near completion, the plans would need to be changed, the Environmental Document would need to be reevaluated and additional R/W would need to be acquired which will result in a considerable delay in letting the project for construction. When the text of the document has been finalized, the required implementation date should be given careful consideration.

Attached are the GDOT comments on the proposed ADA guidelines for public Rights-of-Way.

Sincerely,

Signed by Commissioner Coleman
J. Tom Coleman Jr.
Commissioner


Attachments


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Comments on the Proposed ADA Guidelines for Accessible Public R/W




The Georgian Department of Transportation (GDOT) completely agrees with the concept of the ADA that no person should be denied services because that person has a disability. However, the proposed "Guidelines for Accessible Public Rights-of-Way" dated June 17,2002 specify some requirements that we feel should be given further consideration before implementation.

The GDOT has reviewed the AASHTO comments on the Proposed ADA Guidelines and agrees with their recommendations. The GDOT comments were developed independently but address many of the same issues.

Overview:

Several of the major issues are addressed in general in the Synopsis. More specific comments are addressed in the responses to the individual sections.

The ACCESS BOARD has received many comments that have been posted on their website.

The comments seemed to fit into two categories. The first type response was from persons with disabilities or groups representing persons with disabilities. These comments were generally short and contained references to specific items. Sometimes the comments were in support of or opposed to an item. For example, the visually impaired groups generally supported the detectable warnings at the bottom of the ramps and the groups representing persons with mobility and balance disabilities considered the detectable warnings a tripping hazard to walkers and an inconvenience to persons in wheelchairs. The varied responses from the persons with different viewpoints indicate that there is no solution that satisfies all users in all situations.

The second type of response was from persons or groups that will implement the design requirements. These responses were generally longer and pointed out that many of the requirements would have consequences that the Access Board and the individual members of the Board had not intended or anticipated. Often these responses could be summarized by the following statement: Change the "design requirements" to "design recommendations." This will allow the Engineer to consider all the factors influencing the area in the design of the project.

Following the same thought, as written the only allowable reason for not meeting ALL the design requirements is if it is "Technically Infeasible" to meet the requirements. (And this is only allowed on "alterations", new construction must meet all the Design Requirements.) Technically Infeasible is not defined in the ROW section but a definition is needed. Also, the DOJ Title II Technical Assistance Manual specifically states that when determining Technical Infeasibility, cost is not to be considered. When a roadway type project is being constructed on the R/W, and enough money is available, anything can be built, therefore nothing is technically infeasible. In a slight contradiction, the DOJ CFR states that if you have to remove a load bearing wall in a building then complying with the design requirements is Technically Infeasible. More guidance is required.

The Dept. of Justice, Housing and Urban Development, Dept. of Interior, Dept. of Labor and possibly other agencies have included guidance for not meeting the ADA design requirements in their respective CFRs. Some of the guidance is not in complete agreement but generally they allow deviation from the Design Requirements due to "Technical Infeasibility", "Conflicts with existing law to protect historic resources", "Disproportionality" of the cost of satisfying all the ADA design requirements with the project cost, "Undue Administrative Burden", "Undue Financial Burden" and "Fundamental Alteration of the Nature of the Service". The various CFRs generally require that the head of the agency approve the deviation from the Design Requirements. The FHWA CFR simply states that "wheel chair ramps and other features that may be required to meet ADA are required". The FHWA is the agency that oversees most federal monies spent on public R/W. The FHWA has not provided any usable guidance (that the ADA required them to provide by 1992) on when exceptions to the ADA Design Requirements are justified therefore, the guidance must be included in this document. Also, it is unclear whether guidance included it this document or guidance included in the various CFRs will control.

To follow up on the "unintended consequences" of these requirements, if cost cannot be considered when determining technical infeasibility and if the design parameters are adopted exactly as written, many urban projects will not be built. The disruption to the adjacent properties and the surrounding communities will be too severe. The end result of these requirements (to provide a high level of accessibility) will be less accessibility in areas that would have been improved. The changes to the proposed ADA Design Requirements that the GDOT proposes are to ensure that this is not the result of the ADA Design Requirements.

Whether or not cost can be DIRECTLY considered when determining whether it is necessary to comply with the ADA Design Requirements, the cost of compliance WILL be considered. The funding of projects for new roadways and roadway improvements may seem to be infinite to persons not familiar with the magnitude of these projects, however there is a limited amount of money available and an infinite demand for these funds. Also, the funding is usually divided into categories and specified for certain uses. (For example, resurfacing, intersection improvement, Interstate Highways, bridge rehabilitation, etc.) If one project is very costly, either the project will not be constructed or other projects in that funding category will not be constructed in order to fund the project that is constructed.

The GDOT believes that the intent of the ADA was to provide better access (and service) to everyone (including persons with disabilities), not lower the level of access (and service) to everyone equally.

There is an article in the 9/19/02 edition of the Govt. Computer News about problems providing GIS maps over the Internet. The information has to be provided in usable form to all users to comply with Section 508 of the 1998 ADA Amendment. It would be unfortunate (but not unexpected) if this service was withheld from all citizens in order to comply with the ADA. There is no technology available for blind users to obtain the same information (in an easily useable format) that sighted users obtain, therefore the result may be less service for everyone. (Including the blind person that previously had a sighted friend or family member obtain and interpret the information.)

The ADA does not require that sidewalks be included in roadway projects but if sidewalks are provided the ADA requires that they must be useable by all users. If this premise is used to judge the requirements listed in the "Guidelines for Accessible Public Rights-of-Way", some of the requirements do not appear to fall under ADA regulation. For example, requirements for traffic signals where none would be required except by these guidelines. The GDOT recommends that all the requirements be reviewed and any requirements that are not definitely issues covered by the ADA be removed or changed to recommendations.

There appear to be some discrepancies in the commentary and between the commentary and the proposed text. For example: Commentary 1102.1 "The draft guidelines would not require the provision of sidewalks, street crossings, street furniture, parking or other pedestrian elements where none are intended." Commentary 1105.2 – Crosswalks – "…specifications apply to both marked and unmarked crossings, wherever pedestrian travel is not prohibited." TEXT 1102.1 "All areas of newly designed and newly constructed facilities in public rights-of-way and altered portions of existing facilities … shall comply with Chapter 11.

The final document should be clear and concise. The commentary provided should clarify and provide examples for the Design Requirements. All discrepancies in the commentary (from the text of the requirements) should be omitted or clearly noted as minority opinions.

There are also some discrepancies between the proposed Chapter 11 requirements the previous sections (Ramps are also addressed in Chapter 405 and Curb Ramps are also addressed in Chapter 406). If the requirements are different on public R/W it should be noted in the other chapters whenever there is a difference.

Several of the design requirements for cross slope, grade breaks, etc. are covered in "1103 Pedestrian Access Route". The same requirements are duplicated other sections (ramps, transitions, crosswalks etc.). Consider eliminating the requirements from the other sections since by definition these areas are part of the "Pedestrian Access Route".

The guideline commentary stated "guidelines depart from the advisory committee's report in several areas, which are detailed in the following discussion." There are several items that differ from the Jan. 2001 report in the proposed text that are not discussed. (Possibly "Changes in level" (1103.8) should be "Grade Breaks" and "Grade Breaks" (1104.3.40) should be omitted.)

As an aside: There was an ADA seminar presented in Atlanta last year. Several of members of the Public R/W committee were present. Several questions were posed about the effect of implementing various design parameters. A common answer was "Oh, you would not have to meet that requirement, it isn't reasonable in that case". As written, the requirements do not allow for that solution. The only acceptable solution is "MEET THE DESIGN PARAMETERS".

The SCOPING REQUIREMENTS section needs to be expanded and clarified. Chapter 1102.2.2 states "Where existing elements or spaces in the public R/W are altered, each altered element shall comply with the applicable provisions of Chapter 11."

When a road is resurfaced the crosswalks are altered. This provision requires the cross slope to be less that 2.08% in the crosswalk. This requires that the intersection be "tabletopped" and requires vertical grade changes all of the approach roadways. This requirement will essentially prohibit any resurfacing projects in urban areas where any existing grade or crossslope in the intersection exceeds 2%. (Even if the project would remove severe ruts, vertical lips, and potholes in the crosswalk that make the existing crosswalk unusable for pedestrians with disabilities.)

The "tabletopping requirement will have severe negative impacts on all projects where the natural terrain slopes exceed 2%.

The commentary on 1105.2 – Crosswalks – that states that "…specifications apply to both marked and unmarked crossings, wherever pedestrian travel is not prohibited." If this is intended to be a true statement, it should be reconsidered. Other sections require a pedestrian activated signal where a right turn slip lane is present. A "slip lane" definition should be added but the figures show a right turn movement separated by an island. This would require a traffic signal at nearly every intersection on a multilane road. Also, when a business obtains a driveway access permit on a corner, GDOT requires the addition of a right turn lane. This provision would also require a signal at the intersection (which the developer would be happy to do since it would increase the value of his business). The MUTCD has very specific warrants for the installation of signals that are based on years of experience to provide the best compromise between motorist safety, pedestrian safety and overall usability of the Rights-of-Way. If the Access Board decides that these warrants should be ignored, the decision to ignore them should be based on documented research.

Most GDOT projects are "alterations" in some (or many) respects. For instance even a new roadway on a new location generally follows the existing terrain and crosses existing roads that have homes and businesses near the newly created intersection (or interchange). In the design process we attempt to minimize the impact on these homes and businesses while providing a road that is safe for the traveling public.

As written, the guidelines only allow a deviation from the design parameters when the project is an "alteration" (or where an "addition" project connects with existing construction) and when it is "technically infeasible" to meet the requirement. (Although the Chapter 2 Scoping Requirements in the ABA/ADA final draft commentary (p16) mentions "disproportionality" it is not mentioned in the actual text.)

Additional guidance on what is "technically infeasible" should be provided. When building a road it is usually "technically feasible" to do anything if enough money is available.

The 1999 publication "Accessible Rights of Way, A Design Guide" has a more realistic approach for not meeting the ADA design requirements. "Technically Infeasible", "Fundamental Alteration of the Nature of the Project" and "Undue Burden" were mentioned as justification for not fully complying with the design requirements.

Note that the GDOT has a finite amount of money available. If complying with all of the ADA design parameters adds excessive cost to a project then fewer projects will be built. The overall effect will be fewer projects constructed and fewer accessibility improvements therefore there will be less overall benefit provided to disabled users. (For example, table-topping an intersection in a lightly populated area as part of a major roadway reconstruction project could easily cost an additional $ 2 million on a $20 million contract. That $ 2 million could upgrade 2 or 3 intersections in a highly urbanized area with large numbers of pedestrians.)

The CFR for the Dept. of Justice, Labor, HUD give guidelines on when exceptions to the ADA design parameters are justified. (But the justifications are not the same.) In order to provide consistency in implementing these requirements this information should be included in the Accessibility Guidelines.

For example:

CFR 35.150 states:



A public entity shall operate each service, program, or activity so that the service, program, or activity, when viewed in its entirety, is readily accessible to and usable by individuals with disabilities. This paragraph does not --

(1) Necessarily require a public entity to make each of its existing facilities accessible to and usable by individuals with disabilities;

(2) Require a public entity to take any action that would threaten or destroy the historic significance of an historic property; or

(3) Require a public entity to take any action that it can demonstrate would result in a fundamental alteration in the nature of a service, program, or activity or in undue financial and administrative burdens. In those circumstances where personnel of the public entity believe that the proposed action would fundamentally alter the service, program, or activity or would result in undue financial and administrative burdens, a public entity has the burden of proving that compliance with § 35.150(a) of this part would result in such alteration or burdens. The decision that compliance would result in such alteration or burdens must be made by the head of a public entity or his or her designee after considering all resources available for use in the funding and operation of the service, program, or activity, and must be accompanied by a written statement of the reasons for reaching that conclusion. If an action would result in such an alteration or such burdens, a public entity shall take any other action that would not result in such an alteration or such burdens but would nevertheless ensure that individuals with disabilities receive the benefits or services provided by the public entity.

The GDOT recommends the wording in this section be expanded to address situations where it is not necessary to meet all the design requirements and included in these guidelines. This section should describe and give guidance on "Technically Infeasible", "Fundamental Alteration of the Nature of the Project", "Undue Burden", Undue Financial Burden", and "Disproportionality". The section should also address how to handle conflicts with other Federal laws that deal with preserving historical and archeological sites, wetlands, and other natural resources. This section should also address the level of documentation and level of approval required.

Making the design parameters "recommendations" instead of "requirements" would solve many of these problems.

As written it is not defined precisely where pedestrians must be accommodated on the public R/W. This should be addressed.

GDOT Commentary: It seems that the disruption to the surrounding area, cost, and impacts on the safety of the motorists should be weighed against the need for pedestrian accommodation. This should be an Engineering Decision not a mandated requirement. The GDOT often uses curb and gutter and sidewalks to minimize the R/W requirements (or stay on existing R/W) not to provide pedestrian accommodations. Without relaxation of the design requirements (or allowing engineering judgement) many projects will not be built. The projects improve usability (even though they might not meet all the design requirements) for disabled users.

When the text of the document has been finalized, the required implementation date should be given careful consideration. Several of the proposed requirements will have major impacts on the design of the project and on the required Rights-of-Way. A lead time of 2 years would not be unreasonable for full compliance with some of the proposed requirements. This would allow time to reevaluate the Environmental Document, change the plans and acquire the additional Rights-of-Way.

The following is the Text of the Draft Guidelines for Accessible Public Rights-of-Way with GDOT comments and recommended changes noted.

1101 Application and Administration (referenced standards and defined terms)
1102 Scoping Requirements
1103 Pedestrian Access Route
1104 Curb Ramps and Blended Transitions
1105 Pedestrian Crossings
1106 Accessible Pedestrian Signal Systems
1107 Street Furniture
1108 Detectable Warning Surfaces
1109 On-Street Parking
1110 Call Boxes
1111 Alternate Circulation Path

1101 Application and Administration

1101.1 General. For the purposes of these requirements, the terms listed in section 1101.3 shall have the indicated meaning.

1101.2 Referenced Standards.

1101.2.1 MUTCD. Copies of the referenced standards may be obtained on-line from the Federal Highway Administration at http://mutcd.fhwa.dot.gov/.

MUTCD 2000-Millennium Edition Manual on Uniform Traffic Control Devices.

GDOT Comment – Add AASHTO 2001 Design Guide to the list on standards

1101.3 Defined Terms.

GDOT Comments –

Add definitions for:

Slip Ramp

Perpendicular Curb Ramp

Parallel Curb Ramp

Addition

Alteration

Blended Transition

Technically infeasible

Disproportionality

Undue Financial Burden

Undue Administrative Burden

Fundamental Alteration of the Nature of the Project

Agency that approves ADA design requirements exceptions

GDOT Recommended Definitions -

New facility: A new roadway on new alignment where the horizontal or vertical alignment, or crossslope are not controlled by an existing facility.

Alteration: A project or portion of a project where the horizontal or vertical alignment or crossslope of the roadway are controlled by an existing facility is an "alteration". No alterations may be done that have the effect of decreasing accessibility.

Fundamental alteration in the nature of a project: An improvement that changes the basic concept for the project.

Program Accessibility: If the facility is accessible to people with disabilities through another method or alternative routes, the facility may not be required to comply with all ADA design parameters. Note that curb cut ramps are specifically named as a required element and cannot be excluded.

Undue financial burden: If the cost of providing or maintaining a facility that fully complies with ADA design parameters is prohibitively expensive or the required future funding is not guaranteed, full compliance with the ADA design parameters may be considered an undue financial burden.

For small projects, if complete compliance with the ADA design parameters adds over 20% to the total cost of the project, complete compliance is not required (but should be considered). However, the facilities shall be improved to the maximum extent possible using the 20% additional costs.

For large projects, if complete compliance with the ADA design parameters adds over 20% to the cost of the area of the project where the improvement is needed, complete compliance is not required (but should be considered). However, the facilities shall be improved to the maximum extent possible using the 20% additional costs. (This is intended to address major alteration projects where small areas are not in compliance with the ADA design parameters.)

Disproportional: If the cost of constructing a project (or portion of a project) that fully complies with ADA design parameters is prohibitively expensive full compliance with the ADA design parameters may be considered Disproportional.

For small projects, if complete compliance with the ADA design parameters adds over 20% to the total cost of the project, complete compliance is not required (but should be considered). However, the facilities shall be improved to the maximum extent possible using the 20% additional costs.

For large projects, if complete compliance with the ADA design parameters adds over 20% to the cost of the area of the project where the improvement is needed, complete compliance is not required (but should be considered). However, the project shall meet the ADA Design Requirements to the maximum extent possible using the 20% additional costs. (This is intended to address major projects where small areas are not in compliance with the ADA design parameters.)

Technically infeasible: If complying with the ADA design parameters require that the roadway alignment, grade, sight distance or clear zone not to meet AASHTO desirable requirements then complying with ADA design parameters is "technically infeasible".

Conflicts with other laws that protect historical, cultural, or natural resources make complying with ADA design parameters "technically infeasible".

Note that if complete compliance is "technically infeasible" the facility shall be modified to comply with ADA design parameters to the "maximum extent possible".

Accessible Pedestrian Signal. A device that communicates information about the pedestrian WALK phase in non-visual format.

Accessible Route. A continuous, unobstructed path that complies with Chapter 4.

GDOT Comment:

The definition of Accessible Route should be clarified. It is not clear whether shoulders are an "accessible route" on a road with no curb and gutter and/or no sidewalk.

Channelizing Island. Curbed or painted area outside the vehicular path that is provided to separate and direct traffic movement, which also may serve as a refuge for pedestrians.

Cross Slope. The slope that is perpendicular to the direction of travel. This is usually called superelevation on curves in the public right-of-way (see superelevation).

Crosswalk. That part of a roadway at an intersection that is included within the extensions of the lateral lines of the sidewalks on opposite sides of the roadway, measured from the curbline or, in the absence of curbs, from the edges of the roadway or, in the absence of a sidewalk on one side of the roadway, the part of the roadway included within the extension of the lateral lines of the sidewalk at right angles to the centerline. Also, any portion of a roadway at an intersection or elsewhere that is distinctly indicated for pedestrian crossing by lines or other markings on the surface.

GDOT Comment:

The definition of crosswalk appears to say that a crosswalk is only present if there is sidewalk present or if there is a "marked" crosswalk. While this definition makes it easier to comply with the ADA Design Requirements, it appears to conflict with the text of in other sections of the requirements and with the commentary.

Curb Line. A line at the face of the curb that marks the transition between the sidewalk and the gutter or roadway.

Curb Ramp. A ramp cutting through a curb or built up to it.

Detectable Warning. A surface feature built in or applied to walking surfaces or other elements to warn of hazards on a circulation path.

Dynamic Envelope. The clearance required for a rail vehicle and its cargo overhang due to any combination of loading, lateral motion, or suspension failure.

Element. An architectural or mechanical component of a building, facility, space, site or public right-of-way.

Facility. All or any portion of buildings, structures, improvements, elements and pedestrian or vehicular routes located on a site or in a public right-of-way.

Grade. (See running slope).

Grade Break. The meeting line of two adjacent surfaces of different slope (grade).

Locator Tone. A repeating sound that identifies the location of the pedestrian push button.

Pedestrian Access Route. An accessible corridor for pedestrian use within the public right-of-way.

GDOT Recommended Definition

Pedestrian Access Route. An accessible route, designated by the responsible agency, for pedestrian use within the public right-of-way.

This will allow the "rural" projects to be excluded from ADA requirements.

Public Right-of-Way. Land or property, usually in a corridor, that is acquired for or devoted to transportation purposes.

Roundabout. A circular intersection that has yield control of entering traffic, channelized approaches, counterclockwise circulation, and appropriate geometric curvature to limit travel speeds on the circulatory roadway.

Running Slope. The slope that is parallel to the direction of travel expressed as a ratio of rise to run. In the public right-of-way, this is usually called grade, and is expressed in percent.

Sidewalk. That portion of a public right-of-way between the curb line or lateral line of a roadway and the adjacent property line that is improved for use by pedestrians.

GDOT Comment:

What does "improved for use by pedestrians" mean? We are concerned that this could be interpreted to mean shoulders on "rural" projects or the flat graded area behind the curb if no concrete sidewalk is present.

This definition is critical. For instance if the paved shoulder is a "sidewalk", the ADA design requirements apply to rural projects. The GDOT requires separate right turn lanes on multilane rural roads at all intersections as a safety feature to allow the right turning traffic to move out of the high speed travel lanes. These requirements would mandate that pedestrian activated signals with locator tones be provided at essentially all intersections.

Splitter Island. A flush or raised island that separates entering and exiting traffic in a roundabout.

Street Furniture. Elements in the public right-of-way that are intended for use by pedestrians.

Superelevation. Cross slope on a curve in the roadway (see cross slope).

Walk Interval. That phase of a traffic signal cycle during which the pedestrian is to begin crossing, typically indicated by a WALK message or the walking person symbol and its audible equivalent.

1102 Scoping Requirements

1102.1 General. All areas of newly designed and newly constructed facilities in public rights-of-way and altered portions of existing facilities in public rights-of-way shall comply with Chapter 11.

GDOT Recommended wording:

1102.1 General. All areas of newly designed and newly constructed facilities in public rights-of-way and altered portions of existing facilities in public rights-of-way that include provisions for pedestrians shall comply with Chapter 11.

GDOT Comment:

The SCOPING REQUIREMENTS need to be expanded and clarified. If the exceptions recommended in 1102.2.2 (specifically Fundamental Alteration of the Nature of a Project are not allowed, when a road is resurfaced the crosswalks are altered. This provision requires the cross slope to be less that 2.08% in the crosswalk. This requires that the intersection be "tabletopped" and requires vertical grade changes all of the approach roadways. This requirement will essentially prohibit any resurfacing projects in urban areas where any existing grade or crossslope in the intersection exceeds 2%. (Even if the project would remove severe ruts, vertical lips, and potholes in the crosswalk that make the existing crosswalk unusable for pedestrians with disabilities.)

The same situation will exist if a traffic signal needs to be upgraded. As written, a signal could not be upgraded to allow for protected pedestrian movements without "tabletopping" the intersection.

1102.2 Existing Public Rights-of-Way. Additions to existing public rights-of-way shall comply with 1102.2.1. Alterations to existing public rights-of-way shall comply with 1102.2.2.

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.

1102.2.2 Alterations. 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.

GDOT Comment: Define Spaces as used above.

EXCEPTION: In alterations, where compliance with applicable provisions is technically infeasible, the alteration shall comply to the maximum extent feasible.

GDOT Recommended Wording

EXCEPTION: In alterations, the project shall comply with applicable provisions unless the following applies. If full compliance is not required, the alteration shall comply to the maximum extent feasible.

A public entity shall operate each service, program, or activity and construct each project so that the service, program, or activity, and constructed project when viewed in its entirety, is readily accessible to and usable by individuals with disabilities. This paragraph does not --

(1) Necessarily require a public entity to make all areas of its existing facilities accessible to and usable by individuals with disabilities; or

(2) Require a public entity to take any action that would threaten or destroy the historic significance of an historic property; or that conflict with other laws that protect natural or archeological resources or cemeteries; or

(3) Require a public entity to take any action that is technically infeasible; or

(4) Require a public entity to take any action that it can demonstrate would result in a fundamental alteration in the nature of a service, program, or activity or in undue financial and administrative burdens or in a fundamental alteration of the nature of the project. Also, if the additional cost of fully complying with the ADA Design Requirements exceeds 20% of the cost of the project in the area affected by the improvement, full compliance may be considered "Disproportional" to the cost of constructing that area of the project. In those circumstances where personnel of the public entity believe that the proposed action would fundamentally alter the project, service, program, or activity, or the cost is disproportional or would result in undue financial and administrative burdens, a public entity has the burden of proving that compliance would result in such alteration or burdens. The decision that compliance would result in such alteration or burdens must be made by the head of a public entity or his or her designee after considering all resources available for use in the funding and operation of the service, program, or activity, and must be documented by a written statement of the reasons for reaching that conclusion. If an action would result in such an alteration or such burdens, a public entity shall take any other action that would not result in such an alteration or such burdens but would nevertheless ensure that individuals with disabilities receive the benefits or services provided by the public entity.



1102.2.2.1 Extent of Application. An alteration of an existing element, space, or area of a public right-of-way shall not impose a requirement for accessibility greater than required for new construction.

1102.2.2.2 Prohibited Reduction in Access. An alteration that decreases or has the effect of decreasing the accessibility of a public right-of-way or site arrival points to buildings or facilities adjacent to the altered portion of the public right-of-way, below the requirements for new construction at the time of the alteration is prohibited.



GDOT Comment: As worded it appears redundant. The GDOT wording states that regardless of what exceptions may be approved the accessibility cannot be less that before the project was constructed.

GDOT Recommended wording:

1102.2.2.2 Prohibited Reduction in Access. An alteration that decreases or has the effect of decreasing the accessibility of a public right-of-way or site arrival points to buildings or facilities adjacent to the altered portion of the public right-of-way is prohibited.



1102.3 Alternate Circulation Path. An alternate circulation path complying with 1111 shall be provided whenever the existing pedestrian access route is blocked by construction, alteration, maintenance, or other temporary conditions.

GDOT Comment: The amount of time of the closure and the expected pedestrian usage should be a factor. As written this would require a pedestrian bridge to be constructed if the entire bridge had to be closed for just 10 minutes.

See other comments on 1111

1102.4 Sidewalks. Where sidewalks are provided, they shall contain a continuous pedestrian access route complying with 1103. The pedestrian access route shall connect to elements required to comply with Chapter 11.

1102.5 Protruding Objects. Protruding objects on sidewalks and other pedestrian circulation paths shall comply with 1102.5 and shall not reduce the clear width required for pedestrian accessible routes.

1102.5.1 Protrusion Limits. Objects with leading edges more than 27 inches (685 mm) and not more than 80 inches (2030 mm) above the finish floor or ground shall protrude 4 inches (100 mm) maximum horizontally into the circulation path.

EXCEPTION: Handrails shall be permitted to protrude 4-1/2 inches (115 mm) maximum.

1102.5.2 Post-Mounted Objects. Free-standing objects mounted on posts or pylons shall overhang circulation paths 4 inches (100 mm) maximum when located 27 inches (685 mm) minimum and 80 inches (2030 mm) maximum above the finish floor or ground. Where a sign or other obstruction is mounted between posts or pylons is greater than 12 inches (305 mm), the lowest edge of such sign or obstruction shall be 27 inches (685 mm) maximum or 80 inches (2030 mm) minimum above the finish floor or ground.

EXCEPTION: This requirement shall not apply to sloping portions of handrails serving stairs and ramps.

1102.5.3 Reduced Vertical Clearance. Guardrails or other barriers shall be provided where the vertical clearance is less than 80 inches (2030 mm) high. The leading edge of such guardrail or barrier shall be located 27 inches (685 mm) maximum above the finish floor or ground.

EXCEPTION: Door closers and door stops shall be permitted to be 78 inches (1980 mm) minimum above the finish floor or ground.

1102.6 Curb Ramps and Blended Transitions. A curb ramp or blended transition complying with 1104, or a combination of curb ramps and blended transitions, shall connect the pedestrian access routes to each street crossing within the width of each crosswalk.

1102.7 Pedestrian Signs. Signs for pedestrian use shall comply with 1102.7.

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.

1102.7.2 Informational Signs and Warning Signs. Informational signs and warning signs shall comply with 703.5.

1102.8 Pedestrian Crossings. Where a pedestrian crossing is provided, it shall comply with the applicable provisions of 1105. Where pedestrian signals are provided at a pedestrian crossing, they shall comply with 1106.

1102.9 Street Furniture. Street furniture that is intended for use by pedestrians and installed on or adjacent to a sidewalk shall comply with 309 and 1107.

1102.10 Stairs. Where provided, stairs shall comply with 504. Stair treads shall have a 2 inch (51 mm) wide strip of color contrasting with the tread and riser, the full width of the front edge of each tread.

1102.11 Handrails. Where provided, handrails shall comply with 505.

1102.12 Vertical Access. Where provided elevators shall comply with 407, limited-use/limited-application elevators shall comply with 408, and platform lifts shall comply with 410. Vertical access shall remain unlocked during the operating hours of the facility served.

1102.13 Bus Stops. Bus boarding and alighting areas shall comply with 810.2. Bus shelters shall comply with 810.3.

GDOT comment: The bus stop locations are determined (and often changed) by the local transit authority. The GDOT does not have control on where these are placed and often the bus stops a several locations along a block. In many areas that have bus service there is not space available to provide these landings at all bus stops without severe disruption of the community. Consider requiring one accessible bus landing per block or every ¼ mile.

1102.14 On-Street Parking. 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.

GDOT Comment: The requirement will generally be achievable. However many of the small towns in Georgia are built with a small square. The blocks are very short and the sidewalks are often elevated. In this situation the addition of the accessible parking space (and an access route to the elevated sidewalk) would eliminate most or all the remaining spaces in the block. This would effectively put the businesses on the Town Square out of business. Often the entrances to the businesses are not accessible from the sidewalk due to steps. This requirement would provide access to the sidewalk in front of the businesses but would not provide access to the business.

This is another example of where "Engineering Judgement" should be used instead of a mandated requirement.

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.

1102.16 Call Boxes. Where provided, call boxes shall comply with 1110.

1103 Pedestrian Access Route

1103.1 General. Pedestrian access routes shall connect to elements required to be accessible and shall comply with 1103.

1103.2 Components. Pedestrian access routes shall consist of one or more of the following components: walking surfaces, ramps, curb ramps, blended transitions, crosswalks, pedestrian overpasses and underpasses, elevators, and platform lifts. All components of a pedestrian access route shall comply with the applicable portions of this chapter.

1103.3 Clear Width. The minimum clear width of a pedestrian access route shall be 48 inches (1220 mm), exclusive of the width of the curb.

1103.4 Cross Slope. The cross slope of the pedestrian access route shall be 1:48 maximum.

Also, see comments on crosswalks (which are a part of the pedestrian access route).

The requirement for a 1:48 maximum cross slope in the pedestrian access route will be difficult to meet if the running grade on one of the approach roads in on a grade over 2% or if the superelevation is over 2%. The street crossing is part of the accessible route. This will require table-topping all intersections and realigning roads to use a horizontal curve that does not require any superelevation. (see comments on exceptions)

1103.5 Grade. The grade of the pedestrian access route within a sidewalk shall not exceed the grade established for the adjacent roadway.

EXCEPTION: The running slope 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, or complies with 405.

1103.6 Surfaces. The surfaces of the pedestrian access route shall comply with 302.

1103.7 Surface Gaps at Rail Crossings. Where the pedestrian access route crosses rail systems at grade, the horizontal gap at the inner edge of each rail shall be constructed to the minimum dimension necessary to allow passage of railroad car wheel flanges and shall not exceed 2-½ inches (64 mm).

EXCEPTION: On tracks that carry freight, a maximum horizontal gap of 3 inch (75 mm) shall be permitted.

1103.7.1 Detectable Warnings. Where rail systems cross pedestrian facilities that are not shared with vehicular ways, a detectable warning shall be provided in compliance with 1108.

1103.8 Changes in Level. Changes in level shall comply with 303. Changes in level shall be separated horizontally 30 inches (760 mm) minimum.

GDOT Comment: 303 allows a ¼" max vertical lip, ¼" to ½" beveled on 1:2 slope, over ½" sloped at 1:12 The ¼ " max. lip is almost impossible to meet where asphalt and concrete meet. Milling the lip will be very difficult if the detectable warnings are on the low side and impossible if the detectable warnings are too high. These requirements are too restrictive for normal highway construction tolerances.



EXCEPTION: The horizontal separation requirement shall not apply to detectable warnings.

GDOT Comment: What horizontal separation requirement? It is unclear what this means even if a horizontal separation requirement is specified.

1103.8.1 Rail Crossings. Where the pedestrian access route crosses rail systems at grade, the surface of the pedestrian access route shall be level and flush with the top of the rail at the outer edge and between the rails.

1104 Curb Ramps and Blended Transitions

1104.1 General. Curb ramps and blended transitions shall comply with 1104.

1104.2 Types. Perpendicular curb ramps shall comply with 1104.2.1 and 1104.3; parallel curb ramps shall comply with 1104.2.2 and 1104.3; blended transitions shall comply with 1104.2.3 and 1104.3.

1104.2.1 Perpendicular Curb Ramps. 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.

1104.2.1.1 Running Slope. The running slope shall be 1:48 minimum and 1:12 maximum.

1104.2.1.2 Cross Slope. The cross slope shall be 1:48 maximum.

EXCEPTION: This requirement shall not apply to mid-block crossings.

1104.2.1.3 Landing. A landing 48 inches (1220 mm) minimum by 48 inches (1220 mm) minimum shall be provided at the top of the curb ramp and shall be permitted to overlap other landings and clear floor or ground space. Running and cross slopes shall be 1:48 maximum.

EXCEPTION: Running and cross slope requirements shall not apply to mid-block crossings.

EDITORIAL COMMENT: The cross slope and running grade requirements do not apply at mid-block crossings 1104.2.1.3). If "Engineering Judgement" cannot be used, all pedestrian crossings at intersections can be prohibited and mid-block crossings provided. Is this the intention of these requirements?

1104.2.1.4 Flares. Flared sides with a slope of 1:10 maximum, measured along the curb line, shall be provided where a circulation path crosses the curb ramp.

1104.2.2 Parallel Curb Ramps. Parallel curb ramps shall comply with 1104.2.2, and shall have a running slope that is in-line with the direction of sidewalk travel.

1104.2.2.1 Running Slope. The running slope shall be 1:48 minimum and 1:12 maximum.

EXCEPTION: A parallel curb ramp shall not be required to exceed 15 feet (4570 mm) in length.

1104.2.2.2 Cross Slope. The cross slope shall be 1:48 maximum.

1104.2.2.3 Landing. A landing 48 inches (1220 mm) minimum by 48 inches (1220 mm) minimum shall be provided at the bottom of the ramp run and shall be permitted to overlap other landings and clear floor or ground space. Running and cross slopes shall be 1:48 maximum.

GDOT Comment: This is a major problem. See comments on crosswalk cross slope 1105.2.2. Since this area at the edge of the curb, this can sometimes be accomplished by increasing the radii at the corners to get this are away form the travel lanes to allow room for warping the slope, but this increases the length of the crosswalk. Consider that this will require tradeoffs for the pedestrian.

EXCEPTION: Running and cross slope requirements shall not apply to mid-block crossings.

1104.2.2.4 Diverging Sidewalks. Where a parallel curb ramp does not occupy the entire width of a sidewalk, drop-offs at diverging segments shall be protected with a barrier.

1104.2.3 Blended Transitions. Blended transitions shall comply with 1104.3, and shall have running and cross slopes of 1:48 maximum.

1104.3 Common Elements. Curb ramps and blended transitions shall comply with 1104.3.



1104.3.1 Width. The clear width of landings, blended transitions, and curb ramps, excluding flares, shall be 48 inches (1220 mm) minimum.

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.

1104.3.3 Surfaces. 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.

1104.3.4 Grade Breaks. Grade breaks shall not be permitted on curb ramps, blended transitions, landings, and gutter areas within the pedestrian access route. Surface slopes that meet at grade breaks shall be flush.

GDOT comment: Where did this come from? It appears to be impossible to meet this requirement unless the entire intersection is on the same slope (no crown in the roadways). Also, does flush mean less than the 1/4" vertical lip allowed in the pedestrian access route?



1104.3.5 Changes in Level. Vertical changes in level shall not be permitted on curb ramps, blended transitions, landings, or gutter areas within the pedestrian access route.

GDOT comment: If the intent is to require no vertical lips (0" allowable) in these areas it is impossible to meet. If the ¼" allowed in the pedestrian access path it is OK this requirement is redundant.

1104.3.6 Counter Slopes. The counter slope of the gutter area or street at the foot of a curb ramp or blended transition shall be 1:20 maximum.

GDOT comment: This is OK but it is not what the 2001 report recommended. A definition or picture of "counter slope" would be good.

1104.3.7 Clear Space. Beyond the curb line, a clear space of 48 inches (1220 mm) minimum by 48 inches (1220 mm) minimum shall be provided within the width of the crosswalk and wholly outside the parallel vehicle travel lane.

GDOT comment: The 4x4 clear area is required to begin beyond the curb line. Since the gutter slope only is required to be 5% or less in this area, Can the 4x4 area can include the gutter if the gutter slope is 2.08%? This should be clarified.

1105 Pedestrian Crossings

1105.1 General. Pedestrian crossings shall comply with 1105.

1105.2 Crosswalks. Crosswalks shall comply with 1105.2.

1105.2.1 Width. Marked crosswalks shall be 96 inches (2440 mm) wide minimum.

1105.2.2 Cross Slope. The cross slope shall be 1:48 maximum measured perpendicular to the direction of pedestrian travel.

GDOT comment: This is a major problem, especially if reasonable grounds for exceptions are not provided. This requires "tabletopping" the intersection and adjusting the grades on the approaches. If one of the roads is in a curve where the superelevation is greater than 2.08% it requires a change in the horizontal alignment.

GDOT recommendation: Change "The cross slope shall" to "When practical the cross slope should".

EXCEPTION: This requirement shall not apply to mid-block crossings.

1105.2.3 Running Slope. The running slope shall be 1:20 maximum measured parallel to the direction of pedestrian travel in the crosswalk.

GDOT comment: This is a problem, especially if reasonable grounds for exceptions are not provided and the cross slope requirements are changed. If the cross slope requirements are not change this requirement is meaningless and will not control. This requires changing the grade in the intersection and adjusting the grades on the approaches to less than 5 %. If one of the roads is in a curve where the superelevation is greater than 5% it requires a change in the horizontal alignment.

GDOT recommendation: Change "The running slope shall" to "When practical the cross slope should".

1105.3 Pedestrian Signal Phase Timing. All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet per second (0.91 m/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.

GDOT comment: Currently the GDOT normally uses 3.5 fps that was recommended in the Jan. 2001 report. The speed is reviewed on a case by case basis and 3.0 fps or sometime less is used depending on the type of the pedestrians at the intersection. It is possible to set the signal timing for a pedestrian speed of 3 feet per second. However this will take time from the motorists using the intersection. In order to meet the capacity requirements for the intersection additional traffic lanes may be added. In many situations the additional lanes will have the effect of reducing the usability and safety of the intersection for all users (disabled pedestrians, other pedestrians and motorist). As an aside, the subcommittee recommended 3.5 feet per second. No documentation was provided to justify the full committees change to 3 feet per second. Timing the light for an artificially low speed will lead to more drivers violating the signal and this may ultimately cause a less safe condition for all pedestrians. The GDOT recommends using the MUTCD, which allows "Engineering judgement".

1105.4 Medians and Pedestrian Refuge Islands. Medians and pedestrian refuge islands in crosswalks shall comply with 1105.4 and shall be cut through level with the street or have curb ramps complying with 1104 and shall contain a pedestrian access route complying with 1103. Where the cut-through connects to the street, edges of the cut-through shall be aligned with the direction of the crosswalk for a length of 24 inches (610 mm) minimum.

1105.4.1 Length. Where signal timing is inadequate for full crossing of all traffic lanes or where the crossing is not signalized, cut-through medians and pedestrian refuge islands shall be 72 inches (1830 mm) minimum in length in the direction of pedestrian travel.

GDOT Comment: The 6 foot minimum length requirement for cut-through islands apparently is intended to provide a storage area for pedestrians waiting on a crossing signal. (This is an assumption since there is no discussion.) Engineering judgement should be allowed. This requirement can only be meet by increasing the radii at the intersections. The general consensus is that it is better for pedestrians if small radii are used.

1105.4.2 Detectable Warnings. Medians and refuge islands shall have detectable warnings complying with 1108. Detectable warnings at cut-through islands shall be separated by a 24 inch (610 mm) 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 crossing.

1105.5 Pedestrian Overpasses and Underpasses. Pedestrian overpasses and underpasses shall comply with 1105.5.

1105.5.1 Pedestrian Access Route. Pedestrian overpasses and underpasses shall contain a pedestrian access route complying with 1103.

1105.5.2 Running Slope. The running slope shall not exceed 1:20 maximum.

1105.5.3 Approach. Where the approach exceeds 1:20, the approach shall be a ramp 48 inches (1220 mm) minimum in width and shall comply with 405. Where the rise of a ramped approach exceeds 60 inches (1525 mm), an elevator complying with 407, or a limited- use/limited-application elevator complying with 408 shall be provided.

GDOT Comment: The requirement to require elevators at pedestrian overpasses / underpasses where the total rise / fall of the ramps is over 60 inches will not have a great impact on the GDOT. The GDOT does not build many pedestrian overpasses and the local government signs a maintenance agreement on any that are built on State Routes. However well intentioned the requirement may be, the GDOT suggest it be given very serious reconsideration. The result of this requirement may be that no local government will be willing to accept the maintenance (and associated liabilities) of the elevators. The end result will be that these structures will not be built and all pedestrians will be forced to cross at a mid-block crossing or go to the nearest intersection to cross. The discussion on this item stated that some users were not able to climb a series of ramps due to the amount of exertion required. It seems that the inconvenience for a wheel chair user should be weighed against the safety of a visually impaired person (and all other users of the overpass).



1105.5.4 Stairs. Stairs shall comply with 504.

1105.5.5 Escalators. Escalators shall comply with 810.9.

1105.6 Roundabouts. Where pedestrian crosswalks and pedestrian facilities are provided at roundabouts, they shall comply with 1105.6.

GDOT Comment: The GDOT agrees that it is a challenge for a pedestrian (especially a vision-impaired pedestrian) to cross a roundabout. However adding pedestrian signals to the roundabout not only decreases the capacity of the intersection it violates driver expectations and provides the pedestrians with a false since of security. The GDOT feels that this requirement would increase vehicular accidents (mostly rear-end collisions) and increase pedestrians accidents. The only advantage to it would be that the driver could be charged with running a traffic light in addition to failing to yield to a pedestrian. As an aside, the definition of roundabout states "an intersection that has yield control…". If this requirement is implemented the definition is wrong.



1105.6.1 Separation. 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 (380 mm) maximum above the pedestrian access route.

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.

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.

If the discussion in the commentary that states crosswalks are wherever pedestrians crossing are not prohibited is true, the requirement for a pedestrian actuated signal at right and left turn slip lanes should be reconsidered. On most multilane roads the GDOT constructs right turn lanes to allow the turning traffic to get out of the through lanes. This is done to reduce accidents by providing a safer right turn. As written, this requires a pedestrian activated signal (even if a pedestrian is at the intersection just once every 6 months). This is not only very costly and provides very little benefit; it violates driver expectations and will result in increased accidents and probably increase pedestrian accidents. (see roundabout discussion)

Another consideration for not providing the pedestrian activated signal at all slip lanes and roundabouts: In some area of the state, persons (and sometimes organized groups of persons) solicit handouts at intersections. These persons benefit from stopped traffic. The pedestrian signal would continually be activated by these persons (resulting in traffic congestion) even if no pedestrian was attempting to use the crosswalk.



1106 Accessible Pedestrian Signal Systems

1106.1 General. Pedestrian signal systems shall comply with 1106.

The signal that re

1106.2 Pedestrian Signal Devices. 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.

1106.2.1 Location. Pedestrian signal devices shall be located 60 inches (1525 mm) maximum from the crosswalk line extended, 120 inches (3050 mm) maximum and 30 inches (760 mm) minimum from the curb line, and 120 inches (3050 mm) minimum from other pedestrian signal devices at a crossing. The control face of the signal device shall be installed to face the intersection and be parallel to the direction of the crosswalk it serves.

EXCEPTION: The minimum distance from other signal devices shall not apply to signal devices located in medians and islands.

1106.2.2 Reach and Clear Floor or Ground Space. Pedestrian signal devices shall comply with 308. A clear floor or ground space complying with 305 shall be provided at the signal device and shall connect to or overlap the pedestrian access route.

1106.2.3 Audible Walk Indication. The audible indication of the WALK interval shall be by voice or tone.

1106.2.3.1 Tones. Tones shall consist of multiple frequencies with a dominant component at 880 Hz. The duration of the tone shall be 0.15 seconds and shall repeat at intervals of 0.15 seconds.

1106.2.3.2 Volume. Tone or voice volume measured at 36 inches (915 mm) from the pedestrian signal device shall be 2 dB minimum and 5 dB maximum above ambient noise level and shall be responsive to ambient noise level changes.

1106.3 Pedestrian Pushbuttons. Pedestrian pushbuttons shall comply with 1106.3.

1106.3.1 Operation. Pedestrian pushbuttons shall comply with 309.4.

1106.3.2 Locator Tone. Pedestrian pushbuttons shall incorporate a locator tone at the pushbutton. Locator tone volume measured at 36 inches (915 mm) from the pushbutton shall be 2 dB minimum and 5 dB maximum above ambient noise level and shall be responsive to ambient noise level changes. The duration of the locator tone shall be 0.15 seconds maximum and shall repeat at intervals of one second. The locator tone shall operate during the DON’T WALK and flashing DON’T WALK intervals only and shall be deactivated when the pedestrian signal system is not operative.

1106.3.3 Size and Contrast. Pedestrian pushbuttons shall be a minimum of 2 inches (51 mm) across in one dimension and shall contrast visually with their housing or mounting.

1106.3.4 Optional Features. An extended button press shall be permitted to activate additional features. Buttons that provide additional features shall be marked with three Braille dots forming an equilateral triangle in the center of the pushbutton.

1106.4 Directional Information and Signs. 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.

1106.4.1 Arrow. Signs shall include a tactile arrow aligned parallel to the crosswalk direction. The arrow shall be raised 1/32 inch (0.8 mm) minimum and shall be 1-1/2 inches (38 mm) minimum in length. The arrowhead shall be open at 45 degrees to the shaft and shall be 33 percent of the length of the shaft. Stroke width shall be 10 percent minimum and 15 percent maximum of arrow length. The arrow shall contrast with the background.

1106.4.2 Street Name. Signs shall include street name information aligned parallel to the crosswalk direction and complying with 703.2.

1106.4.3 Crosswalk Configuration. Where provided, graphic indication of crosswalk configuration shall be tactile and shall comply with 703.5.1.

1107 Street Furniture

1107.1 General. Street furniture shall comply with 1107.

1107.2 Clear Floor or Ground Space. 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 12 inches (305 mm) maximum.

1107.3 Drinking Fountains. Where drinking fountains are provided, they shall comply with 602.

1107.4 Public Telephones. Where public telephones are provided, they shall comply with 1107.4.

1107.4.1 Single Telephone. Where a single public telephone is provided, it shall comply with 704.2 and 704.4

1107.4.2 Multiple Telephones. 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.

1107.4.3 Volume Controls. All public telephones shall provide volume controls complying with 704.3.

1107.5 Public Toilet Facilities. 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.

1107.6 Tables, Counters, and Benches. Tables, counters, and benches shall comply with 1107.6.

1107.6.1 Tables. Where tables are provided in a single location, at least 5 percent but no fewer than one, shall comply with 902.

1107.6.2 Counters. Where provided, counters shall comply with 904.

1107.6.3 Benches. 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.

1108 Detectable Warning Surfaces

1108.1 General. Detectable warnings shall consist of a surface of truncated domes aligned in a square grid pattern and shall comply with 1108.

1108.1.1 Dome Size. Truncated domes in a detectable warning surface shall have a base diameter of 0.9 inches (23 mm) minimum to 1.4 inches (36 mm) maximum, a top diameter of 50% of the base diameter minimum to 65% of the base diameter maximum, and a height of 0.2 inches (5 mm).

1108.1.2 Dome Spacing. Truncated domes in a detectable warning surface shall have a center-to-center spacing of 1.6 inches (41 mm) minimum and 2.4 inches (61 mm) maximum, and a base-to-base spacing of 0.65 inches (16 mm) minimum, measured between the most adjacent domes on square grid.

1108.1.3 Contrast. Detectable warning surfaces shall contrast visually with adjacent walking surfaces either light-on-dark, or dark-on-light.

1108.1.4 Size. Detectable warning surfaces shall extend 24 inches (610 mm) minimum in the direction of travel and the full width of the curb ramp, landing, or blended transition.

1108.2 Location.

1108.2.1 Curb Ramps and Blended Transitions. The detectable warning surface shall be located so that the edge nearest the curb line is 6 inches (150 mm) minimum and 8 inches (205 mm) maximum from the curb line.

1108.2.2 Rail Crossings. The detectable warning surface shall be located so that the edge nearest the rail crossing is 6 inches (150 mm) minimum and 8 inches (205 mm) maximum from the vehicle dynamic envelope.

1108.2.3 Platform Edges. Detectable warning surfaces at platform boarding edges shall be 24 inches (610 mm) wide and shall extend the full length of the platform.

1109 On-Street Parking

1109.1 General. Car and van on-street parking spaces shall comply with 1109.

1109.2 Parallel Parking Spaces. An access aisle at least 60 inches (1525 mm) wide shall be provided at street level the full length of the parking space. The access aisle shall connect to a pedestrian access route serving the space. The access aisle shall not encroach on the vehicular travel lane.

GDOT comment: The vehicular travel lane should not include the bike lane, if present.

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 (4270 mm). When an access aisle is not provided, the parking space shall be located at the end of the block face.

1109.3 Perpendicular or Angled Parking Spaces. 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.

1109.4 Curb Ramps or Blended Transition. A curb ramp or blended transition complying with 1104 shall connect the access aisle to the pedestrian access route.

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.

1109.6 Signs. Parking spaces shall be designated as reserved by a sign complying with 502.6. Signs 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.

1109.7 Parking Meters. Where parking meters are provided, they shall comply with 1109.7.

1109.7.1 Operable Parts. Operable parts shall comply with 309.

1109.7.2 Location. 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.

1109.7.3 Displays and Information. Displays and information shall be visible from a point located 40 inches (1015 mm) maximum above the center of the clear floor space in front of the meter.

1110 Call Boxes

1110.1 General. Call boxes shall comply with 1110.

1110.2 Operable Parts. Operable parts shall comply with 308 and 309.4. Where provided, labeling shall comply with 703.2 and 703.3.

EXCEPTION: Mechanically operated systems in which the signal is initiated by a lever pull shall be permitted to have an activating force of 12 lbf (53.4 N) maximum.

1110.3 Turning Space. A turning space complying with 304 shall be provided at the controls.

1110.4 Edge Protection. Edge protection complying with 405.9.2 shall be provided where the area at the call box is adjacent to an abrupt level change.

1110.5 Motor Vehicle Turnouts. Where provided, a motor vehicle turnout shall have a minimum paved area of 16 feet (4880 mm) wide minimum and 23 feet (7015 mm) long minimum and shall connect to the turning space at the call box with a pedestrian access route complying with 1103. Where shoulder texturing is used, it shall be discontinued at the turnout.

1110.6 Two-Way Communication. Where provided, two-way voice communication shall comply with 1110.6, 708.2 and 708.3.

1110.6.1 Volume Controls. Volume controls complying with 704.3 shall be provided.

1110.6.2 TTY. A TTY complying with 704.4 shall be provided.

1111 Alternate Circulation Path

1111.1 General. Alternate circulation paths shall comply with 1111.

Also see comment in 1102.3

1111.2 Width. The alternate circulation path shall have a width of 36 inches (915 mm) minimum.

1111.3 Location. The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street.

GDOT comment: This should be a recommendation and subject to Engineering judgement. This will require additional easement and may cause additional displacements. Providing a pedestrian route on the same side of the road for a few hours, weeks or months should be weighed against the community impacts. Especially since many existing sidewalks were built to avoid taking homes and there is limited pedestrian usage.

This requirement may reduce the overall safety to the pedestrians since it will provide path near the construction equipment.

On a project where existing bridges with sidewalk on both sides are being widened, this requirement will require pedestrian accommodations on both sides, which will often require a temporary pedestrian bridge (or 2 temporary bridges).

1111.4 Protection. The alternate circulation path shall comply with 307 and shall be protected with a barricade complying with 1111.6 to separate the pedestrian access route and alternate circulation path from any adjacent construction, drop-offs, openings, or other hazards.

GDOT comment: This needs clarification. In the permanent condition the pedestrian on the sidewalk is only protected from traffic by curb(2 feet horizontal and 6 inches vertical). This appears to require more protection for a temporary condition.


1111.5 Signs. Signs complying with 703.5 shall be provided at both the near side and the far side of the intersection preceding a disrupted pedestrian access route.

1111.6 Barricades. Barricades shall be continuous, stable, and non-flexible and shall consist of a solid wall or fence or a Type II or Type III barricade as specified in MUTCD section 6F-60 with the bottom or lower rail 1-1/2 inches (38 mm) maximum above the ground or walkway surface, and the top of the fence, wall or upper rail 36 inches (915 mm) minimum above the ground or walkway surface. Barricade support members shall not protrude beyond the barricade face into the pedestrian access route or alternate circulation path.