Draft Guidelines for Accessible Public Rights-of-Way

The American Institute of Architects Comments

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.

The reference to where it can be obtained is not necessary in a code. This is good commentary information.

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

1101.3 Defined Terms.

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.

This definition is superior to the one in the 2 April 02 draft ADAAG.

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.

Delete the last part of the definition—“which also may serve as a refuge for pedestrians.” This is clearly not what defines the channelizing island and should be left to commentary.

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).

The added text about superelevation is advisory and as such unfit for the definition. Recommendation: Place this text in a commentary if there is value in the explanation. Also, see comment under definition of “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.

This definition is unnecessarily confusing.

There is no need to introduce a new term, “roadway,” when ADAAG already has a defined term “vehicular way.”

“Lateral lines of the sidewalk” is not a common term and is confusing. It might be clearer to say the “edges of the sidewalk,” if that is what is meant.

It is unclear why the measurement method is given in the definition. This might be pertinent in some technical criteria and, if so, should be included in the technical provisions, not the definition. However, no place was found in this document where the measurement of the crosswalk was needed.

In addition, the measurement method is included in the middle of the definition, breaking the thought of what defines a crosswalk.

The phrase “…within the extension of the lateral lines of the sidewalk at right angles to the centerline” is unclear. Right angles to the centerline of what?

The last sentence is too open-ended. If this is intended to capture mid-block crosswalks, a new definition should be added. If it is intended to capture all marked crosswalks, then it will likely negate the rest of the definition when it is applied in the real world. For example, the intersection could have a meandering marked path across the intersection that is outside the area of the defined crosswalk, and it would qualify under this part of the definition as a crosswalk.

Proposed definition:

Crosswalk: That part of the vehicular way that is included within the projection of the line of the sidewalk edges across the intersection. Where sidewalks occur on both sides of the intersection, the imaginary lines connect the sidewalk edges across the intersection.

Alternate proposal:

Crosswalk: That part of a vehicular way at an intersection that is included within the imaginary lines connecting sidewalk edges across the vehicular way. In the absence of a sidewalk on one side of the roadway, it is the part of the vehicular way that is included in the projection of the line of the sidewalk edges across the intersection.

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

The definition of curb line needs clarification. Is this line the top back of the curb, the top front, or the toe of the curb? Some curb faces are sloped, raising the question of where the curb line falls.

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

A transition at a curb that has a running slope of less than 1:20 will not be considered a curb ramp, because it is not a “ramp” by definition. Therefore, it will not be required to meet the technical criteria of a curb ramp. But because curb ramps have more than the 1:48 allowed for a blended transition, they are not classified as such and therefore become unregulated.

A curb ramp is a feature that is more commonly understood than a “blended transition,” which is not defined. Recommend defining blended transition, at least in commentary.

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.

The suspension failure is a little perplexing. Isn’t that covered under lateral motion? If not, how is it an enforceable part of the guidelines? Does the envelope include the area of trains that have derailed due to suspension failure? If this is not a necessary part of the definition, it is best deleted or moved into commentary.

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

See comments at 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.

See comments at right-of-way.

Grade. (See running slope).

The term “grade” is probably not necessary in this document, but if found to be necessary, consistency of use will be extremely important. If it is necessary, then it should be differentiated from the term “running slope” by definition. Grade is commonly used by industry for sitework and roadwork. So, if it is necessary to use the term, define it as the slope or running slope of the vehicular way, whichever is appropriate. As shown here, it appears to include only the running slope and not the cross slope. It is unclear how that can be, at an intersection where the running slope of two streets cross, but nonetheless, the definition should be separated from “running slope,” which is typically used for the sidewalk or pedestrian access route. Another problem with identifying this term with a running slope is the following definition of “grade break,” which is not limited to running slope.

In addition, the term should not be used for other purposes in the rule. For example, the term “grade” is used with a completely different meaning in two places—sections 1103.7 and 1103.8.1—in the draft guidelines. Another term should be used here.

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

“Grade” now becomes the same as any slope, not just running slopes. See comments to the definition of “Grade.”

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

A message that says “the button is on the other side of the intersection” satisfies this definition, though clearly not the intended result.

Alternative text:

Locator Tone. A repeating sound originating from a location adjacent to the pedestrian push button for purposes of identifying the location of the pedestrian push button.

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

The term “corridor” adds unnecessary questions to the definition. Corridors in buildings have space defining walls. Corridors in transportation planning have a definition relating to roadways (as used in the next definition). Recommendation: For clarity, use a more common term such as path, pathway, or route. A term commonly used for the setting will help avoid questions about what is meant.

Recognizing that there has been a huge effort not to use the term “accessible route” in this document, it is still a logical term that simply has different technical criteria in the public right-of-way.

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

ADA in general and ADAAG in particular are rather loose in the use of the word “public.” Does this imply that the public owns the underlying property? Or simply has an easement? Alternatively, this could be read to suggest that it is the public who has the right of transportation, or it could be read that he who acquires has the right of transportation. The word “transportation” carries the strong suggestion (almost to the point of being a necessary part of the definition of the word) that something is carried. This tends to exclude pedestrian sidewalks from the definition of public right-of-way.

As written, the definition could include many things that are not intended, such as bicycle paths, skateboard parks, etc.

“Land” is a subset of “property,” so why use both words?

The “usually in a corridor” is advisory text unfit for a definition. Many people will not understand the term “corridor” in this context, particularly since the term as used here has a different meaning than the one used in the definition of “Pedestrian Access Route.”

This definition could include land that a property owner buys from his neighbor for transporting timber to the highway.

This definition is crucial to scoping the regulation, but without better coordination with the definition of site it will weaken accessibility. The proposed definition describes something that can exist on sites, so using the rule that the specific requirements trump the general requirements, it follows that designers will be permitted to use the weaker requirements of rights-of-way where previously they were required to provide a higher level of accessibility.

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.

Delete the phrase “expressed as a ratio of rise to run“ and the second sentence as advisory material inappropriate for a definition.

Again, the term “grade” appears as running slope only. See comments to definitions of “Grade” and “Grade Break.”

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.

This is poor code drafting, because the intent of the designer is the triggering condition. If the designer improved the shoulder of the road to make life easier for the snowplow, it is not a sidewalk even though it looks like a sidewalk and its use by pedestrians is tolerated.

In addition, it can be read in two different ways: It can be read to be only the improved portion of that area, or the entire area if any of it is improved. Clarification of this definition is critical to the definition of “Crosswalk,” as well as the technical criteria for on-street parking in Section 1109.2 (Exception).

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.

This definition might be too broad. There can be many things intended for use by pedestrians that would also be defined as elements, such as pedestrian push buttons and pedestrian overpasses. Yet those are not intended to be covered by the definition of street furniture. It might be best simply to delete the definition.

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

Delete definition. The term is not used in this document, except in commentary in the definition of the term “Cross Slope.” Inclusion of a definition that is not used in the technical requirements is inappropriate.

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.

 The term “Walk Interval” logically includes the time interval for walking all the way across an intersection, or at least to a refuge island. However, that is not what the definition says. This causes confusion. The definition, coupled with the technical provisions where the term is used, appears to define a specific time to start the walk across the intersection. After that interval it is not safe to start. For the blind this is an important feature of the signal.

Because the term does not indicate the definition, it is confusing. Recommend a new term that is indicative of the definition, such as:

Start Walk Phase: That time interval of a traffic signal cycle . . . etc.

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.

Most newly constructed public rights-of-way are designed and constructed by ADA title III entities, while most alteration projects are conducted by ADA title II entities.

Due to a window between the effective dates for various parts of the original ADAAG through which projects could have avoided ADA compliance, the original ADAAG took the nonsensical position that an addition was some sort of alteration. This window has long since closed, so there is no good reason to continue with that approach.

Additions should be treated as new construction. An addition should not be treated as an alteration, like the approach taken by the current ADAAG 4.1.5.

The form of the charging statements is not consistent with the remainder of ADAAG.

Replace 1102.1 through 1102.2.2 with:

1102.1 General. Rights-of-way shall comply with Chapter 11.

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.

See Comment to 1102.1.

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.

See Comment to 1102.1. The only valid piece in this section is the guidance given on how to deal with the interface of new additions to the existing construction.

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.

See Comment to 1102.1.

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

Delete because the general text at ADAAG 202.3 controls this.

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.

Delete because the general text at ADAAG 202.3.2 controls this.

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.

Delete because the general text at ADAAG 202.3.1 controls this.

This is particularly confusing and open-ended. In an alteration, if, in order to make a sidewalk accessible, one would decrease the accessibility of the site arrival point, this section would prohibit that.

However, if by making the same site arrival point accessible will make the sidewalk less accessible than the requirements for new construction, this section would prohibit that as well. This leaves the designers in the position of not being able to meet the rule either way. And someone will be required to make a decision about which is the most important piece of the route to be accessible. For example, it might have to be decided whether the cross slope of the sidewalk becomes too steep or the landing at the building door includes a step.

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.

Delete, because it is an operational issue better contained in the regulations issued by DOJ, DOT, DOD, HUD, GSA, and USPS.

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.

Delete all of 1102.5 because ADAAG 204 controls this issue.

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.

See above

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

See above

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.

See above

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

See above

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.

See above

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

See above

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.

Delete all material covered elsewhere in ADAAG (e.g., signs are now in 810.4 in Draft ADAAG).

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.

Delete—see above.

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.

Move to 810.4 (Draft ADAAG number)

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

Delete

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.

“Pedestrian crossings” is an undefined term. How can one know if one is provided? Should define the term and include what is being crossed.

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.

Delete the phrase “that is intended for use by pedestrians,” since this text is part of the definition. The phrase “or adjacent” is problematic because the land adjacent may be outside the right-of-way, thus violating the definition and illegally requiring work on property not under the control of the entity responsible for the right-of-way.

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.

Delete because ADAAG 407 controls this issue. Delete the hours of service material as better suited to the adopting agency’s regulation.

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

Delete

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.

There is no substantiation given for a parking space on every block face. The ratio of the number of accessible parking spaces to the overall number of on-street parking spaces in the area varies with the length of the block face and type of parking. There is no credit given to public off-street parking made available, for example, by a city. There is no exception given for blocks that feature nothing but a parking garage containing a number of accessible parking spaces. Many businesses provide parking garages with accessible spaces for their clients. The requirement to provide an accessible parking space on each block face needs further study.

As stated in earlier comments, most streets are developed by Title III entities for residential areas. It does not seem logical to require accessible on-street parking on each block face for these areas as well. The effects of this requirement and the justification for the numbers need further clarification.

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.

Delete. This is already covered in ADAAG.

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.

This could be confused as scoping and as requiring pedestrian access routes where pedestrian routes are not planned. This needs to be clarified.

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.

Section 504 of the ADA authorizes the U.S. Access Board to make minimum guidelines—not optimal guidelines. The fact that an industry may have a standard practice that exceeds the minimum needed for accessibility is not a justification for the Board to violate the law by requiring more than minimum.

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

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

The grade and the running slope are the same. See comments to definition of “Grade.”

See General Comment at the beginning of this paper regarding limitations on pedestrian access routes and how they cannot comply with this at curb ramps.

This requirement is an absolute that precludes making the pedestrian access route more accessible by increasing or decreasing the slope. If the roadway is dead level or negative, there is no reason the slope of the pedestrian access route should not exceed the slope of the roadway.

In addition, the approach to a pedestrian underpass could warrant exceeding the adjacent roadway to accomplish the additional height to take the accessible pedestrian route over something.

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.

The exception is unclear. It allows the pedestrian access route to be steeper than the adjacent roadway grade, provided it does not exceed the slope of a walking surface, or it complies with all of the requirements for a ramp. This will not work at curb ramps. These requirements only hold on more level sites. Therefore, cities with some slope will likely end up with ramps and handrails along the sidewalks, while streets with a little more slope will not.

Consider again the place where most new streets are built: the residential development. Again, if there is reason to have the sidewalk any steeper than the roadway, you will end up with ramps and handrails along the street in front of the houses. Or, more likely, you will not have any sidewalks in the development.

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).

The term “grade” is used here in a manner different than the definition. See comments to definition of “Grade.”

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.

This could be read to require detectable warnings at pedestrian overpasses and underpasses.

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

See general comments regarding changes in level.

Note also that even unit pavers that are 30 X 30 inches can have changes in level that are closer together than 30 inches when the joints are staggered.

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

Here is a real conflict in thinking. The guideline states that there can be no changes in level, not even a very narrow scored line in the concrete, yet it mandates changes in level at every curb ramp and intersection of a pedestrian access route and rail crossing with the inclusion of detectable warnings.

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.

The term “grade” is used here in a manner different from the definition. See comments to definition of “Grade.”

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.

A grade break occurs when two slopes meet. A running slope doesn’t “meet the grade break” but rather meets the gutter. The meeting of the ramp slope and the gutter slope forms the grade break.

Delete “grade break” in the last sentence.

This section is in direct conflict with1104.3 Common Elements, which prohibits grade breaks in gutter areas.

Note also that “Perpendicular Curb Ramp” is not defined except by these technical criteria. There is no obvious difference to distinguish it from a “parallel curb ramp.” See comments to Section 1104.2.2 Parallel Curb Ramps.

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

This is probably not possible for curb ramps on the uphill side of an intersection when the grade of the street approximates 1:12.

There should be an exception for running slopes at mid-block crossings in accordance with the exception at 1104.2.1.3.

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.

The landings are not allowed any exceptions for slope. However, the curb ramp is allowed exceptions for the running and cross slopes. This will necessitate a warp in the ramp. Some guidance should be given on how to accomplish a warp like this with the least effect on wheelchair use. The warp combined with the detectable warning bumps could make for a dangerous combination.

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

This exception appears to be misplaced. It appears that there should be a separate exception for running and cross slopes beneath their respective sections.

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.

Delete this because it is both unneeded and untrue: unneeded in that the general ramp requirements control, and untrue in suggesting that slopes less than 1:20 are ramps.

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

Parallel curb ramps are limited to 15 foot max. run, so their slopes will be regulated by the formula of (curb height + (grade times 180 inches))/180 inches). For a 7-inch curb and 3½% road, this means a slope of 7⅜%, and for the 6½% road 10⅜% (i.e., over 2% steeper than will be permitted for perpendicular ramps). It is difficult to visualize a parallel curb ramp that is not a mid-block crossing; if this is so, it means there are no limits on running and cross slopes.

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.

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.

There has been much testimony and debate regarding the benefits and necessity of detectable warnings. Before there is a requirement for detectable warnings to be provided in so many places, the Board should be certain that it is not creating a less accessible walking surface for anyone. Some people have to drag their feet when they walk, and this document is riddled with requirements prohibiting level changes for people who use wheelchairs. It is counterintuitive that such opposing requirements are both so important, and yet both are required in the same location within the pedestrian access route.

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.

Another misuse of the term “grade break.” The first sentence says that grade breaks are not permitted, and then says that surface slopes that meet at grade breaks must be flush. This is either a conflict or, at best, confusing because it can be read to mean that it is the same area. For example, a grade break is not allowed in a gutter area, which can be considered an area with a surface, which would then be allowed, but regulated by the last sentence. If surface slopes are other than the listed areas, then that term should be defined and addressed in a new section. And if the problem with them is vertical changes in level, then that should be addressed in 1104.3.5. Otherwise the idea of “flush” is unclear in this application.

Another conflict is that grade breaks are not allowed on curb ramps. Built-up curb ramps that have flares will by their nature have grade breaks at the sides where the flare meets the running slope of the ramp. The definition of ramp causes the flare to be considered a ramp, where a pedestrian circulation path crosses the curb ramp, as allowed by 1104.2.1.4.

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.

How is it that curb ramps and blended transitions are not allowed to have even the slightest vertical changes in level, but are required to have detectable warnings, which by definition consist of a bunch of level changes. This is counterintuitive.

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.

The counter slope of the gutter area to the curb ramp or blended transition will form what is referred to as a “grade break,” which is not allowed by 1104.3.4, yet this section gives the specifications for them.

This is a conflict.

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.

Revise to clarify by putting all of the criteria for locating the clear space together in the sentence.

A clear space of 48 inches minimum by 48 inches minimum shall be provided within the width of the crosswalk, beyond the curb line, wholly outside the parallel vehicle traffic lane.

Also, it is unclear what the “parallel” vehicle travel lane is. Parallel to what?

1105 Pedestrian Crossings

“Pedestrian crossings” is an undefined term.

1105.1 General. Pedestrian crossings shall comply with 1105.

“Pedestrian crossings” is an undefined term.

1105.2 Crosswalks. Crosswalks shall comply with 1105.2.

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

This requires that crosswalks that are marked be wider than those that are not marked. If the crosswalk, by definition, is not as wide as this, then this will preclude marking. Even the little bit of safety that might be gained for the pedestrian by marking is then lost. Recommendation: Delete this section.

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

This apparently is intended to require tabletop-like crosswalks at the edge of each intersection. It is questionable whether this will be practical and safe for motor vehicle traffic.

The requirement for a crosswalk to have a minimal cross slope will increase the width of every intersection in sloping terrain, because of the need to create this tabletop effect.

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

If it is acceptable to have a cross slope at the mid-block crossing, why not at the intersection? The establishment of crosswalks at mid-block seems to have different requirements because of their effect on vehicular traffic safety. This certainly needs to be a consideration at intersections as well.

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

There seems to be no allowance for street slope (grade) in this section. The street crossing the intersection parallel to the crosswalk might just as likely have a running slope far in excess of the allowable 1:20.

As this tabletop and running slope limitation continues for intersection after intersection up a hill or mountain, it will require that the hill or mountain be removed to a large degree. Otherwise, at some point, the natural slope will depart from the street grade, separating the adjacent sites from the sidewalk/street by a vertical barrier.

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.

Consideration is given in subsequent sections for pedestrian refuge areas in medians, islands, and splitter islands when the signal timing is not adequate for pedestrian travel across the entire intersection or pedestrian crossing. This requirement seems to conflict with those considerations.

What effect will longer crossing times—and the concomitant increases in engine idling time and vehicle trip times—have on clean air requirements?

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.

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.

See general comments at the beginning.

1105.5.4 Stairs. Stairs shall comply with 504.

For buildings, the only stairs that are required by ADAAG 210 to comply with 504 are those used in the accessible means of egress. If an accessible pedestrian route is provided by ramps or elevators, it does not seem that the stairs in these locations should be required to meet 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.

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.

Crosswalk is a defined term that seems to indicate that there is a crosswalk at every intersection that has a sidewalk on any part of the intersection. That definition does not mention the use by pedestrians. The term “pedestrian crosswalk” is not defined. See earlier comment about the term “pedestrian crossing.”

It is unclear whether this is for crossing the slip lane or for crossings that parallel the direction of the slip lane.

1106 Accessible Pedestrian Signal Systems

1106.1 General. Pedestrian signal systems shall comply with 1106.

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.

“Crosswalk line extended” is a difficult term to understand.

The control face must face the intersection, so people standing in front of it will have their backs to the intersection. With the face of the device facing the intersection, it is unclear how it will also be parallel to the direction of the crosswalk it serves.

Ten feet from other signal devices seems like a lot when the right-of-way might not be that wide.

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.

It needs to be made clear that the tone is emanating from approximately the push button location, because a “tone at the pushbutton” can be emanating from anywhere.

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.

The measurement will allow a push button 2 inches long by 1/16 inch wide. Is that acceptable? If not, could it be the intent to make them 2 inches in the smallest dimension?

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.

With all of the requirements for push buttons, arrows, signs, and street names, as well as distances from other devices, the area at the intersection could become cluttered with items that will possibly block the view of motorists, a safety problem that could jeopardize pedestrians as well as motorists. Consideration should be made for the clutter that might occur.

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.

It is unclear where counters might occur in a public right-of-way. The guidelines should not attempt to address temporary vendor operations, but only the permanent street furniture.

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.

It is unclear why 50% of the benches should comply with the provisions of 903. Also, there is no reason given in the discussion why an armrest is required on 50% of the benches in the public right-of-way, when these have not been and are not required in ADAAG.

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.

Delete because this material is covered elsewhere in ADAAG.

Note also that the requirement that the domes be on a square grid is nearly meaningless. A square grid can be applied over the domes at an angle and they would meet the provision. A square grid can be applied over the domes with only certain domes hitting on the grid and, because the grid is moved over the domes, the other domes meet the grid. Some domes might be aligned by a square grid of one size and the other domes aligned to a different size square grid.

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).

Delete because this material is covered elsewhere in ADAAG

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.

Delete because this material is covered elsewhere in ADAAG.

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

Delete because this material is covered elsewhere in ADAAG.

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.

Delete because this material is covered elsewhere in ADAAG.

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.

This assumes a very wide street. This will increase the right-of-way width by at least 10 feet for on-street parking on both sides of the road. Additional width may be required to provide an accessible pedestrian route to the top of curb height.

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.

As written, a 20-foot-wide space between the curb line and the right-of-way boundary would not need to provide an access aisle as long as 6 or more feet was devoted to a green strip, if the sidewalk is defined as the improved area only. See comments to the definition of “Sidewalk.”

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.

This will likely result in a curb ramp cutting into the sidewalk, which will require additional right-of-way space.

1109.5 Obstructions. There shall be no obstructions on the sidewalk adjacent to and for the full length of the space.

This does not make sense for perpendicular or angled parking (i.e., the parking space is not parallel to the sidewalk, and the access aisle is connected to the pedestrian access route).

EXCEPTION: This provision shall not apply to parking signs complying with 1109.6 and parking meters complying with 1109.7.2.

If the obstructions are a problem for the parallel parked cars, why wouldn’t the signs and parking meters be obstructions?

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.

Delete “so as not to interfere with the operation of a side lift or a passenger side transfer.” This is commentary.

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.

Delete “so as not to interfere with the operation of a side lift or a passenger side transfer.” This is commentary.

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.

Which is the front? The side toward the roadway? Depending on what the front is, the dimension will be measured from the surface of the parking space or the surface of the sidewalk.

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.

Most of these devices will be located in remote areas along a highway. An accessible pedestrian route to the device is not likely to be there. Why require a turning space? Why not a simple pull-in and back-out clear floor space?

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.

“Adjacent to an abrupt level change” needs to be clarified. An abrupt level change is a compliant ¼-inch vertical change in level. An abrupt change in level can also mean a rock wall in front of the area. An abrupt change in level can also be the curb that is provided for edge protection. If it means a substantial drop off, then say that.

In addition, what is meant by “the area at the call box is adjacent”? This gives no guidance as to what is under consideration. The turning space required at 1110.3 probably is the area of concern.

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.

The only two-way communications systems within right-of-ways appear to be pay phones and duress call boxes. Does this mean that every pay phone in the right-of-way must have a TTY? Most duress call boxes do not support free-form communication for those who hear, so why is a TTY necessary?

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

Please note that circulation paths are not regulated for running or cross slopes, so this section greatly lowers the level of accessibility that must be provided.

1111.1 General. Alternate circulation paths shall comply with 1111.

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.

Why on the same side of the street? If the disruption that triggered a need for an alternate circulation path is the replacement of the old sidewalk, why force the city to lose a travel lane?

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.

Delete reference to 307, because all circulation paths are already obliged to follow 307. Delete the phrase “pedestrian access route,” because this section concerns alternate circulation paths. Justify the requirement that barricades be provided at drop-offs adjacent to alternate circulation paths when regular circulation paths are not similarly regulated.

Further, as worded this will require barricades along all curbs, thereby forcing parkers to walk in traffic until they reach an intersection before they can join the sidewalk.

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.

The “near side and the far side of the intersection” is confusing. Where is that? Could it be said as “both sides of the intersection, preceding, and on the same side of the street as 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.

It will be difficult to make the barricades continuous. Limited breaks for portable pieces are necessary. There is no reason to call for “non-flexible,” which is a term not easily judged and which eliminates most of the materials typically used, such as wood, plastic, and steel chain-link fencing.