Jane Beautz

October 22, 2002

County of Santa Cruz

RE: COMMENTS ON “DRAFT GUIDELINES ON ACCESSIBLE PUBLIC RIGHTS-OF-WAY”

Dear Members of the Board:

I am writing at the direction of the Santa Cruz County Board of Supervisors to offer several comments on the Draft Guidelines on Accessible Public Rights-of-Way regarding items that appear to need additional clarification.

Section 1102.14 requires that at least one accessible on-street parking space be located on each block face. While this may be desirable in business or commercial areas, it seems rather onerous in residential areas, particularly areas of single family residences. Santa Cruz County is primarily rural in nature and experiencing infill development in its more urban areas. A typical new development might be a cul-de-sac with four or five homes and perhaps one to three parking spaces on each side. A requirement to provide one accessible space on each side would severely limit the amount of street parking available for residents and guests. We would suggest that this section be revised to limit this requirement to commercial and business areas, where there is an actual need for accessible on-street parking.

Section 1105.7 requires that any intersection with slip turn lanes and pedestrian crosswalks include pedestrian activated signals at each segment of the crosswalk, including at the channelizing island. It appears that this requirement as written would apply even if the intersection were not otherwise a candidate for signalization for other traffic control reasons. We would suggest that this section be revised to require signalization of the slip turn lanes only if the main intersection is signalized.

It would also be helpful if the guidelines included a definition of the term “Alteration,” and a discussion of the level of alteration that would require compliance with the guidelines. There was a court decision that found that an asphalt concrete street overlay would require that curb ramps be installed if they did not already exist. Would the new guidelines require a public agency to provide accessible on-street parking spaces when a street is repaved? Would an overlay trigger the requirement to signalize any intersection with slip turn lanes?

We appreciate the opportunity to comment on the proposed regulations prior to their finalization. Santa Cruz County has been very proactive in complying with the Americans with Disabilities Act, and we welcome the formalization of the requirements of the ADA as they apply to public rights-of-way.

Thank you for considering our comments.

Sincerely,

JANE BEAUTZ
Board of Supervisors