Robert Gorski

October 29, 2002

Dear U.S. Access Board:

I write to comment on 4 areas of the proposed guidelines for Public Rights-Of-Way (PROW): roundabouts, truncated domes on curb ramps, accessible pedestrian signals, and scoping for on-street parallel parking.

ROUNDABOUTS The wording of section 1105.6.1 needs clarification. Requiring barriers “along the street side of the sidewalk where crossing is prohibited” includes locations were a strip of parkway grass or bushes or flowers lies between the sidewalk and the curb. I find it hard to believe that barriers are needed as such locations.

To comply with section 1105.6.1 “splitter islands” would have to be totally surrounded by a barrier except for where the pedestrian way crossed the island. I believe that the degree of safety that should be sought for could be provided more simply and at less cost by having barriers along both sides of the pedestrian way that crosses through the island. Where the rest of the island contained a parkway, no barrier would be required.

How will section 1105.6.1 as written apply to roundabouts where the pedestrian crosswalks are not located at or near the circular “rim” of the roundabout, but further away and down the streets that lead into the roundabout. For what distance must the continuous barrier “along the street side of the sidewalk” extend? Section 1105.6.1 as written does not say.

Would truncated domes comply with section 1105.6.1's requirements for a “continuous barriers?”
This section, despite the few words that comprise it, deserves much thought.

Also, the photograph that the U.S. Access Board uses to illustrate a traffic roundabout does not have pedestrian barriers. If no roundabout with barriers exists, I recommend the Board get one established, see that it works the way you want it to work, and then photograph it.


TRUNCATED DOMES ON CURB RAMPS I recommend the U.S. Access Board arrive at a conclusion over this long standing issue similar to the California State Building Code. Truncated domes are needed by most blind individuals only where the slope is too gentle to be a cue by itself. It is unnecessary to have truncated domes on all curb ramps.

Additionally, truncated domes on curb ramps with greater than gentle slopes become a problem for wheelchair users, walker uses, and many semi-ambulatory pedestrians. On greater than gentle slopes, truncated domes become a rough, uneven surface that interferes with balance for semi-ambulant individuals and, for others, with maintaining control over mobility aids - particularly rigid-frame wheelchairs with solid rubber tires.

Installing truncated domes on a slope significantly increases the bumpiness of the ride for wheelchair and walkers users. For some, the ride will be more than an unpleasant annoyance, it will be physically painful. Here in the city of Pasadena, California, I have encountered over the years several wheelchair users who complain of joint pain when they roll over level sidewalk that has been textured to appear historic, and the unevenness of this surface does not approach the awkward bumpiness people will experience if they must negotiate curb ramps with truncated domes.

I myself use a power wheelchair and have experience with truncated domes, and if they are installed on new and altered curb ramps with greater than gentle slopes, the U.S. Access Board will be forcing me back to the 1960s, when I wheeled about and crossed streets by using driveways near intersections and then either “jay rolling” across the street to another driveway, or traveling along the gutter, crossing the street inside the crosswalk, and then traveling along another gutter to a driveway at which I could gain access again to the public sidewalk. Granted, driveways have lips that are bumpy, but that is only one bump and not a flight of bumps, like I will encounter if truncated domes are installed on all new and altered curb ramps.

Also, I submit that truncated domes on curb ramps at greater than gentle slopes do not comply with existing ADAAG Appendix A4.5.1 which advises (in part) that an accessible pathway must have a surface that is “stable and regular,” and that “irregular surfaces such as cobblestones can significantly impede wheelchair movements.” I would like to add that even when a cobblestone surface is “regular,” it remains a surface to avoid.

Lastly, consider this hypothetical situation: A wheelchair user, a user of a walker with small front wheels, and a semi-ambulant person all cross a street and face a choice of two curb ramps leading up to the public sidewalk. One curb ramp has truncated domes on it and the other does not. Which individuals will choose the ramp without domes? The answer, I submit, is all of them because no one in their right mind wants to ascend a ramp of bumps.

ACCESSIBLE PEDESTRIAN SIGNALS I support the provision on APS devices at street intersections. At the same time, I recommend that the provision on locator tones be changed to require these tones only where the APS devices are located an atypical distance from the street corner where they are installed.

In Pasadena, the municipal government three years ago installed APS devices at a very busy intersection in a commercial district. The devices have vibrating arrows, audible messages, and Braille and raised character street labels and are mounted on light standards at a distance from the crosswalk that is typical. The devices do not have locator tones and do not use chirps and beeps as signals. The local government has received positive feedback from several blind individuals who reside in the city. Moreover, in the year 2000 a public celebration of the 10th anniversary of the ADA brought visitors with disabilities to the downtown area and there were reports of blind visitors being pleased by the APS devices.

Two years ago, administrators at the California Institute of Technology contacted the local government and offered to purchase APS devices if the city would install and maintain them at two intersections near the Institute. Motivating the Institute was a desire to assist two employees with vision impairments cross busy streets which were part of each employee’s walking path to the Institute.

ON-STREET PARALLEL PARKING I recommend that the scoping provision be significantly reduced. The current provision is a “one size fits none” solution to the problem of inaccessible street parking. The different lengths of city and especially suburban blocks, the frequency with which parallel parking options are used on different streets, and the presence of nearby off-street parking are all legitimate factors in determining a scoping provision for accessible on-street parking.

And what about streets where parking is permitted only within a small portion of the block face? How can a scoping provision legitimately require two accessible spaces in that situation?

Lastly, this scoping provision would seem in many instances to result in a greater percentage of accessible parking spaces per total number of spaces available than is required by the ADAAG scoping provision for accessible spaces at parking lots.

No matter how the final scoping provision is written, the current provision in the proposed guidelines is having a deleterious effect at the present time in California, where state law permits municipalities to designate parking spaces as reserved for disabled individuals by painting the curb blue. Awareness of the PROW guidelines having specifications for accessible on-street parking spaces has caused parking administrators in Pasadena and at least a handful of other localities to deny requests from disabled people for “blue curb” parking spaces. Such requests typically are from disabled people needing convenient access to their homes, places of worship, schools attended by their children, and other critical sites.

Requests are being denied because parking administrators fear that blue curb spaces are out of compliance with what will likely be a coming provision in the ADAAG. I hope the Access Board agrees that blue curb spaces can be provided at the present time without having to be removed if a provision for accessible on-street parking becomes part of the ADAAG. Further, I hope the Board also agrees that even if a provision for accessible on-street parking becomes effective, blue curb spaces can continue to be provided as long as this is not done in lieu of complying with provisions in the ADAAG.

I urge the Access Board to announce that the proposed provision on accessible on-street parking does not invalidate nor put into jeopardy blue curb parking spaces.