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SALT LAKE COUNTY GOVERNMENT AND PUBLIC WORKS

Dear Access Board,

We have prepared the following table describing our concerns and recommendations regarding the proposed draft Guidelines for Accessible Public Rights-of-Way. We appreciate the Board’s willingness to receive comments concerning this matter. We would be happy to continue to assist in any way we can to help the Board reach their objectives and goals. We strongly support the Board in its efforts to assist those with mobility impairments. We believe that the majority of the draft guidelines are good and will serve to improve many situations. In those areas where we have expressed concerns, we are confident that alternate guidelines can be found to meet the Board’s desires, improve the implementation of the guidelines and increase ownership in them by all parties.

Sincerely,

Mary Ann Cowen, ADA Compliance Specialist (wheelchair veteran of 35 years), Salt Lake County Government

Kevyn Smeltzer, P.E., Operations Director, Operations Division, Salt Lake County Public Works Department

Phil Lanouette, P.E., Construction Manager, Engineering Division, Salt Lake County Public Works Department

M. Leon Berrett, P.E., Operations Director, Operations Division, Salt Lake County Public Works Department

Draft ADA - Concerns

Reference Section	Draft Proposed Guideline	Concerns						Alternate/Additional Recommendations	Comments
Reference Section	Draft Proposed Guideline	Safety	Constructability	Maintainability	Usability	Environmental Issues	Cost	Alternate/Additional Recommendations	Comments
1101.3	Definitions of Terms.		Needed to ensure consistency of design and construction.					Need to define terms such as "blended transition", "technically infeasible", "maximum extent practicable".
1102.3, 1111.3	Alternate circulation path are to be located on the same side of the street and parallel to the disrupted pedestrian access route.	Depending upon the construction, many times the safest route is on the opposite side of the street for all pedestrians.	May be difficult to construct depending upon the construction.				Additional costs would be incurred.	Requirements should be dependent upon the situation. It should be strongly recommended and/or when it is practical without compromising the safety of pedestrians.
1102.6, 1104	General requirement to provide two separate curb ramps at corners instead of one.	If two separate curb ramps are constructed, it would leave a small raised island/curb that could pose a tripping hazard. Cars making sharp turns could be likely to hit it which could result in temporary loss of control of the vehicle.		The raised island/curb could likely be broken by repeated hits by vehicles making sharp right turns.				Allow for combined ramps at corners with different tactile texturing/surfacing in line with the direction of the cross walks. Strongly recommend or require the use of separated ramps when the separation between the ramps is significant enough not to cause safety problems.
1102.14, 1109	On-Street parking. Requires a set number of parking stalls per block.	Could need to be re-installed in locations where the adjacent uses of the block area changes causing existing stall to be in an undesirable location.	The appropriate locations could change as businesses change making it more difficult to design. Residential areas could pose a challenge.		Changes in the area could make stall locations undesirable and more difficult to use.		Costs could be significant if required at all city blocks including residential and commercial.	Require one on-street parking space per x-number of linear feet of public parking spaces or one space per specific number of public parking spaces. (Since block sizes are not consistent throughout the country, the current proposal would not provide proportionately equivalent parking for people with disabilities.)	Should be used only where street parking is clearly identified and marked. Should not be done in residential and certain industrial areas if parking stalls are not marked.
1104.2.1.1 1104.2.1.2 1105.2	Cross slope and running slope.	Trying to comply could create other safety concerns.	A tabled intersection is not always feasible to construct with existing site conditions.	Could be more difficult for snow removal.	Unreasonable in many situations. A tabled intersection could reduce the ride-ability of the intersection.		Depending upon the intersection and location, could become extremely expensive.	Try to match existing conditions as much as is practical without creating or increasing other safety concerns.
1104.3.2 1108.1	Detectable warnings consisting of truncated domes.	Problems with ice and snow removal. Painted surfaces are slippery when wet.	Increased difficulty of construction which would likely result in improper construction.	Domes could pose maintenance problem if they are broken off and need to be repaired.	May be more difficult for wheelchair users especially in poor weather and/or winter conditions.		Additional expense would be incurred.	Slopes that are greater than 1:15 can serve as detectable warnings. Tiles, raised concrete could be used depending upon the local meteorological patterns. Imbedded, textured, colored plastic (i.e. Lexan, etc.) could be used to provide a different feel and sound. These could be circles or squares. In downtown areas, plastic inserts could also be lighted for enhanced visual contrast.
1105.3	Increased signal phase timing for pedestrians.				Increases vehicular delays.	Increased air emissions due to vehicular delays.	Degradation of air quality could result in loss of federal funding.	Encourage larger pedestrian refuges (center median) as needed for wide roads or coordinate longer pedestrian durations with the flow of the traffic.
1105.5.3	Requires an elevator or lift platform access if elevation exceeds 60 inches in ....	Unattended elevators or lifts could pose safety problems to small children and others.		Maintenance problems inherent with outdoor equipment of this nature. Vandalism problems w/ unattended lifts or elevators.	Security problems.		Very Costly.	Require ramp access with appropriate landings.
1105.6.2 1106	Signals at roundabouts.	Could cause drivers to become inpatient or stack vehicles back into roundabout.	Right of way issues.	Additional maintenance concerns as opposed to a traditional roundabout.	Defeats the purpose of a roundabout and increases vehicular delays.	Increased air emissions due to more stopping and idling.	Costly. Degradation of air quality could result in loss of federal funding.	Use textured crosswalks. Crosswalks could also be elevated to act as speed tables and create higher visual awareness of pedestrians.	Many would not be warranted by traffic volumes.
1105.7 1106	Turn lane signalization.			Additional maintenance concerns as opposed to traditional turn lanes.	Defeats the purpose of a turning lane, increases vehicular delays and congestion.	Increased air emissions.	Costly. Degradation of air quality could result in loss of federal funding.	Use textured crosswalks. Crosswalks could also be elevated to act as speed tables and create higher visual awareness of pedestrians.
1106	Accessible pedestrian signals.						Additional costs.	Pedestrian phases could be included at all intersections.	Audible devices are currently being installed as requested.
1106.4.2	Braille street name signs			Could create increased vandalism when signs are within the public’s reach			Additional costs.	If required, should be mountable plaques that could be attached to standard fixtures.