Andrew J. Davis, P.E.

October 28, 2002

City of Akron
Akron Engineering Bureau


The “Draft Public Rights-of-Way Accessibility Guidelines” were circulated throughout various departments of the City of Akron. We are forwarding to you a compilation of comments that were received for use in the development of accessibility guidelines for the public right-of-way.

1. Our city is older and the majority of new development has already occurred. We are mainly concerned with “alterations” and need guidance for applying the new construction standards to existing conditions. We recommend you put a guidance manual for alterations out for public comment as well. When the final rule for public right-of-ways is enacted, the final “alterations manual” should be issued as a companion.

2. Some of the suggested improvements such as tabling intersections, providing elevators, and possible right-of-way acquisition may have significant financial impacts. We request guidance on scoping ADA improvements for various types of projects, and we ask for guidance on how to define feasibility from a financial standpoint.

3. We recommend reserving the requirements for elevators on pedestrian bridges over expressways and the requirements at roundabouts until further research can be provided on these matters.

4. A number of requirements seem excessive if applied universally: Accessible Pedestrian Signals (APS) at all signal locations; 3 feet per second crossing time, one accessible parking space on each block face. Some of these improvements should be driven by engineering analysis, a study of usage, or citizen request. Many of the traffic control features on existing roadways are determined this way, by a warrant based on volume or some other measure, or by a request (such as a school).

5. If the requirement to increase crosswalk striping width by two feet were implemented, this should only be done on new striping locations or after a street has been resurfaced. It is difficult to erase existing striping and repaint. The cost would be very high if required to restripe all crossings in one year.

6. Requiring APS installation at all existing pedestrian signals/buttons will be very costly if required to convert existing equipment immediately. Many cities may eliminate pedestrian buttons for this reason.

7. Narrow streets may limit the aisle from being installed for accessible parking.

8. The 120” between pedestrian signal devices may be prohibitive in existing narrow right-of-ways. More alternatives are needed. Perhaps mounting of devices on a single combined pole would be acceptable. Does the 120” rule apply to the pedestrian signal head also?



9. The definition of “public right-of-way” needs to be more specific. Several of the definitions should match current engineering/public works usage to avoid confusion.

10. 1102.1 – Clarify for applications that may overlap the public right-of-way such as public buildings that may encroach the right-of-way; utility tunnels; vaults.

11. “Maximum extent feasible” and “technically infeasible” are very relative terms. Please provide specific guidelines, applications, and examples of what is acceptable practice in alterations to existing right-of-ways.

12. Alternate Circulation Route for construction will be either very expensive or impractical. Often construction practice allows the closing of routes to expedite the work. Often the existing condition of the sidewalk may be inaccessible before a project begins.

13. 1104.3.3 It may be impractical to move certain grates and utility covers from ramp locations depending on their existing location, space available, and cost to move relative to project cost.

14. 1104 The notes in the front indicate the preference for dual ramps per corner. The way section 1104 is written it does not exclude or discourage the use of diagonal ramps. Practically, diagonal ramps will need to be allowed due to right-of-way constraints. Ramp orientation even with dual ramps can vary enough that the ramps should not be used as a cue for directionality. As section 1104 is written diagonal ramps would be accepted and used on the majority of intersections in our city, except where existing right-of-way is wide enough to accommodate two ramps.

15. More could be said regarding parallel ramps and the “depressed landing”. Any ramp with a “depressed landing” is subject to problems with drainage and debris collection. They should only be used as a last resort in the narrowest right-of-ways. More could be said to describe blended transitions or “combination type” ramps. In fact, this type may be the most used due to right-of-way constraints. Perhaps a requirement for proper drainage should be included.

We thank you for the opportunity to comment on your draft guidelines and hope our comments help with your work.

Please contact Andy Davis at [...] if you need further information.

Sincerely,

Andrew J. Davis, P.E.
Civil Engineer III

Approved:
David J. Celik, P.E.
City Engineer