Arizona Department of Transportation

October 21, 2002

Arizona Department of Transportation
Intermodal Transportation Division

RE: COMMENTS ON AMERICANS WITH DISABILITIES ACT DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY

Dear Mr. Windley:

The Arizona Department of Transportation (ADOT) has reviewed the Americans With Disabilities Draft Guidelines for Accessible Rights-of-Way published on 17 Jun 2002. ADOT endorses the Board’s aim of ensuring that access for persons with disabilities is provided wherever a pedestrian way is newly built or altered, and that the same degree of convenience, connection, and safety afforded the public generally be available to pedestrians with disabilities.

Noting our endorsement of the Board’s aim, we have taken the time to comment on each of the sections and sub sections to the draft guidelines in hope of assisting in the rulemaking process. The comments are enclosed for consideration by the Architectural and Transportation Barriers Compliance Board. We understand that the Board will review all the comments submitted prior to continuing with the proposed rulemaking.

Please contact Kenneth Cooper at [...] if you or the Board have any questions or if you wish to discuss the comments.

Sincerely yours,

Victor M. Mendez, P.E.
Director


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COMMENTS FROM ARIZONA DEPARTMENT OF TRANSPORTATION

AMERICANS WITH DISABILITIES ACT
DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY
PUBLISHED JUNE 17, 2002

General Comments:

A. The Arizona Department of Transportation (ADOT) supports the position expressed in the Introduction to the Draft Guidelines for Accessible Public Rights-of-Way that, “The guidelines do not require alterations or retrofits to existing public rights-of-way, but would apply where a pedestrian route or facility is altered as part of a planned project to improve existing public rights-of-way.”;

B. ADOT recommends the inclusion of graphics to help clarify and explain the guidelines; and

C. ADOT strongly recommends that maximum crosswalk, landing, and ramp slopes be redefined to take into account the grade of the adjacent facility. It may be technically infeasible and poor engineering practice to provide running and/or cross slopes of 1:48 when the grade of the adjacent roadway exceeds two percent (2%).

Sec. 1101 Application and Administration

Sec. 1101.1 General: For the purposes of these requirements, the terms listed in section 1101.3 shall have the indicated meaning.

ADOT has “No comment” on this section.

Sec. 1101.2 Referenced Standards

Recommend that the following manuals also be included by reference into the guidelines as they provide nationally accepted guidance regarding the design of roadways and pedestrian facilities:

A. American Association of State Highway and Transportation Officials (AASHTO), A Policy on Geometric Design of Highways and Streets 2001;

B. AASHTO, Roadside Design Guide 2002; and

C. Federal Highway Administration, Highway Design Handbook For Older Drivers and Pedestrians 2001.

Sec. 11012.1 MUTCD: Copies of the referenced standards may be obtained on-line from the Federal Highway Administration at http://mutcd.fhwa.dot.gov. MUTCD 2000-Millennium Edition Manual on Uniform Traffic Control Devices.

The Arizona Department of Transportation (ADOT) supports the inclusion of the Manual on Uniform Traffic Control Devices (MUTCD) into the guidelines by reference.

Sec. 1101.3 Defined Terms:

ADOT requests a definition be added that clarifies where slope maximum and minimum values are provided, “maximum” and “minimum” refer to the steepness of the slope.

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.

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.

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).

ADOT requests clarification of this definition as the second sentence is not wholly correct. Curves in the public right-of-way may have a normal crown and not be superelevated. Superelevation usually occurs, but not exclusively, in rural settings and where the prevailing speed is greater than 35 miles per hour.

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.

ADOT requests clarification of this definition as it appears to conflict with the requirements for crosswalk width as detailed in Sec. 1105.2.1 Width since existing sidewalks are often less than ninety-six inches (96-in) in width. Sidewalks location is quite variable in relation to the curb line while the location of the crosswalk should be established beyond the stop bar, if present, and stop bar location is a function of the radius of the intersection. Therefore, ADOT recommends that the location of the crosswalk not be defined in relation to the sidewalk location.

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

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

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.

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

Grade. (See running slope).

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

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

Pedestrian Access Route. An accessible corridor for pedestrian use within 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.

ADOT recommends adding the phrase “and under the jurisdiction of a public agency.” As written, the definition could also define parking lots or private transportation facilities such as found in gated communities.

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.

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.

Recommend replacing the word “lateral” with “edge” and the term “adjacent property” with “right-of-way”.

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.

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

Recommend deletion of this term.

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.

Sec. 1102 Scoping Requirements

Sec. 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.

ADOT supports the position that the new guidelines apply to areas of newly designed and constructed facilities in public rights-of-way and requires provision of sidewalks, street crossings, street furniture, parking, or other pedestrian elements only where they are provided as part of construction or improvement projects. ADOT supports clarification of the guideline explicitly stating that pavement-surface treatment projects such as seal coats, friction-course overlays, and mill-and-replace projects not be considered as construction or improvements triggering compliance with these guidelines.

Sec. 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.

Sec. 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.

ADOT has “No comment” on this section.

Sec. 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.

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

ADOT supports the position that the guidelines apply to alterations to existing facilities only in relation to the scope of the project. We think the term “technically infeasible” should be expanded to clearly include consideration of site conditions and topography. We also support the position that lack of existing public right-of-way may be a sufficient reason to prevent the widening of sidewalks and would like to see language in the guideline relieving agencies of any obligation to purchase additional right-of-way. ADOT could support sidewalk widening through the use of no-cost, dedicated pedestrian easements over private land. ADOT also supports the position that new facilities should smoothly transition into older ones.

Sec. 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.

ADOT supports the position that an alteration of an existing area of a public right-of-way shall not impose a requirement for accessibility greater than required for new construction.

Sec. 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.

ADOT supports the position that an alteration shall not decrease the accessibility of a public right-of-way below the requirement for new construction at the time of the alteration.

Sec. 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.

ADOT strongly opposes adoption of this section as written. The current language could require the construction of an alternative circulation path for situations such as the short-term maintenance of the sidewalk or adjacent road. See Section 1111 Alternate Circulation Path for further comments. Compliance would present an unacceptable burden upon the State and local jurisdictions, and the motoring public without a commensurate benefit to pedestrians.

Sec. 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.

ADOT supports the position that where sidewalk is provided it should contain a continuous pedestrian access route (PAR) connecting to elements required to comply with Chapter 11.

Sec. 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.

ADOT has “No comment” on this section.

Sec. 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.

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

ADOT has “No comment” on this section.

Sec. 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.

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

ADOT requests clarification of this guideline in the form of a graphic representation. It appears that the last sentence contradicts guidance given in the first sentence by allowing the lowest edge of a sign to be mounted at 27 inches, maximum, above the finish floor or ground rather than the upper edge.

Sec. 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.

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

ADOT requests clarification of this proposed guideline. Does the term “guardrail” refer to vehicular w-beam or thrie beam, or is it a pedestrian-type barrier? Regardless of the definition, we are concerned that guardrail installed at twenty-seven inches (27 in), adjacent to the PAR, could constitute a tripping hazard for the visually impaired.

Sec. 1102.6 Curbs 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

ADOT supports the proposed guideline requiring that curb ramps be placed in-line with the crosswalk they serve; curb cuts at the mid-point of the curb radius will normally not be allowed. This may effectively double the number, and cost, of curb ramps required on construction projects, but the total cost of such ramps is minimal in terms of the larger project. We note however that sound engineering judgment may dictate the use of only one ramp at a particular intersection due to site geometry and conditions.

Sec. 1102.7 Pedestrian Signs: Signs for pedestrian use shall comply with 1102.7.

ADOT supports the proposed guideline as written. It reiterates guidance given in the MUTCD.

Sec. 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.

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.

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. (Sec. 703 Signs can be found on the Access Board website at http://www. access-board.gov/ada-aba/htm l/tech-0 7. html).

ADOT has “No comment” on this section.

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

ADOT has “No comment” on this section.

Sec. 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.

ADOT strongly opposes this guideline. See Sec. 1105 Pedestrian Crossings for further comment.

Sec. 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. (Sec. 309 Operable Parts can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-03.html)

ADOT has “No comment” on this section.

Sec. 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 (Sec. 504 Stairways can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-05.hmtl)

ADOT has “No comment” on this section.

Sec. 1102.11 Handrails: Where provided, handrails shall comply with 505. (Sec. 505 Handrails can be found on the Access Board website at http.//www.access-board.gov/ada-aba.html/tech-05.hmtl)

ADOT has “No comment” on this section.

Sec. 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 (Sections 407, 408 & 410 can be found on the Access Board website at http://www. access-board.gov/ada-aba/html/tech-04.hmtl)

ADOT has “No comment” on this section.

Sec. 1102.13 Bus Stops. Bus boarding and alighting areas shall comply with 810.2. Bus shelters shall comply with 810.3. (Sections 810.2 & 810.3 can be found on the Access Board website at http://www. access-board.gov/ada-aba/html/tech-08.html)

ADOT has “No comment” on this section.

Sec. 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.

ADOT strongly opposes this guideline. See Sec. 1109 On-Street Parking for further comments.

Sec. 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.

ADOT has “No comment” on this section.

Sec. 1102.16 Call Boxes: Where provided, call boxes shall comply with 1110.

See Sec. 1110 Call Boxes for comments.

Sec. 1103 Pedestrian Access Route

Sec. 1103.1 General: Pedestrian access routes shall connect to elements required to be accessible and shall comply with 1103.

ADOT supports the proposed guideline as written.

Sec. 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 h/is. All components of a pedestrian access route shall comply with the applicable portions of this chapter.

ADOT has “No comment” on this section.

Sec. 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.

ADOT supports the proposed guideline as written.

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

ADOT supports the goal of the proposed guideline, but requests clarification of how the term “technically infeasible” will be applied to pedestrian access routes in areas with greater than a two percent (2%) grade.

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

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. (Sec. 405 Ramps can be found on the Access Board website at http://www. access-board. gov/ada-aba/html/tech 04.hmtl)

ADOT cannot support the proposed guideline because the exception requires the maximum running slope of the PAR to be less than 1:20. See Sec. 1105.2.2 Pedestrian Crossings Cross Slope for further comments.

Sec. 1103.6 Surfaces: The surfaces of the pedestrian access route shall comply with 302. (Sec. 302 Floor or Ground Surfaces can be found on the Access Board website at http://www. access- board.gov/ada-aba/htm l/tech-03.hmtl).

ADOT supports the proposed guideline as written.

Sec. 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-’/2 inches (64 mm).

EXCEPTION: On tracks that carry freight, a maximum horizontal gap of 3 inch (75 mm) shall be permitted.

ADOT has “No comment” on this section.

Sec. 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.

ADOT supports the proposed guideline as written.

Sec. 1103.8 Changes in Level.’ Changes in level shall comply with 303. Changes in level shall be separated horizontally 30 inches (760 mm) minimum. (Sec. 303 Changes in Level can be found on the Access Board website at www.access-board.gov/ada-aba/html/tech-03.hmtl). EXCEPTION: The horizontal separation requirement shall not apply to detectable warnings.

ADOT requests clarification of this guideline. What is meant by “Changes in level shall be separated horizontally 30 inches minimum.”

Sec. 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.

ADOT supports the proposed guideline as written.

Sec. 1104 Curb Ramps and Blended Transitions

Sec. 1104.1 General.’ Curb ramps and blended transitions shall comply with 1104.

ADOT has “No comment” on this section.

Sec. 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.

ADOT cannot support this section because it does not include provision for curb ramps that are in-line with a crosswalk, but neither perpendicular nor parallel. Good engineering practice may include design and construction of non-perpendicular and non-parallel curb ramps.

Sec. 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.

ADOT supports this guideline as written.

Sec. 1104.2.1.1 Running Slope: The running slope shall be 1:48 minimum and 1.12 maximum.

ADOT cannot support this guideline as written because it ignores the possibility of site-specific conditions which could result in running slopes greater than 1:12.

Sec. 1104.2.1.2 Cross Slope: The cross slope shall be 1:48 maximum.

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

ADOT cannot support this guideline and requests that the guideline be reworded to allow the cross slope to match the existing roadway grade. The proposed guideline has an unanticipated and unacceptable consequence when a curb ramp is provided on a facility with greater than a 1:48 longitudinal slope. To comply with this guideline the ramp would either have to be warped between the curbline and the top of the ramp, or the profile of the roadway would have to be modified in the vicinity of the curb ramp to no more than a 1:48 longitudinal slope. Neither one of these options is advisable. The first method, ramp warping, would involve excessive labor in placing and finishing the concrete, and difficulty regarding the placement of the tactile warning strip. The second method, modifying the longitudinal slope, is inadvisable because the algebraic difference of the roadway slopes could trigger the requirement for vertical curves. These requirements are detailed in the American Association of State Highway and Transportation Engineers manual, A Policy on Geometric Design of Highways and Streets The same exception applied to mid-block crossings should be applied to crossings perpendicular to roadways with a longitudinal slope greater than 1:48.

Sec. 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.

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

ADOT supports the requirement for a minimum of a 48-inch by 48-inch landing at the top of the curb ramp. However, we cannot support the guideline language for maximum running and cross slopes of 1:48. At locations where the sidewalk longitudinal grade exceeds two percent (2%) the running slope requirement could not be met without changing the grade. This would run counter to the guidance from Sec. 1103.5 Grade that allows the grade of the PAR within a sidewalk to match the grade established for the adjacent roadway. We would like to see the guideline exception extended to all crossings at the same grade as the adjacent roadway.

Sec. 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.

ADOT cannot support the proposed guideline as written because it ignores site-specific conditions that might require a flare slope of greater than 1:10.

Sec. 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.

ADOT supports this guideline.

Sec. 1104.2.2.1 Running Slope: The running slope shall be 1:48 minimum and 1:12 maximum.

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

ADOT cannot support this guideline as written as it would require extensive engineering and construction efforts in areas where the sidewalk and PAR were adjacent to a roadway with a grade greater than eight and one-third percent (8.33%). We do support a maximum ramp length of fifteen feet (15 ft).

Sec. 1104.2.2.2 Cross Slope: The cross slope shall be 1:48 maximum.

ADOT cannot support this guideline as written as it ignores site-specific conditions that could result in the cross slope being greater than 1:48 without extensive engineering and construction efforts.

Sec. 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.

ADOT supports the guideline requirement for a minimum 48-inch by 48-inch landing at bottom of the parallel ramp. However, we oppose the guideline for maximum running and cross slopes of 1:48 because sidewalks and PARS slopes should be allowed to follow the grade of adjacent roadways. In most instances it would require considerable engineering and construction efforts to provide sidewalk and PAR slopes independent of the adjacent roadway. We would like to see the guideline exception extended to all crossings at the same grade as the adjacent roadway.

Sec. 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.

ADOT supports the proposed guideline as written, but requests clarification of what constitutes a “barrier”.

Sec. 1104.2.3 Blended Transitions: Blended transitions shall comply with 1104.3, and shall have running and cross slopes of 1:48 maximum.

ADOT cannot support the guideline because of its call for maximum running and cross slopes of 1:48 which may be infeasible for a given site.

Sec. 1104.3 Common Elements: Curb ramps and blended transitions shall comply with 1104.3.

Sec. 1104.3.1 Width: The clear width of landings, blended transitions, and curb ramps, excluding flares, shall be 48 inches (1220 mm) minimum.

ADOT supports the proposed guideline as written.

Sec 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.

ADOT supports the proposed guideline, noting however the comments we’ve provided pertaining to Sec. 1108 Detectable Warning Surfaces.

Sec. 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.

ADOT requests a rewording of second sentence of this guideline to acknowledge that circumstances will occur that may require the placement of gratings, access covers, and other appurtenances within the PAR.

Sec. 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.

ADOT requests clarification of the last sentence and what is meant by “surface slopes” and how they shall be “flush”.

Sec. 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.

ADOT requests clarification of “vertical changes in level”.

Sec. 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.

ADOT requests that definition of the term “counter slope” be provided.

Sec. 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.

ADOT strongly opposes this guideline. This guideline would result in an increase in the roadway width by forty-eight inches (48 in) on each side of the road at every ramp location for a total of ninety-six (96 in or 8 ft) at every crosswalk location. There is no rationale presented to justify this guideline; wheelchairs can wait at the top of the landing for the WALK phase. The proposed new guideline for Sec. 1105.3, Pedestrian Signal Phase Timing, takes the ramp length into account for the calculation of the total crossing time.

Sec. 1105 Pedestrian Crossings

Sec. 1105.1 General: Pedestrian crossings shall comply with 1105.

Sec. 1105.2 Crosswalks: Crosswalks shall comply with 1105.2.

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

ADOT cannot support the proposed guideline as written because it mandates a minimum width contrary to that called for in the MUTCD. Section 3B.17 Crosswalk Width of the MUTCD calls for a minimum width of six feet (6 ft), which is research based. Nothing has been presented to show the necessity of widening a crosswalk to eight feet (8 ft).

Sec. 1105.2.2 Cross Slope: The cross slope shall be 1.48 maximum measured perpendicular to the direction of pedestrian travel.

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

ADOT strongly opposes this guideline. The effect of this guideline could be monumental in locations where the longitudinal grade of the roadway exceeds two percent (2%, 1:48 slope). The cross slope of pedestrian crossings perpendicular to the longitudinal grade would be out of compliance with no practical way to remedy the situation. This guideline might better be written to set a goal of a 1:48 slope for the pedestrian crossing cross slope, but contain language acknowledging that existing site conditions may preclude achieving the goal. Mid-block crossings are already exempted under the proposed guideline

Sec. 1105.2.3 Running Slope: The running slope shall be 1.20 maximum measured parallel to the direction of pedestrian travel in the crosswalk

ADOT cannot support this guideline as it would have a negative effect on the placement of marked pedestrian crossings on roadways with grades steeper than five percent (5%, 1:20 slope). The running slope of pedestrian crossings parallel to the longitudinal grade would be out of compliance with no practical way to remedy the situation. This guideline might better be written to set a goal of a 1:20 slope for the pedestrian crossing running slope, but contain language acknowledging that existing site conditions may preclude achieving the goal.

Sec. 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.

ADOT cannot support this guideline as it would impact the pedestrian signal phase timing of almost every traffic signal in the State and two of the consequences would be overwhelming. First, almost every traffic signal in Arizona would have to be re-timed to account for the increase in pedestrian travel length. The current MUTCD guidelines for pedestrian signal phase timing allow the length to be measured from the curb face to the center of the furthest through travel lane. This guideline would add a minimum of fourteen feet (14 ft) to the length which equates to a minimum addition of 4.67 seconds to the pedestrian signal phase length. This could have the consequence of de-optimizing the signal timing at traffic signals and increasing the traffic delay experienced by the other roadway users. Second, all the coordinated signal systems in Arizona would have to be retimed to account for the longer pedestrian phase. This would be an expensive, time-consuming process which would involve most of the local traffic engineers to the detriment of their other responsibilities.

Sec. 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 withllO4 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.

ADOT cannot support this guideline because the language in Sec. 1104 Curb Ramps is already overly restrictive at locations with roadway grade is greater than two percent (2%) (see comment for Sec. 1104.2.1.2 Cross Slope, above).

Sec. 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.

ADOT cannot support this guideline as our current standard width for medians at intersections is forty-eight inches (48 in).

Sec. 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.

ADOT cannot support this guideline as our current standard width for medians at intersections is forty-eight inches (48 in.

Sec. 1105.5 Pedestrian Overpasses and Underpasses: Pedestrian overpasses and underpasses shall comply with 1105.5.

Sec. 1105.5.1 Pedestrian Access Route: Pedestrian overpasses and underpasses shall contain a pedestrian access route complying with 1103.

ADOT supports the proposed guideline as written.

Sec. 1105.5.2 Running Slope: The running slope shall not exceed 1:20 maximum.

ADOT cannot support the proposed guideline as written as it could require the running slope of the PAR to be independent of the longitudinal grade of the adjoining roadway. To require a PAR running slope less than 1:20, independent of the adjoining roadway grade, would require extensive engineering and construction at locations where the adjacent roadway grade is greater than five percent (5%). We support the position that the PAR running slope should not exceed the slope of the adjacent roadway.

Sec. 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. (Sec. 405 Ramps, Sec. 407 Elevators, and Sec. 408 Wheelchair (Platform) Lifts can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-04.hmtl)

ADOT supports the part of the guideline pertaining to minimum ramp width. We strongly oppose that part calling for a limited-use/limited-application or standard elevator where the rise of the ramped approach exceeds sixty inches (60 in). We are deeply concerned that about the safety of pedestrians using such elevators and think it inadvisable to install elevators if we cannot guarantee pedestrian security. In Arizona there are also regular, but unplanned interruptions in electrical service due to electrical storms in the summer and snow storms in the winter. These interruptions could trap people in the elevators without any simple means of extricating them until power is restored. Equally as important in our opposition to the requirement for elevators are their exorbitant costs and the notion we should provide a facility for disabled pedestrians which is well beyond what we’d provide for pedestrian traffic in general.

Sec. 1105.5.4 Stairs: Stairs shall comply with 504. (Sec. 504 Stairways can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-05.hmtl)

ADOT has “No comment” on this section.

Sec. 1105.5.5 Escalators: Escalators shall comply with 810.9.

ADOT has “No comment” on this section.

Sec. 1105.6 Roundabouts: Where pedestrian crosswalks and pedestrian facilities are provided at roundabouts, they shall comply with 1105.6.

Sec. 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.

ADOT strongly opposes this guideline as written because of its possible negative impacts on motorist and pedestrian safety. If handrail is used as a barrier on sidewalks abutting the curb it could present a spearing hazard to motorists. Other types of barrier could present tripping hazards to pedestrians if placed lower than twenty-seven inches (27 in) and a sight restriction to motorists if places above that point. We would like to know why sidewalk at a roundabout is being treated differently from that at any other street intersection?

Sec. 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.

ADOT cannot support this guideline as written. It is inadvisable to promulgate a guideline that would mandate the installation of any traffic control signal without an engineering study to confirm the need for such a signal. Warrants for installation of a signal would investigate such variables as sight distance, traffic volume, pedestrian volume, vehicle speed, and vehicle gap.

Sec. 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.

ADOT cannot support this guideline as written. We request a definition for the term “slip lane” be added to Sec. 1101.3 Terms. Within the Arizona highway system unrestricted right turns are sometimes provided at freeway ramps to handle the volume of exiting traffic. The installation of a signal could cause a dangerous situation where off-ramp traffic would back up onto the freeway. Again, without a case-by-case engineering study, as detailed in the MUTCD, it would be inadvisable to mandate installation of a signal at these locations.

Sec. 1106 Accessible Pedestrian Signal Systems

Sec. 1106.1 General: Pedestrian signal systems shall comply with 1106.

Sec. 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.

ADOT strongly opposes this guideline as written. We see no added value to implementing this guideline, and a possible increased liability due to system failure and application inconsistency.

Sec. 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.

EXCEPTION: The minimum distance from other signal devices shall not apply to signal devices located in medians and islands.

ADOT cannot support the proposed guideline as written because locating all traffic control devices should be done as part of a site-specific engineering study. We think it would be poor engineering practice to utilize this guideline without an investigation of the site and analysis thereof.

Sec. 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. (Sec. 308 Reach Ranges and Sec. 305 Knee and Toe Clearance can be found on the Access Board website at http://www. access-board.gov/ada-aba/html/tech-03.html)

ADOT has “No comment” on this section.

Sec. 1106.2.3 Audible Walk Indication: The audible indication of the WALK interval shall be by voice or tone.

ADOT cannot support this guideline as written. Because of the number of different languages spoken in Arizona it would be technically infeasible to provide any message, in every language, in a timely manner. To arbitrarily decide not to offer the message in a particular language could also leave this Department open to charges of not providing equal access to public services. Also, as noted above, advocacy groups for the visually impaired have not achieved a clear consensus regarding the need for and design of audible and vibrotactile indications.

Sec. 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.

ADOT has “No comment” on this section.

Sec. 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.

ADOT cannot support this section of the guidelines because the sound level produced could be considered a nuisance, particularly in the evening hours and at locations in residential neighborhoods.

Sec. 1106.3 Pedestrian Pushbuttons: Pedestrian pushbuttons shall comply with 1106.3.

Sec. 1106.3.1 Operation. Pedestrian pushbuttons shall comply with 309.4. (Sec. 309.4 Operation can be found on the Access Board website at http://www.access board.gov/ada-aba/html/tech-03.hmtl)

ADOT has “No comment” on this section.

Sec. 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.

ADOT cannot support the proposed guideline because the sound level produced could be considered a nuisance, particularly in the evening hours and at locations in residential neighborhoods.

Sec. 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.

ADOT supports the proposed guideline as written.

Sec. 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.

ADOT has “No comment” on this section.

Sec. 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.

ADOT cannot support this section as the name of streets served by a particular crosswalk is not currently provided at any location. Each location would require costly, custom-made signs which would have to be replaced if damaged or otherwise vandalized.

Sec. 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

ADOT can support this guideline.

Sec. 1106.4.2 Street Name. Signs shall include street name information aligned parallel to the crosswalk direction and complying with 703.2. (Sec. 703.2 Characters That Are Both Tactile and Visual can be found on the Access Board website at http://www.access board.gov/ada-aba/html/tech-07.html)

ADOT cannot support this section of the guidelines because it puts an unreasonable burden on the State and other jurisdictions to produce costly, custom-made signs for each location.

Sec. 1106.4.3 Crosswalk Configuration: Where provided, graphic indication of crosswalk configuration shall be tactile and shall comply with 703.5.1. (Sec. 703.2 Location can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-07.hmtl)

ADOT can support this section as long as there is no requirement to provide graphic indication of the crosswalk configuration.

Sec 1107 Street Furniture

Sec. 1107.1 General: Street furniture shall comply with 1107.

Sec. 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. (Sec. 305 Clear Floor or Ground Space can be found on the Access Board website at www.access-board.gov/ada-aba/html/tech-03.hmtl)

ADOT support this section of the guidelines.

Sec. 1107.3 Drinking Fountains: Where drinking fountains are provided, they shall comply with 602. (Sec. 602 Drinking Fountains and Water Coolers can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-06.hmtl)

ADOT has “No comment” on this section.

Sec. 1107.4 Public Telephones: Where public telephones are provided, they shall comply with 1107.4.

ADOT has “No comment” on this section.

Sec. 1107.4.1 Single Telephone: Where a single public telephone is provided, it shall comply with 704.2 and 704.4. (Sec. 704.2 Wheelchair Accessible Telephones and Sec. 704.4 TTYs can be found on the Access Board website at http://www.access board.gov/ada-aba/html/tech-07.html)

ADOT has “No comment” on this section.

Sec. 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.

ADOT has “No comment” on this section.

Sec. 1107.4.3 Volume Controls: A 11 public telephones shall provide volume controls complying with 704.3. (Sec. 704.3 Volume Control Telephones can be found on the Access Board website at http.//www. access-board.gov/ada-aba/html/tech-0 7.html)

ADOT supports the proposed guideline as written.

Sec. 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. (Sec. 603 Toilet and Bathing Rooms and Sections 604 through 610 can be found on the Access Board website at http.//www.access-board.gov/ada-aba/html/tech-06.html, Sec. 309 Operable Parts at http.//www.access-board.gov/ada-aba.html/tech-03.html and Sec. 703.7.2.1 Finish and Contrast at http.//www. access-board.gov/ada-aba/html/tech-07.html.)

ADOT has “No comment” on this section.

Sec. 1107.6 Tables, Counters, and Benches: Tables, counters, and benches shall comply with 1107.6.

Sec. 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. (Sec. 902 Dining Surfaces and Work Surfaces can be found on the Access Board website at http.//www.access-board.gov/ada-aba/html/tech-09.hmtl)

ADOT has “No comment” on this section.

Sec. 1107.6.2 Counters: Where provided, counters shall comply with 904. (Sec. 904 Sales and Service Counters can be found on the Access Board website at http://www. access-board.gov/ada-aba/html/tech-09.hmtl)

ADOT has “No comment” on this section.

Sec. 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 (Sec. 903 Benches can be found on the Access Board website at http://www. access-board.gov/ada-aba.html/tech-09.hmtl)

ADOT has “No comment” on this section.

Sec 1108 Detectable Warning Surfaces

Sec. 1108.1 General: Detectable warnings shall consist of a surface of truncated domes aligned in a square grid pattern and shall comply with 1108.

ADOT cannot support this guideline because it would restrict the free market development of truncated dome systems by prohibiting the diamond pattern. While the argument arises that the square pattern is friendlier to vibration- sensitive people, there is no research on the possible number of individuals affected. Depending on the dimensions used in the square or diamond pattern and the width of the wheelchair, its wheels will either hit or miss the truncated domes. Therefore, we see no reason to favor one pattern over another in the rulemaking process.

Sec. 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).

ADOT supports the proposed guideline as written.

Sec. 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

ADOT supports this guideline while recommending removal of reference to “square grid” from the last sentence (see comment on Sec. 1108.1 General, above).

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

ADOT supports the proposed guideline as written.

Sec. 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.

ADOT supports the proposed guideline as written.

Sec. 1108.2 Location

Sec. 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.

ADOT supports the proposed guideline as written.

Sec. 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.

ADOT supports the proposed guideline, but recommends the term “vehicle dynamic envelope” be used consistent with the term “dynamic envelope” as shown in Sec. 1103 Terms.

Sec. 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.

ADOT has “No comment” on this section.

Sec 1109 On-Street Parking

Sec. 1109.1 General: Car and van on-street parking spaces shall comply with 1109.

ADOT has “No comment” on this section.

Sec. 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.

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.

ADOT requests further clarification of this guideline before deciding whether we support it.

Sec. 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.

ADOT cannot support this guideline as written because the incremental value of a ninety-six (96-in) wide access aisle over the currently used sixty-inch (60-in) wide access aisle has not been established.

Sec. 1109.4 Curb Ramps or Blended Transitions: A curb ramp or blended transition complying with 1104 shall connect the access aisle to the pedestrian access route.

ADOT supports this guideline in concept, noting however the comments regarding the 1:48 slope (see comments on Sec. 1104.2.1.2 Cross Slope and Sec. 1104.2.1.3 Landing, above).

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

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

ADOT supports the proposed guideline as written.

Sec. 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. (Sec. 502 Parking Spaces can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-05.hmtl)

ADOT supports the proposed guideline as written.

Sec. 1109.7 Parking Meters: Where parking meters are provided, they shall comply with 1109.7.

ADOT supports the proposed guideline as written.

Sec. 1109.7.1 Operable Parts. Operable parts shall comply with 309. (Sec. 309 Operable Parts can be found on the Access Board website at http://www.access board.gov/ada-aba/html/tech-03.hmtl)

ADOT supports the proposed guideline as written.

Sec. 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 l or a passenger side transfer.

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.

ADOT supports the proposed guideline as written.

Sec. 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.

ADOT supports the proposed guideline as written.

Sec. 1110 Call Boxes

Sec. 1110.1 General: Call boxes shall comply with 1110.

ADOT has “No comment” on this section..

Sec. 1110.2 Operable Parts: Operable parts shall comply with 308 and 309.4. Where provided, labeling shall comply with 703.2 and 703.3. (Sec. 703 Signs can be found on the Access Board website at http.//www.access-board.gov/ada-aba/html/tech-07.hmtl)

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.

ADOT supports the proposed guideline as written.

Sec. 1110.3 Turning Space: A turning space complying with 304 shall be provided at the controls. (Sec. 304 Wheelchair Turning Space can be found on the Access Board website at http.//www. access-board.gov/ada-aba/htm l/tech-03.hmtl

ADOT supports the proposed guideline as written.

Sec. 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. (Sec. 405.9.2 Curb or Barrier can be found on the Access Board website at http://www.access-board.gov/ada-aba.html/tech-04.hmtl)

ADOT supports the proposed guideline, but would request further clarification regarding the terms “abrupt level change” and “edge protection”.

Sec. 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.

ADOT supports the basic guideline, but question the requirement of a sixteen-foot (1 6-ft) wide paved area. Provision of a thirteen-foot (1 3-fl) wide paved area is sufficient to provide for an eight-foot (8-ft) wide parking space and a five-foot (5-fl) wide access and the incremental value of an eight-foot (8-ft) wide access route has not been established route (see comment for Sec. 1109.2 Parallel Parking Spaces, above).

Sec. 1110.6 Two- Way Communication: Where provided, two-way voice communication shall comply with 1110.6, 708.2 and 708.3. (Sec. 708 Two-Way Communication Systems can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-07.hmtl)

ADOT has “No comment” on this section.

Sec. 1110.6.1 Volume Controls: Volume controls complying with 704.3 shall be provided (Sec. 704.3 Volume Control Telephones can be found on the Access Board website at http.//www. access-board.gov/ada-aba/html/tech-07.hmtl)

ADOT has “No comment” on this section..

Sec. 1110.6.2 TTY A TTY complying with 704.4 shall be provided (Sec. 704.4 TTYs can be found on the Access Board website at http://www.access-board.gov/ada-aba.html/tech-07.hmtl)

ADOT has “No comment” on this section.

Sec. 1111 Alternate Circulation Path

Sec. 1111.1 General: Alternate circulation paths shall comply with 1111.

ADOT supports the proposed guideline as written.

Sec. 1111.2 Width: The alternate circulation path shall have a width of36 inches (915 mm) minimum.

ADOT strongly supports the guideline requirement for the alternate circulation path minimum width of thirty-six inches (36 in).

Sections 1111.3 Location: The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street.

ADOT strongly opposes this guideline’s requirement for the “Alternate Circulation Path” to be located on the same side of the street as the disrupted PAR. This provision would impose a central-planning approach to traffic control for construction and maintenance operations, and would negatively impact pedestrian comfort and safety while creating an unreasonable burden upon State and local agencies. This provision does not appear to consider the following: A) the length of time a project is underway; B) the type and nature of the project; C) the probable negative impact upon the other users of the transportation facility due to reduced roadway capacity; D) the advisability of and risk inherent in moving pedestrians adjacent to construction or maintenance operations; E) the impact of noise on the pedestrian; nor F) the impact to construction programs, in terms of time and money spent on meeting this guideline.

This proposed guideline is also contrary to guidance provided by the Manual on Uniform Traffic Control Devices (MUTCD), Section 6D.O I Pedestrian Considerations This section of the MUTCD delineates three considerations, of which the first two address this matter. They are as follows:

A. Pedestrians should not be led into conflicts with work site vehicles, equipment, and operations. and

B. Pedestrians should not be led into conflicts with vehicles moving through or around the work site.

Further clarification is provided in the MUTCD on page 6D- 1 as, “Pedestrians should be appropriately directed with advance signing that encourages them to cross to the opposite side of the roadway.” (emphasis added) and 6D-2 as, “Whenever it is feasible, closing off the work site from pedestrian intrusion may be preferable to channelizing pedestrian traffic along the site with temporary traffic control devices such as cones, tubular markers, barricades and drums, or other suitable fencing.”

Sec. 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.

ADOT cannot support this guideline because the Alternate Circulation Path should not be adjacent to construction or maintenance operations (see comment on Sec. 1111.3 Location, above).

Sec. 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. . (Sec. 703.5 Braille can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-07.hmtl)

ADOT strongly supports the placement of signs, at both the near side and far side of the intersections preceding a disrupted PAR, encouraging all pedestrians to cross to the opposite side of the roadway wherever possible (see comment on Sec. 1111.3 Location, above).

Sec. 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.

ADOT cannot support this guideline as written because no temporary barricade system is totally “non- flexible”; temporary barricades differ by how much rigidity they provide. The proposed guideline would also prohibit the use of both Type II and Type III temporary barricades to define the alternative circulation path because they use “T-type” supports that would encroach into the path. Temporary concrete barrier (TCB), which can move up to three feet (3 ft) laterally when struck, would meet most of the intent of this guideline, however, TCB should not be used arbitrarily. Sound engineering judgment should be used to determine, on a case-by-case basis, the advisability of introducing another hazard (the TCB itself) onto the project. Indiscriminate use of TCB could put the public’s health, safety, and welfare at risk.