Minnesota Department of Transportation’s
Response to the Access Board
on
Draft Guidelines for Accessible Public Rights of Way

October 25, 2002

General Discussion
The Minnesota Department of Transportation’s (Mn/DOT) review of the Access Board’s Draft Guidelines for Accessible Public Rights of Way, surfaced broader themes and concerns about the guidelines, which are discussed here.

Flexibility
The wide range of environments that will be encountered by designers within the public right of way was clearly not considered. The rigidity of the guidelines do not allow for engineering judgement and do not respect the cultural, environmental, and physical conditions that a designer must consider on a site by site basis. The current approach of the guidelines may result in poor design, dangerous conditions, a reduction of general services, and operational shortcomings unless flexibility is introduced.

Availability of Resources
There is great concern that the guidelines have been developed without a context that takes the cost of construction and ongoing maintenance into consideration. While it has been made clear that the Access Board views cost as an issue of implementation to be managed by the FHWA and the Department of Justice, guidelines cannot be responsibly developed without these topics being taken into consideration. Many who provided comments are working within a transportation system where resources are already severely taxed?

Like many similar large DOT maintenance organizations, Mn/DOT does not have the budget to do sufficient maintenance on its systems. Therefore, we must put activities that are legally or clearly public safety related at the top of our list when we prioritize resource expenditures – including personnel time and materials. Prior to the proposed ADA requirements becoming law, there needs to be a discussion about expectations of how well these facilities are likely to be maintained with a clear understanding that all railings, signal devices, and surface treatments may not be fully functional at all times. Anything that puts the public in an unsafe condition is something that we must attend to, but if resources are strained we must compare fixing a system that interacts with hundreds or thousands of people above a system or device that substantively interacts with less than a dozen people. If cost is not considered at this time and guidelines are put forward that have cost prohibitive facilities as requirements, it is likely that pedestrian accommodation may be removed from new projects and less desirable improvements will be made to the existing network.

Liability
The guidelines have surfaced the issue of liability. It has been noted in the Mn/DOT response that the guidelines are requesting designers to meet Access Board requirements at the expense of other guidelines and standards that are already in place and enforceable. At this time designers are not being provided guidance on how to negotiate or balance conflicts and that will leave a situation where designers may simply choose not to include treatments. This gap will also invite a wide range of interpretation between the different types of guidance that is available to designers and will subsequently erode the uniformity and predictability that is being sought by Draft Guidelines for Accessible Public Rights of Way. As in the matter of cost the Access Board defers to the Department of Justice once the guidelines are in place, but there are many issues that should be addressed at this stage so that all users of the transportation system will be represented.

In closing Mn/DOT is seeking guidelines that will allow us to improve access within our transportation system and maintain balance between financial, cultural, and operational needs. The Access Board must consider how to responsibly recommend guidelines that can be implemented and will serve the needs of all users. Refinement of the guidelines is clearly needed to reach an acceptable balance point.
General Recommendations
Guideline Usability
To improve the overall usability of the guidelines, the following recommendations are made:
1. Use full citations when there is a cross-reference to another document so users can understand and quickly find the information referenced.
2. Future iterations should have more extensive graphics to illustrate the situations that are being described.
3. Conform to industry practice. (i.e. express grades as a percentage with rise over run in parentheses.)
4. Follow the federal standard for expressing units with metric units first, followed by English units in parentheses (e.g., 3.6 m (12 ft)). To provide additional clarity, Mn/DOT also bolds the English unit in its manuals.
5. Use decimals instead of fractions (e.g., 2.5 rather than 2½).
6. Use consistent unit convention (e.g., inch instead of ”)
7. Please provide an indication of what sort of documentation needs to be kept if the implemented design is challenged.
8. The guidelines do not explicitly state that they are design minimums. Perhaps, this is a topic that will be addressed once the guidelines are integrated into ADAAG, but as a stand-alone piece, the guidelines invite the interpretation that they are maximum specifications for facilities. This assumption should not be allowed to stand since there are many instances where facilities should be designed above the minimum recommendation.

Section Analysis
1101 Application and Administration
Section 1101.3 Defined Terms
There are several concerns with terms used within the guidelines because definitions are not clear or unnecessarily deviate from common industry definition. Specific concerns are as follows:
• Blended Transition: Add a definition for this term in this section. The intent of the term is not clear, because a definition is not provided.
• Crosswalk: Simplify the definition. Potential language could be as follows:
o Crosswalk - (1) That portion of a roadway ordinarily included with the connection of sidewalks at intersections; (2) Any portion of a roadway distinctly indicated for pedestrian crossing by lines or other markings on the surface.
• Dynamic Envelope: This is not a standard industry term and needs definition.
• Pedestrian Clearance Interval: A definition is requested for this term. The suggested language is: the interval following the walk interval, normally symbolized by a flashing “Hand” or “Don’t Walk.”
• Ramp: The following definition is proposed: a sidewalk with a slope greater than 5%, but not exceeding 8.33%.
• Running Slope: For clarity, it is requested that this term be removed and that the term “grade” be used exclusively.
• Superelevation: For clarity, it is requested that this term be removed and that the term “cross slope” be used exclusively.
• Technically Infeasible: Add a definition for this term in this section. The intent and appropriate application of the term is not clear, because a definition is not provided.

1102 Scoping Requirements
Section 1102.2 Alterations
Guideline Language: 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: An alteration where compliance is technically infeasible, the alteration shall comply to the maximum extent feasible.

Requested Change: 1. Additional clarity needs to be provided for the thresholds of alteration either through expanded language in the proposed guidelines or a reference to already existing language.

2. It is recommended that the explanation of technically infeasible found in section 4.1.6 of the July 26, 1991 Federal Register Part III, 28 CFR, Part 36 be restated here along with the exceptions that are within the purview of these guidelines.

Suggested Language: No recommendations.

Justification: The first change is needed to create clarity regarding when the guidelines should be used. As the guidelines are currently written it is unclear as to what types of projects the ADA requirements apply. Mn/DOT’s view is that the maintenance and minor improvement categories where the objective is to keep a facility smooth and open to traffic should be excluded. The second change is requested to provide a clear definition and guidance on the applicability of “technically infeasible” in relation to the guidelines. Given the volume of physical area that right-of-way covers, it would be reasonable to explicitly expand the definition of “technically infeasible” to include environmental site constraints and adverse environmental, social, community, and transportation system user impacts.

Section 1102.5.2 Post-Mounted Objects
Guideline Language: Free-standing objects mounted on posts or pylons shall overhang circulation paths 305 mm (4 in) maximum when located 685 mm (27 in) minimum and 2030 mm (80 in) maximum above the finish floor or ground. Where a sign or other obstruction is mounted between posts or pylons is greater than 305 mm (12 in), the lowest edge of such sign or obstruction shall be 685 mm (27 in) maximum or 2030 mm (80 in) minimum above the finish floor or ground.
EXCEPTION: This requirement shall not apply to sloping portions of handrails serving stairs and ramps.

Requested Change: Reword.

Suggested Language: Free-standing objects mounted on posts or pylons shall overhang circulation paths 100 mm (12 in) maximum when located 685 mm (27 in) minimum and 2030 mm (80 in).

Justification: The suggested change would result in uniform interpretation and application of the proposed guidelines between other guidelines already in force. The 12-inch maximum was established in 1991 under section 4.4.1 of the July 26, 1991 Federal Register, Part III, 28 CFR, Part 36 and is included in the ADAAG Section 307 referenced below. This guideline change will allow for uniform design of integrated roadway and multi-use projects and the development of uniform design standards for both site and roadway facilities.
307 Protruding Objects
307.1 General. Protruding objects shall comply with 307.
307.3 Post-mounted Objects. Free-standing objects mounted on posts or pylons shall overhang 305 mm (12 in) maximum when located 685 mm (27 in) minimum and 2030 mm (80 in) maximum above the floor or ground. Where a sign or other obstruction is mounted between posts or pylons and the clear distance between the posts or pylons is greater than 305 mm (12 in), the lowest edge of such sign or obstruction shall be 685 mm (27 in) maximum or 2030 mm (80 in) minimum above the floor or ground.

Section 1102.7.1 Bus Route Identification
Guideline Language: 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 ADAAG Section 703.2 where audible signs are user or proximity-actuated or are remotely transmitted to a portable receiver carried by an individual.

Requested Change: Delete text referencing non-existing sections of the proposed guideline changes in ADAAG Section 703.

Suggested Language: Bus route identification signs shall comply with ADAAG Sections 703.5.1 through 703.5.4. Bus route identification signs located at bus shelters shall provide raised and Braille characters complying with ADAAG Section 703.2, and shall have rounded corners.

Justification: Section 703.5.5, 703.5.7, and 703.5.8 are not published on the Access Board Web site. Until this text is available for review, references to these sections should be deleted due to the inability of the public to provide adequate review of conditions and impacts.

Section 1102.10 Stairs
Guideline Language: Where provided, stairs shall comply with 504. Stair treads shall have a 51mm (2 in.) wide strip of color contrasting with the tread and riser, the full width of the front edge of each tread.

Requested Change Delete the requirement for color strip.

Suggested Language: Where provided, stairs shall comply with ADAAG Section 504.

Justification: The existing standardized handrail design in accordance with ADAAG Section 504 extends horizontally at the top, bottom and landings of the stairs to delineate the edge of a transition change (edge of stair system). This is the most effective tool to communicate stair locations to a disabled person at all times of day and in all weather conditions. If necessary modify the handrail design guidelines to better communicate the location of the stair system. The addition of a strip of contrasting color is not justified and cannot be adequately maintained with the limited resources available.

The ability to develop a design solution that will meet both public safety and maintenance considerations, without creating a high level of liability, is highly questionable. Any system not maintained will present a liability for the transportation agencies.
Paint: non-permanent, often slippery when wet, high cost to maintain.
Nosing Material: often slippery when wet, a mix of materials allows a point of moisture and salt infiltration that will shorten the life of the structure.
Adhesives: non-permanent, maybe slippery when wet or snow covered, high cost to maintain, frequently delaminates in heat and cold conditions creating loose edges/trippers.
Visibility in snow conditions: not visible under snow cover.
Visibility at night without lighting:
The use of a well-designed handrail system is more useful and visible in all conditions and fully provides a reasonable accommodation for individuals of all abilities.
Context Sensitive Design/Aesthetic Considerations
A color edge strip of high contrast will visually dominate the setting and negatively impact community design objective to blend roadway elements sympathetically with architectural elements and the natural environment.

Section 1102.13 Bus Stops.
Guideline Language: Bus boarding and alighting areas shall comply with 810.2. Bus shelters shall comply with section 810.3.

Requested Change: Delete information referencing non-existing sections of the proposed guideline changes in Sections 810.2 and 810.3 of the ADAAG.

Suggested Language: Not Applicable.

Justification: Sections 810.2 and 810.3 of the ADAAG are not published on the Access Board Web site. Until this text is available for review all references to these sections should be deleted due to the inability of the public to provide adequate review of conditions and impacts.

Section 1102.14 On-Street Parking
Guideline Language: 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.

Requested Change: 1.Reword the original statement with additional text to allow for alternative compliance with the objectives of close easy access.
2.Clarify the definition of a block.
3. Clearly state the intent of the Access Board for this requirement to apply only to commercial areas.

Suggested Language: Where on-street parking is designated by striping or parking meters, on-street accessible parking stalls shall be uniformly distributed along the block faces at a ratio in compliance with Table 208.2 of the ADAAG and shall comply with 1109.
EXCEPTION: Accessible public off-street parking is provided within the block at a ratio of one parking stall per 25, with a minimum of one parking space for the total of all public parking spaces available per block, for both off-street and on-street parking.

Justification: Require On-Street Parking Only in High Use, Designated Public Parking Areas.
This requirement seems to be better targeted to designated parking, striped parking and metered parking. The requirement for one parking space along each curb face in all locations where parking is provided seems excessive. In many cities parking is allowed/provided in all residential areas. On-street parking spaces should not be required in non-commercial areas.

Proposed Distribution of On-Street Parking Seems Excessive
Mn/DOT agrees that a reasonable amount of On-Street parking needs to be provided, however, physical constraints must be considered. The size of a block varies by region and local urban design applications. Blocks in many Midwest communities provide no more than 6 parallel parking stalls per block face due to the curb space reserved for bus stops, driveways, passenger loading zones, service entrances and no parking zones such as at fire hydrants and turn lanes. For many communities this will reduce local parking supply for the general population by more than 17%. This ratio can be as high as 4 times or more than are required for private businesses and public facilities as specified in Table 208.2 of the ADAAG.

The number and type of businesses served by on-street parking also varies widely based on local zoning. For these reasons, use of a minimum criterion of two per block and a ratio of the total parking stalls available is recommended to establish the number of On-Street Parking spaces required.

Provide Local Governments with Design/Location Flexibility to meet the objectives
Managed parking is a local government function related to “zoning”. It seems reasonable to allow for off-street parking within the same area that is designated as accessible parking only (perhaps in parking ramps). Given the grade and cross slope of many roadways, on-street parking spaces will often exceed the desired surface slope 2% (1:48) for the access aisle.

1102.15 Passenger Loading Zones
Guideline Language: 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.

Requested Change: Rewrite section and/or add an exception.

Suggested Language: EXCEPTION: Passenger loading zones are not reserved exclusively for disabled persons and shall not be identified by signage.

Justification: In reviewing this issue with Access Board staff, it is not intended that the passenger loading zones are reserved for exclusive use by disabled persons; however, the text makes this unclear and a conflict exists within other areas of the proposed draft ADA Guidelines Section 1-10.

1103 Pedestrian Access Route
Section 1103.1 General
Guideline Language: Pedestrian access routes shall connect to elements required to be accessible and shall comply with 1103.

Requested Change: Rephrase for better understanding.

Suggested Language: Pedestrian access routes shall connect elements that are required to be accessible and shall comply with Section 1103.

Justification: Not Applicable

Section 1103.4 Cross Slope
Guideline Language: The cross slope of the pedestrian access route shall be 2% (1:48) maximum.

Requested Change: Rephrase and add exception.

Suggested Language: The maximum cross slope of pedestrian access routes shall be 2% (1:48). EXCEPTION: The maximum cross slope of a crosswalk can exceed 2% (1:48) when a disruption in the roadway profile is created that consequently creates a safety hazard. There shall be no cross-slope requirements for midblock crossings.

Justification: Meeting the 2% (1:48) slope requirement would often introduce objectionable profile variations into the roadway, and may even become a safety hazard for motorists and bicyclists.

The proposed slope will impact our ability to drain intersections. The larger the intersection, the more difficult drainage becomes. The introduction of a flat grade would require extensive transitions in and out of them, especially at high-speed intersections. If further restrictions are in place, the design would result in a very rough ride through the intersection including vaulting and dragging of trailers and/or hitches.

Because this maximum cross slope may create a bump in the road, vehicle contact with the pavement will be reduced, thus reducing braking and maneuvering ability.

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

Requested Change: Change wording to clarify.

Suggested Language: The grade of the pedestrian access route within a sidewalk shall not exceed the grade established for the adjacent roadway, even if the roadway is greater than 5% (1:20).
EXCEPTION: The permissible grade of a pedestrian access route may be steeper than the grade of the adjacent roadway, provided that the pedestrian access route is less than 5% (1:20), or complies with Section 405, “Ramps” of the ADAAG.

Justification: Not Applicable

Section 1103.6 Surfaces
Guideline Language: The surfaces of the pedestrian access route shall comply with 302.

Requested Change: Change wording to clarify.

Suggested Language: The surfaces of pedestrian access routes shall comply with Section 302, Floor and Ground Surfaces of the ADAAG.

Justification: A full citation of other referenced guidelines is needed for clarity and uniform application of guidelines.

Section 1103.8 Changes in Level
Guideline Language: Changes in level shall comply with 303. Changes in level shall be separated horizontally 30 inches (760 mm) minimum.
EXCEPTION: The horizontal separation requirement shall not apply to detectable warnings.

Requested Change: Change wording to clarify.

Suggested Language: Changes in level shall comply with ADAAG Section 303 and shall be separated horizontally by a minimum of 760 mm (30 in).
EXCEPTION: The horizontal separation requirement shall not apply to detectable warnings.

Justification: A full citation of referenced guidelines is needed for clarity and uniform application of guidelines. Additionally, the concerns raised in the AASHTO response regarding maintenance and oversight of this treatment should also be considered.


1104 Curb Ramps and Blended Transitions
Section 1104.2.1 Perpendicular Curb Ramps
Guideline Language: 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.

Requested Change: Include language from the discussion section emphasizing that this is a “should” rather than a “shall” condition.

Suggested Language: Where conditions permit, it is preferable to have separate curb ramps at a corner instead of a single ramp. Perpendicular curb ramps shall comply with 1104.2.1, and shall have a grade that cuts through the curb at right angles or meets the gutter grade break at right angles.

Justification: There are many space constraints at intersections that may not always allow for the inclusion of perpendicular curb ramps. The options need to be clear to designers.

Section 1104.2.2 Parallel Curb Ramps
Guideline Language: Parallel curb ramps shall comply with 1104.2.2, and shall have a grade that is in-line with the direction of sidewalk travel.

Requested Change: Rephrase to include language for safety consideration.

Suggested Language: In limited situations where safety will not be further compromised parallel curb ramps shall comply with 1104.2.2, and shall have a grade that is in-line with the direction of sidewalk travel.

Justification: Parallel ramps can be hazardous in northern climates when a grade is introduced in-line with the main direction of travel.

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

Requested Change: Rewrite section to qualify that blended transitions should not be recommended in many circumstances due to a variety of safety concerns.

Suggested Language: None recommended.

Justification: The language of the guidelines should be flexible and allow designers to deal with safety issues on a case by case basis.

Section 1104.3.3 Surfaces
Guideline Language: 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.

Requested Change: Change from a “shall” to a “should” condition.
Add third qualifying sentence.

Suggested Language: In alteration and reconstruction projects, access covers and other appurtenances should be avoided on curb ramps, etc. Any access covers that must remain shall be flush and free of vertical variation 6 mm (0.25 in) or horizontal gaps of 13 mm (0.50 in).

Justification: Prohibition of gratings, access covers and other appurtenances in curb ramps, landings and blended transitions is too restrictive and impractical at some intersections when it seems that the real intent is only to provide an accessible pedestrian route free of hazards. A reasonable and practical option is to allow for access covers that are flush and without vertical variations exceeding 6 mm (0.25 in) or horizontal openings exceeding 13 mm (0.50 in).

Section 1104.3.7 Clear Space
Guideline Language: 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.

Requested Change: Change from a “shall” condition to a “preferred” condition.

Suggested Language: Beyond the curb line, a clear space of 1120 mm (48 in) minimum by 1120 mm (48 in) minimum is recommended within the width of the crosswalk and wholly outside the parallel vehicle travel lane.

Justification: Requiring a 1.2 m (48 in) clear space beyond the curb may be very difficult and costly to achieve at many intersections constrained by adjacent building development, etc. The justification for this requirement should be re-evaluated. This proposed requirement necessitates a 1.2 m (48 in) minimum shoulder or reaction distance in sections where only a 0.6 m (24 in) reaction distance is normally required. The likely use of the intended clear space by turning vehicles would present a safety problem for pedestrians if they were not staying on the sidewalk until it is permissible to cross. The clear space may provide a dangerously false sense of security for the pedestrian and even with striping, it is likely to be disregarded or misunderstood by motorists.

1105 Pedestrian Crossings
Section 1105.2.1 Width
Guideline Language: Marked crosswalks shall be 96 inches (2440 mm) wide minimum.

Requested Change: Reword to reflect current MUTCD practice.

Suggested Language Marked crosswalks shall be a minimum of 1830 mm (72 in) wide. A 2440 mm (96 in) width is desirable.

Justification: Because it is possible that the 2440 mm (96 in) crosswalk would create a problem with the existing loop detector systems if moved toward the stop bar, the additional width would likely move pedestrians closer to the through traffic. The most frequently used sidewalk width in Minnesota is 1525 mm (60 in). Additionally, there is no clear benefit derived from providing a wider crosswalk.

Section 1105.2.2 Cross Slope
Guideline Language: 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.

Requested Change: Change from a “shall” to a “desired” condition.
Add an additional exception.

Suggested Language: The maximum cross slope of the pedestrian access route shall be 2% (1:48).
EXECPTION: The maximum cross slope of a crosswalk can exceed 2% (1:48) only if it does not cause a disruption to the roadway profile that would consequently create a safety hazard.
EXCEPTION: This requirement shall not apply to mid block crossings.

Justification: For profile grades greater than 2% (1:48) the designer needs to provide a flat or “tabled area” through the intersection to meet the required cross slope. To do this on a high-speed roadway will result in a forced profile grade with short vertical curves. Automobile drivers will feel a weightlessness effect going over such a profile. This same effect on trucks could create a very serious safety hazard. Criteria need to be developed as to when and where this should be applied. As the guidelines are currently presented, a designer would have a serious conflict in applying this criteria.

Section 1105.2.3 Running slope
Guideline Language: The running slope shall be 1:20 maximum measured parallel to the direction of pedestrian travel in the crosswalk.

Requested Change: Increase the running maximum running slope to 6% (1:16).

Suggested Language: The grade shall be 6% (1:16) maximum measured parallel to the direction of pedestrian travel in the crosswalk for a maximum length of 38 feet. A running slope of 5% (1:20) is desirable.

Justification: Using a 1:16 maximum slope allows for the application of the lowest maximum cross slope used by a majority of states. The 38 foot length would accommodate the crossing of one direction of a four lane divided highway on a curve that requires the maximum superelevation. In most situations, pedestrian crossings are located in urban environments that have slower speeds. A normal crown can be used there and meeting the running slope of 5% (1:20) would be no problem except at parallel cross walks if the profile grade of the roadway exceeds 5% (1:20).

Section 1105.3 Pedestrian Signal Phase Timing
Guideline Language: All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 0.91 m/s (3.0 ft/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.

Requested Change: Use the proposed pedestrian signal timing on pedestrian crossings where such timing does not force an increase in cycle length above that required using current pedestrian timing. Where the proposed pedestrian signal timing would force an increase in the cycle length, the proposed timing should only be used upon request by the public or the municipality and after an engineering study has shown there is an actual need for the extended time.

Justification: Pedestrian timing requirements are often a controlling factor of the cycle length that can be run at an intersection. Extending the pedestrian timing requirements will require longer than optimum cycle lengths at many or most intersections, resulting in an increase in vehicle delay, pollution, and fuel usage and also a delay to pedestrians waiting to cross. Increases in congestion have been associated with reduced safety. If this were to be implemented at every intersection in the US, the resulting detriment to travelers and the environment would be staggering.

Additionally, with a longer pedestrian clearance time, pedestrians will soon learn that they can still easily make it across the street even if the “Don't Walk” is already flashing. This will encourage pedestrians to begin crossing the street during the flashing “Don't Walk”, which is illegal and unsafe. Pedestrians who need more time to cross can currently have more time by starting to cross at the beginning of the walk period. The clearance time assumes pedestrians start walking at the very end of the walk period.

A computerized traffic simulation/optimization program (Synchro) calculated the impact of changing from our current pedestrian timing to the proposed timing at 5 of our signalized intersections to be as follows:

Total signal delay: increased 22 – 23%
Stops: increased 6 – 10%
Average speed: decreased 9-11%
Fuel consumed: increased 5 – 9%

Section 1105.4.2 Detectable Warnings
Guideline Language: Medians and refuge islands shall have detectable warnings complying with 1108. Detectable warnings at cut-through islands shall be separated by a 24-inch (610mm) 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 crossings.

Requested Change: Reword exception.

Suggested Language: EXCEPTION: Detectable warnings shall not be required on cut-through islands where the crossing is controlled by signals and is timed for full crossings or when the median is four feet or less.

Justification: In situations where a four foot median is used, the Detectable Warning Surface would provide no benefit, since there is no break in the surface for the entire width of median.

Section 1105.5 Pedestrian Overpasses and Underpasses
Guideline Language: Pedestrian overpasses and underpasses shall comply with 1105.5.

Requested Change: Add an exception to clarify that this guideline applies to the intersection of two sidewalk systems connecting services, and does not apply to trails and paths intersecting with sidewalks.

Suggested Language: Pedestrian overpasses and underpasses shall comply with 1105.5.
EXCEPTION: Applies to sidewalks only.

Justification: There are numerous trails and paths, designed for multiple non-motorized user groups, including bicycles and pedestrians, which are exempt from these guidelines. Clarification is required to ensure appropriate application of the guidelines.

Section 1105.5.3 Approach
Guideline Language: 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.

Requested Change: Change provision for elevators from a "shall" condition to a “may” condition.
Reconsider the 60 inches criteria for the rise of the ramped approach.

Suggested Language: Where the slope of the ramp exceeds 5% (1:20), the approach shall be a ramp 1220 mm (48 in) minimum in width and shall comply with Section 405 of the ADAAG. Where the rise of a ramped approach exceeds 2440 mm (96 in), an elevator complying with ADAAG Section 407, or a limited-use/limited-application elevator complying with ADAAG Section 408, may be provided.

Justification: Need not Justified:
Pedestrian bridges are a supplement to other forms of transportation already available in the community. Because of the availability of alternative modes, such as vehicles and special transit services, within a community an elevator should not be mandatory unless it is the only reasonable route available between public services.

Construction Cost:
The high construction costs of the elevators will substantially increase the cost of a pedestrian bridge for its owners. The outcome of the increased cost is that the benefit/cost ratio of a bicycle/pedestrian bridge with an elevator will not allow transportation agencies to justify the construction of a bicycle/pedestrian bridge with an elevator except in the most extreme locations. Additionally, the safety value that these bridges provide to the general public will be denied to everyone if pedestrian overpasses and underpasses become cost prohibitive to build.

In cold regions such as Minnesota, an elevator enclosure may be required increasing the cost of the elevator and enclosure well above the cost of the pedestrian bridge.

Operations Maintenance:
To meet the proposed requirement will also demand significant cost in the area of operation and maintenance. Most transportation agencies will need to contract this service out due to expertise and licensing required to service this equipment which will reduce flexibility with already limited funding. Additionally, a high level of vandalism and misuse by individuals without disabilities is very likely to occur at these unsupervised facilities thereby increasing maintenance and liability costs.

No documentation was provided to indicate that the reliability of elevators in cold climate that are fully exposed to all weather conditions, which will exist on the right-of-way, is available or that they have been tested to operate with minimal failure in severe summer and winter, snow and ice conditions. Research on these topics is requested before developing a requirement

Personal Safety and security:
Surveillance and security systems will be required by agencies to monitor activity in the elevators. Most public elevators are monitored with cameras to avoid assaults, etc. This will require extensive infrastructure, staff, and contract funds to perform this monitoring.

Liability:
The investment of significant personnel and funding resources are required to keep elevators in operation and to respond to equipment failures. Given Minnesota’s wide range of climatic conditions a user would be placed at a great health risk if an elevator system stalls and they became trapped in a stalled elevator for even a short period of time in sub-zero temperatures or over 100 degree temperatures.

Section 1105.6.1 Separation
Guideline Language: 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.

Requested Change: Clarify what materials and treatments may be considered for the development of a continuous barrier.
Remove requirement for a continuous barrier.

Suggested Language: A continuous grass berm shall be provided along the street of the sidewalk where pedestrian crossing is prohibited.

Justification: Requiring a physical separation seems to be an unreasonable requirement to apply only to roundabouts. There are many street configurations that are not normal perpendicular intersections and railings are not required for them. Most roundabout designs have grass berms around them so visually impaired persons can detect when leaving the sidewalk.

Section 1105.6.2 Signals
Guideline Language: 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.

Requested Change: Remove the requirements for pedestrian activated traffic signal and research this issue. Research might include evaluation of surface treatments to help a visually impaired person detect an approaching vehicle.

Suggested Language: No language is recommended at this time.

Justification: Minnesota requires motorists to yield to pedestrians in the crosswalk, as do most states. The crosswalk is set back one car length, which helps to make the crosswalk perpendicular to the roadway. In addition with this placement the pedestrian is crossing in front of the driver as they approach before the driver starts to prepare for the merge. Roundabouts have low-speed traffic with good visibility of the crosswalk areas. This concept also has some of the lowest collision rates of any traffic control device. There is no accident history to support a pedestrian activated signal system.

There are a number of advantages that roundabouts have for pedestrians. First, the number of conflict points is much lower. A pedestrian at a roundabout has 2 conflict points (entering and exiting right turners) compared with 6 conflicts at a standard four-leg intersection. No hazardous left-turn movements are present. Second, severe crashes caused by inattentive driving are eliminated. Crashes that occur when motorists run red lights, ignore stop signs, and make right turns on red do not happen at roundabouts. The design forces a driver to slow down and pay attention. Third, pedestrian exposure to traffic is much lower because the crossings are shorter. The splitter islands at the roundabout approaches allow people to cross one lane of slow-moving traffic at a time, instead of four lanes of traffic that would likely be traveling very fast through a signalized intersection. A pedestrian activated signal requirement would certainly discourage the use of roundabouts and those benefits would be lost to the pedestrian.

Section 1105.7 Turn Lanes at Intersections
Guideline Language: 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.

Requested Change: Eliminate pedestrian activated signal requirement.
Use the more common industry term of “free rights” rather than “slip lanes”.

Suggested Language: Where pedestrian crosswalks are provided at free right turns, a painted crosswalk shall be provided.

Justification: The proposed language would require accessible pedestrian signals at locations where there are currently no signals, accessible or not. See the previous comment supporting the installation of accessible pedestrian signals only upon request and with an engineering study. Some of these locations may have no pedestrian activity of any sort and would not require any pedestrian signals, accessible or not, except for this requirement. Guidance as to where this criterion would be applied should be developed.

Also, to put in the pedestrian signals would also require installation of vehicle indications on these lanes, requiring all vehicles turning right to stop on red. Currently, there are yield sign controls on these lanes. At a location where no pedestrians are present, requiring every vehicle to stop at a new red signal indication will create significant delays, pollution, and fuel consumption.

The issue of signalizing free-right movement needs research that addresses the placement of signal heads and stop bars that will be visible to motorists and the development of warrants for the application of the free-right island. Signalized intersections, even with pedestrian indications, do not ensure the safety of pedestrians in the crosswalk. Adding signal control to the free-right will confuse drivers and induce a false sense of security for pedestrians. Unless a significant pedestrian demand is present, this could add the potential for massive violations.


1106 Accessible Pedestrian Signal Systems (APS)
Section 1106.2 Pedestrian Signal Devices
Guideline Language 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.

Requested Change: Change “shall” condition to “should” and “may” condition to allow for the use of engineering judgement to determine need on a case by case basis or remove the requirement. If the requirement is retained, additional guidance on determining when to install APS is needed.

Suggested Language: Each crosswalk with pedestrian signal indication should have a signal device that may include audible and vibrotactile indications of the WALK interval where needed. Where a pedestrian pushbutton is provided, it should be integrated into the signal device and comply with 1106.3.

Justification: The recommendation to change the requirement from “shall” to “should” is based upon the fact that there is not clear agreement that APS is warranted for all situations. In Minnesota there is not consensus among people who are visually impaired as to whether the accessible pedestrian indications are an improvement or a hindrance in crossing the roadway. One strong point of view that has been conveyed to Mn/DOT is that the accessible pedestrian systems mask the primary cue created by the sound of traffic, reducing accessibility for some users. However, there is consensus among persons who are visually impaired that accessible pedestrian signals need not be installed at all locations and that guidelines can be developed to identify appropriate locations based on requests and engineering studies.

Section: 1106.2.1 Location
Existing Language: 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.

Requested Change: Change these distances to goals, with shorter distances as the minimum requirement.

Suggested Language: No language recommended.

Justification: Due to wide variation in the geometry and constraints found at each intersection, there are likely to be many instances where the implementation of such precise requirements will be infeasible, especially in reconstruction projects.

Section 1106.4 Directional and Information Signs
Guideline Language: 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.

Requested Change: All sign designs should be in conformance with the Manual on Uniform Traffic Control Devices (MUTCD).

Suggested Language: See the MUTCD for language and specifications.

Justification: Uniformity is essential in the design and application of traffic control devices to ensure user safety. Recommendations that deviate from recognized standards compromise that safety.

1107 Street Furniture
Section 1107.2 Clear Floor or Ground Space
Guideline Language: 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 by 12 inches (305 mm) maximum.

Requested Change: Reword second sentence for clarity.

ADAAG Section 305.2 requires a 2% (1:48) slope on the clear floor and ground space that can be accommodated in the sidewalk cross slope direction but not the direction of the grade of the sidewalk. Create an exception to document this.

Suggested Language: The clear floor or ground space may overlap the pedestrian access route by 305 mm (12 in) maximum.

EXCEPTION: The slope of the clear floor or ground may be steeper than 2% (1:48) in the direction of the running slope for the sidewalk, but shall not exceed the grade established for the adjacent roadway.

Justification The text of the second sentence is confusing. It seems to read as a requirement for the clear floor or ground space to overlap into the pedestrian access route without stating why an overlap would be desirable. It is more appropriate to minimize the overlap to no more than 305 mm (12 in) as long as access to the furniture is compliant with appropriate provisions for this guideline.

Clarification and Exception required for 2% (1:48) slope on clear floor or ground
It is critical to point out the proposed exception to Section 305.2 of the ADAAG because it will be technically infeasible to meet the 2% (1:48) slope in the direction of the grade of the sidewalk in the same way that it is infeasible for sidewalks to meet the 5% (1:20) maximum slope requirements.

Section 1107.4.1 Single Telephone
Guideline Language: Where a single public telephone is provided, it shall comply with 704.2 and 704.4.

Requested Change It is strongly recommended that a separate process be initiated to seek legislation that will place and fund the implementation of this guideline with the Public Communications Commission/Public Pay Phone Companies for all public pay phones in the nation.

Add an exception to allow compliance with ADAAG Sections 704.2 and 704.4. The exception will allow for the necessary design for Clear Floor and Ground Space found in section 1107.2

Suggested Language: EXCEPTION: The slope of the clear floor or ground space may be steeper than 2% (1:48) in the direction of the grade for the sidewalk, but shall not exceed the grade established for the adjacent roadway.

Justification This requirement may reduce the total number of public phones installed due to the requirement to provide electrical services and maintain the equipment.

TTY equipment is often purchased and owned directly by the transportation agency, not leased from the phone companies, due to cost of equipment over time. Historically, many smaller phone companies have not offered leasing or maintenance of this equipment. Maintenance of the equipment is problematic in that only the phone company operating the public pay phone has the legal authority to connect and disconnect TTY equipment into the public phone systems. It is impossible for transportation agency staff to effectively maintain this equipment on public phones on right-of-way.

For this reason it is strongly recommended that a separate process be initiated to seek federal legislation requiring the public pay phone companies to provide this service in accordance with these guidelines and collect a public surtax to cover the cost.

See the Following Sections for Additional Comments for this Item
1107.2 Clear Floor or Ground Space: Justification: Clarification and Exception required for 2% (1:48) slope on clear floor or ground space.

Section 1107.4.2 Multiple Telephones
Guideline Language: 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.

Requested Change: See comments for 1107.4.2 above for references to Sections 704.2 and 704.4 of the ADDAG.
Add a definition for “a bank of public telephones”.
Add exception.

Suggested Language: No language is recommended at this time for “a bank of public telephones”.
EXCEPTION: The slope of the clear floor or ground space may be steeper than 2% (1:48) in the direction of the running slope for the sidewalk, but shall not exceed the grade established for the adjacent roadway.

Justification: See comments provided under Justification for sections:1107.2 Clear Floor or Ground Space and 1107.4.1 Single Telephone.

Section 1107.5 Public Toilet Facilities
Existing Language: 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.

Requested Change: Delete reference to the Sections of the ADAAG that are not appropriate for roadside toilets. These sections include 607-608 referring to tubs and showers and Section 610 referring to tub and shower seats.

Suggested Language: Permanent or portable public toilet facilities shall comply with ADAAG Section 603. At least one fixture of each type provided shall comply with ADAAG Sections 604 through 606 and 609.

Justification: Transportation agencies do not provide mixed-use facilities (living or service spaces with showers) on the right-of-way that are not already covered under other sections of the building and site facilities chapter of the ADA guidelines

Section 1107.6 Tables, Counters, and Benches
Guideline Language: Tables, counters, and benches shall comply with 1107.6

Requested Change: Reword.

Suggested Language: Stationary tables, counters, and benches shall comply with 1107.6.

Justification: Designate that this guideline applies to stationary (fixed location) furniture only. Non-fixed objects of this type (often temporarily placed) are highly movable by one or two persons because they are small and lightweight. It is impossible to control the location of and accessibility to movable benches and tables, etc.

Section 1107.6.1 Tables
Guideline Language: Where tables are provided in a single location, at least 5 percent but no less than one, shall comply with 902.

Requested Change: Add an exception.

Suggested Language: EXCEPTION: The slope of the clear floor or ground may be steeper than 2% (1:48) in the direction of the grade of the sidewalk, but shall not exceed the grade established for the adjacent roadway.

Justification: See the Following Sections for Additional Comments for this Item
1107.2 Clear Floor or Ground Space: Justification: Clarification and Exception required for 2% (1:48) grades on clear floor or ground space.

Section 1107.6.2 Counters
Guideline Language: Where provided, counters shall comply with 904.

Requested Change: Add an exception.

Suggested Language: EXCEPTION: The slope of the clear floor or ground may be steeper than 2% (1:48) in the direction of the grade of the sidewalk, but shall not exceed the grade established for the adjacent roadway.

Justification See the Following Sections for Additional Comments for this Item
1107.2 Clear Floor or Ground Space: Justification: Clarification and Exception required for 2% (1:48) slope on clear floor or ground space.

Section 1107.6.3 Benches
Guideline Language: 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.

Requested Change: Add an exception

Suggested Language: Where benches without tables are provided at a single location, at least 20%, but no fewer than one, shall comply with Section 903 of the ADAAG.

EXCEPTION: The slope of the clear floor or ground may be steeper than 2% (1:48) in the direction of the grade of the sidewalk, but shall not exceed the grade established for the adjacent roadway.

Justification: Design flexibility should allow for the use of benches without backs mixed with benches with backs at a ratio of 1:5 or greater to permit designs that achieve the intended architectural design objectives and still provide accommodations within a limited distance. Backless benches allow users to face the street or to choose their orientation based on the wind direction, sun angle, views or other personal reasons and also fit where back-to-back benches would not fit in a very limited space or blend with the aesthetics of the site. The ratio of 1:5 will allow for some minor flexibility to mix the use of benches with and without backs within a single location (close proximity area of 30.5 m (100 ft) to 61 m (200 ft)).

Unless unique conditions exist that justify conflicting guideline requirements for the same element within the ADA, guideline chapters should be uniform to avoid inconsistencies in design application and enable uniformity in enforcement.

1108 Detectable Warning Surfaces
Section 1108.1 General
Guideline Language: Detectable warnings shall consist of a surface of truncated domes aligned in a square grid pattern and shall comply with 1108.

Requested Change: Omit the requirement pending further study.

Suggested Language: Delete section and all related references.

Justification: Numerous comments have been brought forward regarding the maintenance of these facilities in cold weather climates. In particular, there is concern that the complete and timely clearing of the facilities after a snow event may not be possible and could create a hazardous situation for all users and become a liability risk. At this time, it is recommended that the Access Board sponsor additional research to develop best practices regarding the maintenance of truncated domes.

Concern has also been raised about how the use of truncated domes impacts skateboarders, scooter and in-line skate users. Research sponsored by the State of Florida with Charlie Zeeger P.E. as principle investigator, has shown that truncated domes consistently “down” this user group as they attempt to navigate the truncated domes. The result is that accommodation of one user group occurs at the expense of another, and communities are being asked to knowingly create a hazardous condition, which may not be legally defensible. This is not an acceptable or appropriate situation and it is strongly recommended that the Access Board continue to research other treatments that will allow for the accommodation of all user groups.

1109 On Street Parking
Section 1109.1 General
Guideline Language: Car and van on-street parking spaces shall comply with 1109.

Requested Change The Access Board should develop a paragraph specifying when a van space should be provided instead of a car space.

Suggested Language: No language is being recommended at this time.

Justification: Equal access cannot be guaranteed to all user types if a reasonable ratio of van spaces is not provided in the urban areas. A distribution based on Parallel Parking Spaces (access aisle at least 1.5 m (5 ft) vs. Perpendicular or Angled Parking Spaces (Where an access aisle is 2.4 m (8 ft) is insufficient. This is an unreasonable approach to providing reasonable accommodations because it does not ensure that a van stall will be provided within a multi-block area. At this time the ADAAG requires the van stalls have a 2.4 m (8 ft) aisle.

Section 1109.2 Parallel Parking Spaces.
Guideline Language: 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.

Requested Change: Add text to reflect bicycle safety concerns.
Due to environmental and existing road conditions it is not reasonable to develop a 2% (1:48) level access aisle at all locations.
Provide exceptions.

Suggested Language: The access aisle shall not encroach on the vehicular travel lane or on the bicycle travel lane.
1. 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 4874 mm (16 ft). When an access aisle is not provided, the parking space shall be located at the end of the block face.

2. EXCEPTION: Although the access aisles are also used for wheelchair transfer to and from vehicles, the slope may be steeper than 2% (1:48) but shall not exceed the grade established for the adjacent roadway.

Justification: Bicycle Safety
It is critical that designated bicycle lanes are not impacted or eliminated.. This significant and growing transportation mode is designed as a network, with selected routes based on demand and safety accommodations for the rider. Roadway alterations that affect the system or safety design of these facilities will have a negative effect on the safety of bicyclists.

Safety for Visually Impaired Pedestrians
Moving the curb in to allow for an access aisle along side of a car appears to help one group and create a problem for another. A person, who is visually impaired, walking parallel to the roadway on the sidewalk, will find the proposed concept confusing. People who are visually impaired tend to walk near the inside edge of the walk, however, jogs in the walk may introduce problems.

Clarification and Exception required for 2% (1:48) slope on access aisle
The proposed exception to ADAAG Section 502.3 is critical because it will be technically infeasible to meet the 2% (1:48) slope requirement in on-street parking accommodations in the same way that it is infeasible for sidewalks to meet the 5% (1:20) maximum slope requirements.

Width of Public Right-Of-Way must be 16 Feet Wide
The 14-foot exception is not adequate and should be 4.6 m (15 ft). The rebuild to accommodate an accessible stall requires 1.5 m (5 ft) of sidewalk converted to access aisle at street level, plus a 1.8 m (6 ft) for a curb ramp using the perpendicular ramp, plus 1.2 m (4 ft) of landing/clear route at the top of the ramp. The total requirement to meet these minimums is 4.6 m (15 ft).

Parking at End of Block
Proposed guidelines state that where the right-of-way width for an access aisle is not provided, the parking space may be placed at the end of the block, which is where they are now typically located and signed. This is generally a reasonable alternative.

Water and Drainage Impact on Accessible Stall when Curb Line is Altered
Depending on roadway grade, cross slopes volume of and design for surface water removal, modifications to the curb alignment to accommodate the 1.5 m (5 ft) access aisle may adversely impact the access aisle, ramps or blended transitions with excess amounts of pooled water and in winter, ice. When the roadway, due to existing roadway constraints, utility locations and environmental conditions, cannot be designed to remove water from the on-street parking stall, an alternative parking accommodation, such as “Parking at the End of Block”, should be allowed. This is especially critical in northern climates.

Winter Condition Snow Removal
Roadway plows cannot remove snow from an indented access aisle. Snow removal will be considered a secondary priority - delayed until after the major snow event is over and snow emergency work for main roads is complete. Northern states that have a substantial amount of snow over a long season, should be allowed to develop off-street parking facilities that will be plowed more quickly than the individual remote stalls could be.


Section 1109.3 Perpendicular or Angled Parking Spaces
Guideline Language: 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.

Requested Change: The elements/conditions stated in this paragraph and additional information that is more comprehensive and clearly written already exists in ADAAG Sections 502.3 through 502.6. Access aisles should comply with ADAAG Sections 502.3 through 502.6 and specifically include an exception to ADAAG Section 502 requirements for slope.
Some exceptions should be provided so that reasonable percentages of the total available parking spaces and distribution for close access are considered and applied.

Suggested Language: Where perpendicular or angled parking is provided, an access aisle of 2440 mm (96 in) wide minimum shall be provided. It shall comply with ADAAG Sections 502.3 through 502.6 and shall connect to a pedestrian access route serving the space.
EXEMPTION: Although the access aisles are also used for wheelchair transfer to and from vehicles, the slope may be steeper than 2% (1:48) but shall not exceed the grade established for the adjacent roadway.
EXCEPTION: Reductions of parking capacity by over 10% are not required as long as a minimum of two accessible parking spaces per block are provided.

Justification Clarification and Exception required for 2% (1:48) slope on access aisle
The proposed exception to ADAAG Section 502.3 is important because it will be technically infeasible to meet the 2% (1:48) slope requirement in on-street parking accommodations in the same way that it is infeasible for sidewalks to meet the 5% maximum slope requirements.

In cases where the access aisle for on-street parking exceeds a slope of 2% (1:48), alternative parking accommodations should be considered to replace the one parking stall per block face requirement so that the parking stalls provided will better meet the objective of providing access for all.

Proposed Distribution of On-Street Parking Seems Excessive
The required access aisle is equal to the size of an average parking stall. This will result in a net reduction of two general parking stalls per block face. In some communities, this may excessively reduce the availability of general population on-street parking. Reduction of parking capacity by over 10% should not be required so long as a minimum of two accessible parking spaces per block are provided.

Section 1109.4 Curb Ramps or Blended Transition
Guideline Language: A curb ramp or blended transition complying with 1104 shall connect the access aisle to the pedestrian access route.

Suggested Language: See comments for 1104.

Justification: See comments for 1104

Section 1109.5 Obstructions
Guideline Language: 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.

Requested Change: Modify this section to provide for 0.6 m (2 ft) clearance to the curb along the parking space.

Suggested Language: No language is suggested at this time.

Justification: Elimination of All Obstructions Seems Excessive
There seems to be no logical reason for the ban on obstructions abutting the parking space. A 0.6 m (2 ft) clearance to accommodate door swing seems appropriate; however the elimination of all obstructions seems excessive. Space for unloading is part of the access aisle space requirements. Features such as light poles, trees and other street-scaping in the area that abuts the space but are outside a 0.6 m (2 ft) clear zone will not adversely affect the usefulness of the parking space. These features are important to the overall use, safety, and appearance of the street.

Section 1109.7.3 Displays and Information
Guideline Language: Displays and information shall be visible from a point located 1015 mm (40 in.) maximum above the center of the clear floor space in front of the meter.

Requested Change The wording of this section is somewhat unclear and no size is required for text.

Suggested Language Revise section to provide intended guidance.

Justification: Not Applicable

1111 Alternate Circulation Path
Section 1111.1 General
Guideline Language: Alternate circulation paths shall comply with 1111.

Requested Change: The inclusion of any other sections that must be adhered to regarding surfaces, cross slope, grades, etc.
Change “Alternate Circulation Path” to “Pedestrian Detour”.

Suggested Language: Not applicable.

Justification: The clarification is necessary to set the baseline for the expected level of service and provide assistance to designers in the determination of the appropriate location of the alternate circulation path.
Pedestrian detour is preferred because it is an established and recognized term within the transportation industry.


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

Requested Change: Add exception.

Suggested Language: A pedestrian detour shall be parallel to the pedestrian access route on the same side of the street.
EXCEPTION: When a parallel path on the same side of the street is not technically feasible, pedestrians will be routed to the nearest facility. The pedestrian detour shall have adequate access and notification.

Justification: In construction zones it is not always desirable or safe to walk next to the construction site. Access for construction equipment and materials, the availability of right-of-way, and the safety of workers and pedestrians must be factored into the final determination in the creation of a pedestrian detour.
 

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