Freddie Simmons,
P.E.
|
October 29, 2002 |
The ability to travel freely is a right shared by everyone. Unfortunately, no
path is ever totally free of all obstacles. Terrain, weather and distance will
forever plague the pedestrian traveler. Traffic engineers recognize the duty we
have not to create further impediments. However, so long as budgets remain
limited, the world of transportation will be a zero-sum game. Balance is
critical so that an improvement for one portion of the population does not
become a burden on another.
Many of these guidelines incorporate new technologies or new ideas. Too often,
these are concepts that sound plausible but do not work in reality. For
instance: the painting mid-block crosswalks so people can safely cross the
street. Experience has shown that they make pedestrians feel safer without
actually changing driver’s behavior. It is the wary that avoids the speeding
truck bumper, not the blissful. New ideas are important. It is how we evolve as
a society, but to require unproven theories on the trusting public is not a wise
decision.
Many of these changes are being implemented as conditions warrant. For instance:
Accessible Pedestrian Signals are available and policies allow for their use. It
is through this slow-growth process that good ideas can be recognized from the
bad. Declaring a policy that has hidden flaws nationwide has serious
life-and-death consequences.
The various Departments of Transportation across the nation are staffed by
dedicated professionals who have years of training and experience on balancing
the needs of the public. We look at not only how much a feature will cost
directly, but how it will impact those who have to keep it functioning as
designed. These requirements ignore all this and mandate how things shall be
with no knowledge of the impact or effectiveness. It is important for the Board
to understand that these unbalanced and unfunded mandates may benefit a small
fraction of the public, but will certainly impact all.
Section 1102: Scoping Requirements
1102.1: General – All areas of newly designed and newly constructed facilities
in public rights-of-way and altered portions of existing facilities…
1102.2.2 Alterations – Where existing elements or spaces in the public
right-of-way are altered, each altered element or space shall comply…
Background: The requirement is for any altered portions or spaces of existing
facilities. This brings to question if the changes are related to the current
project. Does the addition of a turn lane mandate the upgrade of the signals?
Does changing the signals to the new LED systems mandate the installation of
curb ramps? Does the closing of a median opening mandate the reconstruction of
nearby driveway openings to correct cross-slope problems? Many of these items
are totally unrelated to the other and could expand the scope of projects beyond
any financial capacity to support.
Recommendation: Recommend narrowing the definition of altered portions and
reducing the requirement to a ‘should comply’ standard.
1102.2.2 Alterations: Exception – In alterations, where compliance with
applicable provisions is technically infeasible, the alteration shall comply to
the maximum extent feasible.
Background: This requirement is a huge liability burden if the only limitation
is ‘technical infeasibility’. It is rare that a solution is technically
infeasible but very common that a solution is financially infeasible or
politically impractical.
Recommendation: Recommend providing some protection to the agencies who have to
meet this burden by use of an ‘impractical’ standard.
1102.2.2 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 below the requirements for new construction at
the time of the alteration is prohibited.
Background: This requirement allows for no changes for future conditions. Once a
sidewalk or other access has been placed, it is there forever. This constraint
would not allow for the removal of pedestrian bridges that are rarely used and
have become a center for crime. This requirement would not allow the removal of
mid-block crosswalks that are of questionable benefit and provide a false sense
of security to users.
Recommendation: Recommend removing this requirement from the planned guidelines.
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 condition.
Background: This requirement is not only a huge financial burden for the simpler
activities. The requirement is for ‘temporary conditions’. How temporary is
temporary? Does a crash that blocks a sidewalk require the construction of an
alternate path as part of the response? Does a drill rig parked on a sidewalk to
get soil samples mandate the need?
Recommendation: Recommend incorporating time limits on the minimums necessary. A
standard of ‘overnight’ is easily understandable and enforceable.
1103 Pedestrian Access Route
1103.3 Clear Width – The minimum clear width of a pedestrian access route shall
be 48 inches, exclusive of the width of the curb.
Background: This is an expansion of the current width requirement for 36 inches
for an accessible route (section 4.3.3 ), curb ramps (section 4.7.3, section
4.8.3) and the minimum clear width of 32 inches (section A4.2.1(2)) . These
standards are based on the physical needs of wheelchair users. The need for this
expansion is undocumented and without merit. The extra 12 inches required will
greatly impact roadway space requirements and limit practical solutions to
access deficiencies.
Recommendation: Recommend retaining the current ADA standard of 36 inches with
the 32-inch minimum at single obstructions.
1103.5 Grade – The grade of pedestrian access route within a sidewalk shall not
exceed the grade established for the adjacent roadway.
Background: This requirement opens the various agencies to immense liability
because of limitations caused by terrain. This is an immense county with an
incredibly diverse landscape. This standard will rule out many viable designs
simply because the adjacent roadway does not follow the same contours. Field
conditions are notorious for not allowing what appear to be simple solutions
planned by a distant designer. A short grade change to align a sidewalk at a
crossing that slightly exceeds this minimum will be fodder for the circling
legal vultures.
Recommendation: Recommend loosening this standard to only ‘should not exceed’.
This will allow enough variation to provide legal protection while eliminating
the most grievous examples that are truly a problem.
1104 Curb Ramps and Blended Transitions
1104.2.2.3 Landing – A landing 48 inches minimum by 48 inches 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.
Background: This requirement needs clarification on the exact conditions that
this standard shall be applied. Is this landing required to be outside of
vehicular travel lanes? The minimum cross slope requirement will produce
problems for vehicle control in hilly terrain. These landings will function as
unexpected ‘speed bumps’ for the right side of the vehicles. Drainage can also
be a problem because of the minimum running slope.
Recommendation: Recommend further study to determine how this requirement is to
be implemented and insure there are no expected developments before this
standard is applied nationwide.
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 stall be protected
with a barrier.
Background: This requirement is vague on the situations that require a barrier
and what will satisfy the need for a barrier. How big is the minimum allowable
drop-off? Can landscaping satisfy the requirement for a barrier? Or is a
concrete wall necessary.
Recommendation: Recommend clarifying this standard by defining a drop-off
better, such as: greater than 10 inches and the use of handrail as a barrier.
1104.3.1 Width – The clear width of landings, blended transitions, and curb
ramps, excluding flares, shall be 48 inches minimum.
Background: This requirement is an expansion of the current 36-inch standard
(section 4.7.3). This expansion is without merit. The current standard is based
on the physical needs of wheelchair users. Expanding it to 48 inches only
expands the costs to the public without a corresponding expansion of benefits.
Recommendation: Recommend keeping the width to the current standard unless a
justifiable need is presented.
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.
Background: This requirement has been ‘on-hold’ and awaiting further study most
of the time ADA has been in effect. These tactile surfaces are not universally
desired by the intended users and can present difficulties to other users. They
can be a tripping hazard to those who tend to shuffle their feet. They are a
maintenance headache to keep clean and serviceable. It is questionable if they
do not generate more problems then they supposedly resolve.
Recommendation: Recommend continuing the suspension on these tactile surfaces
until the ‘appropriateness of providing detectable warnings at
vehicular-pedestrian intersections in the public right-of-way should be
established’ as called for in the Access Board’s own advisory committee in a
letter dated July 29, 1996. The ‘appropriateness’ study called for in this
letter does not appear to be in the public domain.
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
Background: This requirement is confusing as to which direction the slope is to
be measured. The term ‘counter slope’ is non-standard and is not presented in
section 1101.3 Defined Terms. If the slope is in reference to the cross slop of
the accessible path, this will be equal to the grade of the adjacent roadway and
impossible to satisfy. If the counter slope is the running slope of the
crosswalk, drainage problems may result because of an insufficient slope.
Recommendation: Recommend properly identifying the slope in question before
continuing this requirement.
1104.3.7 Clear Space – Beyond the curb line, a clear space of 48 inches minimum
by 48 inches minimum shall be provided within the width of the crosswalk and
wholly outside the parallel vehicle travel lane.
Background: This requirement is an extreme example of the continued and subtle
attempt to expand the space requirements of the accessible route. The lack of a
need for 48 inches has been documented many times before (see 1103.3,
1104.2.1.3, 1104.2.2.3, and 1104.3.1). This requirement also appears to overlap
with the requirement for a landing at the bottom of a ramp (1104.2.2.3).
Recommendation: Recommend keeping the current standard of 36 inches as this is
based on a required need. It is also recommended for further explanation
regarding the ‘clear space’ compared to the ‘bottom ramp’.
1105.2 Crosswalks
1105.2.1 Width – Marked crosswalks shall be 96 inches wide minimum.
Background: This requirement is excessive of the national traffic standards and
current ADA requirements without providing sufficient justification on this
expansion. Currently, the Manual on Uniform Traffic Control Devices (MUTCD)
advises that crosswalks ‘should not be less than 6 ft wide’. Current ADA
regulations place the crosswalk as part of the accessible route definition. For
a bi-directional path, 60 inches is the minimum width. Once again this is simply
an attempt to expand the current definition of accessible route and place an
unfunded mandate on local agencies. On some locations, widening the crosswalk
will make little difference, but these two extra feet could be critically
important at other locations.
Recommendation: Recommended retaining the current national standard of 6 feet as
per the MUTCD. There has been no justifiable need to expand the crosswalks and
incur the additional expenses.
1105.3 Pedestrian Signal Phase Timing – All pedestrian signal phase timing shall
be calculated using a pedestrian walking speed of 3.0 feet per second 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.
Background: This requirement will have massive negative impact on the quality of
life for the entire population with no appreciable benefits. The current MUTCD
standard is 4 ft per second and distance is to the center of the farthest
traveled lane. This standard captures a majority of the traveling public while
balancing the needs of pedestrians with the needs of the vehicle drivers. It
also allows for on street parking and a basic understanding of signal timing by
allowing for the yellow clearance time. Finally, this is only a minimum
standard, local engineers routinely extend clearance times to allow for
children, or elderly pedestrians, where such expansion is warranted. This
requirement will extend the clearance time by 33 percent while providing access
to a minimal portion of the population. This extension, especially on the side
street phases, will produce greater vehicle delay times. This will negatively
affect vehicle emissions and reduce air quality in conflict with goals of the
Clean Air Act. To many of our cities are failing to meet these goals without
making the task harder. The extended delays will also increase driver
frustration, leading to more cases of people failing to stop for red lights.
Recommendation: Recommend keeping the current standard of 4 feet per second and
allowing engineers to use their training and experience to adjust the traffic
systems as conditions warrant.
1105.5 Pedestrian Overpasses and Underpasses
1105.5.3 Approach – Where the approach exceeds 1:20, the approach shall be a
ramp 48 inches minimum in width and shall comply with 405. Where the rise of a
ramped approach exceeds 60 inches, an elevator complying with 407 or a
limited-use/limited-application elevator complying with 408 shall be provided.
Background: This requirement will essentially eliminate the use of pedestrian
overpasses/underpasses except at locations with fulltime workers. Pedestrian
overpasses/underpasses are rarely used now because of the cost and space
requirements for the access ramps. This need to provide for a limited portion of
the population hurts the rest by eliminating this solution unless all can be
accommodated. With the expanded use of motorized wheelchairs and personal
electric vehicles, the number of people is dwindling that cannot handle the 5
foot elevation change. Agencies will not install mechanical devices such as
elevators unless they have fulltime workers nearby. The liability is simply too
great. When the elevators break, access is then denied to all. Ramps work 24
hours a day, 7 days a week.
Recommendation: Recommend removing this 5-foot limitation because of the limited
benefits generated verses the potential loss of access to the general
population.
1105.6 Roundabouts
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 maximum above the pedestrian
access route.
Background: This requirement is unnecessary, vague and potentially dangerous. A
roundabout is simply a circular travel lane. Barriers are not typically used
adjacent to travel lanes unless it is to keep vehicles from leaving them. This
requirement implies it is to keep the pedestrians from entering the roadway. A
barrier will not keep pedestrians out if they really want to enter and if they
do get inside, they are then trapped. Europeans, who have far greater
experiences then American, do not include such a ‘pedestrian barrier’. A railing
close to the travel lane can also be dangerous if struck by a vehicle. An
out-of-control motorcyclist leaving the roadway could be decapitated. A vehicle
could snag the railing and whip it through a crowd. If these possibilities sound
too far fetched, look into the MUTCD restriction against using portable school
signs. Cars were hitting these signs and sending them into groups of children.
Recommendation: Recommend removing this requirement because of the potential
problems it could cause. A better solution would be to restrict the crosswalks
from the roundabout ‘core’ and designate a minimum distance of 20 feet from the
outside of the circular path.
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.
Background: This requirement essentially eliminates the benefits produced by
roundabouts by turning them all into expensive signalized intersections.
Roundabouts are used to produce traffic calming without grossly impacting
roadway capacity. They help with meeting clean air mitigation goals and reduce
the maintenance burden by removing marginally warranted traffic signals.
Signalization of any approach totally defeats these benefits. It has been proved
that roundabouts can reduce pedestrian crashes because of slower traffic
conditions and through the use of splitter islands as pedestrian refuge islands.
They are claimed to be dangerous for the blind, but roundabouts are best for
replacing intersections that are ‘stop controlled’, not signalized
intersections. The pedestrian is still vulnerable to errant drivers. In
addition, the pedestrian only has to cross a single lane of traffic instead of
the two or more lanes typically found.
Recommendation: Recommend removing this requirement from the guidelines and
examining minimum requirements for pedestrian crossings at roundabouts.
1106 Accessible Pedestrian Signal Systems
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
Background: This requirement will triple the installation costs of pedestrian
features according to the latest quotes. These devices are new to the market and
will have corresponding developmental problems. The vibrotactile requirement is
especially troubling because this is a mechanical device and will be subject to
high maintenance attention. These devices are not wanted by a significant
portion of the targeted population for various reasons and will generate
resentment by others because of the high cost and lack of need. The current
MUTCD allows traffic engineers to install these devices where there is a need
and where they will be used. A blanket approach would not be cost effective and
will diminish the travel skills of the average blind pedestrian. These devices
induce the false sense of security that the path is safe to cross while masking
the noise generated by the truck running the light.
Recommendation: Recommend not making this a universal requirement but
recognizing the current ability of traffic engineers to use these devices where
they are warranted.
1106.2.1 Location – Pedestrian signal devices shall be located 60 inches maximum
from the crosswalk line extended, 120 inches maximum and 30 inches minimum from
the curb line and 120 inches 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.
Background: This requirement severely limits the locations pedestrian signal
devices can be located. It disallows a common cost-saving technique of
co-locating two signal heads on one pole. Terrain features or right-of-way
restrictions can limit the space available to meet these exacting standards.
Recommendation: Recommend the Board follow the guidance given by the MUTCD. This
states ‘Pedestrian signals indications should be conspicuously and recognizable
to pedestrians at all distances from the beginning of the controlled crosswalk
to a point 10 feet from the end of the controlled crosswalk during both day and
night’.
1106.3 Pedestrian Pushbuttons
1106.3.2 Locator Tone – Pedestrian pushbuttons shall incorporate a locator tone
at the pushbutton…
Background: This requirement will greatly increase the cost of pedestrian
detectors while annoying the general public with the non-stop beeping. These
beeps will mask the traffic noise used by blind pedestrians and will become
common targets for vandals.
Recommendation: We recognize the usefulness of these locator tones and recommend
they be only used at locations that have Accessible Pedestrian Signals. The
recommendation given above for Accessible Signals will limit the locator tone
detectors only to those locations that they are necessary and will produce the
most benefit.
1106.4 Directional Informational and Signs
1106.4.2 Street Name – Signs shall include street name information aligned
parallel to the crosswalk direction and complying with 703.2.
Background: This requirement will greatly increase the maintenance burden for
minimal benefit to the traveling public. The same information can be obtained by
asking a passerby. The only pedestrians who will require these signs are blind
pedestrians outside of their normal walking route who does not pass anyone. This
is an incredibly small fraction of the trips. Currently, street name signs are
placed high so as to be visible and safe from vandals. The tactile requirement
means signs must be close enough to be touched, and damaged. These signs will
have to be custom made for each location and will become common ‘souvenir’
items.
Recommendation: Recommend the Board use a ‘should’ standard and only require the
signs in a central business district.
1106.4.3 Crosswalk Configuration – Where provided, graphic indication of
crosswalk configuration shall be tactile and shall comply with 703.5.1.
Background: This requirement is similar to 1106.4.2 for the limited benefits
produced.
Recommendation: We recognize the worth of tactile depiction of complicated
intersections and recommends the Board pursue standardization of these
techniques before requiring them nationally.
1108 Detectable Warning Surfaces
Again, to restate comments from 1104.3.2. These tactile surfaces are still
questionably beneficial in most locations. The Access Board itself has
recognized the problems of these surfaces by repeatedly suspending their
implementation. They may be of benefit in some locations but if they become too
common, they may become ignored. They can also be hazardous to certain members
of the population and are difficult to keep clear of ice and snow.
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 minimum and
8 inches maximum from the curb line.
Background: This requirement is vague as to which side of the curb the warning
is to be located. If the surface is placed on the ramp side, a tripping hazard
is probable by the fact some people cannot raise their feet high enough and may
stumble. If the surface is placed on the gutter side of the curb, drainage and
vehicle damage become an issue.
Recommendation: Recommend this section be clarified and tactile surfaces not
included in curb ramp slopes.
1108.2.2 Rail Crossings – The detectable warning surface shall be located so
that the edge nearest the rail crossing is 6 inches minimum and 8 inches maximum
from the vehicle dynamic envelope.
Background: This requirement is probably unnecessary and could possibly do more
harm than good. The only time these warnings would be necessary is when crossing
arms do not cover the pedestrian route across the tracks, an uncommon
occurrence. These warnings will supposedly benefit a blind pedestrian who can
feel these slight variations of texture but is unable to feel the vibrations
caused by the massive train barreling down the tracks or hear the earsplitting
whistle that can rattle windows. These warnings will be dangerous to those
pedestrians that shuffle along and trip over the ‘truncated domes’ and pitch
forward onto the tracks.
Recommendation: Recommend not including these as a blanket requirement at rail
crossings but allow the local agencies to specify locations where they can
provide a worthwhile benefit.
1109 On-Street Parking
1109.2 Parallel Parking Spaces – An accessible aisle at least 60 inches 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.
Background: This requirement is confusing and could have great impact on project
budgets. Is this access aisle required for all parking spaces or only for
accessible spaces as required in 4.1.2 (5) (a)? If the requirement is only for
accessible spaces, this is a reasonable standard. If the requirement is for all
parking spaces, vast amounts of right-of-way will be inefficiently used and
available parking spaces severely limited.
Recommendation: Recommend clarification on this requirement so as to specify
that it apply to accessible parking spaces. I do not recommend it become the
standard for all on-street parking.
1109.5 Obstructions – There shall be no obstructions on the sidewalk adjacent to
and for the full length of the space
Background: This requirement eliminates an important safety feature that also
improves the quality of life for everyone: trees. Again, there is confusion over
whether this applies to all parking spaces or only to those designated as
‘accessible’. If this is to apply to all on-street parking spaces, there will be
a serious degradation in the quality of life for all. General pedestrian safety
will be impacted. Clean air mitigation will suffer. Restricting obstructions for
the entire length of the parking space is rather excessive and should only focus
on what is necessary for access.
Recommendation: Recommend this standard only apply to ‘accessible parking
spaces’ and restricts obstructions to the center 50 percent of the space so as
not to interfere with the operation of a side lift or a passenger side transfer.
1111 Alternate Circulation Path
1111.3 Location – The alternate circulation path shall parallel the disrupted
pedestrian access route, on the same side of the street.
Background: This requirement is excessive and will greatly impact minor projects
for minimal benefit. The unwarranted constraint of placing the alternate path on
the same side of the street as the original path is entirely unnecessary. This
says people cannot cross the street to reach another route but can be taken over
hill and dale to get around some utility work. Many times an entire block of
sidewalk is disrupted by maintenance work. What sense does it make to acquire a
construction easement, cut ramps through parking lots, and lay temporary
asphalt, when a perfectly accessible route is across two lanes of traffic? The
MUTCD says ‘Bicyclist and pedestrians should be provided with access and
reasonably safe passage through the temporary control zone.’
Recommendation: Recommend the Board follow the example of the MUTCD and use a
more generalized statement while requiring any route to be fully accessible.
Background
Discussion of Provisions
Text of the Draft Guidelines
The Americans with Disabilities Act (ADA) recognizes and protects the civil rights of people with disabilities and is modeled after earlier landmark laws prohibiting discrimination on the basis of race and gender. To ensure that buildings and facilities are accessible to and usable by people with disabilities, the ADA establishes accessibility requirements for State and local government facilities, places of public accommodation, and commercial facilities. Under the ADA, the Access Board has developed and continues to maintain design guidelines for accessible buildings and facilities known as the ADA Accessibility Guidelines (ADAAG). ADAAG covers a wide variety of facilities and establishes minimum requirements for new construction and alterations.
The Board maintains a similar responsibility for accessibility guidelines under the Architectural Barriers Act (ABA). The ABA requires access to certain facilities designed, built, altered, or leased with Federal funds, including those allocated for transit. Like ADAAG, the Board’s ABA accessibility guidelines apply to new construction and alterations.
The Board plans to undertake rulemaking to supplement its ADA and ABA accessibility guidelines, which primarily cover facilities on sites, by adding new provisions specific to public rights-of-way. The Board’s aim is to ensure 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 is available to pedestrians with disabilities. The guidelines would not require alterations 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.
BACKGROUND
The Need for
Guidelines on Public Rights-of-Way
Local
jurisdictions, and other entities covered by the ADA or ABA, must ensure that
the facilities they build or alter are accessible to people with disabilities.
The Board’s ADA and ABA accessibility guidelines specify the minimum level of
accessibility in new construction and alteration projects and serve as the basis
for enforceable standards maintained by other agencies. Currently, the Board’s
guidelines, like the industry standards from which they derive, focus mainly on
facilities on sites. While they address certain features common to public
sidewalks, such as curb ramps, accessible routes, ground and floor surfaces, and
bus stops and shelters, further guidance is necessary to address conditions
unique to public rights-of-way. Various constraints posed by space limitations
at sidewalks, roadway design practices, slope, and terrain raise valid questions
on how and to what extent access can be achieved. Access for blind pedestrians
at street crossings and wheelchair access to on-street parking are typical of
the issues for which additional guidance is needed. In addition, new trends in
roadway design, such as the growing use of traffic roundabouts, pose additional
challenges to access, while various technological innovations, particularly
those pertaining to pedestrian signaling devices, offer new solutions.
The Board previously proposed guidelines for public rights-of-way under the ADA, which were published for public comment in 1992 and 1994. Based on the comments received, the Board determined that it should further coordinate with the transportation industry and State and local governments before continuing its rulemaking. Consequently, the Board undertook an outreach and training program on accessible public rights-of-way. Under this program, the Board developed a series of videos, an accessibility checklist, and a design guide on accessible public rights-of-way. In addition, the Board sponsored research on tactile warnings at street crossings, accessible pedestrian signals, and traffic roundabouts. The Board has made this information widely available to the public. The interest in these materials has underscored the need for criteria for public rights-of-way that are definitive and enforceable so that local jurisdictions and others are clear on their obligations when constructing or altering streets and sidewalks.
Public Rights-of-Way
Access Advisory Committee
In resuming its
rulemaking effort, the Board chartered an advisory committee in 1999 to develop
recommendations on guidelines for accessible public rights-of-way. Use of
advisory committees has become a standard practice in the Board’s process for
developing and updating design requirements. Through such committees, interested
groups, including those representing designers, industry, and people with
disabilities, play a substantive role in recommending to the Board the content
of the guidelines to be developed. These committees provide significant sources
of expertise while enhancing the level of consensus among stakeholders in
advance of proposing a rule for public comment.
The Public Rights-of-Way Access Advisory Committee was composed of 33 members representing disability organizations, public works departments, transportation and traffic engineering groups, design professionals and civil engineers, government agencies, and standards-setting bodies. The committee coordinated its efforts with leading trade organizations represented on the committee, such as the American Association of State Highway and Transportation Officials, and federal agencies, such as the Federal Highway Administration, to ensure that its recommendations were consistent with generally accepted practice among design professionals. The committee organized several subcommittees focused on key issue areas. The subcommittee structure enabled members to continue work on a tight time schedule between meetings of the full committee and allowed for greater public participation in the process.
The advisory committee met regularly over a year’s time, usually in Washington, D.C. but also in Austin and San Francisco. Its work culminated in the issuance of a report, "Building a True Community," which was submitted to the Board in January 2001. The committee’s report provides criteria for the construction or alteration of public rights-of-way that reflects the broad spectrum of expertise represented by committee members. The report follows a "toolbox" approach to the establishment of guidelines designed to facilitate implementation and to promote an understanding of the needs of all users of public rights-of-ways. The report comprehensively covers the various components of public streets and sidewalks and provides criteria for sidewalks, street fixtures and furnishings, street crossings, vehicular ways, parking, and other components of public rights-of-way. In addition, the report includes advisory notes, figures, and discussion of issues that merit further study or special attention in the Board’s rulemaking. To what extent were transit facilities addressed? There seems to be little addressed.
Release of Draft
Guidelines
An ad hoc group
of Board members proceeded to review the committee’s report in depth and to
craft a set of draft guidelines based on the committee’s recommendations. The
draft guidelines depart from the advisory committee’s report in several areas,
which are detailed in the following discussion. Because of these differences,
the Board is making an advance draft of the guidelines available for comment by
the public, including industry groups, State and local governments, and advisory
committee members. The Board also seeks information and feedback, including
usability and cost data. Instructions on providing comment in writing or at an
information meeting to be held in Portland, Oregon, in October, are provided in
a
notice the Board published on the release of the draft guidelines.
Rulemaking Process
The Board is
making these draft guidelines available for public review and comment to seek
information and input for its use in developing a proposed rule. The proposed
rule will provide another opportunity for public comment on the guidelines. The
Board will then proceed to finalize the guidelines based on public comments
received in response to the proposed rule. The Board’s guidelines serve as the
basis for enforceable standards maintained by other agencies under the ADA and
the ABA. The Department of Justice and the Department of Transportation maintain
standards based on the Board’s guidelines that apply to facilities covered by
the ADA. Design standards for federally funded facilities covered by the ABA are
maintained by the Department of Defense, the Department of Housing and Urban
Development, the General Services Administration, and the U.S. Postal Service.
These enforceable standards must be consistent with the Board’s guidelines.
Relationship to ADA
and ABA Accessibility Guidelines
Currently, the
Board is completing an update of ADAAG, the first comprehensive revision of the
document since its publication in 1991. The revised ADAAG features a new format
and numbering system and a host of updated scoping and technical provisions. The
Board is updating its ABA Accessibility Guidelines along similar lines so that
both of the documents are more consistent. The Board released a draft of the
final ADA and ABA guidelines last April.
The draft guidelines for public rights-of-way are being developed as a supplement to the ADA and ABA guidelines and not as a stand-alone document. As such, they will ultimately comprise a new chapter on public rights-of-way. The Board has revised recommendations from the advisory committee in preparing these draft guidelines in order to facilitate their incorporation into the ADA and ABA guidelines. The draft guidelines presented here support the new format and structure of those documents. In addition, various provisions of this draft refer to provisions in the ADA and ABA guidelines to minimize redundancy. For simplicity, the following discussion refers to the draft final ADA and ABA guidelines released in April as "ADAAG," an acronym that has wide currency.
DRAFT GUIDELINES FOR PUBLIC RIGHTS-OF-WAY: DISCUSSION OF PROVISIONS
The proposed draft is formatted as a separate chapter, 11 Public Rights-of-Way, to be integrated into ADAAG. This chapter has a general section (1101), a scoping section, which indicates what is covered (1102), and technical sections addressing various elements of public rights-of-ways (1103 to 1111). Figures and advisory notes provided in the advisory committee’s report are not included in this draft, but will be included in the proposed rule.
Application and Administration (1101)
Referenced Standards
(1101.2)
The draft
guidelines reference standards issued by the U.S. Federal Highway Administration
known as the
Manual on Uniform Traffic Control Devices (MUTCD). The MUTCD,
which is used by road managers nationwide, covers the application and
installation of traffic signals, signs and pavement markings that regulate,
warn, and guide vehicle and pedestrian users of the public right-of-way.
Currently, the Federal Highway Administration is in the process of updating the
MUTCD.
Defined Terms (1101.3)
The draft
guidelines define various terms common to construction in the public
right-of-way that are used in the provisions that follow. Most of these
definitions derive from key industry sources such as the MUTCD or industry
practice. Consistent with the advisory committee’s report, the draft guidelines
minimize deviations from industry usage and understanding of defined terms to
ensure consistency with industry standards and best practices.
General Scoping: New Construction, Alterations, and Additions (1102)
Scoping
requirements in section 1102 indicate where the draft guidelines apply and which
elements and spaces must comply with the technical provisions. The draft
guidelines cover new construction (1102.1) and additions and alterations
(1102.2). Scoping provisions address various elements and spaces, including
access routes, curb ramps, signs, crossings, and street furniture (1102.3
through 1102.16). Does this include access to transit
facilites?
New Construction
(1102.1)
All areas of
newly designed and newly constructed facilities in public rights-of-way would be
subject to the guidelines. This scoping applies to work such as the extension of
roadways and sidewalks into undeveloped areas, new subdivisions, and similar
types of projects. Full compliance is generally easier in these types of
projects because the scope of work is usually extensive enough to allow
necessary grading and acquisition of sufficient right-of-way. The draft
guidelines would not require the provision of sidewalks, street crossings,
street furniture, parking, or other pedestrian elements where none are intended.
The guidelines address such elements only where they are provided as part of
construction or improvement projects.
Additions and
Alterations (1102.2)
Much of the work
that occurs in public rights-of-way involves alterations to existing facilities
or the addition of facilities within the constraints posed by existing developed
rights-of-way. The draft guidelines, consistent with ADAAG, would apply
technical requirements according to the scope of work for a planned alteration
or addition. This application is based on the premise that the more extensive
the work is, the greater are the opportunities to achieve access. In effect,
compliance is "prorated" based on the extent of the work planned. Industry and
local practices, among other factors, typically govern the scope of a project.
For example, industry practice may broaden the scope of work for a planned
improvement project to ensure a smooth transition to adjacent areas, improve
safety, or upgrade existing elements, such as drainage structures, within or
near the area to be improved.
Clear
definitions are needed for "alteration" and what types of roadway projects
trigger ADA improvements. Also, a process is needed for "accessibility design
exceptions", similar to the design exception process currently used by the FDOT
and FHWA.
The scope of a project would determine the extent to which the guidelines apply. A project involving substantial reconstruction of a roadway may be subject to requirements in the draft guidelines for sidewalks, curb ramps, and street crossings, among others. For less extensive projects, limited improvements to accessibility would generally be expected. For example, if an existing portion of sidewalk along a block face were rebuilt or replaced, at a minimum the new portion of sidewalk would be subject to specifications for sidewalks, including those for curb ramps and surfacing, among other things. However, compliance with these guidelines would not extend to untouched sections of sidewalk outside the planned alterations.
Compliance in alterations is required except where it is "technically infeasible." As defined in ADAAG, this term covers existing structural or space constraints that prohibit compliance, such as removing or altering a load-bearing member of the structural frame. In the case of public rights-of-ways, this may pertain to other types of constraints, such as those posed by existing construction, right-of-way width, and underground structures. What is feasible in a given alteration will depend on a wide range of factors particular to the project. Determinations of technical infeasibility must be made on a case-by-case basis in relation to each project’s unique conditions. For example, it might not be technically feasible to widen a narrow sidewalk undergoing an alteration due to existing buildings that front the sidewalk. On the other hand, such work might be technically feasible at other locations where acquiring additional right-of-way is practicable. Where technical infeasibility is encountered, compliance is required to the maximum extent possible.
The Board believes that guidance material on how to apply the guidelines in alterations projects would provide a valuable compliance tool. A subcommittee of advisory committee members is currently developing a guide on achieving accessibility in alterations to public rights-of-way. The subcommittee has conducted a series of meetings in different cities to gather information for case studies that will be included in the guide being developed. Over the past year, the subcommittee has met in Atlanta, Las Vegas, Portland (Oregon), and San Antonio. The guide is expected to be published early next year.
Existing Public
Rights-of-Ways
In previous
rulemakings in this and other areas, the Board has received comments concerning
the impact of retrofitting existing facilities to meet new guidelines. However,
the Board’s authority under the ADA and ABA extends only to the establishment of
accessibility guidelines for new construction and planned alterations. Its
guidelines do not address existing facilities outside the context of a planned
alteration (except for certain types of transit stations). Thus, the Board seeks
comments on these draft guidelines only as they pertain to new construction,
planned alterations, and additions. Under the ADA and other laws, requirements
issued by the
Department of Justice and the
Department of Transportation address access to existing facilities.
Accessible
Elements and Spaces: Scoping and Technical Requirements (1102.3 - 1111)
Alternate Circulation
Path (1102.3,
1111)
The draft
guidelines address construction within public rights-of-way and call for
alternate circulation paths where pedestrian access routes are temporarily
blocked by construction, alteration, maintenance, or other temporary conditions.
Technical specifications address the minimum clear width (36 inches), location
(on the same side of the street parallel to the disrupted pedestrian access
route), hazardous protruding objects, and criteria for signs and barriers.
Construction at public rights-of-way can be particularly hazardous to people
with visual or mobility impairments if the site is not adequately protected with
a barrier or barricade. In particular, tape or a series of widely spaced traffic
cones placed around a construction site may not be detected by some pedestrians.
Such markings do not provide sufficient cues to enable a blind pedestrian to
anticipate a hazard, nor do they provide an edge along which to travel around an
obstruction. Barriers would be required to be detectable, with edge protection
and railings. The requirements for barriers are based on proposed MUTCD
standards (Chapter 6). Make sure temporary access to
transit is included.
Pedestrian Access
Route (1102.4,
1103)
"Pedestrian
Access Route" is a key term that refers to the portion of the public
right-of-way that serves as an accessible route. Since the technical
requirements for this route are unique to public rights-of-way, the advisory
committee wanted to use a term distinct from "accessible route," which is used
by ADAAG in referring to routes on sites. In many cases, the pedestrian access
route would not have to encompass the full width of sidewalks and other
pedestrian ways. Thus, the term is used to refer to the compliant portion which,
in effect, provides a continuous accessible means of passage.
In new construction, the pedestrian access route would comprise a continuous, unobstructed path connecting to all elements and spaces required to be accessible. In an alteration or addition, the requirements for pedestrian access routes would apply only to new or altered portions of public rights-of-way. As a result, there may be breaks in continuity where the pedestrian access route is interrupted by portions of the existing pedestrian network which have not yet been altered. In such cases, the new or altered portions would be required to blend smoothly with the existing pedestrian network.
Specifications for pedestrian access routes address clear width, cross slope, grade, surface, changes in level, and other characteristics. The pedestrian access route may comprise sidewalks and walking surfaces, curb ramps and ramps, blended transitions, crosswalks, elevators, and other elements recognized by the guidelines.
Minimum Clear Width
(1103.3)
The draft
guidelines specify a minimum clear width of 48 inches for the pedestrian access
route, excluding the width of curbs. The advisory committee had recommended a
minimum width of 60 inches with various exceptions that would have permitted a
reduction to 48 inches in order to accommodate certain fixtures and elements. A
60 inch width would provide wheelchair turning space and passing space. The
Board has specified 48 inches minimum without exceptions, to be consistent with
industry practice. The 48 inch width remains greater than the width ADAAG
generally specifies for accessible routes on sites (36 inches).
For many
years the Florida DOT has constructed ADA features based on providing a minimum
36" clear width (including ramps, and sidewalks at driveway openings). Some
provision is needed to allow features based on earlier ADA requirements to be
grandfathered in, at least for some minimum period of time after adoption of the
rule. To mandate short term compliance with the 48” would have MAJOR impacts to
our work programs and would not be possible.
Grade (1103.5)
A key issue of
routes in public rights-of-ways is the grade or slope of the terrain. ADAAG
requires accessible routes on sites that slope more than 1:20 to be treated as
ramps. Ramps must have handrails on both sides, edge protection, and
intermediate level landings at least every 30 feet, among other requirements. It
would not be practical to apply ramp requirements generally to sidewalks in
sloped areas. Consistent with an advisory committee recommendation, the grade of
the pedestrian access route within a sidewalk is permitted to be as steep as the
grade of the adjoining roadway. The grade can be steeper than the roadway grade
where the route slopes less than 1:20 or is treated as a complying ramp.
Surfaces (1103.6)
The advisory
committee recommended that the pedestrian access route also contain a narrower
route within its boundaries that was smooth and free of irregular surface
features, such as granite pavers, cobble stones, and other types of rough or
jointed surfaces. This would minimize the sometimes painful vibration persons
using wheeled mobility aids may experience traversing rough and uneven surfaces.
However, the committee was not able to identify suitable methods for measuring
surface roughness or rolling vibration that would help determine whether a given
surface was sufficiently smooth. The advisory committee called attention to the
need for research on the relationship between surface roughness and wheeled
mobility aids, including possible measurement protocols. The Board agrees with
the committee that such information needs to be developed, but believes that a
requirement for surface smoothness should not be included until measurable
technical specifications are identified. Thus, a requirement for surface
smoothness has not been included. However, the pedestrian access route is
subject to requirements in ADAAG (section 302) which require surfaces to be
firm, stable, and slip resistant and which prohibit openings that are more than
1/2 inch in one dimension, such as might occur in a grating. In addition, the
Board has limited the frequency of permitted level changes along the pedestrian
access route (discussed below at
section 1103.8).
Surface Gaps at Rail
Crossings (1103.7)
Surface gaps or
openings in pedestrian access routes would be limited to 1/2 inch in one
dimension. This specification is not practicable at rail tracks where gaps must
be at least 2 1/2 inches to safely accommodate rail car wheel flanges. Due to
variations in load and wheel play, the gap must be even larger (3 inches) to
accommodate heavy freight trains. However, such a gap can trap wheelchair caster
wheels, which are prone to turning sideways against vertical displacements, even
slight ones. Specifications in the draft guidelines recognize the gaps widths
required along tracks, including those used by freight trains. The advisory
committee recommended that this provision contain a "sunset" clause that would
require compliance with a 1/2 inch specification by a specified time. The Board
has not included such a clause since it is not possible to reliably predict when
research may find a solution. Attempts have been made to develop a "gap filler"
device, but none of those devices have been successful. The Board is pursuing
options for research on this issue.
The draft guidelines would also require detectable warnings at the outside of each group of tracks that cross the pedestrian access route. This is important since flush surfaces at rail tracks will not provide a tactile cue to people with vision impairments. Where there are multiple sets of tracks, detectable warnings would be required along the outer edges of the entire group of tracks. Detectable warnings would not be required at tracks sharing vehicular ways, such as street car tracks in roadways, since curb ramps along roadways are also required to have detectable warnings (discussed below at section 1104).
Changes in Level
(1103.8)
The pedestrian access route would be subject to requirements in ADAAG for
changes in level (ADAAG 303) which permit level changes up to 1/4 inch without
treatment and level changes between 1/4 and 1/2 inch that are beveled with a
slope no greater than 1:2. Changes in level greater than 1/2 inch are to be
treated as a ramp or curb ramp. In addition to the referenced specifications,
the draft guidelines specify a minimum linear separation of 30 inches between
level changes in pedestrian access routes to prevent successive level changes
that can be disruptive to wheelchair maneuvering, such as those that may be
posed by sidewalk pavers. The advisory committee recommended specifying a
minimum separation of 24 inches based on the standard wheelchair wheelbase,
measured in the predominant direction of pedestrian travel. However, a
separation of at least 30 inches corresponds to a common size of sidewalk
segment and encompasses the wheelbase of most wheelchairs. This would allow most
persons using wheelchairs to clear one level change before encountering another.
This provision would not rule out the use of bricks or other small pavers that
are installed in a manner that provides a relatively flush surface and that are
properly maintained.
Protruding Objects (1102.5)
The draft
guidelines address objects that may project into circulation paths in a manner
hazardous to people with vision impairments. Unlike requirements for pedestrian
access routes, these criteria would apply to the full circulation space of
sidewalks and other pedestrian paths. Objects mounted on walls or posts with
leading edges above the standard sweep of canes (27 inches) and below the
standard head room clearance (80 inches) would be limited to a 4 inch
protrusion.
Curb Ramps and Blended
Transitions (1102.6,
1104)
Curb ramps or
blended transitions would be required to connect pedestrian access routes to
street crossings and to be located within the width of each crosswalk.
Generally, this would require two separate curb ramps at a corner instead of a
single ramp that opens diagonally onto an intersection. The advisory committee
strongly discouraged single installations where possible for several reasons.
Single ramps can misdirect blind pedestrians who use the slope of curb ramps as
a cue. They can increase crossing times for persons who use wheeled mobility
aids and can place users into oncoming traffic at small radius corners where it
is difficult to provide landing space at the bottom that is wholly within marked
crossings. Also, drivers may not be as alert to persons crossing at the apex of
a corner. On the other hand, the advisory committee recognized that providing
two separate compliant curb ramps may not always be practicable, particularly in
alterations, due to storm drain inlets, utility poles, and other constraints.
The draft guidelines provide technical criteria for perpendicular curb ramps, parallel curb ramps, and blended transitions. Perpendicular curb ramps, the most common type, have a running slope that cuts through a curb or meets the gutter grade break at right angles. Parallel curb ramps have a running slope that is in line with the direction of sidewalk travel. Blended transitions can be achieved by depressing the entire curb radius to street level or, less commonly, raising street crossings to sidewalk level, which can serve as a traffic calming strategy by creating a "speed table" at intersections. Various combinations of these different types of ramps and transitions can be used. For example, parallel ramps can be used for a portion of a curb level change in conjunction with a perpendicular ramp or a blended transition. The draft guidelines include requirements specific to each of these elements as well as criteria common to all of them.
Perpendicular Curb Ramps (1104.2.1)
Parallel Curb Ramps
(1104.2.2)
Parallel ramps
are especially suited to narrow rights-of-way where there is insufficient space
for the top landing of a perpendicular curb ramp. In this case, the bottom
landing usually serves as the direct connection to the street crossing. Criteria
for parallel curb ramps address the running slope (1:12 maximum and 1:48
minimum), cross slope (1:48 maximum), level landings at the bottom (at least 48
by 48 inches), and barriers at drop-offs. The running slope of parallel curb
ramps will be affected by the slope of the sidewalk, which is permitted to be as
steep as the adjacent roadway. Thus, a maximum slope of 1:12 may not be
achievable due to the road grade. In recognition of this, an exception limits
the required length of a parallel ramp to 15 feet, regardless of the slope. The
landing required at the bottom of the ramp is not permitted to slope more than
1:48 in any direction, but an exception is also provided for mid-block crossings
where compliance with this specification may be affected by the roadway grade.
Where parallel curb ramps do not span the full width of a sidewalk, a barrier is
required along the drop-off created by the ramp to prevent tripping hazards.
Blended Transitions
(1104.2.3)
Blended
transitions are to have slopes parallel and perpendicular to the curb no greater
than 1:48. Transitions with a slope greater than 1:48 are to be treated as a
curb ramp.
Common Elements
(1104.3)
Curb ramps and
blended transitions would be subject to requirements for clear width (48 inches
minimum), detectable warnings, surfaces, grade breaks, changes in level, counter
slopes, and clear space.
Detectable Warnings
(1104.3.2)
Detectable
warnings provide a distinctive surface of truncated domes detectable by cane or
underfoot to alert people with vision impairments of the transition to vehicular
ways. These warnings compensate for the sloped surfaces of curb ramps which
remove a tactile cue provided by curb faces. ADAAG, as originally published in
1991, contained a requirement for detectable warnings on the surface of curb
ramps and other locations where pedestrian ways blend with vehicular ways
without tactile cues. This requirement was temporarily suspended due to concerns
raised about the specifications, the availability of complying products,
maintenance, usefulness, safety, and the need for further study. The suspension
expired in July 2001.
The advisory committee considered the issue at length and recommended that the draft guidelines require detectable warnings according to revised specifications. The Board agrees with the committee’s recommendation and has included a requirement for a detectable warning surface 2 feet deep where the ramp, landing, or blended transition connects to a crosswalk. Since detectable warnings are intended to replace the cue otherwise provided by a curb drop-off, they would be required to span the entire area where the curb drop-off is absent. This is especially important for blended transitions, where there is no slope to help detect the presence of a ramp.
The advisory committee deliberated on whether to require detectable warnings at all curb ramps and blended transitions or only those which were the least distinguishable. One organization represented on the committee suggested that detectable warnings be required only where the ramp slope was 1:15 or less. The Board seeks comment on this issue as well as any research that supports slopes of 1:15 or steeper being sufficiently detectable by persons with vision impairments.
The technical specifications for detectable warnings are discussed below in section 1108.
Other Requirements for
Curb Ramps and Blended Transitions (1104.3.3 - 1104.3.7)
Other technical
requirements for curb ramps and blended transitions would:
Pedestrian Signs (1102.7)
Signs provided
for pedestrian use would be subject to certain ADAAG specifications for visual
legibility. These requirements would not apply to traffic and street signs
intended for vehicle operators, which are covered by the MUTCD. Provisions are
included for bus route identification signs, informational signs, and warning
signs. Specifications in ADAAG 703.5 for visual characters are referenced. This
section of ADAAG covers finish and contrast, style, the proportions and height
of characters, sign height, stroke thickness, and character and line spacing.
Bus Route
Identification
(1102.7.1)
Bus route identification signs would be subject to the visual character
requirements, except those for character height (which would apply only to the
maximum extent practicable) and sign height. This requirement would not apply to
bus schedules, timetables, or maps. This provision is consistent with existing
ADAAG provisions for bus stops and shelters (section 810.4). In addition, the
draft guidelines would require route identification signs located at bus
shelters to be tactile and provide information in raised and Braille characters
according to specifications in ADAAG (section 703.2). Raised characters are to
have rounded corners. An exception permits certain types of audible signs to
substitute for tactile signage. When is this exception in
force?
Informational Signs
and Warning Signs (1102.7.2)
ADAAG
specifications for visual legibility would also apply to informational signs and
warning signs located in public rights-of-ways, but the draft guidelines would
not require the inclusion of raised and Braille characters. This provision would
apply to signs that label or provide information about, or direction to, public
buildings, transit stations and stops, and many other facilities and elements.
It would also cover signs at elements for pedestrian use, such as signal
pushbuttons, and signs that warn of sidewalk closings or that provide direction
to alternate pedestrian routes. This is a particularly
difficult situation for blind pedestrians. During construction, if routes are
changed, they can quickly become dangerous for blind persons walking into
potentially dangerous construction areas. Identifiable warnings and barriers
are important for safety, not just accessibility.
Pedestrian Crossings (1102.8,
1105)
This section
addresses crosswalks, pedestrian signal timing for crossings, pedestrian
islands, overpasses and underpasses, vehicular roundabouts, turn lane crossings,
and pedestrian signals.
Crosswalks (1105.2)
Requirements for
crosswalks cover the width, cross slope, and running grade. These specifications
would apply to both marked and unmarked crossings, wherever pedestrian travel
across the roadway is not prohibited. Marked crosswalks are specified to be at
least 96 inches wide, as recommended by the advisory committee, which exceeds
the 72 inch minimum specified in the MUTCD. Since pedestrians, including people
with vision impairments and those who use wheelchairs, must pass each other in
an environment that demands rapid crossing times, it is important for crosswalks
to provide adequate width so quick and easy passing occurs without delaying
clearance of the crosswalk.
The cross slope is limited to 1:48, except at mid-block crossings. The cross slope of the crosswalk is the running grade of the roadway. It is not uncommon for streets to be constructed with constant profile grades up to 9 or 10 percent. This specification would require reduction of these profile grades to 2 percent at intersection crosswalks, thus forming "tabled areas" at intersections so that the 1:48 slope is achieved at crosswalks. The specified running slope for crosswalks is 1:20.
Pedestrian Signal
Phase Timing (1105.3)
The draft
guidelines would require pedestrian signal phase timing to be calculated
according to a walking speed of 3.0 feet per second. Industry practice generally
recommends calculations based on a speed ranging from 3.5 to 4.0 feet per
second, though some jurisdictions are reportedly considering a rate of 2.5 feet
per second. The advisory committee recommended using a crossing speed of 3.5
feet per second or less. The Board believes that a rate of 3.0 feet per second
will accommodate a broader range of pedestrians and offer greater access.
Medians and Pedestrian
Refuge Islands (1105.4)
The draft
guidelines would require that medians and pedestrian refuge islands, where
provided, be cut through at street level or have complying curb ramps so that a
pedestrian access route is maintained. Specifications for length and detectable
warnings apply where signal timing does not permit crossing all traffic lanes in
one cycle.
Pedestrian Overpasses
and Underpasses (1105.5)
The draft
guidelines address access to pedestrian overpasses and underpasses, which would
be required to provide a pedestrian access route. A ramp would be required where
the running slope exceeds 1:20. However, overpasses and underpasses commonly
span significant elevation changes. A complying ramp requires at least a foot of
run for every inch of elevation, in addition to space for intermediate level
landings at least every 30 feet or where a ramp changes direction. Due to the
exertion required in maneuvering wheelchairs upslope, lengthy ramps often are
unusable and can be impractical due to the amount of right-of-way space they
require. The Board is not aware of information that specifically indicates at
what point a ramp is too long to be used by persons with disabilities. The
advisory committee recommended that an elevation change of 60 inches be the
cut-off. Consistent with this recommendation, the draft guidelines would require
elevator access where the rise of a ramped approach exceeds 60 inches. The Board
seeks comment on whether this is an appropriate trigger for elevator access. The
requirement references ADAAG specifications for standard passenger elevators
(section 407) and limited-use/limited application elevators (section 408), which
are usually smaller and slower than other passenger elevators and are typically
used for low-traffic, low-rise installations.
In addition to elevator requirements, the draft guidelines apply ADAAG specifications to stairs (section 504) and escalators (section 810.9).
Roundabouts (1105.6)
A growing trend
in roadway design favors continuous-flow roundabouts over traditional signalized
intersections. While their design varies widely, roundabouts typically feature a
circulatory roadway around a central island. Entering traffic yields to vehicles
already in the circle. Increasingly popular in the U.S. because they add vehicle
capacity and reduce delay, roundabouts are a common feature in Europe and
Australia. Because crossing at a roundabout requires a pedestrian to visually
select a safe gap between cars that may not stop, accessibility has been
problematic. While roundabouts may be an asset to traffic planners in
controlling and slowing the flow of traffic at intersections without using
traffic signals, the absence of stopped traffic presents a problem for
pedestrians with vision impairments in crossing streets. Pedestrians report that
vehicles at roundabouts, as well as at other unsignalized crossings, often do
not yield for pedestrians. Persons with vision impairments and pedestrians who
may hesitate at such crossings are at a particular disadvantage.
Can we 'require' "Yield to Pedestrians" signs and
entrances/exits to roundabouts?
To provide safer crossing at roundabouts, the draft guidelines would require pedestrian activated crossing signals at each roundabout crosswalk, including those at splitter islands. (The draft guidelines would ensure that such signals are usable by persons with vision impairments under requirements in section 1106 discussed below.) Although roundabouts are typically used to avoid signalization, the Board is not aware of alternatives that would allow safe passage for pedestrians with disabilities. Aside from accessibility, the use of roundabouts in areas of high pedestrian use has been questioned by some in the industry.
Requiring the signal to be pedestrian activated may help limit the impact on traffic flow. Signal technologies are available that can further minimize the impact, such as devices that halt traffic only while a pedestrian is in the crosswalk. The Board seeks information on alternative design strategies and available technologies that can improve access at roundabouts for persons with disabilities, particularly those with vision impairments.
Barriers or similarly distinct elements are needed to prevent blind persons from inadvertently crossing a roundabout roadway in unsafe locations. The draft guidelines would require a continuous barrier along the street side of the sidewalk where pedestrian crossing is prohibited. If a railing is used, it must have a bottom rail no higher than 15 inches. This dimension would allow use of a standard roadside guardrail while providing sufficient cane detectability.
Turn Lanes at
Intersections (1105.7)
The draft
guidelines also include a requirement for a pedestrian activated signal at each
segment of a crosswalk that crosses right or left turn slip lanes.
Accessible Pedestrian
Signal Systems (1102.8,
1106)
At signalized
intersections, people with vision impairments typically rely on the noise of
traffic alongside them as a cue to begin crossing. The effectiveness of this
technique is compromised by various factors, including increasingly quiet cars,
permitted right turns on red, pedestrian activated signals, and wide streets.
Further, low traffic volumes may make it difficult to discern signal phase
changes. Technologies are available that enable audible and vibrating signals to
be incorporated into pedestrian signal systems, which are those systems that
provide signals expressly for pedestrians, such as "walk" signs. The draft
guidelines would require pedestrian signal systems, where provided, to provide
both audible and vibrating indications of the "walk" interval. Typically, a
small box, with a directional arrow, emits an audible tone or voice message and
vibrates when the walk interval begins.
Increasingly, signals activated by pedestrians, usually by means of a push button, are being installed. The draft guidelines would require push buttons, where provided, to be equipped with a locator tone integrated into the signaling device to indicate that pedestrian activation is necessary and to identify the location of the push button.
The Board is proposing to apply these requirements where pedestrian signal systems are provided at pedestrian crossings. The advisory committee had recommended limiting their application only where certain types of pedestrian signal systems are provided, such as those that are pedestrian activated. The Board believes that access should be required at all crossings equipped with pedestrian signals to ensure a consistent level of accessibility within a pedestrian network. Compliant products are available. A project the Board sponsored on accessible pedestrian signals provides a synthesis on current technology in accessible pedestrian signals, including a listing of devices and manufacturers in the U.S. and abroad, and a matrix comparing the features of each device. The project report, "Accessible Pedestrian Signals" provides information on several different types of devices on the market, including audible, vibrating, and receiver-based infrared systems. Audible systems are now available that feature discreet tones which automatically adjust to the ambient noise level. These systems have replaced older products that had raised concerns about noise pollution. Maybe not require accessible ped signals everywhere, but primarily on/near transit corridors because of transit dependence.
In addition, the criteria for pedestrian signal devices, most of which are consistent with MUTCD specifications, address:
Street Furniture (1102.9,
1107)
The draft
guidelines provide requirements for street furniture made available for
pedestrian use, including drinking fountains, public telephones, toilet
facilities, tables, and benches. The draft guidelines would not require
provision of street furniture, but instead would apply access requirements where
such furniture is provided for pedestrian use. Access would not be required to
elements that do not serve pedestrians, such as utility poles, fire hydrants,
and signal transformers. Since the types of furniture addressed in this section
are covered in ADAAG, this section references relevant ADAAG requirements.
Clear Floor Space
(1107.2)
The draft
guidelines address wheelchair access to street furniture by referencing
requirements for clear floor or ground space in ADAAG 305. Such space must be
connected to a pedestrian access route and meet ADAAG criteria for size (30 by
48 inches minimum), surfacing, knee and toe clearances, positioning, approach,
and maneuvering clearances.
Drinking Fountains
(1107.3)
ADAAG
requirements for drinking fountains in section 602 cover access for people who
use wheelchairs and access for standing persons who may have difficulty bending
or stooping. The draft guidelines would apply these requirements for this dual
access to each installation in public rights-of-way. This can be achieved by
providing two units at each location or installing single units that provide
dual access, such as those equipped with two spouts or combination high-lo
types.
Public Telephones
(1107.4)
ADAAG
requirements for public telephones in section 704 cover wheelchair access,
volume controls, and TTYs, which are devices that enable people with hearing or
speech impairments to communicate through the telephone. For single
installations, the draft guidelines would require public telephones to provide
wheelchair access and TTY access. Where a bank of telephones is provided, these
requirements are to be met at two different phones. All public telephones would
be required to have volume controls, which is consistent with ADAAG, as well as
guidelines the Board issued for telecommunication products under section 255 of
the Telecommunications Act of 1996, which requires telecommunication products
and services to be accessible.
Public Toilet
Facilities (1107.5)
The draft
guidelines would require permanent or portable public toilet facilities to be
accessible according to ADAAG section 603. Where single-user facilities are
clustered at a single location, an exception would permit at least 5% to be
accessible. The advisory committee recommended a minimum scoping requirement of
25%, but the Board has chosen the 5% specification for consistency with ADAAG.
Provided fixtures would be subject to ADAAG requirements in sections 604 through
610, which cover water closets and toilet compartments, urinals, lavatories,
bathing fixtures, and grab bars. In addition, operable parts, dispensers,
receptacles, or other equipment in toilet facilities would need to comply with
relevant criteria in ADAAG section 309, which addresses clear floor space,
height, and operating characteristics (operable with one hand and not requiring
tight grasping, pinching, twisting of the wrist, or more than 5 pounds of force
to operate).
Tables, Counters, and
Benches (1107.6)
At least 5% of
tables, where provided, would be required to comply with ADAAG requirements in
section 902 which cover surface height, knee clearance, and clear ground space.
Counters would be subject to ADAAG requirements at section 904 which address
surface height and approach clearances. Accessible bench requirements in ADAAG
section 903 would be applied to at least half the benches provided. ADAAG
criteria for benches cover size, back support, height, structural strength, and
other features. In addition, the draft guidelines would require accessible
benches to provide an armrest on at least one end.
Detectable Warning
Surfaces (1108)
Pedestrian street
crossings, including, curb ramps and blended transitions (1104.3.2), certain
median and refuge islands (1105.4.2), and rail lines (1103.7) are required to
have detectable warnings for persons with vision impairments. These surfaces
feature a distinctive pattern of raised domes to provide a tactile cue
detectable by cane or underfoot at the boundary between pedestrian and vehicular
routes.
Specifications in section 1108 address the area that these warnings are to cover at required locations. The Board has revised the technical criteria for detectable warnings in order to facilitate compliance and to accommodate existing detectable warning products that have been deemed to provide an equivalent level of accessibility. The revised specifications are also responsive to concerns that had been raised about the impact of the truncated dome surface on wheelchair maneuvering. The Board believes that the revised specifications, which permit wider dome spacing, an in-line grid pattern, and smaller surface coverage at curb ramps (24 inches instead of the full ramp length) will further minimize disruptions or hazards to wheelchair traffic.
Guidance is needed on the location of detectable warning surfaces when curb is not present. For example, there a many instances where sidewalks are present along uncurbed roadways. It appears appropriate that sidewalks that are interrupted by major roads and streets should have warnings, but not residential type driveways. However, commercial establishment driveways can range from very low traffic volume to very high volume. More specific guidance for these situations should be provided.
Stairs (1102.10)
The draft
guidelines apply requirements in ADAAG section 504 to stairs in public
rights-of-way. These ADAAG specifications address tread depth and riser height,
nosings, handrail and surface requirements, and prohibit open risers. The draft
guidelines also include a new requirement for contrasting color across the
nosing of stairs in the public right-of-way. This latter provision was
recommended by the advisory committee because of the difficulty persons with low
vision have in perceiving steps under the variable lighting conditions in public
rights-of-ways.
Handrails (1102.11)
Consistent with
the revised ADAAG, handrails, where provided, would be subject to ADAAG section
505, which provides specifications for height, knuckle clearance, gripping
surface, cross section, surfaces, fittings, and extensions.
Vertical Access (1102.12)
Where elevators
or lifts are provided in public rights-of-ways, the draft guidelines would apply
specifications in ADAAG for passenger elevators (section 407), limited-use/
limited-application elevators (section 408), and platform lifts (section 410).
Elevators are not required by these guidelines except at certain pedestrian
overpasses and underpasses with elevation changes greater than 60 inches.
Bus Stops (1102.13)
ADAAG contains
requirements for bus boarding and alighting areas and bus shelters in section
810.2 and 810.3. These requirements address bus stop surfacing, dimensions,
connections to accessible routes, slope, and wheelchair space within bus
shelters. The draft guidelines would apply these requirements to bus stops and
shelters provided in public rights-of-way.
On-Street Parking (1102.14,
1109)
A key issue
addressed in the guidelines is how to provide access to on-street parking.
Current ADAAG scoping and technical requirements are specific to parking lots
and facilities on sites. Over the years, the Board has received many inquiries
on how they can be applied to on-street spaces. The draft guidelines would
require access to at least one parking space on each block face. The advisory
committee recommended applying ADAAG requirements in section 208 for parking
lots and facilities, which uses a sliding scale based on the total number of
spaces provided. This scale starts out with a requirement for access to at least
1 space for every 25 spaces provided. The Board was concerned about confusion
that might arise in applying a requirement written for parking facilities on
sites to on-street parking. The Board believes that the proposed requirement
will be easier to implement and enforce.
Technical specifications are provided for parallel and perpendicular or angled spaces. Requirements address adjoining access aisles at spaces, accessible connecting routes, signs, and parking meters. An accessible parallel space and access aisle, which must be flush with the street, can be achieved by indenting the curb line, similar to a loading zone. For a passenger with a disability, drivers park in line with the other spaces, leaving aisle space free; drivers with disabilities can park against the curb, leaving aisle space on the driver’s side free. Since the curb indentation takes space from the sidewalk, the access aisle can only be provided where there is sufficient public right-of-way width. Consequently, an exception is provided that allows spaces without aisles where the available public right-of-way is less than 168 inches wide; such spaces would be placed at the end of a block, closer to corner curb ramps or blended transitions. This exception would not apply where perpendicular and angled parking spaces are provided, which are required to have aisles sufficiently wide enough (96 inches minimum) to accommodate van-mounted lifts.
Signs labeling accessible spaces are to include the International Symbol of Accessibility and be located at least 60 inches high at the head or foot of the parking space. Criteria for parking meters address location, the visibility of displays and information, and the height and operating characteristics of controls as specified in ADAAG section 309.
Passenger Loading
Zones (1102.15)
ADAAG
requirements for passenger loading zones would be applied to loading zones in
the public right-of-way. Where a long loading zone is provided, at least one
area in every 100 continuous feet must comply with requirements in ADAAG section
302 and 503 which address the surfacing, the size of vehicle pull-up spaces (8
by 20 feet minimum), the marking and size of access aisles (at least 60 inches
wide and as long as the pull-up space), and vertical clearance (114 inches
minimum).
Call Boxes (1102.16,
1110)
The draft
guidelines address emergency call boxes that are provided at intervals on
roadsides for stranded motorists to use to summon aid. Access requirements would
apply where such devices are provided. Specifications address access for persons
with mobility impairments and persons with sensory impairments, including those
with hearing impairments.
The draft guidelines would require that operable parts be located within accessible reach ranges and meet operating characteristics in ADAAG sections 308 and 309.4. ADAAG specifies that controls be operable with one hand and not require tight grasping, pinching, twisting of the wrist, or more than 5 pounds of force to operate. The Board has received information demonstrating that a particular type of call box that initiates a signal through a lever pull requires up to 12 pounds of force to successfully initiate a signal. An exception has been included for lever pull systems.
Specifications also address the wheelchair space complying with ADAAG 304, edge protection at abrupt level changes in the call-box area as is otherwise specified for ramps in ADAAG section 405.9.2, and access at vehicle pull-over spaces. In addition, audible and visual indicators of an activated signal are required in compliance with ADAAG requirements for two-way communication systems in section 708. Handsets, where provided, must also meet specifications in ADAAG section 708. To accommodate persons with hearing impairments, including those who are deaf, the draft guidelines would require volume control and TTY access at call boxes that provide two-way voice communication.
Text of the Draft Guidelines for Accessible Public Rights-of-Way
1101Application and Administration (referenced standards
and defined terms)
1102 Scoping Requirements
1103 Pedestrian Access Route
1104 Curb Ramps and Blended Transitions
1105 Pedestrian Crossings
1106 Accessible Pedestrian Signal Systems
1107 Street Furniture
1108 Detectable Warning Surfaces
1109 On-Street Parking
1110 Call Boxes
1111 Alternate Circulation Path
1101 Application and Administration
1101.1 General. For the purposes of these requirements, the terms listed in section 1101.3 shall have the indicated meaning.
1101.2 Referenced Standards.
1101.2.1 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.
1101.3 Defined Terms.
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.
Alteration: Need a clear definition, with examples, for Alteration to assist determination when accessibility upgrades are triggered. Especially for routine and/or on-going roadway repair and maintenance activities (resurfacing, restriping, patching potholes, utility construction, etc.) To what extent/at what level do these activities require the accessibility upgrades to surrounding/adjacent facilities in the right-of-way? (EG: For 3-R (resurfacing, rehabilitation and restoration) projects – would it be required to widen existing 3-foot wide curb ramps to 4-foot wide to meet these recommendations?)
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).
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 curb line 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.
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.
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.
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 curve in the roadway (see cross slope).
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.
1102 Scoping Requirements
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
1102.6 Curb Ramps 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.
1102.7 Pedestrian Signs. Signs for pedestrian use shall comply with 1102.7.
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.
1102.7.2 Informational Signs and Warning Signs. Informational signs and warning signs shall comply with 703.5.
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.
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.
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.
1102.11 Handrails. Where provided, handrails shall comply with 505.
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.
1102.13 Bus Stops. Bus boarding and alighting areas shall comply with 810.2. Bus shelters shall comply with 810.3.
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.
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.
1102.16 Call Boxes. Where provided, call boxes shall comply with 1110.
1103 Pedestrian Access Route
1103.1 General. Pedestrian access routes shall connect to elements required to be accessible and shall comply with 1103.
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 lifts. All components of a pedestrian access route shall comply with the applicable portions of this chapter.
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.
1103.4 Cross Slope. The cross slope of the pedestrian access route shall be 1:48 maximum.
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.
1103.6 Surfaces. The surfaces of the pedestrian access route shall comply with 302.
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 2-½ inches (64 mm).
EXCEPTION: On tracks that carry freight, a maximum horizontal gap of 3 inch (75 mm) shall be permitted.
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.
1103.8 Changes in Level. 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.
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.
1104 Curb Ramps and Blended Transitions
1104.1 General. Curb ramps and blended transitions shall comply with 1104.
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.
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.
1104.2.1.1 Running Slope. The running slope shall be 1:48 minimum and 1:12 maximum.
1104.2.1.2 Cross Slope. The cross slope shall be 1:48 maximum.
EXCEPTION: This requirement shall not apply to mid-block crossings.
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.
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.
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.
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 feet (4570 mm) in length.
1104.2.2.2 Cross Slope. The cross slope shall be 1:48 maximum.
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.
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.
1104.2.3 Blended Transitions. Blended transitions shall comply with 1104.3, and shall have running and cross slopes of 1:48 maximum.
1104.3 Common Elements. Curb ramps and blended transitions shall comply with 1104.3.
1104.3.1 Width. The clear width of landings, blended transitions, and curb ramps, excluding flares, shall be 48 inches (1220 mm) minimum.
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.
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.
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.
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.
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.
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.
1105 Pedestrian Crossings
1105.1 General. Pedestrian crossings shall comply with 1105.
1105.2 Crosswalks. Crosswalks shall comply with 1105.2.
1105.2.1 Width. Marked crosswalks shall be 96 inches (2440 mm) wide minimum.
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.
1105.2.3 Running Slope. The running slope shall be 1:20 maximum measured parallel to the direction of pedestrian travel in the crosswalk.
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.
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 with 1104 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.
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.
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.
1105.5 Pedestrian Overpasses and Underpasses. Pedestrian overpasses and underpasses shall comply with 1105.5.
1105.5.1 Pedestrian Access Route. Pedestrian overpasses and underpasses shall contain a pedestrian access route complying with 1103.
1105.5.2 Running Slope. The running slope shall not exceed 1:20 maximum.
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.
1105.5.4 Stairs. Stairs shall comply with 504.
1105.5.5 Escalators. Escalators shall comply with 810.9.
1105.6 Roundabouts. Where pedestrian crosswalks and pedestrian facilities are provided at roundabouts, they shall comply with 1105.6.
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.
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.
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.
1106 Accessible Pedestrian Signal Systems
1106.1 General. Pedestrian signal systems shall comply with 1106.
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.
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.
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.
1106.2.3 Audible Walk Indication. The audible indication of the WALK interval shall be by voice or tone.
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.
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. Can any of the recommended tones be confused with the back-up signal 'beepers' that most heavy equipment uses in construction areas?
1106.3 Pedestrian Pushbuttons. Pedestrian pushbuttons shall comply with 1106.3.
1106.3.1 Operation. Pedestrian pushbuttons shall comply with 309.4.
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.
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.
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. Maybe add a raised 'arrow' pointing toward the direction the button controls; or adding Braille characters on a sign describing the street name for which crossing the button controls.
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.
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.
1106.4.2 Street Name. Signs shall include street name information aligned parallel to the crosswalk direction and complying with 703.2.
1106.4.3 Crosswalk Configuration. Where provided, graphic indication of crosswalk configuration shall be tactile and shall comply with 703.5.1.
1107 Street Furniture
1107.1 General. Street furniture shall comply with 1107.
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.
1107.3 Drinking Fountains. Where drinking fountains are provided, they shall comply with 602.
1107.4 Public Telephones. Where public telephones are provided, they shall comply with 1107.4.
1107.4.1 Single Telephone. Where a single public telephone is provided, it shall comply with 704.2 and 704.4
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.
1107.4.3 Volume Controls. All public telephones shall provide volume controls complying with 704.3.
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.
1107.6 Tables, Counters, and Benches. Tables, counters, and benches shall comply with 1107.6.
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.
1107.6.2 Counters. Where provided, counters shall comply with 904.
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.
1108 Detectable Warning Surfaces
1108.1 General. Detectable warnings shall consist of a surface of truncated domes aligned in a square grid pattern and shall comply with 1108.
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).
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.
1108.1.3 Contrast. Detectable warning surfaces shall contrast visually with adjacent walking surfaces either light-on-dark, or dark-on-light.
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.
1108.2 Location.
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.
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.
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.
1109 On-Street Parking
1109.1 General. Car and van on-street parking spaces shall comply with 1109.
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.
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.
1109.4 Curb Ramps or Blended Transition. A curb ramp or blended transition complying with 1104 shall connect the access aisle to the pedestrian access route.
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.
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.
1109.7 Parking Meters. Where parking meters are provided, they shall comply with 1109.7.
1109.7.1 Operable Parts. Operable parts shall comply with 309.
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 lift 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.
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.
1110 Call Boxes
1110.1 General. Call boxes shall comply with 1110.
1110.2 Operable Parts. Operable parts shall comply with 308 and 309.4. Where provided, labeling shall comply with 703.2 and 703.3.
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.
1110.3 Turning Space. A turning space complying with 304 shall be provided at the controls.
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.
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.
1110.6 Two-Way Communication. Where provided, two-way voice communication shall comply with 1110.6, 708.2 and 708.3.
1110.6.1 Volume Controls. Volume controls complying with 704.3 shall be provided.
1110.6.2 TTY. A TTY complying with 704.4 shall be provided.
1111 Alternate Circulation Path
1111.1 General. Alternate circulation paths shall comply with 1111.
1111.2 Width. The alternate circulation path shall have a width of 36 inches (915 mm) minimum.
1111.3 Location. The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street.
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.
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.
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.