City of Rancho Cucamonga

Subject: Comments on the Americans with Disabilities Act (ADA) Draft Guidelines on
Accessible Public Rights-of-Way

Dear Access Board:

The City of Rancho Cucamonga is a hillside community located in the foothills just south of the San Gabriel Mountains and San Bernardino National Forest in southern California. Being a hillside community, the City of Rancho Cucamonga is faced with many challenges in meeting ADA requirements.

The City of Rancho Cucamonga has reviewed the Draft Guidelines on Accessible Public Rights-of-Way and has some concern and questions regarding the proposed requirements in many areas, including Accessibility/Public Access Routes, Detectable Warnings, Counter Slopes, Cross Slopes in Crosswalks, and Pedestrian Signal Phase Timing.

Regarding Accessibility and Pedestrian Access Route (PAR):

The draft guidelines require a PAR to have a grade of less than 1:20. In steep hillside terrain, this and other requirements may be unattainable. There needs to be consideration in the guidelines for areas of steep terrain in hillside communities.

In addition, there are many areas in hillside communities such as ours where there are no sidewalks provided on roads and highways, but there are pedestrians. The Access Board needs to consider such issues in the development of these guidelines.

Regarding Detectable Warnings:

Section 1104.3.2 We request the Access Board revisit the issue of detectable warnings before instituting this requirement.

Has the Access Board developed a list of approved manufacturers of truncated cone detectable warning surfaces? This may be very beneficial to ensure compliance with the guidelines.

Regarding Counter Slopes

Section 1104.3.6 Counter Slopes. The standard gutter in our City and many others has a slope of 1: 12. The 1:20 requirement would necessitate that we transition to meet the 1:20 requirement fronting the ramp, which is contrary to long-standing practice leading to potential non-compliance. The ramp itself is 1: 12, so is it - necessary that the gutter be that much flatter? Our experience has been that the old standard of a 1/2. or 1/4 " lip presented an obstacle to wheelchairs; perhaps there is confusion as to what is causing the problem. We recommend that the 1:20 requirement be changed to 1: 12.

Regarding Cross Slopes in Crosswalks:

In Section 1105.2.2 the maximum cross slope of 1:48 will require flattened tables at intersections where the prevailing grade of the major through street is greater than 1:48. Long vertical curves will be necessary leading into and out of the intersection to preserve the proper design speed of the major street, resulting in substantial grading and increase the slope of the sidewalk parallel to the major street. The condition will be automatically taken care of where major streets intersect; therefore, it is not necessary to make the general requirement.

Regarding Pedestrian Signal Phase Timing:

The draft guidelines require that all pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet per second (0.91 m/s) maximum, and that 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.

In major metropolitan areas such as southern California where traffic congestion is already very heavy, these requirements pose significant concerns. The slower crossing speeds and longer distance for calculating the traffic signal timing will have a significant impact on traffic flow.

Current industry practices that are widely accepted, primarily recommend the use of 4 feet per second. Also, the minimum distance used for calculating pedestrian signal phase timing is generally from the curb on one side of the street to the center of the farthest traveled lane on the opposite side, or to a median of sufficient width for pedestrians to wait.

The draft guidelines will result in an increase of the duration of the signal phases thereby worsening existing heavy traffic conditions.

Furthermore these draft requirements could severely impact the flow of traffic on major thoroughfares and traffic corridors where the coordination of signal timing is critical, particularly between locally controlled and state controlled roadways. This would be contrary to existing congestion management programs established by the state of California to control traffic congestion.

Notwithstanding the issue of traffic flow, the cost to re-program traffic facilities to comply with the draft guidelines would be cost-prohibitive.

In viewing the Access Board’s web site which posts the comments already received by the Board, we noted that numerous public entities have many of the same concerns as we do regarding the proposed guidelines.

In particular, we noted a letter from the City of Pueblo, Colorado (Department of Transportation) which provides excellent comments on many of the sections that we also have issues. Rather than repeat the same comments in depth, we echo the same concerns on the issues discussed in the City of Pueblo’s letter as itemized below. We have also attached a copy of the letter as printed from your web site.

Section 1101.3 Defined Terms. The proposed definition of “Street Furniture is overly broad.
Section 1102 Scoping Requirements. Acquiring right-of-way can be very burdensome and costly. The conflict regarding ramps in crosswalks needs to be addressed.

Section 1103 Pedestrian Access Route. Clarification regarding changes in level is needed.
Section 1104 Curb Ramps and Blended Transitions. In Section 1104.2.2.4, further clarify “barrier”.
Section 1105 Pedestrian Crossings.
In Section 1105.2.1, the basis of this requirement to exceed MUTCD widths is unclear.
In Section 1105.5, it is more feasible to have resting platforms than elevators.
In Section 1105.61, there are other methods that deserve more thorough consideration to affect the desired result.
In Section 1105.6.2, signals are not necessary in every location to effect accessibility. There is need for more reasonableness.
Section 1106 Accessible Pedestrian Signal Systems. The location dimensions should be revised to communicate the concept as a guidance statement without making it a mandate.
In Section 1106.4 Tactile street name signs as proposed could be expensive and difficult to maintain.
Section 1109 On-Street Parking. It would be more prudent to require parking spaces for the disabled only in business or commercial areas.
In Section 1109.2 regarding parallel parking spaces, the proposed width requirement will limit the ability for flexibility in modifications and could be more costly, without considerable benefit.
We appreciate the opportunity to comment on the proposed guidelines and hope you will consider them in your evaluation of the proposed guidelines. We also wish to thank the City of Pueblo for their informative comments.

This letter is being electronically mailed to you at windley@access-board.gov in addition to being sent via postal mail.

Cordially,

William J. O’Neil
City Engineer
ADA Coordinator

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