I am submitting to you the comments of the California Council of the Blind
regarding: DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY, Docket
Number: 02-1, Submitted: October 27, 2002, to be included in the docket record.

In Microsoft Word 2000 files, you will find attached the following:
1. CCB Resolution 96B-8
2. CCB Resolution 98B-7 Accessible Pedestrian Traffic Signals 3. CCB Resolution 2000A-11 Directional Curb Ramps and Curb Cuts 4. CCB Resolution 2000B-7 Detectable Warning Specifications 5. CCB Resolution 2001A-8 The Visibility of Marked Pedestrian Crossings 6. CCB Resolution 2001B-5 Accessible Pedestrian Signals Minimum Standards 7. CCB Resolution 2001B-9 Installation of Sidewalks and Their Separation from Bicycle Lanes 8. California Council of the Blind's comments on Public Rights-of-Way Guidelines June 17, 2002

If there is any questions regarding this submittal, I can be reached at [...].

Respectfully,

Eugene Lozano, Jr., Chair
Committee on Access and Transportation
California Council of the Blind, Inc.
EXECUTIVE OFFICES

California Council of the Blind

Resolution 96B-8


WHEREAS, there exists a trend to construct corners, sidewalks, and bus-stop pads, either without curbs or with rolled/rounded curbs; and

WHEREAS, this trend is promoted primarily by persons with mobility-limiting
disabilities for reasons of increased access, as well as by architects who view this design as esthetically pleasing; and

WHEREAS, the absence of curbs or the presence of rolled/rounded curbs presents serious hazards for pedestrians, and especially for blind and visually impaired pedestrians; and

WHEREAS, the presence of vertical/squared-faced curbs decreases significantly the serious hazards found at curbless or rolled/rounded curb locations, while at the same time vertical/squared-faced curbs provide a cue with which a blind or visually impaired person may align when crossing a vehicular way; Now therefore

BE IT RESOLVED, by the California Council of the Blind, in convention assembled this 24th day of November, 1996, in the city of San Diego, California, that this organization support the use of vertical/squared-faced curbs at corners, sidewalks, and bus-stop pads adjoining vehicular ways, such as intersections, streets, or parking lots with curb ramps, in accordance with federal, state, or local accessibility standards and local building codes, except in cases where building officials can show that there is a demonstrated need for the use of curbless
corners, sidewalks, bus-stop pads, or walking surfaces which are not separated by railings, planters, or other elements between the pedestrian areas and the vehicular areas, so long as, in such cases, the boundary between these areas is defined by a continuous detectable warning which complies with Title 24 of the California Code of Regulations, and

BE IT FURTHER RESOLVED that this organization and its chapters advocate for the inclusion in building codes and regulations of vertical/squared-faced curb requirements at corners, sidewalks, bus-stop pads, and other appropriate walking surfaces, and

BE IT FURTHER RESOLVED that this organization oppose, by any means necessary, efforts which may compromise the safety and independent travel of blind or visually impaired pedestrians in their access to corners, sidewalks, bus-stop pads, and other walking surfaces.
 

Resolution 98B-7
Accessible Pedestrian Traffic Signals

WHEREAS, it is becoming increasingly common for entities in this state and throughout the country, when installing audible and other accessible pedestrian traffic signals, not to place a signal at every comer of an intersection where a pedestrian crossing can be made; and

WHEREAS, this practice violates the spirit of full accessibility; and

WHEREAS, more importantly, the failure to install an accessible pedestrian traffic signal at each comer of an intersection at which a pedestrian crossing can be made leads to confusion, thus creating serious safety concerns; and

WHEREAS, this failure may also create liability problems for public entities, now,
THEREFORE, BE IT

RESOLVED, by the California Council of the Blind, in convention assembled this 8th day of November, 1998, in the city of Ontario, California, that this organization urge the California Traffic Control Devices Committee and the California Department of Transportation to amend guidelines contained in the California Department of Transportation traffic manual to require that, at any intersection at which an audible pedestrian traffic signal is installed, a signal be placed on each comer at which a pedestrian crossing can be made, and BE IT FURTHER

RESOLVED, that the president of this organization transmit a copy of this resolution to the U.S. Department of Transportation/Federal Highway Administration's, Bicycle and Pedestrian Guidelines Committee, the National Committee to Revise the Manual on Uniform Traffic Devices, and the American Council of the Blind, in order to pursue the adoption of similar guidelines on
the national level.
 

Resolution 2000 A 11 Directional Curb Ramps and Curb Cuts

Whereas, for more than two decades federal and state accessibility standards have mandated the installation of curb ramps and curb cuts at street crossings as part of new construction and alterations; and
Whereas, these accessibility standards have never clearly addressed the orientation of these curb ramps and curb cuts at street crossings; and
Whereas, this failure has frequently resulted in the construction of curb ramps and curb cuts on opposite corners or pedestrian islands that are either not in alignment or not in the intended path of travel; and
Whereas, these practices create access barriers and severe safety hazards for pedestrians with disabilities, and specifically those with visual impairments; and
WHEREAS, these dangers include, (1) a pedestrian with a disability using curb ramps must enter the intersection between perpendicular crosswalks, making them vulnerable to turning traffic while trying to get into one of the crosswalks,
(2) after entering the intersection within the crosswalk, a pedestrian with a disabilities using curb ramps must exit the intersection by leaving the crosswalk to go around the corner within a turn lane to access the only available curb ramp, and
(3) when entering an intersection, a blind or visually impaired pedestrian can easily miss the opposite intended curb and be within moving traffic; and
Whereas, field experience has shown that when curb ramps and curb cuts at opposite corners or pedestrian islands are in alignment within the intended path of travel, they provide greater access and safety for all pedestrians; and
Whereas, field experience has also demonstrated that properly oriented curb ramps and curb cuts have become reliable and effective directional aids in aligning blind and visually impaired travelers with the intended path of travel; and
Whereas, the practice of properly orienting curb ramps and curb cuts fulfills the spirit of full accessibility and safety and may also reduce liability problems for public entities; and
Whereas, these issues are currently being discussed by members of the Public Rights of Way Access Advisory Committee of the Architectural and Transportation Barriers Compliance Board, now therefore, BE IT

RESOLVED, by the California Council of the Blind, in convention assembled this 21st day of May, 2000, in the city of Sacramento, California, that this organization urge the Architectural and Transportation Barriers Compliance Board, and the California Division of the State Architect Access Compliance Program to amend accessibility standards to require that, to the extent technically feasible, there be two curb ramps on each corner at which curb ramps are installed and that all curb ramps and curb cuts on opposite corners and pedestrian islands be in alignment and within the intended path of travel, and be it further
RESOLVED, that a copy of this resolution be submitted to the American Council of the Blind for consideration at its 2000 annual convention.
 

Resolution 2000B-7 Detectable Warning Specifications

Whereas, the California Council of the Blind has long advocated for detectable warning surfaces adjacent to hazardous areas; and

Whereas, reports and research studies sponsored by the US Architectural and Transportation Compliance Board (Access Board), the US Department of Transportation, and Project Action agree that where a curb ramp or level curb pedestrian way exist, a detectable warning strip must be placed immediately adjacent to the vehicular way in order to indicate, for persons who are blind or visually impaired, the precise location of the danger; and

Whereas, some of this work has shown the value of detectable warnings having the following surface characteristics: 70% color contrast from the adjoining walking surface, safety yellow, resiliency, sound difference from the adjoining walking surface, and the alignment of truncated domes on a square grid; and

Whereas, the need has been demonstrated for a depth of 36 inches of detectable warning surface in order to ensure underfoot detection when a blind or visually impaired person approaches a level surface; and

Whereas, the Access Board's Public Right of Way Access Advisory Committee is currently considering the reintroduction into the American's With Disabilities Act Accessibility Guidelines (ADAAG) of detectable warning surface requirements for curb ramps, curb cuts, track crossings, hazardous vehicular areas, and reflecting pools, now, therefore, be it

Resolved, by the California Council of the Blind in convention assembled this 5th day of November, 2000, in the city of Los Angeles, that this organization advocate for the following standards:
(1) The need for detectable warning surfaces at all curb ramps and curb cuts, regardless of slope, track crossings, hazardous vehicular areas, and reflecting pools.

(2) The detectable warning surface at such locations shall extend the full width of the demarcation of the hazardous area, and shall have a depth of 36 inches (914mm's) from the edge of the hazardous area.

(3) The detectable warning surface shall have the following features:
(a) The detectable warning surface shall consist of a durable, slip-resistant material, having a surface texture composed of an alignment pattern of raised, truncated
domes, on a square grid with a diameter of 0.9 inches (22.88mm's) at the base, tapering to 0.45 inches (11.4 mm's) at the top, and a height of nominal 0.2 inches (5.08mm's).


Page 2 Resolution 2000B-7 Detectable Warning Specifications continued


(b) The detectable warning surface shall have at least a 70% color contrast from the adjoining walking surfaces, either light on dark, or dark on light. The material used to provide contrast shall be an integral part of the walking surface. Warning surfaces shall differ from adjoining walking surfaces in resiliency or sound on cane contact. This surface shall be reserved for warning only.
(c) The color yellow shall conform to Federal Color No. 33538, as shown in table number 4 of standard number 595B. Where the color value contrast between the yellow warning and the main walking surface is less than 70%, at least a 2 inch wide (50mm's) black strip shall separate the yellow warning from the main walking surface. Contrast shall be determined by applying the following formula: Contrast = [(B1-B2/B1)] 100% where B1 = light reflectance value (LRV) of the lighter area and B2 = light reflectance value (LRV) of the darker area.

 

Resolution 2001A-8 The Visibility of Marked Pedestrian Crossings

Whereas, marked crossings are of particular use as visual guides to pedestrians with low vision and are of greatest assistance at irregular intersections and mid-block crossings; and

Whereas, both The Manual on Uniform Traffic Control Devices (MUTCD) published by the Federal Highway Administration (FHWA) and the California Department of Transportation (Cal Trans) Traffic Manual require that when crosswalk lines are installed, they shall be solid white lines, marking both edges of the crosswalk, except that the Cal Trans manual requires that, in the case of school crossings, the outside edges be outlined with safety yellow crosswalk lines, and

Whereas, many urban street crossings are, however, beginning to be delineated in brick or other unit paving materials, particularly where design standards have been developed for an historic district or other significant area; and

Whereas, these street crossings utilizing brick or other unit paving materials have been found by pedestrians with low vision to be difficult to visually distinguish from the adjoining street surface; and

Whereas, when adjacent public sidewalks are similarly paved, it is difficult to distinguish between sidewalk areas and street crossings, particularly if non-raised sidewalks have been installed in lieu of well-defined sidewalk curb ramps, and

Whereas, in addition, colors used in brick or unit paving materials cannot be easily distinguished by persons with color blindness, and

Whereas, it is essential to use markings with a strong visual contrast, both between sidewalk surfaces and crossings and between street surface and crosswalk lines, now therefore, be it

Resolved, by the California Council of the Blind, in convention assembled this 22nd day of April, 2001, in the city of Sacramento, California, that this organization urge the California Department of Transportation and local Public Works Departments to cease installing street crossings that are delineated in brick or other unit paving materials, and be it further

Resolved, that when the California Department of Transportation or a local Public Works Department decides to install street crossings that are delineated in brick or other unit paving materials in historic districts or other significant areas that their edges shall be marked with white crosswalk lines except if they are at school crossings, which requires the use of safety yellow crosswalk lines.
 

Resolution 2001B-5
Accessible Pedestrian Signals Minimum Standards

WHEREAS, the California Council of the Blind (CCB) has, for many years, advocated strongly for the use of accessible pedestrian signals, and has been a leader in providing advice on the most appropriate standards to govern their use and installation; and
WHEREAS, subsequent to the adoption of accessible pedestrian signals standards in the Federal Highway Administration (FHWA) Manual on Uniform Traffic Control Devices 2000 millennium edition, as well as accessible pedestrian signals recommendations January 10, 2001 by the Public Rights-of-Way Access Advisory Committee (PROWAAC) of the Federal Access Board, the California Traffic Control Devices Committee is examining the extent to which changes should be made in the audible pedestrian signals guidelines contained in the California Traffic Manual; and
WHEREAS, the CCB, pursuant to Resolution 2001A-1, expressed its view that neither the FHWA standards nor the PROWAAC recommendations were wholly satisfactory, and that California should not, in adopting changes to its guidelines, accept the totality of either federal document; and
WHEREAS, the CCB, at the behest of the California Traffic Control Devices Committee (CTCDC), is providing input on proposed changes to the aforementioned manual, NOW, THEREFORE, BE IT
RESOLVED, by the California Council of the Blind, in convention assembled this 4th day of November 2001, in the city of Los Angeles, California that this organization urge the California Traffic Control Devices Committee (CTCDC) to include all of the following requirements in the California Traffic Manual:
(1) Whenever the state or a local jurisdiction is evaluating the desirability of placing accessible pedestrian signals at a specific existing signalized location, the professional to be consulted in this matter shall be an orientation and mobility instructor certified by the Academy for Certification of Vision Rehabilitation and Education Professionals (ACVREP);
(2) The state or a local jurisdiction shall not require or request that organizations who represent pedestrians who have disabilities and other community organizations be in agreement that there is a widespread community demand for the installation of an accessible pedestrian signal at a specific existing signalized location;

Whenever the state or a local jurisdiction is installing a new, or upgrading an existing traffic signal, the signal shall be automatically equipped with accessible pedestrian signals;
(3) The following minimum features requirements shall apply to all accessible pedestrian signals (including overhead devices) that are installed in the state:
(a) All accessible pedestrian signals must have an auditory tone to announce the walk interval. Until ongoing research has been concluded, the auditory tones shall be limited to two options, either a Cuckoo walk sound for a crosswalk in the North-South direction and a Peep-Peep walk sound for a crosswalk in the East-West direction (the closest proximity to these compass directions) or verbal messages to communicate the walk interval that provides a clear message that the walk interval is in effect, as well as to which crossing it applies.
(b) All accessible pedestrian signals must have vibrotactile devices to indicate both that the walk interval is in effect and to which direction it applies, through the use of a vibrating directional arrow or some other means;
(c) All accessible pedestrian signals must have a pedestrian push button with a locator tone;
(d) All audible tones and locator tones must automatically adjust in volume in relation to the ambient noise level;
(e) Activation of the pedestrian traffic signal shall simultaneously activate the accessible pedestrian signal;
(f) All Pedestrian push buttons that activate an accessible pedestrian signal must be marked with a universal tactile and visual symbol that identifies that there is an accessible pedestrian signal at the crossing, and BE IT FURTHER
RESOLVED that these standards not prohibit the state or a local jurisdiction from providing additional accessible pedestrian signal features if requested by organizations who represent pedestrians who have disabilities, other community organizations, and/or individuals, and BE IT FURTHER
RESOLVED, that this organization transmit a copy of this resolution to the Federal Access Board for use in its consideration of future guidelines on this subject, and BE IT FURTHER
RESOLVED, that this organization transmit a copy of this resolution to the American Council of the Blind for consideration by the ACB Board of Directors or at the 2002 ACB Convention.
 

Resolution 2001B-09
Installation of Sidewalks and Their Separation from Bicycle Lanes

WHEREAS, the public is entitled to access in public rights-of-way; and

WHEREAS, many miles of public rights-of-way in the United States have been
developed in such a way that only motor vehicular access is provided; and

WHEREAS, neither the Americans with Disabilities Act nor any other federal, state, or local law requires jurisdictions to provide sidewalks or bicycle lanes; and

WHEREAS, both pedestrians and bicyclists are entitled to their fair share of the public right-of-way; and

WHEREAS, due to the significant speed differential between bicycles and pedestrians, the physical separation of sidewalks from bicycle lanes, including those located on bridges, are necessary for safety and access for all; NOW, THEREFORE BE IT

RESOLVED by the California Council of the Blind, in convention assembled this 4th day of November 2001, in the city of Los Angeles, California that this organization recommend that the Federal Access Board, the United States Department of Transportation, the United States Department of Justice, the California Department of Transportation, and the Division of the State Architect require that, whenever a road or bridge is constructed or reconstructed in a public right-of-way in an urbanized area, sidewalks shall, unless technically infeasible, be included, with these sidewalks to be physically separated from bicycle lanes and roadways, and BE IT FURTHER,

RESOLVED, that the California Council of the Blind and its local chapters work closely with pedestrian, transportation, and bicycle advocacy organizations in order to support the physical separation of bicycle from pedestrian facilities and the adequate provision of both types of facilities by prioritizing their construction ahead of the construction of automobile facilities, and to ensure that bicycle and pedestrian facilities are constructed at the appropriate width, and BE IT FURTHER

RESOLVED, that this organization transmit a copy of this resolution to the Federal Access Board for use in its consideration of future guidelines on this subject, and BE IT FURTHER

RESOLVED, that this organization transmit a copy of this resolution to the American Council of the Blind for consideration by the ACB Board of Directors or at the 2002 ACB Convention.
 

Eugene Lozano, Jr., Chair
Committee on Access and Transportation
California Council of the Blind
EXECUTIVE OFFICES

COMMENTS OF THE CALIFORNIA COUNCIL OF THE BLIND
Regarding: DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY
Docket Number: 02-1
Submitted: October 27, 2002
Submitted by: Eugene Lozano, Jr., Chair, Committee on Access and Transportation, California Council of the Blind

The California Council of the Blind (CCB) is pleased to submit the following comments on the Draft Guidelines for Accessible Public Rights-Of-Way, which were issued on June 17, 2002.

The CCB, a state affiliate of the American Council of the Blind (ACB), is a statewide membership organization. Its members are blind, visually impaired and fully sighted individuals who are concerned about the dignity and well-being of blind and visually impaired people throughout the state. Formed in 1934, the Council has become the largest organization of people who are blind or visually impaired in the state of California, with over 50 chapters and special interest affiliates and a membership of over 3,000.

Through a variety of programs and services, CCB enables people who are blind or visually impaired to live and work independently and to participate in their own communities. The Council has influenced change in such areas and issues as civil rights, employment, rehabilitation, transportation, environmental access, travel, recreation, Social Security, and other benefits. To strengthen advocacy efforts, the Council often works in coalition with other state disability groups.

On behalf of the CCB, I wish to express our support to the recommendations contained in this draft. These guidelines are vital to insure that persons with disabilities have an equal opportunity to participate in their community. In the text that follows, we will highlight some of the proposals which we believe have the greatest impact on pedestrians who are physically disabled, blind or visually impaired, and provide our comments, amendments, and recommendations thereon.

In our comments, any language that is to be added will be underlined and in bold text and any language to be deleted will have a strike out through the text.

1. Section 1102.3. Alternate Circulation Path. The proposed guideline requires an alternate circulation path whenever the existing sidewalk is
blocked by construction, alteration, maintenance or other temporary conditions. This will insure that people with disabilities will not be denied access to the public sidewalks for the duration of the construction project, which can last for years.

2. Section 1102.10. Stairs. The proposal to require a 2-inch visually contrasting strip along each tread nosing is very important for persons with visual impairments, particularly those with little or no depth perception. This section needs to be amended as follows: "Where provided, stairs shall comply with 504. The upper approach as well as all stair treads shall have be clearly marked with a 2-inch (51 mm) wide strip of color contrasting with the tread and riser, dark on light or light on dark, the full width of the front edge of each tread."

The upper approach is not a stair tread and it is essential that its nosing be seen before someone begins to decent a stairway. Also, light/dark contrast is the important feature followed by the color hue. There are persons with eye conditions such as macular degeneration, which have the color blindness in the areas of red and green, but can see safety yellow. Therefore, they must rely on the contrast between the stripping material from the materials that make up the upper approach and the individual traits of the stairway.

As stated by many studies (Rodstein, M., "Accidents Among the Aged: Incidence, Causes, and Prevention," Journal of Chronic Disease, 1964, 7: 515-526; Sekuler, R., Hutman, L.P., and Owsley, C. J., "Human Aging and Spatial Vision," Science, September 1980, 209(4462) : 1255-1256; Pauls, J.L., "What Can We Do to Improve Stair Safety," Building Standards, May-June 1994), stair falls are a cause of many serious injuries, and the largest category of these falls are caused by misjudging and overstepping the width of treads. Lori Sakamoto, O.D., and Edwin B. Mehr, O.D., in "A New Method of Stair Markings for he Visually Impaired," state that "Judging stair tread width requires that a traveler differentiate between the light and dark areas produced by the shadows of steps. This type of spatial discrimination depends upon contrast sensitivity. Decrease in contrast sensitivity is a normal age-related change. In the presence of ocular pathology there is an even greater problem with stair discrimination." Thus discerning where steps begin and end can be a problem for a great many people, including aging people with gradually deteriorating contrast sensitivity, as well as those officially considered "visually impaired."

It has been argued that all that is required to alleviate this problem is adequate lighting. This is a drastic over simplification, as Dr. Samuel Genensky, O.D. and founder of the Center for the Partially Sighted, which was originally established in Santa Monica, California, and is now in Los Angeles, discussed in his May 6, 1992 comments on proposed ANSI A 117.1 Regulations for the Marking of Steps and Stairs 4.9.9: "...steps and stairs can only be illuminated so as to cast shadows that reveal their presence if the artificial illumination is placed very precisely so as to produce the required shadows. Unfortunately, the positioning of artificial illumination to achieve this effect is not very practical, and could prove to be counter-productive." This specific type of lighting is very different, he explains, from the generic, overall lighting usually used to illuminate spaces in buildings. "To require that builders and building owners provide illumination for the steps and stairs in addition to the illumination of the broader areas when the illumination of the broader areas illuminates the stairs adequately, is both costly and unjust, especially when one realizes that the marking of the stairs...coupled with the overall room and/or hall lighting will accomplish the task to everyone's satisfaction and safety." Furthermore, the lighting problem is even more complex where outside stairs are concerned. "In the case of steps and stairs that in the daytime depend n illumination from the sky or sun, the presence or absence of shadows cast by the steps or stairs changes from hour to hour depending on the position of the sun and on the light provided by the sky."

Stair markings are already required by several different sets of regulations, including the California Building Code (Part 2, Title 24, CCR), section 1133B.4.4 Striping for the visually impaired, July 1999 (this requirement has been in the California Building Code since 1981), and the National Fire Protection Association, Inc.'s "Code for Safety of Life from Fire in Buildings and Structures," Section 8-2.5.6.9(g), 1988. These precedents for this section argue for its validity.

As a personal note, when I was a visually impaired pedestrian growing up in san Francisco, I found that the stripping on the exterior stairs rather than grooves was the most effective way for me to distinguish the upper approach and all treads of stairs. It was not uncommon to find on some of the steeper hills in the city that there were some steps incorporated into the sidewalk (some were very steep), and there were some occasions I came close to falling down them when they were not marked, particularly when it was dark.

Now as a totally blind pedestrian, I still support stair strippings, but would like to see that on the upper approach of each flight of steps, there be a safety yellow colored detectable warning surface set back the depth of one stair tread to alert me of the potential hazard of a series of stairs, which is in the public right of way.

3. Section 1102.12. Vertical Access. The proposal to require that vertical access elevators and lifts remain unlocked is vital for persons with disabilities, who cannot use stairways. This will insure that access to the disabled is as readily available as it to the general public. Experience has shown that locked elevators and lifts in effect deny access to persons with disabilities.

4. Section 1102.13 Bus Stops. "Bus boarding and alighting areas shall comply with 810.2. ..." The CCB requests this section and section 810.2 be amended to require that all newly constructed or altered bus stop pads be required to be raised, to have a minimum 6 inch type 2 curb (vertical/squared-faced), and to be on a pedestrian access route making them more accessible and safer for seniors, persons with ambulatory physical disabilities, and persons who are blind or visually impaired. There are two major problems with the current bus stop pads specifications because they do not address whether the pad is to be raised or not. 1) Seniors and persons with ambulatory physical disabilities quite often have the problem of bridging the vertical and horizontal gap that exists between the bus stop pad and the first step of a transit vehicle with or without kneeling capacity. When the bus stop pad is at grate level, the vertical gap between it and the first step of the bus often exceeds 7 inches in height, which can be a physical challenge for many individuals who have limited use of their lower extremities when trying to raise their feet high enough to alight the vehicle. If the pad was raised a minimum 6 inches above grate, the vertical gap would be significantly reduced making the transit vehicle more accessible to these individuals. Additionally, by requiring that the raised pad have a type 2 curb (vertical/squared-faced) rather than a type 1 or 1A curb (rolled), the transit vehicle can move in closer to the bus stop pad, which would significantly reduce the horizontal gap that must be bridged by persons with limited use of their lower extremities. 2) When bus stop pads are at grate level, there is no way for a person who is blind or visually impaired to know where they can safely stand so to avoid being hit by the incoming transit vehicle and/or other moving vehicular traffic. On the other hand, the raised pad provides a clear demarcation as to where the pad stops and the vehicular way begins. Also, the vertical curb reduces the potential of an incoming transit vehicle from entering a bus stop pad area and striking awaiting pedestrian.

Therefore, we request that these sections be amended to require bus stop pads to be raised with a minimum 6 inch type 2 curb (vertical/squared-faced) and to be placed on a pedestrian access route. If for unknown reasons, the Access Board feels that it is necessary not to address the grate level issue, then the bus stop pads must be required to have detectable warning surfaces that are in compliance with section 1108 to alert persons who are blind or visually impaired of the boundary separating the bus stop pad from the vehicular way.

Please refer to the attached CCB Resolution 96B-8.

5. Section 1102.14. On-Street Parking. The proposed requirement that at least one accessible on-street parking space be provided for each block face is absolutely necessary to insure that persons with disabilities are able to have equal access to on street parking.

6. Section 1103.7.1 Detectable Warnings. The proposed guideline is essential to ensure where rail systems cross pedestrian facilities that are not shared with vehicular ways that detectable warning surfaces be installed on both sides of the track(s) so to alert a person who is blind or visually impaired that they are entering a potentially hazardous situation.

7. Section 1103.8. Changes in Level. Requiring that changes in level can not occur more frequently than every 30 inches is critically important and will insure that designers and builders will not use the allowed changes in level to occur every few inches in order to avoid building ramps.

8. Section 1104.3.2. Detectable Warnings. The proposed guideline to require Detectable Warnings or truncated domes at all curb ramps regardless as to their slopes is vitally important to persons who are blind or visually impaired. Truncated domes are necessary to insure that persons with visual impairments are able to detect where the sidewalk stops and the street begins. Research has been conducted which addresses concerns about safety of detectable warnings, indicating that detectable warning on slopes and on generally horizontal surfaces have minimal impact on the safety and ease of travel for persons having physical disabilities (Bentzen, B., Nolin, T., Easton, R., Desmaris, P., and Mitchell, P., 1994; Hauger, et al, 1996). By requiring that the truncated domes be in a line and widely spaced pattern, wheelchair users will be able to wheel across the domes without difficulty.

The ATBCB has concluded research demonstrating the need for detectable warnings and their effectiveness for persons having visually impairments and their potential benefit also for persons having physical disabilities (Hauger et al. 1996); the original requirement was suspended pending the conduct of this research.

Additional research by Bentzen and Barlow (Impact of curb ramps on the safety of persons who are blind, Journal of Visual Impairment and Blindness 89, 319-328) found that on 35% of approaches to unfamiliar intersections via curb ramps (without detectable warnings), experienced blind travelers stepped into the street before they realized they were in the street. Moreover, on 59% of those approaches, there was traffic on the street into which they stepped. A very high level of risk. Moreover, failure to detect streets was very highly correlated with slope of curb ramp, with more failures to detect the street occurring when the slope was minimal.

Bentzen and Barlow's research substantiates the need for detectable warnings on all curb ramps regardless of their slope and would refute the argument to restrict the use of detectable warnings on curb ramps with the slope of 1 unit vertical to 15 units horizontal or less.

The proponent of restricting the detectable warning surfaces to such a gradual slope is citing the California Code of Regulations, Title 24 Accessibility Standards section 1127B.5 (8) 1999 edition without knowing any of the background history, which established the 1 unit vertical to 15 units horizontal or less limitation for detectable warnings on curb ramps in the state of California.

This requirement was originally established in 1994 by the Office of the State Architect (OSA), now the Division of the State Architect (DSA), to provide some degree of safety for persons who are blind or visually impaired when negotiating curb ramps. The ADAAG requirement for detectable warning had been suspended, but the danger still existed for persons who are blind or visually impaired when negotiating curb ramps. Therefore, Jud Boies, Chief, OSA made an arbitrate decision with no research backing to propose a regulation to limit the installation of detectable warning surfaces on those curb ramps with a slope of 1 unit vertical to 15 units horizontal or less so to reduce some, but not all of the danger faced by blind or visually impaired pedestrians. He felt that it would be irresponsible to know of the danger, and not to address the issue while waiting for research to be performed, which might take many years.

Through formal public hearings, Mr. Boies took the proposed regulation to the California Disability Community and requested input from its members. The members of the Disability Community felt that the safety of blind and visually impaired pedestrians was a paramount issue that needed to be addressed immediately. Also, they felt that Mr. Boies' proposed regulation was the best compromise that could be achieved while waiting for the federal government to sponsor research on the Detectability of Detectable Warnings by Individuals with Visual Impairments, and the Safety and Negotiability on Slopes for Persons with Physical Disabilities.

As it can be seen there is no scientific research to support a limitation of detectable warning surfaces on curb ramps with the slope of 1 unit vertical to 15 units horizontal or less. Rather, there is research that substantiates the need for detectable warning surfaces on all curb ramps regardless of their slope.

Please refer to the attached CCB Resolution 2000B-7 Detectable Warning Specifications.

9. There needs to be created a section 1104.3.8 "Non-shared Curb Ramps." These proposed guidelines fail to clearly address the problems of shared curb ramps by not requiring there be a ramp for each crossing at a corner. The orientation of curb ramps toward the center of an intersection can be disorienting for pedestrians who are blind or visually impaired. In addition, they require an extra turn for wheelchair users. We believe that the guidelines need to encourage orientation of the ramp in the direction of travel along the direction of the crosswalk. The public right-of-way access advisory committee addressed this issue in the "Building a True Community Final Report Public Rights-of-Way Access Advisory Committee" page 80 under heading "Discussion" and made several recommendations, which do not appear to have been incorporated into these draft guidelines.

CCB feels it is vital for the Access Board to address the issue of providing separate curb ramps at corners in these draft guidelines so to ensure greater safety and orientation assistance to persons with disabilities, particularly those with visual impairments.

Please refer to the attached CCB resolution 2000 A-11 Directional Curb Ramps and Curb Cuts.

10. Section 1105.2 Crosswalks. The proposal to require that marked crosswalks have a width of 96 inches (2440 mm) minimum, that the cross slope shall be 1:48 or 2.08 percent maximum measured perpendicular to the direction of pedestrian travel, and that the running slope shall be 1:20 maximum measured parallel to the direction of pedestrian travel in the crosswalk are critical to insuring that people with disabilities can cross vehicular ways safely, quickly and without physical injuries.

Section 1105.2 needs to be amended to have a section 1105.2.4 that requires that the crosswalk markings be a clearly contrasting color from the road pavement and the sidewalk such as white as required in the Manual on Uniform Traffic Control Devices. Further, the proposed section that the state and local jurisdictions be prohibited from installing street crossings that are delineated in brick or other unit paving materials, and furthermore, when these governmental entities decide to install street crossings that are delineated in brick or other unit paving materials in historic districts or other significant areas that their edges shall be marked with white crosswalk lines.

Persons with visual impairments use the crosswalk markings as a visual guide to make street crossings because of the high visibility of the white color. When traffic engineers use street crossings that are delineated in brick or other unit paving materials with red and other non-clearly contrasting color, access and safety are diminished for persons with visual impairments.

Please refer to attached CCB Resolution 2001A-8 The Visibility of Marked Pedestrian Crossings.

11. Section 1105.4 Medians and Pedestrian Refuge Islands. It is essential to persons who are blind or visually impaired that 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. These edges provide a directional orientation reference point for persons who are blind or visually impaired when starting to make a crossing to the opposite intended corner. The cut-through edges when not in alignment with the crosswalk marking can potentially orient the blind or visually impaired pedestrian into oncoming traffic as well as to exacerbate the veering problem they face when trying to make a street crossing (Guth, D. and LaDuke, R., "The Veering Tendency of Blind Pedestrians: An Analysis of the Problem and Literature Review," Journal of Visual Impairment and Blindness, 1994, 391-400; Guth, D. and LaDuke, R., "Veering by Blind Pedestrians: Individual Differences and Their Implications for Instruction," Journal of Visual Impairment and Blindness, 1995, 28-37).

12. The proposed section 1105.4.2 Detectable Warnings guideline that requires Detectable Warnings/truncated domes at cut-throughs and curb ramps at medians and pedestrian refuge islands is vitally important to persons who are blind or visually impaired. Detectable warnings are necessary to insure that persons who are blind or visually impaired are able to detect where the medians and pedestrian refuge islands stops and the street begins.

However, the exception must be deleted. Detectable warnings inform the pedestrian who is blind or visually impaired about the presence of a cut-through island or median. They should be required at all medians and islands. Although the pedestrian may not need to stop at that location when the signal timing is adequate for a full crossing, slower pedestrians may prefer to stop and wait, if they know the refuge exists. In the absence of an APS, blind or visually impaired pedestrians frequently begin crossing during the clearance interval because of the difficulty of determining the exact onset of the walk interval, and the resulting inability to "claim" the crosswalk before vehicles turning across the crosswalk. Hence, these pedestrians may have insufficient time to cross the street. Denying these pedestrians the information that they have a safe refuge constitutes discrimination and endangers the life safety of pedestrians who are blind or visually impaired in such situations. Even in the presence of APS, because they are unable to make eye contact with drivers, pedestrians with visual impairments have difficulty claiming the crosswalk during the walk interval, and may be delayed in starting crossings relative to sighted pedestrians.

In addition, contacting the side edge unexpectedly when traveling within the cut-through section of the median can be disorienting and confusing if pedestrians do not realize they are within a median area. The detectable warning provides the pedestrian with information about the location of the cut-through refuge area.
By requiring that the detectable warning domes be in a line and widely spaced pattern, wheelchair users will be able to wheel across the domes without difficulty.

13. Section 1105.5.3. Overpass and Underpass Approach. Requiring an elevator to provide accessibility where sidewalks cross overpasses and underpasses that create a rise in the sidewalk greater than five feet is essential to insure that people with disabilities will not be barred from using the sidewalks by the difficulty in ascending more than five feet. Most people with mobility disabilities do not have the stamina to ascend more than five feet at a time.

14. Section 1105.6.1. Separation. Requiring a continuous barrier e.g., railing along the street side of the sidewalk where people will be precluded from inadvertently entering the vehicular way in "roundabouts" is one of the essential cues of notifying/guiding persons who are blind and visually impaired where to locate and to make a street crossing. However, it is unclear what a continuous barrier is, except for a railing and should be clarified in this section. Therefore, the CCB recommends the deletion of the word “barriers” and replace it with “landscaping separation or railings” so that the text will read as follows, “Continuous barriers landscaping separation or railings shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited. When railings are used, they shall have a bottom rail 15 inches (380 mm) maximum above the pedestrian access route.”

15. Section 1105.6.2 Signals. CCB concurs with the Access Board’s recommendation that pedestrian activated traffic signals complying with 1106 be provided for each segment of the crosswalk, including splitter island, as indicated in 1105.6.2. When traffic sound cues are absent or unpredictable, information can be insufficient to locate the crosswalk and for determining the onset of the walk interval, especially at a roundabout.

When traffic signals and stop signs regulate traffic movements at intersections, the resulting breaks in traffic flow usually provide identifiable and predictable periods - gaps - during which pedestrians can cross. Such predictable breaks do not usually occur at roundabouts, and so pedestrians must make judgments about the speed and travel paths of approaching vehicles (and the duration of gaps between vehicles). The selection of appropriate gaps at roundabouts is problematic for most persons who are blind or visually impaired.

Traffic sounds at roundabouts can provide ambiguous cues whether circulating vehicles will exit or continue around the circulatory roadway or to know when it is appropriate time to cross.

Therefore, the requirement for the use of accessible pedestrian activated traffic signals at roundabouts appears to be the only feasible means of giving blind and visually impaired pedestrians safe access to the crosswalks at roundabouts, while causing a minimal interference with the flow of traffic on the roundabout. Further, it is important that at these intersections, as well as at those intersections where a pedestrian crosswalk is provided at a right or left turn slip lane, an accessible pedestrian activated traffic signal that complies with 1106 is provided for each segment of the pedestrian crosswalk, including the island.

16. Section 1105.7 Turn Lanes and Intersections. CCB concurs with the Access Board’s recommendation that 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.

17. Section 1106.1 General. The CCB feels it is essential for the safety of persons with disabilities, especially those with visual impairments and/or hearing loss that this section and all its subparts be adopted. Requiring audible and vibrotactile indications of the WALK interval as well as locator tones at signalized intersections provides the same opportunities and safety provided for the general public. Lack of audible/vibrotactile indicators with locator tones where the general public is provided signalized intersections is program access discrimination under title 2 of the ADA and section 504 of the Rehabilitation Act of 1973 because this precludes persons with visual impairments and/or hearing losses from the full and equal use of the public right of way.

Further, we agree with the Access Board that care should be exercised in the location of pedestrian push buttons to insure that, to the maximum extent feasible, push buttons for accessible pedestrian signals will be positioned where they can be located and activated by the pedestrian while leaving sufficient opportunity for the pedestrian to reach the curb in time to respond to the walk interval indication. If the recommended guidelines are followed correctly, the accessible pedestrian signal systems will not be disruptive to the surrounding community. Therefore, we believe their benefits far outweigh the minimal impact they may have on the environment.

We would like to take this opportunity to share with you an unexpected benefit of the use of accessible pedestrian signal systems, which was given to the Sacramento County Disability Compliance Office on Wednesday, July 3, 2002 from Collette Guido, 2251 Watt Ave. #133, Sacramento, CA 95825. Her statement follows:

“-----Original Message-----
From: CGCheapSuit@aol.com [mailto:CGCheapSuit@aol.com]
Sent: Wednesday, July 03, 2002 2:16 PM
To: Bennett. Cheryl
Cc: CGCheapSuit@aol.com
Subject: RE: Disability Advisory Committee Meeting
I am e-mailing my address to the Board on 4/02/02 per Mike Wilkerson's request.
A message to the County Board of Supervisors: I have noticed at Butano St. and Watt Ave. a great improvement to the pedestrians' crossing with the sound of the chirping signal to assist the visually impaired. I live very near this crossing, however, I have a physical impairment, which requires a walker or wheel chair. When crossing I have observed that cars turn neither right or left while a pedestrian is on the crossing walk. As opposed to crossings without the sound, people have ignored myself and husband, still making the turns, during our crossing. I believe we could assist all pedestrians' with the sound of the chirping, it seems to capture the attention of the driver that a pedestrian is crossing and to wait until their all the way across before turning. I hope with all sincerity that we can install these devices to help save all the lives of persons' in our community, whether disabled or not. Thank-You for your consideration, Sincerely, Colette Guido”
We feel these guidelines are reasonably written regarding the manner in which visually impaired individuals should be able to effectively access information about signal phases, as well as street identification and intersection design. It is essential that accessible pedestrian signals convey information in a manner that is unambiguous and we believe these guidelines will accomplish this.

Please refer to the attached CCB Resolution 2001B-5 Accessible Pedestrian Signals Minimum Standards.

18. Section 1106.2 Pedestrian Signal Devices. CCB concurs with the Access Board’s recommendation that each crosswalk with pedestrian signal indication shall have a signal device, which includes audible and vibrotactile indications of the WALK interval. Without such a requirement, traffic engineers may decide not to fully equip all crosswalks at an intersection with accessible pedestrian signals based on the idea that it is not worth the investment of money and time for a small segment of the pedestrian population. The result of such action by traffic engineers are the violation of one civil rights to have full and equal access to a program that is available to all other pedestrians, a reduction in safety, and confusion as to where pedestrians can legally cross at an intersection.

Please refer to the attached CCB Resolution 98B-7 Accessible Pedestrian Traffic Signals.

19. Section 1106.2.3 Audible Walk Indication. CCB concurs with the Access Board’s recommendation that the audible indication of the WALK interval shall be by voice or tone. We feel the term “voice” clearly indicates that the message must consist of the full pronunciation of all vowels and such consonants as (b), (d), (g), (m), etc. It has been the experience of some of our members that digital speech/synthetic speech does not always provide an accurate reproduction of the full human voice, which results in uncertainty and confusion as to what has been said. The use of “JAWS” or “Window Eyes synthetic speech” is problematic for some persons with hearing loss or auditory perceptional processing learning disabilities because the speech is robotic and does not have all the richness of the human voice, which adds to the intelligibility of the message. On the other hand, the AT&T text to speech messaging capabilities, http://www.naturalvoices.att.com/demos/index.html provides a far superior representation of the human voice, which would be more intelligible to these individuals in the outdoor environment than would be the use of JAWS or Window Eyes synthetic speech. Therefore, it is our opinion until there is a criteria established for digital speech, the term “voice” needs to be used to clearly indicate there is to be accurate reproduction of the human voice contained within any message admitted by an accessible pedestrian signal.

Further, CCB recommends that this section be expanded to include recommendations for speech WALK messages, as well as push button informational message based on the work performed by Bentzen, B., Ph.D., Barlow, J., M.Ed., and Franck, L., M.Ed., Determining Recommended Language for Speech Messages used by Accessible Pedestrian Signals: Final Report, Accessible Design for the Blind, January 7, 2002.

20. Section 1106.2.3.1 Tones. CCB wishes to know what research was the basis for the proposed language, "The duration of the tone shall be 0.15 seconds and shall repeat at intervals of 0.15 seconds." We have been unsuccessful in locating the research, which would substantiate the effectiveness of this language. Additionally, we cannot find this specification in the Federal Highway Administration Manual on Uniform Traffic Control Devices, millennium edition December 2000.

21. Section 1106.3.1 Operation. CCB recommends that this section be amended as follows: “Pedestrian pushbuttons shall comply with 309.4. Activation of the pedestrian traffic signal shall simultaneously activate the accessible pedestrian signal.” This section needs to clarify that it is required that when a pedestrian signal is activated simultaneously, it is to communicate information about the pedestrian WALK phase in visual and non-visual formats. Not to provide this information simultaneously is program access discrimination under title 2 of the ADA and section 504 of the Rehabilitation Act of 1973 because this precludes persons with visual impairments and/or hearing losses from the full and equal use of the public right of way.

This amendment would ensure that section 1106.3.4 Optional Features can be implemented if the community has a desire for additional information to be provided e.g., street name, description of crossing, etc. by accessible pedestrian signals. If an extended button press is permitted to communicate information about the pedestrian WALK phase in non-visual format, it will preclude additional information to be provided without using a separate device with locator tone, which would add to the cost of making an intersection more accessible.

22. Section 1106.3.2 Locator Tone. CCB concurs with the Access Board’s recommendation for the use of locator tone as part of an accessible pedestrian signal. The locator tone alerts the blind or visually impaired pedestrian to the presence of the push button and the location of the corresponding crosswalk. In addition, as the locator tone becomes consistently incorporated into accessible pedestrian signal systems, the blind or visually impaired pedestrian will have the benefit of knowing that further accessible information is forthcoming as a result of his/her long press activation of the push button. Since these tones are only audible at close range, if the recommended guidelines are followed correctly, they will not be disruptive to the surrounding community.

23. Section 1108 Detectable Warning Surfaces. The requirement for detectable warnings at all curb ramps, blended transitions, track crossings, medians/pedestrian refuge islands, and platform edges is strongly supported by the CCB. There is no well-substantiated evidence in research or practice that detectable warning surfaces are barriers to pedestrians. There is, in fact, substantial evidence to the contrary. Research by Hauger, Rigby, Safewright and McAuley (Detectable warning Surfaces at Curb Ramps, Journal of Visual Impairment and Blindness 90:512-525, 1996), in a project sponsored by the US Architectural and Transportation Barriers Compliance Board, found that persons who travel using such aids as wheelchairs, canes, crutches and walkers generally preferred curb ramps with detectable warning surfaces over curb ramps surfaced with blushed concrete on four criteria, including effort, stability, traction and safety. Thus, the persons popularly perceived as being at most risk on detectable warnings as being easier to negotiate, providing more stability and traction, and generally feeling safer.

In the same project, 1,683 pedestrians, many of whom had shopping carts, and two of whom happened to be mobility impaired, were observed at three entrances to retail stores where detectable surfaces had been installed. There were no incidents of trips, slips or falls, and at two of the sites where it was possible to easily avoid traversing the detectable warning surface, only a small percentage of persons did not walk on the detectable warning surface. Those who did not walk on the detectable warning surfaces may have just been going in a slightly different direction to get to their destination by the shortest route. People were observed running and bicycling cross the detectable warning with no apparent concern.

Prior to installation of detectable warnings along Bay Area Rapid Transit (BART) platforms, BART installed detectable warnings at the entrance to a much-used elevator. This was a surface most pedestrians had not previously experienced and could not possibly have expected in such a location. All traffic in and out of the elevator was videotaped over a period of several months without incident or adverse comment (Personal communication, Ralph Weule, BART). Since the installation of detectable warnings on all platforms of BART there have been no individuals or groups who have complained to BART that their travel has been adversely affected by the presence of detectable warnings at platforms edges (Personal communication, Ralph Weule, BART). Furthermore, at locations where riders are transferring from a vehicle to a platform, crossing a small gap, and frequently negotiating a small level change BART's experience has been extremely positive with an approximate 70 % reduction in trackway falls by vision impaired patrons and an approximate 40 % reduction in trackway fall incidents overall, as well as an overall reduction in platform gap falls after detectable warning surfaces were installed (1994 APTA Annual Conference, BART Experience With Platform Edge Detection Tiles By Lee Cohen, Senior Safety Engineer).

In research by Bentzen, Nolin, Easton, Desmarais and Mitchell (Detectable Warnings: Detectability by individuals with visual impairments, and safety and negotiability on slopes for persons with physical impairments, US Department of Transportation, Volpe National Transportation Systems Center. Final Report DOT-VNTSC-FTA-94-4, 1994), 40 participants having a wide range of physical disabilities, who traveled either with no aid, aids having wheels (such as wheelchairs and scooters), or aids having tips (such as canes, crutches and walkers) traveled up and down 10, 4' x 6' ramps having a slope of 1:12 and surfaced with 9 different detectable warning materials or with brushed concrete. Participants were videotaped as they maneuvered up and down and turned on each ramp. Performance was rated by independent observers for effort and for stability going up and going down, and for wheel or tip slipping or entrapment (difficulty controlling or changing direction). On 88.5% of rated measures, performance on detectable warning surfaces was rated as equal to performance for that individual on the brushed concrete ramp. No participant was judged by an independent physical therapist who viewed the video tapes as being at serious risk as a result of the detectable warnings. Thirty-three of the 40 participants had few or no observable difficulties, and appeared to compensate quite well for difficulties they experienced on the detectable warning surfaces.

While off-street curb ramps, pedestrian islands, vehicular ways or porte-cochere or similar areas in front of adjacent to existing hotels, motels or restaurants are less highly traveled than the public right of way, and there is numerically less risk to persons who are unable to detect the limit of the pedestrian way. Nonetheless, in these situations persons who are visually impaired are at a high level of risk precisely because of slow moving traffic which does not provide consistent auditory clues regarding the limit of the pedestrian way. In addition, the frequency of backing traffic in such locations, typically automobiles which do not have an alerting backing up tone, makes traffic especially unpredictable to persons who are visually impaired who either by accident or by intent to cross the vehicular way, are in the vehicular way. Competent blind travelers, normally needing no assistance to cross most streets, driveways and track crossings, should not be subjected to the choice of facing exceptional risk or seeking, waiting for, and accepting help which they would not need if detectable warnings were provided to define the limit of the pedestrian way.

24. Section 1108.1.1 Dome Size. CCB feels the proposed standard allows too much latitude in the dimensions of the truncated domes. We feel a more definitive standard is essential to ensure the consistency/standardization of detectable warning truncated domes, which is needed for optimum underfoot detection.

We would like to propose substituting this section with the following language, “The detectable warning surface shall consist of a durable, slip-resistant material, having a surface texture composed of raised truncated domes aligned in a square grid pattern with a diameter of 0.9 inches (22.88mm's) at the base, tapering to 0.45 inches (11.4 mm's) at the top, and a height of 0.2 inches (5.08mm's). The 0.2 inch dome height shall be measured from the highest point on top of a dome to the highest point of the surface between the domes.”

For many years these dimensions have been in use in Japan, United States, the State of California, and experience to date indicates that surfaces comprised of domes having .9 inch base diameter and .45 inch top diameter, having up to 1.0 inch base-to-base separation, have not resulted in excessive complaints and have resulted in no liability litigation.

Our concern is by requiring dome dimensions of having a base diameter of up to a maximum 1.4 inches (36 mm), a top diameter of up to 65% of the base diameter maximum, with veering dome spacing could potentially result in a surface that will feel flat underfoot if the spacing is narrow. The truncated dome, which has a top diameter of 65% of the base diameter maximum will exert less pounds of pressure per square inch felt underneath the foot when compared to a top diameter of 50% of the base diameter, thus reducing the potential of detecting each of the individual dome. Allowing a specification that permits the top diameter to be 65% of the base diameter will result in a truncated dome having a profile that is almost vertical, which could increase the potential of tripping.

The additional specification we are proposing for measuring the truncated dome height is to ensure that a height of 0.2 inches (5 mm) is consistently maintain throughout the detectable warning surface regardless of the means for providing a slip resistant surface e.g., raised field dots. If this specification does not exist, field dots or equivalent in the area between truncated domes will reduce the dome height by their own height measurement, thus making the dome less detectable.

We would like to stress that uniformity and consistency are critical for an effective detectable warning surface. Therefore, it is crucial that strict language that specifies all dome size dimensions must be incorporated in this section and any associated figure to ensure that effective detectable warning surfaces are installed in the environment.

Please refer to the attached Resolution 2000B-7 Detectable Warning Specifications.

25. Section 1108.1.3 Contrast. We agree with this section and feel this section needs to be amended to require that there be at least a 70 percent contrast between the detectable warning surface and the adjoining walking surface. This Specification for at least a 70 percent contrast will ensure that the detectable warning surface is seen by all and from a distance.

Also, we would like to see this section to be amended to require that "the detectable warning surface be the color yellow conforming to Federal Color No. 33538, as shown in Table IV of Standard No. 595B. Where the color value contrast between the yellow warning and the main walking surface is less than 70 percent, a 2 inch-wide (50 mm) black strip shall separate the yellow warning from the main walking surface. Contrast shall be determined by: Contrast = [(B1-B2/B1)] 100 percent where B1 = light reflectance value (LRV) of the lighter area and B2 = light reflectance value (LRV) of the darker area." This color of yellow has been specified by the city of Roseville, California, the city of Sacramento, California, and the county of Sacramento for the detectable warning surfaces that they have installed within the last four years without any complaints regarding the ecstatic of the color.

There are several reasons for this choice of color. Physiologically, yellow is at the peak of the human photopic luminosity function, and thus is the color that appears brightest to the human eye. Yellow is quite distinctive in its color appearance, so that it is easily recognized. When used as a cautionary floor or other walking surface, yellow is likely to be distinct and easily differentiated from its immediate background. This is because yellow or colors close to it are rarely used for floors and other walking surfaces. Alternative warning markings, such as black or white, are more likely to loose conspicuousness against certain commonplace backgrounds, as walking surfaces are most commonly of neutral colors. Safety yellow is an unusual color to encounter in one's environment and almost invariably denotes risk and the need for caution.

The American National Standards Institute defines safety yellow as "the color for the identification of CAUTION" and that it should be used for "marking physical hazards which might result in: striking against, stumbling, falling, tripping, or being caught in-between" (ANSI Z535.1-1991, 6.3). The International Organization for Standardization states that yellow denotes "Caution, risk of danger . . . indications of dangers," (ISO 3864-1984(E), 5.1).

In research by Bentzen, Nolin, and Easton (Detectable Warning Surfaces: Color, Contrast, and Reflectance, US Department of Transportation. Final Report September 1994) report, "Subjective preference for the two contrasts in which the detectable warning was safety yellow (Pantone 109u), despite the relatively low value of those contrasts (40% and 62%), suggests that this color was more salient to persons with low vision than the other colors tested. While this research does not reveal the reason for the subjective superiority of safety yellow, its strong preferability, coupled with its high objective detectability even in contrasts as low as 40%, indicate that specification of safety yellow (ISO 3864) for detectable warnings could result in excellent visual detectability, as well as providing a standard color which already has international recognition for warnings."

Thus choosing safety yellow for detectable warnings is in conformance with existing national and international standards. The use of safety yellow results in warnings which are universally recognized and which are reliably visually detectable and highly salient to people having low vision.

Please refer to the attached Resolution 2000B-7 Detectable Warning Specifications.

26. Section 1108.1.4 Size. The CCB wishes to have the 24 inch minimum specification change to 36 inches.

Research has been conducted which addresses concerns about safety of detectable warnings, indicating that detectable warning on slopes and on generally horizontal surfaces have minimal impact on the safety and ease of travel for persons having physical disabilities (Bentzen, B., Nolin, T., Easton, R., Desmaris, P., and Mitchell, P., 1994; Hauger, et al, 1996).

Research has found that persons who are blind more reliably detected detectable warnings at 30 inches or 36 inches than at 24 inches, 24 inch deep detectable warnings were repeatedly detected on 85-90% of trials (Peck, A. & Bentzen, B., 1987). Additional research analysis shows that 24 to 36 inches of a detectable warning surface are typically required to enable stopping on 90-95% of trials on which the surfaces are detected (Bentzen, B., Nolin, T., Easton, R., Desmarais, L., and Mitchell, P., 1994). The CCB has received comments from blind and visually impaired pedestrians to stop on 100% of approaches on non-resilient detectable warnings (e.g. concrete, ceramic) compared with resilient detectable warnings (e.g. rubber like) requires at least 36 inches depth of detectable warning surface. These pedestrians feel non-resilient detectable warning surfaces are lacking many of the cues e.g., rebound, contrast of sound on cane contact needed to adequately detect these warnings which have a depth less than 36 inches.

Consistency in depth of detectable warnings promotes consistent interpretation. Blind pedestrians in any setting of the US should know that when they encounter a detectable warning, they need to stop immediately and check it out, as there is a vehicular or falling hazard immediately ahead. There is very minimal stopping distance.

The deeper the detectable warning, the greater the possible adverse effect on persons with mobility impairments, and the greater the expense of installation and maintenance. Therefore, the depth of 36 inches detected on 90-95% of trials in multiple experiments is being recommended by the CCB. The original ADAAG 4.7.7 specifies the detectable warning surface shall extend the full depth of the curb ramp ends up providing less precise information to blind pedestrians than installing a smaller amount in a very predictable location, as well as increased expense and greater possible adverse impact on persons with mobility impairments.

Permitting the depth of detectable warnings to be 36 inches will result in the consistency that is so important to consistent detection and fast stopping by blind pedestrians.

Please refer to the attached Resolution 2000B-7 Detectable Warning Specifications.

27. Section 1108.2.2 Rail Crossings. The CCB supports this section and feels that an exception needs to be added to address rail crossings that have automatic gates.

We propose the following language, "Exception: Where automatic gates across pedestrian ways bar pedestrian access to the crossing when rail vehicles are approaching or at a crossing, the detectable warning surface shall be located to the side of the automatic gate farthest from the crossing."

Automatic gates can cause serious head injury to pedestrians who are blind or visually impaired when approaching crossings. There is currently no reliable way for pedestrians who are blind to be notified of the location of automatic gates. Gate support is typically outside the normal pedestrian route and not likely to be encountered by blind pedestrians. Where there is a gate, a blind pedestrian may become trapped between the gate and the crossing, with the gate barring the way for the blind pedestrian to move farther away from the crossing.

28. Sections 1111.4 and 1111.6. Barricades. It is essential for the safety of persons with disabilities, especially those with visual impairments, that the proposed guidelines require a solid wall or fence for barricades to separate the sidewalk from adjacent construction sites, drop-offs, openings and other hazards, as proposed. These barricades will avoid someone from rolling, walking, tripping or falling into a hazardous construction area.

Recommended Topics to be added to these proposed Guidelines

1. Recommended section 11XX Curb and Gutter. The CCB feels very strongly that a section regarding the type of curbs that are to be used in new construction and alterations development must be addressed in these guidelines. Our preference is that type 2 curbs be used for all developments regardless of their zoning, street width, or intersection width. Type 2 curbs provide a greater degree of safety and access along sidewalks, the radius of corners, and bus stops for all pedestrians, including those with disabilities. The type 2 curb provides the following benefits over the use of the type 1 and 1A curbs:
a) They discourage motor vehicles from cutting corners and possibly striking a pedestrian wanting to make a crossing.
b) They provide a more effective orientation cue, which a blind or visually impaired pedestrian can use to align him or herself when crossing a vehicular way.
c) They add to the detectability of gradually sloped flared sides of curb ramps.
d) They discourage the parking of motorized vehicles on or across sidewalks, which can be a potential hazard to persons who are blind or visually impaired and a physical barrier to the pedestrian access route for persons with mobility limitations.
e) They reduce the horizontal and vertical gaps that must be bridged by a person alighting a transit vehicle from a bus stop pad.

However, we do acknowledge there may be construction and financial reasons e.g. the placement of a driveway that requires the use of type 1 curb in single family residential developments, which necessitate their use and the use of type 1A in other locations. Therefore, with grade reluctants, we are proposing the limited use of type 1 and 1A curbs in addition to type 2 in our underlined proposed language, which is to follow:
"Curb and gutter shall be installed adjacent to all developments as follows:
A. Type 1A Curb and Gutter: All developments and all locations not included in B through D below, or as required by the Director of the state or local Department of Transportation.
B. Type 1 Curb and Gutter: 40 foot and 50 foot streets in single family residential developments.
C. Type 2 Curb and Gutter: Frontage roads; parks; unfenced schools; open space areas; public facilities; 40-foot, 50-foot, 56-foot, 60-foot, 66-foot, 74-foot, 84-foot, 108-foot, and 130-foot streets with commercial, industrial, and multi-family (not duplex) developments.
D. Type 2 Curb and Gutter: Within the curb return areas of all intersections regardless of their width, and at all bus turnouts, bus stops, bays, or other areas where a lift or ramp is to be deployed.
E. Type 2 Curb and Gutter: Locations on 40-foot, 50-foot, 56-foot, 60-foot, 66-foot, 74-foot, 84-foot, 108-foot, and 130-foot streets where the sidewalk is separated from the curb by lawn or approved landscaping."

Please refer to the attached CCB Resolution 96B-8.

2. Recommended section 11XY Separation of Sidewalks from Bicycle Lanes. The CCB recommends these guidelines to include a section, which requires that whenever a road or bridge is constructed or reconstructed in a public right-of-way in an urbanized area that a sidewalk shall be constructed unless technically infeasible, which is physically separated from a bicycle lane and/or roadway. Many of our members have had the unfortunate and dangerous experience of having to share the public right-of-way with bicyclists when state or local Department of Transportation has deemed as a cost saving solution to place both modes of transportation within the same facility e.g., bicycle lane. What have frequently occurred in a shared facility are conflicts between fast moving bicyclists with pedestrians, which often results in non-reported injuries unless there is a fatality. These conflicts are less avoidable when the pedestrian has a disability that prevents them from seeing, hearing, or moving in response to an approaching bicycle, especially if it is coming from behind them.

We strongly believe that both pedestrians and bicyclists are entitled to their fair share of the public right-of-way, which consists of separate facilities for each and that these facilities be separated from the roadway so to ensure greater safety and access for each.

Please refer to the attached CCB Resolution 2001B-09 Installation of Sidewalks and Their Separation from Bicycle Lanes.

We are proposing that the Public Rights-of-way Access Advisory Committee be convened to consider these two recommendations so that they can be included in the next release of these guidelines.

Thank you for your time and consideration to the California Council of the Blind, Inc.'s comments, amendments, and recommendations.

Respectfully submitted,

Eugene Lozano, Jr., Chair
Committee on Access and transportation
California Council of the Blind

 

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