Arizona Department of Transportation
|
October 21, 2002 |
Arizona Department of Transportation
Intermodal Transportation Division
RE: COMMENTS ON AMERICANS WITH DISABILITIES ACT DRAFT GUIDELINES FOR ACCESSIBLE
PUBLIC RIGHTS-OF-WAY
Dear Mr. Windley:
The Arizona Department of Transportation (ADOT) has reviewed the Americans With
Disabilities Draft Guidelines for Accessible Rights-of-Way published on 17 Jun
2002. ADOT endorses the Board’s aim of ensuring that access for persons with
disabilities is provided wherever a pedestrian way is newly built or altered,
and that the same degree of convenience, connection, and safety afforded the
public generally be available to pedestrians with disabilities.
Noting our endorsement of the Board’s aim, we have taken the time to comment on
each of the sections and sub sections to the draft guidelines in hope of
assisting in the rulemaking process. The comments are enclosed for consideration
by the Architectural and Transportation Barriers Compliance Board. We understand
that the Board will review all the comments submitted prior to continuing with
the proposed rulemaking.
Please contact Kenneth Cooper at [...] if you or the Board have any questions or
if you wish to discuss the comments.
Sincerely yours,
Victor M. Mendez, P.E.
Director
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COMMENTS FROM ARIZONA DEPARTMENT OF TRANSPORTATION
AMERICANS WITH DISABILITIES ACT
DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY
PUBLISHED JUNE 17, 2002
General Comments:
A. The Arizona Department of Transportation (ADOT) supports the position
expressed in the Introduction to the Draft Guidelines for Accessible Public
Rights-of-Way that, “The guidelines do not require alterations or retrofits to
existing public rights-of-way, but would apply where a pedestrian route or
facility is altered as part of a planned project to improve existing public
rights-of-way.”;
B. ADOT recommends the inclusion of graphics to help clarify and explain the
guidelines; and
C. ADOT strongly recommends that maximum crosswalk, landing, and ramp slopes be
redefined to take into account the grade of the adjacent facility. It may be
technically infeasible and poor engineering practice to provide running and/or
cross slopes of 1:48 when the grade of the adjacent roadway exceeds two percent
(2%).
Sec. 1101 Application and Administration
Sec. 1101.1 General: For the purposes of these requirements, the terms listed in
section 1101.3 shall have the indicated meaning.
ADOT has “No comment” on this section.
Sec. 1101.2 Referenced Standards
Recommend that the following manuals also be included by reference into the
guidelines as they provide nationally accepted guidance regarding the design of
roadways and pedestrian facilities:
A. American Association of State Highway and Transportation Officials (AASHTO),
A Policy on Geometric Design of Highways and Streets 2001;
B. AASHTO, Roadside Design Guide 2002; and
C. Federal Highway Administration, Highway Design Handbook For Older Drivers and
Pedestrians 2001.
Sec. 11012.1 MUTCD: Copies of the referenced standards may be obtained on-line
from the Federal Highway Administration at http://mutcd.fhwa.dot.gov. MUTCD
2000-Millennium Edition Manual on Uniform Traffic Control Devices.
The Arizona Department of Transportation (ADOT) supports the inclusion of the
Manual on Uniform Traffic Control Devices (MUTCD) into the guidelines by
reference.
Sec. 1101.3 Defined Terms:
ADOT requests a definition be added that clarifies where slope maximum and
minimum values are provided, “maximum” and “minimum” refer to the steepness of
the slope.
Accessible Pedestrian Signal. A device that communicates information about the
pedestrian WALK phase in non-visual format.
Accessible Route. A continuous, unobstructed path that complies with Chapter 4.
Channelizing Island. Curbed or painted area outside the vehicular path that is
provided to separate and direct traffic movement, which also may serve as a
refuge for pedestrians.
Cross Slope. The slope that is perpendicular to the direction of travel.
This is usually called superelevation on curves in the public right-of-way (see
superelevation).
ADOT requests clarification of this definition as the second sentence is not
wholly correct. Curves in the public right-of-way may have a normal crown and
not be superelevated. Superelevation usually occurs, but not exclusively, in
rural settings and where the prevailing speed is greater than 35 miles per hour.
Crosswalk. That part of a roadway at an intersection that is included within the
extensions of the lateral lines of the sidewalks on opposite sides of the
roadway, measured from the curbline or, in the absence of curbs, from the edges
of the roadway or, in the absence of a sidewalk on one side of the roadway, the
part of the roadway included within the extension of the lateral lines of the
sidewalk at right angles to the centerline. Also, any portion of a roadway at an
intersection or elsewhere that is distinctly indicated for pedestrian crossing
by lines or other markings on the surface.
ADOT requests clarification of this definition as it appears to conflict with
the requirements for crosswalk width as detailed in Sec. 1105.2.1 Width since
existing sidewalks are often less than ninety-six inches (96-in) in width.
Sidewalks location is quite variable in relation to the curb line while the
location of the crosswalk should be established beyond the stop bar, if present,
and stop bar location is a function of the radius of the intersection.
Therefore, ADOT recommends that the location of the crosswalk not be defined in
relation to the sidewalk location.
Curb Line. A line at the face of the curb that marks the transition between the
sidewalk and the gutter or roadway.
Curb Ramp. A ramp cutting through a curb or built up to it.
Detectable Warning. A surface feature built in or applied to walking surfaces or
other elements to warn of hazards on a circulation path. Dynamic Envelope. The
clearance required for a rail vehicle and its cargo overhang due to any
combination of loading, lateral motion, or suspension failure.
Element. An architectural or mechanical component of a building, facility,
space, site or public right-of-way.
Facility. All or any portion of buildings, structures, improvements, elements
and pedestrian or vehicular routes located on a site or in a public
right-of-way.
Grade. (See running slope).
Grade Break. The meeting line of two adjacent surfaces of different slope
(grade).
Locator Tone. A repeating sound that identifies the location of the pedestrian
push button.
Pedestrian Access Route. An accessible corridor for pedestrian use within the
public right-of-way.
Public Right-of-Way. Land or property, usually in a corridor, that is acquired
for or devoted to transportation purposes.
ADOT recommends adding the phrase “and under the jurisdiction of a public
agency.” As written, the definition could also define parking lots or private
transportation facilities such as found in gated communities.
Roundabout. A circular intersection that has yield control of entering traffic,
channelized approaches, counterclockwise circulation, and appropriate geometric
curvature to limit travel speeds on the circulatory roadway.
Running Slope. The slope that is parallel to the direction of travel expressed
as a ratio of rise to run. In the public right-of-way, this is usually called
grade, and is expressed in percent.
Sidewalk. That portion of a public right-of-way between the curb line or lateral
line of a roadway and the adjacent property line that is improved for use by
pedestrians.
Recommend replacing the word “lateral” with “edge” and the term “adjacent
property” with “right-of-way”.
Splitter Island. A flush or raised island that separates entering and exiting
traffic in a roundabout.
Street Furniture. Elements in the public right-of-way that are intended for use
by pedestrians.
Superelevation. Cross slope on a curie in the roadway (see cross slope).
Recommend deletion of this term.
Walk Interval. That phase of a traffic signal cycle during which the pedestrian
is to begin crossing, typically indicated by a WALK message or the walking
person symbol and its audible equivalent.
Sec. 1102 Scoping Requirements
Sec. 1102.1 General: All areas of newly designed and newly constructed
facilities in public rights- of-way and altered portions of existing facilities
in public rights-of-way shall comply with Chapter 11.
ADOT supports the position that the new guidelines apply to areas of newly
designed and constructed facilities in public rights-of-way and requires
provision of sidewalks, street crossings, street furniture, parking, or other
pedestrian elements only where they are provided as part of construction or
improvement projects. ADOT supports clarification of the guideline explicitly
stating that pavement-surface treatment projects such as seal coats,
friction-course overlays, and mill-and-replace projects not be considered as
construction or improvements triggering compliance with these guidelines.
Sec. 1102.2 Existing Public Rights-of-Way. Additions to existing public
rights-of-way shall comply with 1102.2.1. Alterations to existing public
rights-of-way shall comply with 1102.2.2.
Sec. 1102.2.1 Additions: Each addition to an existing public right-of-way shall
comply with the applicable provisions of Chapter 11. Where the addition connects
with existing construction, the connection shall comply with 1102.2.2.
ADOT has “No comment” on this section.
Sec. 1102.2.2 Alterations: Where existing elements or spaces in the public
right-of-way are altered, each altered element or space shall comply with the
applicable provisions of Chapter 11.
EXCEPTION: In alterations, where compliance with applicable provisions is
technically infeasible, the alteration shall comply to the maximum extent
feasible.
ADOT supports the position that the guidelines apply to alterations to existing
facilities only in relation to the scope of the project. We think the term
“technically infeasible” should be expanded to clearly include consideration of
site conditions and topography. We also support the position that lack of
existing public right-of-way may be a sufficient reason to prevent the widening
of sidewalks and would like to see language in the guideline relieving agencies
of any obligation to purchase additional right-of-way. ADOT could support
sidewalk widening through the use of no-cost, dedicated pedestrian easements
over private land. ADOT also supports the position that new facilities should
smoothly transition into older ones.
Sec. 1102.2.2.1 Extent of Application: An alteration of an existing element,
space, or area of a public right-of-way shall not impose a requirement for
accessibility greater than required for new construction.
ADOT supports the position that an alteration of an existing area of a public
right-of-way shall not impose a requirement for accessibility greater than
required for new construction.
Sec. 1102.2.2.2 Prohibited Reduction in Access. An alteration that decreases or
has the effect of decreasing the accessibility of a public right-of-way or site
arrival points to buildings or facilities adjacent to the altered portion of the
public right-of-way, below the requirements for new construction at the time of
the alteration is prohibited.
ADOT supports the position that an alteration shall not decrease the
accessibility of a public right-of-way below the requirement for new
construction at the time of the alteration.
Sec. 1102.3 Alternate Circulation Path: An alternate circulation path complying
with 1111 shall be provided whenever the existing pedestrian access route is
blocked by construction, alteration, maintenance, or other temporary conditions.
ADOT strongly opposes adoption of this section as written. The current language
could require the construction of an alternative circulation path for situations
such as the short-term maintenance of the sidewalk or adjacent road. See Section
1111 Alternate Circulation Path for further comments. Compliance would present
an unacceptable burden upon the State and local jurisdictions, and the motoring
public without a commensurate benefit to pedestrians.
Sec. 1102.4 Sidewalks: Where sidewalks are provided, they shall contain a
continuous pedestrian access route complying with 1103. The pedestrian access
route shall connect to elements required to comply with Chapter 11.
ADOT supports the position that where sidewalk is provided it should contain a
continuous pedestrian access route (PAR) connecting to elements required to
comply with Chapter 11.
Sec. 1102.5 Protruding Objects: Protruding objects on sidewalks and other
pedestrian circulation paths shall comply with 1102.5 and shall not reduce the
clear width required for pedestrian accessible routes.
ADOT has “No comment” on this section.
Sec. 1102.5.1 Protrusion Limits. Objects with leading edges more than 27 inches
(685 mm) and not more than 80 inches (2030 mm) above the finish floor or ground
shall protrude 4 inches (100 mm) maximum horizontally into the circulation path.
EXCEPTION: Handrails shall be permitted to protrude 4-1/2 inches (115 mm)
maximum.
ADOT has “No comment” on this section.
Sec. 1102.5.2 Post-Mounted Objects: Free-standing objects mounted on posts or
pylons shall overhang circulation paths 4 inches (100 mm) maximum when located
27 inches (685 mm) minimum and 80 inches (2030 mm) maximum above the finish
floor or ground Where a sign or other obstruction is mounted between posts or
pylons is greater than 12 inches (305 mm), the lowest edge of such sign or
obstruction shall be 27 inches (685 mm) maximum or 80 inches (2030 mm) minimum
above the finish floor or ground.
EXCEPTION: This requirement shall not apply to sloping portions of handrails
serving stairs and ramps.
ADOT requests clarification of this guideline in the form of a graphic
representation. It appears that the last sentence contradicts guidance given in
the first sentence by allowing the lowest edge of a sign to be mounted at 27
inches, maximum, above the finish floor or ground rather than the upper edge.
Sec. 1102.5.3 Reduced Vertical Clearance: Guardrails or other barriers shall be
provided where the vertical clearance is less than 80 inches (2030 mm) high. The
leading edge of such guardrail or barrier shall be located 27 inches (685 mm)
maximum above the finish floor or ground.
EXCEPTION: Door closers and door stops shall be permitted to be 78 inches (1980
mm) minimum above the finish floor or ground.
ADOT requests clarification of this proposed guideline. Does the term
“guardrail” refer to vehicular w-beam or thrie beam, or is it a pedestrian-type
barrier? Regardless of the definition, we are concerned that guardrail installed
at twenty-seven inches (27 in), adjacent to the PAR, could constitute a tripping
hazard for the visually impaired.
Sec. 1102.6 Curbs and Blended Transitions: A curb ramp or blended transition
complying with 1104, or a combination of curb ramps and blended transitions,
shall connect the pedestrian access routes to each street crossing within the
width of each crosswalk
ADOT supports the proposed guideline requiring that curb ramps be placed in-line
with the crosswalk they serve; curb cuts at the mid-point of the curb radius
will normally not be allowed. This may effectively double the number, and cost,
of curb ramps required on construction projects, but the total cost of such
ramps is minimal in terms of the larger project. We note however that sound
engineering judgment may dictate the use of only one ramp at a particular
intersection due to site geometry and conditions.
Sec. 1102.7 Pedestrian Signs: Signs for pedestrian use shall comply with 1102.7.
ADOT supports the proposed guideline as written. It reiterates guidance given in
the MUTCD.
Sec. 1102.7.1 Bus Route Identification: Bus route identification signs shall
comply with 703.5.1 through 703.5.4, and 703.5.7 and 703.5.8. In addition, to
the maximum extent practicable, bus route identification signs shall comply with
703.5.5. Bus route identification signs located at bus shelters shall provide
raised and Braille characters complying with 703.2, and shall have rounded
corners.
EXCEPTIONS.
1. Bus schedules, timetables and maps that are posted at the bus stop or bus
shelter shall not be required to comply with 1102.7.
2: Signs shall not be required to comply with 703.2 where audible signs are
user- or proximity-actuated or are remotely transmitted to a portable receiver
carried by an individual. (Sec. 703 Signs can be found on the Access Board
website at http://www. access-board.gov/ada-aba/htm l/tech-0 7. html).
ADOT has “No comment” on this section.
Sec. 1102.7.2 Informational Signs and Warning Signs: Informational signs and
warning signs shall comply with 703.5.
ADOT has “No comment” on this section.
Sec. 1102.8 Pedestrian Crossings: Where a pedestrian crossing is provided, it
shall comply with the applicable provisions of 1105. Where pedestrian signals
are provided at a pedestrian crossing, they shall comply with 1106.
ADOT strongly opposes this guideline. See Sec. 1105 Pedestrian Crossings for
further comment.
Sec. 1102.9 Street Furniture: Street furniture that is intended for use by
pedestrians and installed on or adjacent to a sidewalk shall comply with 309 and
1107. (Sec. 309 Operable Parts can be found on the Access Board website at
http://www.access-board.gov/ada-aba/html/tech-03.html)
ADOT has “No comment” on this section.
Sec. 1102.10 Stairs: Where provided, stairs shall comply with 504. Stair treads
shall have a 2 inch (51 mm) wide strip of color contrasting with the tread and
riser, the full width of the front edge of each tread (Sec. 504 Stairways can be
found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-05.hmtl)
ADOT has “No comment” on this section.
Sec. 1102.11 Handrails: Where provided, handrails shall comply with 505. (Sec.
505 Handrails can be found on the Access Board website at http.//www.access-board.gov/ada-aba.html/tech-05.hmtl)
ADOT has “No comment” on this section.
Sec. 1102.12 Vertical Access: Where provided elevators shall comply with 407,
limited use/limited-application elevators shall comply with 408, and platform
lifts shall comply with 410. Vertical access shall remain unlocked during the
operating hours of the facility served (Sections 407, 408 & 410 can be found on
the Access Board website at http://www. access-board.gov/ada-aba/html/tech-04.hmtl)
ADOT has “No comment” on this section.
Sec. 1102.13 Bus Stops. Bus boarding and alighting areas shall comply with
810.2. Bus shelters shall comply with 810.3. (Sections 810.2 & 810.3 can be
found on the Access Board website at http://www. access-board.gov/ada-aba/html/tech-08.html)
ADOT has “No comment” on this section.
Sec. 1102.14 On-Street Parking: Where on-street parking is provided, at least
one accessible on-street parking space shall be located on each block face and
shall comply with 1109.
ADOT strongly opposes this guideline. See Sec. 1109 On-Street Parking for
further comments.
Sec. 1102.15 Passenger Loading Zones: Where passenger loading zones are
provided, they shall connect to a pedestrian access route and shall provide a
minimum of one passenger loading zone in every continuous 100 linear feet (30 m)
of loading zone space, or fraction thereof complying with 302, 503.2, 503.3, and
503.5.
ADOT has “No comment” on this section.
Sec. 1102.16 Call Boxes: Where provided, call boxes shall comply with 1110.
See Sec. 1110 Call Boxes for comments.
Sec. 1103 Pedestrian Access Route
Sec. 1103.1 General: Pedestrian access routes shall connect to elements required
to be accessible and shall comply with 1103.
ADOT supports the proposed guideline as written.
Sec. 1103.2 Components: Pedestrian access routes shall consist of one or more of
the following components: walking surfaces, ramps, curb ramps, blended
transitions, crosswalks, pedestrian overpasses and underpasses, elevators, and
platform h/is. All components of a pedestrian access route shall comply with the
applicable portions of this chapter.
ADOT has “No comment” on this section.
Sec. 1103.3 Clear Width: The minimum clear width of a pedestrian access route
shall be 48 inches (1220 mm), exclusive of the width of the curb.
ADOT supports the proposed guideline as written.
Sec. 1103.4 Cross Slopes: The cross slope of the pedestrian access route shall
be 1:48 maximum.
ADOT supports the goal of the proposed guideline, but requests clarification of
how the term “technically infeasible” will be applied to pedestrian access
routes in areas with greater than a two percent (2%) grade.
Sec. 1103.5 Grade: The grade of the pedestrian access route within a sidewalk
shall not exceed the grade established for the adjacent roadway.
EXCEPTION: The running slope of a pedestrian access route shall be permitted to
be steeper than the grade of the adjacent roadway, provided that the pedestrian
access route is less than 1:20, or complies with 405. (Sec. 405 Ramps can be
found on the Access Board website at http://www. access-board. gov/ada-aba/html/tech
04.hmtl)
ADOT cannot support the proposed guideline because the exception requires the
maximum running slope of the PAR to be less than 1:20. See Sec. 1105.2.2
Pedestrian Crossings Cross Slope for further comments.
Sec. 1103.6 Surfaces: The surfaces of the pedestrian access route shall comply
with 302. (Sec. 302 Floor or Ground Surfaces can be found on the Access Board
website at http://www. access- board.gov/ada-aba/htm l/tech-03.hmtl).
ADOT supports the proposed guideline as written.
Sec. 1103.7 Surface Gaps at Rail Crossings.’ Where the pedestrian access route
crosses rail systems at grade, the horizontal gap at the inner edge of each rail
shall be constructed to the minimum dimension necessary to allow passage of
railroad car wheel flanges and shall not exceed 2-’/2 inches (64 mm).
EXCEPTION: On tracks that carry freight, a maximum horizontal gap of 3 inch (75
mm) shall be permitted.
ADOT has “No comment” on this section.
Sec. 1103.7.1 Detectable Warnings: Where rail systems cross pedestrian
facilities that are not shared with vehicular ways, a detectable warning shall
be provided in compliance with 1108.
ADOT supports the proposed guideline as written.
Sec. 1103.8 Changes in Level.’ Changes in level shall comply with 303. Changes
in level shall be separated horizontally 30 inches (760 mm) minimum. (Sec. 303
Changes in Level can be found on the Access Board website at
www.access-board.gov/ada-aba/html/tech-03.hmtl). EXCEPTION: The horizontal
separation requirement shall not apply to detectable warnings.
ADOT requests clarification of this guideline. What is meant by “Changes in
level shall be separated horizontally 30 inches minimum.”
Sec. 1103.8.1 Rail Crossings.’ Where the pedestrian access route crosses rail
systems at grade, the surface of the pedestrian access route shall be level and
flush with the top of the rail at the outer edge and between the rails.
ADOT supports the proposed guideline as written.
Sec. 1104 Curb Ramps and Blended Transitions
Sec. 1104.1 General.’ Curb ramps and blended transitions shall comply with 1104.
ADOT has “No comment” on this section.
Sec. 1104.2 Types: Perpendicular curb ramps shall comply with 1104.2.1 and
1104.3; parallel curb ramps shall comply with 1104.2.2 and 1104.3; blended
transitions shall comply with 1104.2.3 and 1104.3.
ADOT cannot support this section because it does not include provision for curb
ramps that are in-line with a crosswalk, but neither perpendicular nor parallel.
Good engineering practice may include design and construction of
non-perpendicular and non-parallel curb ramps.
Sec. 1104.2.1 Perpendicular Curb Ramps: Perpendicular curb ramps shall comply
with 1104.2.1, and shall have a running slope that cuts through the curb at
right angles or meets the gutter grade break at right angles.
ADOT supports this guideline as written.
Sec. 1104.2.1.1 Running Slope: The running slope shall be 1:48 minimum and 1.12
maximum.
ADOT cannot support this guideline as written because it ignores the possibility
of site-specific conditions which could result in running slopes greater than
1:12.
Sec. 1104.2.1.2 Cross Slope: The cross slope shall be 1:48 maximum.
EXCEPTION: This requirement shall not apply to mid-block crossings.
ADOT cannot support this guideline and requests that the guideline be reworded
to allow the cross slope to match the existing roadway grade. The proposed
guideline has an unanticipated and unacceptable consequence when a curb ramp is
provided on a facility with greater than a 1:48 longitudinal slope. To comply
with this guideline the ramp would either have to be warped between the curbline
and the top of the ramp, or the profile of the roadway would have to be modified
in the vicinity of the curb ramp to no more than a 1:48 longitudinal slope.
Neither one of these options is advisable. The first method, ramp warping, would
involve excessive labor in placing and finishing the concrete, and difficulty
regarding the placement of the tactile warning strip. The second method,
modifying the longitudinal slope, is inadvisable because the algebraic
difference of the roadway slopes could trigger the requirement for vertical
curves. These requirements are detailed in the American Association of State
Highway and Transportation Engineers manual, A Policy on Geometric Design of
Highways and Streets The same exception applied to mid-block crossings should be
applied to crossings perpendicular to roadways with a longitudinal slope greater
than 1:48.
Sec. 1104.2.1.3 Landing: A landing 48 inches (1220 mm) minimum by 48 inches
(1220 mm) minimum shall be provided at the top of the curb ramp and shall be
permitted to overlap other landings and clear floor or ground space. Running and
cross slopes shall be 1:48 maximum.
EXCEPTION: Running and cross slope requirements shall not apply to mid-block
crossings.
ADOT supports the requirement for a minimum of a 48-inch by 48-inch landing at
the top of the curb ramp. However, we cannot support the guideline language for
maximum running and cross slopes of 1:48. At locations where the sidewalk
longitudinal grade exceeds two percent (2%) the running slope requirement could
not be met without changing the grade. This would run counter to the guidance
from Sec. 1103.5 Grade that allows the grade of the PAR within a sidewalk to
match the grade established for the adjacent roadway. We would like to see the
guideline exception extended to all crossings at the same grade as the adjacent
roadway.
Sec. 1104.2.1.4 Flares: Flared sides with a slope of 1:10 maximum, measured
along the curb line, shall be provided where a circulation path crosses the curb
ramp.
ADOT cannot support the proposed guideline as written because it ignores
site-specific conditions that might require a flare slope of greater than 1:10.
Sec. 1104.2.2 Parallel Curb Ramps: Parallel curb ramps shall comply with
1104.2.2, and shall have a running slope that is in-line with the direction of
sidewalk travel.
ADOT supports this guideline.
Sec. 1104.2.2.1 Running Slope: The running slope shall be 1:48 minimum and 1:12
maximum.
EXCEPTION: A parallel curb ramp shall not be required to exceed 15 fret (4570
mm) in length.
ADOT cannot support this guideline as written as it would require extensive
engineering and construction efforts in areas where the sidewalk and PAR were
adjacent to a roadway with a grade greater than eight and one-third percent
(8.33%). We do support a maximum ramp length of fifteen feet (15 ft).
Sec. 1104.2.2.2 Cross Slope: The cross slope shall be 1:48 maximum.
ADOT cannot support this guideline as written as it ignores site-specific
conditions that could result in the cross slope being greater than 1:48 without
extensive engineering and construction efforts.
Sec. 1104.2.2.3 Landing: A landing 48 inches (1220 mm) minimum by 48 inches
(1220 mm) minimum shall be provided at the bottom of the ramp run and shall be
permitted to overlap other landings and clear floor or ground space. Running and
cross slopes shall be 1:48 maximum.
EXCEPTION: Running and cross slope requirements shall not apply to mid- block
crossings.
ADOT supports the guideline requirement for a minimum 48-inch by 48-inch landing
at bottom of the parallel ramp. However, we oppose the guideline for maximum
running and cross slopes of 1:48 because sidewalks and PARS slopes should be
allowed to follow the grade of adjacent roadways. In most instances it would
require considerable engineering and construction efforts to provide sidewalk
and PAR slopes independent of the adjacent roadway. We would like to see the
guideline exception extended to all crossings at the same grade as the adjacent
roadway.
Sec. 1104.2.2.4 Diverging Sidewalks: Where a parallel curb ramp does not occupy
the entire width of a sidewalk, drop-offs at diverging segments shall be
protected with a barrier.
ADOT supports the proposed guideline as written, but requests clarification of
what constitutes a “barrier”.
Sec. 1104.2.3 Blended Transitions: Blended transitions shall comply with 1104.3,
and shall have running and cross slopes of 1:48 maximum.
ADOT cannot support the guideline because of its call for maximum running and
cross slopes of 1:48 which may be infeasible for a given site.
Sec. 1104.3 Common Elements: Curb ramps and blended transitions shall comply
with 1104.3.
Sec. 1104.3.1 Width: The clear width of landings, blended transitions, and curb
ramps, excluding flares, shall be 48 inches (1220 mm) minimum.
ADOT supports the proposed guideline as written.
Sec 1104.3.2 Detectable Warnings: Detectable warning surfaces complying with
1108 shall be provided, where a curb ramp, landing, or blended transition
connects to a crosswalk.
ADOT supports the proposed guideline, noting however the comments we’ve provided
pertaining to Sec. 1108 Detectable Warning Surfaces.
Sec. 1104.3.3 Surfaces: Surfaces of curb ramps, blended transitions, and
landings shall comply with 302. Gratings, access covers, and other appurtenances
shall not be located on curb ramps, landings, blended transitions, and gutter
areas within the pedestrian access route.
ADOT requests a rewording of second sentence of this guideline to acknowledge
that circumstances will occur that may require the placement of gratings, access
covers, and other appurtenances within the PAR.
Sec. 1104.3.4 Grade Breaks: Grade breaks shall not be permitted on curb ramps,
blended transitions, landings, and gutter areas within the pedestrian access
route. Surface slopes that meet at grade breaks shall be flush.
ADOT requests clarification of the last sentence and what is meant by “surface
slopes” and how they shall be “flush”.
Sec. 1104.3.5 Changes in Level: Vertical changes in level shall not be permitted
on curb ramps, blended transitions, landings, or gutter areas within the
pedestrian access route.
ADOT requests clarification of “vertical changes in level”.
Sec. 1104.3.6 Counter Slopes: The counter slope of the gutter area or street at
the foot of a curb ramp or blended transition shall be 1:20 maximum.
ADOT requests that definition of the term “counter slope” be provided.
Sec. 1104.3.7 Clear Space: Beyond the curb line, a clear space of 48 inches
(1220 mm) minimum by 48 inches (1220 mm) minimum shall be provided within the
width of the crosswalk and wholly outside the parallel vehicle travel lane.
ADOT strongly opposes this guideline. This guideline would result in an increase
in the roadway width by forty-eight inches (48 in) on each side of the road at
every ramp location for a total of ninety-six (96 in or 8 ft) at every crosswalk
location. There is no rationale presented to justify this guideline; wheelchairs
can wait at the top of the landing for the WALK phase. The proposed new
guideline for Sec. 1105.3, Pedestrian Signal Phase Timing, takes the ramp length
into account for the calculation of the total crossing time.
Sec. 1105 Pedestrian Crossings
Sec. 1105.1 General: Pedestrian crossings shall comply with 1105.
Sec. 1105.2 Crosswalks: Crosswalks shall comply with 1105.2.
Sec. 1105.2.1 Width: Marked crosswalks shall be 96 inches (2440 mm) wide
minimum.
ADOT cannot support the proposed guideline as written because it mandates a
minimum width contrary to that called for in the MUTCD. Section 3B.17 Crosswalk
Width of the MUTCD calls for a minimum width of six feet (6 ft), which is
research based. Nothing has been presented to show the necessity of widening a
crosswalk to eight feet (8 ft).
Sec. 1105.2.2 Cross Slope: The cross slope shall be 1.48 maximum measured
perpendicular to the direction of pedestrian travel.
EXCEPTION: This requirement shall not apply to mid-block crossings.
ADOT strongly opposes this guideline. The effect of this guideline could be
monumental in locations where the longitudinal grade of the roadway exceeds two
percent (2%, 1:48 slope). The cross slope of pedestrian crossings perpendicular
to the longitudinal grade would be out of compliance with no practical way to
remedy the situation. This guideline might better be written to set a goal of a
1:48 slope for the pedestrian crossing cross slope, but contain language
acknowledging that existing site conditions may preclude achieving the goal.
Mid-block crossings are already exempted under the proposed guideline
Sec. 1105.2.3 Running Slope: The running slope shall be 1.20 maximum measured
parallel to the direction of pedestrian travel in the crosswalk
ADOT cannot support this guideline as it would have a negative effect on the
placement of marked pedestrian crossings on roadways with grades steeper than
five percent (5%, 1:20 slope). The running slope of pedestrian crossings
parallel to the longitudinal grade would be out of compliance with no practical
way to remedy the situation. This guideline might better be written to set a
goal of a 1:20 slope for the pedestrian crossing running slope, but contain
language acknowledging that existing site conditions may preclude achieving the
goal.
Sec. 1105.3 Pedestrian Signal Phase Timing: All pedestrian signal phase timing
shall be calculated using a pedestrian walk speed of 3. 0 feet per second (0.91
m/s) maximum. The total crosswalk distance used in calculating pedestrian signal
phase timing shall include the entire length of the crosswalk plus the length of
the curb ramp.
ADOT cannot support this guideline as it would impact the pedestrian signal
phase timing of almost every traffic signal in the State and two of the
consequences would be overwhelming. First, almost every traffic signal in
Arizona would have to be re-timed to account for the increase in pedestrian
travel length. The current MUTCD guidelines for pedestrian signal phase timing
allow the length to be measured from the curb face to the center of the furthest
through travel lane. This guideline would add a minimum of fourteen feet (14 ft)
to the length which equates to a minimum addition of 4.67 seconds to the
pedestrian signal phase length. This could have the consequence of de-optimizing
the signal timing at traffic signals and increasing the traffic delay
experienced by the other roadway users. Second, all the coordinated signal
systems in Arizona would have to be retimed to account for the longer pedestrian
phase. This would be an expensive, time-consuming process which would involve
most of the local traffic engineers to the detriment of their other
responsibilities.
Sec. 1105.4 Medians and Pedestrian Refuge Islands: Medians and pedestrian refuge
islands in crosswalks shall comply with 1105.4 and shall be cut through level
with the street or have curb ramps complying withllO4 and shall contain a
pedestrian access route complying with 1103. Where the cut-through connects to
the street, edges of the cut-through shall be aligned with the direction of the
crosswalk for a length of 24 inches (610 mm) minimum.
ADOT cannot support this guideline because the language in Sec. 1104 Curb Ramps
is already overly restrictive at locations with roadway grade is greater than
two percent (2%) (see comment for Sec. 1104.2.1.2 Cross Slope, above).
Sec. 1105.4.1 Length: Where signal timing is inadequate for full crossing of all
traffic lanes or where the crossing is not signalized, cut-through medians and
pedestrian refuge islands shall be 72 inches (1830 mm) minimum in length in the
direction of pedestrian travel.
ADOT cannot support this guideline as our current standard width for medians at
intersections is forty-eight inches (48 in).
Sec. 1105.4.2 Detectable Warnings: Medians and refuge islands shall have
detectable warnings complying with 1108. Detectable warnings at cut-through
islands shall be separated by a 24 inch (610 mm) minimum length of walkway
without detectable warnings.
EXCEPTION: Detectable warnings shall not be required on cut-through islands
where the crossing is controlled by signals and is timed for full crossing.
ADOT cannot support this guideline as our current standard width for medians at
intersections is forty-eight inches (48 in.
Sec. 1105.5 Pedestrian Overpasses and Underpasses: Pedestrian overpasses and
underpasses shall comply with 1105.5.
Sec. 1105.5.1 Pedestrian Access Route: Pedestrian overpasses and underpasses
shall contain a pedestrian access route complying with 1103.
ADOT supports the proposed guideline as written.
Sec. 1105.5.2 Running Slope: The running slope shall not exceed 1:20 maximum.
ADOT cannot support the proposed guideline as written as it could require the
running slope of the PAR to be independent of the longitudinal grade of the
adjoining roadway. To require a PAR running slope less than 1:20, independent of
the adjoining roadway grade, would require extensive engineering and
construction at locations where the adjacent roadway grade is greater than five
percent (5%). We support the position that the PAR running slope should not
exceed the slope of the adjacent roadway.
Sec. 1105.5.3 Approach: Where the approach exceeds 1:20, the approach shall be a
ramp 48 inches (1220 mm) minimum in width and shall comply with 405. Where the
rise of a ramped approach exceeds 60 inches (1525 mm), an elevator complying
with 407, or a limited- use/limited-application elevator complying with 408
shall be provided. (Sec. 405 Ramps, Sec. 407 Elevators, and Sec. 408 Wheelchair
(Platform) Lifts can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-04.hmtl)
ADOT supports the part of the guideline pertaining to minimum ramp width. We
strongly oppose that part calling for a limited-use/limited-application or
standard elevator where the rise of the ramped approach exceeds sixty inches (60
in). We are deeply concerned that about the safety of pedestrians using such
elevators and think it inadvisable to install elevators if we cannot guarantee
pedestrian security. In Arizona there are also regular, but unplanned
interruptions in electrical service due to electrical storms in the summer and
snow storms in the winter. These interruptions could trap people in the
elevators without any simple means of extricating them until power is restored.
Equally as important in our opposition to the requirement for elevators are
their exorbitant costs and the notion we should provide a facility for disabled
pedestrians which is well beyond what we’d provide for pedestrian traffic in
general.
Sec. 1105.5.4 Stairs: Stairs shall comply with 504. (Sec. 504 Stairways can be
found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-05.hmtl)
ADOT has “No comment” on this section.
Sec. 1105.5.5 Escalators: Escalators shall comply with 810.9.
ADOT has “No comment” on this section.
Sec. 1105.6 Roundabouts: Where pedestrian crosswalks and pedestrian facilities
are provided at roundabouts, they shall comply with 1105.6.
Sec. 1105.6.1 Separation: Continuous barriers shall be provided along the street
side of the sidewalk where pedestrian crossing is prohibited. Where railings are
used, they shall have a bottom rail 15 inches (380 mm) maximum above the
pedestrian access route.
ADOT strongly opposes this guideline as written because of its possible negative
impacts on motorist and pedestrian safety. If handrail is used as a barrier on
sidewalks abutting the curb it could present a spearing hazard to motorists.
Other types of barrier could present tripping hazards to pedestrians if placed
lower than twenty-seven inches (27 in) and a sight restriction to motorists if
places above that point. We would like to know why sidewalk at a roundabout is
being treated differently from that at any other street intersection?
Sec. 1105.6.2 Signals: A pedestrian activated traffic signal complying with 1106
shall be provided for each segment of the crosswalk, including the splitter
island. Signals shall clearly identify which crosswalk segment the signal
serves.
ADOT cannot support this guideline as written. It is inadvisable to promulgate a
guideline that would mandate the installation of any traffic control signal
without an engineering study to confirm the need for such a signal. Warrants for
installation of a signal would investigate such variables as sight distance,
traffic volume, pedestrian volume, vehicle speed, and vehicle gap.
Sec. 1105.7 Turn Lanes at Intersections: Where pedestrian crosswalks are
provided at right or left turn slip lanes, a pedestrian activated traffic signal
complying with 1106 shall be provided for each segment of the pedestrian
crosswalk, including at the channelizing island.
ADOT cannot support this guideline as written. We request a definition for the
term “slip lane” be added to Sec. 1101.3 Terms. Within the Arizona highway
system unrestricted right turns are sometimes provided at freeway ramps to
handle the volume of exiting traffic. The installation of a signal could cause a
dangerous situation where off-ramp traffic would back up onto the freeway.
Again, without a case-by-case engineering study, as detailed in the MUTCD, it
would be inadvisable to mandate installation of a signal at these locations.
Sec. 1106 Accessible Pedestrian Signal Systems
Sec. 1106.1 General: Pedestrian signal systems shall comply with 1106.
Sec. 1106.2 Pedestrian Signal Devices: Each crosswalk with pedestrian signal
indication shall have a signal device which includes audible and vibrotactile
indications of the WALK interval. Where a pedestrian pushbutton is provided, it
shall be integrated into the signal device and shall comply with 1106.3.
ADOT strongly opposes this guideline as written. We see no added value to
implementing this guideline, and a possible increased liability due to system
failure and application inconsistency.
Sec. 1106.2.1 Location: Pedestrian signal devices shall be located 60 inches
(1525 mm) maximum from the crosswalk line extended, 120 inches (3050 mm) maximum
and 30 inches (760 mm) minimum from the curb line, and 120 inches (3050 mm)
minimum from other pedestrian signal devices at a crossing. The control face of
the signal device shall be installed to face the intersection and be parallel to
the direction of the crosswalk it serves.
EXCEPTION: The minimum distance from other signal devices shall not apply to
signal devices located in medians and islands.
ADOT cannot support the proposed guideline as written because locating all
traffic control devices should be done as part of a site-specific engineering
study. We think it would be poor engineering practice to utilize this guideline
without an investigation of the site and analysis thereof.
Sec. 1106.2.2 Reach and Clear Floor or Ground Space: Pedestrian signal devices
shall comply with 308. A clear floor or ground space complying with 305 shall be
provided at the signal device and shall connect to or overlap the pedestrian
access route. (Sec. 308 Reach Ranges and Sec. 305 Knee and Toe Clearance can be
found on the Access Board website at http://www. access-board.gov/ada-aba/html/tech-03.html)
ADOT has “No comment” on this section.
Sec. 1106.2.3 Audible Walk Indication: The audible indication of the WALK
interval shall be by voice or tone.
ADOT cannot support this guideline as written. Because of the number of
different languages spoken in Arizona it would be technically infeasible to
provide any message, in every language, in a timely manner. To arbitrarily
decide not to offer the message in a particular language could also leave this
Department open to charges of not providing equal access to public services.
Also, as noted above, advocacy groups for the visually impaired have not
achieved a clear consensus regarding the need for and design of audible and
vibrotactile indications.
Sec. 1106.2.3.1 Tones: Tones shall consist of multiple frequencies with a
dominant component at 880 Hz. The duration of the tone shall be 0.15 seconds and
shall repeat at intervals of 0.15 seconds.
ADOT has “No comment” on this section.
Sec. 1106.2.3.2 Volume: Tone or voice volume measured at 36 inches (915 mm) from
the pedestrian signal device shall be 2 dB minimum and 5 dB maximum above
ambient noise level and shall be responsive to ambient noise level changes.
ADOT cannot support this section of the guidelines because the sound level
produced could be considered a nuisance, particularly in the evening hours and
at locations in residential neighborhoods.
Sec. 1106.3 Pedestrian Pushbuttons: Pedestrian pushbuttons shall comply with
1106.3.
Sec. 1106.3.1 Operation. Pedestrian pushbuttons shall comply with 309.4. (Sec.
309.4 Operation can be found on the Access Board website at http://www.access
board.gov/ada-aba/html/tech-03.hmtl)
ADOT has “No comment” on this section.
Sec. 1106.3.2 Locator Tone. Pedestrian pushbuttons shall incorporate a locator
tone at the pushbutton. Locator tone volume measured at 36 inches (915 mm) from
the pushbutton shall be 2 dB minimum and 5 dB maximum above ambient noise level
and shall be responsive to ambient noise level changes. The duration of the
locator tone shall be 0.15 seconds maximum and shall repeat at intervals of one
second The locator tone shall operate during the DON’T WALK and flashing DON’T
WALK intervals only and shall be deactivated when the pedestrian signal system
is not operative.
ADOT cannot support the proposed guideline because the sound level produced
could be considered a nuisance, particularly in the evening hours and at
locations in residential neighborhoods.
Sec. 1106.3.3 Size and Contrast. Pedestrian pushbuttons shall be a minimum of 2
inches (51 mm) across in one dimension and shall contrast visually with their
housing or mounting.
ADOT supports the proposed guideline as written.
Sec. 1106.3.4 Optional Features: An extended button press shall be permitted to
activate additional features. Buttons that provide additional features shall be
marked with three Braille dots forming an equilateral triangle in the center of
the pushbutton.
ADOT has “No comment” on this section.
Sec. 1106.4 Directional Information and Signs. Pedestrian signal devices shall
provide tactile and visual signs on the face of the device or its housing or
mounting indicating crosswalk direction and the name of the street containing
the crosswalk served by the pedestrian signal.
ADOT cannot support this section as the name of streets served by a particular
crosswalk is not currently provided at any location. Each location would require
costly, custom-made signs which would have to be replaced if damaged or
otherwise vandalized.
Sec. 1106.4.1 Arrow: Signs shall include a tactile arrow aligned parallel to the
crosswalk direction. The arrow shall be raised 1/32 inch (0.8 mm) minimum and
shall be 1-1/2 inches (38 mm) minimum in length. The arrowhead shall be open at
45 degrees to the shaft and shall be 33 percent of the length of the shaft.
Stroke width shall be 10 percent minimum and 15 percent maximum of arrow length.
The arrow shall contrast with the background
ADOT can support this guideline.
Sec. 1106.4.2 Street Name. Signs shall include street name information aligned
parallel to the crosswalk direction and complying with 703.2. (Sec. 703.2
Characters That Are Both Tactile and Visual can be found on the Access Board
website at http://www.access board.gov/ada-aba/html/tech-07.html)
ADOT cannot support this section of the guidelines because it puts an
unreasonable burden on the State and other jurisdictions to produce costly,
custom-made signs for each location.
Sec. 1106.4.3 Crosswalk Configuration: Where provided, graphic indication of
crosswalk configuration shall be tactile and shall comply with 703.5.1. (Sec.
703.2 Location can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-07.hmtl)
ADOT can support this section as long as there is no requirement to provide
graphic indication of the crosswalk configuration.
Sec 1107 Street Furniture
Sec. 1107.1 General: Street furniture shall comply with 1107.
Sec. 1107.2 Clear Floor or Ground Space: Street furniture shall have clear floor
or ground space complying with 305 and shall be connected to the pedestrian
access route. The clear floor or ground space shall overlap the pedestrian
access route 12 inches (305 mm) maximum. (Sec. 305 Clear Floor or Ground Space
can be found on the Access Board website at www.access-board.gov/ada-aba/html/tech-03.hmtl)
ADOT support this section of the guidelines.
Sec. 1107.3 Drinking Fountains: Where drinking fountains are provided, they
shall comply with 602. (Sec. 602 Drinking Fountains and Water Coolers can be
found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-06.hmtl)
ADOT has “No comment” on this section.
Sec. 1107.4 Public Telephones: Where public telephones are provided, they shall
comply with 1107.4.
ADOT has “No comment” on this section.
Sec. 1107.4.1 Single Telephone: Where a single public telephone is provided, it
shall comply with 704.2 and 704.4. (Sec. 704.2 Wheelchair Accessible Telephones
and Sec. 704.4 TTYs can be found on the Access Board website at http://www.access
board.gov/ada-aba/html/tech-07.html)
ADOT has “No comment” on this section.
Sec. 1107.4.2 Multiple Telephones: Where a bank of public telephones is
provided, at least one telephone shall comply with 704.2, and at least one
additional telephone shall comply with 704.4.
ADOT has “No comment” on this section.
Sec. 1107.4.3 Volume Controls: A 11 public telephones shall provide volume
controls complying with 704.3. (Sec. 704.3 Volume Control Telephones can be
found on the Access Board website at http.//www. access-board.gov/ada-aba/html/tech-0
7.html)
ADOT supports the proposed guideline as written.
Sec. 1107.5 Public Toilet Facilities: Permanent or portable public toilet
facilities shall comply with 603. At least one fixture of each type provided
shall comply with 604 through 610. Operable parts, dispensers, receptacles, or
other equipment shall comply with 309.
EXCEPTION: Where multiple single-user toilet facilities are clustered at a
single location, at least 5 percent, but no fewer than one single-user toilet at
each cluster shall comply with 603 and shall be identified by the International
Symbol of Accessibility complying with 703.7.2.1. (Sec. 603 Toilet and Bathing
Rooms and Sections 604 through 610 can be found on the Access Board website at
http.//www.access-board.gov/ada-aba/html/tech-06.html, Sec. 309 Operable Parts
at http.//www.access-board.gov/ada-aba.html/tech-03.html and Sec. 703.7.2.1
Finish and Contrast at http.//www. access-board.gov/ada-aba/html/tech-07.html.)
ADOT has “No comment” on this section.
Sec. 1107.6 Tables, Counters, and Benches: Tables, counters, and benches shall
comply with 1107.6.
Sec. 1107.6.1 Tables: Where tables are provided in a single location, at least 5
percent but no fewer than one, shall comply with 902. (Sec. 902 Dining Surfaces
and Work Surfaces can be found on the Access Board website at http.//www.access-board.gov/ada-aba/html/tech-09.hmtl)
ADOT has “No comment” on this section.
Sec. 1107.6.2 Counters: Where provided, counters shall comply with 904. (Sec.
904 Sales and Service Counters can be found on the Access Board website at
http://www. access-board.gov/ada-aba/html/tech-09.hmtl)
ADOT has “No comment” on this section.
Sec. 1107.6.3 Benches: Where benches without tables are provided at a single
location, at least 50 percent, but no fewer than one, shall comply with 903 and
shall have an armrest on at least one end (Sec. 903 Benches can be found on the
Access Board website at http://www. access-board.gov/ada-aba.html/tech-09.hmtl)
ADOT has “No comment” on this section.
Sec 1108 Detectable Warning Surfaces
Sec. 1108.1 General: Detectable warnings shall consist of a surface of truncated
domes aligned in a square grid pattern and shall comply with 1108.
ADOT cannot support this guideline because it would restrict the free market
development of truncated dome systems by prohibiting the diamond pattern. While
the argument arises that the square pattern is friendlier to vibration-
sensitive people, there is no research on the possible number of individuals
affected. Depending on the dimensions used in the square or diamond pattern and
the width of the wheelchair, its wheels will either hit or miss the truncated
domes. Therefore, we see no reason to favor one pattern over another in the
rulemaking process.
Sec. 1108.1.1 Dome Size: Truncated domes in a detectable warning surface shall
have a base diameter of 0.9 inches (23 mm) minimum to 1.4 inches (36 mm)
maximum, a top diameter of 50% of the base diameter minimum to 65% of the base
diameter maximum, and a height of 0.2 inches (5 mm).
ADOT supports the proposed guideline as written.
Sec. 1108.1.2 Dome Spacing: Truncated domes in a detectable warning surface
shall have a center-to-center spacing of 1.6 inches (41 mm) minimum and 2.4
inches (61 mm) maximum, and a base-to-base spacing of 0.65 inches (16 mm)
minimum, measured between the most adjacent domes on square grid
ADOT supports this guideline while recommending removal of reference to “square
grid” from the last sentence (see comment on Sec. 1108.1 General, above).
Sec. 1108.1.3 Contrast: Detectable warning surfaces shall contrast visually with
adjacent walking surfaces either light-on-dark, or dark-on-light.
ADOT supports the proposed guideline as written.
Sec. 1108.1.4 Size: Detectable warning surfaces shall extend 24 inches (610 mm)
minimum in the direction of travel and the full width of the curb ramp, landing,
or blended transition.
ADOT supports the proposed guideline as written.
Sec. 1108.2 Location
Sec. 1108.2.1 Curb Ramps and Blended Transitions: The detectable warning surface
shall be located so that the edge nearest the curb line is 6 inches (150 mm)
minimum and 8 inches (205 mm) maximum from the curb line.
ADOT supports the proposed guideline as written.
Sec. 1108.2.2 Rail Crossings: The detectable warning surface shall be located so
that the edge nearest the rail crossing is 6 inches (150 mm) minimum and 8
inches (205 mm) maximum from the vehicle dynamic envelope.
ADOT supports the proposed guideline, but recommends the term “vehicle dynamic
envelope” be used consistent with the term “dynamic envelope” as shown in Sec.
1103 Terms.
Sec. 1108.2.3 Platform Edges: Detectable warning surfaces at platform boarding
edges shall be 24 inches (610 mm) wide and shall extend the full length of the
platform.
ADOT has “No comment” on this section.
Sec 1109 On-Street Parking
Sec. 1109.1 General: Car and van on-street parking spaces shall comply with
1109.
ADOT has “No comment” on this section.
Sec. 1109.2 Parallel Parking Spaces: An access aisle at least 60 inches (1525
mm) wide shall be provided at street level the full length of the parking space.
The access aisle shall connect to a pedestrian access route serving the space.
The access aisle shall not encroach on the vehicular travel lane.
EXCEPTION: An access aisle is not required where the width of the sidewalk
between the extension of the normal curb and boundary of the public right-of-way
is less than 14 feet (4270 mm). When an access aisle is not provided, the
parking space shall be located at the end of the block face.
ADOT requests further clarification of this guideline before deciding whether we
support it.
Sec. 1109.3 Perpendicular or Angled Parking Spaces: Where perpendicular or
angled parking is provided, an access aisle 96 inches (2440 mm) wide minimum
shall be provided at street level the full length of the parking space and shall
connect to a pedestrian access route serving the space. Access aisles shall be
marked so as to discourage parking in them.
ADOT cannot support this guideline as written because the incremental value of a
ninety-six (96-in) wide access aisle over the currently used sixty-inch (60-in)
wide access aisle has not been established.
Sec. 1109.4 Curb Ramps or Blended Transitions: A curb ramp or blended transition
complying with 1104 shall connect the access aisle to the pedestrian access
route.
ADOT supports this guideline in concept, noting however the comments regarding
the 1:48 slope (see comments on Sec. 1104.2.1.2 Cross Slope and Sec. 1104.2.1.3
Landing, above).
Sec. 1109.5 Obstructions. There shall be no obstructions on the sidewalk
adjacent to and for the full length of the space.
EXCEPTION: This provision shall not apply to parking signs complying with 1109.6
and parking meters complying with 1109.7.2.
ADOT supports the proposed guideline as written.
Sec. 1109.6 Signs: Parking spaces shall be designated as reserved by a sign
complying with 502.6. Signs shall be located at the head or foot of the parking
space so as not to interfere with the operation of a side lift or a passenger
side transfer. (Sec. 502 Parking Spaces can be found on the Access Board website
at http://www.access-board.gov/ada-aba/html/tech-05.hmtl)
ADOT supports the proposed guideline as written.
Sec. 1109.7 Parking Meters: Where parking meters are provided, they shall comply
with 1109.7.
ADOT supports the proposed guideline as written.
Sec. 1109.7.1 Operable Parts. Operable parts shall comply with 309. (Sec. 309
Operable Parts can be found on the Access Board website at http://www.access
board.gov/ada-aba/html/tech-03.hmtl)
ADOT supports the proposed guideline as written.
Sec. 1109.7.2 Location: A parking meter shall be located at the head or foot of
the parking space so as not to interfere with the operation of a side l or a
passenger side transfer.
EXCEPTION: Where parking meters are not provided at the space, but payment for
parking in the space is included in a centralized collection box or paying
station, the space shall be connected to the centralized collection point with a
pedestrian access route.
ADOT supports the proposed guideline as written.
Sec. 1109.7.3 Displays and Information.’ Displays and information shall be
visible from a point located 40 inches (1015 mm) maximum above the center of the
clear floor space in front of the meter.
ADOT supports the proposed guideline as written.
Sec. 1110 Call Boxes
Sec. 1110.1 General: Call boxes shall comply with 1110.
ADOT has “No comment” on this section..
Sec. 1110.2 Operable Parts: Operable parts shall comply with 308 and 309.4.
Where provided, labeling shall comply with 703.2 and 703.3. (Sec. 703 Signs can
be found on the Access Board website at http.//www.access-board.gov/ada-aba/html/tech-07.hmtl)
EXCEPTION: Mechanically operated systems in which the signal is initiated by a
lever pull shall be permitted to have an activating force of 12 lbf (53.4 N)
maximum.
ADOT supports the proposed guideline as written.
Sec. 1110.3 Turning Space: A turning space complying with 304 shall be provided
at the controls. (Sec. 304 Wheelchair Turning Space can be found on the Access
Board website at http.//www. access-board.gov/ada-aba/htm l/tech-03.hmtl
ADOT supports the proposed guideline as written.
Sec. 1110.4 Edge Protection: Edge protection complying with 405.9.2 shall be
provided where the area at the call box is adjacent to an abrupt level change.
(Sec. 405.9.2 Curb or Barrier can be found on the Access Board website at
http://www.access-board.gov/ada-aba.html/tech-04.hmtl)
ADOT supports the proposed guideline, but would request further clarification
regarding the terms “abrupt level change” and “edge protection”.
Sec. 1110.5 Motor Vehicle Turnouts: Where provided, a motor vehicle turnout
shall have a minimum paved area of 16 feet (4880 mm) wide minimum and 23 feet
(7015 mm) long minimum and shall connect to the turning space at the call box
with a pedestrian access route complying with 1103. Where shoulder texturing is
used, it shall be discontinued at the turnout.
ADOT supports the basic guideline, but question the requirement of a
sixteen-foot (1 6-ft) wide paved area. Provision of a thirteen-foot (1 3-fl)
wide paved area is sufficient to provide for an eight-foot (8-ft) wide parking
space and a five-foot (5-fl) wide access and the incremental value of an
eight-foot (8-ft) wide access route has not been established route (see comment
for Sec. 1109.2 Parallel Parking Spaces, above).
Sec. 1110.6 Two- Way Communication: Where provided, two-way voice communication
shall comply with 1110.6, 708.2 and 708.3. (Sec. 708 Two-Way Communication
Systems can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-07.hmtl)
ADOT has “No comment” on this section.
Sec. 1110.6.1 Volume Controls: Volume controls complying with 704.3 shall be
provided (Sec. 704.3 Volume Control Telephones can be found on the Access Board
website at http.//www. access-board.gov/ada-aba/html/tech-07.hmtl)
ADOT has “No comment” on this section..
Sec. 1110.6.2 TTY A TTY complying with 704.4 shall be provided (Sec. 704.4 TTYs
can be found on the Access Board website at http://www.access-board.gov/ada-aba.html/tech-07.hmtl)
ADOT has “No comment” on this section.
Sec. 1111 Alternate Circulation Path
Sec. 1111.1 General: Alternate circulation paths shall comply with 1111.
ADOT supports the proposed guideline as written.
Sec. 1111.2 Width: The alternate circulation path shall have a width of36 inches
(915 mm) minimum.
ADOT strongly supports the guideline requirement for the alternate circulation
path minimum width of thirty-six inches (36 in).
Sections 1111.3 Location: The alternate circulation path shall parallel the
disrupted pedestrian access route, on the same side of the street.
ADOT strongly opposes this guideline’s requirement for the “Alternate
Circulation Path” to be located on the same side of the street as the disrupted
PAR. This provision would impose a central-planning approach to traffic control
for construction and maintenance operations, and would negatively impact
pedestrian comfort and safety while creating an unreasonable burden upon State
and local agencies. This provision does not appear to consider the following: A)
the length of time a project is underway; B) the type and nature of the project;
C) the probable negative impact upon the other users of the transportation
facility due to reduced roadway capacity; D) the advisability of and risk
inherent in moving pedestrians adjacent to construction or maintenance
operations; E) the impact of noise on the pedestrian; nor F) the impact to
construction programs, in terms of time and money spent on meeting this
guideline.
This proposed guideline is also contrary to guidance provided by the Manual on
Uniform Traffic Control Devices (MUTCD), Section 6D.O I Pedestrian
Considerations This section of the MUTCD delineates three considerations, of
which the first two address this matter. They are as follows:
A. Pedestrians should not be led into conflicts with work site vehicles,
equipment, and operations. and
B. Pedestrians should not be led into conflicts with vehicles moving through or
around the work site.
Further clarification is provided in the MUTCD on page 6D- 1 as, “Pedestrians
should be appropriately directed with advance signing that encourages them to
cross to the opposite side of the roadway.” (emphasis added) and 6D-2 as,
“Whenever it is feasible, closing off the work site from pedestrian intrusion
may be preferable to channelizing pedestrian traffic along the site with
temporary traffic control devices such as cones, tubular markers, barricades and
drums, or other suitable fencing.”
Sec. 1111.4 Protection: The alternate circulation path shall comply with 307 and
shall be protected with a barricade complying with 1111.6 to separate the
pedestrian access route and alternate circulation path from any adjacent
construction, drop-offs, openings, or other hazards.
ADOT cannot support this guideline because the Alternate Circulation Path should
not be adjacent to construction or maintenance operations (see comment on Sec.
1111.3 Location, above).
Sec. 1111.5 Signs: Signs complying with 703.5 shall be provided at both the near
side and the far side of the intersection preceding a disrupted pedestrian
access route. . (Sec. 703.5 Braille can be found on the Access Board website at
http://www.access-board.gov/ada-aba/html/tech-07.hmtl)
ADOT strongly supports the placement of signs, at both the near side and far
side of the intersections preceding a disrupted PAR, encouraging all pedestrians
to cross to the opposite side of the roadway wherever possible (see comment on
Sec. 1111.3 Location, above).
Sec. 1111.6 Barricades: Barricades shall be continuous, stable, and non-flexible
and shall consist of a solid wall or fence or a Type II or Type III barricade as
specified in MUTCD section 6F-60 with the bottom or lower rail 1-1/2 inches (38
mm) maximum above the ground or walkway surface, and the top of the fence, wall
or upper rail 36 inches (915 mm) minimum above the ground or walkway surface.
Barricade support members shall not protrude beyond the barricade face into the
pedestrian access route or alternate circulation path.
ADOT cannot support this guideline as written because no temporary barricade
system is totally “non- flexible”; temporary barricades differ by how much
rigidity they provide. The proposed guideline would also prohibit the use of
both Type II and Type III temporary barricades to define the alternative
circulation path because they use “T-type” supports that would encroach into the
path. Temporary concrete barrier (TCB), which can move up to three feet (3 ft)
laterally when struck, would meet most of the intent of this guideline, however,
TCB should not be used arbitrarily. Sound engineering judgment should be used to
determine, on a case-by-case basis, the advisability of introducing another
hazard (the TCB itself) onto the project. Indiscriminate use of TCB could put
the public’s health, safety, and welfare at risk.
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