Robert W. Bronkall, P.E.

October 28, 2002

RE: COMMENTS ON DRAFT ADA GUIDELINES FOR PUBLIC RIGHT OF WAYS


The Access Board should be applauded for taking on the challenge of creating
guidelines for public right of ways. It seems that whenever guidelines are
developed, it is based upon a “one size fits all” approach. Unfortunately, it
appears that new guidelines do just that and create situations that are
technically infeasible to build. The following are my concerns based upon
reading the draft guidelines.

1. The document (www.access-board.gov/rowdraft.htm) is presented with a
narrative text to explain what the actual text says. This is an indicator that
the actual text of the guidelines is insufficient or too complicated. The
actual text should be written in plain language so that anyone can understand
it. A simple solution is to replace the actual text with the narrative text.
Please refer to 49 CFR 26 (a) as an example of a fairly well written text.

2. The narrative text for Section 1102.2 hints about exemptions for
handling technically infeasible cases, such as constraints posed by existing
right of way or existing construction. The actual text for Section 1102.2 does
not specifically include those exemptions. The text should be changed to
include specific examples of exemptions as well as guidelines for unforeseen
situations.

Also, the actual text should include an exemption for “land locked”
improvements. For instance, if an in-fill piece of sidewalk is constructed to
current ADA standards and connects to two pieces of existing inaccessible
sidewalk, the new improvements while being ADA compliant is still technically
inaccessible since there is no way to get to the new improvements.

3. Section 1103.4 specifies a maximum cross slope of 1:48 (2%). In
general, this guideline works fine until a steep intersection is reached. At a
steep intersection it is technically infeasible. Example: An existing
collector road has a constant grade of 10% and a side road connects to the
collector road to form a T intersection. As the side road approaches the
collector road, the side road is super elevated to 10% to match the collector
road. While the sidewalks on the side road can be kept at 2% for a while,
eventually the side road sidewalk must transition from the standard cross slope
(2%) into the grade of the collector road (10%). This would result in cross
slopes that exceed well beyond 2%. A simple solution is to establish 2% as the
preferred cross slope with the maximum cross slope to be no greater than the
super elevation of the road.

If intersection were built “Speed Table” style, with the intersection being
relatively “level” and the side streets immediately changing grade, this would
not be a problem. However, I would not recommend that new intersections be
built “level” due to roadway safety issues such as sight distances, stopping
sight distances, and the ease at which vehicles can be “launched” into the air.

4. Section 1104 specifies requirements for curb ramps. In general, these
guidelines work fine until a steep intersection is reached. At which point it
is technically infeasible to construct the curb ramp to the proposed
standards. Example: An existing collector road has a constant grade of 10%
and an existing side road connects to the collector road to form a T
intersection. As the side road approaches the collector road, the side road is
super elevated to 10% to match the collector road. While the sidewalks on the
side road can be kept at 2% for a while, eventually the side road sidewalk must
transition from the standard cross slope (2%) into the grade of the collector
road (10%). In this example, both the grades of the curb and the cross slope
sidewalk are constantly changing throughout the curb return. There will always
be one place on the curb return where the curb ramp cross slope would be
minimized, however, the cross slope would still be greater than 2%. However,
this location may not be the preferred location for the curb ramp. A decision
needs to be made: place the curb ramp with “less than desirable” slopes in a
bad location, or place curb ramp with “severe” slopes in a good location.

It is my suggestion that the all maximum grade/slope references to cross
slopes, flares, running slopes and landings be removed from the guidelines.
Instead a standard size curb ramp will be installed. The standard size curb
ramp would be based upon the relative grade changes to come up with uniform
dimensions. For a 6” curb, the ramp length would be 0.5’ divided by 8.33% = 6
feet; the flare dimension along the face of curb would be 0.5’ divided by 10% =
5 feet; and a landing or clear space will be 4 feet square. To minimize
hardship on pedestrians, cross slope grades should be minimized as much as the
site allows.

By making all curb ramps uniform in size, a sight impaired person would then
know that it is “three” steps before they enter the roadway. Obviously, grades
and cross slopes will be steeper on the ramp and pose a greater challenge to
some. But grade appears to be a less significant concern since sidewalk
grades can now be greater than 8.33% for an indefinite distance without having
any “level” rest areas. In addition, the proposed guidelines also specify a
maximum ramp length of 15 feet, which in some instances, will result in ramps
having a grade in excess of 8.33%.

5. Section 1105.2 specifies a maximum cross slope of 1:48 (2%). Again,
this guideline works fine until a steep intersection is reached. It is
technically infeasible at certain intersections. Example: An existing
collector road has a constant grade of 10% and a side road connects to the
collector road to form a T intersection. As the side road approaches the
collector road, the side road is super elevated to 10% to match the collector
road. In this case, as a pedestrian travels along the side road and wishes to
cross the collector road, the pedestrian will need to negotiate a 10% cross
slope (being the grade of the collector road), which is the grade of the
collector road.

If intersection were built “Speed Table” style, with the intersection being
relatively “level” and the side streets immediately changing grade, this would
not be a problem. However, I would not recommend that new intersections be
built “level” due to roadway safety issues such as sight distances, stopping
sight distances, and the ease at which vehicles can be “launched” into the air.

6. It is suggested that before the guidelines are implemented a field test
should be performed. A study would be conducted to retrofit a handful of
intersections with the guidelines. The proposed intersections should be ones
that are topographically challenged and have a high volume of disabled
pedestrian traffic. The study would monitor the travel of pedestrians prior to
the retrofit and after the retrofit. 90 to 180 days after the pedestrians have
used the retrofitted intersection, interviews can then be conducted with
pedestrians that use the sidewalk to determine the effectiveness of the
improvements.

If the survey indicates that changes are required, the intersections should be
re-retrofitted and a second interview should be conducted. The process can be
repeated to further refine the design elements that are most important.

7. Section 1105.6 specifies that pedestrian signals are required at cross
walks at roundabouts. The purposes of the roundabout is to improve the
vehicular traffic flow without the need to install a traffic signal. While a
roundabout may not be the most pedestrian friendly intersection, it serves a
purpose in lower volume urban roads where signals are not warranted. This
requirement would cause agencies to jump directly to traffic signals. It is
suggested that this requirement be removed from the text.

8. Section 1102.14 should provide an exemption for on-street parallel
parking. However, nothing should prohibit an agency from providing ADA
compliant parallel parking when necessary.

9. Section 1105 requires truncated domes as a warning device. Domes are
difficult for able persons to cross. An effective warning system is needed
that is easy for all persons to travel across. In addition, domes make it
difficult to completely remove snow from a cross walk. Further, snow remove
equipment may shave off the domes.

10. Also of concern is what level of modifications will require different
elements of the project site to be retrofitted for ADA compliance?

(a) Would any of the following require the installation of chirping
indicators at an intersection with an existing traffic signal and cross walk?
(i) an asphalt overlay project
(ii) changing the signal timing
(iii) adding a left (or right) turn signal head on an existing mast
(iv) replacing a traffic controller
(v) installing a new curb ramp in conjunction with an asphalt overlay
project
(vi) reconfiguration of the striping on a road
(vii) adding or deleting no parking areas along a road
(viii) replacing damaged curb and gutter
(ix) installing a storm drain line in the street

(b) Would any of the following require the retrofit of non-ADA compliant
sidewalk?
(i) an asphalt overlay project
(ii) changing the signal timing
(iii) adding a left turn signal head on an existing mast
(iv) replacing a traffic controller
(v) installing a new curb ramp in conjunction with an asphalt overlay
project
(vi) reconfiguration of the striping on a road
(vii) adding or deleting no parking areas along a road
(viii) replacing damaged curb and gutter
(ix) installing a storm drain line in the street

(c) Would any of the following require that new “in fill” sidewalk be
installed along a road where there is a patch work of sidewalk that is not
connected together?
(i) an asphalt overlay project
(ii) changing the signal timing
(iii) adding a left turn signal head on an existing mast
(iv) replacing a traffic controller
(v) installing a new curb ramp in conjunction with an asphalt overlay
project
(vi) reconfiguration of the striping on a road
(vii) adding or deleting no parking areas along a road
(viii) replacing damaged curb and gutter
(ix) installing a storm drain line in the street

11. Section 1111 involves providing alternate circulation path. In areas
where pedestrian traffic volume is low, exemptions should be provided
for “short duration” projects that will involve the temporary closure of the
sidewalk for less than 1 day. Obviously, projects that involve lengthy closure
of the sidewalk should provide an alternate circulate path if sufficient
roadway lane width and/or right of way permits. For short duration projects,
more time may be spent constructing and removing temporary access routes that
meet grade and cross slope requirements than the actual time spent doing the
original project.

The requirement for the alternate circulation path to be parallel to the
disrupted pedestrian access route and on the same side of the road is very
often not possible due to the nature of construction projects. In situations
where the entire right of way is being altered (or built) there is often no
safe area to establish a pedestrian access route. It is suggested that the
guidelines are changed to provide a alternate circulation path in the safest
and most direct route that is feasible within the scope of the construction
project.

In addition, on two lane road projects where the entire paved road is 24 feet
wide (or less), insufficient room exists to “shift” a pedestrian access route
(the unpaved shoulder) onto the road and still provide a one lane detour for
vehicles.

12. Section 1103 involves pedestrian access routes. In rural areas,
pedestrians often walk along a paved or unpaved shoulder. It appears that
these shoulders are considered part of the access route. Due to topography,
right of way constraints, and flood control purposes cross slopes often exceed
2%, and widths are almost always less than 4 feet from the edge of the fog line
to the edge of the shoulder. Over-side drains, guard rails, berms, dikes,
mailboxes, utility poles, and headwalls often project into the shoulder area.

On rural roads, flattening the shoulders will often increase the depth of a
roadside ditch, which can decrease roadway safety. It is not always possible
to raise the grade of the ditch due to topography/drainage, or if the ditch has
been classified as a wetland and/or is habitat for endangered animals.

It is suggested that shoulders (paved or unpaved) are exempted from these
provisions.

Thank you for allowing the opportunity to comment on the proposed guidelines.

Sincerely,
_______________________________
Robert W. Bronkall, P.E.
Civil Engineer