A. Marvin Munzenmaier
|
October 25, 2002 |
CITY OF EL CAJON DEPARTMENT OF PUBLIC WORKS
The following are the City of El Cajon’s comments regarding the “DRAFT ADA
GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY ISSUED BY THE ACCESS BOARD ON
JUNE 17, 2002”:
The overall guidelines do not differentiate between the rights-of-way
characteristics of different regions in the Country. For example, the
infrastructure of Southern California is very different than other major cities
on the east coast. The proposed guidelines seem to require a "wide brush"
approach for all types of street systems in the Country.
We ask that a second draft of the proposed guidelines be circulated for
additional review and comment. The second draft should incorporate the comments
and concerns expressed by the different agencies.
The proposed guidelines must include definitions for the following terms, or
phrases that are commonly used throughout the document:
• “New Construction”. The common understanding in the municipal engineering
field is that new construction means the installation of new infrastructure in
newly developed areas.
• “Additions”. This term is vague and can be open to various interpretations.
The addition of certain components of infrastructure such as underground
utilities or traffic signals should not prompt the implementation of the
guidelines. An addition should be defined as the widening or extension of a
street segment, which would normally involve the installation of all components
of infrastructure.
• “Alterations”. This term is also vague and can be open to various
interpretations. Maintenance projects such as pavement overlays and surface
treatments are not alterations but simply maintenance measures to preserve and
extend the life of pavement. An alteration should be defined as the
reconstruction of a given street segment. Reconstruction should be defined as
the full removal and replacement of surface and subsurface improvements in
already developed areas.
Also a definition of “Blended Transitions” should be included, and the proposed
definition of “Street Furniture” seems to be overly broad and should be revised.
The paragraphs under the additions and alterations section include several
ambiguities with respect to type of work, project limits and extent of
compliance with these guidelines. Some of the phrases that are unclear are:
“substantial reconstruction”, “less extensive projects”, “limited improvements”
and “maximum extent possible”. Phrases like these are vague and cause
implementation difficulties.
The following are comments that pertain to specific sections of the draft
guidelines:
1102 Scoping Requirements
The discussion of provisions indicates that pedestrian elements are not required
where none are intended. However, that interpretation is unclear from the
wording of 1102. The discussion also indicates only the elements affected by
construction have to comply with the provisions, but there appears to be areas
of easy misinterpretation such as 1102.4 which states, “The pedestrian access
route shall connect to elements required to comply with Chapter 11.”
The requirement to acquire right-of-way where “practicable” may have a chilling
effect on projects, which may be technically feasible but have a requirement to
purchase right-of-way from an unwilling seller. Most jurisdictions have the
right to exercise eminent domain provisions, however, that is a very burdensome
and expensive process and may force policy makers to abandon a worthy project
rather than overcome those burdens.
In 1102.6 there is a conflict in the requirement to have the ramp located within
the width of each crosswalk and the desire of the advisory committee to
discourage single ramp installations when there are not marked crosswalks and
48” sidewalks are attached to the back of the curb head. The “unmarked
crosswalk” definition, clarifying that a crosswalk is the extension of sidewalk
lines, means that only a single combined ramp could be constructed for the ramps
to be located within the unmarked crosswalks.
1103 Pedestrian Access Route
On some projects the minimum clear sidewalk width of 48” is infeasible. A 36”
minimum clear width should be allowed as an exception to the 48” minimum. The
“changes in level” section needs to be clarified. It is unclear how to interpret
the meaning of “Changes in level shall be separated horizontally 30 inches
minimum.”
1104 Curb Ramps and Blended Transitions
The wording seems to imply that ramps can only be parallel or perpendicular.
Many times crosswalks are skewed and the allowance of a ramp parallel to the
crosswalk (but not perpendicular to the road) might provide better direction. In
1104.2.1.1 & 1104.2.2.1, it is not obvious why there would be a concern for
specifying a minimum slope.
In 1104.2.2.4 it is unclear what a “barrier” entails.
In 1104.3.2 it is our contention that detectable warnings should only be
required for ramps with slopes of 1:15 or less.
In addition, it is unreasonable to treat changes in level greater than /2” as a
ramp or curb ramp. Also, the requirement to install 2 ramps at each curb return
should apply to new construction projects only.
1105 Pedestrian Crossings
In 1105.2.1 the marked crosswalk width is increased from the MUTCD minimum width
of 6 ft. to 8 ft. While this is not much of a hardship on jurisdictions it does
raise an area of concern about the general misconceptions of marked lines on the
roadway. The discussion seems to indicate the extra width will help those with
vision impairments and those who use wheelchairs to pass. Two thoughts about
that concept: 1) the marking material does not provide a “magic zone of
protection” nor does it in any way constrain or confine pedestrians — any
pedestrian can reasonably step beyond the edge of any crosswalk boundary and 2)
there is absolutely no requirement to mark any crosswalk. Therefore, the
necessity to exceed the MUTCD widths appears to have no basis.
In 1105.2.2 the maximum cross slope of 1:48 will require “tables” at each
intersection which will degrade the ride-ability of vehicular traffic and may
compound grade problems in mid-block sections of steep roadways.
The 1:20 maximum running slope as specified in 1105.2.3 will not work on higher
speed roadways with “tee” intersections located on horizontal curves. The super
elevation requirements of the through roadway may routinely be as much as 8% or
9%. To reduce this to 5% or less will potentially compromise the safety of the
motoring public.
1105.3 Pedestrian Signal Phase Timing
The requirements of 3 feet per second as the maximum walking time and increasing
the distance to include ramp lengths have the potential for significant
unintended consequences. Most jurisdictions are now timing pedestrian clearance
intervals based on the character of the intersection. Usually, if there is a
demonstrated need for longer clearance times, the jurisdiction will accommodate
that need. However, to mandate increased crossing time when there is not a
demonstrated need will cause unnecessary vehicle delay, which can be directly
related to increased accidents at intersections as well as amplified driver
frustration. This mandate clearly needs to be linked to a demonstrated need for
each individual intersection. Our recommendation would be to require
jurisdictions to develop pedestrian clearance timing in concert with the
disabled community, based on the specific requirements of the specific location.
In 1105.4 the width of the median island is not specified. We would assume it to
be 48”, however, the discussion contained in the crosswalk width section could
lead one to assume the minimum width should be 96”. This should be clarified.
1105.5 Pedestrian Overpasses and Underpasses
The requirement to install an elevator or limited-use elevator for applications
where the rise of a ramped approach exceeds 60 inches, will also have unintended
consequences. Since this is a discretionary structure and there are very few
areas that will have a ramped approach of less than 60” a jurisdiction will, in
many cases, forgo the installation of the overpass rather than come up with the
significant additional funds to construct and maintain an elevator. Also, this
requirement is not practical and can be dangerous for the public. An
unsupervised elevator, if it became disabled, would be a dangerous situation for
the passengers. This does not address the construction or maintenance costs of
those elevators, along with the public liability of crimes against the public in
an unsupervised enclosed area. The homeless population will use the elevators at
night and possibly during the day. Some overpasses are located away from
populated areas, and bringing electric power to those locations would be an
unreasonable cost. This would be a bad regulation and violation of the public
trust. Our recommendation would be to have “resting platforms” at appropriate
intervals, like other ramps.
1105.6 Roundabouts
The requirements proposed in this section are not consistent with accessible
pedestrian considerations in other areas. There will also be unintended
consequences associated with these requirements if implemented.
In 1105.6.1 the requirement to install a continuous barrier is not consistent
with other applications where pedestrians are prohibited, yet barriers are not
required. The positive guidance approach is the best way to handle the concern
of pedestrians wandering through the center of the roundabout. As shown in the
discussion page picture, sidewalks and ramp locations can better address
pedestrian channelization than ugly, hard to maintain, hazardous barriers. Also,
as a matter of consistency, if barriers are required here they should also be
required at all “high-design” intersections and even in mid-block locations to
prohibit pedestrian crossings.
In 1105.6.2 the requirement for signalization on every leg of a roundabout
defeats the original purpose of the roundabout concept. Thousands of low-volume,
neighborhood roundabouts are being built, many as traffic calming devices. To
require signals on every leg is tremendously cost prohibitive and does not
ensure additional safety benefits. An unintended consequence may be an explosion
of drivers pushing the red light and disrespect for these signals specifically
and all signals generally if numerous unwarranted signals are installed where
drivers perceive they are being stopped unnecessarily. A fundamental concept for
roundabout crosswalks is the designer must treat each crossing as a mid-block
crosswalk, both in theory and in design. The access board discussion states,
“Because crossing at a roundabout requires a pedestrian to visually select a
safe gap between cars that may not stop, accessibility has been problematic.”
However, this same problem exists at every mid- block crosswalk! If there is a
mandate to require signals here then the argument could be made that every
crosswalk everywhere should be signalized. Obviously, this is a preposterous
argument, but that is why we use engineering criteria and judgment — so that a
rational balance of perspectives is maintained. Again, the user community has
the ear of jurisdictions and specific needs for each crossing can easily be
accommodated without the imposition of a far-reaching, harsh standard.
1105.7 Turn Lanes at Intersections
There are literally thousands of existing “slip” lanes at non-signalized
intersections and this design is continuing to be built. The imposition of this
requirement would essentially eliminate slip lane design for non signalized
intersections. This would have the unintended consequence of increased
congestion, which would also increase intersection accidents. We believe a
better solution would be to require jurisdictions, in consultation with the
disabled community, to evaluate the signalization of slip lanes at signalized
intersections.
1106 Accessible Pedestrian Signal Systems
We generally agree with the proposal to require pedestrian signal devices that
provide better information and guidance for the pedestrian, even though there
will be a slight increase in installation costs. However, there is a precision
to the location dimensions that many times simply cannot be met. The “location”
wording should be changed to communicate the concept as a guidance statement
without making it a mandate.
In 1106.4 the one area we would object to is the requirement “. . .of tactile
and visual signs on the face of the device or its housing or mounting indicating
crosswalk direction and the name of the street. . .“. Tactile street name signs
are not required at any other location and to require them on pedestrian
crossing hardware changes these devices from “off the shelf’ equipment to custom
devices. This makes them almost impossible to effectively maintain.
1109 On-Street Parking
The majority of streets being built in El Cajon each year are in typical
residential neighborhoods. To require an indented, signed, handicap space on
every residential block is surely not what the committee intended. We would
suspect the concern is associated only with areas where there are parking meters
or time limited parking, such as in business areas. Our recommendation would be
to require such handicap spaces only in business or commercial areas.
In 1109.2 Parallel Parking Spaces — the requirement to provide a 60” access
aisle is extremely burdensome and will have significant unintended consequences
that will restrict our ability to help the disabled community. Currently we
install handicap signs in both residential and business areas quickly and easily
to accommodate individual and varying requests. The five-foot indent is simply
out of character in residential neighborhoods. With this requirement we will be
unable to continue our policy of “immediately taking care of the disabled
community.” In the future in order to install a handicap space we will have to
propose a capital project to construct a five ft. indent aisle. This means
projects will have to compete with other city projects for very limited funds
and, even if funded, would have large time delays before completion. It also
means we would be unable to respond to changing needs by moving a handicap space
slightly. Once the space is installed we would lose our ability to quickly
change locations to accommodate specific requests. It is amazing how many times
we change sign locations. Our recommendation would be to eliminate this
requirement. It does not serve the best long-term interests of the disabled
community. In addition, the 5’ minimum height of handicap signs is in violation
of the minimum requirements of the MUTCD.
Passenger Loading Zones
The discussion text states a 5’ access aisle is required for each passenger
loading zone (PLZ). Again, as stated above in the handicap signing discussion,
this has the effect of limiting our ability to quickly install PLZ signing and
if these requirements are adopted we will not be able to install PLZ signs in
the accommodating manner that we have historically done. Access aisles adjacent
to PLZ zones should be eliminated as a mandated construction requirement.
1111 Alternate Circulation Path
The requirement to provide an alternate path is generally correct. However, the
requirement of a path only on the same side of the street, with no provision for
“reasonableness”, is not feasible in many instances. Many times the scope of
construction is such that no pedestrians can be accommodated and, in fact, the
forcing of pedestrians into this type of area may create an intolerable safety
hazard. Simply put, there are situations where pedestrians cannot or should not
be accommodated and must be moved to the opposite side of the street or in the
case of total street closures moved around an entire block. The guideline for
requiring alternate circulation paths should be a recommendation and not a
requirement.
In 1111.6 the requirement of a lower rail within 1 1/2” of the surface does not
make sense since railings only require a rail at 27” for detectability. The
restriction of non-flexible fencing material would appear to be an unnecessary
restriction. Plastic fencing products are now extremely strong, durable and easy
to install and would appear to accommodate the need to provide pedestrian
channelization and protection in a reasonable manner. The allowance of this
material would make it much easier for jurisdictions to require protection in
very short-term construction areas.
The above comments and suggestions should not be viewed as objections to the
concept of providing reasonable access for the disabled community. We, in the
City Of El Cajon, have historically been and continue to be in support of
reasonable accommodations within the right-of-way. We have been seeking
direction for uniformity of devices and installation practices for years. Our
desire is to communicate potential pit-falls and unintended consequences
associated with several of the proposed standards and our plea is for balance in
the regulations. Should you have any questions or need further clarification on
any of our comments, please contact Dennis Davies, Principal Civil Engineer at
[...].
Sincerely,
A. Marvin Munzenmaier
Director of Public Works
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