SECTION

DRAFT GUIDELINE

COMMENTS

Background introductory comments

Why do the draft guidelines have areas that “depart from the advisory committee’s report” in several areas?

Why is “pedestrian access route” referred to as a portion of the “public” right-of-way that serves an accessible route?  There are pedestrian access routes on private business properties that have the same ADA requirements of providing access.  Sometimes providing too many terms becomes confusing.  Can the word “public” be deleted?

1101.3

Defined Terms

For “Detectable Warning” ADD the word “pedestrian” prior to “circulation path”

For “Public Right-of-Way” ADD the word “public” before “transportation purposes”

1102

Compliance in alterations is required except where it is “technically infeasible”.

“such work might be technically feasible … where acquiring additional R/W is practicable”.

Who should be making the final determination of technical infeasibility?   Currently VDOT makes this determination in conjunction with our local FHWA office.   The background comments to the draft say “Determinations of technical infeasibility must be made on a case-by-case basis in relation to each project’s unique conditions.”  The purchase of additional R/W may put the project over budget and thus make it financially infeasible. Does technically infeasible also include financial constraints?  The background portion of the document indicates that a subcommittee of advisory committee members is currently developing a guide on “accessibility in alterations” due out next year.  Is that document going to be issued within the same time frame of finalizing the requirements for Public Right of Way?

1102.1

General:

New Construction

“The draft Guidelines would not require the provision of sidewalks, street crossings, … where none are intended”.

The term “where none are intended” needs to be clarified as well as “who” makes that determination.

SECTION

DRAFT GUIDELINE

COMMENTS

1102.2.2.2

Prohibited reduction in pedestrian access facilities

It is not clear who should determine (or how is it determined) if there is a net reduction.

1102.3

Alternate circulation path

It may not be feasible to provide continuous circulation on the same side of the road during construction, or even along the roadway due to limited work areas.

The requirement for a ridged barrier may not be the most economic separation of pedestrian traffic from the construction work area. Would using orange plastic fence or snow fence be considered an acceptable option?

1102.5.3

Reduced Vertical Clearance

ADD “ed” to “finish” in the last phrase “finished floor or ground”.  Same change to the following paragraph under “EXCEPTION”.

1102.10

Stairs

This requires stair treads to have a 2 inch wide strip of color contrasting with the tread and riser, the full width of the front edge of each tread.  The word “slip resistant” should be added since there are some materials that may be deemed “contrasting” but would cause a more slippery edge to the step.

1102.12

Vertical access for

pedestrian overpasses and underpasses

The requirement to require an elevator or limited use elevator for applications where the rise of the ramp approaches or exceeds 60 inches may make the project infeasible due to the additional cost associated with construction and maintenance. Also, there could be security issues.  We have had projects where the terrain has permitted us to use multiple ramps and landings in a “switch-back” design that meets the maximum grade requirements for ramps without providing an elevator.  We would like to be given the flexibility to be allowed to continue this practice.

1102.14

On street parking

Should this requirement be limited to commercial/business districts? Should consideration be given to the number of spaces available within a block? In subdivisions, what would the impact be of placing a restricted space in front of someone’s home.  The advisory committee recommended applying ADAAG requirements (1 handicapped space for every 25 spaces provided) and the Board was concerned about confusion in applying that requirement to on-street parking.  We recommend using the 1 in 25 rule with the option of “adding additional spaces” upon request of users or localities during the design of projects or during the scoping of alteration projects based on type of adjoining business or community facilities or whether or not the parking is strictly residential.

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DRAFT GUIDELINE

COMMENTS

1103.3

Clear Width

Minimum width required for permanent pedestrian access routes is 48 inches.  The minimum width required in ADAAG is 36” for use by a person in a wheelchair.  We have physical constraints in some alteration projects which have restricted us to the minimum of 36 inches in the past.  If we will no longer be allowed that “exception”, will we be considered “not in compliance”? (see comments in 1111 where 36 inches is acceptable for alternate circulation paths).  VDOT has adopted a minimum sidewalk width of 60 inches, however, physical constraints in some instances could be a problem.

1103.6

Surfaces of pedestrian access routes

What is the requirement for compliance should settlement occur after construction (at what point will repairs be required). This could increase maintenance or construction costs if required to use a higher standard.  Is there any research currently underway or in a plan that would provide more definitive guidance on the requirements for meeting “stable, firm and slip-resistant”?

1103.7

Surface gaps at railroad crossings

We support the position that the exemption end 4 years after new technology is developed an approved. How do we ensure compliance when working with the railroad?

1104.2.2.1

Parallel Curb Ramps

Running Slope - EXCEPTION

This statement says “A parallel curb ramp shall not be required to exceed 15 feet in length.  To some users of the guidelines, they may find this difficult to determine whether that 15 feet is “two ramps coming down to a landing” or whether it refers to “each ramp” coming down to a landing.  We see the “parallel curb ramp” as being one item consisting of “two sloping ramps and one landing at the bottom”.  If this is the intent, the wording should be “the sloping portions of a parallel curb ramp shall not be required to exceed 15 feet”.  If the intent is that both sloping sides plus the landing, the wording should be “the overall dimension of a parallel curb ramp including both sloping sides and landing shall not exceed 15 feet.”

1104.2.2.4.

Parallel Curb Ramps

More information is needed to clarify the intent of “drop-offs at diverging segments shall be protected with a barrier”.  What type of barrier is intended here and what is the height of drop-off  that warrants the barrier?

SECTION

DRAFT GUIDELINE

COMMENTS

1105

Pedestrian crossings

Increasing the width of the crosswalk does not provide any enhanced safety to the pedestrian.  The painted lines do not prohibit the pedestrian from stepping outside the line if they needed to get around another pedestrian. The extra two feet that the vehicle is required to set back from the intersection may limit sight distance thus affecting right turn on red (capacity issue)  This proposed regulation should not be more strict than the MUTCD (which only requires 72 inches instead of the proposed 96 inches in these guidelines) since one of the related issues is where to place the stop bar for vehicles in relation to the marked crosswalk.

1105.2.2

Cross slopes

This section needs to be looked at from a constructability standpoint. Examples on super elevated roads.

1105.3

Pedestrian Signal phase timing

What impact will this have on intersections that currently have capacity problems? Will this change require intersection modifications due to increased phasing time and decreased capacity?

1105.6

Roundabouts

The use of pedestrian signals can be costly and dramatically reduce any positive gains that are possibly obtain from the use of roundabouts. What makes this requirement any different from unsignalized intersections?

Also the addition of physical barriers for channeling of pedestrians can become a costly maintenance item as well as esthetically unpleasing.  A suggested physical separation that may enhance the roundabout design would be a utility strip such as we use along many sidewalk installations.  The designated crossings would be more defined with this added buffer strip to separate the pedestrians from vehicular traffic and to then direct them to the crossing locations through installation of curb ramps.

1105.7

Slip lanes

The use of pedestrian activated signals could be a costly retrofit.

SECTION

DRAFT GUIDELINE

COMMENTS

1108

Detectable warning surfaces

What are the allowable tolerances in order to be in complains with ADAAG?  Since the dimensions are given in decimal units in imperial measure, what allowance would be acceptable for fractional units used for construction methods?

The fact that the detectable warning surface is now only required to cover a 24-inch wide portion of the bottom of the ramp instead of covering the entire ramp is both a cost savings and a way of minimizing the impact to wheel chair users.

The fact that this part of the ADAAG became “regulation by default” is very disturbing.  This requirement had been temporarily suspended due to concerns raised about the specifications, the availability of complying products, maintenance, usefulness, safety, and the need for further study.  The suspension EXPIRED in July 2001, and thus became LAW. 

The advisory committee deliberated on whether or not detectable warnings should only be required for those curb ramps that had a slope of 1:15 or less (maybe assuming that anything steeper would be detectable from the change in slope).  We feel the Board should research this change to determine if there is evidence to support the value of requiring detectable warnings on all curb ramps.

1108.13

Contrast

What impact will time and weather have on maintaining the desired contrast?

1111.2

Alternate Circulation Path

Minimum width of 36 inches is required, yet the minimum width required under 1103.3 for permanent pedestrian access routes is 48 inches.  The minimum width required in ADAAG is 36” for use by a person in a wheelchair.  We have some physical constraints in some alteration projects which have restricted us to the minimum of 36 inches in the past.