City of Palm Springs
Department of Public Works and Engineering
Palm Springs, CA  92262

Re:  Comments Regarding “Draft Guidelines for Accessible Public Rights-of-Way” 

Enclosed, please find the comments provided by myself, the Director of Public Works/City Engineer, and Phil Kaplan, the ADA Coordinator for the City of Palm Springs. 

Sincerely, 
David J. Barakian
Director of Public Works/City Engineer

Comments Regarding “Draft Guidelines for Accessible Public Rights-of-Way”

Additions and Alterations (1102.2), 2^nd Paragraph, 2^nd Sentence:  But if you’re just reconstructing the pavement and not touching the curbs or sidewalks, it doesn’t seem logical you should be required to reconstruct curbs and sidewalks to make them compatible. 

Alternate Circulation Path (1102.3, 1111), 1^st Paragraph, 1^st Sentence:  Where feasible? 

Pedestrian Access Route (1102.4), (1103):  I recommend that clearer guidance be given with respect to sidewalk cross slope through a drive approach, i.e. does a 48-inch “flat” area need to be provided around the approach in areas with curb adjacent sidewalk to avoid the large cross slopes in approaches?  Also, I recommend the issue of sidewalk or pedestrian access adjacent to bay parking areas to be addressed.  I feel sidewalks should not be allowed behind vehicles parking in “bays” 90 degrees to the centerline of the street.  The sidewalks should go around the bays and be in front of the parked vehicles or bay parking should be discouraged in pedestrian areas.  

Grade (1103.5), 1^st Paragraph, 3^rd Sentence:  What about cross slopes and drive approaches.  Need to specify what the regulation is for sidewalk at drive approaches with respect to cross slope. 

Surface Gaps at Rail Crossings (1103.7), 1^st Paragraph:  What about gaps at bridge joints? 

Curb Ramps and Blended Transitions (1102.6, 1104), 1^st Paragraph:  What is permitted lip?  ½”?  Flush?  Or what?  If single ramp can go within crosswalk width, then why not? 

Pedestrian Signal Phase Timing (1105.3), 1^st Paragraph:  This would result in longer cycle lengths and therefore more vehicle delay and lower level of service – what data justifies 3 fps?  Define from where to where or in accordance with Traffic Manual? 

Pedestrian Overpasses and Underpasses (1105.5), 1^st Paragraph:  What about if it is privately owned i.e. not for public but spans a public street? 

Roundabouts (1105.6):

2^nd Paragraph, 1^st Sentence:  This defeats part of the purpose of roundabouts.  3^rd Sentence:  Cross at intersection before or after, if you can’t cross unless traffic must stop. 

3^rd Paragraph:  Signals should not be installed unless warranted for pedestrians. 

Accessible Pedestrian Signal Systems (1102.8, 1106), 2^nd Paragraph:  All signals must have an audible Tone?  3^rd Paragraph, 1^st Sentence:  Pedestrian ONLY signals not at intersection or what?  Need to be clear. 

Street Furniture (1102.9, 1107), 1^st Paragraph:  Does this apply to restaurant tables in the right-of-way? 

1102.2.2 Alterations:  Impossible to interpret this. 

1102.8 Pedestrian Crossings:  Is every crosswalk a pedestrian crossing? 

1102.9 Street Furniture:  Not customers of a restaurant? 

1105.3 Pedestrian Signal Phase Timing, 2^nd Sentence:  Major divergence from current Caltrans guidelines vehicle delay will result.  Currently it is 4fps from curb to center of lane opposite the far curb.

1105.6.2 Signals:  With audible tone and vibro tactile indications? 

1109.2    Parallel Parking Spaces:  These need a drawing to explain.