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Leslie Salgado-Tamayo
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October 28, 2002 |
Sincerely,
Leslie Salgado-Tamayo
Chief, ADA and Special Projects,
Facilities Engineering Maryland Transit Administration
Maryland Transit Administration (MTA) –
Comments on the
“Draft Guidelines for Accessible Public Rights-of-Way”
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.
MTA’s comment
- What constitutes an “alteration”? We need more definite guidelines. This is not a new problem with ADAAG.
- We need a better definition of “maximum extent feasible”. Is there a dollar amount? More guidance needed.
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.
MTA’s comment
- Refer to comment under 1111.
1102.7 Pedestrian Signs. Signs for pedestrian use shall comply with 1102.7.
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.
MTA’s comment
- It is not clear if providing bus route identification signs, at bus shelters, in raised and Braille characters is required only where bus route identification signs in compliance with 703.5.5 are provided. If required, at bus shelters, what are the recommended placement locations, since shelters don’t have doors?
1102.8 Pedestrian Crossings. Where a pedestrian crossing is provided, it shall comply with the applicable provisions of 1105.
MTA’s comment
- See comment under Section 1105.
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.
MTA’s comment
- “2 inch wide strip of color contrasting with the tread and riser” is a new requirement that will increase costs of maintenance.
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.
MTA’s comment
- This increases the minimum clear width from 36 to 48 inches. This requirement will result in increased construction costs and, in some cases require additional right-of-way. We recommend that you allow 36 inches where providing 48 inches is not feasible.
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 2-½ inches (64 mm).
EXCEPTION: On tracks that carry freight, a maximum horizontal gap of 3 inch (75 mm) shall be permitted. .
MTA’s comment
Allowing the 3-inch gap helps clear an ongoing problem where transit agencies provide their services via tracks owned by freight companies.
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.
MTA’s comment
- This reflects the new increased width of sidewalk (from 36 to 48 inches). This will result in increased construction costs and, in some cases require additional right-of-way. We recommend that you allow 36 inches where the sidewalk is allowed to be 36 inches wide.
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.
MTA’s comment
- This reflects the new increased width of sidewalk (from 36 to 48 inches). This will result in increased construction costs and, in some cases require additional right-of-way. We recommend that you allow 36 inches where the sidewalk is allowed to be 36 inches wide.
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.
MTA’s comment
- What constitutes a drop-off where a “barrier” would be required?
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.
MTA’s comment
- This is a new requirement that will create tripping hazards and the resulting liability as well as increased maintenance costs.
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.
MTA’s comment
- Diagram needed in order to better understand this requirement.
1105.2 Crosswalks. Crosswalks shall comply with 1105.2.
1105.2.1 Width. Marked crosswalks shall be 96 inches (2440 mm) wide minimum.
MTA’s comment
- This is an increase of two feet over MUTCD’s 72 inch minimum width for marked crosswalks. This will result in increased construction and maintenance costs.
1105.2.2 Cross Slope. The cross slope shall be 1:48 maximum measured perpendicular to the direction of pedestrian travel.
MTA’s comment
- Meeting this requirement may be highly unrealistic when dealing with existing roads or parking lots that are being upgraded.
1105.5 Pedestrian Overpasses and Underpasses. Pedestrian overpasses and underpasses shall comply with 1105.5.
1105.5.1 Pedestrian Access Route. Pedestrian overpasses and underpasses shall contain a pedestrian access route complying with 1103.
1105.5.2 Running Slope. The running slope shall not exceed 1:20 maximum.
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.
MTA’s comment
- This new requirement will have major design, construction, maintenance and safety impacts on our agency. The need to have a limit to the maximum rise for a ramp is understandable. However, 60 inches appears to be unreasonable. We recommend that some latitude be provided.
1111 Alternate Circulation Path
1111.1 General. Alternate circulation paths shall comply with 1111.
1111.2 Width. The alternate circulation path shall have a width of 36 inches (915 mm) minimum.
1111.3 Location. The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street.
MTA’s comment
- Providing a 36 inch min. alternate circulation path on the same side of the street places unrealistic restrictions that will result in longer duration of project and higher construction costs. Adding the words “Where feasible” at the beginning of 1111.3 would provide some flexibility.