City of Sacarmento, Department of Public Works

To: Access Board

From: Michael A. Whipple, Public Works ADA Coordinator

Re: Public comments for draft Public Rights-of-Way Guidelines



I would like to submit the following comments regarding the Draft Guidelines for Accessible Public Rights-of-Way.

1102.3 Alternate Circulation Path

This would be a very cost prohibiting guideline when imposed as in the draft guidelines. It is not practical and/or cost effective to provide an alternate circulation path as stated in this section and section1111. Our City does provide an alternate circulation path when construction, maintenance or similar situations is going to impede the normal circulation path for any considerable amount of time. On the other hand it will increase the cost of our curb ramp program beyond the $5 million we spend annually now. Our program hardly ever blocks a whole intersection at one time to install a new curb ramp. An individual can cross the street and proceed on their way during the 4 days we are working on the new curb ramp(s). To have a contractor comply with what is being proposed would mean they would have to have many of the types of barricades required and then they would have to have a crew, which was just moving barricades on a daily basis. This also implies that at all locations there is the room to provide this alternate path and then you still have the problem of using some type of portable ramps to get people from the street to the sidewalk or vice versa. This would also impact areas where the sidewalk was not contiguous with the street and a garden/landscaping strip had to be crossed to get back to the sidewalk. This would then also impact the parking along the street as each space next to the corner would have to be blocked off and this would need to be done daily for one to seven blocks. As this picture unfolds it can be seen that many things would be impacted and another alternative for an alternate circulation path would need to be added to the guidelines.

This might be able to be worked out better if Section 1111.3 Location was reworked. A time limit for the amount of days an alternate circulation path would be needed could also solve this problem. This would mean something like if the regular circulation path is not available for 7 or more days and no alternate circulation path within a two block radius is provided then you would use the proposed guidelines. This section will have a large financial impact on doing curb ramps alone and with many cities already not up to speed this really could slow down reconstruction or retrofitting of curb ramps not to mention other areas it will impact that are not seen at this time.

1102.14 On-Street Parking

This guideline will not provide the needed parking for people with disabilities but will increase the placard abuse that is seen around the country and especially here in California. This guideline will also decrease regular on-street parking spaces in areas where a parking garage or lot is near and they (garages and lots) provide a number of disabled parking spaces. This would have an impact on cities in their downtown areas where parking is usually at a premium. Along with this guideline comes the new requirements for a curb ramp when the disabled space is parallel to the curb and the 60-inch access isle. The curb ramp issue can add a large expense to the entities already trying to pay for the curb ramps they are doing on the corners. This scenario could make an entity choose between curb ramps at the corner and whether they are single or dual and the curb ramp at the disabled parking space on that block face. The other area is the access isle and how that will impact the flow of traffic when you have one parking spot along the street, which sticks out five feet more than the rest. Also, what would happen when you have to provide the disabled parking spaces on each side of the street? You could have two scenarios with this street; 1) If both spaces where opposite each other on the street you would in essence create a bottle neck situation where lanes have to narrow to allow for the extra 10 feet of space needed for the two five foot access aisles which when put together like this would decrease the street by on lane to accommodate the access aisles. 2) To avoid the first scenario you stagger the disabled parking along the street so the spaces are not opposite each other, you then would create a snake like effect for the traffic using the street. This guideline will create dangerous scenarios and needs to be reworked to really create more and safer disabled parking.

Before moving on to the next comment I would like to make a statement about our Visual Community here in Sacramento. We have a strong, vocal and actively involved visual community representing both sides of the blind philosophies. The Council and the Federation make sure that at any meetings that are held in the Sacramento area they both have representatives there to make sure that their philosophies are heard and taken into consideration. The City of Sacramento takes a stand with these two organizations stating they represent a percentage of the visual community and I take the position that I represent the rest of those people out there who do not belong to one or the other of these groups. So what we try to achieve here is a balance for both sides and use our philosophy of "Trying to achieve the greatest amount of accessibility for the largest amount of people".

1104.3.2 Detectable Warnings

I would like to preface this comment section with the fact that we are in California so we have the requirement to put truncated domes on curb ramps with slopes less than 6.67% (1:15). Within the City of Sacramento we have adopted this as one of our standards for curb ramps. So if the Access Board uses the new revised ADA (when it finally becomes enforceable) and does not require truncated domes we will still be putting them on curb ramps with slopes less than 6.67% (1:15).

I write the above paragraph because we did three days of field study with people representing all major disabilities and it was agreed that the State truncated dome section was a good compromise and pleased the Council, Federation and the folks with mobility types of disabilities. It is felt that it is not cost effective to put truncated domes on all curb ramps in all locations. It is felt that the California requirement is a good compromise and that this standard should be adopted or given strong consideration when this section is completed. Through our work with truncated domes we know that it can cost between $400 and $1000 extra to put the truncated domes on curb ramps. If you take the average cost of these figures, $700, when we do a minimum of 1,500 curb ramps a year we are adding an additional $1 million dollars if we had to do truncated domes on all curb ramps. That might almost be enough to be considered a financial burden on our available dollars.

We also believe the new requirements for the spacing and sizing of truncated domes will have an impact on the entire disabled community. It has taken the Access Board enough years to get people to consider using truncated domes again it is not the time to be changing the spacing requirements. Our visual community does not like the minimum and maximum spacing because you would have all sorts of different truncated domes along a pedestrian access route and it could cause disorientation, sprained ankles or some unknown problem on the truncated dome plates when the larger spacing is used which would have more slippage in the field area because it gets larger. Also when using the larger spacing between domes it does not guarantee people in wheelchairs will be able to line up their wheels because they come in all sizes and shapes so it is not guaranteed that the wheels would roll between the truncated domes. If this requirement was put into the new chapter we might find ourselves back at the drawing board deciding whether truncated domes are safe or not and thus having another suspension.

1105.6 Roundabouts

We do not agree with the pedestrian traffic signals for Roundabouts. This defeats the purpose of the Roundabout and can be more dangerous to the pedestrians. I do not need to go into the studies or statistics as I have seen them quoted plenty of times in comments already received. It is important to note in these statistics that there is more safety with a Roundabout without pedestrian signals than one with. It would be more prudent for the access board to be requiring truncated domes at these locations, crosswalks and midcrossing pedestrian safety areas, despite slopes, than the pedestrian activated signal.

1106 Accessible Pedestrian Signal Systems

There is so much controversy on whether these devices help or hinder that more research needs to be done. We do not agree that all pedestrian signals should have some type of ped-activated signal. This area needs much more study and then put back out with a new set of proposed guidelines for comment. What is listed in this draft is overwhelming and not yet proved as long lasting working devices. I am talking about the audible, vibrotactile or locator tones devices just to mention a few. I don’t believe the Access Board wants to get into another situation like the early truncated domes.

1108 Detectable Warning Surfaces

We have already made comment on this area but would just like to reiterate the importance of keeping the current truncated dome requirements for size and spacing. When a manufacturer has the ability to use sizes or spacing from X to Y then there will not be any consistency with the truncated domes being used. This seems like we are taking a step backwards and will just end up having truncated domes go on suspension again until the new spacing can be tested and shown that it is safe. The new sizing and spacing should not be adopted. Let us try to work with the visual community to find a common ground and at least use the requirements for size and spacing we now have.