Alan R. Zahradnik

October 28, 2002

Re: Comments on Draft Guidelines for Accessible Public Rights-of-Way

The Golden Gate Bridge, Highway and Transportation District (District) is pleased to respond to the Architectural and Transportation Barriers Compliance Board’s (ATBCB) draft guidelines addressing accessibility in the public right-of-way.

District operates the Golden Gate Bridge and provides public bus, ferry, and paratransit services within the U.S. Highway 101 corridor between destinations in the counties of Marin, Sonoma, Contra Costa, and San Francisco, California. Golden Gate Transit (GGT) serves approximately 1200 bus stops and transit facilities within these four counties. These stops are located within the public right-of-way of over 22 different city and unincorporated county jurisdictions. In addition, GGT has over 30 years of experience providing public transit services, including cooperating with those agencies that have jurisdiction over the rights-of-way where these stops are located. Based on this experience, the District has the following comments regarding the draft guidelines:

1. Guideline No. 1102.7.1- Bus Route Identification:

This guideline provides that 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.

District Comment: ATBCB should remove the requirement for Braille and raised letter route identifications. It is common for transit agencies to change schedules and routes three and four times per year. Transit agencies also replace or install bus shelters often. In order for signs to be made which withstand normal use, weather conditions, and


vandalism, it is necessary to make them of durable materials such as aluminum. This requires a separate die to be fabricated for each bus stop. Average costs of having dies fabricated begin at fifteen hundred dollars. The expense of fabricating signs and the logistics of installing/replacing Braille and raised letter signs would be prohibitive to transit authorities. Technological advances in the future may provide the opportunity to more practically address this issue compared to the regulation that is being proposed.

In addition, some stops have many routes serving one location. The proposed change, which would lower the mid-sign reach of 48 inches, would effectively require route number signs that would span the interiors of bus stop shelters.

2. Guideline No. 1103.3 - Pedestrian Access Route Clear Width: The guideline provides that the minimum clear width of a pedestrian access route be 48 inches (1220 mm), exclusive of the width of the curb.

District Comment: The District believes it could be impractical to provide a total clear width of 54 inches from face of curb to the back of the sidewalk. There is insufficient right-of-way for this purpose in many jurisdictions. Many sidewalks are about 42 inches wide to face of curb with utility and other poles at various locations within the sidewalk area. Some jurisdictions have 24 inches to 36 inches clear zone from the face of curb where no utility poles/trees/bus signs shall be installed. Adding the 24 inches utility-clear zone, the diameter of a utility pole base (about 12 inches to 18 inches), and the proposed 48 inches clear pedestrian access width would result in a sidewalk that was 84 inches wide. Any sidewalk improvement to meet this standard could require acquiring property from adjacent private property owners. This would potentially be very difficult to do and, if accomplished, would significantly increase project cost. Such a provision would discourage local jurisdictions from improving sidewalks within their public right-of-way.

This paragraph may also preclude a transit system from installing a bus sign on a sidewalk that is less than 72 inches (6 feet) wide (24 inches clear zone from face of curb and 48 inches ADA clear zone). The definition of accessibility clearances around the bus stop or information sign is also not clear. If the 48 inches ruling applies around the entire sign, this poses another significant problem.

3. Guideline Nos: 1104.3.2 Detectable Warnings. The guideline provides that detectable warning surfaces complying with guideline 1108 shall be provided, where a curb ramp, landing, or blended transition connects to a crosswalk.

1108.1 General. The guideline provides that detectable warnings shall consist of a surface of truncated domes aligned in a square grid pattern and shall comply with 1108.

1108.1.4 Size. The guideline provides that detectable warning surfaces shall extend 24 inches (610 mm) minimum in the direction of travel and the full width of the curb ramp, landing, or blended transition.

District Comment: The District recommends the requirement for truncated domes at curb ramps, landings and blended transitions be removed from the guidelines. Truncated domes should only be used on transit platform edges. Truncated domes can set off muscle spasms for spinal injury citizens in wheelchairs. Use of truncated domes in curb ramps and crosswalks which are adjacent to light rail or commuter rail platforms may cause persons who are blind or partially sighted to become confused as to where they are and could lead to serious injury. An alternative tactile tile should be used in this application. If the provision is not removed, the minimum standard should be 36 inches in the direction of travel.

Thank you for the opportunity to comment on this proposal. District looks forward to a Notice of Proposed Rulemaking that considers and is responsive to the comments outlined above.

Very truly yours,

Alan R. Zahradnik
Planning Director