David T. Harden

October 25, 2002

CITY OF DELRAY BEACH


RE: Draft Guidelines for Accessible Public Rights-of-Way

The City of Delray Beach, Florida, has reviewed the Draft Guidelines for Accessible Public Rights-of-Way being proposed by the Architectural and Transportation Barriers Compliance Board and has the following comments/concerns:

Sec. 1102.14, 1109 — Requiring one ADA accessible space per block face doesn’t seem practical for smaller municipalities which have five (5) to eight (8) spaces per block. In many instances, this would require 20% of the public parking spaces designated as handicapped accessible. This percentage is excessive when compared to the requirements in parking lots and garages which starts at four percent (4%) and reduces to two percent (2%) for capacities between 501 and 1000 spaces.

Sec. 1109.2 — The suggestion of the “bump-in” for parallel parking spaces with the thought that users needing access from the drivers side would park in the spaces against the curb assumes that drivers would be able to easily complete that maneuver. Realistically, on a two-lane roadway, the vehicle would have to impede traffic flow of the adjacent lane to achieve a great enough angle to use the space as suggested. Exiting the space would create similar hazards. To accommodate such a design would require the elimination of additional on-street spaces.

Sec. 1109.3 — Required dimensions in the state of Florida currently exceed the national standard of an eight foot (8’) space with a five foot (5’) access panel by mandating the parking space to be twelve feet (12’) wide with a five foot (5’) access panel (17’). The proposal to have all on-street perpendicular or angled parking spaces to be van accessible requiring a 96” access panel (eight (8’), would result in twenty foot (20’) wide spaces. Current Florida accessibility requirements exceed the proposed national standard by one foot (I). Perhaps the proposal should be reevaluated to provide a minimum width which would keep the state of Florida and others which might mirror Florida’s guidelines, in compliance. A suggestion would to allow alternative designs which accommodate a total width of 17’ with a minimum access panel of 5’.

Sec. 1109.5 — Prohibiting any obstructions for the entire length of sidewalk adjacent to an accessible parallel space seems unreasonable. Determining a reasonably sized area, perhaps ten feet (10’) at the center of the space, would accommodate the entering and exiting of vehicles while allowing for streetscape elements to remain or be installed. The primary concern would remain the unobstructed access to the pedestrian or walking system.

Sec. 1105.2 — It seems unlikely that the widening of crosswalks to eight feet (8) to provide the physically challenged ample ability to get across streets would be as effective as the suggestion of the Board which is addressed in section 1105.3. It would seem that the adjustment of the pedestrian signal phase timing to a rate of 2.5 to 3 feet per second would create a safer more pedestrian friendly environment. Additionally, increasing the width of the crosswalk might require the relocation of streetscape elements along with the widening of existing curb ramps which might prove cost prohibitive to some smaller municipalities.

In closing, the City of Delray Beach, Florida has a large senior and physically challenged population and is cognizant of the day-to-day challenges they face. Although not mandated, the City has installed numerous ADA accessible spaces throughout the downtown area (on-street parking and public parking lots) and continually monitors and addresses the needs of the community. I believe most municipalities share this philosophy.

Please take these comments and suggestions into consideration while realizing the impact on smaller municipalities that will be created through the adoption of these proposals as currently drafted.

Feel free to contact me at 561-243-7015 if I may be of any further assistance.

Sincerely,

David T. Harden
City Manager