Douglas J. Cross
|
October 28, 2002 |
AC Transit
Alameda-Contra Costa Transit District, Oakland, California
RE: Draft Guidelines for Accessible Public Rights-of-Way
Dear Mr. Windley:
AC Transit is writing to respond to the Access Board's draft ADAAG guidelines
for accessibility in public rights-of-way. AC Transit is the public transit
system in the San Francisco East Bay area, operating a fleet of 800 buses and
180 paratransit vehicles. We serve a diverse population that includes many
individuals with disabilities. Our service area is home to many
disability-oriented advocacy and service organizations, with constituencies at
the local, state, national, and international levels. AC Transit's Accessibility
Advisory Committee (AAC) has been a pioneering leader in consumer advocacy for
local public transportation systems.
1102.7.1 Bus Route Identification: We do not agree that Braille/raised print
route identifications should be required at bus shelters. In our area, shelters
are provided and controlled by municipalities, not the transit system. In the
Bay Area, Braille/raised print identifiers are usually placed on bus stop sign
poles, by the transit system. They are not directly associated with shelters,
which are sometimes placed for advertising visibility, not for transit ridership
reasons.
AC Transit has nearly 7,000 stops. It is common for transit agencies, including
AC Transit, to change schedules and routes often. Braille/raised print signs
which must be customized for certain bus stops are expensive to make, and even
more expensive to keep current. They are much more involved than stop sign
decals, which can be changed easily. Local transit systems have limited field
staff, and cannot be expected to handle the cost and complexity of maintaining
tactile signage, without additional resources.
AC Transit is currently experimenting with bus route numbers in Braille/raised
print on selected route information signs. We foresee adopting a tactile signage
standard that will provide for route numbers at bus stops where there are
multiple bus stop poles. This situation exists at transit centers, rail station
transfer locations, and major downtown transfer locations. Some of these have
shelters, and some do not.
AC Transit is considering a universal identifier for all other bus stops, most
likely saying simply "Bus". This type of sign is in use by many transit systems,
and has been found useful to blind passengers, where a variety of poles and
posts can make finding the bus stop confusing. The AC Transit AAC agrees with
management that full "route identifier" signs should not be required at all
stops, or those with shelters, and that the simple "universal identifier" may be
a more reasonable ADAAG requirement.
In any case, the proposed ADAAG requirement is unclear. It should state more
specifically what information is required, at a minimum. Many transit systems
have information about destinations, frequency, time span, and other items on
route signs. This amount of information would not fit on the narrow type of
Braille/raised print signs AC Transit and other Bay Area transit systems are
using, which must fit on a vertical signpost, without creating a hazard for
pedestrians. Our plans are to provide only the route number or letter as the
“route identifier”.
1103.3 Pedestrian Access Route Clear Width: Sidewalk width is not a factor under
the control of most transit systems, including AC Transit. Our staff feels that
it is reasonable to require adequate sidewalk space where feasible. We would be
wary, however, of any interpretation that would preclude the placement of bus
stops at new or re-built locations that did not comply. While we work
cooperatively with local municipalities to provide facilities that support
transit usage, we ultimately cannot control them. We are also sensitive to the
potential problems pointed out in the American Public Transportation
Association’s (APTA) letter to you of Oct. 28,
2002. One issue is that such a provision may discourage local jurisdictions from
improving their sidewalks.
In reviewing the proposal, our advisory committee, the AAC, felt that the
originally-contemplated width of 60” would be more appropriate than the final
draft figure of 48”, for reasons of promoting increased accessibility. Our staff
pointed out that while this may be a worthy goal, it could create even more
problems of the type mentioned in the APTA letter.
1104.3.2 Detectable Warnings: We support the proposed changes to the technical
specifications of truncated dome detectable warnings. However, we think it is
premature to expand the application of these warning features, due to several
outstanding issues associated with their use.
In California, the state building code already provides for a different type of
textural feature alerting pedestrians to the presence of curb ramps. There is
also a potential for the proposed 24” application to be confused with rail (or
Bus Rapid Transit) platform edges. If this requirement is pursued, the original
concept of 36” for marking hazardous vehicular ways should be more strongly
considered. In general, both our staff and AAC feel that more research and
public input should be conducted before changing the existing guidelines.
We appreciate the opportunity to comment on this proposal and look forward to an
NPRM that accommodates the comments of all affected parties. If you need any
further information, please feel free to contact me at [...].
Sincerely,
Douglas J. Cross
Accessible Services Manager