Michael A. Whipple
|
October 28, 2002 |
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.