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Attached is the City of Dallas' comments of the draft ADA guidelines for public rights-of-way. Please call me if you have any questions.

Elizabeth Baptista-Fernandez, P.E.
Assistant Director
Public Works and Transportation Department
City of Dallas

COMMENTS CONCERNING DRAFT ADA GUIDELINES

Section 1102.3 (Alternate Circulation Path)

This may not be practical on some restricted rights-of-way. Typically the street is under construction at the same time as the sidewalk. For some time period, the parkway area will be blocked without adequate right-of-way to provide an alternate circulation path on the same side. Would it not be acceptable to provide for the pedestrian to be able to cross to the open side of the street at an intersection as the circulation path?

Section 1102.7.2 (Informational Signs and Warning Signs)

Will the proposed visual legibility requirements for pedestrian signs be compatible with the those found in the MUTCD?

Section 1102.8, 1106 (Accessible Pedestrian Signal Systems)

The City of Dallas is concerned that the installation of audible, vibrating or receiver-based infrared pedestrian signals at all signalized pedestrian crossings will be too costly and a maintenance burden. Could the implementation of this equipment be limited to only those locations where an engineering study has determined that there is a significant need for such devices?

Are the tactile and visual signs that indicate crosswalk direction, street names and crosswalk configuration consistent with MUTCD specifications?

Section 1102.14 (On-Street Parking)

Installing one accessible parking space in each block face will be too costly to implement. Will the Federal Government provide funding to comply with this requirement?

Section 1102.15 (Passenger Loading Zones)

Installing one passenger loading zone for every continuous 100 linear feet of loading zone space will be too costly to implement. Again, will the Federal Government provide funding to comply with this requirement?

Section 1103.3 (Minimum Clear Width)

The 48" minimum clear width requirement will be difficult to meet in many situations due to limited right-of-way. Also, Dallas has been in compliance with the ADA minimum 36” clear width utilizing it as a construction standard for some time and has received no comment from the public that it has not been accommodated or negatively impacted.

Section 1103.5 (Grade)

It is understood that the grade of the sidewalk can equal but not exceed the grade of the adjacent established roadway. However, it is not clear whether or not a sidewalk with a grade greater than 5% should be treated as a ramp assuming the grade of the sidewalk is matching the grade of the adjacent road.

Section 1104.2.1.2 (Cross Slope)

Not clear. Where within the ramp does this apply?

Section 1104.2.1.3 (Landing)

36” is sufficient. See comment for section 1103.3

Section 1104.2.2.2 (Cross Slope)

Not clear. Where within the ramp does this apply?

Section 1104.3.1 (Width)

36” is sufficient. See comment for section 1103.3

Section 1104.3.3 (Surfaces)

Certain covers built flush with the ramp do not impair the surface or interfere with the detectable warning. There should be an exception for cases of restricted rights-of-way considering a practical solution is technologically feasible.

Also, will there be a restriction on the installation of street light poles, traffic signal poles, traffic signposts and pull boxes within curb ramps and blended transitions? If so, this will be a problem because limited right-of-way often dictates that some of these items be located in curb ramps and blended transitions.

Section 1104.3.7 (Clear Space)

36” is sufficient. See comment for section 1103.3

Section 1105.3 (Pedestrian Signal Phase Timing)

The City of Dallas recommends that a maximum walking speed of 4 feet per second, as specified in the MUTCD, continue to be used to calculate pedestrian crossing times. Using slower walking speeds to calculate pedestrian crossing times should be site-specific and a matter of engineering judgement rather than a requirement.

Increasing the total crosswalk distance used in pedestrian crossing time calculations to include the ramp is not practical. It would require too much time be devoted to pedestrians and increase delays to motorists. Traffic congestion and air pollution would increase. Why was this requirement added? Once the pedestrian reaches the ramp, he is out of the street.

Section 1105.6 (Roundabouts)

What type of signal control is being proposed for pedestrian crossings in roundabouts? Standard traffic signals operating in red-yellow-green mode would defeat the purpose of the roundabout. Could pedestrian-actuated flashing crosswalks be considered instead?

Section 1105.7 (Turn Lanes at Intersections)

What type of signal control is being proposed for pedestrian crosswalks that traverse slip ramps at intersections? Standard traffic signals operating in red-yellow-green mode would interfere with the free flow of traffic for which these ramps were built. Also, the additional signal displays will complicate traffic signal phasing at the intersection. Again, could pedestrian-actuated flashing crosswalks be used instead?

Section 1111.3 (Location)

See comment for 1102.3