James H. Lindley 
September 25, 2002


Dear Sir or Madam:

Attached to this letter are comments on the Draft Guidelines for Accessible Public Rights-of-Way (June 17, 2002) from the Center For Independence (CFI), covering the three counties of Thurston South King, and Pierce.

CFI is a State Independent Living Council (SILC) member. Our services consist of Community Advocacy and Education, Independent Living Services, Peer Support Services and Information and Referral. Of special note is our Integral Environs Design Project, that fosters Comprehensive planning in community integration.

The organization supplies advisers to the planning and transportation partners in our communities on matters of accessibility and mobility.

Sincerely,

James H. Lindley,
Director


What is a Holistic Environment

A Holistic Environment is a building or location that does not need extra ordinary adaptation for any “Special” Group of people. It is a place that has been Modified or pre-designed for everyone’s use and enjoyment throughout their life times.

An environments for ones lifetime includes, wayfinding, multi- model transportation, building auditing and environmental impact analysis and understanding, and comprehensive integral design concepts.

Comprehensive Integral Design

Working with the engineers and architects to assist in using the above elements in an environment in order to create a holistic environment that can support the conceptual design of the architect and engineer without compromising the importance and inclusion of the holistic elements of a design.

The inclusion of holistic environmental design concepts leads to a more universal configuration by:

  1. Eliminating design barriers in order to improve building and public area access.
  2. Cultivating a vision to improve the quality of life for all people through holistic and humane thinking that builds true human communities.

How does integral design improve human communities? There will no longer be a need to discuss adaptation for “People with Special Needs”. All locations that are available for use by the public will be modified or pre-designed for all people. This will be accomplished by:

  1. Comprehensive thinking by engineers, designers and architects.
  2. Fostering development for a continuing culture of understanding that values the holistic vision of human communities by municipal, state and federal entities.
  3. Stringent enforcement of pub that address holistic design.

New aspects that are missing from most programs include

  1. Tactile Wayfinding
  2. Full Sensory Signage
  3. Sound, vibration and the impact of sound distribution within environments
  4. Textural surfacing for natural environments
  5. Studies of how people have navigated natural environments by reading the lay of the land
  6. The physiology of motion in a designed environment

 

We will now discuss some of our ideas about amending proposed ADAAG Standards.

We are discussing.

 

1102.5.1 Protrusion Limits. Objects with leading edges more than 27 inches (685 mm) and not more than 80 inches (2030 mm) above the finish floor or ground shall not protrude 4 inches (100 mm) maximum horizontally into the circulation path.

Amendment: Protrusion Limits should read zero. Reduce Vertical Clearance should read 14” to allow for people with different heights using canes. The 27” height will run a cane holders hand into the object being approached.

The height of many people today is 6 plus feet. It suggests that the protrusion height should be 8 feet.

1102.9 Street Furniture. Street furniture that is intended for use by pedestrians and installed on or adjacent to a sidewalk shall comply with 309 and 1107.

Amendment: The Street furniture must have a high contrast marking or be in high contrast to the background along a pedestrian way. The street furniture will not extend into the clear path area.

1107.2 Clear Floor or Ground Space. Street furniture shall have clear floor or ground space complying with 305 and shall be connected to the pedestrian access route. The clear floor or ground space shall overlap the pedestrian access route 12 inches (305 mm) maximum.

Amendment: Zero tolerance for encroachment of anything into a clear floor or Ground Space. Change guidelines so that furniture may not encroach on minimum clear area. Any infringement into clear space creates a null of the definition of clear space.

1102.13 Bus Stops. Bus boarding and alighting areas shall comply with 810.2. Bus shelters shall comply with 810.3.

Amendment: Bus stops in public right-of way will be required to have benches where service frequency is 30 minutes or more.

This requirement would enable m persons with disabilities to mainline and use fixed route transit.

1103.3 Clear Width. The minimum clear width of a pedestrian access route shall be 48 inches (1220 mm), exclusive of the width of the curb.

Amendment: Change minimum clear width to 60”. Larger wheelchairs, people using Dog Guides, people using sighted guides, people using wheel chairs and assistance animals all exceed the 48 inches proposed in this section.

1103.6 Surfaces. The surfaces of the pedestrian access route shall comply with 302.

Amendment: The surface of pedestrian access routes should have an area 36” wide minimum which that has a smooth surface. Smooth area should be a minimum of 12” from curb. Grout in paver and tile surfaces must be even with the face of the tile to avoid setting off muscle spasms or causing physical pain. Also many times if the area is rough the cane tip gets caught in the spaces.

1104.3.2 Detectable Warnings. Detectable warning surfaces complying with 1108 shall be provided, where a curb ramp, landing, or blended transition connects to a crosswalk.

1108.1 General. 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. 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.

Amendment: Remove requirement for truncated domes at landings and blended transitions. In the event of a landing, alleyway crossing or any surface that blends flat with a passageway including Rail Road crossing should have tactile warning bars that extend from 16” from the point of the barrier to 36” in depth. In the case of Pedestrian crossings at a Rail Road Crossing the tactile surface must be coupled with a pedestrian crossing gate.

If the provision is not removed the minimum should be 36 inches in direction of travel, and an additional tactile surface flag be placed as a locator for the placement of safe crossing. These are used throughout Europe on the curb to locate the proper location of the crossing.

1105.3 Pedestrian Signal Phase Timing. All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet per second (0.91 m/s) maximum. The total crosswalk distance used in calculating pedestrian signal phase timing shall include the entire length of the crosswalk plus the length of the curb ramp.

Amendment: Recommend that the walk speed shall be reduced to 2.5 feet per second maximum. The total crosswalk distance used in calculating pedestrian signal phase timing shall include the entire length of the crosswalk plus the distance from the curb cut if they are inline plus the distance from audible/tactile pedestrian signal to curb cut must be included in the walk speed requirement.

1105.4 Medians and Pedestrian Refuge Islands. Medians and pedestrian refuge islands in crosswalks shall comply with 1105.4 and shall be cut through level with the street or have curb ramps complying with 1104 and shall contain a pedestrian access route complying with 1103. Where the cut-through connects to the street, edges of the cut-through shall be aligned with the direction of the crosswalk for a length of 24 inches (610 mm) minimum.

Amendment: Please refer to comment on 1108.1.4

Roads that require an island must include a pedestrian signal on the island so that people may clearly see when to cross.

1106.2.1 Location. Pedestrian signal devices shall be located 60 inches (1525 mm) maximum from the crosswalk line extended, 120 inches (3050 mm) maximum and 30 inches (760 mm) minimum from the curb line, and 120 inches (3050 mm) minimum from other pedestrian signal devices at a crossing. The control face of the signal device shall be installed to face the intersection and be parallel to the direction of the crosswalk it serves.

Amendment: Minimum distance must be 18” from curb. A maximum requirement should be 30” to allow peoples using tactile indicators to be closer to the curb cut and or crosswalk. The activation button must be on the pedestrian side of the pole for people with limited range of motion. Poles 18” to 30” from the curb will be treated like street furniture.

1108.2.2 Rail Crossings. The detectable warning surface shall be located so that the edge nearest the rail crossing is 6 inches (150 mm) minimum and 8 inches (205 mm) maximum from the vehicle dynamic envelope.

Amendment: Detectable warnings must begin no less than 16” from the dynamic envelope and extend to 36”. Where there are pedestrian crossing there must be a pedestrian crossing gate as commented on in 1108.1.4

1111.2 Width. The alternate circulation path shall have a width of 36 inches (915 mm) minimum.

Amendment: Minimum clear width must be 42 inches to allow for persons using large wheel chairs, Double Strollers, Dog Guides or sighted guides and attendants.


(Attachment)

Holistic Environments Accessibility Consulting

For Everyone’s Use and Enjoyment Throughout Their Lifetimes

 

What is a Holistic Environment?

A Holistic Environment is a building or location that does not need extra-ordinary adaptation for any “Special” group of people. It is a place that has been modified or pre-designed for everyone’s use and enjoyment throughout their life times.

Holistic environments include wayfinding, multi-modal transportation, building auditing and environmental impact analysis and comprehensive integral design concepts.

Wayfinding

Tactile surface information system incorporated into the initial environmental design. This is a value added design, giving direction and information that can be retrofitted into existing settings.

Multi-modal Transportation

Analysis, planning and development of transportation movement and access from pedestrian and bicycle to private motorized and public transportation.

Building Auditing

Analysis and inspection of approaches and buildings that already exist in an environment in order to bring their design up to standards for a Holistic Environment. The suggestions from this analysis include building approaches from transportation portals to include the actual internals and usage of the building for people throughout their lifetimes.

Environmental Impact Analysis

Analysis of sound, movement and population usage on the environment, whether it is in an urban, suburban, rural or nature area. The analysis helps to plan for holistic and wayfinding elements for least impact and intrusion in that environment.

Understanding the movement of people and how they interact within a given environment.

Design features that complement an environment structured for people.

In order to accomplish all of the above, we must be aware of the effect on the general environment. One may use these holistic accessibility ideas in various environments in a way that does not negatively impact nature areas, or any other area that may be designed.

Comprehensive Integral Design

Working with the engineers and architects to assist in using the above elements in an environment in order to create a Holistic Environment that can support the conceptual design of the architect and engineer without compromising the importance and inclusion of the holistic elements of a design.

The inclusion of holistic environmental design concepts leads to a more universal configuration by:

  1. Eliminating design barriers in order to improve building and public area access.
  2. Cultivating a vision to improve the quality of life for people through holistic and humane thinking that builds true human communities.

How does “Holistic Environments - Accessibility Consulting” improve human communities? There will no longer be a need to discuss adaptation for “People with Special Needs”.  All locations that are available for use by the public will be modified or pre-designed for all people. This will be accomplished by:

1.      Comprehensive thinking by engineers, designers and architects.

2.      Fostering development for a continuing culture of understanding that values the holistic vision of human communities by municipal, state and federal entities.

3.      Stringent enforcement of public policies that address holistic design.

Holistic Environmental Design accomplishes several things through the reduction of value added costs:

1. Reduction of taxes

a)      Reduction of costs of design

b)      Reduction of prices of “Special Needs” concept of building materials

c)      Reduction of excess costs of hiring after-the-fact consultants

d)      Reduction of excess redesign costs

e)      Reduction of excess demolition and retrofit costs to new environments

2. New ways of designing conceptual thinking

a)      Holistic thinking

b)      Integral design

c)      Reduction of discrimination

d)      International standards development

e)      Design for people

f)        No need to rebuild or retrofit newly built structures

g)      Reduction of transportation costs due to integral design concepts

h)      Towns and cities become user friendly for all

There is also the architectural aspect of International Access Design, in the sense that if one is designing an environment, one needs to be aware of engineering and architectural design practices.

New Aspects that are Missing from Most Programs Include:

1.      Tactile Wayfinding

2.      Full Sensory Signage

3.      Sound, vibration and the impact of sound distribution within environments

4.      Textural surfacing for natural environments

5.      Studies of how people have navigated natural environments by reading the lay of the land

6.      The physiology of motion in a designed environment

Services We Provide

1.      On site inspection and evaluation

2.      Research for your specific needs

3.      Proposals for methods of holistic modification

4.      Availability of vendors

5.      Tactile Mapping

6.      Referral for Braille and large print brochures, menus, etc.

7.      Information services about the Americans with Disabilities Act (ADA)

8.      Information services about international regulations and standards on accessibility

9.      Continuous support through all stages of your project

We Provide Training in Interaction with People who have Disabilities

1.      Training and guidance of staff members

2.      Interpersonal skills training

3.      Middle Eastern disabled and the ADA

We are recognized by the following organizations worldwide for expertise on accessibility issues

Domestically

1.      Department of Human Services - Olympia, WA

2.      The American Council of the Blind

3.      Department of Services for the Blind

4.      National Foundation for the Blind

5.      Sound Transit

6.      Pierce County Coordinated Transportation Coalition

7.      Pierce Transit

8.      The Evergreen State College - Olympia, WA

9.      City of Tacoma

10.  Lighthouse for the Blind - Seattle

Internationally

1.      The Royal National Institute of the Blind - London

2.      O.N.C.E. Organization for the Blind - Spain

3.      The Ministry of Tourism and Antiquities - The Hashemite Kingdom of Jordan

4.      Ministry of Tourism - Israel

5.      Ministry of Tourism - Cairo, Egypt

6.      The Government Tourist Corporation - Israel

7.      Ministry of the Interior - Israel

8.      Migdal Or (Lighthouse for the Blind) - Israel

9.      The Bernard Bloomfield Science Museum - Hebrew University - Jerusalem, Israel

10.  The National Science Museum - Haifa, Israel

11.  The Technion, Department of Architecture — Israel

 

Holistic Environments Accessibility Consulting
 

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