William W. Millar, American Public Transportation Association
|
October 28, 2002 |
American Public Transportation Association
RE: Draft Guidelines for Accessible Public Rights-of-Way
The American Public Transportation Association (APTA) is pleased to respond to
the Architectural and Transportation Barriers Compliance Board’s (Access Board)
draft guidelines addressing accessibility in the public right-of-way.
About APTA
APTA is a nonprofit international association of over 1,500 public and private
member organizations including transit systems and commuter rail operators;
planning, design, construction and finance firms; product and service providers;
academic institutions, transit associations and state departments of
transportation. APTA members serve the public interest by providing safe,
efficient and economical transit services and products. Over ninety percent of
persons using public transportation in the United States and Canada are served
by APTA members.
Comments
APTA has been part of this rulemaking from its inception and will continue to
participate in the development of guidelines related to accessibility in the
public right-of-way. Indeed, since 1999, APTA has contributed its input to the
Public Rights of Way Access Advisory Committee. Now, with the release of the
draft guidelines, APTA has the following comments:
1102.7.1 Bus Route Identification. Bus route identification signs shall comply
with 703.5.1 through 703.5.4, and 703.5.7 and 703.5.8. In addition, to the
maximum extent practicable, bus route identification signs shall comply with
703.5.5. Bus route identification signs located at bus shelters shall provide
raised and Braille characters complying with 703.2, and shall have rounded
corners.
Comment: Remove requirement for Braille and raised letter route identifications.
It is common for transit agencies to change schedules and routes three or four
times per year. Transit agencies also replace or install bus shelters often. For
signs to withstand normal use, weather conditions and vandalism, it is necessary
to make them of durable materials such as aluminum. This requires a separate die
to be fabricated for each bus stop; the average cost of having dies fabricated
begins at fifteen hundred dollars. In short, the expense of fabricating signs
and the logistics of installing/replacing Braille and raised letter signs would
be prohibitive to transit authorities. We suggest that the Access Board explore
ways that could more practically address this issue, including new technologies.
Some stops have up to 30 or more different vehicle routes stopping at one
location. The proposed change, which would lower the mid-sign reach of 48
inches, would effectively require multiple route number signs to span the
interiors of bus stop shelters.
1103.3 Pedestrian Access Route Clear Width. The minimum clear width of a
pedestrian access route shall be 48 inches (1220 mm), exclusive of the width of
the curb.
Comment: It could be very impractical to provide a total clear width of 54”,
from face of curb to the back of the sidewalk, for the accessible route due to
tight right-of-ways. Many sidewalks are about 42” wide with utility poles right
in the middle. Some cities also have a 24” – 36” clear zone from the face of
curb where no utility poles/trees/bus signs shall be installed. Adding the 24”
utility-clear zone, plus the diameter of utility pole base (about 12”-18”) to
the 48” ADA clear width, the sidewalk width would be 84” wide. Any such sidewalk
improvement would require acquiring property from adjacent owners, which will
definitely increase project cost. Such a provision would discourage local
jurisdictions from improving their sidewalks.
This paragraph also may preclude a transit system from installing a bus sign on
a sidewalk with less than 72” (6 ft) wide (24” clear zone from face of curb and
48” ADA clear zone). We are also concerned about the definition on accessibility
clearances around the bus stop or information sign. If the 48” ruling applies
around the entire sign, this poses another significant problem.
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.
Comment: We recommend that truncated domes not be required at curb ramps,
landings and blended transitions. In our view, truncated domes generally should
only be used on transit platform edges. Truncated domes can set off muscle
spasms for persons with spinal injuries in wheelchairs. Moreover, use of
truncated domes in curb ramps, crosswalks, and blended transitions may cause
persons with visual impairments to become confused as to where they are and
could lead to serious injury. Currently, truncated domes are used at rail
stations to indicate to persons with visual impairments to stop; in contrast,
the guideline proposes to use truncated domes at curb ramps to indicate to a
person with visual impairments to proceed. An alternative tactile tile must be
used in this application. If the provision is not removed the minimum should be
36 inches in direction of travel.
1102.3 Alternate Circulation Path. An alternate circulation path complying with
1111 shall be provided whenever the existing pedestrian access route is blocked
by construction, alteration, maintenance, or other temporary conditions.
1111 Alternate Circulation Path
1111.1 General. Alternate circulation paths shall comply with 1111.
1111.2 Width. The alternate circulation path shall have a width of 36 inches
(915 mm) minimum.
1111.3 Location. The alternate circulation path shall parallel the disrupted
pedestrian access route, on the same side of the street.
1111.4 Protection. The alternate circulation path shall comply with 307 and
shall be protected with a barricade complying with 1111.6 to separate the
pedestrian access route and alternate circulation path from any adjacent
construction, drop-offs, openings, or other hazards.
Comment: The requirement for the alternate circulation path to be parallel to
the disrupted pedestrian access route and on the same side of the street is very
often not possible due to the nature of constructions projects which are causing
the disruption. In situations where entire rights-of-way are being built or
redesigned there is often no safe area to establish a pedestrian access route
which meets this guideline. We recommend that the proposed guideline be changed
to read that the alternate circulation path shall be located in the safest and
most direct route feasible within the scope of the construction project.
Conclusion
We appreciate the opportunity to comment on this proposal and look forward to an
NPRM that accommodates the comments of all affected parties. For further
information, please contact Kristin O’Grady at [... ].
Sincerely yours,
William W. Millar, President