Barbara Barker
|
October 22, 2002 |
ACCESSIBLE PUBLIC RIGHTS OF WAY MONTGOMERY COUNTY, MARYLAND - PUBLIC PARKING
PROGRAM
The following analysis of the proposed draft guidelines for public R-O-W is
limited to issues that arise from attempting to provide handicap on-street
parking only as it affects parking in the Central Business Districts (CBDs) of
Montgomery County, Maryland. This discussion is limited to public on-street
parking, specifically as it relates to the Parking Districts and County policies
within these Districts.
ASSESSMENT & COMMENTS
If the County is required to provide handicap spaces on-street, in the manner
mandated by this change, there are three areas of consideration that will most
affect the Public Parking Program in Montgomery County:
1. The method used for calculation of the number of handicap spaces to be
provided on-street.
2. The physical requirements of the area to be designated as a handicap space.
3. Current policies in effect for Montgomery County's Public Parking System.
1. METHODS OF CALCULATION: HANDICAP ON-STREET PARKING
• The number of handicap spaces required, when the Access Board's method of
allocation is used, far exceeds the number required if the Advisory Committee's
(approximately 2%) method is used. And we suspect that the Board numbers far
exceed the actual number of disabled patrons using parking spaces, since it
would require 9 to 22% of all parking spaces to be designated for handicap use
only.
• The percentage in excess of ADAAG is an unrealistic allocation, (See Table I)
ranging from 350, 3.5 times to almost 5 times the number required by current ADA
standards.
• Rather than allocating one space per block face, the decision on where to
locate the spaces to be designated should be left to the individual
jurisdictions, which can balance the accessibility requirement to the actual
demand.
Table I
COMPARISON OF THE NUMBER OF ON-STREET
HANDICAP PARKING SPACES REQUIRED
Parking District |
Total No. On-Street Spaces |
Average No. Spaces per Block Face |
Total No. Block Faces |
Spaces required per Access Board Guidelines (1) |
Spaces required per ADA Accessibility Guidelines (2) |
Difference (% in excess) |
Bethesda |
766 |
8 |
94 |
94 |
16
|
78 (487.5%) |
Silver Spring |
994 |
11 |
101 |
101 |
20 |
81 (405%) |
Wheaton |
391 |
11 |
36 |
36 |
8
|
28 (350%) |
Montgomery Hills |
23 |
5 |
5 |
5 |
1 |
4 (400%) |
1. Access Board Guidelines require provision of one handicap parking space for
each block face.
2. Advisory Committee recommendations are for use of the ADAAG sliding scale
ratio to be based on the total number parking spaces provided.
2. PHYSICAL REQUIREMENTS OF DESIGNATED HANDICAP SPACES
In Montgomery County's CBDs, the distances from building property lines to curb
lines vary in width, typically from 4 feet to 12 feet. This is less than the
minimum width of 14 feet required by the Access Board, to accommodate the
recessed parking space area suggested in the draft guidelines. The Access
Board's proposed remedy raises extreme safety concerns. For R-O-Ws too narrow to
include an indentation, they propose to locate a handicap space at the end of
the block, closer to a curb ramp within the width of each crosswalk. "Closer to
a curb ramp" does not address the question of how to safely access the ramp when
no designated access route has been provided.
In Montgomery County all on-street parking is provided parallel to the roadway
and curb. Most CBD sidewalks have less than 14 feet of R-O-W, therefore the
handicap spaces would have to be located at the ends of the blocks. Handicap
patrons would be required to use the vehicular travel lanes to access the ramps
at the ends of the blocks. These end spaces are frequently 50-100 feet away from
the ramps, creating an extremely unsafe situation for disabled users.
If Committee recommendations are followed, the No Parking distance will be
increased. In a discussion on vehicular obstructions (02.4.13), the Committee
suggests "lengthening the no parking zone adjacent to a crosswalk, since
wheelchair users and people of short stature may be hidden from a motorist's
view by parked cars." This legislation would require wheelchair patrons to
maneuver within the traffic flow for several minutes, placing them in a very
dangerous situation. In addition, the lengthening of the No Parking zone can
only be accomplished by further reducing the number of parking spaces available
to the general public.
Where sufficient R-O-W does exist, the length of the indentation would have to
make allowance not only for the length of the vehicle, but for a sufficient area
of maneuverability around the vehicle to an access ramp provided within the
indentation area (depicted in Fig. 61, Section 14.2 ADAAG). This would allow the
disabled driver to safely gain access to the ramped segment of the indentation,
without being exposed to the traffic flow. But it is clear that these
indentations would have to be longer than just one car length, thus further
eliminating additional on-street parking spaces available to the general public.
Obstructions
Attached to this document are five pictures that reflect the desirable
streetscaping methods adopted by this County. In some cases, a reverse easement
has been granted allowing landscaping and café tables and chairs to be placed
adjacent to parking spaces, and 6 feet of pedestrian access route has been
located alongside the storefronts. In addition, several streets have been
streetscaped by County initiated projects. Once again, many amenities have been
made available which would not have been allowed if the 60 or 72 inch
unobstructed pedestrian access route were provided.
In summary, even if the provision of one handicap space for each block face
could be properly addressed, the physical constraints such as sidewalk space
limitations, slope and terrain would make this allocation "technically
infeasible" in most of the locations within our downtown CBDs.
3. MONTGOMERY COUNTY PUBLIC PARKING SYSTEM POLICIES
Montgomery County's policy is to provide designated accessible parking spaces
for handicapped users in off-street public parking lots and garages. Designated
handicap spaces provide free parking for those patrons whose vehicles display a
handicap tag or permit. In addition, any metered space may be used, free of
charge. This is also true for all on-street parking spaces in our CBDs.
The main consideration for not designating specific on-street handicap parking
spaces is the extreme safety concerns. Our present policy allows handicapped
patrons to park in the places best suited to their capabilities. Provision of
designated handicap parking spaces, by the County traffic engineers, implies
that these are safe locations for wheelchair patrons to enter and exit their
vehicles. Since 98% of all our CBD pedestrian R-O-Ws are less than 14 feet in
width, most of these patrons would be required to exit their vehicles into the
flow of traffic. Due to the ever-present danger posed by adjacent traffic this
is not considered a safe action, and is in direct conflict with the policy,
dictated by our County Attorney, which highly discourages the on-street
designation of these spaces. An exception is made when an adjacent store caters
specifically to handicapped individuals, such as the Universal Artificial Limb
store in Silver Spring, and where no nearby off-street parking exists.
For this proposed legislation to mandate the installation of these spaces
on-street, without the provision of direct access from the designated handicap
space to the pedestrian routes (without use of the travel lane in a public
roadway), creates extreme liability issues for the jurisdiction providing such
designation. We believe that this could leave us open to law suits arguing that,
by our designation of a handicap space at the end of a block, we have deemed it
a safe location for maneuvering to an access ramp.
It makes perfect sense to provide on-street handicap parking spaces in areas
where these standards are achievable; however, in our downtown CBD areas those
would represent less than 2% of the block faces. Even provision of two handicap
spaces together in one block makes more sense than attempting to accomplish the
requirement on both sides of a given street.
It is also obvious from the examples presented in Table I, that the number of
spaces to be provided on-street, using the Access Board Guidelines, is
excessive. We would recommend that if the ADAAG required number of handicap
spaces cannot be provided on-street in an indented area, the requirement be met
in nearby off-street facilities. Perhaps a standard could be recommended that if
an off-street facility is not available within a 2-3 block radius, the safest
on-street space be provided to satisfy the ADAAG requirement for that area.
Barbara Barker
Senior Parking Planning Specialist
Montgomery County, Maryland