Douglas Weiszhaar
|
October 25, 2002 |
Minnesota Department of Transportation’s
Response to the Access Board
on
Draft Guidelines for Accessible Public Rights of Way
October 25, 2002
General Discussion
The Minnesota Department of Transportation’s (Mn/DOT) review of the Access
Board’s Draft Guidelines for Accessible Public Rights of Way, surfaced broader
themes and concerns about the guidelines, which are discussed here.
Flexibility
The wide range of environments that will be encountered by designers within the
public right of way was clearly not considered. The rigidity of the guidelines
do not allow for engineering judgement and do not respect the cultural,
environmental, and physical conditions that a designer must consider on a site
by site basis. The current approach of the guidelines may result in poor design,
dangerous conditions, a reduction of general services, and operational
shortcomings unless flexibility is introduced.
Availability of Resources
There is great concern that the guidelines have been developed without a context
that takes the cost of construction and ongoing maintenance into consideration.
While it has been made clear that the Access Board views cost as an issue of
implementation to be managed by the FHWA and the Department of Justice,
guidelines cannot be responsibly developed without these topics being taken into
consideration. Many who provided comments are working within a transportation
system where resources are already severely taxed?
Like many similar large DOT maintenance organizations, Mn/DOT does not have the
budget to do sufficient maintenance on its systems. Therefore, we must put
activities that are legally or clearly public safety related at the top of our
list when we prioritize resource expenditures – including personnel time and
materials. Prior to the proposed ADA requirements becoming law, there needs to
be a discussion about expectations of how well these facilities are likely to be
maintained with a clear understanding that all railings, signal devices, and
surface treatments may not be fully functional at all times. Anything that puts
the public in an unsafe condition is something that we must attend to, but if
resources are strained we must compare fixing a system that interacts with
hundreds or thousands of people above a system or device that substantively
interacts with less than a dozen people. If cost is not considered at this time
and guidelines are put forward that have cost prohibitive facilities as
requirements, it is likely that pedestrian accommodation may be removed from new
projects and less desirable improvements will be made to the existing network.
Liability
The guidelines have surfaced the issue of liability. It has been noted in the Mn/DOT
response that the guidelines are requesting designers to meet Access Board
requirements at the expense of other guidelines and standards that are already
in place and enforceable. At this time designers are not being provided guidance
on how to negotiate or balance conflicts and that will leave a situation where
designers may simply choose not to include treatments. This gap will also invite
a wide range of interpretation between the different types of guidance that is
available to designers and will subsequently erode the uniformity and
predictability that is being sought by Draft Guidelines for Accessible Public
Rights of Way. As in the matter of cost the Access Board defers to the
Department of Justice once the guidelines are in place, but there are many
issues that should be addressed at this stage so that all users of the
transportation system will be represented.
In closing Mn/DOT is seeking guidelines that will allow us to improve access
within our transportation system and maintain balance between financial,
cultural, and operational needs. The Access Board must consider how to
responsibly recommend guidelines that can be implemented and will serve the
needs of all users. Refinement of the guidelines is clearly needed to reach an
acceptable balance point.
General Recommendations
Guideline Usability
To improve the overall usability of the guidelines, the following
recommendations are made:
1. Use full citations when there is a cross-reference to another document so
users can understand and quickly find the information referenced.
2. Future iterations should have more extensive graphics to illustrate the
situations that are being described.
3. Conform to industry practice. (i.e. express grades as a percentage with rise
over run in parentheses.)
4. Follow the federal standard for expressing units with metric units first,
followed by English units in parentheses (e.g., 3.6 m (12 ft)). To provide
additional clarity, Mn/DOT also bolds the English unit in its manuals.
5. Use decimals instead of fractions (e.g., 2.5 rather than 2½).
6. Use consistent unit convention (e.g., inch instead of ”)
7. Please provide an indication of what sort of documentation needs to be kept
if the implemented design is challenged.
8. The guidelines do not explicitly state that they are design minimums.
Perhaps, this is a topic that will be addressed once the guidelines are
integrated into ADAAG, but as a stand-alone piece, the guidelines invite the
interpretation that they are maximum specifications for facilities. This
assumption should not be allowed to stand since there are many instances where
facilities should be designed above the minimum recommendation.
Section Analysis
1101 Application and Administration
Section 1101.3 Defined Terms
There are several concerns with terms used within the guidelines because
definitions are not clear or unnecessarily deviate from common industry
definition. Specific concerns are as follows:
• Blended Transition: Add a definition for this term in this section. The intent
of the term is not clear, because a definition is not provided.
• Crosswalk: Simplify the definition. Potential language could be as follows:
o Crosswalk - (1) That portion of a roadway ordinarily included with the
connection of sidewalks at intersections; (2) Any portion of a roadway
distinctly indicated for pedestrian crossing by lines or other markings on the
surface.
• Dynamic Envelope: This is not a standard industry term and needs definition.
• Pedestrian Clearance Interval: A definition is requested for this term. The
suggested language is: the interval following the walk interval, normally
symbolized by a flashing “Hand” or “Don’t Walk.”
• Ramp: The following definition is proposed: a sidewalk with a slope greater
than 5%, but not exceeding 8.33%.
• Running Slope: For clarity, it is requested that this term be removed and that
the term “grade” be used exclusively.
• Superelevation: For clarity, it is requested that this term be removed and
that the term “cross slope” be used exclusively.
• Technically Infeasible: Add a definition for this term in this section. The
intent and appropriate application of the term is not clear, because a
definition is not provided.
1102 Scoping Requirements
Section 1102.2 Alterations
Guideline Language: Where existing elements or spaces in the public right-of-way
are altered, each altered element or space shall comply with the applicable
provisions of Chapter 11.
EXCEPTION: An alteration where compliance is technically infeasible, the
alteration shall comply to the maximum extent feasible.
Requested Change: 1. Additional clarity needs to be provided for the thresholds
of alteration either through expanded language in the proposed guidelines or a
reference to already existing language.
2. It is recommended that the explanation of technically infeasible found in
section 4.1.6 of the July 26, 1991 Federal Register Part III, 28 CFR, Part 36 be
restated here along with the exceptions that are within the purview of these
guidelines.
Suggested Language: No recommendations.
Justification: The first change is needed to create clarity regarding when the
guidelines should be used. As the guidelines are currently written it is unclear
as to what types of projects the ADA requirements apply. Mn/DOT’s view is that
the maintenance and minor improvement categories where the objective is to keep
a facility smooth and open to traffic should be excluded. The second change is
requested to provide a clear definition and guidance on the applicability of
“technically infeasible” in relation to the guidelines. Given the volume of
physical area that right-of-way covers, it would be reasonable to explicitly
expand the definition of “technically infeasible” to include environmental site
constraints and adverse environmental, social, community, and transportation
system user impacts.
Section 1102.5.2 Post-Mounted Objects
Guideline Language: Free-standing objects mounted on posts or pylons shall
overhang circulation paths 305 mm (4 in) maximum when located 685 mm (27 in)
minimum and 2030 mm (80 in) maximum above the finish floor or ground. Where a
sign or other obstruction is mounted between posts or pylons is greater than 305
mm (12 in), the lowest edge of such sign or obstruction shall be 685 mm (27 in)
maximum or 2030 mm (80 in) minimum above the finish floor or ground.
EXCEPTION: This requirement shall not apply to sloping portions of handrails
serving stairs and ramps.
Requested Change: Reword.
Suggested Language: Free-standing objects mounted on posts or pylons shall
overhang circulation paths 100 mm (12 in) maximum when located 685 mm (27 in)
minimum and 2030 mm (80 in).
Justification: The suggested change would result in uniform interpretation and
application of the proposed guidelines between other guidelines already in
force. The 12-inch maximum was established in 1991 under section 4.4.1 of the
July 26, 1991 Federal Register, Part III, 28 CFR, Part 36 and is included in the
ADAAG Section 307 referenced below. This guideline change will allow for uniform
design of integrated roadway and multi-use projects and the development of
uniform design standards for both site and roadway facilities.
307 Protruding Objects
307.1 General. Protruding objects shall comply with 307.
307.3 Post-mounted Objects. Free-standing objects mounted on posts or pylons
shall overhang 305 mm (12 in) maximum when located 685 mm (27 in) minimum and
2030 mm (80 in) maximum above the floor or ground. Where a sign or other
obstruction is mounted between posts or pylons and the clear distance between
the posts or pylons is greater than 305 mm (12 in), the lowest edge of such sign
or obstruction shall be 685 mm (27 in) maximum or 2030 mm (80 in) minimum above
the floor or ground.
Section 1102.7.1 Bus Route Identification
Guideline Language: 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.
EXCEPTIONS:
1. Bus schedules, timetables and maps that are posted at the bus stop or bus
shelter shall not be required to comply with 1102.7.
2. Signs shall not be required to comply with ADAAG Section 703.2 where audible
signs are user or proximity-actuated or are remotely transmitted to a portable
receiver carried by an individual.
Requested Change: Delete text referencing non-existing sections of the proposed
guideline changes in ADAAG Section 703.
Suggested Language: Bus route identification signs shall comply with ADAAG
Sections 703.5.1 through 703.5.4. Bus route identification signs located at bus
shelters shall provide raised and Braille characters complying with ADAAG
Section 703.2, and shall have rounded corners.
Justification: Section 703.5.5, 703.5.7, and 703.5.8 are not published on the
Access Board Web site. Until this text is available for review, references to
these sections should be deleted due to the inability of the public to provide
adequate review of conditions and impacts.
Section 1102.10 Stairs
Guideline Language: Where provided, stairs shall comply with 504. Stair treads
shall have a 51mm (2 in.) wide strip of color contrasting with the tread and
riser, the full width of the front edge of each tread.
Requested Change Delete the requirement for color strip.
Suggested Language: Where provided, stairs shall comply with ADAAG Section 504.
Justification: The existing standardized handrail design in accordance with
ADAAG Section 504 extends horizontally at the top, bottom and landings of the
stairs to delineate the edge of a transition change (edge of stair system). This
is the most effective tool to communicate stair locations to a disabled person
at all times of day and in all weather conditions. If necessary modify the
handrail design guidelines to better communicate the location of the stair
system. The addition of a strip of contrasting color is not justified and cannot
be adequately maintained with the limited resources available.
The ability to develop a design solution that will meet both public safety and
maintenance considerations, without creating a high level of liability, is
highly questionable. Any system not maintained will present a liability for the
transportation agencies.
Paint: non-permanent, often slippery when wet, high cost to maintain.
Nosing Material: often slippery when wet, a mix of materials allows a point of
moisture and salt infiltration that will shorten the life of the structure.
Adhesives: non-permanent, maybe slippery when wet or snow covered, high cost to
maintain, frequently delaminates in heat and cold conditions creating loose
edges/trippers.
Visibility in snow conditions: not visible under snow cover.
Visibility at night without lighting:
The use of a well-designed handrail system is more useful and visible in all
conditions and fully provides a reasonable accommodation for individuals of all
abilities.
Context Sensitive Design/Aesthetic Considerations
A color edge strip of high contrast will visually dominate the setting and
negatively impact community design objective to blend roadway elements
sympathetically with architectural elements and the natural environment.
Section 1102.13 Bus Stops.
Guideline Language: Bus boarding and alighting areas shall comply with 810.2.
Bus shelters shall comply with section 810.3.
Requested Change: Delete information referencing non-existing sections of the
proposed guideline changes in Sections 810.2 and 810.3 of the ADAAG.
Suggested Language: Not Applicable.
Justification: Sections 810.2 and 810.3 of the ADAAG are not published on the
Access Board Web site. Until this text is available for review all references to
these sections should be deleted due to the inability of the public to provide
adequate review of conditions and impacts.
Section 1102.14 On-Street Parking
Guideline Language: Where on-street parking is provided, at least one accessible
on-street parking space shall be located on each block face and shall comply
with 1109.
Requested Change: 1.Reword the original statement with additional text to allow
for alternative compliance with the objectives of close easy access.
2.Clarify the definition of a block.
3. Clearly state the intent of the Access Board for this requirement to apply
only to commercial areas.
Suggested Language: Where on-street parking is designated by striping or parking
meters, on-street accessible parking stalls shall be uniformly distributed along
the block faces at a ratio in compliance with Table 208.2 of the ADAAG and shall
comply with 1109.
EXCEPTION: Accessible public off-street parking is provided within the block at
a ratio of one parking stall per 25, with a minimum of one parking space for the
total of all public parking spaces available per block, for both off-street and
on-street parking.
Justification: Require On-Street Parking Only in High Use, Designated Public
Parking Areas.
This requirement seems to be better targeted to designated parking, striped
parking and metered parking. The requirement for one parking space along each
curb face in all locations where parking is provided seems excessive. In many
cities parking is allowed/provided in all residential areas. On-street parking
spaces should not be required in non-commercial areas.
Proposed Distribution of On-Street Parking Seems Excessive
Mn/DOT agrees that a reasonable amount of On-Street parking needs to be
provided, however, physical constraints must be considered. The size of a block
varies by region and local urban design applications. Blocks in many Midwest
communities provide no more than 6 parallel parking stalls per block face due to
the curb space reserved for bus stops, driveways, passenger loading zones,
service entrances and no parking zones such as at fire hydrants and turn lanes.
For many communities this will reduce local parking supply for the general
population by more than 17%. This ratio can be as high as 4 times or more than
are required for private businesses and public facilities as specified in Table
208.2 of the ADAAG.
The number and type of businesses served by on-street parking also varies widely
based on local zoning. For these reasons, use of a minimum criterion of two per
block and a ratio of the total parking stalls available is recommended to
establish the number of On-Street Parking spaces required.
Provide Local Governments with Design/Location Flexibility to meet the
objectives
Managed parking is a local government function related to “zoning”. It seems
reasonable to allow for off-street parking within the same area that is
designated as accessible parking only (perhaps in parking ramps). Given the
grade and cross slope of many roadways, on-street parking spaces will often
exceed the desired surface slope 2% (1:48) for the access aisle.
1102.15 Passenger Loading Zones
Guideline Language: Where passenger loading zones are provided, they shall
connect to a pedestrian access route and shall provide a minimum of one
passenger loading zone in every continuous 100 linear feet (30 m) of loading
zone space, or fraction thereof, complying with 302, 503.2, 503.3, and 503.5.
Requested Change: Rewrite section and/or add an exception.
Suggested Language: EXCEPTION: Passenger loading zones are not reserved
exclusively for disabled persons and shall not be identified by signage.
Justification: In reviewing this issue with Access Board staff, it is not
intended that the passenger loading zones are reserved for exclusive use by
disabled persons; however, the text makes this unclear and a conflict exists
within other areas of the proposed draft ADA Guidelines Section 1-10.
1103 Pedestrian Access Route
Section 1103.1 General
Guideline Language: Pedestrian access routes shall connect to elements required
to be accessible and shall comply with 1103.
Requested Change: Rephrase for better understanding.
Suggested Language: Pedestrian access routes shall connect elements that are
required to be accessible and shall comply with Section 1103.
Justification: Not Applicable
Section 1103.4 Cross Slope
Guideline Language: The cross slope of the pedestrian access route shall be 2%
(1:48) maximum.
Requested Change: Rephrase and add exception.
Suggested Language: The maximum cross slope of pedestrian access routes shall be
2% (1:48). EXCEPTION: The maximum cross slope of a crosswalk can exceed 2%
(1:48) when a disruption in the roadway profile is created that consequently
creates a safety hazard. There shall be no cross-slope requirements for midblock
crossings.
Justification: Meeting the 2% (1:48) slope requirement would often introduce
objectionable profile variations into the roadway, and may even become a safety
hazard for motorists and bicyclists.
The proposed slope will impact our ability to drain intersections. The larger
the intersection, the more difficult drainage becomes. The introduction of a
flat grade would require extensive transitions in and out of them, especially at
high-speed intersections. If further restrictions are in place, the design would
result in a very rough ride through the intersection including vaulting and
dragging of trailers and/or hitches.
Because this maximum cross slope may create a bump in the road, vehicle contact
with the pavement will be reduced, thus reducing braking and maneuvering
ability.
Section 1103.5 Grade
Guideline Language: The grade of the pedestrian access route within a sidewalk
shall not exceed the grade established for the adjacent roadway.
EXCEPTION: The grade of a pedestrian access route shall be permitted to be
steeper than the grade of the adjacent roadway, provided that the pedestrian
access route is less than 1:20, or complies with 405.
Requested Change: Change wording to clarify.
Suggested Language: The grade of the pedestrian access route within a sidewalk
shall not exceed the grade established for the adjacent roadway, even if the
roadway is greater than 5% (1:20).
EXCEPTION: The permissible grade of a pedestrian access route may be steeper
than the grade of the adjacent roadway, provided that the pedestrian access
route is less than 5% (1:20), or complies with Section 405, “Ramps” of the ADAAG.
Justification: Not Applicable
Section 1103.6 Surfaces
Guideline Language: The surfaces of the pedestrian access route shall comply
with 302.
Requested Change: Change wording to clarify.
Suggested Language: The surfaces of pedestrian access routes shall comply with
Section 302, Floor and Ground Surfaces of the ADAAG.
Justification: A full citation of other referenced guidelines is needed for
clarity and uniform application of guidelines.
Section 1103.8 Changes in Level
Guideline Language: Changes in level shall comply with 303. Changes in level
shall be separated horizontally 30 inches (760 mm) minimum.
EXCEPTION: The horizontal separation requirement shall not apply to detectable
warnings.
Requested Change: Change wording to clarify.
Suggested Language: Changes in level shall comply with ADAAG Section 303 and
shall be separated horizontally by a minimum of 760 mm (30 in).
EXCEPTION: The horizontal separation requirement shall not apply to detectable
warnings.
Justification: A full citation of referenced guidelines is needed for clarity
and uniform application of guidelines. Additionally, the concerns raised in the
AASHTO response regarding maintenance and oversight of this treatment should
also be considered.
1104 Curb Ramps and Blended Transitions
Section 1104.2.1 Perpendicular Curb Ramps
Guideline Language: Perpendicular curb ramps shall comply with 1104.2.1, and
shall have a running slope that cuts through the curb at right angles or meets
the gutter grade break at right angles.
Requested Change: Include language from the discussion section emphasizing that
this is a “should” rather than a “shall” condition.
Suggested Language: Where conditions permit, it is preferable to have separate
curb ramps at a corner instead of a single ramp. Perpendicular curb ramps shall
comply with 1104.2.1, and shall have a grade that cuts through the curb at right
angles or meets the gutter grade break at right angles.
Justification: There are many space constraints at intersections that may not
always allow for the inclusion of perpendicular curb ramps. The options need to
be clear to designers.
Section 1104.2.2 Parallel Curb Ramps
Guideline Language: Parallel curb ramps shall comply with 1104.2.2, and shall
have a grade that is in-line with the direction of sidewalk travel.
Requested Change: Rephrase to include language for safety consideration.
Suggested Language: In limited situations where safety will not be further
compromised parallel curb ramps shall comply with 1104.2.2, and shall have a
grade that is in-line with the direction of sidewalk travel.
Justification: Parallel ramps can be hazardous in northern climates when a grade
is introduced in-line with the main direction of travel.
Section 1104.2.3 Blended Transitions
Guideline Language: Blended transitions shall comply with 1104.3, and shall have
running and cross slopes of 1:48 maximum.
Requested Change: Rewrite section to qualify that blended transitions should not
be recommended in many circumstances due to a variety of safety concerns.
Suggested Language: None recommended.
Justification: The language of the guidelines should be flexible and allow
designers to deal with safety issues on a case by case basis.
Section 1104.3.3 Surfaces
Guideline Language: Surfaces of curb ramps, blended transitions, and landings
shall comply with 302. Gratings, access covers, and other appurtenances shall
not be located on curb ramps, landings, blended transitions, and gutter areas
within the pedestrian access route.
Requested Change: Change from a “shall” to a “should” condition.
Add third qualifying sentence.
Suggested Language: In alteration and reconstruction projects, access covers and
other appurtenances should be avoided on curb ramps, etc. Any access covers that
must remain shall be flush and free of vertical variation 6 mm (0.25 in) or
horizontal gaps of 13 mm (0.50 in).
Justification: Prohibition of gratings, access covers and other appurtenances in
curb ramps, landings and blended transitions is too restrictive and impractical
at some intersections when it seems that the real intent is only to provide an
accessible pedestrian route free of hazards. A reasonable and practical option
is to allow for access covers that are flush and without vertical variations
exceeding 6 mm (0.25 in) or horizontal openings exceeding 13 mm (0.50 in).
Section 1104.3.7 Clear Space
Guideline Language: Beyond the curb line, a clear space of 48 inches (1220 mm)
minimum by 48 inches (1220 mm) minimum shall be provided within the width of the
crosswalk and wholly outside the parallel vehicle travel lane.
Requested Change: Change from a “shall” condition to a “preferred” condition.
Suggested Language: Beyond the curb line, a clear space of 1120 mm (48 in)
minimum by 1120 mm (48 in) minimum is recommended within the width of the
crosswalk and wholly outside the parallel vehicle travel lane.
Justification: Requiring a 1.2 m (48 in) clear space beyond the curb may be very
difficult and costly to achieve at many intersections constrained by adjacent
building development, etc. The justification for this requirement should be
re-evaluated. This proposed requirement necessitates a 1.2 m (48 in) minimum
shoulder or reaction distance in sections where only a 0.6 m (24 in) reaction
distance is normally required. The likely use of the intended clear space by
turning vehicles would present a safety problem for pedestrians if they were not
staying on the sidewalk until it is permissible to cross. The clear space may
provide a dangerously false sense of security for the pedestrian and even with
striping, it is likely to be disregarded or misunderstood by motorists.
1105 Pedestrian Crossings
Section 1105.2.1 Width
Guideline Language: Marked crosswalks shall be 96 inches (2440 mm) wide minimum.
Requested Change: Reword to reflect current MUTCD practice.
Suggested Language Marked crosswalks shall be a minimum of 1830 mm (72 in) wide.
A 2440 mm (96 in) width is desirable.
Justification: Because it is possible that the 2440 mm (96 in) crosswalk would
create a problem with the existing loop detector systems if moved toward the
stop bar, the additional width would likely move pedestrians closer to the
through traffic. The most frequently used sidewalk width in Minnesota is 1525 mm
(60 in). Additionally, there is no clear benefit derived from providing a wider
crosswalk.
Section 1105.2.2 Cross Slope
Guideline Language: The cross slope shall be 1:48 maximum measured perpendicular
to the direction of pedestrian travel.
EXCEPTION: This requirement shall not apply to mid-block crossings.
Requested Change: Change from a “shall” to a “desired” condition.
Add an additional exception.
Suggested Language: The maximum cross slope of the pedestrian access route shall
be 2% (1:48).
EXECPTION: The maximum cross slope of a crosswalk can exceed 2% (1:48) only if
it does not cause a disruption to the roadway profile that would consequently
create a safety hazard.
EXCEPTION: This requirement shall not apply to mid block crossings.
Justification: For profile grades greater than 2% (1:48) the designer needs to
provide a flat or “tabled area” through the intersection to meet the required
cross slope. To do this on a high-speed roadway will result in a forced profile
grade with short vertical curves. Automobile drivers will feel a weightlessness
effect going over such a profile. This same effect on trucks could create a very
serious safety hazard. Criteria need to be developed as to when and where this
should be applied. As the guidelines are currently presented, a designer would
have a serious conflict in applying this criteria.
Section 1105.2.3 Running slope
Guideline Language: The running slope shall be 1:20 maximum measured parallel to
the direction of pedestrian travel in the crosswalk.
Requested Change: Increase the running maximum running slope to 6% (1:16).
Suggested Language: The grade shall be 6% (1:16) maximum measured parallel to
the direction of pedestrian travel in the crosswalk for a maximum length of 38
feet. A running slope of 5% (1:20) is desirable.
Justification: Using a 1:16 maximum slope allows for the application of the
lowest maximum cross slope used by a majority of states. The 38 foot length
would accommodate the crossing of one direction of a four lane divided highway
on a curve that requires the maximum superelevation. In most situations,
pedestrian crossings are located in urban environments that have slower speeds.
A normal crown can be used there and meeting the running slope of 5% (1:20)
would be no problem except at parallel cross walks if the profile grade of the
roadway exceeds 5% (1:20).
Section 1105.3 Pedestrian Signal Phase Timing
Guideline Language: All pedestrian signal phase timing shall be calculated using
a pedestrian walk speed of 0.91 m/s (3.0 ft/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.
Requested Change: Use the proposed pedestrian signal timing on pedestrian
crossings where such timing does not force an increase in cycle length above
that required using current pedestrian timing. Where the proposed pedestrian
signal timing would force an increase in the cycle length, the proposed timing
should only be used upon request by the public or the municipality and after an
engineering study has shown there is an actual need for the extended time.
Justification: Pedestrian timing requirements are often a controlling factor of
the cycle length that can be run at an intersection. Extending the pedestrian
timing requirements will require longer than optimum cycle lengths at many or
most intersections, resulting in an increase in vehicle delay, pollution, and
fuel usage and also a delay to pedestrians waiting to cross. Increases in
congestion have been associated with reduced safety. If this were to be
implemented at every intersection in the US, the resulting detriment to
travelers and the environment would be staggering.
Additionally, with a longer pedestrian clearance time, pedestrians will soon
learn that they can still easily make it across the street even if the “Don't
Walk” is already flashing. This will encourage pedestrians to begin crossing the
street during the flashing “Don't Walk”, which is illegal and unsafe.
Pedestrians who need more time to cross can currently have more time by starting
to cross at the beginning of the walk period. The clearance time assumes
pedestrians start walking at the very end of the walk period.
A computerized traffic simulation/optimization program (Synchro) calculated the
impact of changing from our current pedestrian timing to the proposed timing at
5 of our signalized intersections to be as follows:
Total signal delay: increased 22 – 23%
Stops: increased 6 – 10%
Average speed: decreased 9-11%
Fuel consumed: increased 5 – 9%
Section 1105.4.2 Detectable Warnings
Guideline Language: Medians and refuge islands shall have detectable warnings
complying with 1108. Detectable warnings at cut-through islands shall be
separated by a 24-inch (610mm) minimum length of walkway without detectable
warnings.
EXCEPTION: Detectable warnings shall not be required on cut-through islands
where the crossing is controlled by signals and is timed for full crossings.
Requested Change: Reword exception.
Suggested Language: EXCEPTION: Detectable warnings shall not be required on
cut-through islands where the crossing is controlled by signals and is timed for
full crossings or when the median is four feet or less.
Justification: In situations where a four foot median is used, the Detectable
Warning Surface would provide no benefit, since there is no break in the surface
for the entire width of median.
Section 1105.5 Pedestrian Overpasses and Underpasses
Guideline Language: Pedestrian overpasses and underpasses shall comply with
1105.5.
Requested Change: Add an exception to clarify that this guideline applies to the
intersection of two sidewalk systems connecting services, and does not apply to
trails and paths intersecting with sidewalks.
Suggested Language: Pedestrian overpasses and underpasses shall comply with
1105.5.
EXCEPTION: Applies to sidewalks only.
Justification: There are numerous trails and paths, designed for multiple
non-motorized user groups, including bicycles and pedestrians, which are exempt
from these guidelines. Clarification is required to ensure appropriate
application of the guidelines.
Section 1105.5.3 Approach
Guideline Language: Where the approach exceeds 1:20, the approach shall be a
ramp 48 inches (1220 mm) minimum in width and shall comply with 405. Where the
rise of a ramped approach exceeds 60 inches (1525 mm), an elevator complying
with 407, or a limited-use/limited-application elevator complying with 408,
shall be provided.
Requested Change: Change provision for elevators from a "shall" condition to a
“may” condition.
Reconsider the 60 inches criteria for the rise of the ramped approach.
Suggested Language: Where the slope of the ramp exceeds 5% (1:20), the approach
shall be a ramp 1220 mm (48 in) minimum in width and shall comply with Section
405 of the ADAAG. Where the rise of a ramped approach exceeds 2440 mm (96 in),
an elevator complying with ADAAG Section 407, or a
limited-use/limited-application elevator complying with ADAAG Section 408, may
be provided.
Justification: Need not Justified:
Pedestrian bridges are a supplement to other forms of transportation already
available in the community. Because of the availability of alternative modes,
such as vehicles and special transit services, within a community an elevator
should not be mandatory unless it is the only reasonable route available between
public services.
Construction Cost:
The high construction costs of the elevators will substantially increase the
cost of a pedestrian bridge for its owners. The outcome of the increased cost is
that the benefit/cost ratio of a bicycle/pedestrian bridge with an elevator will
not allow transportation agencies to justify the construction of a
bicycle/pedestrian bridge with an elevator except in the most extreme locations.
Additionally, the safety value that these bridges provide to the general public
will be denied to everyone if pedestrian overpasses and underpasses become cost
prohibitive to build.
In cold regions such as Minnesota, an elevator enclosure may be required
increasing the cost of the elevator and enclosure well above the cost of the
pedestrian bridge.
Operations Maintenance:
To meet the proposed requirement will also demand significant cost in the area
of operation and maintenance. Most transportation agencies will need to contract
this service out due to expertise and licensing required to service this
equipment which will reduce flexibility with already limited funding.
Additionally, a high level of vandalism and misuse by individuals without
disabilities is very likely to occur at these unsupervised facilities thereby
increasing maintenance and liability costs.
No documentation was provided to indicate that the reliability of elevators in
cold climate that are fully exposed to all weather conditions, which will exist
on the right-of-way, is available or that they have been tested to operate with
minimal failure in severe summer and winter, snow and ice conditions. Research
on these topics is requested before developing a requirement
Personal Safety and security:
Surveillance and security systems will be required by agencies to monitor
activity in the elevators. Most public elevators are monitored with cameras to
avoid assaults, etc. This will require extensive infrastructure, staff, and
contract funds to perform this monitoring.
Liability:
The investment of significant personnel and funding resources are required to
keep elevators in operation and to respond to equipment failures. Given
Minnesota’s wide range of climatic conditions a user would be placed at a great
health risk if an elevator system stalls and they became trapped in a stalled
elevator for even a short period of time in sub-zero temperatures or over 100
degree temperatures.
Section 1105.6.1 Separation
Guideline Language: Continuous barriers shall be provided along the street side
of the sidewalk where pedestrian crossing is prohibited. Where railings are
used, they shall have a bottom rail 15 inches (380 mm) maximum above the
pedestrian access route.
Requested Change: Clarify what materials and treatments may be considered for
the development of a continuous barrier.
Remove requirement for a continuous barrier.
Suggested Language: A continuous grass berm shall be provided along the street
of the sidewalk where pedestrian crossing is prohibited.
Justification: Requiring a physical separation seems to be an unreasonable
requirement to apply only to roundabouts. There are many street configurations
that are not normal perpendicular intersections and railings are not required
for them. Most roundabout designs have grass berms around them so visually
impaired persons can detect when leaving the sidewalk.
Section 1105.6.2 Signals
Guideline Language: A pedestrian activated traffic signal complying with 1106
shall be provided for each segment of the crosswalk, including the splitter
island. Signals shall clearly identify which crosswalk segment the signal
serves.
Requested Change: Remove the requirements for pedestrian activated traffic
signal and research this issue. Research might include evaluation of surface
treatments to help a visually impaired person detect an approaching vehicle.
Suggested Language: No language is recommended at this time.
Justification: Minnesota requires motorists to yield to pedestrians in the
crosswalk, as do most states. The crosswalk is set back one car length, which
helps to make the crosswalk perpendicular to the roadway. In addition with this
placement the pedestrian is crossing in front of the driver as they approach
before the driver starts to prepare for the merge. Roundabouts have low-speed
traffic with good visibility of the crosswalk areas. This concept also has some
of the lowest collision rates of any traffic control device. There is no
accident history to support a pedestrian activated signal system.
There are a number of advantages that roundabouts have for pedestrians. First,
the number of conflict points is much lower. A pedestrian at a roundabout has 2
conflict points (entering and exiting right turners) compared with 6 conflicts
at a standard four-leg intersection. No hazardous left-turn movements are
present. Second, severe crashes caused by inattentive driving are eliminated.
Crashes that occur when motorists run red lights, ignore stop signs, and make
right turns on red do not happen at roundabouts. The design forces a driver to
slow down and pay attention. Third, pedestrian exposure to traffic is much lower
because the crossings are shorter. The splitter islands at the roundabout
approaches allow people to cross one lane of slow-moving traffic at a time,
instead of four lanes of traffic that would likely be traveling very fast
through a signalized intersection. A pedestrian activated signal requirement
would certainly discourage the use of roundabouts and those benefits would be
lost to the pedestrian.
Section 1105.7 Turn Lanes at Intersections
Guideline Language: Where pedestrian crosswalks are provided at right-or
left-turn slip lanes, a pedestrian activated traffic signal complying with 1106
shall be provided for each segment of the pedestrian crosswalk, including at the
channelizing island.
Requested Change: Eliminate pedestrian activated signal requirement.
Use the more common industry term of “free rights” rather than “slip lanes”.
Suggested Language: Where pedestrian crosswalks are provided at free right
turns, a painted crosswalk shall be provided.
Justification: The proposed language would require accessible pedestrian signals
at locations where there are currently no signals, accessible or not. See the
previous comment supporting the installation of accessible pedestrian signals
only upon request and with an engineering study. Some of these locations may
have no pedestrian activity of any sort and would not require any pedestrian
signals, accessible or not, except for this requirement. Guidance as to where
this criterion would be applied should be developed.
Also, to put in the pedestrian signals would also require installation of
vehicle indications on these lanes, requiring all vehicles turning right to stop
on red. Currently, there are yield sign controls on these lanes. At a location
where no pedestrians are present, requiring every vehicle to stop at a new red
signal indication will create significant delays, pollution, and fuel
consumption.
The issue of signalizing free-right movement needs research that addresses the
placement of signal heads and stop bars that will be visible to motorists and
the development of warrants for the application of the free-right island.
Signalized intersections, even with pedestrian indications, do not ensure the
safety of pedestrians in the crosswalk. Adding signal control to the free-right
will confuse drivers and induce a false sense of security for pedestrians.
Unless a significant pedestrian demand is present, this could add the potential
for massive violations.
1106 Accessible Pedestrian Signal Systems (APS)
Section 1106.2 Pedestrian Signal Devices
Guideline Language Each crosswalk with pedestrian signal indication shall have a
signal device, which includes audible and vibrotactile indications of the WALK
interval. Where a pedestrian pushbutton is provided, it shall be integrated into
the signal device and shall comply with 1106.3.
Requested Change: Change “shall” condition to “should” and “may” condition to
allow for the use of engineering judgement to determine need on a case by case
basis or remove the requirement. If the requirement is retained, additional
guidance on determining when to install APS is needed.
Suggested Language: Each crosswalk with pedestrian signal indication should have
a signal device that may include audible and vibrotactile indications of the
WALK interval where needed. Where a pedestrian pushbutton is provided, it should
be integrated into the signal device and comply with 1106.3.
Justification: The recommendation to change the requirement from “shall” to
“should” is based upon the fact that there is not clear agreement that APS is
warranted for all situations. In Minnesota there is not consensus among people
who are visually impaired as to whether the accessible pedestrian indications
are an improvement or a hindrance in crossing the roadway. One strong point of
view that has been conveyed to Mn/DOT is that the accessible pedestrian systems
mask the primary cue created by the sound of traffic, reducing accessibility for
some users. However, there is consensus among persons who are visually impaired
that accessible pedestrian signals need not be installed at all locations and
that guidelines can be developed to identify appropriate locations based on
requests and engineering studies.
Section: 1106.2.1 Location
Existing Language: 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.
EXCEPTION: The minimum distance from other signal devices shall not apply to
signal devices located in medians and islands.
Requested Change: Change these distances to goals, with shorter distances as the
minimum requirement.
Suggested Language: No language recommended.
Justification: Due to wide variation in the geometry and constraints found at
each intersection, there are likely to be many instances where the
implementation of such precise requirements will be infeasible, especially in
reconstruction projects.
Section 1106.4 Directional and Information Signs
Guideline Language: Pedestrian signal devices shall provide tactile and visual
signs on the face of the device or its housing or mounting indicating crosswalk
direction and the name of the street containing the crosswalk served by the
pedestrian signal.
Requested Change: All sign designs should be in conformance with the Manual on
Uniform Traffic Control Devices (MUTCD).
Suggested Language: See the MUTCD for language and specifications.
Justification: Uniformity is essential in the design and application of traffic
control devices to ensure user safety. Recommendations that deviate from
recognized standards compromise that safety.
1107 Street Furniture
Section 1107.2 Clear Floor or Ground Space
Guideline Language: 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 by 12
inches (305 mm) maximum.
Requested Change: Reword second sentence for clarity.
ADAAG Section 305.2 requires a 2% (1:48) slope on the clear floor and ground
space that can be accommodated in the sidewalk cross slope direction but not the
direction of the grade of the sidewalk. Create an exception to document this.
Suggested Language: The clear floor or ground space may overlap the pedestrian
access route by 305 mm (12 in) maximum.
EXCEPTION: The slope of the clear floor or ground may be steeper than 2% (1:48)
in the direction of the running slope for the sidewalk, but shall not exceed the
grade established for the adjacent roadway.
Justification The text of the second sentence is confusing. It seems to read as
a requirement for the clear floor or ground space to overlap into the pedestrian
access route without stating why an overlap would be desirable. It is more
appropriate to minimize the overlap to no more than 305 mm (12 in) as long as
access to the furniture is compliant with appropriate provisions for this
guideline.
Clarification and Exception required for 2% (1:48) slope on clear floor or
ground
It is critical to point out the proposed exception to Section 305.2 of the ADAAG
because it will be technically infeasible to meet the 2% (1:48) slope in the
direction of the grade of the sidewalk in the same way that it is infeasible for
sidewalks to meet the 5% (1:20) maximum slope requirements.
Section 1107.4.1 Single Telephone
Guideline Language: Where a single public telephone is provided, it shall comply
with 704.2 and 704.4.
Requested Change It is strongly recommended that a separate process be initiated
to seek legislation that will place and fund the implementation of this
guideline with the Public Communications Commission/Public Pay Phone Companies
for all public pay phones in the nation.
Add an exception to allow compliance with ADAAG Sections 704.2 and 704.4. The
exception will allow for the necessary design for Clear Floor and Ground Space
found in section 1107.2
Suggested Language: EXCEPTION: The slope of the clear floor or ground space may
be steeper than 2% (1:48) in the direction of the grade for the sidewalk, but
shall not exceed the grade established for the adjacent roadway.
Justification This requirement may reduce the total number of public phones
installed due to the requirement to provide electrical services and maintain the
equipment.
TTY equipment is often purchased and owned directly by the transportation
agency, not leased from the phone companies, due to cost of equipment over time.
Historically, many smaller phone companies have not offered leasing or
maintenance of this equipment. Maintenance of the equipment is problematic in
that only the phone company operating the public pay phone has the legal
authority to connect and disconnect TTY equipment into the public phone systems.
It is impossible for transportation agency staff to effectively maintain this
equipment on public phones on right-of-way.
For this reason it is strongly recommended that a separate process be initiated
to seek federal legislation requiring the public pay phone companies to provide
this service in accordance with these guidelines and collect a public surtax to
cover the cost.
See the Following Sections for Additional Comments for this Item
1107.2 Clear Floor or Ground Space: Justification: Clarification and Exception
required for 2% (1:48) slope on clear floor or ground space.
Section 1107.4.2 Multiple Telephones
Guideline Language: Where a bank of public telephones is provided, at least one
telephone shall comply with 704.2, and at least one additional telephone shall
comply with 704.4.
Requested Change: See comments for 1107.4.2 above for references to Sections
704.2 and 704.4 of the ADDAG.
Add a definition for “a bank of public telephones”.
Add exception.
Suggested Language: No language is recommended at this time for “a bank of
public telephones”.
EXCEPTION: The slope of the clear floor or ground space may be steeper than 2%
(1:48) in the direction of the running slope for the sidewalk, but shall not
exceed the grade established for the adjacent roadway.
Justification: See comments provided under Justification for sections:1107.2
Clear Floor or Ground Space and 1107.4.1 Single Telephone.
Section 1107.5 Public Toilet Facilities
Existing Language: Permanent or portable public toilet facilities shall comply
with 603. At least one fixture of each type provided shall comply with 604
through 610. Operable parts, dispensers, receptacles, or other equipment shall
comply with 309.
EXCEPTION: Where multiple single-user toilet facilities are clustered at a
single location, at least 5 percent , but no fewer than one single-user toilet
at each cluster shall comply with 603 and shall be identified by the
International Symbol of Accessibility complying with 703.7.2.1.
Requested Change: Delete reference to the Sections of the ADAAG that are not
appropriate for roadside toilets. These sections include 607-608 referring to
tubs and showers and Section 610 referring to tub and shower seats.
Suggested Language: Permanent or portable public toilet facilities shall comply
with ADAAG Section 603. At least one fixture of each type provided shall comply
with ADAAG Sections 604 through 606 and 609.
Justification: Transportation agencies do not provide mixed-use facilities
(living or service spaces with showers) on the right-of-way that are not already
covered under other sections of the building and site facilities chapter of the
ADA guidelines
Section 1107.6 Tables, Counters, and Benches
Guideline Language: Tables, counters, and benches shall comply with 1107.6
Requested Change: Reword.
Suggested Language: Stationary tables, counters, and benches shall comply with
1107.6.
Justification: Designate that this guideline applies to stationary (fixed
location) furniture only. Non-fixed objects of this type (often temporarily
placed) are highly movable by one or two persons because they are small and
lightweight. It is impossible to control the location of and accessibility to
movable benches and tables, etc.
Section 1107.6.1 Tables
Guideline Language: Where tables are provided in a single location, at least 5
percent but no less than one, shall comply with 902.
Requested Change: Add an exception.
Suggested Language: EXCEPTION: The slope of the clear floor or ground may be
steeper than 2% (1:48) in the direction of the grade of the sidewalk, but shall
not exceed the grade established for the adjacent roadway.
Justification: See the Following Sections for Additional Comments for this Item
1107.2 Clear Floor or Ground Space: Justification: Clarification and Exception
required for 2% (1:48) grades on clear floor or ground space.
Section 1107.6.2 Counters
Guideline Language: Where provided, counters shall comply with 904.
Requested Change: Add an exception.
Suggested Language: EXCEPTION: The slope of the clear floor or ground may be
steeper than 2% (1:48) in the direction of the grade of the sidewalk, but shall
not exceed the grade established for the adjacent roadway.
Justification See the Following Sections for Additional Comments for this Item
1107.2 Clear Floor or Ground Space: Justification: Clarification and Exception
required for 2% (1:48) slope on clear floor or ground space.
Section 1107.6.3 Benches
Guideline Language: Where benches without tables are provided at a single
location, at least 50 percent, but no fewer than one, shall comply with 903 and
shall have an armrest on at least one end.
Requested Change: Add an exception
Suggested Language: Where benches without tables are provided at a single
location, at least 20%, but no fewer than one, shall comply with Section 903 of
the ADAAG.
EXCEPTION: The slope of the clear floor or ground may be steeper than 2% (1:48)
in the direction of the grade of the sidewalk, but shall not exceed the grade
established for the adjacent roadway.
Justification: Design flexibility should allow for the use of benches without
backs mixed with benches with backs at a ratio of 1:5 or greater to permit
designs that achieve the intended architectural design objectives and still
provide accommodations within a limited distance. Backless benches allow users
to face the street or to choose their orientation based on the wind direction,
sun angle, views or other personal reasons and also fit where back-to-back
benches would not fit in a very limited space or blend with the aesthetics of
the site. The ratio of 1:5 will allow for some minor flexibility to mix the use
of benches with and without backs within a single location (close proximity area
of 30.5 m (100 ft) to 61 m (200 ft)).
Unless unique conditions exist that justify conflicting guideline requirements
for the same element within the ADA, guideline chapters should be uniform to
avoid inconsistencies in design application and enable uniformity in
enforcement.
1108 Detectable Warning Surfaces
Section 1108.1 General
Guideline Language: Detectable warnings shall consist of a surface of truncated
domes aligned in a square grid pattern and shall comply with 1108.
Requested Change: Omit the requirement pending further study.
Suggested Language: Delete section and all related references.
Justification: Numerous comments have been brought forward regarding the
maintenance of these facilities in cold weather climates. In particular, there
is concern that the complete and timely clearing of the facilities after a snow
event may not be possible and could create a hazardous situation for all users
and become a liability risk. At this time, it is recommended that the Access
Board sponsor additional research to develop best practices regarding the
maintenance of truncated domes.
Concern has also been raised about how the use of truncated domes impacts
skateboarders, scooter and in-line skate users. Research sponsored by the State
of Florida with Charlie Zeeger P.E. as principle investigator, has shown that
truncated domes consistently “down” this user group as they attempt to navigate
the truncated domes. The result is that accommodation of one user group occurs
at the expense of another, and communities are being asked to knowingly create a
hazardous condition, which may not be legally defensible. This is not an
acceptable or appropriate situation and it is strongly recommended that the
Access Board continue to research other treatments that will allow for the
accommodation of all user groups.
1109 On Street Parking
Section 1109.1 General
Guideline Language: Car and van on-street parking spaces shall comply with 1109.
Requested Change The Access Board should develop a paragraph specifying when a
van space should be provided instead of a car space.
Suggested Language: No language is being recommended at this time.
Justification: Equal access cannot be guaranteed to all user types if a
reasonable ratio of van spaces is not provided in the urban areas. A
distribution based on Parallel Parking Spaces (access aisle at least 1.5 m (5
ft) vs. Perpendicular or Angled Parking Spaces (Where an access aisle is 2.4 m
(8 ft) is insufficient. This is an unreasonable approach to providing reasonable
accommodations because it does not ensure that a van stall will be provided
within a multi-block area. At this time the ADAAG requires the van stalls have a
2.4 m (8 ft) aisle.
Section 1109.2 Parallel Parking Spaces.
Guideline Language: An access aisle at least 60 inches (1525 mm) wide shall be
provided at street level the full length of the parking space. The access aisle
shall connect to a pedestrian access route serving the space. The access aisle
shall not encroach on the vehicular travel lane.
EXCEPTION: An access aisle is not required where the width of the sidewalk
between the extension of the normal curb and boundary of the public right-of-way
is less than 14 feet (4270 mm). When an access aisle is not provided, the
parking space shall be located at the end of the block face.
Requested Change: Add text to reflect bicycle safety concerns.
Due to environmental and existing road conditions it is not reasonable to
develop a 2% (1:48) level access aisle at all locations.
Provide exceptions.
Suggested Language: The access aisle shall not encroach on the vehicular travel
lane or on the bicycle travel lane.
1. EXCEPTION: An access aisle is not required where the width of the sidewalk
between the extension of the normal curb and boundary of the public right-of-way
is less than 4874 mm (16 ft). When an access aisle is not provided, the parking
space shall be located at the end of the block face.
2. EXCEPTION: Although the access aisles are also used for wheelchair transfer
to and from vehicles, the slope may be steeper than 2% (1:48) but shall not
exceed the grade established for the adjacent roadway.
Justification: Bicycle Safety
It is critical that designated bicycle lanes are not impacted or eliminated..
This significant and growing transportation mode is designed as a network, with
selected routes based on demand and safety accommodations for the rider. Roadway
alterations that affect the system or safety design of these facilities will
have a negative effect on the safety of bicyclists.
Safety for Visually Impaired Pedestrians
Moving the curb in to allow for an access aisle along side of a car appears to
help one group and create a problem for another. A person, who is visually
impaired, walking parallel to the roadway on the sidewalk, will find the
proposed concept confusing. People who are visually impaired tend to walk near
the inside edge of the walk, however, jogs in the walk may introduce problems.
Clarification and Exception required for 2% (1:48) slope on access aisle
The proposed exception to ADAAG Section 502.3 is critical because it will be
technically infeasible to meet the 2% (1:48) slope requirement in on-street
parking accommodations in the same way that it is infeasible for sidewalks to
meet the 5% (1:20) maximum slope requirements.
Width of Public Right-Of-Way must be 16 Feet Wide
The 14-foot exception is not adequate and should be 4.6 m (15 ft). The rebuild
to accommodate an accessible stall requires 1.5 m (5 ft) of sidewalk converted
to access aisle at street level, plus a 1.8 m (6 ft) for a curb ramp using the
perpendicular ramp, plus 1.2 m (4 ft) of landing/clear route at the top of the
ramp. The total requirement to meet these minimums is 4.6 m (15 ft).
Parking at End of Block
Proposed guidelines state that where the right-of-way width for an access aisle
is not provided, the parking space may be placed at the end of the block, which
is where they are now typically located and signed. This is generally a
reasonable alternative.
Water and Drainage Impact on Accessible Stall when Curb Line is Altered
Depending on roadway grade, cross slopes volume of and design for surface water
removal, modifications to the curb alignment to accommodate the 1.5 m (5 ft)
access aisle may adversely impact the access aisle, ramps or blended transitions
with excess amounts of pooled water and in winter, ice. When the roadway, due to
existing roadway constraints, utility locations and environmental conditions,
cannot be designed to remove water from the on-street parking stall, an
alternative parking accommodation, such as “Parking at the End of Block”, should
be allowed. This is especially critical in northern climates.
Winter Condition Snow Removal
Roadway plows cannot remove snow from an indented access aisle. Snow removal
will be considered a secondary priority - delayed until after the major snow
event is over and snow emergency work for main roads is complete. Northern
states that have a substantial amount of snow over a long season, should be
allowed to develop off-street parking facilities that will be plowed more
quickly than the individual remote stalls could be.
Section 1109.3 Perpendicular or Angled Parking Spaces
Guideline Language: Where perpendicular or angled parking is provided, an access
aisle 96 inches (2440 mm) wide minimum shall be provided at street level the
full length of the parking space and shall connect to a pedestrian access route
serving the space. Access aisles shall be marked so as to discourage parking in
them.
Requested Change: The elements/conditions stated in this paragraph and
additional information that is more comprehensive and clearly written already
exists in ADAAG Sections 502.3 through 502.6. Access aisles should comply with
ADAAG Sections 502.3 through 502.6 and specifically include an exception to
ADAAG Section 502 requirements for slope.
Some exceptions should be provided so that reasonable percentages of the total
available parking spaces and distribution for close access are considered and
applied.
Suggested Language: Where perpendicular or angled parking is provided, an access
aisle of 2440 mm (96 in) wide minimum shall be provided. It shall comply with
ADAAG Sections 502.3 through 502.6 and shall connect to a pedestrian access
route serving the space.
EXEMPTION: Although the access aisles are also used for wheelchair transfer to
and from vehicles, the slope may be steeper than 2% (1:48) but shall not exceed
the grade established for the adjacent roadway.
EXCEPTION: Reductions of parking capacity by over 10% are not required as long
as a minimum of two accessible parking spaces per block are provided.
Justification Clarification and Exception required for 2% (1:48) slope on access
aisle
The proposed exception to ADAAG Section 502.3 is important because it will be
technically infeasible to meet the 2% (1:48) slope requirement in on-street
parking accommodations in the same way that it is infeasible for sidewalks to
meet the 5% maximum slope requirements.
In cases where the access aisle for on-street parking exceeds a slope of 2%
(1:48), alternative parking accommodations should be considered to replace the
one parking stall per block face requirement so that the parking stalls provided
will better meet the objective of providing access for all.
Proposed Distribution of On-Street Parking Seems Excessive
The required access aisle is equal to the size of an average parking stall. This
will result in a net reduction of two general parking stalls per block face. In
some communities, this may excessively reduce the availability of general
population on-street parking. Reduction of parking capacity by over 10% should
not be required so long as a minimum of two accessible parking spaces per block
are provided.
Section 1109.4 Curb Ramps or Blended Transition
Guideline Language: A curb ramp or blended transition complying with 1104 shall
connect the access aisle to the pedestrian access route.
Suggested Language: See comments for 1104.
Justification: See comments for 1104
Section 1109.5 Obstructions
Guideline Language: There shall be no obstructions on the sidewalk adjacent to
and for the full length of the space. EXCEPTION: This provision shall not apply
to parking signs complying with 1109.6 and parking meters complying with
1109.7.2.
Requested Change: Modify this section to provide for 0.6 m (2 ft) clearance to
the curb along the parking space.
Suggested Language: No language is suggested at this time.
Justification: Elimination of All Obstructions Seems Excessive
There seems to be no logical reason for the ban on obstructions abutting the
parking space. A 0.6 m (2 ft) clearance to accommodate door swing seems
appropriate; however the elimination of all obstructions seems excessive. Space
for unloading is part of the access aisle space requirements. Features such as
light poles, trees and other street-scaping in the area that abuts the space but
are outside a 0.6 m (2 ft) clear zone will not adversely affect the usefulness
of the parking space. These features are important to the overall use, safety,
and appearance of the street.
Section 1109.7.3 Displays and Information
Guideline Language: Displays and information shall be visible from a point
located 1015 mm (40 in.) maximum above the center of the clear floor space in
front of the meter.
Requested Change The wording of this section is somewhat unclear and no size is
required for text.
Suggested Language Revise section to provide intended guidance.
Justification: Not Applicable
1111 Alternate Circulation Path
Section 1111.1 General
Guideline Language: Alternate circulation paths shall comply with 1111.
Requested Change: The inclusion of any other sections that must be adhered to
regarding surfaces, cross slope, grades, etc.
Change “Alternate Circulation Path” to “Pedestrian Detour”.
Suggested Language: Not applicable.
Justification: The clarification is necessary to set the baseline for the
expected level of service and provide assistance to designers in the
determination of the appropriate location of the alternate circulation path.
Pedestrian detour is preferred because it is an established and recognized term
within the transportation industry.
Section 1111.3 Location
Guideline Language: The alternate circulation path shall parallel the disrupted
access route, on the same side of the street.
Requested Change: Add exception.
Suggested Language: A pedestrian detour shall be parallel to the pedestrian
access route on the same side of the street.
EXCEPTION: When a parallel path on the same side of the street is not
technically feasible, pedestrians will be routed to the nearest facility. The
pedestrian detour shall have adequate access and notification.
Justification: In construction zones it is not always desirable or safe to walk
next to the construction site. Access for construction equipment and materials,
the availability of right-of-way, and the safety of workers and pedestrians must
be factored into the final determination in the creation of a pedestrian detour.