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 Boards (Access Board) draft guidelines addressing accessibility in the public right-of-way.
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.
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.
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 OGrady at [... ].
William W. Millar, President
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