Alan R. Zahradnik
October 28, 2002
Re: Comments on Draft Guidelines for Accessible Public Rights-of-Way
The Golden Gate Bridge, Highway and Transportation District (District) is
pleased to respond to the Architectural and Transportation Barriers Compliance
Board’s (ATBCB) draft guidelines addressing accessibility in the public
District operates the Golden Gate Bridge and provides public bus, ferry, and
paratransit services within the U.S. Highway 101 corridor between destinations
in the counties of Marin, Sonoma, Contra Costa, and San Francisco, California.
Golden Gate Transit (GGT) serves approximately 1200 bus stops and transit
facilities within these four counties. These stops are located within the public
right-of-way of over 22 different city and unincorporated county jurisdictions.
In addition, GGT has over 30 years of experience providing public transit
services, including cooperating with those agencies that have jurisdiction over
the rights-of-way where these stops are located. Based on this experience, the
District has the following comments regarding the draft guidelines:
1. Guideline No. 1102.7.1- Bus Route Identification:
This guideline provides that 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.
District Comment: ATBCB should remove the requirement for Braille and raised
letter route identifications. It is common for transit agencies to change
schedules and routes three and four times per year. Transit agencies also
replace or install bus shelters often. In order for signs to be made which
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. Average costs
of having dies fabricated begin at fifteen hundred dollars. The expense of
fabricating signs and the logistics of installing/replacing Braille and raised
letter signs would be prohibitive to transit authorities. Technological advances
in the future may provide the opportunity to more practically address this issue
compared to the regulation that is being proposed.
In addition, some stops have many routes serving one location. The proposed
change, which would lower the mid-sign reach of 48 inches, would effectively
require route number signs that would span the interiors of bus stop shelters.
2. Guideline No. 1103.3 - Pedestrian Access Route Clear Width: The guideline
provides that the minimum clear width of a pedestrian access route be 48 inches
(1220 mm), exclusive of the width of the curb.
District Comment: The District believes it could be impractical to provide a
total clear width of 54 inches from face of curb to the back of the sidewalk.
There is insufficient right-of-way for this purpose in many jurisdictions. Many
sidewalks are about 42 inches wide to face of curb with utility and other poles
at various locations within the sidewalk area. Some jurisdictions have 24 inches
to 36 inches clear zone from the face of curb where no utility poles/trees/bus
signs shall be installed. Adding the 24 inches utility-clear zone, the diameter
of a utility pole base (about 12 inches to 18 inches), and the proposed 48
inches clear pedestrian access width would result in a sidewalk that was 84
inches wide. Any sidewalk improvement to meet this standard could require
acquiring property from adjacent private property owners. This would potentially
be very difficult to do and, if accomplished, would significantly increase
project cost. Such a provision would discourage local jurisdictions from
improving sidewalks within their public right-of-way.
This paragraph may also preclude a transit system from installing a bus sign on
a sidewalk that is less than 72 inches (6 feet) wide (24 inches clear zone from
face of curb and 48 inches ADA clear zone). The definition of accessibility
clearances around the bus stop or information sign is also not clear. If the 48
inches ruling applies around the entire sign, this poses another significant
3. Guideline Nos: 1104.3.2 Detectable Warnings. The guideline provides that
detectable warning surfaces complying with guideline 1108 shall be provided,
where a curb ramp, landing, or blended transition connects to a crosswalk.
1108.1 General. The guideline provides that detectable warnings shall consist of
a surface of truncated domes aligned in a square grid pattern and shall comply
1108.1.4 Size. The guideline provides that 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.
District Comment: The District recommends the requirement for truncated domes at
curb ramps, landings and blended transitions be removed from the guidelines.
Truncated domes should only be used on transit platform edges. Truncated domes
can set off muscle spasms for spinal injury citizens in wheelchairs. Use of
truncated domes in curb ramps and crosswalks which are adjacent to light rail or
commuter rail platforms may cause persons who are blind or partially sighted to
become confused as to where they are and could lead to serious injury. An
alternative tactile tile should be used in this application. If the provision is
not removed, the minimum standard should be 36 inches in the direction of
Thank you for the opportunity to comment on this proposal. District looks
forward to a Notice of Proposed Rulemaking that considers and is responsive to
the comments outlined above.
Very truly yours,
Alan R. Zahradnik