Andrew J. Davis, P.E.
October 28, 2002
City of Akron
Akron Engineering Bureau
The “Draft Public Rights-of-Way Accessibility Guidelines” were circulated
throughout various departments of the City of Akron. We are forwarding to you a
compilation of comments that were received for use in the development of
accessibility guidelines for the public right-of-way.
1. Our city is older and the majority of new development has already occurred.
We are mainly concerned with “alterations” and need guidance for applying the
new construction standards to existing conditions. We recommend you put a
guidance manual for alterations out for public comment as well. When the final
rule for public right-of-ways is enacted, the final “alterations manual” should
be issued as a companion.
2. Some of the suggested improvements such as tabling intersections, providing
elevators, and possible right-of-way acquisition may have significant financial
impacts. We request guidance on scoping ADA improvements for various types of
projects, and we ask for guidance on how to define feasibility from a financial
3. We recommend reserving the requirements for elevators on pedestrian bridges
over expressways and the requirements at roundabouts until further research can
be provided on these matters.
4. A number of requirements seem excessive if applied universally: Accessible
Pedestrian Signals (APS) at all signal locations; 3 feet per second crossing
time, one accessible parking space on each block face. Some of these
improvements should be driven by engineering analysis, a study of usage, or
citizen request. Many of the traffic control features on existing roadways are
determined this way, by a warrant based on volume or some other measure, or by a
request (such as a school).
5. If the requirement to increase crosswalk striping width by two feet were
implemented, this should only be done on new striping locations or after a
street has been resurfaced. It is difficult to erase existing striping and
repaint. The cost would be very high if required to restripe all crossings in
6. Requiring APS installation at all existing pedestrian signals/buttons will be
very costly if required to convert existing equipment immediately. Many cities
may eliminate pedestrian buttons for this reason.
7. Narrow streets may limit the aisle from being installed for accessible
8. The 120” between pedestrian signal devices may be prohibitive in existing
narrow right-of-ways. More alternatives are needed. Perhaps mounting of devices
on a single combined pole would be acceptable. Does the 120” rule apply to the
pedestrian signal head also?
9. The definition of “public right-of-way” needs to be more specific. Several of
the definitions should match current engineering/public works usage to avoid
10. 1102.1 – Clarify for applications that may overlap the public right-of-way
such as public buildings that may encroach the right-of-way; utility tunnels;
11. “Maximum extent feasible” and “technically infeasible” are very relative
terms. Please provide specific guidelines, applications, and examples of what is
acceptable practice in alterations to existing right-of-ways.
12. Alternate Circulation Route for construction will be either very expensive
or impractical. Often construction practice allows the closing of routes to
expedite the work. Often the existing condition of the sidewalk may be
inaccessible before a project begins.
13. 1104.3.3 It may be impractical to move certain grates and utility covers
from ramp locations depending on their existing location, space available, and
cost to move relative to project cost.
14. 1104 The notes in the front indicate the preference for dual ramps per
corner. The way section 1104 is written it does not exclude or discourage the
use of diagonal ramps. Practically, diagonal ramps will need to be allowed due
to right-of-way constraints. Ramp orientation even with dual ramps can vary
enough that the ramps should not be used as a cue for directionality. As section
1104 is written diagonal ramps would be accepted and used on the majority of
intersections in our city, except where existing right-of-way is wide enough to
accommodate two ramps.
15. More could be said regarding parallel ramps and the “depressed landing”. Any
ramp with a “depressed landing” is subject to problems with drainage and debris
collection. They should only be used as a last resort in the narrowest
right-of-ways. More could be said to describe blended transitions or
“combination type” ramps. In fact, this type may be the most used due to
right-of-way constraints. Perhaps a requirement for proper drainage should be
We thank you for the opportunity to comment on your draft guidelines and hope
our comments help with your work.
Please contact Andy Davis at [...] if you need further information.
Andrew J. Davis, P.E.
Civil Engineer III
David J. Celik, P.E.