We have reviewed the Americans with Disabilities Act Accessibility Guidelines
and the comments and recommendations
AASHTO to the guidelines. We are in agreement with the comments and
recommendations made by AASHTO. However, we would like to emphasize the
requirements, which will most directly effect us.
Section 1102.2.2 – Alterations
“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: In alterations, where compliance with applicable provisions is
technically infeasible, the alteration shall comply to the maximum extent
There is no clear definition of an alteration. We need to know what types of
work such as maintenance, replacement, or improvements on the signals, roadway,
or sidewalk will trigger the alteration requirement. Does it mean that any
replacement, upgrade, or modification will require us to meet the provisions of
Chapter 11? We could be in a position where any upgrade of existing facilities
would require large expenditures of money to meet ADAAG requirements. Depending
on the extra cost, projects could be postponed or moved down the priority list
and replaced by other projects.
Section 1102.3 – Alternate Circulation Paths
An alternate circulation path complying with [Section] 1111 shall be provided
whenever the existing pedestrian access route is blocked by construction,
alteration, maintenance or other temporary conditions.
Section 1111.3 – Location [of Alternate Circulation Paths]
“The alternate circulation path shall parallel the disrupted pedestrian access
route, on the same side of the street.”
When a sidewalk is blocked because of construction, the natural detour route is
the other side of the street or around the block to avoid the construction area.
Placing a person with disabilities into a construction area with construction
equipment and other hazards is not a good idea. Only in special cases where
access to a particular building must be maintained do we make special
Section 1105.2.2 – Cross Slope [of crosswalks]
“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
On our primary highways we normally give priority to our primary highway and
carry the profile grade through the intersection. In all cases where the profile
grade is over 2%, we would be required to adjust the grades to provide a 2%
cross slope for the cross walk. In hilly areas with profile grades greater than
2%, using minimum length vertical curves (100' or greater), we would be faced
with total replacement of the existing highway pavement to meet the 2% cross
walk requirement. With steeper profile grades, we could not even meet minimum
vertical curve requirements.
We recommend that the cross walk slope be tied to the existing topography in the
project area, matching the profile grade of the highway like the mid-block cross
Sections 1105.6, 1105.6.1, and 1105.6.2 – Roundabouts, including separation and
Section 1105.6 – Roundabouts: “Where pedestrian cross walks and pedestrian
facilities are provided at roundabouts, they shall comply with 1105.6.”
Section 1105.6.1 – Separation [at roundabouts]:
“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 (380mm) maximum above the pedestrian access route.”
Section 1105.6.2 – Signals [at Roundabouts]:
“A pedestrian activated signal complying with [Section] 1106 shall be provided
for each segment of the cross walk, including the splitter island. Signals shall
clearly identify which cross walk segment the signal serves.”
Stopping traffic at roundabouts is contrary to the philosophy of roundabouts and
defeats the purpose of constructing them in any location.
We recommend “reserving” section 1105.6 through 1105.6.2 until the
Transportation Research Board’s National Cooperative Highway Research Program (NCHRP)
Project 3-65, “Applying Roundabouts in the United States”, is complete.
Will Stein, P.E.
Design Methods Engineer
Iowa Department of Transportation