Arthur T. Leahy
October 24, 2002
The Orange County Transportation Authority (OCTA) is pleased to respond to the
Architectural and Transportation Barriers Compliance Board’s (Access Board)
draft guidelines addressing accessibility in the public right-of-way.
OCTA is the primary provider of public transportation services in Orange County,
California and operates in an area of 797 square miles, serving 34 cities,
unincorporated areas and 2.8 million residents. Fixed route transit services
provided by OCTA form the basic countywide network of local, rail connector, and
express routes consisting of more than 6,500 bus stops along 77 bus routes.
Since 1992, OCTA has worked closely with its Special Needs in Transit Advisory
Committee, a citizens group which advises OCTA on issues relating to transit and
paratransit services. In concert with that Committee and over the last ten
years, OCTA has made significant capital investments in its shelters, stops,
buses, and call boxes to comply with the federal Americans with Disabilities Act
(ADA). These investments include:
• Since 1996, OCTA has provided over $5 million to many of its region’s 34
cities to remodel bus shelters to make them ADA compliant and in the next five
years, plans to expend over $5 million more.
• OCTA recently completed a major retrofit of its 1,300 freeway emergency call
boxes to install teletypewriter devices and achieve ADA compliance at a cost of
over $3 million.
• Since 1994, OCTA has funded the ACCESS program which provides shared-ride
paratransit service for those unable to use the regular, fixed route bus service
because of functional limitations caused by a disability at a cost of
approximately $21 million annually.
While OCTA has made significant progress in meeting and exceeding the
requirements of current ADA regulations in its bus fleet, emergency call boxes,
and bus stops, we believe that the Access Board’s draft guidelines for the
construction or reconstruction of bus shelters, curbs, and street crossings
could negatively affect future city and county construction. Further, the
proposed standards for bus route identification are particularly burdensome to
OCTA. Our specific comments on these two areas of concern are addressed as
OCTA is concerned that some of the standards listed in the guidelines could have
a dampening effect on new construction or alterations either because they would
be cost prohibitive or because local governmental entities would not be able to
comply with the guidelines for practical reasons. The specific areas identified
as problematic include:
Section 1103.3 Minimum Clear Width specifies a minimum clear width of 48 inches
for the pedestrian access route, excluding the width of the curbs. Most of
Orange County’s pedestrian access routes are 8 feet or 96 inches, including the
width of the curb. OCTA and its cities are projected to expend over $10 million
from 1996-2006 to bring all of its remaining shelters, estimated at over 1500
shelters, into compliance with current ADA standards, which require a shelter of
48 inches from back to front and 36 inches for pedestrian access. Under the
Access Board’s draft guidelines, Orange County’s pedestrian accesses would be
six inches short of the 48-inch minimum.
Section 1102.6 Curb Ramps and Blended Transitions would require that transitions
connecting pedestrian access routes to street crossings to be located within the
width of each crosswalk. Separate curb ramps to both crosswalks at a corner
instead of a single ramp at the diagonal apex may be preferable but are
generally not practical on urban streets due to storm drain inlets, utility
poles, and signal standards. The costs of moving these facilities can run into
the thousands of dollars and significantly add to the overall project expense.
Section 1104.3.3-1104.3.7 Other Requirements for Curb Ramps and Blended
Transitions would prohibit the placement of gratings, storm drain utility and
sewer access covers, and similar fixtures on ramps, landings, transitions, and
portions of the gutter within the pedestrian access route. As the guidelines
apply not only to new construction but to alterations of existing facilities,
the costs associated with moving these facilities, as stated before, can run
into the thousands of dollars and are not always practical. Even new
construction may at times not be operationally or economically viable if the
Access Board’s draft guidelines must be followed in every instance.
Bus Route Identification
Section 1102.7.1 Bus Route Identification requires bus route identification
signs located at bus shelters to have raised and Braille characters. While OCTA
does not own and is not responsible for the bus rights-of-way and shelters
maintained throughout the county, it does maintain bus signs noting the route
numbers at the stops.
We agree with the letter sent to you by the American Public Transportation
Association (APTA) dated October 28, 2002 in which they note that the expense of
fabricating these signs and the logistics of installing/replacing them would be
prohibitive to transit authorities. Using APTA’s estimates of $1,500 per sign,
OCTA estimates our initial cost to make and install the Braille signage at $9.6
million countywide. In addition, OCTA undergoes major service changes up to four
times year, in which we may drop, shorten or change existing routes. Two years
ago, because of massive route changes, we replaced 6,500 signs; this year, we
replaced 3,500. We believe the proposal recommended in the Access Board’s draft
guidelines would require a significant initial and ongoing capital investment.
In lieu of the above requirement, we recommend another way of addressing this
issue would be a requirement to identify the bus stop by the name of the bus
service company (i.e. Orange County Transportation Authority) along with an
individualized bus stop identification number (i.e. #1640) written in Braille
and posted on the bus stop. These signs would only need to be posted once no
matter how many times the routes or bus numbers changed. Information on the bus
routes, times, frequency, etc. could then be obtained via a telephone call
identifying the bus stop identification number. OCTA is currently working on
implementing such a system now in Orange County.
If you or your staff has any questions regarding OCTA’s comments on the Access
Board’s draft guidelines, please call Sue Zuhlke, Manager of Government
Relations, at [ ... ].
Arthur T. Leahy
Chief Executive Officer
c: California League of Cities
California State Association of Counties