James A. Noyes and Ronald J. Ornee
October 24, 2002
COUNTY OF LOS ANGELES
DEPARTMENT OF PUBLIC WORKS
JAMES A. NOYES, Director
Attention Rules Docket Clerk
AMERICANS WITH DISABILITIES ACT
ACCESSIBILITY GUIDELINES FOR BUILDINGS AND FACILITIES
ARCHITECTURAL BARRIERS ACT ACCESSIBILITY GUIDELINES
COMMENTS ON FEDERAL REGISTER NOTICE OF DRAFT GUIDELINES
36 CFR PARTS 1190 AND 1191
FR DOC. 02-15117
Following are our comments to the June 17, 2002, Federal Register notice of the
Architectural and Transportation Barriers Compliance Board’s draft guidelines,
which address accessibility in the public right of way. On those items which
indicate our need to make modifications to our facilities, we have not
identified a source of funding to comply. There are a large number of traffic
signals that the County is responsible for. This does not include the many
traffic signals maintained by the 88 cities in the County nor those signals
under jurisdiction of the State Department of Transportation. A significant
amount of time and additional funding will be needed for the design and
installation of the proposed modifications.
1102.14 On-Street Parking (Page 21 of 31)
Since the majority of block faces being built each year are in typical
residential neighborhoods, we will be required to provide an indented and signed
handicap space on every residential block face if the guidelines of this section
are adopted. We assume the real concern is associated only with areas where
there are parking meters or time limited parking, such as in business areas. We
recommend handicap spaces only be required in business or commercial areas.
Secondly, in areas with very short block lengths, the requirement of one space
per block face will be viewed by the public and business community as being
extremely excessive. We recommend a balanced approach that gives guidance to
longer block areas of one space per block face, but allows one handicap space
per 25 or so spaces (or a percentage of spaces) within short block areas.
1102.15 Passenger Loading Zones (Page 22 of 33)
The required 60-inch access aisle for each passenger loading zone (PLZ) has the
effect of limiting the ability to quickly install PLZ signing. Prior to
establishing a PLZ, we would need to propose a capital project to construct a
5-foot indent aisle. Therefore, we recommend access aisles adjacent to PLZs be
eliminated as a mandated construction requirement. This requirement is subject
to California Traffic Control Devices Committee (CTCDC) consideration.
• 1102.7.2 Informational Signs and Warning Signs (Page 21 of 31)
The American with Disabilities Act Accessibility Guidelines (ADAAG)
specifications for visual legibility for signs at elements for pedestrian use
will require us to modify our pedestrian signal pushbuttons.
• 1103.3 Clear Width (Page 22 of 33)
We agree that it is preferable to use 48-inch minimum clear width rather than
the 60-inch originally recommended by the advisory committee. However, we
request additional guidance or direction be given on whether exceptions can be
utilized for alterations to existing roadways as allowed in 1102.2.2 Alterations
(page 20 of 33). There are cases when alteration projects require an exception
because a minimum width of 48 inches is technically infeasible due to
obstructions such as utility poles and boxes, mature trees, and limited right of
way. In the past , we have generally tried to maintain a minimum clear width of
36 inches at obstructions, or in very restricted conditions, a minimum of 32
inches which matches the width allowed for accessible routes in ADAAG Section
• 1103.8 Changes in Level (Page 22 of 31)
This section states that the changes in level must comply with ADAAG 303, which
permits a Y2-Inch maximum allowable displacement. We use a 1-inch threshold to
determine whether sidewalk repairs are needed. If the guidelines are adopted,
this policy may need to be revised or an exception should be considered.
• 1104 Curb Ramps and Blended Transitions (Page 23 of 31)
The discussion of the provisions states that the advisory committee strongly
discouraged single installations of curb ramps; therefore, suggesting that ramps
be either parallel or perpendicular. However, installing two curb ramps at one
corner is normally infeasible due to physical obstructions such as pull boxes
and signal standards. We recommend Section 1104 address this issue.
• 1220.127.116.11 Flares (Page 23 of 31)
The term “circulation path” should be defined and explained how it is different,
if at all, from the term “pedestrian access route.”
• 1104.3.4 Grade Breaks (Page 24 of 31)
We request that clarification be provided on whether grade breaks are not being
permitted within separate sloped components of the curb ramps, such as flares,
ramps, and landings, because we understand that grade breaks are permitted
between components such as at the top and bottom of ramp runs, or at the edges
of landings and flared sides.
• 1104.3.7 Clear Space (Page 24 of 31)
For some streets where there is a vehicle travel lane adjacent to the curb
(i.e., no parking lane), there would be insufficient width to provide a clear
distance of 48 inches from the curb face that is wholly outside the vehicle
travel lane. We recommend an exception be allowed for these cases.
• 1105.2.2 Crosswalks, Cross Slope (Page 25 of 31)
Many existing roadways have a longitudinal slope of more than 2 percent, which
would require an exception to the minimum of 1:48 cross slope for crosswalks. We
recommend that this section be revised to allow the cross slope match the
existing grade of the street when the type of work is an alteration.
• 1105.2.3 Crosswalks, Running Slope (Page 25 of 31)
Some existing roadways, especially on local residential streets, have existing
cross slopes greater than 5 percent, which would require an exception to the
minimum of 1:20 running slope for crosswalks. We recommend this section be
revised to allow the running slope to match the existing grade of the street
when the type of work is an alteration.
• 1105.3 Pedestrian Signal Phase Timing (Page 25 of 31)
The pedestrian walking speed we use to calculate the pedestrian timing interval
for traffic signals is 4.0 feet per second, which is consistent with the Manual
of Uniform Traffic Control Devices (MUTCD). Revising the walking speed
requirement from 4.0 to 3.0 feet per second will require adjustment to all our
traffic signals, and our current method to calculate the total pedestrian signal
phase timing distance will need to be updated to reflect the new proposal.
• 1105.4 Medians and Pedestrian Refuge Islands (Page 25 of 31)
The last sentence of this section is not clear. The reference to “edges of the
cut- through” should be clarified.
• 1105.6 Roundabouts (Page 26 of 31)
Pedestrian-activated crossing signals will severely impact the operation of a
roundabout. An activated pedestrian signal can stop the flow of traffic within
the circle, causing a momentary gridlock situation and increasing the potential
for rear-end accidents. We do not agree with the statement that “requiring the
signal to be pedestrian activated may help limit the impact on traffic flow.” A
pedestrian signal will almost defeat the features and purpose of a roundabout.
If the guidelines of this section are adopted, design alternatives will need to
be explored. These guidelines should be reviewed by the CTCDC before being
• 1105.7 Turn Lanes at Intersections (Page 26 of 31)
If the guidelines of this section are adopted, we will be required to install
pedestrian signals at locations with free-flow right-turn lanes.
1106 Accessible Pedestrian Signal Systems (Page 26 of 31)
Requiring such systems at each pedestrian signal will cause a slight increase in
the installation costs, and we will need to modify our current pedestrian signal
systems at signalized locations. Due to their “intelligence,” these systems
typically require periodic calibration and, therefore, will require a higher
maintenance cost. The application of these systems should only be applied to
signals where pedestrian activation is required. Pedestrians signals that “rest
in walk” will cause these systems to be activated continuously with the
vibrating buttons and audible voice, adding to the noise concerns.
Also, clarification is needed as to whether or not these devices apply to
pedestrian- activated flashers.
• 1106.3.3 Pedestrian Pushbuttons, Size and Contrast (Page 27 of 31)
If the guidelines of this section are adopted, we will need to replace all
pedestrian pushbuttons with the Americans with Disabilities Act type.
• 1106.4 Directional Information and Signs (Page 27 of 31)
If the guidelines of this section are adopted, we will need to modify all
pedestrian signal systems to include these signs.
• 1109.2 On-Street Parking, Parallel Parking Spaces (Page 29 of 31)
The requirement to provide a 60-inch access aisle is extremely burdensome and
will also have significant unintended consequences that will restrict our
ability to help the disabled community, rather than enhance our ability to help
them. The current practice is to install handicap signs in both residential and
business areas quickly and easily to accommodate individual and varying
requests. The 5-foot indent is simply out of character in residential
neighborhoods. This requirement will make us unable to continue our policy of
“immediately taking care of the disabled community.”
If the guidelines of this section are adopted, in order to install a handicap
space, we will have to propose a capital project to construct a 5-foot indent
aisle. Also, we will no longer be able to respond to changes by moving a
handicap space slightly.
We recommend this requirement be eliminated. It does not serve the best
long-term interests of the disabled community. Additionally, the 5-foot minimum
height of handicap signs is in violation of the minimum requirements of the
MUTCD. These guidelines should be reviewed by the CTCDC prior to adoption.
1111 Alternate Circulation Path (Page 31 of 31)
The requirement to provide an alternate path on the same side of the street,
with no provision for “reasonableness,” is not feasible in many instances. Many
times, the scope of construction is such that no pedestrians can be
accommodated, and forcing pedestrians into this type of area may create an
intolerable safety hazard. There are situations where pedestrians cannot or
should not be accommodated, and they must be moved to the opposite side of the
street, or in the case of total street closures, moved around an entire block.
The requirements of this section would be very difficult, if not impossible, to
implement during construction, If implementation was possible, a formal plan
detailing how these requirements are to be met would need to be included in the
plan set. Construction productivity would be impacted and result in higher unit
prices for items of work associated with traffic control, removals, and
construction of sidewalk, driveways, and curb ramps. In many areas, it would be
impossible to provide the required minimum clear width of 36 inches. In
addition, this requirement would put an additional burden on contractors to
provide and maintain a safe work zone and may result in additional claims.
• 1111.6 Alternate Circulation Path, Barricades (Page 31 of 31)
The requirement for a lower rail within 1 1/2 inches of the ground surface
diminishes the effectiveness and visibility of the barricades to motorists.
There is also a potential conflict with the American Association of State
Highway Transportation Officials design guidelines for stopping sight distance
and the MUTCD standard for minimum retroreflective area facing road users.
Placing the lower rail 1 1/2 inches above the ground would place the lower rail
entirely below the American Association of State Highway Transportation
Officials’ 2-foot object height assumption for calculating stopping sight
distance and could effectively leave as little as 120,000 sq.mm. (192 sq.in.) of
retroreflective area “visible” to the road user (for a Type II barricade), which
would not satisfy the MUTCD’s minimum standard of 174,000 sq.mm. (270 sq.in.).
The restriction of nonflexible fencing material is an unnecessary restriction.
Plastic fencing products are now extremely strong, durable, and easy to install;
therefore, they are capable of providing pedestrian channelization and
protection in a reasonable manner. We recommend plastic fencing products be
allowed in order to make it easier for jurisdictions to provide protection in
very short-term construction areas.
Thank you for the opportunity to comment on the draft guidelines for accessible
public rights of way.
Very truly yours,
JAMES A. NOYES
Director of Public Works
RONALD J. ORNEE,
Chief Deputy Director