Patrick G. Rivera
|October 3, 2002|
Attached are comments on the recently released Draft Guidelines on accessibility of public rights-of-way from the City and County of San Francisco, Department of Public Works, Bureau of Engineering, Streets & Highways Section. Thank you for the opportunity to allow us to comment.
Patrick G. Rivera
City and County of San Francisco
Department of Public Works
Bureau of Engineering
Streets & Highways Section, Manager
Re: Comments on the Draft Guidelines on Accessible Public Rights-of-Way as Proposed by the Access Board
I understand that you are accepting comments on the recently released Draft Guidelines on accessibility of public rights-of-way now being considered by the Access Board. Below comments from the City and County of San Francisco, Department of Public Works, Streets & Highways Section. Note that these comments do not represent the entire Department’s comments but only one design section. There may be other sections with in the Department submitting comments.
1102 Scoping Requirements:
In 1102.2 there are discussions indicating compliance requirements, exceptions due to technical infeasibilities etc. However, there is no clear guidance to what extent an ADA compliant alteration is necessary for locally funded projects. In other words the cost impact is not discussed. Case in point. As part of a traffic signal upgrade project, we’re required to install curb ramps. However, the cost to install the curb ramp component is almost as much as the traffic signal upgrade component. We have been unable to determine what dollar amount increase is considered hardship or what percentage cost increase on a project due to ADA requirements are reasonable.
Even though it’s stated in 1104.3.2, it’s best to include it in this section as well.
1126.96.36.199 Cross Slope
In the City and County of San Francisco the street and sidewalk grades range from 2% to 22%. This section states that the running slope shall be 1:48 (2%) minimum and 1:12 (8.33%) maximum. In order to comply with these grades, a considerable amount of sidewalk reconstruction is required in order to conform to the existing sidewalk grade or in some cases it’s impossible to meet the requirements. There needs to be an Exception for this type of scenario. One solution would be to measure the grades relative to the slope of the existing sidewalk.
Flares with 10% slope measured along the curb line may create a steep wing when a curb ramp is constructed parallel to the crosswalk at a skewed intersection.
1188.8.131.52 Running Slope
“Parallel curb ramps shall not be required to exceed 15 feet.” These curb ramps consist of two ramps meeting at the bottom with a level landing. Is it the total length or each side 15’ max?
1104.3.2 Detectable Warnings
If detectable warnings (truncated domes as in 1108) would be required for all curb ramps regardless of the slope, then is the color contrast of the curb ramp required by the CA State Title 24 be required.
The prohibition of gratings, storm drains, utility and sewer access covers on ramps, and landings, transitions and gutters within the pedestrian access route will be challenging to comply with. The question is:
1104.3.6 Counter Slopes
The requirement of 1:20 (5%) maximum counter slope for gutter and/or street at foot of ramp will trigger extensive reconstruction and regrading of many street intersections in San Francisco. If we can’t raise the gutter, do we have to lower the street to comply? An evaluation of underground utilities, stormwater flow and traffic impacts would be required when gutter or street elevations are changed significantly.
1104.3.7 Clear Space
The roadway next to the curb on major routes may be a vehicle travel lane during “rush hour” times. The requirement of a 4’ by 4’ clear space at bottom of ramp outside the parallel vehicle travel lane conflicts with current traffic routing.
1105.2.2 Cross Slope
1105.2.3 Running Slope
In the City and County of San Francisco the street and sidewalk grades range from 2% to 22%. In 1105.2.2 the maximum cross slope of 1:48 (2%) and in addition to 1105.2.3 where the running slope is 1:20 (5%) max for the entire crosswalk, will require reconstruction and regrading concrete gutters and possibly reconstruction of entire intersections. There needs to be an Exception for this type of scenario. One solution would be to measure the grades relative to the slope of the existing sidewalk.
1108.2.1 Curb Ramps and Blended Transitions
Many ramps are located along the radius of the curb return, so the ramp bottom at the curb line is curved and not perpendicular to the path of travel. Custom design and production of a pre-cast or cast-in-place surface with truncated domes that fit these irregular areas will be difficult. A solution would be to increase the maximum distance to the curb line from 8 inches to 12 inches to allow for straight-edge technology to fit real-world curves.
The above comments do not represent a complete list of comments from the City and County of San Francisco. You may be receiving additional comments from other Departments and Agencies. I would like to thank you for allowing the Engineer’s in my Section and me the opportunity to comment on the draft guidelines. Please add me to your e-mail list regarding this topic.
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