Ken Ross, P.E.
October 22, 2002
SUBJECT: Proposed ADA Accessibility Guidelines
Ladies and Gentlemen:
We hereby request that you consider our comments with respect to some of the
provisions contained in the proposed guidelines.
1102.2 Additions and Alterations and 1103.3 Minimum Clear Widths
Much of the work done in our public rights-of-way involves repairs to existing
facilities. The rules as proposed require portions that are altered be brought
into compliance when it is technically feasible. In older cities there exists is
a huge amount of sidewalks that do not meet the new 4-foot width requirement. In
our city alone we estimate that half of our sidewalks (close to 95 miles) do not
meet this criteria. Widening these sidewalks in a piecemeal fashion to meet the
proposed 4-foot criteria will not only diminish the quantity of sidewalk repair
work an entity can perform each year, it will cause us to adversely impact our
citizens when we cut into their landscaped areas, modify their sprinkler
systems, and cause additional strain on their backs to shovel snow off of the
• We would like to suggest that the ADAAG minimum width of three feet be used in
existing neighborhoods where alterations are occurring.
1102.3 and 1111.3 Alternate Circulation Path Location
The mandate that the alternate circulation path “shall be parallel to and on the
same side of the street” is not always practical. Elsewhere in the proposed
regulations there are provisions for engineering judgment and a determination of
what is reasonable and/or feasible.
• We believe that there should be a “where practical” clause in this section as
1101.3 Defined Terms—Crosswalk and 1102.6 Curb Ramps and Blended Transitions
Since July 26, 1990, most cities have been retrofitting their intersections to
provide curb ramps in order to try to address the public accommodation rules
established by the Department of Justice and Department of Transportation. In
Englewood we have been able to provide 1800 curb ramps at intersections in our
city. The vast majority of these intersections have single ramps that are
located in the middle of the curb radius. If the wording in these two sections
gets approved it will mean almost all of these ramps are noncompliant. That is a
terrible reward for responsible agencies that have tried to make real progress
toward providing public accommodation for people that have disabilities. As a
result, as alterations occur at all these intersections, the existing curb ramp
would have to be removed and two new ones installed, except in cases where it
was technically infeasible.
• We believe that this requirement would be far less obtrusive to the cities
that have tried to be responsive toward the needs of people with disabilities if
the mandate for locating ramps within the width of each crosswalk were changed
to make this a requirement only where the crosswalks are indicated by lines or
other markings. Most cities only provide crosswalk markings at intersections
where there are high pedestrian volumes, or busier streets, or at locations
where it is desired to minimize the areas of pedestrian and vehicle conflict. It
is at these locations where single ramps ought to be discouraged.
The continuous barrier requirements and the pedestrian signal requirements that
are proposed will virtually eliminate all roundabouts or will force planners and
engineers to create pedestrian access corridors that avoid roundabout locations.
• We believe that roundabouts are a valuable tool in the transportation
engineer’s tool kit. We believe that the proposed guidelines provide unnecessary
restrictions and cost increases. The maximum operating speeds in or around
roundabouts are only around 22 miles per hour. Why not take advantage of the
reduced speeds and safe stopping distances that are created as a result of the
roundabout? We believe it would be far more prudent to address the issue by
requiring more signage that emphasizes that pedestrians have the right-of-way
and drivers must stop for pedestrians in crosswalks.
1106 Accessible Pedestrian Signal Systems
1106.2 Pedestrian Signal Devices and 1106.2.3 Audible Walk Indication and
1106.3.2 Locator Tone
The MUTCD already provides good support and guidance with respect to providing
audible and vibrotactile walk indications. And the MUTCD indicates that
pedestrians with visual disabilities primarily rely on traffic noise and
therefore at the vast majority of intersections, audible walk indications are
not required. However the MUTCD also emphasizes that advice from affected
individuals or organizations that represent pedestrians should be given
deference, and it is important to determine what the community wants and needs
are important in making these determinations.
• We believe that mandating audible and vibrotactile walk indications at all
traffic signals is a waste and is ill advised. But if particular signalized
intersections present difficulties for pedestrians with visual disabilities,
then those safety concerns must be addressed.
We appreciate your consideration of these comments and concerns. If you have any
questions, please feel free to call me at [...].
Ken Ross, P.E.
Director of Public Works