Discussion of Provisions

The proposed draft is formatted as a separate chapter, 11 Public Rights-of-Way, to be integrated into ADAAG. This chapter has a general section (1101), a scoping section, which indicates what is covered (1102), and technical sections addressing various elements of public rights-of-ways (1103 to 1111). Figures and advisory notes provided in the advisory committee’s report are not included in this draft, but will be included in the proposed rule.

Application and Administration (1101)

Referenced Standards (1101.2)
The draft guidelines reference standards issued by the U.S. Federal Highway Administration known as the Manual on Uniform Traffic Control Devices (MUTCD). The MUTCD, which is used by road managers nationwide, covers the application and installation of traffic signals, signs and pavement markings that regulate, warn, and guide vehicle and pedestrian users of the public right-of-way. Currently, the Federal Highway Administration is in the process of updating the MUTCD.

Defined Terms (1101.3)
The draft guidelines define various terms common to construction in the public right-of-way that are used in the provisions that follow. Most of these definitions derive from key industry sources such as the MUTCD or industry practice. Consistent with the advisory committee’s report, the draft guidelines minimize deviations from industry usage and understanding of defined terms to ensure consistency with industry standards and best practices.

General Scoping: New Construction, Alterations, and Additions (1102)

Scoping requirements in section 1102 indicate where the draft guidelines apply and which elements and spaces must comply with the technical provisions. The draft guidelines cover new construction (1102.1) and additions and alterations (1102.2). Scoping provisions address various elements and spaces, including access routes, curb ramps, signs, crossings, and street furniture (1102.3 through 1102.16).

New Construction (1102.1)
All areas of newly designed and newly constructed facilities in public rights-of-way would be subject to the guidelines. This scoping applies to work such as the extension of roadways and sidewalks into undeveloped areas, new subdivisions, and similar types of projects. Full compliance is generally easier in these types of projects because the scope of work is usually extensive enough to allow necessary grading and acquisition of sufficient right-of-way. The draft guidelines would not require the provision of sidewalks, street crossings, street furniture, parking, or other pedestrian elements where none are intended. The guidelines address such elements only where they are provided as part of construction or improvement projects.

Additions and Alterations (1102.2)
Much of the work that occurs in public rights-of-way involves alterations to existing facilities or the addition of facilities within the constraints posed by existing developed rights-of-way. The draft guidelines, consistent with ADAAG, would apply technical requirements according to the scope of work for a planned alteration or addition. This application is based on the premise that the more extensive the work is, the greater are the opportunities to achieve access. In effect, compliance is "prorated" based on the extent of the work planned. Industry and local practices, among other factors, typically govern the scope of a project. For example, industry practice may broaden the scope of work for a planned improvement project to ensure a smooth transition to adjacent areas, improve safety, or upgrade existing elements, such as drainage structures, within or near the area to be improved.

The scope of a project would determine the extent to which the guidelines apply. A project involving substantial reconstruction of a roadway may be subject to requirements in the draft guidelines for sidewalks, curb ramps, and street crossings, among others. For less extensive projects, limited improvements to accessibility would generally be expected. For example, if an existing portion of sidewalk along a block face were rebuilt or replaced, at a minimum the new portion of sidewalk would be subject to specifications for sidewalks, including those for curb ramps and surfacing, among other things. However, compliance with these guidelines would not extend to untouched sections of sidewalk outside the planned alterations.

Compliance in alterations is required except where it is "technically infeasible." As defined in ADAAG, this term covers existing structural or space constraints that prohibit compliance, such as removing or altering a load-bearing member of the structural frame. In the case of public rights-of-ways, this may pertain to other types of constraints, such as those posed by existing construction, right-of-way width, and underground structures. What is feasible in a given alteration will depend on a wide range of factors particular to the project. Determinations of technical infeasibility must be made on a case-by-case basis in relation to each project’s unique conditions. For example, it might not be technically feasible to widen a narrow sidewalk undergoing an alteration due to existing buildings that front the sidewalk. On the other hand, such work might be technically feasible at other locations where acquiring additional right-of-way is practicable. Where technical infeasibility is encountered, compliance is required to the maximum extent possible.

The Board believes that guidance material on how to apply the guidelines in alterations projects would provide a valuable compliance tool. A subcommittee of advisory committee members is currently developing a guide on achieving accessibility in alterations to public rights-of-way. The subcommittee has conducted a series of meetings in different cities to gather information for case studies that will be included in the guide being developed. Over the past year, the subcommittee has met in Atlanta, Las Vegas, Portland (Oregon), and San Antonio. The guide is expected to be published early next year.

Existing Public Rights-of-Ways
In previous rulemakings in this and other areas, the Board has received comments concerning the impact of retrofitting existing facilities to meet new guidelines. However, the Board’s authority under the ADA and ABA extends only to the establishment of accessibility guidelines for new construction and planned alterations. Its guidelines do not address existing facilities outside the context of a planned alteration (except for certain types of transit stations). Thus, the Board seeks comments on these draft guidelines only as they pertain to new construction, planned alterations, and additions. Under the ADA and other laws, requirements issued by the Department of Justice and the Department of Transportation address access to existing facilities.

Accessible Elements and Spaces: Scoping and Technical Requirements (1102.3 - 1111)

Alternate Circulation Path (1102.3, 1111)
The draft guidelines address construction within public rights-of-way and call for alternate circulation paths where pedestrian access routes are temporarily blocked by construction, alteration, maintenance, or other temporary conditions. Technical specifications address the minimum clear width (36 inches), location (on the same side of the street parallel to the disrupted pedestrian access route), hazardous protruding objects, and criteria for signs and barriers. Construction at public rights-of-way can be particularly hazardous to people with visual or mobility impairments if the site is not adequately protected with a barrier or barricade. In particular, tape or a series of widely spaced traffic cones placed around a construction site may not be detected by some pedestrians. Such markings do not provide sufficient cues to enable a blind pedestrian to anticipate a hazard, nor do they provide an edge along which to travel around an obstruction. Barriers would be required to be detectable, with edge protection and railings. The requirements for barriers are based on proposed MUTCD standards (Chapter 6).

Pedestrian Access Route (1102.4, 1103)
"Pedestrian Access Route" is a key term that refers to the portion of the public right-of-way that serves as an accessible route. Since the technical requirements for this route are unique to public rights-of-way, the advisory committee wanted to use a term distinct from "accessible route," which is used by ADAAG in referring to routes on sites. In many cases, the pedestrian access route would not have to encompass the full width of sidewalks and other pedestrian ways. Thus, the term is used to refer to the compliant portion which, in effect, provides a continuous accessible means of passage.

In new construction, the pedestrian access route would comprise a continuous, unobstructed path connecting to all elements and spaces required to be accessible. In an alteration or addition, the requirements for pedestrian access routes would apply only to new or altered portions of public rights-of-way. As a result, there may be breaks in continuity where the pedestrian access route is interrupted by portions of the existing pedestrian network which have not yet been altered. In such cases, the new or altered portions would be required to blend smoothly with the existing pedestrian network.

Specifications for pedestrian access routes address clear width, cross slope, grade, surface, changes in level, and other characteristics. The pedestrian access route may comprise sidewalks and walking surfaces, curb ramps and ramps, blended transitions, crosswalks, elevators, and other elements recognized by the guidelines.

Minimum Clear Width (1103.3)
The draft guidelines specify a minimum clear width of 48 inches for the pedestrian access route, excluding the width of curbs. The advisory committee had recommended a minimum width of 60 inches with various exceptions that would have permitted a reduction to 48 inches in order to accommodate certain fixtures and elements. A 60 inch width would provide wheelchair turning space and passing space. The Board has specified 48 inches minimum without exceptions, to be consistent with industry practice. The 48 inch width remains greater than the width ADAAG generally specifies for accessible routes on sites (36 inches).

Grade (1103.5)
A key issue of routes in public rights-of-ways is the grade or slope of the terrain. ADAAG requires accessible routes on sites that slope more than 1:20 to be treated as ramps. Ramps must have handrails on both sides, edge protection, and intermediate level landings at least every 30 feet, among other requirements. It would not be practical to apply ramp requirements generally to sidewalks in sloped areas. Consistent with an advisory committee recommendation, the grade of the pedestrian access route within a sidewalk is permitted to be as steep as the grade of the adjoining roadway. The grade can be steeper than the roadway grade where the route slopes less than 1:20 or is treated as a complying ramp.

Surfaces (1103.6)
The advisory committee recommended that the pedestrian access route also contain a narrower route within its boundaries that was smooth and free of irregular surface features, such as granite pavers, cobble stones, and other types of rough or jointed surfaces. This would minimize the sometimes painful vibration persons using wheeled mobility aids may experience traversing rough and uneven surfaces. However, the committee was not able to identify suitable methods for measuring surface roughness or rolling vibration that would help determine whether a given surface was sufficiently smooth. The advisory committee called attention to the need for research on the relationship between surface roughness and wheeled mobility aids, including possible measurement protocols. The Board agrees with the committee that such information needs to be developed, but believes that a requirement for surface smoothness should not be included until measurable technical specifications are identified. Thus, a requirement for surface smoothness has not been included. However, the pedestrian access route is subject to requirements in ADAAG (section 302) which require surfaces to be firm, stable, and slip resistant and which prohibit openings that are more than 1/2 inch in one dimension, such as might occur in a grating. In addition, the Board has limited the frequency of permitted level changes along the pedestrian access route (discussed below at section 1103.8).

Surface Gaps at Rail Crossings (1103.7)
Surface gaps or openings in pedestrian access routes would be limited to 1/2 inch in one dimension. This specification is not practicable at rail tracks where gaps must be at least 2 1/2 inches to safely accommodate rail car wheel flanges. Due to variations in load and wheel play, the gap must be even larger (3 inches) to accommodate heavy freight trains. However, such a gap can trap wheelchair caster wheels, which are prone to turning sideways against vertical displacements, even slight ones. Specifications in the draft guidelines recognize the gaps widths required along tracks, including those used by freight trains. The advisory committee recommended that this provision contain a "sunset" clause that would require compliance with a 1/2 inch specification by a specified time. The Board has not included such a clause since it is not possible to reliably predict when research may find a solution. Attempts have been made to develop a "gap filler" device, but none of those devices have been successful. The Board is pursuing options for research on this issue.

The draft guidelines would also require detectable warnings at the outside of each group of tracks that cross the pedestrian access route. This is important since flush surfaces at rail tracks will not provide a tactile cue to people with vision impairments. Where there are multiple sets of tracks, detectable warnings would be required along the outer edges of the entire group of tracks. Detectable warnings would not be required at tracks sharing vehicular ways, such as street car tracks in roadways, since curb ramps along roadways are also required to have detectable warnings (discussed below at section 1104).

Changes in Level (1103.8)

The pedestrian access route would be subject to requirements in ADAAG for changes in level (ADAAG 303) which permit level changes up to 1/4 inch without treatment and level changes between 1/4 and 1/2 inch that are beveled with a slope no greater than 1:2. Changes in level greater than 1/2 inch are to be treated as a ramp or curb ramp. In addition to the referenced specifications, the draft guidelines specify a minimum linear separation of 30 inches between level changes in pedestrian access routes to prevent successive level changes that can be disruptive to wheelchair maneuvering, such as those that may be posed by sidewalk pavers. The advisory committee recommended specifying a minimum separation of 24 inches based on the standard wheelchair wheelbase, measured in the predominant direction of pedestrian travel. However, a separation of at least 30 inches corresponds to a common size of sidewalk segment and encompasses the wheelbase of most wheelchairs. This would allow most persons using wheelchairs to clear one level change before encountering another. This provision would not rule out the use of bricks or other small pavers that are installed in a manner that provides a relatively flush surface and that are properly maintained.

Protruding Objects (1102.5)
The draft guidelines address objects that may project into circulation paths in a manner hazardous to people with vision impairments. Unlike requirements for pedestrian access routes, these criteria would apply to the full circulation space of sidewalks and other pedestrian paths. Objects mounted on walls or posts with leading edges above the standard sweep of canes (27 inches) and below the standard head room clearance (80 inches) would be limited to a 4 inch protrusion.

Curb Ramps and Blended Transitions (1102.6,1104)
Curb ramps or blended transitions would be required to connect pedestrian access routes to street crossings and to be located within the width of each crosswalk. Generally, this would require two separate curb ramps at a corner instead of a single ramp that opens diagonally onto an intersection. The advisory committee strongly discouraged single installations where possible for several reasons. Single ramps can misdirect blind pedestrians who use the slope of curb ramps as a cue. They can increase crossing times for persons who use wheeled mobility aids and can place users into oncoming traffic at small radius corners where it is difficult to provide landing space at the bottom that is wholly within marked crossings. Also, drivers may not be as alert to persons crossing at the apex of a corner. On the other hand, the advisory committee recognized that providing two separate compliant curb ramps may not always be practicable, particularly in alterations, due to storm drain inlets, utility poles, and other constraints.

The draft guidelines provide technical criteria for perpendicular curb ramps, parallel curb ramps, and blended transitions. Perpendicular curb ramps, the most common type, have a running slope that cuts through a curb or meets the gutter grade break at right angles. Parallel curb ramps have a running slope that is in line with the direction of sidewalk travel. Blended transitions can be achieved by depressing the entire curb radius to street level or, less commonly, raising street crossings to sidewalk level, which can serve as a traffic calming strategy by creating a "speed table" at intersections. Various combinations of these different types of ramps and transitions can be used. For example, parallel ramps can be used for a portion of a curb level change in conjunction with a perpendicular ramp or a blended transition. The draft guidelines include requirements specific to each of these elements as well as criteria common to all of them.

Perpendicular Curb Ramps (1104.2.1)Perpendicular Curb Ramp
Consistent with ADAAG, curb ramps must have a maximum running slope of 1:12. The draft guidelines specify a minimum running slope of 1:48 for perpendicular ramps (and parallel ramps) in order to distinguish them from blended transitions, which cannot have a slope of more than 1:48. Requirements specific to perpendicular curb ramps address the cross slope (1:48 maximum), level landings at the top (48 by 48 inches minimum), and side flares (1:10 maximum slope). Sidewalks are permitted to follow the running grade of the adjoining roadway, which determines the cross slope of perpendicular ramps and landings at mid-block crossings. Exceptions are provided for ramps located at mid-block crossings that permit the cross slope of the ramp and landing to be greater than 1:48 so that the ramp can transition smoothly to the street crossing. Otherwise, maintaining a 1:48 cross slope at streets with a steeper grade would result in a warped transition from the ramp to the road, which is problematic for wheelchair maneuvering.

Parallel Curb Ramps (1104.2.2)Parallel Curb Ramp
Parallel ramps are especially suited to narrow rights-of-way where there is insufficient space for the top landing of a perpendicular curb ramp. In this case, the bottom landing usually serves as the direct connection to the street crossing. Criteria for parallel curb ramps address the running slope (1:12 maximum and 1:48 minimum), cross slope (1:48 maximum), level landings at the bottom (at least 48 by 48 inches), and barriers at drop-offs. The running slope of parallel curb ramps will be affected by the slope of the sidewalk, which is permitted to be as steep as the adjacent roadway. Thus, a maximum slope of 1:12 may not be achievable due to the road grade. In recognition of this, an exception limits the required length of a parallel ramp to 15 feet, regardless of the slope. The landing required at the bottom of the ramp is not permitted to slope more than 1:48 in any direction, but an exception is also provided for mid-block crossings where compliance with this specification may be affected by the roadway grade. Where parallel curb ramps do not span the full width of a sidewalk, a barrier is required along the drop-off created by the ramp to prevent tripping hazards.

Blended Transitions (1104.2.3)Blended Transition
Blended transitions are to have slopes parallel and perpendicular to the curb no greater than 1:48. Transitions with a slope greater than 1:48 are to be treated as a curb ramp.

Common Elements (1104.3)
Curb ramps and blended transitions would be subject to requirements for clear width (48 inches minimum), detectable warnings, surfaces, grade breaks, changes in level, counter slopes, and clear space.

Detectable Warnings (1104.3.2)
Detectable warnings provide a distinctive surface of truncated domes detectable by cane or underfoot to alert people with vision impairments of the transition to vehicular ways. These warnings compensate for the sloped surfaces of curb ramps which remove a tactile cue provided by curb faces. ADAAG, as originally published in 1991, contained a requirement for detectable warnings on the surface of curb ramps and other locations where pedestrian ways blend with vehicular ways without tactile cues. This requirement was temporarily suspended due to concerns raised about the specifications, the availability of complying products, maintenance, usefulness, safety, and the need for further study. The suspension expired in July 2001.

The advisory committee considered the issue at length and recommended that the draft guidelines require detectable warnings according to revised specifications. The Board agrees with the committee’s recommendation and has included a requirement for a detectable warning surface 2 feet deep where the ramp, landing, or blended transition connects to a crosswalk. Since detectable warnings are intended to replace the cue otherwise provided by a curb drop-off, they would be required to span the entire area where the curb drop-off is absent. This is especially important for blended transitions, where there is no slope to help detect the presence of a ramp.

The advisory committee deliberated on whether to require detectable warnings at all curb ramps and blended transitions or only those which were the least distinguishable. One organization represented on the committee suggested that detectable warnings be required only where the ramp slope was 1:15 or less. The Board seeks comment on this issue as well as any research that supports slopes of 1:15 or steeper being sufficiently detectable by persons with vision impairments.

The technical specifications for detectable warnings are discussed below in section 1108. 

Other Requirements for Curb Ramps and Blended Transitions (1104.3.3 - 1104.3.7)
Other technical requirements for curb ramps and blended transitions would:

  • require compliance with specifications in ADAAG section 302 covering surface firmness, stability, and slip-resistance;
  • 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;
  • prohibit grade breaks on ramp runs, blended transitions, landings, and gutter areas within the pedestrian access route;
  • require a flush transition at permitted grade breaks, such as at the top and bottom of ramp runs;
  • prohibit any vertical changes in level on curb ramps, landings and gutter areas within the pedestrian access route;
  • limit the counter slope of the gutter area or street at the foot of the curb ramp or blended transition to be 1:20 maximum (the advisory committee had recommended that the sum of the slope of the ramp and gutter or street be 11 percent or less, but the Board believes that the 1:20 specification, which is consistent with ADAAG, will be easier to understand and enforce); and
  • require clear space at least 48 by 48 inches, located beyond the curb line and wholly within crosswalks and out of the parallel traffic travel lane.

Pedestrian Signs (1102.7)
Signs provided for pedestrian use would be subject to certain ADAAG specifications for visual legibility. These requirements would not apply to traffic and street signs intended for vehicle operators, which are covered by the MUTCD. Provisions are included for bus route identification signs, informational signs, and warning signs. Specifications in ADAAG 703.5 for visual characters are referenced. This section of ADAAG covers finish and contrast, style, the proportions and height of characters, sign height, stroke thickness, and character and line spacing.

Bus Route Identification(1102.7.1)
Bus route identification signs would be subject to the visual character requirements, except those for character height (which would apply only to the maximum extent practicable) and sign height. This requirement would not apply to bus schedules, timetables, or maps. This provision is consistent with existing ADAAG provisions for bus stops and shelters (section 810.4). In addition, the draft guidelines would require route identification signs located at bus shelters to be tactile and provide information in raised and Braille characters according to specifications in ADAAG (section 703.2). Raised characters are to have rounded corners. An exception permits certain types of audible signs to substitute for tactile signage.

Informational Signs and Warning Signs (1102.7.2)
ADAAG specifications for visual legibility would also apply to informational signs and warning signs located in public rights-of-ways, but the draft guidelines would not require the inclusion of raised and Braille characters. This provision would apply to signs that label or provide information about, or direction to, public buildings, transit stations and stops, and many other facilities and elements. It would also cover signs at elements for pedestrian use, such as signal pushbuttons, and signs that warn of sidewalk closings or that provide direction to alternate pedestrian routes.

Pedestrian Crossings (1102.8, 1105)
This section addresses crosswalks, pedestrian signal timing for crossings, pedestrian islands, overpasses and underpasses, vehicular roundabouts, turn lane crossings, and pedestrian signals.

Crosswalks (1105.2)
Requirements for crosswalks cover the width, cross slope, and running grade. These specifications would apply to both marked and unmarked crossings, wherever pedestrian travel across the roadway is not prohibited. Marked crosswalks are specified to be at least 96 inches wide, as recommended by the advisory committee, which exceeds the 72 inch minimum specified in the MUTCD. Since pedestrians, including people with vision impairments and those who use wheelchairs, must pass each other in an environment that demands rapid crossing times, it is important for crosswalks to provide adequate width so quick and easy passing occurs without delaying clearance of the crosswalk.

The cross slope is limited to 1:48, except at mid-block crossings. The cross slope of the crosswalk is the running grade of the roadway. It is not uncommon for streets to be constructed with constant profile grades up to 9 or 10 percent. This specification would require reduction of these profile grades to 2 percent at intersection crosswalks, thus forming "tabled areas" at intersections so that the 1:48 slope is achieved at crosswalks. The specified running slope for crosswalks is 1:20.

Pedestrian Signal Phase Timing (1105.3)
The draft guidelines would require pedestrian signal phase timing to be calculated according to a walking speed of 3.0 feet per second. Industry practice generally recommends calculations based on a speed ranging from 3.5 to 4.0 feet per second, though some jurisdictions are reportedly considering a rate of 2.5 feet per second. The advisory committee recommended using a crossing speed of 3.5 feet per second or less. The Board believes that a rate of 3.0 feet per second will accommodate a broader range of pedestrians and offer greater access.

Medians and Pedestrian Refuge Islands (1105.4)
The draft guidelines would require that medians and pedestrian refuge islands, where provided, be cut through at street level or have complying curb ramps so that a pedestrian access route is maintained. Specifications for length and detectable warnings apply where signal timing does not permit crossing all traffic lanes in one cycle.

Pedestrian Overpasses and Underpasses (1105.5)
The draft guidelines address access to pedestrian overpasses and underpasses, which would be required to provide a pedestrian access route. A ramp would be required where the running slope exceeds 1:20. However, overpasses and underpasses commonly span significant elevation changes. A complying ramp requires at least a foot of run for every inch of elevation, in addition to space for intermediate level landings at least every 30 feet or where a ramp changes direction. Due to the exertion required in maneuvering wheelchairs upslope, lengthy ramps often are unusable and can be impractical due to the amount of right-of-way space they require. The Board is not aware of information that specifically indicates at what point a ramp is too long to be used by persons with disabilities. The advisory committee recommended that an elevation change of 60 inches be the cut-off. Consistent with this recommendation, the draft guidelines would require elevator access where the rise of a ramped approach exceeds 60 inches. The Board seeks comment on whether this is an appropriate trigger for elevator access. The requirement references ADAAG specifications for standard passenger elevators (section 407) and limited-use/limited application elevators (section 408), which are usually smaller and slower than other passenger elevators and are typically used for low-traffic, low-rise installations.

In addition to elevator requirements, the draft guidelines apply ADAAG specifications to stairs (section 504) and escalators (section 810.9).

Roundabouts (1105.6)
A growing trend in roadway design favors continuous-flow roundabouts over traditional signalized intersections. While their design varies widely, roundabouts typically feature a circulatory roadway around a central island. Entering traffic yields to vehicles already in the circle. Increasingly popular in the U.S. because they add vehicle capacity and reduce delay, roundabouts are a common feature in Europe and Australia. Because crossing at a roundabout requires a pedestrian to visually select a safe gap between cars that may not stop, accessibility has been problematic. While roundabouts may be an asset to traffic planners in controlling and slowing the flow of traffic at intersections without using traffic signals, the absence of stopped traffic presents a problem for pedestrians with vision impairments in crossing streets. Pedestrians report that vehicles at roundabouts, as well as at other unsignalized crossings, often do not yield for pedestrians. Persons with vision impairments and pedestrians who may hesitate at such crossings are at a particular disadvantage.

To provide safer crossing at roundabouts, the draft guidelines would require pedestrian activated crossing signals at each roundabout crosswalk, including those at splitter islands. (The draft guidelines would ensure that such signals are usable by persons with vision impairments under requirements in section 1106 discussed below.) Although roundabouts are typically used to avoid signalization, the Board is not aware of alternatives that would allow safe passage for pedestrians with disabilities. Aside from accessibility, the use of roundabouts in areas of high pedestrian use has been questioned by some in the industry.

Requiring the signal to be pedestrian activated may help limit the impact on traffic flow. Signal technologies are available that can further minimize the impact, such as devices that halt traffic only while a pedestrian is in the crosswalk. The Board seeks information on alternative design strategies and available technologies that can improve access at roundabouts for persons with disabilities, particularly those with vision impairments.

Barriers or similarly distinct elements are needed to prevent blind persons from inadvertently crossing a roundabout roadway in unsafe locations. The draft guidelines would require a continuous barrier along the street side of the sidewalk where pedestrian crossing is prohibited. If a railing is used, it must have a bottom rail no higher than 15 inches. This dimension would allow use of a standard roadside guardrail while providing sufficient cane detectability.

Turn Lanes at Intersections (1105.7)
The draft guidelines also include a requirement for a pedestrian activated signal at each segment of a crosswalk that crosses right or left turn slip lanes.

Accessible Pedestrian Signal Systems (1102.8, 1106)
At signalized intersections, people with vision impairments typically rely on the noise of traffic alongside them as a cue to begin crossing. The effectiveness of this technique is compromised by various factors, including increasingly quiet cars, permitted right turns on red, pedestrian activated signals, and wide streets. Further, low traffic volumes may make it difficult to discern signal phase changes. Technologies are available that enable audible and vibrating signals to be incorporated into pedestrian signal systems, which are those systems that provide signals expressly for pedestrians, such as "walk" signs. The draft guidelines would require pedestrian signal systems, where provided, to provide both audible and vibrating indications of the "walk" interval. Typically, a small box, with a directional arrow, emits an audible tone or voice message and vibrates when the walk interval begins.

Increasingly, signals activated by pedestrians, usually by means of a push button, are being installed. The draft guidelines would require push buttons, where provided, to be equipped with a locator tone integrated into the signaling device to indicate that pedestrian activation is necessary and to identify the location of the push button.

The Board is proposing to apply these requirements where pedestrian signal systems are provided at pedestrian crossings. The advisory committee had recommended limiting their application only where certain types of pedestrian signal systems are provided, such as those that are pedestrian activated. The Board believes that access should be required at all crossings equipped with pedestrian signals to ensure a consistent level of accessibility within a pedestrian network. Compliant products are available. A project the Board sponsored on accessible pedestrian signals provides a synthesis on current technology in accessible pedestrian signals, including a listing of devices and manufacturers in the U.S. and abroad, and a matrix comparing the features of each device. The project report, "Accessible Pedestrian Signals" provides information on several different types of devices on the market, including audible, vibrating, and receiver-based infrared systems. Audible systems are now available that feature discreet tones which automatically adjust to the ambient noise level. These systems have replaced older products that had raised concerns about noise pollution.

In addition, the criteria for pedestrian signal devices, most of which are consistent with MUTCD specifications, address:

  • placement close to the crosswalk they serve and separation from other signals;
  • mounting location at accessible reach ranges (as specified in ADAAG section 308);
  • clear ground space (complying with ADAAG section 305)that is connected to the pedestrian access route;
  • characteristics of required tone or voice indicators;
  • operating characteristics for pushbuttons (as specified in ADAAG section 309.4 for operable parts); and
  • tactile and visual signs that indicate crosswalk direction, street names, and crosswalk configurations.

Street Furniture (1102.9, 1107)
The draft guidelines provide requirements for street furniture made available for pedestrian use, including drinking fountains, public telephones, toilet facilities, tables, and benches. The draft guidelines would not require provision of street furniture, but instead would apply access requirements where such furniture is provided for pedestrian use. Access would not be required to elements that do not serve pedestrians, such as utility poles, fire hydrants, and signal transformers. Since the types of furniture addressed in this section are covered in ADAAG, this section references relevant ADAAG requirements.

Clear Floor Space (1107.2)
The draft guidelines address wheelchair access to street furniture by referencing requirements for clear floor or ground space in ADAAG 305. Such space must be connected to a pedestrian access route and meet ADAAG criteria for size (30 by 48 inches minimum), surfacing, knee and toe clearances, positioning, approach, and maneuvering clearances.

Drinking Fountains (1107.3)
ADAAG requirements for drinking fountains in section 602 cover access for people who use wheelchairs and access for standing persons who may have difficulty bending or stooping. The draft guidelines would apply these requirements for this dual access to each installation in public rights-of-way. This can be achieved by providing two units at each location or installing single units that provide dual access, such as those equipped with two spouts or combination high-lo types.

Public Telephones (1107.4)
ADAAG requirements for public telephones in section 704 cover wheelchair access, volume controls, and TTYs, which are devices that enable people with hearing or speech impairments to communicate through the telephone. For single installations, the draft guidelines would require public telephones to provide wheelchair access and TTY access. Where a bank of telephones is provided, these requirements are to be met at two different phones. All public telephones would be required to have volume controls, which is consistent with ADAAG, as well as guidelines the Board issued for telecommunication products under section 255 of the Telecommunications Act of 1996, which requires telecommunication products and services to be accessible.

Public Toilet Facilities (1107.5)
The draft guidelines would require permanent or portable public toilet facilities to be accessible according to ADAAG section 603. Where single-user facilities are clustered at a single location, an exception would permit at least 5% to be accessible. The advisory committee recommended a minimum scoping requirement of 25%, but the Board has chosen the 5% specification for consistency with ADAAG. Provided fixtures would be subject to ADAAG requirements in sections 604 through 610, which cover water closets and toilet compartments, urinals, lavatories, bathing fixtures, and grab bars. In addition, operable parts, dispensers, receptacles, or other equipment in toilet facilities would need to comply with relevant criteria in ADAAG section 309, which addresses clear floor space, height, and operating characteristics (operable with one hand and not requiring tight grasping, pinching, twisting of the wrist, or more than 5 pounds of force to operate).

Tables, Counters, and Benches (1107.6)
At least 5% of tables, where provided, would be required to comply with ADAAG requirements in section 902 which cover surface height, knee clearance, and clear ground space. Counters would be subject to ADAAG requirements at section 904 which address surface height and approach clearances. Accessible bench requirements in ADAAG section 903 would be applied to at least half the benches provided. ADAAG criteria for benches cover size, back support, height, structural strength, and other features. In addition, the draft guidelines would require accessible benches to provide an armrest on at least one end.

Detectable Warning Surfaces (1108)
Pedestrian street crossings, including, curb ramps and blended transitions (1104.3.2), certain median and refuge islands (1105.4.2), and rail lines (1103.7) are required to have detectable warnings for persons with vision impairments. These surfaces feature a distinctive pattern of raised domes to provide a tactile cue detectable by cane or underfoot at the boundary between pedestrian and vehicular routes.

Specifications in section 1108 address the area that these warnings are to cover at required locations. The Board has revised the technical criteria for detectable warnings in order to facilitate compliance and to accommodate existing detectable warning products that have been deemed to provide an equivalent level of accessibility. The revised specifications are also responsive to concerns that had been raised about the impact of the truncated dome surface on wheelchair maneuvering. The Board believes that the revised specifications, which permit wider dome spacing, an in-line grid pattern, and smaller surface coverage at curb ramps (24 inches instead of the full ramp length) will further minimize disruptions or hazards to wheelchair traffic.

Stairs (1102.10)
The draft guidelines apply requirements in ADAAG section 504 to stairs in public rights-of-way. These ADAAG specifications address tread depth and riser height, nosings, handrail and surface requirements, and prohibit open risers. The draft guidelines also include a new requirement for contrasting color across the nosing of stairs in the public right-of-way. This latter provision was recommended by the advisory committee because of the difficulty persons with low vision have in perceiving steps under the variable lighting conditions in public rights-of-ways.

Handrails (1102.11)
Consistent with the revised ADAAG, handrails, where provided, would be subject to ADAAG section 505, which provides specifications for height, knuckle clearance, gripping surface, cross section, surfaces, fittings, and extensions.

Vertical Access (1102.12)
Where elevators or lifts are provided in public rights-of-ways, the draft guidelines would apply specifications in ADAAG for passenger elevators (section 407), limited-use/ limited-application elevators (section 408), and platform lifts (section 410). Elevators are not required by these guidelines except at certain pedestrian overpasses and underpasses with elevation changes greater than 60 inches.

Bus Stops (1102.13)
ADAAG contains requirements for bus boarding and alighting areas and bus shelters in section 810.2 and 810.3. These requirements address bus stop surfacing, dimensions, connections to accessible routes, slope, and wheelchair space within bus shelters. The draft guidelines would apply these requirements to bus stops and shelters provided in public rights-of-way.

On-Street Parking (1102.14, 1109)
A key issue addressed in the guidelines is how to provide access to on-street parking. Current ADAAG scoping and technical requirements are specific to parking lots and facilities on sites. Over the years, the Board has received many inquiries on how they can be applied to on-street spaces. The draft guidelines would require access to at least one parking space on each block face. The advisory committee recommended applying ADAAG requirements in section 208 for parking lots and facilities which uses a sliding scale based on the total number of spaces provided. This scale starts out with a requirement for access to at least 1 space for every 25 spaces provided. The Board was concerned about confusion that might arise in applying a requirement written for parking facilities on sites to on-street parking. The Board believes that the proposed requirement will be easier to implement and enforce.

Technical specifications are provided for parallel and perpendicular or angled spaces. Requirements address adjoining access aisles at spaces, accessible connecting routes, signs, and parking meters. An accessible parallel space and access aisle, which must be flush with the street, can be achieved by indenting the curb line, similar to a loading zone. For a passenger with a disability, drivers park in line with the other spaces, leaving aisle space free; drivers with disabilities can park against the curb, leaving aisle space on the driver’s side free. Since the curb indentation takes space from the sidewalk, the access aisle can only be provided where there is sufficient public right-of-way width. Consequently, an exception is provided that allows spaces without aisles where the available public right-of-way is less than 168 inches wide; such spaces would be placed at the end of a block, closer to corner curb ramps or blended transitions. This exception would not apply where perpendicular and angled parking spaces are provided, which are required to have aisles sufficiently wide enough (96 inches minimum) to accommodate van-mounted lifts.

Signs labeling accessible spaces are to include the International Symbol of Accessibility and be located at least 60 inches high at the head or foot of the parking space. Criteria for parking meters address location, the visibility of displays and information, and the height and operating characteristics of controls as specified in ADAAG section 309.

Passenger Loading Zones (1102.15)
ADAAG requirements for passenger loading zones would be applied to loading zones in the public right-of-way. Where a long loading zone is provided, at least one area in every 100 continuous feet must comply with requirements in ADAAG section 302 and 503 which address the surfacing, the size of vehicle pull-up spaces (8 by 20 feet minimum), the marking and size of access aisles (at least 60 inches wide and as long as the pull-up space), and vertical clearance (114 inches minimum).

Call Boxes (1102.16, 1110)
The draft guidelines address emergency call boxes that are provided at intervals on roadsides for stranded motorists to use to summon aid. Access requirements would apply where such devices are provided. Specifications address access for persons with mobility impairments and persons with sensory impairments, including those with hearing impairments.

The draft guidelines would require that operable parts be located within accessible reach ranges and meet operating characteristics in ADAAG sections 308 and 309.4. ADAAG specifies that controls be operable with one hand and not require tight grasping, pinching, twisting of the wrist, or more than 5 pounds of force to operate. The Board has received information demonstrating that a particular type of call box that initiates a signal through a lever pull requires up to 12 pounds of force to successfully initiate a signal. An exception has been included for lever pull systems.

Specifications also address the wheelchair space complying with ADAAG 304, edge protection at abrupt level changes in the call-box area as is otherwise specified for ramps in ADAAG section 405.9.2, and access at vehicle pull-over spaces. In addition, audible and visual indicators of an activated signal are required in compliance with ADAAG requirements for two-way communication systems in section 708. Handsets, where provided, must also meet specifications in ADAAG section 708. To accommodate persons with hearing impairments, including those who are deaf, the draft guidelines would require volume control and TTY access at call boxes that provide two-way voice communication.