Appendix to Regulatory Assessment

Comparison of Proposed Accessibility Guidelines for Pedestrian Facilities in the Public Right-Of-Way and DOJ 2010 ADA Standards for Accessibile Design

Introduction

The regulatory assessment prepared by the Access Board for the proposed accessibility guidelines for pedestrian facilities in the public right-of-way assumes that, in the absence of the proposed accessibility guidelines, state and local transportation departments will use the DOJ 2010 ADA Standards for Accessible Design (hereinafter referred to as “DOJ 2010 Standards”) in the Department of Justice regulations implementing Title II of the Americans with Disabilities Act (28 CFR part 35) to the extent feasible when designing, constructing, or altering pedestrian facilities in the public right-of-way, consistent with the guidance issued by the Federal Highway Administration.1  The DOJ 2010 Standards are available on the Department of Justice website at: http://www.ada.gov/2010ADAstandards_index.htm.

The proposed accessibility guidelines for pedestrian facilities in the public right-of-way are compared to DOJ 2010 Standards, other applicable standards, and industry practices in the tables below.

Table 1.  Proposed Guidelines Contain Same Requirements as in DOJ 2010 Standards

Table 1 analyzes requirements in the proposed guidelines that are the same as requirements in the DOJ 2010 Standards.2  The requirements in the proposed guidelines in Table 1 will have no impacts on state and local transportation departments compared to the requirements in the DOJ 2010 Standards because the requirements are the same.

Table 2.  Proposed Guidelines Adapt Requirements in DOJ 2010 Standards

Table 2 analyzes requirements in the proposed guidelines that adapt requirements in DOJ 2010 Standards to allow for conditions and constraints in the public right-of-way.3  The requirements in the proposed guidelines in Table 2 do not establish greater requirements for accessibility in the public right-of-way than the requirements in the DOJ 2010 Standards and industry practices.  Some of the requirements in the proposed guidelines in Table 2 establish lesser requirements for accessibility in the public right-of-way than the requirements in the DOJ 2010 Standards. For example, where the pedestrian access route in a sidewalk is contained within the street or highway right-of-way, the grade of the pedestrian access route is permitted to equal the general grade established for the adjacent street or highway to allow for typical roadway geometry instead of the running slope requirements for accessible routes on sites.  The requirements in the proposed guidelines in Table 2 will have no impacts on state and local transportation departments compared to the requirements in the DOJ 2010 Standards and industry practices, except for the 2 percent maximum cross slope requirement for pedestrian access routes contained within pedestrian street crossings with stop or yield control where vehicles slow or stop before proceeding through the intersection (see R204.3 and R302.6).  This requirement will have more than minimal impact on the design and construction of new tabled intersections in hilly urban areas that contain pedestrian street crossings with stop or yield control.

Table 3.  Proposed Guidelines Contain Requirements Not in DOJ 2010 Standards

Table 3 analyzes requirements in the proposed guidelines for which there are no corresponding requirements in the DOJ 2010 Standards.4  The requirements in the proposed guidelines in Table 3 are compared to other applicable accessibility standards and the 2009 edition of Manual on Uniform Traffic Control Devices for Streets and Highways (MUTCD).  Where the requirements in the proposed guidelines in Table 3 are the same as the requirements in other applicable accessibility standards or the MUTCD, the requirements will have no impacts on state and local transportation departments.  Where a requirement in the proposed guidelines in Table 3 differs from a corresponding requirement in other applicable accessibility standards or there is no corresponding requirement in other applicable accessibility standards, the analysis used the following factors to identify whether the requirement will have more than minimal impacts on state and local transportation departments:

  • Whether the requirement can be easily incorporated into the design of the element or facility?
  • Whether the requirement adds features to the element or facility?
  • Whether the requirement reduces space needed for other purposes?
  • What are the additional costs due to the requirement compared to the total design and construction costs for the element or facility?

A requirement that can be easily incorporated into the design of an element or facility, and does not add features to the element or facility or reduce space needed for other purposes will have minimal impacts on state and local transportation departments.  A requirement that cannot be easily incorporated into the design of an element or facility, adds features to the element or facility, or reduces space needed for other purposes and that results in additional costs compared to the total design and construction costs of the element or facility which are not negligible (i.e., are worth considering) will have more than minimal impacts on state and local transportation departments.

The analysis identified three requirements in the proposed guidelines in Table 3 that will have more than minimal impacts on state and local transportation departments:

  • Detectable warning surfaces on curb ramps and blended transitions at pedestrian street crossings (see R208.1 and R305);
  • Accessible pedestrian signals and pedestrian pushbuttons (see R209); and
  • Pedestrian activated signals at roundabout intersections with multi-lane pedestrian street crossings (see R206 and R306.3.2).

[1] See Federal Highway Administration, Office of Program Administration, “Pedestrians and Accessible Design” at: http://www.fhwa.dot.gov/programadmin/pedestrians.cfm.

[2] The requirements analyzed in Table 1include:  drinking fountains, public toilet facilities, tables, counters, passenger loading zones, ramps, stairways, handrails, doors, doorways, gates, operable parts, clear spaces, knee and toe clearance, and reach ranges.

[3] The requirements analyzed in Table 2 include:  sidewalks and other pedestrian circulation paths, pedestrian street crossings, pedestrian overpasses and underpasses, pedestrian at-grade rail crossings, curb ramps and blended transitions, protruding objects, transit stops and transit shelters used by buses and light rail vehicles, on-street parking, and escalators.  The requirements for transit stops and transit shelters used by buses and light vehicles are compared to the accessibility standards in the Department of Transportation regulations implementing the public transportation parts of Title II of the Americans with Disabilities Act.

[4] The requirements analyzed in Table 3 include:  alternate pedestrian access routes, pedestrian signal phase timing, accessible pedestrian signals and pedestrian pushbuttons, pedestrian street crossings at roundabouts, detectable warning surfaces on curb ramps and blended transitions at pedestrian street crossings, detectable warning surfaces on pedestrian at-grade rail crossings not located within a street or highway, pedestrian signs, and benches.


Table 1:  Proposed Guidelines Contain Same Requirements as in DOJ 2010 Standards for Pedestrian Facilities in the Public Right-of-Way
Element or FacilityDOJ 2010 StandardsProposed GuidelinesAnalysis
Drinking Fountains

211
Requires drinking fountains to comply with 602.

602.1 to 602.6
Contains requirements for clear space, operable parts, spout height and location, and water flow.

R212.2
Requires drinking fountains to comply with 602.1 to 602.6 of DOJ 2010 Standards.

No impacts compared to DOJ 2010 Standards.

Public Toilet Facilities

206.2.4
Requires accessible routes within facilities.

213
Requires toilet facilities to comply with 603 to 610.  Where multiple single-user portable units are clustered at a location, at least 5 percent required to comply with 213.

603 to 610
Contains requirements for toilet rooms, water closets and toilet compartments, urinals, lavatories and sinks, bathtubs, shower compartments, grab bars, and seats.

R212.3
Requires public toilet facilities to comply with 206.2.4 and 603 to 610 of DOJ 2010 Standards.  Where multiple single-user units are clustered at a location, at least 5 percent required to comply with R212.3.

No impacts compared to DOJ 2010 Standards.

Tables

226
Requires at least 5 percent of tables to comply with 902.

902
Contains requirements for clear space and height.

R212.4
Requires at least 5 percent of tables to comply with 902 of DOJ 2010 Standards.

No impacts compared to DOJ 2010 Standards.

Counters

227
Requires counters to comply with 904.

904
Contains requirements for approach.

R212.5
Requires counters to comply with 904 of DOJ 2010 Standards.

No impacts compared to DOJ 2010 Standards.

Passenger Loading Zones

209
Requires one accessible passenger loading zone complying with 503 for each 30 m (100.0 ft) of continuous loading zone space.

503
Contains requirements for vehicle pull-up space and access aisle.

R216
Requires one accessible passenger loading zone complying with R310 for each 30 m (100.0 ft) of continuous loading zone space.

R310
Contains requirements for vehicle pull-up space and access aisle.

No impacts compared to DOJ 2010 Standards.

Ramps

405
Contains requirements for running and cross slopes, width, rise, landings, surfaces, handrails, and edge protection for ramps that are part of accessible routes.

R407
Contains requirements for running and cross slopes, width, rise, landings, surfaces, handrails, and edge protection for ramps that are part of pedestrian access routes.

No impacts compared to DOJ 2010 Standards.

Stairways

210
Requires stairways that are part of means of egress to comply with 504.

504
Contains requirements for treads and risers, nosings, and handrails.

R216
Requires stairways provided on pedestrian circulation paths to comply with R408.

R408
Contains requirements for treads and risers, nosings, and handrails.

No impacts compared to DOJ 2010 Standards.

Handrails

403.6
Requires handrails provided on walking surfaces to comply with 505.

405.8
Requires handrails complying with 505 on ramp runs with rise greater than 150 mm (6 in).

504.6
Requires handrails complying with 505 on stairways.

505
Contains requirements for sides, continuity, height, clearance, gripping surface, cross section, surfaces, fittings, and extensions. Requirements for sides, continuity, and extensions apply only to ramps and stairways.

R217
Requires handrails provided on pedestrian circulation paths to comply with R409.

R407.8
Requires handrails complying with R409 on ramp runs with rise greater than 150 mm (6 in).

R408.6
Requires handrails complying with R409 on stairways.

R409
Contains requirements for sides, continuity, height, clearance, gripping surface, cross section, surfaces, fittings, and extensions. Requirements for sides, continuity, and extensions apply only to ramps and stairways.

No impacts compared to DOJ 2010 Standards.

Doors & Doorways, Gates

206.5
Requires doors, doorways, and gates providing user passage to comply with 404.

404
Contains requirements for manual, automatic, and power-assisted doors and gates, including clear width, maneuvering clearances, thresholds, doors and gates in series, hardware, closing speed, opening force, surfaces, vision lights, controls, and break out opening.

R218
Requires doors, doorways, and gates at pedestrian facilities to comply with 404 of DOJ 2010 Standards.

No impacts compared to DOJ 2010 Standards.

Operable Parts

205
Requires operable parts on accessible elements and accessible routes, and in accessible rooms and spaces to comply with 309.

309
Contains requirements for clear space, height, and operation.

R403
Contains requirements for clear space, height, and operation for operable parts on pedestrian pushbuttons at accessible pedestrian signals, and parking meters and parking pay stations at accessible parking spaces.

No impacts compared to DOJ 2010 Standards.

Clear Spaces, Knee & Toe Clearance

305, 306
Contains requirements for surfaces, size, position, approach, maneuvering space, and knee and toe clearance for clear floor or ground spaces required at operable parts and accessible elements.

R404, R405
Contains requirements for surfaces, size, position, approach, maneuvering space, and knee and toe clearance for clear spaces required at operable parts (see R403), benches, and transit shelters.

No impacts compared to DOJ 2010 Standards.

Reach Ranges

308

Contains requirements for forward and side reach to operable parts and accessible elements.

R406
Contains requirements for forward and side reach to operable parts (see R403).

No impacts compared to DOJ 2010 Standards.

Table 2:  Proposed Guidelines Adapt Requirements in DOJ 2010 Standards to Pedestrian Facilities in the Public Right-of-Way
Element or FacilityDOJ 2010 StandardsProposed GuidelinesAnalysis
* DOT Standards apply to transportation facilities used in the provision of dedicated transportation services and intercity and commuter rail services.
Sidewalks & Other Pedestrian Circulation Paths

206.2.2
Requires accessible routes complying with 401 to 410 within sites.

106.5
Site defined to include “parcel of land bounded by a property line or a designated portion of a public right-of-way.”

R204.2
Requires pedestrian access routes complying with R302 within sidewalks and other pedestrian circulation paths located in public right-of-way.

105.5
Public right-of-way defined to include “public land or property, usually in interconnected corridors, that is acquired for or dedicated to transportation purposes.”

No impacts compared to DOJ 2010 Standards and industry practices.  Adapts accessible route requirements to sidewalks and other pedestrian circulation paths in public right-of-way.  In alterations where existing physical constraints make it impracticable to fully comply with new construction requirements, compliance is required to extent practicable (see R202.3.1).

Width

403.5.1
915 mm (3.0 ft) minimum

R302.3
1.2 m (4.0 ft) minimum

Industry practice is to design sidewalks 1.2 m (4.0 ft) wide minimum so two people can walk side-by-side and pass a third person comfortably.  In commercial areas, sidewalks are wider than 1.2 m (4.0 ft). See AASHTO Green Book (p. 398); AASHTO Pedestrian Facilities Guide (p. 58).

Passing Spaces

403.5.3
Where clear width less than 1.5 m (5.0 ft) wide, requires passing spaces 1.5 m (5.0 ft) by 1.5 m (5.0 ft) minimum at intervals of 61 m (200.0 ft) maximum.

R302.4
Where clear width less than 1.5 m (5.0 ft) wide, requires passing spaces 1.5 m (5.0 ft) by 1.5 m (5.0 ft) minimum at intervals of 61 m (200.0 ft) maximum.

Same as DOJ 2010 Standards.

Grade

403.4 Walking Surfaces
5 percent maximum

405.2 Ramps
8.3 percent maximum

R302.5
Where pedestrian access route is contained within street or highway right-of-way, permits grade to equal general grade established for adjacent street or highway.  Where pedestrian access route is not contained within street or highway right-of-way, requires 5 percent maximum grade.

Grade requirements modified to allow for typical roadway geometry.

Cross Slope

403.3
2 percent maximum

R302.6
2 percent maximum

Same as DOJ 2010 Standards.

Surfaces

302.1, 403.2
Firm, stable, and slip resistant

R302.7
Firm, stable, and slip resistant

Same as DOJ 2010 Standards.

Vertical Alignment

403.4
Requires changes in level to comply with 303.

R302.7.1
Requires vertical alignment within pedestrian access routes to be generally planar, and grade breaks to be flush.

Adapts requirement for level surfaces to pedestrian access routes in the public right-of-way.

Vertical Surface Discontinuities

303
Permits vertical surface discontinuities up to 13 mm (0.5 in) maximum.  Requires vertical surface discontinuities between 6.4 mm (0.25 in) and 13 mm (0.5 in) to be beveled.

R302.7.2
Permits vertical surface discontinuities up to 13 mm (0.5 in) maximum.  Requires vertical surface discontinuities between 6.4 mm (0.25 in) and 13 mm (0.5 in) to be beveled across the entire vertical surface discontinuity.

Same as DOJ 2010 Standards, except bevel required across entire vertical surface discontinuity.

Horizontal Openings in Gratings & Joints

302.3, 403.2
Must not allow passage of sphere more than 13 mm (0.5 in) in diameter.

R302.7.3
Must not allow passage of sphere more than 13 mm (0.5 in) in diameter.

Same as DOJ 2010 Standards.

Pedestrian Street Crossings

Apply accessible route requirements.

Apply pedestrian access route requirements with following modifications:

R302.3.1 Width at Medians & Pedestrian Refuge Islands
1.5 m (5.0 ft) minimum

R302.5.1 Grade
5 percent maximum

R302.6.1 Cross Slope at Crossings Without Yield or Stop Control
5 percent maximum at crossings without yield or stop control (i.e., where vehicles proceed thru intersection without slowing or stopping)

R302.6.2 Cross Slope at Midblock Crossings
Permits cross slope to equal street or highway grade.

No impacts compared to DOJ 2010 Standards, except as noted below.  Adapts accessible route requirements to pedestrian street crossings to allow for typical roadway geometry.  In alterations where existing physical constraints make it impracticable to fully comply with new construction requirements, compliance is required to the extent practicable (see R202.3.1).

2 percent maximum cross slope will have more than minimal impact on new construction of tabled intersections in hilly urban areas that contain pedestrian street crossings with yield or stop control where vehicles slow or stop before proceeding thru the intersection. Impact is analyzed in regulatory assessment.

Pedestrian Overpasses & Underpasses

Apply accessible route requirements.

Apply pedestrian access route requirements with following modifications:

R204.4
Where overpass, underpass, bridge, or similar structure is designed for pedestrian use only and approach slope to structure exceeds 5 percent, requires ramp, elevator, limited use/limited application elevator, or platform lift.  Where overpass, underpass, bridge, or similar structure is designed for both pedestrian and vehicle use and pedestrian access route is contained within street or highway right-of-way, grade of pedestrian access route is permitted to equal general grade established for adjacent street or highway.

No impacts compared to DOJ 2010 Standards.  Design of new pedestrian overpasses and underpasses currently required to include ramps.  See FHWA Policy on Accessible Design at: http://www.fhwa.dot.gov/program admin/pedestrians.cfm.  Allows use of ramps, elevators, or platform lifts to access overpasses and underpasses designed for pedestrians only.  Adapts accessible route requirements to pedestrian overpasses and underpasses designed for both pedestrian and vehicle use.

Pedestrian At-Grade Rail Crossings

402, 810.10
Requires pedestrian at-grade rail crossings to comply with accessible route requirements.  Permits flangeway gaps to be 64 mm (2.5 in) maximum.

R302.7.1, R302.7.4
Requires pedestrian access route to be level and flush with top of rail at outer edges of rail.  Requires surface between rails to be aligned with top of rail.  Permits flangeway gaps to be 64 mm (2.5 in) maximum on non-freight rail track, and 75 mm (3 in) on freight rail track.

No impacts compared to DOJ 2010 Standards.  Permits wider flangeway gaps for freight railway track.

Curb Ramps & Blended Transitions

28 CFR 35.151 (c) (i)
Requires curb ramps or other sloped areas at pedestrian street crossings on newly constructed or altered streets, roads, highways, and street level pedestrian walkways.

206.2.2, 402.2
Requires accessible routes within sites.  Curb ramps are components of accessible routes.

406
Contains requirements for perpendicular curb ramps, including location, landings, flared sides, and counter slope. Permits diagonal curb ramps.

R207.1
Curb ramps, blended transitions, or combination of curb ramps and blended transitions required to connect pedestrian access routes at each pedestrian street crossing (i.e., sidewalk level and street level).

R207.2
Permits single diagonal curb ramp to serve both pedestrian street crossings in alterations, where existing physical constraints prevent compliance with R207.1.

R304
Contains requirements for perpendicular curb ramps (turning space, running slope, and flared sides); parallel curb ramps (turning space and running slope); blended transitions (running slope); and common requirements applicable to curb ramps and blended transitions (width, grade breaks, cross slope, counter slope, and clear space).

No impacts compared to DOJ 2010 Standards.  Adapts curb ramp requirements to public right-of-way.  Includes additional designs for parallel curb ramps and blended transitions.  Permits cross slope of curb ramps and blended transitions at pedestrian street crossings without yield or stop control where vehicles do not slow or stop before proceeding thru the intersection and at midblock pedestrian street crossings to equal street or highway grade.

Protruding Objects

204, 307.5
Requires protruding objects on circulation paths to comply with 307 and not reduce clear width required for accessible routes.

307
Contains requirements for protrusion limits, post-mounted objects, and vertical clearance.

R210
Requires protruding objects along or overhanging pedestrian circulation paths to comply with R402 and not reduce clear width required for pedestrian access routes.

R402
Contains requirements for protrusion limits, post-mounted objects, and vertical clearance.

No impacts compared to DOJ 2010 Standards and MUTCD.  Limits posted-mounted objects that are 685 mm (2.25 ft) minimum and 2030 mm (6.7 ft) maximum above sidewalk from projecting into pedestrian circulation paths 100 mm (4 in) maximum measured horizontally from post or pylon base.  MUTCD requires bottom of signs installed on sidewalks to be 2030 mm (6.7 ft) minimum above sidewalk, and bottom of secondary signs mounted below another sign that are lower than 2030 mm (6.7 ft) above sidewalk to project not more than 100 mm (4 in) into sidewalk.

Transit Stops, Boarding & Alighting Areas

218, 810.2*
Contains requirements for bus boarding and alighting areas, including surfaces, dimensions, slope, and accessible route connections.

R213, R308.1.1, R308.1.3
Contains requirements for boarding and alighting areas at sidewalk or street level transit stops, including surfaces, dimensions, grade, and pedestrian access route connections.  Where transit stops serve vehicles with more than one car, requires boarding and alighting area serving each car to comply with requirements,

No impacts compared to DOT Standards and current industry practices.*  Adapts boarding and alighting area requirements to transit stops in public right-of-way used by buses and light rail vehicles.

Boarding Platforms

218, 810.5*
Contains requirements for rail boarding platforms, including platform and vehicle floor coordination and slope.

R213, R308.1.2, R308.1.3
Contains requirements for boarding platforms at transit stops, including platform and vehicle floor coordination, slope, surfaces, and pedestrian access route connections.

No impacts compared to DOT Standards and current industry practices.*  Adapts boarding platform requirements to transit stops in public right-of-way used by buses and light rail vehicles.

Detectable Warning Surfaces

218, 810.5.2*
Requires detectable warning surfaces on boarding platforms at rail stations.

705*
Contains requirements for dome size and spacing, contrast, size, and placement of detectable warning surfaces.

R208
Requires detectable warning surfaces at boarding platforms at transit stops for buses and rail vehicles, and at boarding and alighting areas at sidewalk or street level transit stops for rail vehicles.

R305
Contains requirements for dome size and spacing, contrast, size, and placement of detectable warning surfaces.

No impacts compared to DOT Standards and current industry practices.*  Adapts requirements for detectable warning surfaces on boarding platforms to transit stops in public right-of-way used by buses and light rail vehicles.

Route Signs

218, 703, 810.4, 810.6.2*
Requires signs that identify routes served by bus stops and rail stations to comply with requirements for visual characters on signs. Bus route signs required to comply with requirements for character height to maximum extent practicable.  Bus route signs not required to comply with requirements for height from ground and line spacing.  Permits use of audible signs as an alternative means of compliance for signs at rail stations.

R211.3, R410
Requires signs that identify routes served by transit stops to comply with requirements for visual characters on signs. Permits use of audible sign systems and other technologies to provide equivalent information as an alternative means of compliance.

No impacts compared to DOT Standards and current industry practices.*  Adapts requirements for route signs to transit stops in public right-of-way used by buses and light rail vehicles.

Transit Shelters

218, 810.3*
Requires clear space within bus shelters, and accessible route connections.

R213, R308.2
Requires clear space within transit shelters, and pedestrian access route connections.  Requires environmental controls to be proximity-actuated, and protruding objects to comply with R402.

No impacts compared to DOT Standards and current industry practices.*  Adapts requirements for transit shelters to transit stops in public right-of-way used by buses and light rail vehicles.  Requires environmental controls to be proximity-actuated instead of complying with requirements for operable parts (see R403).  Clarifies that requirements for protruding objects applies to transit shelters.

On-Street Parking

208
Where parking is provided, requires minimum number of accessible parking spaces complying with 502.

502
Contains requirements for vehicle spaces and adjoining access aisles.

216.5, 502.6, 703.7.2.1
Requires accessible parking spaces to be identified by signs displaying International Symbol of Accessibility.

R214
Where on-street parking is provided and is marked or metered, requires minimum number of accessible parking spaces complying with R309.

R309.2
Requires access aisles at accessible parallel parking spaces, where width of adjacent sidewalk or available right-of-way exceeds 4.3 m (14.0 f).  In alterations (e.g., parallel parking spaces marked or parking meters installed on existing street), access aisles not required where street or sidewalk adjacent to parking spaces is not altered.  Where access aisles not provided, requires accessible parallel parking spaces to be located at end of block face.

R309.3
Requires access aisles at perpendicular and angled parking spaces.  Permits two accessible parking spaces to share common access aisle.

R309.4
Requires curb ramps or blended transitions to connect access aisles to pedestrian access routes.  Permits curb ramps or blended transitions at pedestrian street crossings to serve parking spaces located at end of block face.

R309.5
Requires parking meters and parking pay stations serving accessible parking spaces to be located at head or foot of parking space, and displays and information to be visible to person seated in wheelchair.  Requires operable parts to comply with R403.

R211.4, R411
Requires accessible parking spaces to be identified by signs displaying International Symbol of Accessibility.

No impacts compared to DOJ 2010 Standards.  Adapts parking requirements to public right-of-way.  Accessible parallel parking spaces located adjacent to no parking zones will not result in loss of parking spaces.  Loss of perpendicular and angled parking spaces is same as compared to DOJ 2010 Standards (1 parking space per 50 marked or metered parking spaces on the block perimeter).  Impacts on alterations that do not involve changes to street or sidewalk are minimal since access aisles not required.

Escalators

810.9
Requires escalators in rail stations to comply with ASME A17.1 Safety Code for Elevators and Escalators sections on steps, and entrance and egress ends.

R216
Requires escalators on pedestrian circulation paths to comply with ASME A17.1 Safety Code for Elevators and Escalators sections on steps, and entrance and egress ends.

No impacts compared to ASME A17.1 Safety Code for Elevators and Escalators.  Escalators comply with ASME A17.1 Safety Code for Elevators and Escalators as standard of care for industry.

Table 3:  Proposed Guidelines Contain Requirements Not in DOJ 2010 Standards for Pedestrian Facilities in the Public Right-of-Way
Element or FacilityProposed GuidelinesOther Applicable StandardsAnalysis
Alternate Pedestrian Access Routes

R205, R303
Requires alternate pedestrian access routes to comply with referenced MUTCD standard statements when pedestrian access routes are temporarily closed by construction, alterations, maintenance operations, or other conditions.

Referenced MUTCD standard statements require alternate pedestrian routes to be accessible and detectable when pedestrian routes are temporarily closed by construction, alterations, maintenance operations, or other conditions.

Compliance with referenced MUTCD standard statements is mandatory (see MUTCD, section 1A.13).  No impacts compared to MUTCD.

Pedestrian Street Crossings — Pedestrian Signal Phase Timing

R206, R306.2
Requires pedestrian signal phase timing to comply with referenced MUTCD standard statements.

Referenced MUTCD standard statements contain requirements for pedestrian signal phase timing.

Compliance with referenced MUTCD standard statements is mandatory (see MUTCD, section 1A.13).  No impacts compared to MUTCD.

Pedestrian Street Crossings — Accessible Pedestrian Signals and Pedestrian Pushbuttons

R209, R307
Requires pedestrian signals to include accessible pedestrian signals and pedestrian pushbuttons that comply with referenced MUTCD standard statements.  Requires operable parts to comply with R403.

R206, R306.5
At signalized intersections, requires pedestrian activated signals complying with R209 at multi-lane channelized turn lanes.

Referenced MUTCD standard statements contain requirements for installation of accessible pedestrian signals and pedestrian pushbuttons. However, MUTCD does not require pedestrian signals to include accessible pedestrian signals and pedestrian pushbuttons.

Transportation Equity Act for 21st Century (TEA-21) requires audible pedestrian signals to be included in transportation plans and projects, where appropriate (23 U.S.C. (g)).

Accessible pedestrian signals and pushbuttons add features to pedestrian signals.  Additional costs due to requirement compared to total design and construction costs for pedestrian signals are not negligible.  Impact will be more than minimal and is analyzed in Regulatory Assessment.

Pedestrian Street Crossings — Roundabouts

R206, R306.2

Requires detectable edge treatment (e.g., grass strip) between sidewalk and curb at roundabouts with pedestrian facilities where pedestrian street crossing is not intended.

R206, R306.3

Requires pedestrian activated signals at roundabouts with multi-lane pedestrian street crossings.

R206, R306.4
Requires pedestrian activated signals at roundabouts with pedestrian street crossings at multi-lane channelized turn lanes.

None

Detectable edge treatment can be easily incorporated into design of roundabouts with pedestrian facilities.  Any additional costs due to requirement compared to total design and construction costs for roundabouts are negligible.  Impact will be minimal.

Pedestrian activated signals add features to roundabouts.  Additional costs due to requirement compared to total design and construction costs for roundabouts are not negligible.  Impact will be more than minimal and is analyzed in Regulatory Assessment.

Pedestrian Street Crossings — Detectable Warning Surfaces on Curb Ramps, Blended Transitions, and Pedestrian Refuge Islands

R208
Requires detectable warning surfaces on curb ramps, blended transitions, and pedestrian refuge islands at pedestrian street crossings.  Detectable warning surfaces not required at pedestrian refuge islands that are cut-trough at street level and are less than 1.8 m (6.0 ft) in length in direction of pedestrian travel.

DOJ 1991 Standards require detectable warning surfaces on curb ramps.  DOJ 1991 Standards can be used until March 15, 2012.

DOJ 2010 Standards do not require detectable warning surfaces on curb ramps.  DOJ 2010 Standards effective on March 15, 2012, but DOJ permits use before this date.

DOT Section 504 Standards require detectable warning surfaces on curb ramps.

DOJ and DOT permit use of UFAS. UFAS does not require detectable warning surfaces on curb ramps.  DOJ does not permit use of UFAS on or after March 15, 2012.

Design manuals issued by all state transportation departments require detectable warning surfaces on curb ramps.

AASHTO Green Book (p. 100) and Pedestrian Facilities Guide (p. 85) recommend detectable warning surfaces on curb ramps.

The DOJ 2010 Standards and UFAS do not require detectable warning surfaces on curb ramps.  The requirement adds features to curb ramps.  Additional costs due to requirement compared to total design and construction costs for curb ramps are not negligible. Impact will be more than minimal and is analyzed in Regulatory Assessment.

Pedestrian At-Grade Rail Crossings Not Located Within Street or Highway — Detectable Warning Surfaces

R208
Requires detectable warning surfaces at pedestrian at-grade rail crossings not located within street or highway.

None

Few pedestrian at-grade rail crossings not located within street or highway are constructed or altered in any year.  Additional costs due to requirement are negligible compared to total design and construction costs for pedestrian at-grade rail crossings.  Impact will be minimal.

Pedestrian Signs

R211.2, R410
Requires signs, other than transit signs, that provide directions, warnings, or other information for pedestrians only to comply with requirements for visual characters on signs.  Permits use of audible sign systems and other technologies to provide equivalent information as an alternative means of compliance.

None

Requirements for visual characters on signs are same as in DOJ 1991 and 2010 Standards.  Sign designers are familiar with requirements, and they can be easily incorporated into design of signs. Any additional costs due to the requirement are negligible compared to total design and construction costs for signs.  Impact will be minimal.

Benches

R212.6
Requires clear space adjacent to at least 50 percent of benches at each location.  Does not apply to benches at tables.

None

Clear space can be easily incorporated into design of benches and the adjacent pedestrian circulation path.  Any additional costs due to the requirement are negligible compared to total design and construction costs for benches and adjacent pedestrian circulation path.  Impact will be minimal.