Discussion of Provisions


Clarifications, modifications, and changes that have been incorporated in this draft in response to public comment from industry, consumers, and State and local government agencies are briefly discussed below.

R104.2.1 MUTCD. This draft references the 2003 edition of the Manual on Uniform Traffic Control Devices (MUTCD). The Access Board works closely with the MUTCD team at the Federal Highway Administration (FHWA) to harmonize standards and advisory material and to sponsor needed research. Changes in future MUTCD provisions for accessible pedestrian signals, markings (including detectable warnings), and temporary traffic zones are in process. A joint FHWA/ American Traffic Safety Services Association (ATSSA)/Access Board demonstration project identified desirable characteristics for pedestrian channelizing devices. FHWA research projects on pedestrian usability at roundabouts and contrast in detectable warnings are underway, and the Board has proposed a FY 2006 project on pedestrian demand signals for use at multi-lane roundabout crossings.

R105 Definitions. This draft uses definitions drawn from key industry references where they exist.

R201 Application. Text and advisory material has been added to clarify the application of these guidelines to new or altered work (permanent or temporary) put in place within the scope or limits of a planned project in the public right-of-way.

Other requirements, including those for existing facilities, maintenance of accessible features, and effective communication that derive from the ADA title II implementing regulations (28 CFR part 35) or Federal highway-aid funding (49 CFR part 27), are not addressed in these guidelines for new construction and alteration. Advisory notes have been added to clarify this difference.

This draft now includes a reference to the revised ADA and ABA Accessibility Guidelines (36 CFR part 1191) to cover buildings and facilities newly constructed or altered within the public right-of-way.

R202 Alterations and Additions to Existing Facilities. Text and advisory notes have been added to this draft to clarify the application of new construction guidelines to an alteration project. New work put in place within an existing developed right-of-way must comply with these guidelines to the maximum extent feasible; see Advisory R202.3. Transitional segments that connect undisturbed improvements with new work can facilitate compliance (R202.1.1). Where items are placed within an existing developed streetscape and the circulation route is not altered, items required to be accessible shall be located for optimal usability and access (R202.1.2).

An alteration is a change in a space or element that affects, or could affect, the accessibility or usability of that space or element. In general, when a feature in the public right-of-way is altered, the requirements for new construction in this document must be applied to the maximum extent feasible within the scope or boundary of the project that has been planned. This document does not contain a ‘path of travel’ obligation to expand a given scope of work to include other items or elements that are adjacent to the alteration project nor does it cover an agency’s obligations to achieve program access in its existing facilities that are not being altered.

In response to the comments received, the Board has developed answers to frequently asked questions regarding the application of the alterations requirements. Those questions and the Board’s responses have been included at the end of this discussion.

R204 Pedestrian Access Route (technical provisions at R301). This draft clarifies the requirement for a 1.2-meter-wide (4 ft) accessible route of travel within a pedestrian circulation path, which may be a wider sidewalk, shoulder (if pedestrian use is not prohibited), shared street, or street crossing. A provision requiring periodic passing spaces 1.5 m (5 ft) in width, omitted in the first draft, has been re-instituted. Because of the constraints imposed by right-of-way width, the pedestrian access route (PAR) is relieved of the slope limits that would apply to an accessible route on a site provided it matches the general grade of the adjacent roadway (R301.4). Where the PAR is supported by structure, as in an underpass, overpass, or bridge, this draft requires compliance with ADAAG requirements for ramps.

Technical provisions in the June 2002 draft that would have required a 30-inch separation between changes in level in the PAR have been replaced in this draft with provisions requiring a planar surface (R305.1) and limiting surface discontinuities (R301.5.2). An advisory note discourages the use of heavily textured, rough, or excessively chamfered unit pavings. Research undertaken by the Research and Rehabilitation Training Center (RRTC) at the University of Pittsburgh, under contract to a group of unit masonry associations, measured the vibration effects of various chamfer spacings on wheeled mobility devices and found that chamfers of less than 1.25 mm (.5 in), if flush, were not distinguishable from cast-in-place concrete sidewalks with a broom finish.

A series of related provisions in the June 2002 draft has been reorganized into R301.7 Horizontal Openings, which now includes walkway joints, gratings, flangeway gaps at rail crossings, and sill gaps at elevators and lifts. (Platform and car gaps at transit facilities are addressed at 36 CFR part 1191).

R205 Alternate Pedestrian Access Route. This draft clarifies that the establishment of an alternate pedestrian route is an alteration that must comply to the maximum extent feasible with technical provisions for the pedestrian access route, including curb ramps or blended transitions. MUTCD requirements and advisory material at Part 6D.01 and 6D.02 are referenced and an advisory note added to highlight the safety benefits of same-side alternate routes. Specifications for pedestrian channelizing devices and barricades at 302.4 include a reference to the MUTCD.

R206 Pedestrian Crossings (technical provisions at R305). This draft omits a provision in the June 2002 draft that would have required 2.4 m-wide (8 ft) markings at crosswalks. The MUTCD minimum of 1.8 m (6 ft) has been proposed at 305.2.1 of this draft.

Measurements on which pedestrian signal phase timing are based have been modified in response to industry comment. Calculations now proposed in R305.3 in the current draft would require the distance to be the full street width and the pedestrian walking speed to be 1.1 m/s (3.5 fps).

The June 2002 draft also proposed that the approaches to overpasses and underpasses be provided with elevators where the grade change was 1.5 m (5 ft) or greater. Both industry and persons with disabilities opposed this requirement with persons with disabilities expressing a preference for ramps, even if lengthy, to ensure the availability of a crossing. Elevators in single installations provide no access at all when out of service. Industry expressed concerns about cost and maintenance requirements. The current draft applies ramp provisions at R305.5 (but permits elevators, LULAs, and lifts).

Newly available research and the comments of both industry and consumer representatives confirm the Access Board’s concerns about the usability of pedestrian crossings at roundabouts and channelized turn lanes. However, access to additional data has indicated that well-designed roundabouts and channelized turn lanes with single-lane crossings can provide cues that make non-visual use possible. Accordingly, this draft (R305.6.2) provides that signals (including accessible pedestrian signal features) be required only at multi-lane pedestrian crossings of roundabouts. The Board does not prescribe the signal operation here and has proposed that FHWA conduct research to identify appropriate technologies. Two-head signals that flash amber, then flash red and go to steady red, are in use in Australia and the United Kingdom. US motorists are familiar with pre-emptive signals installed for emergency vehicles. Utah has at least one roundabout that uses standard railway gates across the roadway when light rail cars pass through the roundabout. The Board believes that the occasional use of a properly-designed pedestrian demand signal may actually reduce delay at pedestrian crossings.

R207 Curb Ramps and Blended Transitions (technical provisions at R303). Additional text, advisory, and illustrations have been added to this draft to describe curb ramp types (perpendicular, parallel, and their combination) and to distinguish them from blended transitions, for which a definition has now been provided at R105. Blended transitions are connections between the PAR and the street that have a running slope of 1:20 or less. Level landings, gently sloped transitions, and raised crosswalks fall into this category. Parallel and perpendicular curb ramps have a running slope between 1:20 and 1:12 (steeper slopes are not permitted in new construction).

Non-visual wayfinding cues can be provided by the orientation of curb ramps, particularly if they are in-line with the path of pedestrian travel along a sidewalk. Curb ramps installed at tangent points rather than on the corner radius provide more usable cues and locate the shortest crossing point. The Access Board is collaborating with the Institute of Transportation Engineers (ITE) on a project to standardize sidewalk/ramp/crossing schemes for optimal non-visual cuing based upon a range of corner radii and attached/separated sidewalk configurations. An advisory note (R303.1) in this draft notes the benefits for pedestrians.

Cross slope provisions at midblock curb ramps (R303) have been revised in response to industry comment to permit warping to meet roadway grade. Similar changes have been made to technical provisions at pedestrian crossings (R305.2.2). Crossings of streets without stop control would be permitted a 1:20 maximum cross slope.

Running slope limits at crosswalks (R305.2.3) are maintained at 1:20 maximum in this draft. Many commenters noted that design practices that approach this limit in new construction may have to mill the roadway crown before resurfacing in order to retain usable crossings.

R208 Accessible Pedestrian Signals (technical provisions at R306). APS provisions in this draft differ only slightly from those of the June 2002 draft. Many commenters to the June 2002 draft expressed concerns about the costs of retrofitting intersections with APS, which is not required by these or prior proposals, which guide only new construction and alterations. Where new pedestrian signals are being installed or added, scoping in this document would require that they incorporate audible and vibrotactile features.

Comments from disability organizations and individuals to the June 2002 draft were diverse. Many who believed that retrofitting was required objected to what they understood to be excessive cost. And even those who did not support a general requirement that all future pedestrian signals incorporate audible and vibrotactile formats nevertheless saw the need for them at certain types of intersections including irregular crossings, lengthy crossings, and at complex intersections with multiple vehicle turning phases or leading pedestrian interval phasing. Although many responders noted the utility of non-visual cues, a clear majority of commenters who identified themselves as blind supported universal pedestrian signals.

R209 Protruding Objects (technical provisions at R401). Advisory notes have been added at several places in this document to remind users of the need to consider projections into the pedestrian circulation route when coordinating the placement of improvements, appurtenances, utilities, or street furniture. Comments from disability organizations and individuals identified blocked or compromised pedestrian routes as a major barrier to independent travel. Protruding objects provisions in this draft have been revised only to accommodate the new format and add advisory information.

R210 Pedestrian Signs (technical provisions at R409). An advisory note has been added to clarify requirements for visual legibility in signs that indicate sidewalk closure, pedestrian detour, and tourist route signage covered in MUTCD. Braille street name signage is required only on APS pedbuttons (R306.4.2).

Signage provisions in this draft have been revised only to accommodate the new format and add advisory information.

R211 Street Furniture (technical provisions at R307). Advisory notes have been added at several places in this document to remind users of the need to consider the dimensions and use of pedestrian circulation routes when coordinating the placement of improvements, appurtenances, utilities, or street furniture. Comments from disability organizations and individuals identified blocked or compromised pedestrian routes as a major barrier to independent travel.

Street furniture provisions in this draft have been revised only to accommodate the new format and add advisory information.

R212 Bus Stops (technical provisions at R410.2). An advisory note has been added to clarify the difference between establishing a bus stop by installing signage (signage must comply with R210.2) and constructing a bus stop (boarding/alighting areas, if provided, must comply with R410, bus shelters with R410.2).

Bus stop provisions in this draft have been revised only to accommodate the new format and add advisory information.

R213 Stairways (technical provisions at R407). Stairway provisions in this draft have been revised only to accommodate the new format.

R214 Handrails (technical provisions at R408). Handrail provisions in this draft have been revised only to accommodate the new format and add an advisory note on alterations and protruding objects.

R215 Vertical Access (technical provisions in ADAAG). Vertical access provisions in this draft have been revised only to accommodate the new format and add an advisory note on elevator use in extremes of terrain.

R216 On-Street Parking (scoping at Table R216; technical provisions at R308). Table R216 in this draft has been adapted from the table in ADAAG based upon the overall number of spaces provided within a block (or analog). Commenters strongly objected to scoping based upon the numbers of parking spaces on a block face, which could, in many places, require very high numbers of spaces disproportionate to those required in lots.

Additionally, this draft clarifies when, in new construction or alterations, the presence of a sidewalk or border wider than 4.3 m (14 ft) can accommodate an access aisle that is indented into the curb for protected transfer space, a construction that is similar to that of an on-street loading zone provided at an office, hotel, convention center, arena, or airport (R308.2.1).

Advisory notes have been added at several places in this section to convey additional information about indented, end-of-block, perpendicular or angled spaces, and signage.

R218 Call Boxes (technical provisions at R309). Call box provisions in this draft have been revised only to accommodate the new format and add an advisory note at R309.1 about the applicability of accessible call box technology to other types of communications systems, such as on-street security systems.

R219 Transit Platforms (technical provisions at R414). Transit provisions from the ADA and ABA Accessibility Guidelines (204) have been newly incorporated in this draft.

R220 Escalators. Escalator provisions in this draft have been revised only to accommodate the new format.

R221 Detectable Warning Surfaces (technical provisions at R304). Transportation industry and State and local government agency commenters expressed concern about the durability, maintainability, and contrast of detectable warning materials required at curb ramps and blended transitions in the June 2002 draft. Recent research by several State departments of transportation and by the Transportation Research Board identified several high-performing products suitable for both new construction and alterations. Approximately 20 manufacturers now produce detectable warning products in metal, concrete, tile, pavers, resilient sheets, and membrane types. The FHWA is currently overseeing human factors research intended to test the contrast effectiveness of 13 different detectable warning colors when viewed by people who have low vision.

Comments from disability organizations and individuals were divided in much the same way as consumer comments on accessible pedestrian signals. Many expressed concern about cost but, valued detectable warnings as a way to provide a cue at certain locations such as pedestrian waiting areas at roadway medians, islands, and roundabout splitter islands and at low-slope blended transitions to street crossings. A majority of these commenters favored the June 2002 draft provision requiring detectable warnings at flush transitions between sidewalks and street crossings.

The rows of domes in the detectable warning material (technical provisions at R304.2.2) must be aligned with the path of wheelchair travel, which is required to be perpendicular to the grade break at the toe of the ramp to permit tracking between dome rows. On blended transitions, dome orientation is not significant.

A new advisory note (R304.1.1) covers the use of radial dome patterns.

Detectable warnings provisions in this draft have also been clarified with respect to their permitted setback from the grade break marking the face of a curb. One corner of the detectable warning must be within 205 mm (8 in) of the grade break; no other point on the leading edge of the detectable warning may be more than 1.5 m (5 ft) from the grade break (R304.2.1).

R222 Doors, Doorways, and Gates (technical provisions at R411). These provisions have been added to this draft from the ADA and ABA Accessibility Guidelines (2004). Because public sidewalks serve the entrances and other facilities of abutters covered by title III of the ADA, coordination of slope, cross slope, and maneuvering space requirements is typically required. In many places, developers provide sidewalk improvements as part of a project. State and local governments must include accessibility compliance in such work.