October 22, 2002
County of Santa Cruz
RE: COMMENTS ON “DRAFT GUIDELINES ON ACCESSIBLE PUBLIC RIGHTS-OF-WAY”
Dear Members of the Board:
I am writing at the direction of the Santa Cruz County Board of Supervisors to
offer several comments on the Draft Guidelines on Accessible Public
Rights-of-Way regarding items that appear to need additional clarification.
Section 1102.14 requires that at least one accessible on-street parking space be
located on each block face. While this may be desirable in business or
commercial areas, it seems rather onerous in residential areas, particularly
areas of single family residences. Santa Cruz County is primarily rural in
nature and experiencing infill development in its more urban areas. A typical
new development might be a cul-de-sac with four or five homes and perhaps one to
three parking spaces on each side. A requirement to provide one accessible space
on each side would severely limit the amount of street parking available for
residents and guests. We would suggest that this section be revised to limit
this requirement to commercial and business areas, where there is an actual need
for accessible on-street parking.
Section 1105.7 requires that any intersection with slip turn lanes and
pedestrian crosswalks include pedestrian activated signals at each segment of
the crosswalk, including at the channelizing island. It appears that this
requirement as written would apply even if the intersection were not otherwise a
candidate for signalization for other traffic control reasons. We would suggest
that this section be revised to require signalization of the slip turn lanes
only if the main intersection is signalized.
It would also be helpful if the guidelines included a definition of the term
“Alteration,” and a discussion of the level of alteration that would require
compliance with the guidelines. There was a court decision that found that an
asphalt concrete street overlay would require that curb ramps be installed if
they did not already exist. Would the new guidelines require a public agency to
provide accessible on-street parking spaces when a street is repaved? Would an
overlay trigger the requirement to signalize any intersection with slip turn
We appreciate the opportunity to comment on the proposed regulations prior to
their finalization. Santa Cruz County has been very proactive in complying with
the Americans with Disabilities Act, and we welcome the formalization of the
requirements of the ADA as they apply to public rights-of-way.
Thank you for considering our comments.
Board of Supervisors