October 29, 2002
Due to untimely rain on the weekends of the last month and a hectic work
schedule with no room for much picture taking, I have several comments that do
warrant pictures, but have been unable to take these. I would be happy to do so
this Sunday, but realize that the technical date for comments will have been
(Note: I decided to go out tonight and try to capture some of the more
I would strongly encourage members of the Portland Summit to visit a city on the
opposite side of the country for insight into how these PROWAAC ADA Standards
are being enforced. I work for a Landscape Architecture firm in Nashville, TN.
By working on several public projects, I have been intimately involved in
discussions of accessibility in our town. Due to a legal ruling, Nashville has
been singled out as a "test market", it seems, for the PROWAAC. Many of the
standards that were placed into effect by the 1999 Guide: Accessible Public
Rights-of-Way Design Guide
are now being reversed. The city of Nashville is literally ripping up the corner
of every intersection and re-pouring it. Nearly every intersection now requires
a different analysis, approach, and maneuver by handicapped individuals. Because
of the now much more complicated use of these intersections by those who are
supposed to benefit, I feel that there needs to be more time to develop these
guidelines in a more cost-effective, practical and standardized way. There are
several issues concerns about intersections that I have with the PROWAAC as it
is being interpreted in Nashville today:
1. Every intersection is different. There is no standard. I mentioned this
before, but one cannot fathom how difficult it must be for blind people to
navigate these intersections. The trip-hazards alone are formidable to the
unwitting pedestrian. The formula appears to be to place a 4'x4' pad as close to
the road grade as possible. Then, tie this back into the existing grade around
the curve at the intersection, no matter the resulting grade. The problem here
is, there are no two crosswalk beginnings alike. One pad could be 1' from the
road, the other 5'. I have attached two pictures that I was able to take to
illustrate this point. (Example 1.jpg and Example
2.jpg) This intersection used to be fairly evenly pitched around the turn on
this side. The new ADA PROWAAC recommended solution was to cut this curved walk
out; I assume because the cross-slope was greater than 2%. The resulting ramp
between the upper side of the curve, and the lower was 16%. 16%! On the other
side of this intersection, the result was 13%. Both of these exceed the
acceptable slope on an accessible ramp. Are there any handrails? No! As a side
note, the area that used to be the paved sidewalk around the curve on
example2.jpg has now been grassed. This has resulted in major ruts by semis,
whom always seem to jump sharp curbs in the city. It is now one of the largest
rut/puddles I have seen.
2. There are now trip hazards for normal ambulatory pedestrians, and especially
for blind persons. Because of the associated catch basins at typical city
corners, trip hazards have been created by the new standards of the PROWAAC.
Also, seemingly in no particular manner, there are other instances where it
appears a curb was formed for lack of a better reason. In one particularly
hilarious instance, the walk was lowered at the corner, but a curb was formed to
the rear of the walk. (curb at back of walk.jpg) Kind of defeats the point,
3. Public health, safety, and welfare are in danger at instances where a new
crosswalk corner is constructed on the downhill side of a slope. Water now
gathers in the low places created by lack of a curb; I can't imagine how many
lawsuits are bound to occur from people slipping on icy puddles in the winter.
Additionally, some of these 4'x4' pads are so close to the Apex of the curb,
within 6" in some cases, that the protection of the pedestrian seems to been
have forgotten when designed for accessibility. Cars sharply cutting city
corners could potentially harm pedestrians waiting to cross the street.
4. Damage to private/public/historic properties. As you can see from some of the
pictures I have taken, there are walls that have been undermined to the point
that you can see the footing-to-wall rebar, or the soil underneath older curb
construction. Again, lawsuit is the only word that springs to mind.
I don't know if it is the enforcement of the PROWAAC that is causing all of this
confusion, or the PROWAAC itself, but I do know that more time is needed for
discussing the merits of the various proposed provisions and/or training those
enforcing those standards..
See attached photos.