David S. Zelenok, P.E.
|October 28, 2002|
Re: Draft “Guidelines for Accessible Public Rights-of-Way”
Dear Access Board Members:
Thank you for the opportunity to comment on the proposed “Guidelines for Accessible Public Rights-of-Way”. The City of Colorado Springs is committed to providing pedestrian access to the greatest extent possible within the public right-of-way for all of our citizens. Many of the changes proposed with the new guidelines are necessary to provide citizens with disabilities acceptable access within the public right-of-way. However, there are several sections that may cause unintended negative consequences and should be modified.
After review of the proposed standards, the City of Colorado Springs Public Works Department wishes to provide the following comments/concerns:
1102.3 Alternate Circulation Path
The requirement for barriers with edge protection and railings is unclear and would be beyond the scope of many projects. The spirit of the requirement, to provide a clearly defined path for all to follow, could be accomplished with reflective barrels, tightly spaced cones and other means depending on the project size and duration.
1104.3.2 Detectable Warnings.(1108)
It is our position that truncated dome detectable warnings should not be required for curb ramps in the public right-of-way. Even with only the bottom 2’ of ramps proposed with truncated domes, we are still very concerned about the difficulty of removing snow and ice from the ramps. We see this potentially causing a very serious safety problem for pedestrians in the winter for communities that have snow and freezing temperatures, like Colorado Springs. We are also concerned with the constructability of the truncated dome surface, the additional costs that will be required per new ramp (and even more so if all existing ramps will need to be retrofitted), and finally the long term maintenance and durability of cast in place, pre-cast or stick-on truncated dome surfacing with snow removal operations.
The City of Colorado Springs has had an on going program for many years to install pedestrian ramps with all new street construction, with our annual Pedestrian Ramp Projects which construct curb ramps in existing streets and neighborhoods, with all Capital Improvement Projects, and with maintenance projects that repair or replace curb and/or sidewalks at street intersections. We have worked very hard with all stakeholders in our community and in particular with the various user groups to develop our pedestrian ramp standard.
We have developed our own detectable warning scoring pattering for our pedestrian ramp standard in Colorado Springs. We construct all our new pedestrian ramps with ½” wide x ½”deep scoring on the ramp surface at 9’’ on center perpendicular to the run of the ramp. We also construct all pedestrian ramps with concrete with a “Springs Brown” coloring admixture to provide visual contrast. Working with our local community, the ½” scoring at 9’’ on center was developed to provide tactile assistance to pedestrians who are blind, and the colored concrete standard was adopted to provide clearer identification of the ramp location for citizens with visual disabilities. The standard is well accepted by our community, from user groups with disabilities to the construction industry and developers. The colored concrete adds a cost increase over plain concrete, but the surface is easily constructed, durable, and does not pose any cold weather or other maintenance concerns.
If truncated domes are required, we foresee construction quality problems and maintenance/safety concerns. Also with the increased costs, we see a reduction in the number of ramps we will be able to construct each year, given our limited funding resources.
The cross slope requirement of 1:48 appears to be too restrictive for most of Colorado Springs’ streets given our foothills topography. Our current design standard provide for 4% at most new street intersections, with 6% allowed on minor residential streets in hillside areas. Also 6% is not uncommon on super-elevated roadway sections and even greater cross-slopes exist in some of our older existing neighborhoods. Allowable cross-slope of 4% to 6% would be more realistic for our typical grades and areas with topography similar to or steeper than Colorado Springs.
The specified running slope for crosswalks of 1:20 may also be too restrictive. Cross-slopes of 5% may be achievable on many new streets, but again superelevated and hillside roadways typically can have cross-slopes of 6% or more. Reconstruction/improvement projects in older neighborhoods or existing downtown areas where existing street crowns may be 8% to 10% would also be a problem. Exception should be included in the guidelines when the existing topography or improvements do not practically allow for the 5% maximum running slope.
1105.5 Pedestrian Overpasses and Underpasses
The consequences of having to install elevators at all locations with vertical rises of more than 60” will have a negative effect on many projects and may result in having LESS access than before for the community. Since most pedestrian overpasses are discretionary structures, many jurisdictions will forego the entire project rather than face the additional costs of constructing and maintaining an elevator. Certainly, elevators may be designed into some projects, and may indeed be desirable in some circumstances, but to require them for all rises over 60” would cause unintended negative consequences.
Roundabouts are generally not used in areas of high pedestrian traffic, and the installation of pedestrian activated signals at each leg could cause significant safety issues to both vehicular traffic and pedestrians. As in any unsignalized pedestrian crossing or mid-block crossing, engineering judgement and coordination with citizens, including those with disabilities would provide the best results. A roundabout located in a low traffic volume neighborhood may operate very safely with no pedestrian activated signals. There may be other locations and designs that call for signalized crossings, but to mandate them for every location is counterproductive.
1105.7 Turn Lanes at Intersections
A requirement to signalize slip lanes negates the very purpose of the free-flow lane and should not be mandated. By its design, with a traffic island provided, the distance a pedestrian must cross is already minimized, and pedestrians are faced with only a single travel lane to cross. Like roundabouts, slip lanes should be treated on a case by case basis. Communication with the community of users and engineering judgement should determine what devices provide the appropriate degree of safety.
1105.8 Accessible Pedestrian Signal Systems
Audible and vibrating indications for the walk phase of signals can be of value to some individuals with visual disabilities, but in many cases are not desired. The extra noisemakers hinder or distract many blind people who are trained to stop and listen to parallel and cross traffic to know when it is safe to cross the street. Problems still exist with the industry truly producing signals that adjust volumes to the ambient noise levels. Locations with recall pedestrian crossing phases (all signals in downtown Colorado Springs, and at many major corridor/side streets) will be subjected to 24 hours/day “chirping.” Audible and vibrating indications for the walk phase of signals should not be mandated, but like other traffic engineering features or devices should be at the discretion of the Traffic Engineering Department or controlling authority with communication from users and engineering judgement determining if they are warranted.
1107.6 Tables, Counters, and Benches
Currently all bus benches at bus shelters locations in Colorado Springs have a bench with armrests and the sites are ADA compliant with dimensions, slopes, wheel chair space, and accessible concrete pads. However, none of the benches at many other bus stops without shelters have benches with armrests. The new guidelines would require considerable expensive to replace some 700+ bus benches with new benches with armrests.
1102.14 On-Street Parking
Proposing one ADA space per each block face will significantly reduce the amount of available parking in an already tight market. In recent reconstruction of much of Colorado Springs downtown core, approximately one ADA space per two face blocks was constructed and is adequately serving our community’s needs with spaces often vacant or unused. In our older downtown, there are no streets that allow angled ADA parking due to slope restrictions, therefore, all ADA spaces must be parallel which replaces 2 to 3 regular spaces per block face. The proposed number would have a very large financial impact on our downtown businesses loosing some 300 public parking spaces, not to mention almost $300,000 per year lose in revenue to the Parking System, plus the cost of ramps, railings etc. Allocating on-street spaces in the same fashion as surface lots or parking garages would be more realistic. Also more flexibility needs to be provided in the proposed guidelines to locate ADA parking spaces where they are most needed, not just one per block face. Residential or commercial developments with adequate off street parking may not need any additional on street ADA parking spaces.
The original ADA guidelines had an exception clause for undue financial hardship. The requirement for on street ADA spaces should not mandate that spaces be installed by a certain date, but should require that they be added to the existing on street parking areas as reconstruction or new improvements are funded. With larger scope projects, needed ramp construction, pavement cross slope adjustments, and changes to curb lines can more easily be provided.
We are completely supportive of adequate ADA parking, however from experience, it appears that the number of parking spaces required is over estimated. For example, currently we have 22 ADA spaces in the City parking garage that most often go unused. We currently have a waiting list of over 75 people requesting a space in the garage. This has resulted in an annual loss of revenue totaling $13,200. At the proposed number, losses in metered on street parking revenues up to $300,000 per year would have a significant impact to City revenues. All of our recent downtown reconstruction and pedestrian improvements have been funded by the parking system funds. Lost parking revenues and adverse financial affects to downtown business owners are both major concerns.
The City of Colorado Springs has historically and will continue to support reasonable accommodations within the public right-of-way. The comments and suggestions should not be viewed as objections to the spirit of ADA. We support removing barriers and improving mobility and access for all. We hope the Access Board will use our comments to better understand some pit-falls, and in our opinion, some unintended consequences associated with several of the proposed standards. We trust that the final guidelines will reach a balance between economically feasible project costs and safety for all individuals.
David S. Zelenok, P.E.
Director of Public Works
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