|October 2, 2002|
Please find the attached word documents with concerns from Douglas County, Colorado, and a copy of the letter from the City of Pueblo, Colo., because we agree with Mr. Centa's concerns. Thank you for your work on these proposed guidelines.
Douglas County, Colorado
Douglas County, Colorado
DEPARTMENT OF PUBLIC WORKS
Ms. Lisa M. Fontana
Technical Projects Senior Dir.
September 30, 2002
SUBJECT: DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY
Thank you for the opportunity and timely notification requesting comments on these proposed guidelines. After reviewing the proposed standards, Douglas County Public Works has several concerns regarding the significant unintended consequences, and the devastating impact on our annual maintenance and repair budget, if these standards are made into law.
After reading the letter to Scott Windley (U.S. Access Board) from Daniel E. Centa with the City of Pueblo, Colorado (copy attached), we strongly agree with and support Mr. Centa's concerns, and would like to add some of our own:
First, as discussed in Mr. Centa's letter, Douglas County is firmly committed to providing pedestrian accommodations within our Public right-of-ways whenever physically and financially possible, which includes accommodating people with disabilities as well. However, some of these proposed standards will end up costing the County so much more money than originally planned, that many improvement projects may be canceled because of these proposed ADA requirements. For example, if we're doing curb/gutter/sidewalk R&R (remove and replace) in an old residential subdivision and we remove broken concrete at a curb return and install a handicap ramp at that corner (where the streets were built before the requirement to have HC ramps), the County would also have to remove the curb-return across the street (so there would be an HC ramp on both sides of the street) even though the curb-return is not broken. In fact, the County would have to put HC ramps at all 4 corners of the intersection (whether the curb/gutter/sidewalk needs replaced or not). In other words, multiply the original cost by four.
1) In the Defined Terms, the definition of Pedestrian Access Route does not address trails which are not ADA accessible. In Douglas County, many County roads are built in areas of such steep topography that we end up with gravel trails which meander in and out of the Public right-of-way (ROW), and in some cases, are intended to be bicycle trails shared with pedestrians and joggers. Does this definition mean that all pedestrian "Access Routes" within the Public ROW must be ADA accessible?
2) The Definition of "Sidewalk" means that the curb-head (which is 6" wide on vertical curb & gutter) is considered part of the sidewalk, as well as any landscaping back of the walk but within the public ROW.
3) In the definition of "Walk Interval", we request that the last part of this sentence be revised to state ".....or the walking person symbol and its audible equivalent if equipped".
4) In Section 1102.2.2 Alterations, the term "technically infeasible" seems extremely nebulous. We must assume that term also includes financially infeasible, because many of the requirements stated in these proposed guidelines will end up costing Douglas County much more money to retrofit ADA facilities into existing (built before ADA requirements) streets.
5) In Section 1103.3 Clear Width, it is unclear if this is a "setback" from the edge of the sidewalk, or if this is supposed to be a 48" "clear path" for the sidewalk. Also, this section also says that the 48" dimension is "exclusive of the width of the curb", which is contrary to the definition "Sidewalk" (see above comment #2).
6) In Section 1104, this section states in more than one place, the cross slope of a curb ramp or a Landing cannot exceed 1:48 (2%). This means that if we have a major through street that is 4% running slope (longitudinal grade) that is crossed by a crosswalk at a minor street, the County would have to rip out the intersection, plus about 200-300 feet in both directions, to flatten out the intersection so the crosswalk won't exceed 1:48 cross slope. This requirement is unrealistic, and financially unattainable by small local governments.
7) In Section 1104.2.3, please define "Blended Transitions".
8) In Section 1104.3.4 Grade Breaks, this section says "Grade breaks shall not be permitted on curb ramps". How can you build a curb ramp without grade breaks? Maybe this is a difference in how we define grade break. Most Engineers call a grade break as the point on the sidewalk where you go from the natural slope of the sidewalk to the 1:12 slope down to the flowline of the street. Maybe if the definition of grade break were provided, we wouldn't have this concern. If our definitions are the same, and your intent is to eliminate these grade breaks by putting in a short vertical curve, this requirement is also unrealistic.
9) Section 1104.3.5 Changes in Level, please define. If this means a step, like in a stairway, isn't that already an ADA requirement?
10) Section 1105 talks about the Ped Crossings. We must express the same concern as mentioned in comment #6 above about the 1:48 max. cross slope.
11) Section 1105.3 Pedestrian Signal Phase Timing, the new proposed 3.0 ft./sec. speed for a pedestrian is reasonable in some locations, and unrealistic in others. Douglas County is on the edge of the urban Denver area (one of the fastest growing County's in the US over the last 10 years), and as such, some of our traffic signals have sidewalk on one side of the street and a cow pasture on the other side (without sidewalks). This requirement would be reasonable at an intersection close to Denver General Hospital, where a large number of the pedestrians might be handicapped, but at the intersection referred to above, there would never be a handicapped person trying to cross the street, because the trail leading up to the street is too steep, has an excessive cross slope, is 1/2 mile from the nearest parking lot, and is made with gravel/rocks.
This 3.0 ft/sec speed will also put the County into the situation of requiring a wider right-of-way for public streets with 4 or more lanes, because we will always need a 6' median. Right now, we're lucky if we can get a 4' median (so our signs posted in the median won't get whacked by our snow removal equipment). This means the developers will have to give up a wider right-of-way (good luck!), or the County will have to pay for additional right-of-way (and condemn if necessary) where we're improving an existing road. We suggest that these requirements be made on a case by case basis, or make the speed 3.0 fps where possible, and 4.0 fps max.
12) In Section 1105.6.2 Roundabout Signals, the purpose of a roundabout is to eliminate the need for a traffic signal. What this guideline will do is eliminate most proposed roundabouts, and any existing roundabouts will be taken out and replaced with a traffic signal. The Roundabout design publications we've seen all have the same opinion about pedestrians, "Keep pedestrians as far away from a roundabout as possible".
13) Section 1105.7 Turn Lanes at Intersections, this requirement would basically eliminate all slip lanes and right-in/right-out driveways, because of the cost. We respectfully request that sections 1105.6 and 1105.7 be revised to be installed on a case-by-case basis, to respond to community needs.
14) Section 1106.2 Pedestrian Signal Devices, requires "...audible and vibrotactile indication of the WALK interval". This requirement would be prohibitively expensive and unrealistic. We recommend this section be revised to be revised to be installed on a case-by-case basis, to respond to community needs.
15) Section 1106.2.1 Location is very confusing, and we're not sure where the Ped signal devices should be installed. Also, most times we are limited to one or two places we can place a signal pole at a corner because of buried utilities, so this would add more cost to a project if we have to relocate underground utilities.
16) Section 1126.96.36.199 Volume requires the ped signal device to be responsive to ambient noise level changes. At some point, the pedestrian signal device will be more expensive to install and maintain than the traffic signal for cars and trucks. This requirement is unreasonable and cost prohibitive.
17) Section 1106.4 Optional Features, since this is an "optional" feature, Douglas County will probably not be able to afford programmable pedestrian pushbuttons.
18) Section 1106.4 Directional Information and Signs, which requires "tactile and visual signs on the face of the device" with the street names is unrealistic, cost prohibitive, and redundant since the MUTCD requires street name signs with larger fonts.
19) Section 1108.1 requires truncated domes be placed as detectable warnings. The County snow removal equipment will remove anything like this located within the public street. Also, many sidewalks and trails in Douglas County are maintained (snow removal) with pickups with snowplows, which will also remove the domes. This requirements would be cost prohibitive to install and maintain.
20) Section 1109.2 Parallel Parking Spaces. Please see the concerns expressed in Mr. Centa's letter.
21) Section 1111 Alternative Circulation Path requires an alternate circulation path "on the same side of the street". Most of the time, this requirement will not be physically possible without the County having to condemn additional right-of-way (or temporary easement) for the alternate path. This requirement would be achievable in some cases and we recommend this section be revised to..." recommend the alternate circulation path on the same side of the street be installed on a case-by-case basis, whenever possible".
Douglas County would like to reiterate our sincere desire to accommodate handicapped pedestrians whenever possible. However, there are some cases where, if we are required by law to add cost prohibitive improvements when we do simple repairs to a public street, we won't fix the street in a timely manor and end up postponing the repairs until we can afford to add the ADA improvements proposed in these Guidelines.
If you have any questions, or would like to discuss this letter, please feel free to contact me.
Ron Coontz, P.E., P.L.S.
Daniel E. Centa, PE, City of Pueblo
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