David T. Harden
October 25, 2002
CITY OF DELRAY BEACH
RE: Draft Guidelines for Accessible Public Rights-of-Way
The City of Delray Beach, Florida, has reviewed the Draft Guidelines for
Accessible Public Rights-of-Way being proposed by the Architectural and
Transportation Barriers Compliance Board and has the following
Sec. 1102.14, 1109 — Requiring one ADA accessible space per block face doesn’t
seem practical for smaller municipalities which have five (5) to eight (8)
spaces per block. In many instances, this would require 20% of the public
parking spaces designated as handicapped accessible. This percentage is
excessive when compared to the requirements in parking lots and garages which
starts at four percent (4%) and reduces to two percent (2%) for capacities
between 501 and 1000 spaces.
Sec. 1109.2 — The suggestion of the “bump-in” for parallel parking spaces with
the thought that users needing access from the drivers side would park in the
spaces against the curb assumes that drivers would be able to easily complete
that maneuver. Realistically, on a two-lane roadway, the vehicle would have to
impede traffic flow of the adjacent lane to achieve a great enough angle to use
the space as suggested. Exiting the space would create similar hazards. To
accommodate such a design would require the elimination of additional on-street
Sec. 1109.3 — Required dimensions in the state of Florida currently exceed the
national standard of an eight foot (8’) space with a five foot (5’) access panel
by mandating the parking space to be twelve feet (12’) wide with a five foot
(5’) access panel (17’). The proposal to have all on-street perpendicular or
angled parking spaces to be van accessible requiring a 96” access panel (eight
(8’), would result in twenty foot (20’) wide spaces. Current Florida
accessibility requirements exceed the proposed national standard by one foot
(I). Perhaps the proposal should be reevaluated to provide a minimum width which
would keep the state of Florida and others which might mirror Florida’s
guidelines, in compliance. A suggestion would to allow alternative designs which
accommodate a total width of 17’ with a minimum access panel of 5’.
Sec. 1109.5 — Prohibiting any obstructions for the entire length of sidewalk
adjacent to an accessible parallel space seems unreasonable. Determining a
reasonably sized area, perhaps ten feet (10’) at the center of the space, would
accommodate the entering and exiting of vehicles while allowing for streetscape
elements to remain or be installed. The primary concern would remain the
unobstructed access to the pedestrian or walking system.
Sec. 1105.2 — It seems unlikely that the widening of crosswalks to eight feet
(8) to provide the physically challenged ample ability to get across streets
would be as effective as the suggestion of the Board which is addressed in
section 1105.3. It would seem that the adjustment of the pedestrian signal phase
timing to a rate of 2.5 to 3 feet per second would create a safer more
pedestrian friendly environment. Additionally, increasing the width of the
crosswalk might require the relocation of streetscape elements along with the
widening of existing curb ramps which might prove cost prohibitive to some
In closing, the City of Delray Beach, Florida has a large senior and physically
challenged population and is cognizant of the day-to-day challenges they face.
Although not mandated, the City has installed numerous ADA accessible spaces
throughout the downtown area (on-street parking and public parking lots) and
continually monitors and addresses the needs of the community. I believe most
municipalities share this philosophy.
Please take these comments and suggestions into consideration while realizing
the impact on smaller municipalities that will be created through the adoption
of these proposals as currently drafted.
Feel free to contact me at 561-243-7015 if I may be of any further assistance.
David T. Harden