R201 Application

R201.1 Scope. All newly designed and newly constructed facilities located in the public right-of-way shall comply with these requirements. All altered portions of existing facilities located in the public right-of-way shall comply with these requirements to the maximum extent feasible.

Advisory R201.1 Scope. This document (see R101.1General) covers facilities for pedestrian circulation and use in the right-of-way. Examples of facilities include, but are not limited to, walkways and sidewalks, street or highway shoulders where pedestrians are not prohibited, crosswalks, islands and medians, overpasses and underpasses, on-street parking spaces and loading zones, and equipment, signals, signs, street furniture, and other appurtenances provided for pedestrians. Examples of facilities not included are manholes and utility vaults.

These requirements are to be applied to all areas of a facility within the scope or limits of the planned project unless expressly exempted or limited with respect to the number of multiple elements required to be accessible. For example, not all benches are required to be accessible; those that are not required to be accessible are not required to comply with these requirements or to be served by a pedestrian access route.

R201.2 Temporary and Permanent Facilities. These requirements shall apply to temporary and permanent facilities.

Advisory R201.2 Temporary and Permanent Facilities. Temporary facilities covered by these requirements include, but are not limited to, temporary routes around work zones, portable toilets in the public right-of-way, sidewalk vending facilities, street fair booths, performance stages and reviewing stands, and the pedestrian access routes that serve them. As permitted in R203.1.1, structures and equipment directly associated with the actual processes of construction are not required to be accessible.

Elements are often placed on a sidewalk without coordination by different agencies or entities. The U.S. Department of Justice ADA regulations require that the usability of accessible features be maintained (28 CFR §35.133 and §36.211).

R201.3 Requirements for Buildings and Structures. Buildings, structures, and similar facilities constructed in the public right-of-way but not specified in this document shall comply with the applicable requirements in 36 CFR part 1191 (the ADA and ABA Accessibility Guidelines).

R201.3.1 Buildings and Structures Covered by the Americans with Disabilities Act. Buildings, structures, and similar facilities covered by the Americans with Disabilities Act (ADA) shall comply with Appendices B and D to 36 CFR part 1191 (the ADA and ABA Accessibility Guidelines).

R201.3.2 Buildings and Structures Covered by the Architectural Barriers Act. Buildings, structures, and similar facilities covered by the Architectural Barriers Act (ABA) shall comply with Appendices C and D to 36 CFR part 1191.

R202 Alterations and Additions to Existing Facilities

R202.1 General. Additions and alterations to existing facilities shall comply with R202.

Advisory R202.1 General. Alterations include, but are not limited to, renovation, rehabilitation, reconstruction, historic restoration, resurfacing of circulation paths or vehicular ways, or changes or rearrangement of structural parts or elements of a facility.

The U.S. Department of Justice Title II regulation at 28 CFR 35.151(e) requires that curb ramps be installed whenever pedestrian walkways on sidewalks and across streets are newly constructed or altered. A 1993 case, Kinney v. Yerusalim, 9 F.3d 1067 (3d Cir. 1993), cert. denied, 511 U.S. 1033 (1994), held that resurfacing of a street constitutes an alteration that requires the installation of curb ramps (for text see

Pavement patching and liquid-applied sealing, lane restriping, and short-term maintenance activities are not alterations.

R202.1.1 Transitional Segments. Transitional segments connecting to existing unaltered segments shall comply with R301 to the maximum extent feasible.

Advisory R202.1.1 Transitional Segments. It is often possible to construct transitional segments that blend between existing undisturbed facilities and newly-altered elements. This may permit the work of the alteration to more nearly meet the new construction standards. At a later time, when other walkway segments are altered, the non-complying transitional segments can be removed and replaced with complying work.

R202.1.2 Added Elements. Where elements are added and the circulation path is not altered, a pedestrian access route is not required.

Advisory R202.1.2 Added Elements. This provision does not eliminate the requirements specified for a particular element. For example, a bench that is installed on an existing sidewalk must have the necessary clearances and clear floor space specified in section 307. Where possible added elements should connect to an existing pedestrian access route.

R202.2 Additions. Each addition to an existing facility shall comply with the requirements for new construction. Where an existing pedestrian circulation path is extended, the extension shall contain a pedestrian access route complying with R301.

R202.3 Alterations. Where existing elements or spaces are altered, each altered element or space within the limits or scope of the project shall comply with the applicable requirements for new construction to the maximum extent feasible.

Advisory R202.3 Alterations. From the U.S. Department of Justice title III regulation at 28 CFR 36.402 Alterations: "The phrase ‘to the maximum extent feasible,’ … applies to the occasional case where the nature of an existing facility makes it virtually impossible to comply fully with applicable accessibility standards through a planned alteration. In these circumstances, the alteration shall provide the maximum physical accessibility feasible. Any altered features of the facility that can be made accessible shall be made accessible. If providing accessibility in conformance with this section to individuals with certain disabilities (e.g., those who use wheelchairs) would not be feasible, the facility shall be made accessible to persons with other types of disabilities (e.g., those who use crutches, those who have impaired vision or hearing, or those who have other impairments)."

Existing conditions (e.g., underlying terrain, right-of-way availability, underground structures, adjacent developed facilities, drainage, the presence of a notable natural or historic feature) may limit choices in an alterations project. In determining the maximum feasible accessibility that can be achieved for pedestrians with disabilities within a given alterations project, covered entities may consider constructability limits commensurate with those of the project as a whole.

There is no ‘path-of-travel’ obligation in these guidelines; covered entities shall apply the guidelines to achieve the maximum feasible accessibility within the limits of the planned project boundary or scope. However, the alteration of multiple elements or spaces within a facility may provide a cost-effective opportunity to make the entire facility, or a significant portion of it, accessible. When undertaking right-of-way alterations, jurisdictions should consult their transition plans to determine if related work has been identified as needed to achieve program accessibility in existing facilities at the same location.

Most rights-of-way work occurs as an alteration in a complex environment also regulated for vehicle operation and safety and subject to the well-established industry practice of applying ‘engineering judgment’. These techniques can also be used to evaluate the feasibility of accessibility solutions.

R202.3.1 Prohibited Reduction in Required Access. An alteration shall not decrease or have the effect of decreasing the accessibility of a facility or an accessible connection to an adjacent building or site below the requirements for new construction in effect at the time of the alteration.

Advisory R202.3.1 Prohibited Reduction in Access. Sidewalk improvements that correct existing excessive cross slope should be carefully planned to avoid the imposition of barriers elsewhere, as, for example, creating excessive slope in a curb ramp or adding a step at an existing building entrance. Solutions that have been successfully implemented include:

1)split sidewalks that serve entrances and roadway at separate levels;
2)sidewalk widths of greater cross slope at street edge, with a pedestrian access route
at lesser cross slope along building entrances;
3)a pedestrian access route along the curb, with ramped entrances along the shop

Where facilities are newly-constructed or altered along an existing sidewalk, it may not always be possible to provide the required level landing at an entrance or other feature required to be accessible without altering the sidewalk. Often, the jurisdiction will require the developer of a new or altered facility on a site served by the sidewalk to redesign and replace the public sidewalk as a part of the permit for construction. Careful coordination between public and private planning is the usual practice.

R202.3.2 Extent of Application. An alteration of an existing element, space, or area of a facility shall not impose a requirement for accessibility greater than required for new construction.

R202.3.3 Alterations to Qualified Historic Facilities. Where the State Historic Preservation Officer or Advisory Council on Historic Preservation determines that compliance with these requirements would threaten or destroy the historic significance of a qualified facility or element, compliance shall be required to the maximum extent that does not threaten or destroy the historic significance.

Advisory R202.3.3 Alterations to Qualified Historic Facilities. It is the element or facility subject to the alteration which must have historic significance. Furthermore, it must be determined that compliance with these requirements would threaten or destroy the historic significance, not merely alter the appearance.

R202.3.3.1 Historic District. Location of the facility or element within an historic district is not a sufficient condition for qualification as an historic facility.

Advisory R202.3.3.1 Historic District. Altered street crossings, sidewalks, and pedestrian facilities that are not historic but are merely located in historic areas must meet new construction requirements to the maximum extent feasible.

R202.3.3.2 Reproductions or Replications. Reproductions or replications of historic facilities shall not qualify as historic facilities.

R203 General Exceptions

R203.1 General. Facilities, sites, spaces, and elements are exempt from these requirements to the extent specified by R203.

R203.1.1 Construction Sites. Structures and sites directly associated with the actual processes of construction, including but not limited to, scaffolding, bridging, materials hoists, materials storage, portable toilet units provided for use exclusively by construction personnel, and construction trailers, shall not be required to comply with this part.

R203.1.2 Limited Access Spaces. Spaces accessed only by ladders, catwalks, crawl spaces, or very narrow passageways shall not be required to comply with this part.

R203.1.3 Machinery Spaces. Spaces or elements frequented only by service personnel for maintenance, repair, or occasional monitoring of equipment shall not be required to comply with this part. Machinery spaces include, but are not limited to, elevator pits or elevator penthouses; mechanical, electrical or communications equipment cabinets and vaults; electric substations and transformer vaults; and highway and tunnel utility facilities.

R203.1.4 Single Occupant Structures. Single occupant structures accessed only by passageways below grade or elevated above standard curb height, including but not limited to toll booths that are accessed only by underground tunnels, shall not be required to comply with this part.

R204 Pedestrian Access Route
Pedestrian circulation paths shall contain a pedestrian access route complying with R301 which connects to facilities, elements, and spaces required to be accessible by Chapter R2 and to accessible routes required to connect to public streets and sidewalks by section 206.2.1 of appendix B to 36 CFR part 1191 (the ADA and ABA Accessibility Guidelines) or section F206.2.1 of appendix C of 36 CFR 1191 (the ADA and ABA Accessibility Guidelines). Where a pedestrian circulation path is provided in the street, along a highway, or within a shoulder, it shall contain a pedestrian access route.

Advisory R204 Pedestrian Access Route. The pedestrian access route is a portion of the general pedestrian circulation path, which may include walkways, sidewalks, street crossings and crosswalks, and overpasses and underpasses, courtyards, elevators, platform lifts, stairs, ramps and landings. Where sidewalks are not provided, pedestrian circulation paths maybe provided in the street, highway, or shoulder unless pedestrian use is prohibited. This provision does not require a pedestrian access route if a pedestrian circulation path is not provided.

R205 Alternate Pedestrian Access Route
When an existing pedestrian access route is blocked by construction, alteration, maintenance, or other temporary conditions, an alternate pedestrian access route complying to the maximum extent feasible with R301, R302, and Section 6D.01 and 6D.02 of the MUTCD (incorporated by reference; see R104.2.1) shall be provided.

Advisory R205 Alternate Pedestrian Access Route. Same-side travel is preferred because it does not increase pedestrian exposure and risk of accident consequent upon added street crossings. A route that uses vehicle lane width may be shorter, safer, and more usable than one that requires two street crossings, even if the roadway surface is imperfect. Part 6D.01 of the MUTCD requires alternate routes to provide the best elements of accessibility provided in the pedestrian circulation route before its disruption.

R206 Pedestrian Crossings
Where a pedestrian street or rail track crossing is provided, it shall contain a pedestrian access route complying with R301 and the applicable provisions of R305. Where a pedestrian rail crossing is not contained within a street or highway, a detectable warning shall be provided in compliance with R304.

Advisory R206 Pedestrian Crossings. When tracks are located in a street or highway that has a pedestrian route, the detectable warnings at the curb ramps make a second set of detectable warnings at the rail unnecessary in most applications. When rail tracks are not associated with a street or highway, they must have detectable warnings across the pedestrian access route on either side.

R207 Curb Ramps and Blended Transitions
A curb ramp or blended transition complying with R303, or a combination of curb ramps and blended transitions, shall connect the pedestrian access route to each pedestrian street crossing within the width of each crosswalk.

R208 Accessible Pedestrian Signals (APS)
Where pedestrian signals are provided at pedestrian street crossings, they shall comply with R306.

R209 Protruding Objects
Protruding objects along or overhanging any portion of a pedestrian circulation path shall comply with R401 and shall not reduce the clear width required for pedestrian access routes.

Advisory R209 Protruding Objects. Banners, awnings, tree branches, and temporary street or highway signs may also be hazards if not placed or maintained properly.

R210 Pedestrian Signs

R210.1 General. Signs designed primarily for pedestrian use shall comply with R210.

R210.2 Bus Route Identification. Bus route identification signs shall comply with R409.5.1 through R409.5.4, and R409.5.7 and R409.5.8. In addition, to the maximum extent practicable, bus route identification signs shall comply with R409.5.5. Bus route identification signs located at bus shelters shall provide raised and braille characters complying with R409.2, and shall have rounded corners. Signs shall not be required to comply with R409.2 where audible signs are user- or proximity-actuated or are remotely transmitted to a portable receiver carried by an individual. Bus schedules, timetables and maps that are posted at the bus stop or bus shelter are not required to comply.

R210.3 Directional, Informational, and Warning Signs. Directional, informational, and warning signs shall comply with R409.5.

Advisory R210.3 Directional, Informational, and Warning Signs. This provision applies legibility criteria to text signs. Examples of covered signs include, but are not limited to, sidewalk closure and pedestrian detour signing required by MUTCD, tourist information signing, and pedestrian route signing along an historic trail. Standard highway street-name signage is not covered by this part.

Braille identification of street names is a required feature where APS are provided (see R306).

A proximity-,-user-, or button-activated audible sign can provide this information in audible formats for pedestrians who don’t read print. Such devices are now being manufactured for rights-of-way applications.

R211 Street Furniture
Street furniture intended for use by pedestrians and installed on or adjacent to a pedestrian circulation path shall comply with R307.

Advisory R211 Street Furniture. This scoping applies usability and operability criteria to certain items intended for pedestrian use in the public right-of-way. Where multiple items of a single type are provided at a single location, only a proportion may be required to be accessible and to be located on a pedestrian access route. Types of street furniture for which usability and operational criteria are provided include elements such as drinking fountains; public telephones; public toilet facilities; and tables, counters, and benches in R211; parking meters in R308.6; bus stops and shelters in R212; and signage, including bus stop signage, in R210. Where applicable, usability and operability provisions shall be satisfied in the design and construction of other items installed on or along a public right-of-way for pedestrian use (see sections R307, R401, and R405).

Some items intended for pedestrian use are installed on private property bounded by a public right-of-way and are intended for use from the right-of-way. Such items include wall-mounted ATMs, overnight mail kiosks, and walk-up service windows. Other items may be placed within a public sidewalk under the terms of a public space permit, such as the tables, chairs, and enclosures used by sidewalk cafes and restaurants or sidewalk vending carts and machines. The ADA and ABA Accessibility Guidelines cover these street furniture items, which should not be permitted to intrude on the required pedestrian access route or to violate protruding objects provisions.

Some street furniture, such as fire hydrants, signal control boxes, signal and sign poles, and overhead awnings and signs, is not intended for pedestrian operation. These and similar items shall not intrude on the required pedestrian access route or violate protruding objects provisions (see sections R301 and R401).

The location of bicycle racks on a public sidewalk should consider their footprint in use, since a bicycle carelessly fixed to a rack can become a barrier to accessible travel along a pedestrian access route or a protruding object along it.

Careful coordination is required between agencies and divisions authorized to install items on and along sidewalks in order to avoid inadvertent conditions that may constitute barriers. The U.S. Department of Justice ADA regulations require that the usability of accessible features be maintained (28 CFR §35.133 and §36.211).

R212 Bus Stops
Where provided, bus boarding and alighting areas shall comply with R410. Where provided, bus shelters shall comply with R410.2.

Advisory R212 Bus Stops. Where bus stops are marked along existing streets by the placement of signage, benches, or shelters, other features necessary to accessibility, such as surface improvements and curb ramps, will be subject to the program access requirements of the U.S. Department of Justice title II regulation at 28 CFR 35.151 or the U.S. Department of Transportation 504 regulation at 49 CFR Part 27. Transportation, public works, and transit agencies should consider including needed improvements in their transition plans and other program accessibility planning.

Furthermore, the placement of such items is subject to usability and protruding objects provisions that apply to street furniture. Bus stop benches and shelters shall not intrude into an existing pedestrian access route.

Signage required at bus stops is scoped at R210.2 Bus Route Identification.

R213 Stairways
Where provided on a pedestrian circulation path, stairways shall comply with R407. Stairways shall not be part of a pedestrian access route.

R214 Handrails
Where provided, handrails shall comply with R408.

Advisory R214 Handrails. It may not be feasible to install handrails with fully complying features on existing developed rights-of-way if the full horizontal handrail extension would narrow a required pedestrian access route or be a hazard to cross traffic. Handrail design should not constitute a protruding object (see R401).

R215 Vertical Access
Where provided, elevators, limited-use/limited-application elevators, and platform lifts shall comply with the applicable requirements in section 407, 408, and 410 of Appendix D to 36 CFR part 1191 (the ADA and ABA Accessibility Guidelines) and shall provide for independent operation. Vertical access shall remain unlocked during the operating hours of the facility served.

Advisory R215. Vertical Access. Elevators in public and private buildings accessible from the public right-of-way have been successfully used to provide low-effort routes between sidewalk levels in hilly terrain.

R216 On-Street Parking
Where on-street parking is marked or metered, accessible parking spaces complying with R308 shall be provided on the block perimeter in accordance with Table R216.

Advisory R216 On-Street Parking. Accessible on-street parking spaces are best located where the street has the least crown and grade and close to key destinations. Adjacent sidewalk space should be free of obstructions (including curb ramps) to permit deployment of a van side-lift.

Table R216 Accessible Parking Spaces

Total Number of Marked or Metered Parking Spaces on the Block Perimeter

Minimum Required Number of Accessible Parking Spaces

1 to 25


26 to 50


51 to 75


76 to 100


101 to 150


151 to 200


201 and over

4% of total

R217 Passenger Loading Zones
Where passenger loading zones are provided, a minimum of one passenger loading zone complying with R412 shall be provided in every continuous 30 m (100 ft) of loading zone space or fraction thereof.

R218 Call Boxes
Where provided, roadside call boxes shall comply with R309.

R219 Transit Platforms
Where provided, transit platforms shall comply with R414.

R220 Escalators
Where provided, escalators shall comply with sections and of ASME A17.1 (incorporated by reference; see 104.2.2).

R221 Detectable Warning Surfaces
Detectable warning surfaces shall comply with R304.

Advisory R221 Detectable Warning Surfaces. Detectable warning surfaces are required where curb ramps, blended transitions, or landings provide a flush pedestrian connection to the street. Sidewalk crossings of residential driveways should not generally be provided with detectable warnings, since the pedestrian right-of-way continues across most driveway aprons and overuse of detectable warning surfaces should be avoided in the interests of message clarity. However, where commercial driveways are provided with traffic control devices or otherwise are permitted to operate like public streets, detectable warnings should be provided at the junction between the pedestrian route and the street.

R222 Doors, Doorways, and Gates
Where provided, doors, doorways, and gates shall comply with R411.