Hello and welcome to the ADA Distance Learning Series hosted by your regional Disability and Business Technical Assistance Center. Today we are going to talk about access to public rights of way and the proposed accessibility guidelines for these areas. Joining us is Lois Thibault of the U.S. Access Board. Hi Lois.
Hi Jennifer. Great to be with you again.
Thank you. Lois is one of our back by popular demand presenters. She joined us a couple years ago on common errors and omissions in new construction. We are very excited to have you back. Lois incidentally has spent the last one or two years now as the Access Board liaison to a national advisory committee tasked with developing accessibility guidelines for public rights of way. This spring the Access Board published the draft guidelines and Lois is going to give us some of the highlights. Lois I will turn it over to you and we will open it up for questions and answers from our audience.
Thanks, Jennifer. I guess the best place to start is with a general description of what the public right of way is and why it is different enough from other things that we regulate under and ADA to need its own separate set of accessibility guidelines. We look at the public right of way as those strips of land that connect pedestrians and vehicles through roadways, usually in municipality or a town. But it also could be a right of way along a river, along a transportation track, say a railway, it could be along a major highway. The idea of right of way is that the public, the local jurisdiction, has control over it. And the land is not really bought or sold in the way that sites where buildings are constructed are dealt with, but is provided as a service to the residents and taxpayers of a particular jurisdiction. Because the right of way is constrained in a lot of ways, perhaps, by underlying slope, by narrowness, width, something that is already developed along it, which kind of fixes its edges, and because it is linear as opposed to constrained on four sides like a site is, it conceivably could go on almost forever, or at least until you get to the boundaries of a jurisdiction. So it has very different characteristics and those characteristics tend to act to limit the possibilities, what you can do to make the right of way accessible. For our purposes at the Access Board we have looked at the right of way as being sidewalks, street crossings and the related pedestrian facilities that the sidewalk may support, benches and things like that, perhaps telephones, drinking fountains and so on. We started looking at rights of way issues back in 1992. Right after the board finished its work on developing guidelines under Title III of the ADA. Guidelines for buildings and facilities covered by Title III. Title III facilities and also some Title II facilities, say state and local government buildings, for instance, are all built on sites, very little is actually constructed in the public right of way. So you have on a site a stopping and a starting place, you can require an accessible route that goes from the boundary of the site to the accessible entrance. That is what the ADA accessibility guidelines were developed to describe, those accessibility requirements that provided a usable building or facility on a site. When the ADA was passed, and the Access Board was given responsibility to develop guidelines that covered entities could use to measure whether they were meeting the intent of the ADA, most of our focus was on making sure that the guidelines we developed would guarantee an accessible building or a facility. And we reserved the access issues for the public right of way until later after we had gotten the ADAAG under our belts. But we always intended to do it and we used it, the development of ADAAG as an opportunity to think about rights of way issues before starting it in 1992. Now, the ADA requires that all new construction, regardless of where it is, public right of way, on a site, even in some cases on passenger vessels, and in places that we are just now also getting around to regulating, be constructed, designed and constructed to be accessible. When they are new and if they are being altered they also have to be accessible to the maximum extent feasible. The guidelines that we developed are measures of how that is done. You can follow the guidelines and be confident that if you build according to them that you have met the requirements under the ADA for accessible design and construction. Of course there are many other ADA requirements, this is actually just a fairly limited one. So from the beginning, people who were designing and constructing in the public right of way if a downtown was having a downtown improvement project, if a city was newly laying out roadways for a commercial center, all of those things were covered by the ADA. But what they did not have was a recipe, if you will, for how to design and construct them so that they would be accessible. In these circumstances, where there are not guidelines specific to a particular kind of use, the Justice Department, the enforcing agency, has said look to what is already out there in terms of guidelines, look to the ADA accessibility guidelines, perhaps to the Uniform Federal Accessibility Standards (UFAS) or even a state or local guideline of equivalent usability, and apply those guidelines and standards as best you can to the situation that you are facing. In many places that works fairly well. But the public right of way is so different from a route or a walkway on a site, that it clearly demanded a special set of provisions. A really good example, I think, is in some places, Seattle, Pittsburgh, San Francisco, if you applied the ADAAG requirements for an accessible route you would have to make ramps with landings and handrails out of all your sidewalks. We knew that we did not want to do that. That would fundamentally alter what sidewalks were constructed for, which was to provide for pedestrian transportation at the edge of a roadway. So that was one of the first issues that we addressed in 1992 when we began our work on developing guidelines for public rights of way. In December of that year we proposed some draft guidelines for public rights of way that eventually in 1994 became an interim final rule. Because this was a fairly new issue for people who do the design and construction work in the public right of way, these proposed guidelines aroused a great deal of both comment and concern. It has only been recently that highway engineers who are responsible for the design of our roadways have become much sensitized to the needs of pedestrians and pedestrians with disabilities were particularly low on their list. So there was a substantial learning curve needed in order to bring transportation industry designers to an understanding of the basic rationale behind accessibility provisions. And to help them understand what they needed to do to their standard procedures and planning methods to make sure that their new sidewalks and related facilities and the work that they did in alterations would meet the needs of pedestrians with disabilities. The Access Board in 1994 after the interim final rule was published embarked on a fairly comprehensive outreach program to the highway industry . We developed manuals, a videotape, several technical assistance bulletins, we did some syntheses on key issues like detectable warnings and accessible pedestrian signals all in an attempt to reach industry with the information they needed to design for accessibility. Much of this information I think has been posted in advance of this program and it is all with one exception, available on our web site directly for download. The videotape you would need to call us, specially to order but copies are available free if you are interested, just so dial up our toll free number 800-872-2253 and ask for one of the technical assistance staff to send you a copy of the videotape. In 1998 the Access Board decided that it would reserve the rights of way proposals that had been published as an interim final rule in 1994. The Justice Department had not taken any action on any of the four sections that had been published in 1994 and by then the board had started on a revision, a very substantial revision, to its basic ADAAG document and we wanted to fold in several of those recently proposed sections into this major rule making. So we chose to reserve the sections on housing and public rights of way and in essence begin our rule making again feeling that by this time the industry would have come to a better understanding of accessibility requirements and would be both more sympathetic and more helpful in comment to what we were proposing. So, we started by convening the public rights of way access advisory committee, which was the largest of the federal advisory committees that we have ever worked with. We now do most of our rule making through this consensus process bringing together stakeholders from industry, from consumer groups, from state and local governments and the private sector, manufacturers, operators, and so on, in what usually is a one or two-year effort to look at key issues, make recommendations to the board, and from those recommendations then encourage the board to develop more broadly consensual standards. Working through a advisory committee has a lot of benefits for us because it helps us to identify areas of particular concern, issues that may be specific to a field, an industry, that the Access Board may not be fully familiar with. We are then able to understand industry regulations, practices and requirements and accommodate them in a way that makes for a more well rounded and balanced proposal. The rights of way committee included 12 from the transportation industry, about that number representing organizations of consumers. For instance, we had the American Council of the Blind and the National Federation of the Blind and also AAR which is the organization that represents orientation and mobility specialists. We had representation from Seeing Eye in New Jersey, from a number of state and local governments, from the Department of Justice and the Federal Highway Administration, and several state and local transportation and public works agencies, we had ADA coordinators from cities and states, we had private sector consultants, transportation and traffic engineers, and architects, landscape architects, planners, it was a huge group. Overall about 55 members, 33 of them full members and 22 alternates. In addition, we worked to keep our meetings both informational and we met around the country. We often conducted on the street exercises, that looked at local conditions and considered specific sidewalk and street crossing problems. We did this in Portland, Oregon and Atlanta and San Antonio. And tried to involve not only just the membership of the committee and the alternates, but local engineers and disability advocates. Overall several hundred people were involved in the meetings and presentations and information gathering. This committee, that we call it PROWAC, was I think one of the most collegial that we have ever had at the Access Board. In fact they are still working on our behalf, developing a technical assistance manual that we will issue when we publish our notice of proposed rule making to help engineers understand how to apply the proposed guidelines to alterations which is largely what happens in the public right of way. There is very little actual new construction in the public right of way. Well, sometimes, you know, a new town is established or a new commercial center, but much of the construction that occur in the public right of way is a reworking of what is already there: street widening or narrowing, a change in you know the design of a downtown or several city blocks. All of those situations, which we would consider alterations, require engineers to have a high degree of understanding of the rationale behind accessibility because it is impossible unless you are doing a fairly wholesale reconstruction to achieve the full range of new construction requirements in most alterations. You will encounter underground drainage of vaults, a building wall that is in a location that prohibits widening, there is a conflict between the needs of vehicular and pedestrian circulation, there is safety issues, transportation practice issues, and so most engineers when they are working in the public right of way, are making engineering judgments about what can be achieved when you are trying to drop in a curb ramp at a specific location and you cannot achieve all of the requirements that you could if you had total control as you would in new construction. So you may have to sacrifice a little bit on cross slope, there may be a width issue, you may have to think of a different way of achieving access between the sidewalk and the street because there is not enough width to put in a standard curb ramp. These are all critical issues that engineers are dealing with more of the time than they are dealing with new construction. The rights of way committee has spent the last year developing a technical assistance manual that we hope will be published about mid-year in 2003. Partial funding for the manual is coming from the Federal Highway Administration, which has been our partner in this rule making. And it is being produced under the direction of the Institute of Transportation Engineers, which is the major membership organization for highway engineers in the U.S. particularly urban engineering and public agency staff. That document should be ready about mid-year, which is when we hope that we will be able to go on to the next step in rule making and the two will be companion publications. The document that I am going to generally describe today is actually a preliminary document. It is a draft, not yet an official notice of proposed rule making, and it was published in order to assist the rights of way committee in developing the technical assistance manual they are working on and to obtain preliminary industry and public input to some of the changes that we have proposed. The publication that the PROWAC committee delivered to the Access Board in January 2001, their recommendations for an accessible public right of way were presented to the Transportation Research Board. And then once the board became familiar with them, we began our staff work on a regulatory document that would reflect their regulations. For a number of reasons, the membership of the board, the interests of the board, staff concerns, and issues, even politics is involved, the board''s proposals differ somewhat from the recommendations of the rights of way committee and in a few key areas, particularly with respect to the width of the passageway that is required to be accessible in a public sidewalk. And so we wanted to give good notice of these changes before we actually began the official rule making process and make sure that everybody understood. Those of us who do rule making every day, get very frazzled with the details and we are very comfortable with phrases like proposed and guidelines and standards and notices, proposed rule making and things like that, but we find that we often confuse the public with all of these terms. And the public does not understand the difference between a guideline which is what the Access Board produces, and a standard, which is what the Justice Department produces. With respect to the standards under the ADA, they are one and the same document. For the most part, the Justice Department has simply adopted our guidelines into the standards that they publish under the ADA. But that will nott always be the case. And in fact, we have now produced at the board many more guidelines than the Justice Department has incorporated into their standards. So we have sections on judicial facilities, correctional facilities, children''s elements, some changes to Title II issues, generally. And upcoming very soon, the final rule for recreation, it has just been approved by the office of management and budget. So those are all going to be guidelines but not yet standards. And we will be adding the public rights of way guidelines to that list, we hope, sometime next year or possibly the following year. But first, we want to take public comments and maybe either the temperature or the pulse of the transportation industry to make sure that we are all on the same page, that industry finds our proposals doable, and that people with disabilities who are the pedestrians who use these facilities will find them usable. So, we are going through that preliminary process now. It will culminate in a public meeting, an all day public meeting in Portland, Oregon on October 8th, where our board will meet and listen to public comment. We are doing it in Portland because both the chair of the public rights of way access advisory committee and the editor of the committee''s recommendations to the board are Portland residents. One Jerry Marcusino, the supervising engineer for the Transportation Department in Portland, who was our chair, and the other Ellen Vander slice, who edited very ably and under a tight deadline, the recommendations of the committee to produce the committee''s report. So when we are in Portland we are going to be able to recognize their contributions. So this is very much a, we think, a consensus document. We have heard because it has been out on the streets since June 17th, that there remains some concerns on the part of traffic and transportation engineers. Some of those I think are probably misunderstandings others are in areas where we have proposed a requirement but asked a number of questions in our discussion and commentary material about ways to achieve certain objectives that would meet more nearly with industry practices. A very key issue really for the ten years that this rule making has been in process is the distinction between new construction and alterations. This is, of course, a fairly arbitrary thing. And with respect to buildings and facilities and in our own rule making efforts, at the Access Board we have one understanding of it. But the transportation industry has its own set of practices and terminology and so on. And there has been confusion, I think, since the very beginning of the process of developing the guidelines about what we meant by new construction. The advisory committee I think said it best. It means a cornfield in Kansas that is being newly turned into a public right of way. Where you have lots of control over how wide the right of way might be, how much of it will be roadway, how much sidewalk, where you can carefully manage running slope, cross slope, and all of those other issues. Most other work as I have indicated earlier, is going to be work that would be considered alterations. When industry engineers read our earlier proposals, they came to believe, though, this was not an accurate understanding, that if the guideline was adopted that they would then have to improve all of their existing streetscapes, sidewalks, crosswalks and so on to the standards that we were proposing for new construction. And we have had a difficult time explaining ourselves to industry helping them understand that when they do an alteration, obviously the new work that gets put in place whether it is a curb ramp or a segment of a sidewalk, must as best it can, meet the new construction standards, just as an alteration to a building must attempt first to meet the new construction standards, but that there are lots of situations of technical infeasibility that may preclude the full achievement of the new construction standards. And when those situations are encountered, then the engineer needs to make judgments about what must be sacrificed, if you will, in order to achieve a usable product that is the best that can be achieved under the conditions in which they are working. I think we are finally starting to make progress in this area, and that engineers understand a little bit more these issues, but much remains, I think, to be explained. The fact that the ADA unlike a building code, also requires public agencies and private sector entities to actively retrofit, whether it is under program access or barrier removal, is also a problem because those things get conflated in the minds of engineers and it is not easy to discriminate what is a program access improvement required just to make sure that someone with a disability is not precluded from using a facility and what might be new construction and alteration, so we are working hard on commentary and we are doing a lot of training going to industry events and so on, to make this a bit clearer. Let me just list the key issues that we have identified and I guess I will start with the first issue, which is one of width. The Access Board''s proposal says that every new sidewalk and altered sidewalks to the maximum extent feasible, should contain what we call a pedestrian access route, it is like an accessible route but it is not as stringent. That pedestrian access route should be 48 inches wide. The advisory committee recommended 60 inches, we looked at common practice in sidewalk design and in a number of different places while industry is certainly transitioning to something wider, 60 inches is recommended, we felt that we could be more comfortable right now at 48 inches. Other issues detectable warnings which is both a hot issue currently because the temporary suspension of detectable warnings in ADAAG has expired and the Federal Highway Administration has let its customers know its state and local government agencies they expect to see detectable warnings on curb ramps. We have proposed a new technical standard on detectable warnings, still composed of truncated domes, but a shorter width of them only two feet, the same 24 inches that is required still on platforms at transit. Set this surface back about six inches from the curb line on the curb ramp for the blended transition ask then orient the domes in a grid pattern as opposed to the offset pattern that we first called for, so that wheelchair users can track between them. This is a compromise that was worked out between disability organizations and we and the Federal Highway Administration are encouraging agencies that now are installing detectable warnings on curb ramps to use the new specification as a they say an equivalent facilitation. Accessible pedestrian signals, typically audible and vibro-tactile. When new signals are installed, pedestrian signals, they should include a visible and audible and a vibro-tactile component, any place that pedestrian signals are installed. We have newly suggested requirements for alternate circulation paths at construction projects that affect sidewalks and other pedestrian routes and will require where feasible, same side temporary routes. We have suggested that walking speeds are set too high in industry documents and need to be reduced to about three feet per second when industry calculates how much time needs to be allotted for a signal cycle, etc. We have seen that a lot of agencies seem to be dealing with this by installing technologies that allow them to see with either microwave or video or infrared technology if there is a pedestrian still in a crosswalk at the end of a signal cycle and then to just extend the vehicle red until the pedestrian clears, so this is certainly one way of achieving that goal. The other highly controversial issue is roundabouts, which are no stop or continuous passage round circulatory intersections where traffic yields to traffic in the circle, but basically is not required to stop if there is a gap that they can occupy. Roundabouts are very efficient movers of traffic, and are being welcomed by traffic engineers as a way of relieving congestion. So we are seeing more and more of them put in, particularly in some states where they have been adding them in great numbers, Maryland, the northwest. They have proved to provide confusing cues to pedestrians with vision impairments and we are working hard to develop some standards for roundabout design that will provide the cues that blind pedestrians need to recognize and safely cross in a gap at roundabouts, but we are a long way from having good solutions. In the interim, in the draft proposal, on the advice of the advisory committee we have proposed that roundabouts have signal control, whether it is a signal that a pedestrian can activate and is not operating most of the time but only when a particular pedestrian needs it. We have not determined that yet and we are really looking to industry to give us advice on what may be feasible in the various kinds of roundabouts that there are. We are also working very closely with industry groups to coordinate their development of a pedestrian guide so that we are all talking about the same thing and to harmonize the regulations that each of us propose. Once we have finished analyzing public comment and all the other comment that we receive on this draft, we will move forward with preparation of a notice of proposed rule making which will have more extensive commentary than the current version does and which we will be able to incorporate many of the suggestions we hope to get from the public, from industry, on some of these issues that may be still somewhat controversial. So look for that document in the spring of 2003 with the usual rule making process, then to follow. I think that is about it. In fact I think I have used perhaps more time than I ought to have. Jennifer?
If there are questions I would be happy to answer the ones that I can and then if not, maybe we can talk a little bit about our research program for next year, too.
We would be happy to put you on the hot seat. Let us talk a little bit before we open it up to questions, about access routes. And I think this is a really good point to make, especially with some of the new rules that the Access Board is going to be coming out with, that you are going to see the word access route but not in its traditional use. The public rights of way committee has new term called pedestrian access route. In the outdoor areas you will see one for an outdoor recreation access route or a trail. There is also another one for a beach access route. And when I think about access route, I think about the maximum grade cannot exceed 1 and 20, or 1 in 12 where it has a ramp, and one of the big misperceptions when this advisory committee first convened was people were thinking oh, public rights of way, we are going to have to flatten them all in order to make them accessible. Could you talk about how the draft addresses pedestrian access routes and specifically the running slope?
Sure. We saw that the how closely the running slope of a sidewalk had to be tied to the roadway slope and felt that this was an area where we had to relax the requirements of the accessible route in order not to really, as you observe, sort of change the face of U.S. towns and cities. It is not feasible to flatten things out, although we would certainly like to see a bit more flatness, particularly at intersections. And so the committee in one of its earliest decisions said yes, the pedestrian access route can take the slope of underlying terrain or the adjacent roadway that it is essentially attached to and that that slope does not have to be treated as a ramp with level landings for every 30 inches of rise, with handrails on both sides, and so on. That it was simply going to be developed relative to the development of the roadway and we called that a pedestrian access route because obviously it is not an accessible route, some may be quite steep and there is in fact no limitation except the limitation on roadway steepness, for a pedestrian access route. And a pedestrian access route is not a sidewalk, it is a width and a height actually, it has volume, within a sidewalk. Many sidewalks in urban areas in big cities will be 20 feet wide. The requirement for a pedestrian access route is that it be four feet wide within the width of that sidewalk. And that it connect with other accessible features, curb ramps, street crossings, building entrances, anything else of a pedestrian nature that might be on the sidewalk.
Good, thanks Lois.
Yes, hello. I have a question about reduced vibration zone. Has the investigating group come up with a measurable technical specification tool or any guidelines on that?
Well, actually we floundered on that. This was a recommendation of the advisory committee that did not get into the draft, for exactly the reason that you have identified. The difficulty, well, the absence of a standard of measurement. There are standards for roadway smoothness and we are working now with the Federal Highway Administration to develop both a tool, something perhaps like a walking profiler or something, and a protocol that can say eliminate split face granite cobbles and maybe some extreme forms of impressed concrete, or things like that, but still permit brick, well laid brick sidewalks and things like that. I would imagine that that is going to take us a few years and it may be the next iteration of ADAAG before we get to that point. It is something that we are going to encourage and we are going to work toward but it is not in the draft proposal.
I was wondering, you were talking about how there is a lot of stuff being done like buses and a lot of railway stuff being done for people with handicaps. A lot of stuff is like being done for people with handicaps, and I was just wondering, I have been living in Memphis most of my life, and well, like I grew up with a lot of people with disabilities and stuff, and I actually have not seen a lot of stuff being done here because no offense, but like a lot of people who have disabilities and handicaps, they are kind of shunned upon, and kinds of ignored and stuff. And I was just wondering how is Memphis going to be affected?
Well, when Memphis engineers do a new project, they need to look to either current or propose ed guidelines, actually since 1990 or 1991 when the first guidelines came out, they have needed to make sure that all of their newly constructed work was accessible according to some measure, which might have been ADAAG, it might have been UFAS , it might have been the ANSI.A117 standard if they have not been working on that for ten years they want to go back and look at some things. What we are doing now is simply refining or clarifying what accessibility in the public right of way is. Everybody is already required to make things accessible. And we are just trying to tie how to do that to the specific problems that you see in the public right of way. So it really should not change very much, and in some cases it may be a relief to engineers. In other cases where people have not been building according to an accessibility standard, it may be a surprise. But we really are not changing very much, just documenting it a bit better.
Hi. This is Chris. Hi Lois. A couple questions. I notice there is a diagram that shows a detectable warning at a curb ramp that is in front of an access aisle. I wonder is that something that is current now or is that something that is going to be in proposed and that was one. And the other one had to with the 48 inch minimum, you know how it is over here in Hawaii we do not just have a lot of space. How does that work for existing conditions?
Well, exactly. Let me take the second one first. We wrestled with this both in the advisory committee and at the staff level. What we have produced is a guideline that we think of as sort of a gold standard, it is what you need to aim at. But we understand that you are not always going to be able to achieve it in an alteration. It is virtually impossible, we believe, and believe me we tried it, to develop an alteration standard that will cover every combination of circumstances that might be encountered in the public right of way where you can control for cross slope but not for width but you have this or you have that. We believe that it was more important to give engineers both the objective and then an understanding of the rationale behind the accessibility requirements. That is what the committee is working on now, a manual. And allow those decisions to be made in the field. Sometimes width is going to be sacrificed and you are going to get a sidewalk that is no more than 36 inches wide. Other times depending on the scope of the project that you are doing, somebody may be able to install a bulb out and add extra width in some places. So those are decisions that engineers who are in place and understand all of the other factors that have to be balanced, are best qualified to make if they understand the access issues. That is our objective, is to provide them both with an objective to aim at and the education and technical assistance they need then to make good decisions in balancing those factors. As far as detectable warnings go, the temporary suspension that was in place for six years or so, expired last year in July, more than a year ago. So the requirement is now once again in force in ADAAG so we are seeing lots more installations of detectable warnings. We are encouraging the use of detectable warnings according to the new specifications and expect to see them in the public right of way and for the short term at least, on sites any time you have got a location where the sidewalk and the the interface is ramped or blended.
So the access aisle is considered street?
The access aisle may be a street, yes. I think there are locations where an access aisle may occupy a circulation route. The access aisle issue if you are talking about a curb ramp that goes to an access aisle in a parking lot I think is a very special case. In most instances may not require a detectable warning on a site. Those of you who have looked at the detectable warnings issue may know that the proposal of the ... in the revised ADAAG that will be coming out will not have a requirement for detectable warnings on any work on site, since they will ultimately as things go forward as we currently anticipate, detectable warnings will be a product required in the public right of way. At transit platform edges and where sidewalks cross streets, essentially, where the danger is greatest.
Good, thanks for your question, Chris. Lois, let us talk about on street parking.
I see there is a new definition of what an accessible on street parking parking space actually looks like. You cannot actually just put up a sign that says accessible parking, we have to have an access aisle now?
Well, you may just put up a sign. If you are working in an existing developed environment, that may be what the accessible space is, a sign. Where you have got wide sidewalks and you have the ability to provide an access aisle, we expect that it will be provided again in new construction. Those are fairly rare occurrences, sometimes a downtown is, you know, streetscape is rebuilt and we would expect to see accessible spaces. Typically they will be at the head or foot of a block where you can use the curb ramp that is at the intersection. The access aisle may be indented into the sidewalk if there is adequate width in big developed urban areas. In many cases it may be just the balance of a curb lane sufficient width to open your door and exit your car.
Good. What about parking meters? Is that going to be covered?
Parking meters are a item that requires operation. So we have some reach range and operation issues there. We are also seeing a lot of sort of new mainly European technologies now where you put some money in a device and get a little slip that you put on the dashboard of your car, so all of those mechanisms will have to be accessible within reach ranges and so on.
Hi. My name is Judith, I actually have three questions. Has there been another design guide since the one that was put out in 1999?
No. But we are working on it. The advisory committee is working on a design guide specifically for alterations
I mean the one you are talking about in existence right now
Yes, that is the only one right now. The Federal Highway Administration has a design guide also, called "Designing Accessible Sidewalks and Trails" in two volumes which is very useful, too.
Okay. And is there any proposals in the new guidelines for extended block parking? I gather that I cannot remember offhand, but in the existing proposed guidelines, you are proposing at least one space per block.
If the block is three blocks long, we have been trying to recommend that they put several curb side parking areas along that block but the argument that we are getting is there are no crosswalks so we do not need to have accessible parking. Between the two corners which are three blocks apart
Block sizes vary enormously in the U.S. And some pedestrian friendly cities like Portland you have very short block, 200 people in Portland are saying gosh that is a big inventory of accessible spaces and other cities you go for a considerable distance. I think cities will have to arrive at their own understanding of what the a block face is. This was a tough issue for the advisory committee to develop a common standard that would apply. I think if there are very long blocks with spaces at the head and foot on both sides would be very appropriate. But it may require more definition in a locality that does not have a standard way of... that we would understand as a block.
Like maybe ten per mile or something like that?
Uh-huh, yes. That is certainly a possibility. One of the things we found in working in the right of way is how very many different ways cities are designed and built. How many different kinds of curb ramps there are and parking arrangements and so on. And it has been very difficult to feel that we have even got a small handle on all of the things that might need to be covered. So I do not think that we have necessarily done it, you know, perfectly or well even, yet, and that might be a really good subject for comment to this draft proposal.
My name is Pam. I just have a question about the crosswalk situation where it is three foot per second and then you said you said if the person is still in the crosswalk they would be delayed? That they would be delayed. How is that... is that technology that would let the driver to know to wait or signs saying yield to pedestrians? We are in a situation where people are in crosswalks, they are in the middle and drivers are not seeing them and almost hitting them. You know, they are turning, pedestrians are going the same direction as the traffic, pedestrians and traffic are going parallel. But when they make a turn, they would be turning into the path of the pedestrians. And it is a really dangerous situation and we are trying to work with it, but I do not know if that is something that is going to be mandated? Am I understanding you correctly about the delay to traffic?
Well, what I was describing was technology that is in place in some cities that can actually extend the time that there is a red light for vehicles if there is still is a person in the crosswalk. That is done with infrared or video technology, there is a lot of ways that it can be done. It would be one of the ways of satisfying the demand that we are expressing in our guideline that the crossing time be extended because many pedestrians do not walk at the four feet per second that the timing is based on now. Things have changed enormously in the U.S. in the last ten or 15 years, pedestrians and cars are fighting for the same time and space, this has had a particularly difficult effect on pedestrians with vision impairments, and we are trying to adjust the balance a little bit to return some safety to being a pedestrian and to making sure that people with disabilities are not inequitably affected by some of those things that have changed, right turn on red, for instance, roundabouts, and things like that. But this is a process that we are not driving. The whole issue of pedestrianism I think is a bigger issue than accessibility and we are aligning ourselves with pedestrian interests, but a lot needs to be done still to bring transportation engineers to an understanding that this is space that needs to be safely shared by a number of users, bicyclists as well, this is a start to the process. We welcome, you know, comments about this issue particularly there are other people in the transportation industry who are working on these issues also which are not strictly speaking, disability issues.
Which are four way stops rejected? Four way stops to traffic for pedestrians to go all the way around?
They have not been rejected, no. I think there are a lot of different ways of satisfying this particular need. And that is one of the reasons that we have put this proposal out, you can think of it perhaps as a start or a baby proposal where we are trying to both suggest what the issues are. Identify some possible ways of dealing with them and then asking for public recommendations and input on the kinds of situations that they are facing, what the issues are, so that when we go to the next step in our rule making, when we develop our notice of proposed rule making, while we will have more comprehensive answers, maybe a wider range of answers for different situations and so on. This is really a very preliminary notice that we have put out and we are looking for answers as much as anything else.
Thanks for your question. Lois we are coming up at the top of our hour and unfortunately we could probably talk about pedestrian access routes and public rights of way all day long but we have to come to a close. I think you make a really good point even though this is a draft, people are still able to comment on it right now; is that right?
Absolutely. Until the end of October they can comment to us by mail, by e-mail, by fax, the directions are actually right on our web site where the draft is posted. www.access-board.gov.
Thanks very much for joining us today, Lois, we appreciate you taking time out of your busy schedule before you leave on vacation.
Thank you for your hospitality.
Thank you to all of our sites for joining us today, we were excited you were able to spend this afternoon with us and hope you will join us next month on September 17 when we talk about accommodations for students with psychiatric disabilities in the classroom. As a reminder the transcript for this session will be posted to the Great Lakes web site next week on www.ADAgreatlakes.org. And in the event that you have questions about the ADA or upcoming sessions, please call your regional Disability and Business Technical Assistance Center at 800-949-4232.
Or the Access Board at 800-872-2253.
Very good. Thanks Lois and thanks to all of you for joining us today.