Public Rights of Way: What are the rules?

Operator

Good day. Ladies and gentlemen, thank you for standing by and welcome to the "Public Rights of Way: What are the Rules?" conference call. At this time all participants are in listen only mode. Later we will conduct questions and answers. Instructions will be given at that time. If you should require assistance during the call please press the star then 0. I would now like to turn the conference over to your host, Mr. Peter Berg. So you may begin.

Peter Berg

Thank you very much and that you all for holding on. We had some technical difficulties at the top of the hour so I apologize and thank you all for waiting for us. Welcome again today to the ADA Audio Conference series, which is a project of the National Network of Regional ADA centers, also known as Disability Business Technical Assistance Centers or DBTACs. You may contact the regional ADA center that serves your state by dialing 1-800-949-4232. We have participants joining us today via telephone, audio streaming, and realtime captioning. As the operator mentioned today’s session is being record and an audio archive as well as a text transcript will be posted to the ADA Audio conference website approximately 10 to 14 business days from today''s session. Today''s session begins a two part series on state and local governments. Today we will be looking at public rights of way and the unique design, design areas when it comes to public rights of way. The ADA standards for accessible design were created to address accessibility to facilities in the built environment and the U.S. Access Board recognized early on that there was a need for specific rules to address the unique features of public rights of way. Today we are very fortunate and very pleased to have with us, to have Lois Thibault with the U.S. Access Board. She is the Coordinator of Research for the Access Board. Lois is a licensed architect who joined the Access Board in 1992 to head up their training activities. In 1998 she became responsible for program research. She also assists in the Access Board''s rule making processes as well as conducting training and providing technical assistance for public and private entities. A couple of the research areas that Lois is currently working on include public rights of way and classroom acoustics. Lois in 1999 produced a document authored the document "Accessible Rights of Way" which looked at the design guidelines for sidewalks and other public rights of way features so we are fortunate to have with us today Lois. She is going to go through her presentation and following her presentation we will have a question and answer period. So without further ado I will turn it over to Lois. Welcome, Lois.

Lois Thibault

Thank you, Peter. I am really interested to do this today, it is the first teleconference I have participated in and I am delighted to be doing the training from a very comfy seat in a hotel room in Portland, Oregon, not my usual base in Washington, DC. But I am here attending meeting of the Acoustical Society of America conference and some rule making that we hope to set out soon on classroom acoustics. So that will be later this afternoon. Just a warning to all of you listeners out there I have a program of 144 slides. We will never get through them all. I have put a little stop at 100 slides where we are going to ask for questions and hope that you look at the rest of the offering perhaps at a later time. The additional slides are mostly good examples of rights of way design that will sort of enhance this initial presentation. On your screen right now is the modern logo of the Access Board replacing the old eagle with arrowheads. We used to have just an indicator that we are a Federal Agency, the United States Access Board. Next. My name, Lois Thibault and as Peter said the Coordinator for the Research for the Access Board and one of three members of the public rights of way team at the Access Board. I will show you pictures at the end of Scott Windley and Dennis Cannon who are the other two, and it is really Scott who makes things happen in public rights of way. Next. We are an independent federal agency, essentially charged to develop accessibility guidelines under a range of laws. Our finished work includes ADA accessible guidelines for buildings and facilities, work on standards for transportation vehicles, telecommunication guidelines, and guidelines for electronic and information technology. Several new guidelines are in development and the photo on this page shows our 10th floor offices in downtown Washington, D.C. Next. The Access Board is the federal government''s accessibility specialist. Our mandate includes four major responsibilities, rule making, which is what we call the process of developing guidelines and there is a page from the federal register on the left of your screen. Technical assistance and training, much as I am doing now and a photo of Earlene Sesker, one of our experienced Spanish speaking trainers. And then on the right some research in wheel mobility that is being done at State Univeristy of New York at Buffalo. Our last next please. Our last responsibility is enforcement of federal facility accessibility. We don''t have any enforcement responsibilities under the ADA, under the Rehab Act, but under the Architectural Barriers Act we do. And here are some photos of our key staff members. We have architects and engineers and specialists in recreation, historic preservation, and on the left with the halo is Marsha Mazz , who over sees all of our technical assistance and rule making. Paul Beatty who does vessels, if you have got a question about vessels, why Paul is the one to send it to. Peggy Greenwell who wears two hats, both recreation and outdoor accessibility specialty, but also she is our training coordinator and there with the sheriff star is Scott Windley who heads up our rights of way effort and on the right Dennis Cannon who is our transit specialist and if you look on our website you can get not only all of our e mail addresses but also our telephone numbers. Next. In the works and, that is what I am going to talk to you about today some guidelines that are coming up in development and that would be public rights of way. We are at a second draft published in 2005 of that document but we also have live candidates in passenger vessels and outdoor recreation and transit vehicle guidelines that are being updated. So some photos on the bottom of all of those activities, from public rights of way, to vessels, to outdoor trails, picnic areas and then access to transit vehicles. Next. Just a title page, Public Rights of Way Accessibility, we sometimes call it PROW and you will hear us talk about PROWAG which is all about pro accessibility guidelines, PROAAC which is the PROW Accessibility Advisory Committee that helped us develop the guidelines, and then sometimes we say we need to be proactive. Slide 9, next, the public right of way and this is from a historic postcard of I think it is North Hampton, Massachusetts, near where I grew up. Just an illustration of what the public right of way is. It is essentially a network of common space that is reserved for community mobility, not just for cars but also for pedestrians and cyclists and transit. Next. Everyone under common law has a right to use of the public right of way regardless of your mode. And this is an English postcard you can see a double-decker bus, a vehicle, a gentlemen on a bicycle and pedestrian if there are no facilities for your mode then you will probably be using the roadway. Next. Just to look at the history of public rights of way rule making, back when I started at the Access Board in 1992 it was my first assignment. We got a proposed rule, Section 14 and in 1994 we got as far as interim final rule but in 1998 that section, Section 14 was reserved and we concentrated on some outreach because it was clear that particularly the implementers, state and local governments and the highway agencies had a lot of misconceptions and misunderstandings about what civil rights law would require, among them the idea that they would have to level all of their current facilities and tills and provide all new. So we spent some time developing videos and publications that tended to set their minds at ease. In 1999 we did an advisory meeting that had quite a number of stakeholders in it from state and federal government, contractors and consultants and state and federal agencies as well as disability advocates and in 2001 they published a series of recommendations in a report called "Building a True Community" and that is available on our website if you want to look at it. And in 2002 the Access Board rights of way staff took that committee report and turned it into a, the first draft of Public Rights of Way Accessibility Guidelines. Next. I am on slide 12 just in case we are off a little bit. And here is some, a slide that just takes a look at some of the key issues and comments, interestingly of the 1400 comments we got a lot. Quite a lot. Only 300 came from the highway community but almost 800 were submitted by people identifying themselves as having blindness or low vision. So a lot of the comments were focused on detectible warnings and accessible pedestrian signals. In 2005 we made and then published a new draft to show generally the changes that we had made in response to industry and disability comment and in order to help develop a cost benefit analysis that is always required when you do a regulation. We didn''t ask for any comments in 2005. We will ask for comments in our next step which will be a notice of proposed rule making but I will get to that later. Next slide. We are currently working with industry organizations to develop that cost/benefit assessment. We hope to have the required regulatory assessment done this summer. The office of management and budget will review it. Then we will publish it with a notice of proposed rule making sometime late in 2009. We will have a good period of public comment, probably three months. And then we hope to have a final rule by late 2010. Since it has had a couple of publications already we think that we are pretty close to a final version. The next slide, number 14, is a series of questions that Peter Berg pulled together that will be addressed during the balance of this presentation. And I have numbered them with a little star. So every time I have got a slide that comes up and one of the questions is raised why you will see it on the screen. Next slide. Again just a heading slide, Accessibility Regulation and because the public right of way is a very different animal than say work on sites, buildings and facilities on sites it is necessary to talk not only about the guidelines and standards but about the regulations that stand behind it. Because the standards are perhaps of less importance in the overall picture of what is required than are the regulations and the provisions in Title II of the ADA and under the Rehab Act as well although I will gloss that a little bit. So I am going to talk right now, so don''t let your eyes glaze over about the regulatory background. Next slide. Here is just a little legal outline. Laws are something Congress does. When they pass a law they assign responsibility for developing regulations to an appropriate federal agency. The three laws that we have rights of way provisions under are the Architectural Barriers Act, for instance, the national highway system, any federal lands. The mall in Washington, D.C. is a federal land governed by the Architectural Barriers Act, ADA, Section 504, federal aid construction. So transit, the federal highway''s program of subsidizing, sidewalk and street construction everywhere and then the Americans with Disabilities Act of 1990, the ADA which covers state and local governments generally. Next slide. From laws to regulations to standards the implementing regulations are what do the work, the heavy lifting under Title II of the ADA. They establish and identify all of the requirements, the anti discrimination requirements. They provide by reference standards for new construction and alterations and that is what we do or work towards and then also assign compliance and enforcement responsibility. So it is the regulations and not the standards that you need to look to for what is required in the first instance in the public right of way. Next slide. Title II of the ADA is implementing regulation. It has two parts. On the left, DOJ''s Subtitle A covering state and local governments generally which includes, pedestrian facilities, sidewalks, street crossings and related facilities. And DOT''s Subtitle B which covers transportation facilities and systems. That is a historic photo I think there of Dennis Cannon at a transit fare gate. Next slide. So here is the language of ADA Title II, Subtitle A, Department of Justice regulation, "No qualified individual can be excluded from participation and/or denied the benefits of" and that is the overall application of the ADA with respect to public rights of way and other covered facilities. Next slide. And this is Subtitle B which says essentially the same thing, no one may be denied the opportunity to use a transportation service, and that is subtitle B, the DOT rule. Next slide. Here is a view of the Justice Department''s ADA home page. So you can see that it has the regulation. It has some links to legal documents. It has obviously the Title II technical assistance manual. Title II is different from Title III in that the regulation itself includes only the preamble the commentary and the rule and regulation, it doesn''t have a standard in it as Title III does, but it does say in Title II that either of two design and construction standards would be deemed to comply. That is you don''t have to use them, but if you do you would be deemed to be in compliance. So those standards are the old UFAS way back in 1984 which was also the 504 standard and the 1991 ADAAG, but it also goes on to say other methods are permitted and this is quite different, excuse me, from Title III. Next slide. Here are some of the provisions in Title II where our work is in the 35.151, new construction and alterations and 151(c), especially accessibility standards, but look at everything else that is in there, general prohibitions which is where you need to find the modify your practices. Maintenance of accessible features, making sure that snow or something else doesn''t block an individual''s access to either a facility or a program. What to do about existing facilities, most of us call that program accessibility. Your requirements for a transition plan and particularly for a curb ramp transition plan. And down at the bottom effective communication. Next slide, so just a little recap here. Regulations set the requirements and there are four principal obligations that affect the public right of way and the first one is the most powerful from our point of view. New construction and alterations must be accessible to people and useable by people with disabilities, cost is no consideration. That is true now and has been since 1991 and in fact goes right back to the model of Section 504. New construction must be accessible to and useable by people with disability. Below that line the responsibilities are in the regulation, not you know measured by the standard. So existing facilities and programs must achieve program accessibility. People with disabilities must be accommodated where reasonable and necessary for access and steps must be taken to ensure effective communication. So those are the Title II requirements. Next slide. Program accessibility, most of us are familiar with this and it has policy, operational, design and construction and many other considerations. The photo on the left, policy about the use of adapted segways as mobility devices. Perhaps a change in a practice to provide extra time for a crossing. Or perhaps an accommodation in the form of an accessible pedestrian signal at an intersection. And in the right, this gentleman who uses a scooter had asked for the community to change its policy on parking. So that his vehicle could be located close to his home. So all of those are program access issues that aren''t addressed in guidelines and standards but by the regulations. Next slide. Just a little illustration of other obligations, principally the need outlined in Title II to develop a curb ramp transition plan and to implement it. So identify the work that needs to be done and schedule that work. And one of the things that we always encourage at the Access Board is to make sure that when you are doing a project in your community or when someone else is doing a project in your community that they always look back to the transition plans and the curb transition plan to see if there is work that could be included in an otherwise planned project. Next slide. And I am on 26. And here is the Title II discussion about what we call accommodations but they call modifications in policies, practices or procedures when necessary to avoid discrimination on the basis of disability. And the next slide is an illustration of exactly that requirement, modification in a policy. This is a snowy street in Concord, New Hampshire, and the young woman on the left is a high school student and her parents asked to have a stop sign installed at a crossing she uses and there isn''t a warrant for a stop sign, in highway industry regulations at such a location, but after some discussion the city agreed that they would try the provision of a stop sign at this location so that her crossing might be safer. So, that is a perfect example of an accommodation under Title II in an example drawn from the public right of way. Slide 28, a little aside on maintenance and versus maintaining accessible features. Maintenance is a phrase that is often used in the highway industry to talks about things like resurfacing roadways and so on. But when maintained is used in Title II, it means keeping a facility, that is accessible that you have already provided it means keeping it available and open to use. Next slide. And here are some examples of situations where that maintenance is needed. Where it is where a truck is blocking a sidewalk, where trash cans are blocking a sidewalk, where there is a basketball net fully blocking a sidewalk, where a jurisdiction has permitted the newspaper vending machines to partially block a sidewalk and where snow might make it difficult for someone to reach a program or a facility. Next. Here is a statement from the federal highway administration who are charged by the Justice Department to help implement Title II in the public right of way and this memo says part of this maintenance obligation includes snow removal. So for those of you who have had questions about does snow need to be removed, what the federal highway administration says is yes, you need to have a policy and a practice for making sure that snow gets removed from your public sidewalks. Next. Communications, a public entity shall take appropriate steps to ensure that communications are as effective and here is the first star, one of our list of questions, No. 3, and Peter''s question was "At intersections that have pedestrian signals that display the remaining time before the light changes will that information need to be audible?" The APS requirements in the public rights of way accessibility guidelines do not require the countdown information be provided in an accessible format. It may be that some forms of accessible pedestrian audible outputs, for instance, a fast tick that decays as time goes on can be used to convey that information. But it is not required in or won''t be required in PROWAG.

Peter Berg

Lois, do you want to explain what APS is?

Lois Thibault

I am sorry, APS is our shorthand for Accessible Pedestrian Signal. Accessible in the sense that they not only provide visible walk and don''t walk information, but they also provide an audible prompt that the walk sign is on and they provide a vibrotactile signal that can be palmed if you will and vibrates when its, when the pedestrian walk is activated. There are some devices, some APS devices that actually do provide a voice count down, although it isn''t required or won''t be required. Slide 32, here are some things that we would hope that rights, public rights works agencies will consider about effective communications. Making sure that public meetings are produced in accessible formats. That the information is available about changes to the public right of way. And that there is outreach to everyone, not just the folks who might read the notice in the newspaper. Next. So what about these requirements under Title II? I want to talk just a minute before we get into PROWAG about how you know when you have satisfied those requirements. For a newly constructed facility the Justice Departments says a high degree of convenient access. For altered facilities the justice department says accessible to and useable by people with disabilities to the maximum extent feasible. That is you can take in to account perhaps some existing features that make it difficult to achieve a high degree of convenient access as you would be expected to do in new construction. For programs, services and benefits, that program access idea, it is a slightly lesser standard. Those programs must be available but not necessarily every one would need to be accessible. And accommodations are on a different page all together. They must be reasonable both for the individual requesting it and for the provider, the public works agency that is going to be accommodating the individual. So quite separate from standards. Next. So here is the new construction provision in Title II. Each facility constructed by on behalf of or for the use of a public entity shall be designed and constructed in such manner that the facility or part is readily accessible to and useable by individuals with disabilities and here is a reference back to question No. 1 on Peter''s list, "What type of work will trigger the requirement to comply with the public rights of way accessibility guidelines?" Well, when they are finalized as standards, any new construction but right now the answer is exactly the same because the requirement has been in place since 1991. All new construction shall be accessible to and useable by people with disabilities. What is different now, there isn''t a an adopted standard but you still have if you are a public works agency the requirement to comply to make it readily accessible to and useable by people with disabilities. Slide 35, a high degree of convenient access, and this shows essentially brand new work, a new curb ramp, ah where are the detectible warnings? In a completely new development, everything is new. So it is quite easy to plan, to comply fully with design standards. Alterations, next slide. Each facility altered by, on behalf of or for the use of a public entity shall to the maximum extent feasible be altered so that it is readily accessibly to and useable by individuals with disabilities. Again this is a current obligation. So question No. 8 on Peter''s list "Are there exceptions for the minimum width of a sidewalk where existing conditions won''t allow full compliance with the guidelines?" Indeed, and here it is, to the maximum extent feasible. So you may take note of the existing features of say a downtown or a neighborhood and the implementing regulations say do the best you can with what you have got to work with but you will do the best job if you understand what the rationale behind many of the provisions is. But it is essentially a requirement to do the best you can with each individual provision. Next slide. Alterations, there is this additional piece of the Title II regulation that says when you construct or alter a street, a road, a highway or a pedestrian walkway you must include curb ramps in the scope of your work. So any time a roadway or a sidewalk is newly placed or changed, it needs to have those curb ramps. Next slide and I am on 38. What does maximum extent feasible mean? And this is language directly from the justice preamble. The occasional case where the nature makes it of the existing facility makes it virtually impossible to comply fully with applicable standards and it goes on to say provide the maximum physical accessibility that is feasible. So that isn''t exactly an exception but it puts the onus on the provider to squeeze out the most accessibility they can from the situation at hand. Slide 39, what is an alteration, and an alteration is something that changes the usability of something. So if you are altering the sidewalk or the street, you must include curb ramps if there are pedestrian facilities in those locations. But some projects are so small and on the left you see a situation where some workers are simply replacing small flags in a much bigger sidewalk. Not much you can do about access there except provide a roll-able surface. But if as in the middle photo you are providing, you are resurfacing a street then that is considered an alteration, and there was a court to that effect and of this of course if you are reconstructing like the folks in the photo on the right that is very much akin to full new construction. Next slide. Just a title slide and now we are finally to the point of talking about standards. We are going to focus on standards for new construction and alterations which is our principal work at the Access Board, and then just to leave you with a reminder that DOJ and DOT oversee the program access issues that we have just discussed. Next slide, 42, and here is what Title II says, "Design, construction or alteration of facilities in conformance with UFAS or with ADAAG shall be deemed to comply. So if you use them we will say you are complying. And then it goes on to say departures from particular requirements, for instance, you might use PROWAG, the draft PROWAG, shall be permitted when clearly evident that equivalent access is provided. So, Title II even in its provision setting standards that you might use encourages the use of other methods. And this is the Title II equivalent for Subtitle B standards for accessible transportation facilities. Many of you know that the Department of Transportation for its transportation facility responsibilities under Subtitle B of Title II have already adopted the Access Board''s new ADAAG 2004 as their standard under Title II of the ADA. So this would apply to transportation facility stations and bus stops and things of that sort. So they are already using the 2004 ADAAG that hasn''t yet been adopted for other parts of Title II and then here is one of the provisions that the Department of Transportation actually added to their adoption of ADAAG. They added detectible warnings back in to curb ramp provision. And so there is an answer to question No. 9, "What is going on with detectible warnings in this rule?" Well, the PROWAG will include provisions for detectible and the DOT rule has added them back in because they are missing from ADAAG 2004 because of the shift from ADAAG to PROWAG for the public right of way. Slide 45, a little side discussion about guidelines and standards. When the Access Board develops them they are called guidelines. Another agency has to act in order to make them in to standards. So for Title II Subtitle A that is the Department of Justice. They haven''t finished yet but for Title II Subtitle B DOT they have completed their work. Now I want to talk a bit about how do you measure compliance? That goes back to the issue of the standards that have been set as a measure of compliance under Title II. And that is exactly what the standards are. They are not in and of themselves requirements. They are simply a way that you can use to measure whether you have complied with making construction accessible to and useable by people with disabilities. So a measure, a safe harbor, I call them often a recipe for accessibility but not the requirements themselves. If you use them, you will be deemed to be in compliance, but if the standards or the guidelines don''t include something and there are many things that the current standards don''t include you are then on your own to figure out what makes them accessible to and useable by people with disabilities. So standards are a kind of relief for practitioners and for agencies because they mean that instead of making those decisions and gathering that evidence on your own you can rely on the standard. Slide 47, a little review of accessibility standards. A gold standard for new construction, you should be able to meet every provision. The goal for alterations, certainly to the maximum extent feasible, and the guiding idea for your program access improvements if you are a public works agency, but not applicable to accommodations. 48, this is a little bit of a recap of design and construction standards. Subtitle A allows covered entities to use ADAAG, UFAS or equivalents. Subtitle B requires the use of the new ADAAG 2004, and then Title II also designates DOT to oversee transportation, implementation under subtitle A. Slide 49, using ADAAG in the public right of way and here we are going back a little bit into history and addressing the need for PROWAG, public rights of way accessible guidelines. ADAAG was developed for buildings and facilities and doesn’t really have any provisions that are specific to the right of way. So people who use ADAAG or even UFAS have to adapt it in many ways to make it fit in the right of way. There have been a lot of uncertainty and there have been many complaints and there have been many situations in which a court has asked that work be torn out and replaced. But ADAAG because it isn''t a good rights of way fits, very difficult to adapt to that environment. It requires only one accessible route on a site. Any slope that is greater than 5 percent needs to be treated as a ramp. It doesn''t include signals and crossings and crosswalks. It has a path of travel requirement that is very difficult to understand in the right of way and it is principally an architectural standard rather than an engineering one. So, the answer clearly was that we needed a standard or a guideline that was specific to the public right of way. And here are some of the reasons why. On the top right you will see an illustration from the Justice Department''s voting technical assistants and it shows the accessible route required on a site, from a bus stop to an entrance, from a parking space, from a loading zone and then in to the building connecting to all of the common use and other spaces required to be accessible, but on a public right of way in the big photo below every route needs to provide access because there are addresses everywhere along that sidewalk that people need to get to. So in the public right of way every pedestrian route needs to conform to accessibility requirements and that generally means that those accessibility requirements can''t be the same as those for access the accessible route that is on a site. Next slide and I am on 52. So on the left we see what ADAAG might require in a sidewalk on a slope. On the right what PROWAG would require. The sidewalk in PROWAG can meet the slope of the roadway. The sidewalk on the left, the accessible route on the left has to be ramped in order to provide the required access on a site. How deep and this is perhaps an example of how many of the PROWAG provisions are already being implemented in spite of the fact that it is still a draft. On the left, detectible warnings on a curb ramp in I think Austin, Texas. On the right the two foot deep curb ramp detectible warnings in Massachusetts. So a special provision in PROWAG to limit the depth of detectible warnings to 24 inches as opposed to the specification in the current ADAAG. And other choices, ADAAG includes only one kind of curb ramp and it is the perpendicular curb ramp with the side flares that we are all so familiar with. But PROWAG includes many, many more types and they are all derived from the same basic rules, but there are projected ramps and parallel ramps and built up ramps and combination ramps, raised crossings, lots of different types. So that is a particular advantage of PROWAG. And many of those types of ramps are being provided across the country right now. So there it is, the need for PROWAG. Again a little bit of walk through of recent history, showing our advisory committee the report and the revised draft guidelines that we are working with now. And on to slide 56. How is PROWAG different from ADAAG. It adapts basic ADAAG. It is going to be a stand alone document using rights of way language and measures, that means it will be metric first. But here are the key differences. All sidewalks must contain a PAR, a pedestrian access route. It doesn''t mean that the full sidewalk width has to be a pedestrian access route but the sidewalk must contain it, and that''s true of every sidewalk. Sidewalk slope may follow the roadway. There are expanded curb types, a reduced detectible warning area, no path of travel requirement because it’s so difficult to say when something starts and stops in the right of way and where it goes. New signaling provisions and new provisions for roundabout design. Those circular intersections that are popping up in many states following a European model and here we have question 5 from Peter''s list, “Will all public sidewalks have to comply or just public sidewalks that are part of an accessible route?” And then a question about sidewalks in subdivisions which it deserves a separate answer. Yes, all sidewalks will have to comply. They will have to contain a pedestrian access route and there won''t be essentially the idea of an accessible route in the public right of way. Subdivisions are a special example. The Justice Department has said that in residential subdivisions access isn''t an issue, but by the same token, justice has already indicated if you are a subdivision designer or provider and you intend to turn over your public sidewalks at a future date for state and local government maintenance or operation, then those sidewalks would have to meet accessibility criteria. And it is also true that state and local governments apply all kinds of subdivision and zoning regulations and they probably have an obligation under Title II to apply accessibility provisions either under their own state law or even under a federal law that expects its state and local government will deliver accessibility as part of their own obligations. Slide 57, here are the is the table of contents for the draft PROWAG and you can see that it has four major parts. The usual ones you see in any rule, the scoping, that is how many and under what condition something needs to be accessible. And then a series of technical provisions for the key rights of way issues, the pedestrian access route and alternate circulation path, curb ramps, blended transitions, detectable warnings, pedestrian crossings, accessible pedestrian signals, street furniture and equipment and on street parking. And then we have also pulled in a number of provisions for say maneuvering space at doors, elevators, escalators, things like that from the 2004 ADAAG that would also apply under some conditions. Slide 58 and here we are back to finally the draft PROWAG and a key provision. A high degree of convenient access is easiest to achieve in new construction and here we are thinking about the cornfield in Kansas that is being redeveloped in to a neighborhood center, a commercial facility, something of that sort and it has newly designed and engineered sidewalks and streets and street crossings and pedestrian facilities. Alterations, much more common in the right of way than new construction whether it''s a resurfacing as on the left or a reconstruction of a say a part of a downtown improvement project. Again follow the guidelines for new construction to the maximum extent feasible and make sure you include curb ramps. Slide 60, draft PROWAG also includes provisions for access routes, a minimum of four foot wide and it may be on a shoulder or sidewalk with passing spaces at 200 foot intervals, five feet wide. Key provisions, the running slope of the pedestrian access route may match but not exceed that of the adjacent roadway. So on the left a sidewalk in Seattle that clearly follows the roadway slope, but the one on the right I think from suburban Atlanta where the sidewalk route is a much more complex slope and a much more difficult trip than the roadway slope that is adjacent to it, that wouldn''t be permitted once the PROWAG is the adopted standard. So, here is question No. 4 from Peter''s list, "In hilly areas will the sidewalk be required to be at a 1/12 maximum slope?" Nope, it won''t be. The sidewalk in all cases may match the adjacent roadway slope but it may not exceed it. Slide 62, however, if you put your pedestrian access route that is part of a sidewalk on a structure, then PROWAG says that structure must be an accessible route that is four feet wide. So if you do an overpass or an underpass or a pedestrian bridge, it needs to be designed as a ramp if the slope is more than 5 percent, or as a walk where it is less than 5 percent. That means more than 5 percent slope on your bridge you will need to have level landings and handrails, just as ADAAG would require but it all must be at least four feet wide, the pedestrian access route. Slide 63, a very key provision. One about cross slope limit. The cross slope in the pedestrian access route to a maximum of 2 percent. And the cross slope is always measured perpendicular to the centerline of the walkway. On the right is a photo from Portland where I am where I took it the last time that I was here showing a, the possibility of actually having a narrow pedestrian access route in an older sidewalk and then ramping up to the entrance at the side of it. You don''t need to keep 2 percent across the whole sidewalk in older neighborhoods. It may be a positive advantage to break that in to flatter and steeper slopes. Slide 64, something we call tabling at intersections. The photo on the left from San Francisco, the one on the right from Washington, D.C. showing that as you get to a cross street, if you are on a hilly slope you need to level out so that you have a level space for your curb ramps, your landings and so on. So when ever two sidewalks each with a 2 percent cross slope intersect the result will be a level landing that’s 2 percent in each direction and therefore tabled. Slide 65, when you detour the pedestrian route, provide an alternate and this is also required by federal highway administration regulations and keep it on the same side if it is feasible. Slide 66, provisions on protruding objects, 4 percent maximum protrusion in the public right of way. And don''t forget things like stairs on sidewalks where you need to make sure that it is protected below 80 inches and above 27 inches because those are the beyond detection areas. Slide 67, provide a curb ramp or a blended transition for each crossing. On the left a sidewalk in Vancouver, Washington, showing a really nice, this is my favorite detail lately, a nice small radius, keeping car speeds down. Good wayfindings from the raised curb at the left, nice detectible warnings at the toe. On the right a blended transition flat, 5 percent slope or less with detectible warnings along the bollards. Next slide, 68, this is another view on the left of the Vancouver sidewalk showing how such curb ramps can be in line with the crossing which is a wonderful feature for accessibility if for wayfindings and orientation and on the right a drawing showing the need to keep sidewalks in line and to keep the toe of the curb ramp parallel to the top and in line with the crossing. Slide 93 whoops, 73. Uh oh I skipped some I see, let me get myself back. Slide 69, okay. Sorry, everyone. Provide a level turning space at the top of a perpendicular ramp, at the bottom of a parallel ramp and at all corners. We used to call these areas landings, but in the public rights of way accessibility guidelines we call them turning spaces so it is clearer why they are provided. When you need to turn if you are using a mobility device, you need to be able to do it on a level-ish surface. That is to 2 percent in either direction. And so that is why we have made the point that where a turn must be made to use a pedestrian route, you need to have a flat area. Slide 75 no. Slide 70. Yes. Combined ramps, this is a scheme that we picked up actually from Sacramento, California, where you bring the sidewalk down slightly to a common level landing and then turn in either direction with a shorter perpendicular ramp to the street. Those generally works best when you have a setback on the sidewalk. Again you need the level turning space. Slide 71 and here is a slide that shows why you need to do it. Really tough to ask someone to climb a ramp and turn at the same time because it means that you are climbing by pushing with one arm and breaking turning with the other. So you have only half of your pushing force available and you can''t take a run at a ramp from the bottom because you need to turn. And often this kind of travel puts one wheel or another at different times up off the ground which compromises control. Slide 72, here are blended transitions. One in Little Rock and one actually here in Portland again, blended transitions have a slope of less than 5 percent. They are not ramps. So they needn’t have a perpendicular relationship with the street. 73, detectible warnings, on the left you see a photo of the chair and several of the key members of the public rights of way access advisory committee. That is Janet Barlow with the cane and Jerry Markesino from Portland, who is our Chair. They are considering a two foot depth of detectible warnings, and on the right is the granite detectible warnings that are in front of the White House in Washington. And question number 9 from Peter’s list, “What’s going on with detectable warnings in this rule?” Well detectable warnings are in the rule, and in the DOT rule as well, and the current provisions which I think will not change because they are based on pretty good research from Japan say that a minimum of 24 inches in depth is detectible. We have added a range to the dome diameters for detectible warnings. So that there is a little bit of give in the specification. This is principally for the convenience of the manufacturers, and it turned out in research that the spacing wasn''t very key to detectability. Detectible warnings are particularly useful at medians and pedestrian refuges so that you that you are in a place of pedestrian safety. Again the technical specification for 24 inches, it is nice if you have got enough width, PROWAG says 6 feet in the median so that you can use detectable warnings there like parentases where you open them, that means that you have gotten there to the median and then you have a space and then you open them again to cross the second street. Detectible warnings should also always be installed in pairs. You open them and close them when you get back to pedestrian safety. And typically they are used to mark where the curb edge would have been if it was still there. So be careful where you locate them. Slide 75, do driveways need detectible warnings? Typically not and here is the, this is the slide that Scott calls, I will blame it on him, driveways from hell with 1,2,3,4,5,6, perhaps 10 driveways, all of them incorrectly done with flared sides rather than ramped edges. And if we have enough time to get to the very end you will see some much better plans for driveways, but generally detectible warnings are not required on driveways because driveways are considered pedestrian areas and detectible warnings mark the edge of a vehicular area. This provision, adequate time to cross is a measurement provision in PROWAG and it says that you must provide essentially three and a half feet per second on your timing on your signals. And you must measure it curb to curb. These are things that are also changing in the DOT document, the manual on uniform traffic control devices which has been harmonized with the draft PROWAG. So the question number 6, from Peter’s list says "Do these guidelines establish a minimum amount of time to cross before the light changes based on the distance from curb to curb?” And yes they do. But don’t forget that if you or someone there is someone in a community who uses a crossing and finds that the time isn’t adequate, you could easily ask for an accommodation. And that can be accomplished in many ways, some pedestrian signals have a button that you can push in for an extended period of time that will extend the crossing. You can always put in video capture that will keep the light on red for vehicles, as long as you need it and there are other ways of extending crossing time if requested and necessary. Slide 77, here are three photos of standard types of accessible pedestrian signals. The one on the left has a series of little slugs that you can drop in at the side that essentially map the crossing that you are about to use. So it can tell you how many vehicle lanes. Is there is a bicycle lane. Is there a light rail in the middle of the road. That is useful information, particularly if you are traveling in a new area because it’s hard to assess your crossing time if you don''t know how wide the roadway is, and the question that Peter asked was, "Will audible pedestrian signals be required at every intersection.?" Well not at every intersection but wherever a pedestrian signal is provided it will need to provide both visible, audible and vibrotactile information. So if you are providing anything for pedestrians, it has to be an accessible pedestrian signal in PROWAG. Some of the APS have voice output. Some have ticks. Some have tones. Slide 78, here are some locations indicated for the support poles for APS. We have some reach limits in the draft PROWAG and the reason that we do it is shown on slide 79, location, location, location. For people who are using the vibrotactile feature on the APS you need to be lined up for your crossing while you have a hand on the device because it is the vibration that indicates when the walk occurs. And so you have to be right close to your departure curb. The next slide shows a situation in which you are not, you are coming along a wide sidewalk, this is probably 25 feet or so, and where is the pedestrian button, way at the back of sidewalk. So that means that you need to know the pedestrian button is there, detour to push it, head for the sidewalk where you want to cross, and by then you have probably missed your walk signal. So do you have time to go back and do it again? We want to avoid these kinds of situations. So the pedestrian signals should be located within a few feet of the departure curb. Slide 81, now talking about roundabouts. These are again circular intersections where approaching vehicles yield to vehicles that are already in the circle. Narrow ones with only one lane of crossing tend to be in low speed environments in neighborhoods but where there are where there is more than one vehicle lane to cross the sounds of traffic circulating can mask all of the audible queues that you would use to identify when you might have a gap. And so PROWAG will require a signal for a pedestrian or a pedestrian demand signal in those locations. So we have three photos of places where you already have these kinds of signals, one in Utah where a light rail vehicle actually goes through the roundabout. The lower left hand one in Australia where they use two head signals, and the right a signal in upper New York state. Slide 82 shows a signal technology called a HAWK that is being tested in Golden, Colorado, at a roundabout and there is a photo shown there. The pedestrian pushes the button which has a locator tone in it, the signal flashes, then comes up solid red for the vehicles and then once the pedestrian crosses the vehicle can go again. These have been pioneered in Tuscan, Arizona where they use them on major roadways to call a crossing signal for a pedestrian. And then the last provision for roundabouts is to require the sidewalk to be separated by a grass strip or a fence so that navigating around these nonrectalinier environments is a little bit clearer. Just a few more provisions and then we will talk a little about resources. Street furniture must be useable but not in the way. That means it must provide knee room but it must not project in to the pedestrian access route, so we talk about drinking fountains on street telephones, even small toilet facilities that exist on sidewalks, fire protection boxes, mailboxes, things of that sort. Slide 85.

Peter Berg

Lois, I am sorry, we are about at a quarter passed the hour and just for the participants we are going to go past the bottom of the hour so, hopefully you can hang with us because we did get started about ten minutes late. So, but we will still provide an opportunity for questions.

Lois Thibault

I think I have got about five more minutes left Peter. Will that work all right?

Peter Berg

That is perfect. That will give us 20 minutes for questions, perfect.

Lois Thibault

Here are the provisions for the on street parking. In PROWAG they are divided in to two types. One is a wide sidewalk more than 14 feet where an access aisle would be required and these are very like drop-offs like at hotels and on the right you will see a photograph of that. It has a curb ramp at one end. On the left a narrower sidewalk where really all that is required is a sign. If you keep these to the corners of the street where the curb ramps already are provided, then that is all that needs to be done for narrower sidewalks. And then Peter''s question, "Will accessible on street parking be required in the same numbers required in the ADA standards?" Yes. The scoping is exactly the same chart as you use for accessible spaces on sites. And you would just use as the basis for your scoping all of the parking spaces that would be provided on the perimeter on the block. So add up all four sides of a block and then apply the chart and then provide those spaces in places that it makes sense. Where it is flattest, where it is needed where it is nearest to curb ramps and so on. Diagonal on street parking, here is an example from Vancouver, Washington, is excellent for van accessibility and on the right you can see some sketches that show how to incorporate ramps up from diagonal on street parking. Slide 87, talking a little bit about bus stops. An interesting issue because this is a combination both of new construction and of program access. Remember, the standards apply when you are choosing to design or construct something. So if what you are doing is as in the photo at the left providing a bus stop by sticking a sign in the ground, well, the provision say that that sign needs to meet accessibility criteria. But the provisions don''t say that you need to provide a sidewalk or a concrete pad or a shelter or even information about when the next bus is coming. But those are all program access requirements. So if you are sticking a sign in the ground and you are a transit agency, it often means that the local jurisdiction then has an item on its transition plan that it needs to deal with and they would deal with that obviously by scheduling and eventually providing a concrete pad, a way to get to it, perhaps a sidewalk or at least a curb ramp that would provide access because as Scott says pedestrians don''t helicopter in to the bus stops. Here is a note from the Department of Justice. It is on their website that says "If installation of a curb ramp or pedestrian walkway is necessary to ensure that individuals with disabilities have access to a particular state or local program such as a school, the public entity may in some circumstances be required to install a ramp or walkway where none existed previously." And again, this is a program access obligation. There is, except for program access, no otherwise straightforward obligation to provide a sidewalk or a curb ramp. Slide 89, two slides here on bus stop costs just making the point that if you provide access to a bus stop you may be able to save a great deal in paratransit costs and this was a case study from the Maryland Transit Administration that showed you could pay for minimum improvements in a bus stop in less then two months, by saving in paratransit rides. Slide 91. Just to finish up here, remember that rule making is always a two step process for the Access Board. We develop the minimum guidelines and then other federal agencies adopt them and what they adopt must be consistent with what we have finalized. So under the ADA, DOJ and DOT and has already moved under the ABA for federal agencies and then with the Rehab Act every federal agency has its own set of Rehab Act regulations. Slide 92, and this is maybe the high point of my presentation, at least for me, can you use the 2005 PROWAG now? Yes. Remember, other methods are permitted in Title II. PROWAG is been around for low these many years, more than 15 years its basic issues. Title II says hey, it’s okay to use other methods if they provide equivalent accessibility. The Federal Highway Administration has issued a memorandum on their website, it is on ours as well that says it is a best practice. The Department of Justice has a policy letter that indicates that ADAAG, UFAS or other standard may provide the desired and required accessibility and it is a better fit for the right of way and, of course, many, many parts of the PROWAG are already being utilized whether it is detectible warnings, the idea of providing a portion of the sidewalk that is accessible, the path of travel requirements, curb ramps, and several states, we have a list of about six right now that have actually already adopted PROWAG as their state standards. A couple of ideas for those of you who are interested in how to make sure that curb ramps are more useable. There are a lot of things that can be manipulated in curb ramp design. The radius of the corner, whether there’s a set back or not, how high the curb is and that can be higher or lower depending on how much water it has to retain and things like that. So sometimes you can lower a curb to increase accessibility. Where you put the ramp whether it is directional or not or whether the roadway surface comes up to meet the ramp and then conditions at the edge of the ramp, whether you have a flare or returned edge that is protected in some way. Next to last category here I call it resources and Peter asks question 10, "What type of technical assistance materials are available?" And here are a few, the principle one, and we have paper copies available in bulk if you want to provide them to people in your area. This is an alteration manual that was developed by our PROWAAC committee and it has wonderful examples of sort of work arounds for situations where the new construction standards or guidelines can''t be effectively implemented. So if you want a copy, Peter knows how to get them. You can call or e mail me or you can e mail Al Baes at our office which is baes@accessboard.gov and ask for a publication called “ROW ALT” for rights of way for alterations and as I said we have cartons of them still. Look on our website, here is our rights of way home page. It has a whole host of information from research on signals, to detectible warnings, to a contrast, to pedestrian access, to roundabouts. So check it out and see if there isn''t a link to something that you want to know. Look at the website for accessible design for the blind. They have the best information on accessible pedestrian signals and also on detectible warnings. Their principals did much of the research on both issues and you can pick up a power point from them, you can look at research and some very good explications. Slide 98, this is the Federal Highway Administration website. This is the memo from federal highway that says that you can use the draft PROWAG as a best practice where ADAAG is inapplicable or silent. And here is a publication from the federal highway administration that you can download called Designing Sidewalks and Trails for Access. It is a wonderful series of illustrations. And now I am ready for questions. But let me find that one slide. There you go. And this is the link for contacting those of us directly. Again Scott on the left, our offices, Dennis and myself and our e mail and telephone numbers. So let''s have some questions Peter.

Peter Berg

All right. Thanks Lois. Great deal of information. Operator, do you want to come back in and give the folks instructions on how to ask questions, get in line to ask questions, please?

Operator

Yes, sir. Ladies and gentlemen, if you have a question at this time please press the 1 key on your one touch tone telephone. You may remove yourself from the queue any time by pressing the pound key.

Peter Berg

And just a quick note for folks if you could just limit it to one question so we can get to as many as possible and if you are on speaker phone, if could just pick up the headset to ask a question so that everyone can hear you. Lois, just a quick question, one that was submitted electronically during the session, someone had a question about the term "high degree of convenient access." Where would that be found in the DOJ technical assistance regulations?

Lois Thibault

It is in their Title III preamble. I think you can probably do a word search to come up with it.

Peter Berg

Excellent. Thank you. Operator do we have our first question from our participants please?

Operator

Again, ladies and gentlemen, if you have questions please press the 1 key on your touch tone telephone. Our first question. Your line is open.

Peter Berg

Go ahead with your question, please.

Caller

Do you have a question?

Peter Berg

Your line is up. Do you have a question, please?

Caller

You have got the wrong slot. We didn''t phone in a question.

Peter Berg

Okay. Let''s go to our next question, please.

Operator

The next question. Your line is open. Go ahead.

Caller

Yes. In a curb ramp design what is the maximum and minimum height of a curb?

Lois Thibault

You can manipulate the curb and in many communities the curb height is already set but you shouldn''t have a curb ramp slope that exceeds 1/12, and, of course, the lesser the slope that you can provide in a curb ramp the better. But there is no restraint in PROWAG on the curb height itself if I have understood you correctly.

Peter Berg

And, Lois, I have a question that goes along with that other one that was submitted electronically. In a retrofit situation, I think you talked about this, you talked about maximum extent feasible, this coming from a municipality and knowing that in retrofitting, limited on space and difficult to get the full landing and difficult to get the flared edges to be at less than 1/12 slope and do you have some examples on how in those situations they can comply?

Lois Thibault

That is exactly what our alterations manual deals with it. But I can offer lots of examples. Use a different kind of a curb ramp. If you have a narrow sidewalk that is attached to the curb, use a parallel ramp where you bring the sidewalk down, provide the level landing with the width of the sidewalk and then go back up again. I never like to go down in order to then go back up again but if you have got a four foot sidewalk, that is pretty much all you can do or consider a combined sidewalk where you bring the sidewalk down a little bit, have a level landing and then have a short run to the street if you that could be as short as two feet and you can do these in about a six foot wide sidewalk. Think about, you know, separating the sidewalk back if you have got the space. Think about raising a crosswalk if you have got that kind of a roadway. In Washington, D.C., they have been doing something very interesting. They take the toe of the curb ramp and continue it all the way out to the end of the gutter. That means that it meets the street at a slightly higher elevation and it doesn''t let the pounding that usually happens at the toe of a curb ramp occur. So you get a little bit of pounding on either side of the toe of the curb ramp but not in the ramp, the useable portion of the ramp itself and it can shorten the length of a ramp by about 14, 16 inches depending on how wide your gutter is. It is a very effective alteration technique.

Peter Berg

Right, excellent, and thank you, Lois. And you were correct, it is the Title III preamble that contains the language about the high degree of convenient access. So folks want to look for that. Operator, can we have our next question please?

Operator

Our next question. Your line is open.

Peter Berg

Go ahead with your question. Your line is up, please.

Caller

There is a requirement to provide an accessible bus stop when a municipality places a bus sign in the ground. Is there any other triggering factor besides? Is there a time element involved?

Lois Thibault

No, there is not. Bus stops are a difficult issue because they are very often placed by a transit authority that doesn''t exercise any other authority over say improvements at the bus stop which may be provided by a jurisdiction and there has to be some coordination between the two agencies. That doesn''t always occur. Pardon me?

Caller

I would say between the transit agency and the county that they are operating in more than likely.

Lois Thibault

Yes. Uh huh.

Caller

There is no triggering factor in terms of a time element that say like you would have under a Title III entity and the ADAAG and pre existing and new and if they do they have to provide program access to some extent.

Lois Thibault

Yes. And then you can hurry up that process and if you are say an individual with a disability and you say at this particular bus stop I need, you know, this kind of an accommodation. I need a sidewalk to it. I need a concrete pad where a lift can be deployed and so and so. In a public right of way you very often see these combinations of new construction, sticking the pole in the ground, program access and then individual accommodation. That allows you if you’re a jurisdiction to maybe spend the money in places that you know are significantly used.

Caller

Are there technical materials to support that concept?

Lois Thibault

Say again.

Caller

Are there technical materials available that support that concept?

Lois Thibault

That brings it all together and talks about bus stops? No. But you can deduce it from the provisions in the in Title II which is why I talked so much about how Title II interfaces with the standards which are really very often sort of a minor portion because so much of what gets done in a jurisdiction is really either an alteration, a program access improvement or even an individual accommodation.

Peter Berg

Excellent. Operator, could we have our next question, please?

Operator

Our next question. Your line is open.

Caller

Hi. My question was regarding slide 64 when you talked about tabled intersections.

Lois Thibault

Uh huh.

Caller

And there was a decision which was one of untabled in Washington, D.C. question is in existing conditions when you have an untabled intersection what would be considered the maximum extent feasible when making our curb ramp?

Lois Thibault

Not much you can do if only the scope of your work was say dropping in a curb ramp at that location. Here is a big connection between the scope of your plan project and what you can realistically achieve with respect to accessibility. If you are just replacing a small portion of sidewalk, you are not going to be able to make much in the way of the improvement, but some day that roadway segment will be reconstructed and then that is when you make that improvement, but there is almost nothing that you can do when you are dropping in a curb ramp in an existing developed environment. You make sure you have done the best that you can, you locate it in a way, perhaps minimizes the access problem, you are careful about how you design it, but you are not going to be able to correct a significant cross slope problem like that sidewalk has.

Peter Berg

All right. Thank you. And, Lois, I have another question submitted electronically and this has to do with on street parking where you have parking spaces deemed as used as, for instance, in the city of Chicago where the spaces are not necessarily marked and it is just parallel parking. How would PROWAG address that situation?

Lois Thibault

Well again there may be a couple of ways. PROWAG says when the city provides it, and, of course, this is true of all of the standards. It requires an action to provide something to essentially trigger the accessibility requirements. So if something is simply allowed to occur, then chances are there isn''t an obligation under new construction but you always have obligations under program access or accommodation. So someone in a neighborhood where residents park on a street may seek a marked space in front of his or her house and that would be an accommodation that jurisdiction would have to weigh and decide. Is it necessary for access, can they provide it. But it wouldn''t be governed by the standards.

Peter Berg

Very good and one other quick one before we get out to the telephone. Someone wanted to know how the public rights of way guideline would apply to trails.

Lois Thibault

Trails is a separate rule making and it is proceeding at the federal level on a fairly fast track. We hope to have it out soon. The and it is a rule making that is mostly dealing with oh the things that you would think of as back country trails. Right now the difficult issue for a lot of jurisdictions is shared use paths because they''re alternate to sidewalks that will cross open terrain usually. And the question there is we want them to be more accessible perhaps than trails which are a little bit say wilder and less developed. But perhaps they aren''t going to be able to be as accessible as accessible route on a site. And so the difficulty will be in doing the rule making for shared use paths.

Peter Berg

Right. And those are being developed under the Architectural Barriers Act.

Lois Thibault

The trails are. Yes. Shared use paths are is going to be a new rulemaking for us. Right. We are starting to get our ducks in a row on that one.

Peter Berg

Excellent, can we have another question, please.

Operator

Your line is open.

Caller

Yes, I have a question about where the pedestrian buttons in relation to ones that already exist, how do they determine where they are located and at what intersections?

Lois Thibault

Well, there are provisions in both draft PROWAG and actually already out there in something called a Manual on Uniform Traffic Control Devices which is kind of a highway bible that says it has to be within a certain distance of the marked crosswalk, with a certain distance of the curb. You have to separate them so that the sound from one doesn''t, you know, comingle with the sound from another and make it either inaudible or confusing. And then there are height requirements as well. So it needs to be within reach ranges. It can''t be over an obstruction. I must say that many of the ones that I see are completely in the wrong places and violate not only what the draft that PROWAG would require but what the current MUTCB would require.

Peter Berg

Thank you for your question. Another electronic question, Lois. Any thoughts or considerations of using detectible warning, the detectible warnings as a wayfinding or directional tool for individuals with low vision or who are blind and not just a queue that they are going from a sidewalk in to vehicular way?

Lois Thibault

This is area that needs research, we have embarked on some of it and I would say our current attitude right now is that yes, more queues are necessary but our concern is that using detectible warnings in that way might compromise their function in other ways. We don''t want to ask detectable warnings to carry too much information for fear then they won''t be able to carry the basic information which is essentially your next step may be into the street. We have looked at Corduroy patterns those are used quite commonly abroad in Australia and the UK and the Netherlands you see them and of course we have embarked on audible queuing and focused signal beams and things like that. But I would say that we don''t have any ready solutions for what certainly is a problem that is a concern. And we are looking at it.

Peter Berg

And currently the standards address it in terms that the curb ramp should be designed to provide that directional information?

Lois Thibault

If you can do it. Yeah, we encourage it but it isn’t required curb ramps to be directional but that requires certain other design accommodations in order to do that. But it is a huge benefit if you can do it.

Peter Berg

Okay, let''s try and get one more question then, please.

Operator

Our next question. Your line is open.

Caller

In the draft PROWAG does a blended transition with of a slope less than 5 percent require a detectible warning?

Lois Thibault

Oh yes. The lower the slope the fewer the queues you can pick up from it. So very definitely that is a location where you need detectible warnings. Some of the more problematic ones are do you need it on the bicycle ramps that are used to take bicycle riders off a roundabout so they can go around it as a pedestrian and then get back on it to the roadway after it.

Caller

I was confused with your slide but I don’t have the number of the slide, but there is no detectible warning for your one on blended transitions. I want to in sure that I have the accurate information.

Lois Thibault

It maybe didn''t show up because of all of the design overlays that I put on it. But the one in Lawrenceville, Kansas does have a detectable warning on it but it just doesn’t have very good contrast, but I apologize. Sometimes you find a slide that does nine out of the ten things that you want. But then people say that is what I saw in the Access Board presentation. So it must be okay.

Caller

Okay, thank you.

Peter Berg

Thank you for your questions and thank you to everyone for your patience today in the delay that we had at the start of the session. If you did not have an opportunity to ask your question of Lois, I would encourage you to contact your regional ADA center by dialing 800 949 4232.

Lois Thibault

And Peter I would be happy to take questions by e mail.

Peter Berg

And Lois’s contact information is available on the ADA Audio Conference website at www.ada audio.org. If you go under the speaker information you can find Lois''s contact information. I want to thank everyone for joining us today. I hope that some of you will be back with us or all of you will be back with us on June 16th when we will conclude our two part state and local government series when we will be taking a look at emergency preparedness with our speaker Cameron I am sorry, Karl Cameron who will be joining you in June for that session. And you can find information on that session by going to the ADA Audio website or by calling the Audio Conference toll free line at 877 232 1990. That is 877 ADA 1990. Again the audio archive and text transcript of this session will be available in approximately two weeks on the ADA audio website. And once again I want like to thank all of our participants and would like to especially thank you, Lois, who has been a long time friend to the DBTACs, the ADA centers and we appreciate her time that she has spent with us today. So I thank all of you today and I hope that you are all enjoying a lovely spring day out there. Take care and I hope to hear you next month. Thank you.

Operator

Ladies and gentlemen, that does conclude our conference for today. Thank you for your participation. You may now disconnect.