1

UNITED STATES ACCESS BOARD

WASHINGTON, DC

APPENDIX TO REGULATORY ASSESSMENT

COMPARISON OF 

PROPOSED ACCESSIBILITY GUIDELINES FOR 

PEDESTRIAN FACILITIES IN THE PUBLIC RIGHT-OF-WAY

AND

DOJ 2010 ADA STANDARDS FOR ACCESSIBILE DESIGN 

June 2011
2

Introduction

The regulatory assessment prepared by the Access Board for the proposed accessibility guidelines for pedestrian facilities in the public 

right-of-way assumes that, in the absence of the proposed accessibility guidelines, state and local transportation departments will use 

the DOJ 2010 ADA Standards for Accessible Design (hereinafter referred to as “DOJ 2010 Standards”) in the Department of Justice 

regulations implementing Title II of the Americans with Disabilities Act (28 CFR part 35) to the extent feasible when designing, 

constructing, or altering pedestrian facilities in the public right-of-way, consistent with the guidance issued by the Federal Highway

Administration.1 The DOJ 2010 Standards are available on the Department of Justice website at: 

http://www.ada.gov/2010ADAstandards_index.htm. 

The proposed accessibility guidelines for pedestrian facilities in the public right-of-way are compared to DOJ 2010 Standards, other 

applicable standards, and industry practices in the tables below.

Table 1. Proposed Guidelines Contain Same Requirements as in DOJ 2010 Standards

Table 1 analyzes requirements in the proposed guidelines that are the same as requirements in the DOJ 2010 Standards.

2

 The 

requirements in the proposed guidelines in Table 1 will have no impacts on state and local transportation departments compared to the 

requirements in the DOJ 2010 Standards because the requirements are the same.

Table 2. Proposed Guidelines Adapt Requirements in DOJ 2010 Standards 

Table 2 analyzes requirements in the proposed guidelines that adapt requirements in DOJ 2010 Standards to allow for conditions and 

constraints in the public right-of-way.

3

 The requirements in the proposed guidelines in Table 2 do not establish greater requirements 

 

1

 See Federal Highway Administration, Office of Program Administration, “Pedestrians and Accessible Design” at: 

http://www.fhwa.dot.gov/programadmin/pedestrians.cfm. 

2

 The requirements analyzed in Table 1include: drinking fountains, public toilet facilities, tables, counters, passenger loading zones, ramps, stairways, handrails, 

doors, doorways, gates, operable parts, clear spaces, knee and toe clearance, and reach ranges.

3

 The requirements analyzed in Table 2 include: sidewalks and other pedestrian circulation paths, pedestrian street crossings, pedestrian overpasses and 

underpasses, pedestrian at-grade rail crossings, curb ramps and blended transitions, protruding objects, transit stops and transit shelters used by buses and light 

rail vehicles, on-street parking, and escalators. The requirements for transit stops and transit shelters used by buses and light vehicles are compared to the 

accessibility standards in the Department of Transportation regulations implementing the public transportation parts of Title II of the Americans with Disabilities 

Act. 
3

for accessibility in the public right-of-way than the requirements in the DOJ 2010 Standards and industry practices. Some of the 

requirements in the proposed guidelines in Table 2 establish lesser requirements for accessibility in the public right-of-way than the 

requirements in the DOJ 2010 Standards. For example, where the pedestrian access route in a sidewalk is contained within the street 

or highway right-of-way, the grade of the pedestrian access route is permitted to equal the general grade established for the adjacent 

street or highway to allow for typical roadway geometry instead of the running slope requirements for accessible routes on sites. The 

requirements in the proposed guidelines in Table 2 will have no impacts on state and local transportation departments compared to the 

requirements in the DOJ 2010 Standards and industry practices, except for the 2 percent maximum cross slope requirement for 

pedestrian access routes contained within pedestrian street crossings with stop or yield control where vehicles slow or stop before 

proceeding through the intersection (see R204.3 and R302.6). This requirement will have more than minimal impact on the design 

and construction of new tabled intersections in hilly urban areas that contain pedestrian street crossings with stop or yield control. 

Table 3. Proposed Guidelines Contain Requirements Not in DOJ 2010 Standards

Table 3 analyzes requirements in the proposed guidelines for which there are no corresponding requirements in the DOJ 2010 

Standards.

4

 The requirements in the proposed guidelines in Table 3 are compared to other applicable accessibility standards and the 

2009 edition of Manual on Uniform Traffic Control Devices for Streets and Highways (MUTCD). Where the requirements in the 

proposed guidelines in Table 3 are the same as the requirements in other applicable accessibility standards or the MUTCD, the 

requirements will have no impacts on state and local transportation departments. Where a requirement in the proposed guidelines in 

Table 3 differs from a corresponding requirement in other applicable accessibility standards or there is no corresponding requirement 

in other applicable accessibility standards, the analysis used the following factors to identify whether the requirement will have more 

than minimal impacts on state and local transportation departments:

 Whether the requirement can be easily incorporated into the design of the element or facility? 

 Whether the requirement adds features to the element or facility?

 Whether the requirement reduces space needed for other purposes?

 What are the additional costs due to the requirement compared to the total design and construction costs for the element or 

facility?

 

4

 The requirements analyzed in Table 3 include: alternate pedestrian access routes, pedestrian signal phase timing, accessible pedestrian signals and pedestrian 

pushbuttons, pedestrian street crossings at roundabouts, detectable warning surfaces on curb ramps and blended transitions at pedestrian street crossings, 

detectable warning surfaces on pedestrian at-grade rail crossings not located within a street or highway, pedestrian signs, and benches.
4

A requirement that can be easily incorporated into the design of an element or facility, and does not add features to the element or 

facility or reduce space needed for other purposes will have minimal impacts on state and local transportation departments. A 

requirement that cannot be easily incorporated into the design of an element or facility, adds features to the element or facility, or 

reduces space needed for other purposes and that results in additional costs compared to the total design and construction costs of the 

element or facility which are not negligible (i.e., are worth considering) will have more than minimal impacts on state and local 

transportation departments.

The analysis identified three requirements in the proposed guidelines in Table 3 that will have more than minimal impacts on state and 

local transportation departments:

 Detectable warning surfaces on curb ramps and blended transitions at pedestrian street crossings (see R208.1 and R305); 

 Accessible pedestrian signals and pedestrian pushbuttons (see R209); and

 Pedestrian activated signals at roundabout intersections with multi-lane pedestrian street crossings (see R206 and R306.3.2).
5

Table 1: Proposed Guidelines Contain Same Requirements as in DOJ 2010 Standards

for Pedestrian Facilities in the Public Right-of-Way

Element or Facility DOJ 2010 Standards Proposed Guidelines Analysis

Drinking Fountains 211

Requires drinking fountains to comply with 

602.

602.1 to 602.6

Contains requirements for clear space, 

operable parts, spout height and location, 

and water flow.

R212.2

Requires drinking fountains to comply with 

602.1 to 602.6 of DOJ 2010 Standards.

No impacts compared to DOJ 2010 

Standards.

Public Toilet Facilities 206.2.4

Requires accessible routes within facilities.

213

Requires toilet facilities to comply with 603 

to 610. Where multiple single-user portable 

units are clustered at a location, at least 5 

percent required to comply with 213.

603 to 610

Contains requirements for toilet rooms, 

water closets and toilet compartments, 

urinals, lavatories and sinks, bathtubs, 

shower compartments, grab bars, and seats. 

R212.3

Requires public toilet facilities to comply 

with 206.2.4 and 603 to 610 of DOJ 2010 

Standards. Where multiple single-user units 

are clustered at a location, at least 5 percent 

required to comply with R212.3.

No impacts compared to DOJ 2010 

Standards.

Tables 226

Requires at least 5 percent of tables to 

comply with 902.

902

Contains requirements for clear space and 

height.

R212.4

Requires at least 5 percent of tables to 

comply with 902 of DOJ 2010 Standards.

No impacts compared to DOJ 2010 

Standards.

Counters 227

Requires counters to comply with 904.

904

Contains requirements for approach.

R212.5

Requires counters to comply with 904 of 

DOJ 2010 Standards.

No impacts compared to DOJ 2010 

Standards.
6

Element or Facility DOJ 2010 Standards Proposed Guidelines Analysis

Passenger Loading 

Zones

209

Requires one accessible passenger loading 

zone complying with 503 for each 30 m 

(100.0 ft) of continuous loading zone space.

503

Contains requirements for vehicle pull-up 

space and access aisle.

R216

Requires one accessible passenger loading 

zone complying with R310 for each 30 m 

(100.0 ft) of continuous loading zone space.

R310

Contains requirements for vehicle pull-up 

space and access aisle.

No impacts compared to DOJ 2010 

Standards.

Ramps 405

Contains requirements for running and cross 

slopes, width, rise, landings, surfaces, 

handrails, and edge protection for ramps 

that are part of accessible routes. 

R407

Contains requirements for running and cross 

slopes, width, rise, landings, surfaces, 

handrails, and edge protection for ramps 

that are part of pedestrian access routes.

No impacts compared to DOJ 2010 

Standards.

Stairways 210

Requires stairways that are part of means of 

egress to comply with 504.

504

Contains requirements for treads and risers, 

nosings, and handrails. 

R216

Requires stairways provided on pedestrian 

circulation paths to comply with R408.

R408

Contains requirements for treads and risers, 

nosings, and handrails. 

No impacts compared to DOJ 2010 

Standards.

Handrails 403.6

Requires handrails provided on walking 

surfaces to comply with 505.

405.8

Requires handrails complying with 505 on 

ramp runs with rise greater than 150 mm (6 

in).

504.6

Requires handrails complying with 505 on 

stairways.

505

Contains requirements for sides, continuity, 

height, clearance, gripping surface, cross 

section, surfaces, fittings, and extensions. 

Requirements for sides, continuity, and 

extensions apply only to ramps and 

R217

Requires handrails provided on pedestrian 

circulation paths to comply with R409.

R407.8

Requires handrails complying with R409 on 

ramp runs with rise greater than 150 mm (6 

in).

R408.6

Requires handrails complying with R409 on 

stairways.

R409

Contains requirements for sides, continuity, 

height, clearance, gripping surface, cross 

section, surfaces, fittings, and extensions. 

Requirements for sides, continuity, and 

extensions apply only to ramps and 

No impacts compared to DOJ 2010 

Standards.
7

Element or Facility DOJ 2010 Standards Proposed Guidelines Analysis

stairways. stairways. 

Doors & Doorways,

Gates

206.5

Requires doors, doorways, and gates 

providing user passage to comply with 404.

404

Contains requirements for manual, 

automatic, and power-assisted doors and 

gates, including clear width, maneuvering 

clearances, thresholds, doors and gates in 

series, hardware, closing speed, opening 

force, surfaces, vision lights, controls, and 

break out opening. 

R218

Requires doors, doorways, and gates at 

pedestrian facilities to comply with 404 of 

DOJ 2010 Standards.

No impacts compared to DOJ 2010 

Standards.

Operable Parts 205

Requires operable parts on accessible 

elements and accessible routes, and in 

accessible rooms and spaces to comply with 

309.

309

Contains requirements for clear space, 

height, and operation.

R403

Contains requirements for clear space, 

height, and operation for operable parts on 

pedestrian pushbuttons at accessible 

pedestrian signals, and parking meters and 

parking pay stations at accessible parking 

spaces.

No impacts compared to DOJ 2010 

Standards.

Clear Spaces,

Knee &Toe Clearance

305, 306

Contains requirements for surfaces, size, 

position, approach, maneuvering space, and 

knee and toe clearance for clear floor or 

ground spaces required at operable parts 

and accessible elements. 

R404, R405

Contains requirements for surfaces, size, 

position, approach, maneuvering space, and 

knee and toe clearance for clear spaces 

required at operable parts (see R403), 

benches, and transit shelters.

No impacts compared to DOJ 2010 

Standards.

Reach Ranges 308 

Contains requirements for forward and side 

reach to operable parts and accessible 

elements. 

R406

Contains requirements for forward and side 

reach to operable parts (see R403).

No impacts compared to DOJ 2010 

Standards.
8

Table 2: Proposed Guidelines Adapt Requirements in DOJ 2010 Standards

to Pedestrian Facilities in the Public Right-of-Way 

Element or Facility DOJ 2010 Standards Proposed Guidelines Analysis

Sidewalks & Other 

Pedestrian Circulation 

Paths

206.2.2

Requires accessible routes complying with 

401 to 410 within sites.

106.5

Site defined to include “parcel of land 

bounded by a property line or a designated 

portion of a public right-of-way.” 

R204.2

Requires pedestrian access routes 

complying with R302 within sidewalks and 

other pedestrian circulation paths located in 

public right-of-way. 

105.5

Public right-of-way defined to include 

“public land or property, usually in 

interconnected corridors, that is acquired for 

or dedicated to transportation purposes.”

No impacts compared to DOJ 2010 

Standards and industry practices. 

Adapts accessible route requirements 

to sidewalks and other pedestrian 

circulation paths in public right-ofway. In alterations where existing 

physical constraints make it 

impracticable to fully comply with 

new construction requirements, 

compliance is required to extent 

practicable (see R202.3.1).

Width 403.5.1

915 mm (3.0 ft) minimum

R302.3

1.2 m (4.0 ft) minimum

Industry practice is to design 

sidewalks 1.2 m (4.0 ft) wide 

minimum so two people can walk 

side-by-side and pass a third person 

comfortably. In commercial areas, 

sidewalks are wider than 1.2 m (4.0 

ft). See AASHTO Green Book (p. 

398); AASHTO Pedestrian Facilities 

Guide (p. 58). 

Passing Spaces 403.5.3

Where clear width less than 1.5 m (5.0 ft) 

wide, requires passing spaces 1.5 m (5.0 ft) 

by 1.5 m (5.0 ft) minimum at intervals of 61 

m (200.0 ft) maximum.

R302.4

Where clear width less than 1.5 m (5.0 ft) 

wide, requires passing spaces 1.5 m (5.0 ft) 

by 1.5 m (5.0 ft) minimum at intervals of 61 

m (200.0 ft) maximum.

Same as DOJ 2010 Standards.

Grade 403.4 Walking Surfaces

5 percent maximum 

405.2 Ramps

8.3 percent maximum

R302.5

Where pedestrian access route is contained 

within street or highway right-of-way, 

permits grade to equal general grade 

established for adjacent street or highway. 

Where pedestrian access route is not 

contained within street or highway right-ofway, requires 5 percent maximum grade.

Grade requirements modified to allow

for typical roadway geometry.

Cross Slope 403.3

2 percent maximum 

R302.6

2 percent maximum

Same as DOJ 2010 Standards.
9

Element or Facility DOJ 2010 Standards Proposed Guidelines Analysis

Surfaces 302.1, 403.2

Firm, stable, and slip resistant

R302.7

Firm, stable, and slip resistant

Same as DOJ 2010 Standards.

Vertical Alignment 403.4

Requires changes in level to comply with 

303.

R302.7.1

Requires vertical alignment within 

pedestrian access routes to be generally 

planar, and grade breaks to be flush.

Adapts requirement for level surfaces 

to pedestrian access routes in the 

public right-of-way.

Vertical Surface 

Discontinuities

303

Permits vertical surface discontinuities up to 

13 mm (0.5 in) maximum. Requires 

vertical surface discontinuities between 6.4 

mm (0.25 in) and 13 mm (0.5 in) to be 

beveled.

R302.7.2

Permits vertical surface discontinuities up to 

13 mm (0.5 in) maximum. Requires 

vertical surface discontinuities between 6.4 

mm (0.25 in) and 13 mm (0.5 in) to be 

beveled across the entire vertical surface 

discontinuity.

Same as DOJ 2010 Standards, except

bevel required across entire vertical 

surface discontinuity.

Horizontal Openings in 

Gratings & Joints

302.3, 403.2

Must not allow passage of sphere more than 

13 mm (0.5 in) in diameter.

R302.7.3

Must not allow passage of sphere more than 

13 mm (0.5 in) in diameter.

Same as DOJ 2010 Standards.

Pedestrian Street 

Crossings

Apply accessible route requirements. Apply pedestrian access route requirements 

with following modifications:

R302.3.1 Width at Medians & Pedestrian 

Refuge Islands

1.5 m (5.0 ft) minimum

R302.5.1 Grade

5 percent maximum

R302.6.1 Cross Slope at Crossings 

Without Yield or Stop Control

5 percent maximum at crossings without 

yield or stop control (i.e., where vehicles

proceed thru intersection without slowing or 

stopping)

R302.6.2 Cross Slope at Midblock 

Crossings

Permits cross slope to equal street or 

highway grade.

No impacts compared to DOJ 2010 

Standards, except as noted below. 

Adapts accessible route requirements 

to pedestrian street crossings to allow

for typical roadway geometry. In 

alterations where existing physical 

constraints make it impracticable to 

fully comply with new construction 

requirements, compliance is required 

to the extent practicable (see 

R202.3.1). 

2 percent maximum cross slope will 

have more than minimal impact on 

new construction of tabled 

intersections in hilly urban areas that 

contain pedestrian street crossings 

with yield or stop control where 

vehicles slow or stop before 

proceeding thru the intersection. 

Impact is analyzed in regulatory 

assessment.
10

Element or Facility DOJ 2010 Standards Proposed Guidelines Analysis

Pedestrian Overpasses 

& Underpasses

Apply accessible route requirements. Apply pedestrian access route requirements 

with following modifications:

R204.4

Where overpass, underpass, bridge, or

similar structure is designed for pedestrian 

use only and approach slope to structure 

exceeds 5 percent, requires ramp, elevator, 

limited use/limited application elevator, or 

platform lift. Where overpass, underpass, 

bridge, or similar structure is designed for 

both pedestrian and vehicle use and 

pedestrian access route is contained within 

street or highway right-of-way, grade of 

pedestrian access route is permitted to equal 

general grade established for adjacent street 

or highway.

No impacts compared to DOJ 2010 

Standards. Design of new pedestrian 

overpasses and underpasses currently 

required to include ramps. See FHWA 

Policy on Accessible Design at: 

http://www.fhwa.dot.gov/program 

admin/pedestrians.cfm. Allows use of 

ramps, elevators, or platform lifts to 

access overpasses and underpasses 

designed for pedestrians only. Adapts 

accessible route requirements to 

pedestrian overpasses and underpasses 

designed for both pedestrian and 

vehicle use.

Pedestrian At-Grade 

Rail Crossings

402, 810.10

Requires pedestrian at-grade rail crossings 

to comply with accessible route 

requirements. Permits flangeway gaps to be 

64 mm (2.5 in) maximum. 

R302.7.1, R302.7.4

Requires pedestrian access route to be level 

and flush with top of rail at outer edges of 

rail. Requires surface between rails to be 

aligned with top of rail. Permits flangeway 

gaps to be 64 mm (2.5 in) maximum on 

non-freight rail track, and 75 mm (3 in) on 

freight rail track. 

No impacts compared to DOJ 2010 

Standards. Permits wider flangeway 

gaps for freight railway track.

Curb Ramps & 

Blended Transitions

28 CFR 35.151 (c) (i)

Requires curb ramps or other sloped areas at 

pedestrian street crossings on newly 

constructed or altered streets, roads, 

highways, and street level pedestrian 

walkways.

206.2.2, 402.2

Requires accessible routes within sites. 

Curb ramps are components of accessible 

routes.

406

R207.1

Curb ramps, blended transitions, or 

combination of curb ramps and blended 

transitions required to connect pedestrian 

access routes at each pedestrian street 

crossing (i.e., sidewalk level and street 

level).

R207.2

Permits single diagonal curb ramp to serve 

both pedestrian street crossings in 

alterations, where existing physical 

constraints prevent compliance with 

R207.1.

No impacts compared to DOJ 2010 

Standards. Adapts curb ramp 

requirements to public right-of-way. 

Includes additional designs for parallel 

curb ramps and blended transitions. 

Permits cross slope of curb ramps and 

blended transitions at pedestrian street 

crossings without yield or stop control 

where vehicles do not slow or stop 

before proceeding thru the intersection 

and at midblock pedestrian street 

crossings to equal street or highway 

grade.
11

Element or Facility DOJ 2010 Standards Proposed Guidelines Analysis

Contains requirements for perpendicular 

curb ramps, including location, landings, 

flared sides, and counter slope. Permits 

diagonal curb ramps.

R304

Contains requirements for perpendicular 

curb ramps (turning space, running slope, 

and flared sides); parallel curb ramps 

(turning space and running slope); blended 

transitions (running slope); and common 

requirements applicable to curb ramps and 

blended transitions (width, grade breaks, 

cross slope, counter slope, and clear space).

Protruding Objects 204, 307.5

Requires protruding objects on circulation 

paths to comply with 307 and not reduce 

clear width required for accessible routes.

307

Contains requirements for protrusion limits, 

post-mounted objects, and vertical 

clearance.

R210

Requires protruding objects along or 

overhanging pedestrian circulation paths to 

comply with R402 and not reduce clear 

width required for pedestrian access routes.

R402

Contains requirements for protrusion limits, 

post-mounted objects, and vertical 

clearance.

No impacts compared to DOJ 2010 

Standards and MUTCD. Limits 

posted-mounted objects that are 685 

mm (2.25 ft) minimum and 2030 mm 

(6.7 ft) maximum above sidewalk 

from projecting into pedestrian 

circulation paths 100 mm (4 in) 

maximum measured horizontally from 

post or pylon base. MUTCD requires 

bottom of signs installed on sidewalks

to be 2030 mm (6.7 ft) minimum 

above sidewalk, and bottom of 

secondary signs mounted below 

another sign that are lower than 2030 

mm (6.7 ft) above sidewalk to project 

not more than 100 mm (4 in) into 

sidewalk.

Transit Stops

Boarding &

Alighting Areas

218, 810.2*

Contains requirements for bus boarding and 

alighting areas, including surfaces, 

dimensions, slope, and accessible route 

connections.

R213, R308.1.1, R308.1.3

Contains requirements for boarding and 

alighting areas at sidewalk or street level 

transit stops, including surfaces, 

dimensions, grade, and pedestrian access 

route connections. Where transit stops 

serve vehicles with more than one car, 

requires boarding and alighting area serving 

each car to comply with requirements,

No impacts compared to DOT 

Standards and current industry 

practices.* Adapts boarding and 

alighting area requirements to transit 

stops in public right-of-way used by 

buses and light rail vehicles. 

Boarding Platforms 218, 810.5*

Contains requirements for rail boarding 

platforms, including platform and vehicle 

R213, R308.1.2, R308.1.3

Contains requirements for boarding 

platforms at transit stops, including 

No impacts compared to DOT 

Standards and current industry 

practices.* Adapts boarding platform 
12

Element or Facility DOJ 2010 Standards Proposed Guidelines Analysis

floor coordination and slope. platform and vehicle floor coordination, 

slope, surfaces, and pedestrian access route 

connections. 

requirements to transit stops in public 

right-of-way used by buses and light 

rail vehicles. 

Detectable Warning 

Surfaces

218, 810.5.2*

Requires detectable warning surfaces on 

boarding platforms at rail stations.

705*

Contains requirements for dome size and 

spacing, contrast, size, and placement of 

detectable warning surfaces.

R208

Requires detectable warning surfaces at 

boarding platforms at transit stops for buses 

and rail vehicles, and at boarding and 

alighting areas at sidewalk or street level 

transit stops for rail vehicles.

R305

Contains requirements for dome size and 

spacing, contrast, size, and placement of 

detectable warning surfaces.

No impacts compared to DOT 

Standards and current industry 

practices.* Adapts requirements for 

detectable warning surfaces on 

boarding platforms to transit stops in 

public right-of-way used by buses and 

light rail vehicles. 

Route Signs 218, 703, 810.4, 810.6.2*

Requires signs that identify routes served by 

bus stops and rail stations to comply with 

requirements for visual characters on signs. 

Bus route signs required to comply with

requirements for character height to 

maximum extent practicable. Bus route 

signs not required to comply with 

requirements for height from ground and 

line spacing. Permits use of audible signs

as an alternative means of compliance for 

signs at rail stations.

R211.3, R410

Requires signs that identify routes served by 

transit stops to comply with requirements 

for visual characters on signs. Permits use 

of audible sign systems and other 

technologies to provide equivalent 

information as an alternative means of 

compliance.

No impacts compared to DOT 

Standards and current industry 

practices.* Adapts requirements for 

route signs to transit stops in public 

right-of-way used by buses and light 

rail vehicles. 

Transit Shelters 218, 810.3*

Requires clear space within bus shelters, 

and accessible route connections.

R213, R308.2

Requires clear space within transit shelters, 

and pedestrian access route connections. 

Requires environmental controls to be 

proximity-actuated, and protruding objects 

to comply with R402.

No impacts compared to DOT 

Standards and current industry 

practices.* Adapts requirements for 

transit shelters to transit stops in 

public right-of-way used by buses and 

light rail vehicles. Requires 

environmental controls to be 

proximity-actuated instead of 

complying with requirements for 

operable parts (see R403). Clarifies 

that requirements for protruding 

objects applies to transit shelters. 
13

Element or Facility DOJ 2010 Standards Proposed Guidelines Analysis

On-Street Parking 208

Where parking is provided, requires 

minimum number of accessible parking 

spaces complying with 502.

502

Contains requirements for vehicle spaces 

and adjoining access aisles.

216.5, 502.6, 703.7.2.1

Requires accessible parking spaces to be 

identified by signs displaying International 

Symbol of Accessibility.

R214

Where on-street parking is provided and is 

marked or metered, requires minimum 

number of accessible parking spaces 

complying with R309.

R309.2

Requires access aisles at accessible parallel 

parking spaces, where width of adjacent 

sidewalk or available right-of-way exceeds 

4.3 m (14.0 f). In alterations (e.g., parallel 

parking spaces marked or parking meters 

installed on existing street), access aisles 

not required where street or sidewalk 

adjacent to parking spaces is not altered. 

Where access aisles not provided, requires 

accessible parallel parking spaces to be 

located at end of block face.

R309.3

Requires access aisles at perpendicular and 

angled parking spaces. Permits two 

accessible parking spaces to share common 

access aisle.

R309.4

Requires curb ramps or blended transitions 

to connect access aisles to pedestrian access 

routes. Permits curb ramps or blended 

transitions at pedestrian street crossings to 

serve parking spaces located at end of block 

face.

R309.5

Requires parking meters and parking pay 

stations serving accessible parking spaces to 

be located at head or foot of parking space, 

and displays and information to be visible to 

person seated in wheelchair. Requires 

No impacts compared to DOJ 2010 

Standards. Adapts parking 

requirements to public right-of-way. 

Accessible parallel parking spaces 

located adjacent to no parking zones 

will not result in loss of parking 

spaces. Loss of perpendicular and 

angled parking spaces is same as 

compared to DOJ 2010 Standards (1 

parking space per 50 marked or 

metered parking spaces on the block 

perimeter). Impacts on alterations that 

do not involve changes to street or 

sidewalk are minimal since access 

aisles not required.
14

Element or Facility DOJ 2010 Standards Proposed Guidelines Analysis

operable parts to comply with R403.

R211.4, R411

Requires accessible parking spaces to be 

identified by signs displaying International 

Symbol of Accessibility.

Escalators 810.9

Requires escalators in rail stations to 

comply with ASME A17.1 Safety Code for 

Elevators and Escalators sections on steps, 

and entrance and egress ends.

R216

Requires escalators on pedestrian 

circulation paths to comply with ASME 

A17.1 Safety Code for Elevators and 

Escalators sections on steps, and entrance 

and egress ends.

No impacts compared to ASME A17.1 

Safety Code for Elevators and 

Escalators. Escalators comply with 

ASME A17.1 Safety Code for 

Elevators and Escalators as standard of 

care for industry.

* DOT Standards apply to transportation facilities used in the provision of dedicated transportation services and intercity and commuter rail services.
15

Table 3: Proposed Guidelines Contain Requirements Not in DOJ 2010 Standards

for Pedestrian Facilities in the Public Right-of-Way

Element or Facility Proposed Guidelines Other Applicable Standards Analysis

Alternate Pedestrian 

Access Routes

R205, R303

Requires alternate pedestrian access routes

to comply with referenced MUTCD 

standard statements when pedestrian access 

routes are temporarily closed by 

construction, alterations, maintenance 

operations, or other conditions. 

Referenced MUTCD standard statements 

require alternate pedestrian routes to be 

accessible and detectable when pedestrian 

routes are temporarily closed by 

construction, alterations, maintenance 

operations, or other conditions.

Compliance with referenced MUTCD 

standard statements is mandatory (see 

MUTCD, section 1A.13). No impacts 

compared to MUTCD.

Pedestrian Street 

Crossings – Pedestrian 

Signal Phase Timing

R206, R306.2

Requires pedestrian signal phase timing to 

comply with referenced MUTCD standard 

statements.

Referenced MUTCD standard statements 

contain requirements for pedestrian signal 

phase timing.

Compliance with referenced MUTCD 

standard statements is mandatory (see 

MUTCD, section 1A.13). No impacts 

compared to MUTCD.

Pedestrian Street 

Crossings – Accessible 

Pedestrian Signals and 

Pedestrian Pushbuttons

R209, R307

Requires pedestrian signals to include 

accessible pedestrian signals and pedestrian 

pushbuttons that comply with referenced 

MUTCD standard statements. Requires 

operable parts to comply with R403.

R206, R306.5

At signalized intersections, requires 

pedestrian activated signals complying with 

R209 at multi-lane channelized turn lanes.

Referenced MUTCD standard statements 

contain requirements for installation of 

accessible pedestrian signals and pedestrian 

pushbuttons. However, MUTCD does not 

require pedestrian signals to include 

accessible pedestrian signals and pedestrian 

pushbuttons.

Transportation Equity Act for 21st Century 

(TEA-21) requires audible pedestrian 

signals to be included in transportation 

plans and projects, where appropriate (23 

U.S.C. (g)).

Accessible pedestrian signals and 

pushbuttons add features to pedestrian 

signals. Additional costs due to 

requirement compared to total design 

and construction costs for pedestrian 

signals are not negligible. Impact will 

be more than minimal and is analyzed 

in Regulatory Assessment.

Pedestrian Street 

Crossings –

Roundabouts

R206, R306.2 

Requires detectable edge treatment (e.g., 

grass strip) between sidewalk and curb at 

roundabouts with pedestrian facilities where 

pedestrian street crossing is not intended.

R206, R306.3 

Requires pedestrian activated signals at 

roundabouts with multi-lane pedestrian 

street crossings.

None Detectable edge treatment can be 

easily incorporated into design of 

roundabouts with pedestrian facilities. 

Any additional costs due to 

requirement compared to total design 

and construction costs for roundabouts 

are negligible. Impact will be 

minimal.

Pedestrian activated signals add 

features to roundabouts. Additional 
16

Element or Facility Proposed Guidelines Other Applicable Standards Analysis

R206, R306.4

Requires pedestrian activated signals at 

roundabouts with pedestrian street crossings 

at multi-lane channelized turn lanes. 

costs due to requirement compared to 

total design and construction costs for 

roundabouts are not negligible. 

Impact will be more than minimal and 

is analyzed in Regulatory Assessment.

Pedestrian Street 

Crossings – Detectable 

Warning Surfaces on 

Curb Ramps, Blended 

Transitions, and 

Pedestrian Refuge 

Islands

R208

Requires detectable warning surfaces on 

curb ramps, blended transitions, and 

pedestrian refuge islands at pedestrian street 

crossings. Detectable warning surfaces not 

required at pedestrian refuge islands that are 

cut-trough at street level and are less than 

1.8 m (6.0 ft) in length in direction of 

pedestrian travel.

DOJ 1991 Standards require detectable 

warning surfaces on curb ramps. DOJ 1991 

Standards can be used until March 15, 2012.

DOJ 2010 Standards do not require 

detectable warning surfaces on curb ramps. 

DOJ 2010 Standards effective on March 15, 

2012, but DOJ permits use before this date.

DOT Section 504 Standards require 

detectable warning surfaces on curb ramps. 

DOJ and DOT permit use of UFAS. UFAS 

does not require detectable warning surfaces

on curb ramps. DOJ does not permit use of 

UFAS on or after March 15, 2012.

Design manuals issued by all state 

transportation departments require 

detectable warning surfaces on curb ramps.

AASHTO Green Book (p. 100) and 

Pedestrian Facilities Guide (p. 85) 

recommend detectable warning surfaces on 

curb ramps.

The DOJ 2010 Standards and UFAS 

do not require detectable warning 

surfaces on curb ramps. The 

requirement adds features to curb 

ramps. Additional costs due to 

requirement compared to total design 

and construction costs for curb ramps 

are not negligible. Impact will be more 

than minimal and is analyzed in 

Regulatory Assessment.

Pedestrian At-Grade 

Rail Crossings Not 

Located Within Street 

or Highway –

Detectable Warning 

Surfaces 

R208

Requires detectable warning surfaces at 

pedestrian at-grade rail crossings not 

located within street or highway.

None Few pedestrian at-grade rail crossings 

not located within street or highway 

are constructed or altered in any year. 

Additional costs due to requirement 

are negligible compared to total design 

and construction costs for pedestrian 

at-grade rail crossings. Impact will be 

minimal.
17

Element or Facility Proposed Guidelines Other Applicable Standards Analysis

Pedestrian Signs R211.2, R410

Requires signs, other than transit signs, that 

provide directions, warnings, or other 

information for pedestrians only to comply 

with requirements for visual characters on 

signs. Permits use of audible sign systems 

and other technologies to provide equivalent 

information as an alternative means of 

compliance.

None Requirements for visual characters on 

signs are same as in DOJ 1991 and 

2010 Standards. Sign designers are 

familiar with requirements, and they 

can be easily incorporated into design 

of signs. Any additional costs due to 

the requirement are negligible 

compared to total design and 

construction costs for signs. Impact 

will be minimal.

Benches R212.6

Requires clear space adjacent to at least 50 

percent of benches at each location. Does 

not apply to benches at tables.

None Clear space can be easily incorporated 

into design of benches and the 

adjacent pedestrian circulation path. 

Any additional costs due to the 

requirement are negligible compared 

to total design and construction costs 

for benches and adjacent pedestrian 

circulation path. Impact will be 

minimal.