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### UNITED STATES ACCESS BOARD
WASHI NGTON, 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

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### Introduction

The regulatory

assessment prepared by

the Access Board for the proposed accessibility guidelines for pedestrian facilities in the public right

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- 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

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- 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

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- way are compared to DOJ 2010 S tandards, other applicable standards, and industry practices in the tables below. Table 1. Proposed Guidelines Contain Same Requirements as in DOJ 2010 Standards

Table 1 anal yz es requirements in the proposed guidelines that are the same as requirements in the DOJ 2010 Standards

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### The requirements in the proposed guidelines in Table 1 will have no impacts on state and local transportation departments compare d to th e requirements in the DOJ 2010 Standards because the requirements are the same. Table 2. Proposed Guidelines Adapt Requirements in DOJ 2010 Standards

Table 2 anal yz es requirements in the proposed guidelines that adapt requirements in DOJ 2010 Standards to allow for conditions and constraints in the public right

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- way

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### 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 loadin g zones, ramps, stairways, handrails, doors, doorw ays, gates, operable parts, clear spaces, knee and toe clearance, and reach ranges.

3 The requirements analyzed in Table 2 include: sidew alks and other pedestrian circulation paths, pedestrian street crossings, pedestrian overpasses and underpasses, pedestrian at

- grade rai l 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.

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### for accessibility

in the public right

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- 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

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- way than the requirements in the DOJ 2010 Standards . For example, where the pedestrian access r oute in a sidewalk is contained within the street or highway

right

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- 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 t ypical 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 compare d to the requirements in the DOJ 2010 Standards and industry practi ces, 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 yi eld control. Table 3. Proposed Guidelines Contain Requirements Not in DOJ 2010 Standards

Table 3 anal yz es requirements in the proposed guidelines for which there are no corresponding requirements in the DOJ 2010 Standards

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### The requirements in the proposed guideli nes in Table 3 are compared to other applicable accessibility standards and the 2009 edition of Manual on Uniform Traffic Control Devices for Streets and Highway s (MUTCD). Where the requirements in the proposed guidelines in Table 3 are the same as the re quirements 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 guideli nes 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 analy sis used the following factors to identify whether the requirement will have more than minimal impacts on state and loc al 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 purp oses?

 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 w arning surfaces on curb ramps and blended transitions at pedestrian street cros sings, detectable warning surfaces on pedestrian at

- grade rail crossings not located within a street or highway, pedestrian signs, and benches.

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### A requirement that can be easil y incorporated into the design of an element or facilit y, 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 easil y 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 co sts 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 anal ys is 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 sur faces 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 pedestri an street crossings (see R206 and R306.3.2).

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

f or Pedestrian Facilities in the Public Right

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Ele ment 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 DO J 2010 Standards. No impacts compared to DOJ 2010 Standards.

Public Toilet Facilities 206.2.4 Requires accessible route s 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.

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Ele ment or Facility DOJ 2010 Standards Proposed Guidelines Analysis Passenger Loading Zo nes 209 Requires one accessible passenger loading
zone com plying 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 com plyin g 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 s tairways that are part of means of egress to comply with 504.

504 Contains requirements for treads and risers, nosings, and handrails. R216 Requires s tairways provided on pedestrian circulation path s to com

ply w ith 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 com

plying with 505 on ram p runs with rise greater than 150 mm (6 in).

504.6 Requires handrails com

plying 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 han drails provided on pedestrian circulation paths to comply with R409

. R407.8 Requires handrails com

plying with R409 on ram p runs with rise greater than 150 mm (6 in).

R408.6 Requires handrails com

plying 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 St andards.

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Ele ment or Facility DOJ 2010 Standards Proposed Guidelines Analysis stairways. stairways. Doors & Doorways , Gates 206.5 Requires doors, doorw ays, and gates providing user passage to comply with 404

. 404 Contains requirements for manual, automatic, and pow er
- 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, doorw ays, 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 a ccessible elements. R406 Contains requirements for forward and side reach to operable parts (see R403). No impacts compared to DOJ 2010 Standards.

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### Table 2: Proposed Guidelines Adapt Requirements in DOJ 2010 Standards

to Pedestrian Facilities in the Public Right

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- Way

Ele ment or Facility DOJ 2010 Standards Proposed Guidelines Analysis Sidewalks & Other Pedestrian Circulation Paths 206.2.2 Requires a ccessible routes com plying 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

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- wa y.” R204.2

Requires p edestrian access routes complying with R302 within sidewalks and other pedestrian circulation paths located in public r ight

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- wa y.
105.5 Public right

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- wa y 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. Ad apts accessible route requirements to sidewalks and other pedestrian circulation paths in public right

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wa y. In alterations where existing physical constraints make it im practicable 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. Sam e 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

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- wa y, permits grade to equal general grade established for adjacent street or highway

. Where pedestrian access route is not contained within street or highway right

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wa y, 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 Sam e as DOJ 2010 Standards.

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Ele ment 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 Sam e as DOJ 2010 Standards.
Vertical Alignment 403.4

Requires c hanges in level to comply with 303. R302. 7.1 Requires v ertical alignment within pedestrian access routes to be generally planar , and grade breaks to be flush

. Adapts requirement for level surfaces t o pedestrian access routes in the public right

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- wa y.
Vertical Surface Discontinuities 303

Permits v ertical surface discontinuities up to 13 mm (0.5 in) maximum. Requires
v ertical surface discontinuities betw een 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. Sam e 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. Sam e 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) mi nimum

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., whe re vehicles proceed thru intersection without slowing or stopping )

R302.6. 2 Cross Slope at Midblock Crossings Permit s 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 ma ximum 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 w here vehicles slow or stop before proceeding thru the intersection

. Im pact is analyzed in regulatory assessment.

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Ele ment or Facility DOJ 2010 Standards Proposed Guidelines Analysis Pedestrian Overpasses & Underpasses Apply accessible route requirements. Apply pedestrian access route requirements with following modifications:

R20 4 .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 desig ned for both pedestrian and vehicle use and pedestrian access route is contained within street or highway right

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- wa y, 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 p edestrian 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
ram ps, 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 f

langeway gaps to be 64 mm (2.5 in) maximum. R302.7.1, R302.7.4 Requires p edestrian acc ess route to be level and flush with top of rail at outer edges of rail. Requires s urface between rails to be aligned with top of rail. Permits f langeway 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 35.1 51 (c) (i) Requires c urb 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 a cce s sible routes within sites. Curb ramps are com

ponents 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

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- wa y. 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.

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Ele ment 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 commo n 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 circu lation paths to comply with 307 and not reduce clear width required for accessible routes.

307 Contains requirements for protrusion limits, post

- mo unted 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

- mo unted objects, and vertical clearance. No impacts compared to DOJ 2010 Standards and MUTCD. Limits posted

- mo unted objects that are 685 mm (2.25 ft) minimum and 2030 mm (6.7 ft) ma ximum above sidewalk from projecting into pedestrian circulation path s 100 mm (4 in) maximum measured horizontally from post or pylon base. MUTCD requires bottom of signs installed on sidew alk s 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 surface s , dim ensions, 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, dim ensions, 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 are a r equirements to transit stops in public right

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- wa y used by buses and light rail vehicles.

Boarding Platform s 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 stop s, including No impacts compared to DOT Standards and current industry practices. * Adapts boarding platform

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Ele ment or Facility DOJ 2010 Standards Proposed Guidelines Analysis floor coordination and slope. platform and vehicle floor coordination, slope, surfaces, and pedestrian access route connections. r equirements to transit stops in public right

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- wa y 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 r equirements for detectable warning surfaces on boarding platforms to transit stops in public right

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- wa y 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 comp ly w ith requirements for height from ground and line spacing. Permits use of audible sign s 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 r equirements for route signs to transit stops in public right

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- wa y 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 r equirements for transit shelters t o transit stops in public right

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- wa y used by buses and light rail vehicles. Requires environmental controls to be proximity

- actuated instead of complying with requirements for operable p arts (see R403). Clarifies that requirements for protruding objects applies to transit shelters.

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Ele ment 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
c om plying with R309.

R309.2 Requires access aisles at accessible parallel parking spaces, where width of adjacent sidewalk or available right

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- wa y 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 si dewalk 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 ac cessible 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
r equirements to public right

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- wa y

. 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 parkin g 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

Ele ment or Facility DOJ 2010 Standards Proposed Guidelines Analysis
o perable 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 e scalators 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 impact s compared to ASME A17.1 Safety Code for Elevators and Escalators. Esc alators 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 Fa cilities in the Public Right

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- Way

Ele ment or Facility Proposed Guidelines Other Applicable Standards Analysis Alternate Pedestrian Access Routes R205 , R303 Requires alternate pedestrian access route s to compl y with referenced MUTCD standard statements when pedestrian access route s are tem

porarily closed by construction, alterations, maintenance operations, or other conditions. Referenced MUTCD standard statements require alternate pedestrian routes to be
acce ssible and detectable when pedestrian route s are tem

porarily closed by construction, alterations, maintenance operations, or other conditions. Com pliance with referenced MUTCD standard statements is mandatory (see MUTCD, section 1A.13). No impacts compare d to MUTCD.

Pedestrian Street Crossings

– Pedestrian Signal Phase Timing R20 6, 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. Com pliance with referenced MUTCD standard statements is mandatory (see MUTCD, section 1A.13). No impacts compared to MUTCD. Pedestrian Street Crossings

– A ccessible 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 21 st Century (TEA

- 21) requires audible pedestrian signals to be included in transportation plans and projects, w

here appropriate (23 U.S.C. (g)). Ac cessible 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) betw een sidewalk and curb at roundabouts with pedestrian facilities where pedestrian street crossing is not i ntended.
R206, R306.3 Requires pedestrian activated signals at roundabouts with multi

- lane pedestrian street crossings. None D etectable 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

. Im

pact will be minimal. Pedestrian activated signals add features to roundabouts. Additional

### 16

Ele ment or Facility Proposed Guidelines Other Applicable Standards Analysis R206, R306.4 Requires pedestrian activated signals at roundabouts with pedestrian street crossings at m ulti

- lane channelized turn lanes. costs due to requirement compared to total design and constru ction costs for roundabouts are not negligible. Im pact 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 Re quires 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 D OJ permits use before this date.

DOT Section 504 S tandards require detectable warning surfaces on curb ramps.

DO J 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. T he DOJ 2010 Standards and UFAS do not require detectable warning surfaces on curb ramps . The requirement adds features to curb
ram ps. Additional costs due to requirement compared to total design and construction costs for curb ramps are not negligible. Im

pa ct 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. A dditional costs due to requirement are negligible com

pared to total design and construction costs for pedestrian at

- grade rail crossings

. Im pact will be minimal.

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Ele ment 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 pedestrian s 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 sig ns 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 co sts 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. Im

pact will be minimal.