2021 ADA Self-Evaluation for Transportation
I ACCESSIBL :
BOULDER
ADA SELF-EVALUATION AND TRANSITION PLAN
City of Boulder
ADA Self-Evaluation for the Transportation System
Spring 2021
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Acknowledgements
Lead Transportation Staff
Jenny Godwin, Associate Transportation Planner
Melanie Sloan, Transportation Planner II
Noreen Walsh, Senior Transportation Planner
Jon Brachna, Capital Improvement Projects Intern
Contributing Departments
Capital Improvements Program (CIP), including the Pavement Management Program (PMP)
Finance: Risk Management Division
Historic Preservation
Planning & Development Services (P&DS)
Public Information Resources (IR)
Transportation and Mobility Department: Capital Projects, Transportation Planning, and Transportation
Operations Divisions
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Table of Contents
PART 1 – INTRODUCTION
1.1 Americans with Disabilities Act (ADA)
1.2 City of Boulder
1.3 ADA Self-Evaluation for the City’s Transportation System
PART 2 – LITERATURE REVIEW & BACKGROUND
2.1 Guiding Policies & Programs Overview
2.2 Other Municipalities
2.3 External Partners
PART 3 – BOULDER EXISTING CONDITIONS
3.1 Guiding Policies & Programs Overview
3.2 Programs to Construct/Upgrade Accessible Facilities
3.3 Infrastructure Data
Figure 1: City of Boulder Accessible Pedestrian Signal Locations
Figure 2: City of Boulder Missing Sidewalk Links
Figure 3: Transit Stop Ownership
Figure 4: Transit Stop Snow Maintenance Responsibility
Figure 5: Annual Sidewalk Repair Program Prioritization
Figure 6: Curb Ramps Updated/Installed to Meet ADA
3.4 Community Input
PART 4 – FINDINGS & AREAS OF IMPROVEMENT
4.1 Existing City Best Practices
4.2 Major Gaps & Challenges
Category #1: Consistency in Standards/Design/Construction
Category #2: Communications/Engagement
Category #3: Data Tracking/Monitoring
Category #4: Funding/Coordination/Prioritization
PART 5 – NEXT STEPS
5.1 Transition Plan
DEFINITIONS
APPENDIX
Outreach Summary
Barriers Mapping Questionnaire
Inventory Consultant Investigation
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Part 1: Introduction
1.1 Americans with Disabilities Act (ADA)
The American with Disabilities Act (ADA) is a wide-ranging civil rights law for persons with
disabilities that prohibits discrimination and ensures equal opportunity for persons with
disabilities in employment, state and local government services, public accommodations,
commercial facilities, and transportation.1
Legislative Requirements
ADA Title II
ADA Title II provides guidance that cities must follow, and within subtitle A, the guidelines protect
qualified individuals with disabilities from discrimination on the basis of disability in services, programs,
and activities provided by state and local government entities. Title II extends the prohibition on
discrimination established by section 504 of the Rehabilitation Act of 1973, as amended, 29 U.S.C. 794,
to all activities of state and local governments regardless of whether these entities receive federal
financial assistance.2 Key Title II requirements include reasonable accommodation for employees with
disabilities; program accessibility; effective communication with people who have hearing or vision
disabilities; and accessible new construction and alterations. Each agency is responsible for enforcing its
own regulations.3
Title II ADA Self-Evaluation & Transition Plan Requirements
Title II outlines requirements applicable to public entities with 50 or more employees, in order
to ensure that maintaining ADA compliance is a priority, that community member ADA-related
complaints are routed appropriately and that where a lack of compliance exists, appropriate
timeframes for achieving ADA compliance are outlined. Specific requirements include:
1) Developing a Self-Evaluation to review current services, policies, and practices, both
in language and in application, for meeting ADA compliance
2) Providing a process by which interested community members, especially those
persons with disabilities, can offer comments and feedback on the Self-Evaluation
3) Developing a grievance procedure so that compliance issues may be addressed in a
timely manner
4) Designating an employee responsible with overseeing Title II compliance
5) Developing an ADA Transition Plan if structural changes are necessary for achieving
program accessibility
Additional Resources:
https://www.ada.gov/ada_title_II.htm
https://www.ada.gov/regs2010/titleII_2010/titleII_2010_regulations.htm
1 Source: U.S. Department of Justice
2 Source: U.S. Department of Justice, Civil Rights Division
3 Source: U.S. Department of Justice, Civil Rights Division
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Recommended Escalation Procedures
1. Complete an Inquire Boulder ticket. These can be found via the Americans with Disabilities Act
topic under the People with Disabilities Information section on the City of Boulder website.
When submitting a ticket, please be sure to include relevant images, files or a physical notation
of the accessibility issue you would like addressed, as relevant. These tickets are then sent to
the correct response personnel within the City.
2. If you do not feel your issue was adequately resolved, you can file a formal ADA Grievance
Procedure with the City’s ADA Coordinator, James Brown via the webpage.
3. At any point, or if the above processes did not provide an adequate issue resolution, you can file
a Title II violation with the Department of Justice via the procedures outlined below.
Regulatory Agencies Resources (Department of Justice)
Complaints of Title II violations may be filed with the Department of Justice within 180 days of the date
of discrimination. In certain situations, cases may be referred to a mediation program sponsored by the
Department. The Department may bring a lawsuit where it has investigated a matter and has been
unable to resolve violations.
U.S. Department of Justice
Civil Rights Division
950 Pennsylvania Avenue, N.W.
Disability Rights Section -NYAV
Washington, D.C. 20530
www.ada.gov
(800) 514-0301 (voice)
(800) 514-0383 (TTY)
Title II may also be enforced through private lawsuits in federal court. It is not necessary to file a
complaint with the DOJ or any other federal agency, or to receive a "right-to-sue" letter, before going to
court.4
Undue Burden
Under ADA, the City of Boulder is not required to provide an accommodation that imposes an undue
burden on the operation of the city's business. Undue burden means significant difficulty or expense is
incurred in the provision of accommodation. Undue burden includes, but is not limited to, financial
difficulty. Undue burden refers to any modification that would be unduly costly, extensive, substantial,
or disruptive, or that would fundamentally alter the nature of operation of the business of the city.
The following factors shall be considered in determining whether a program modification would create
an undue burden: the nature and cost of the modification; the financial resources of the city available to
make the modification; the impact the expense of the accommodation will have on the affected city
operation; and the permanence of the alterations affecting the site.5
4 Source: U.S. Department of Justice
5 Source: City of Commerce, California ADA Self-Evaluation and Transition Plan
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TYPES OF DISABILITIES
IN COLORADO INCLUDE:
Mobility
Serious difficulty walking ore.limbing stairs
Cognition
Serious difficulty concentrating,
remembering or making decisions
Independent Living
Difficul ty doing errands alone, such as
vis iting a doctor's office or shopping
Hearing
Deaf or serious difficulty hearing
Vision
Blind or serious difficulty seeing, even
when wearing glasses
Self-Care
Difficulty dressing or bathing"'
8.2%
f 7 .9%
4 .9%
QI) 4.3%
0 2.8%
f 2.4%
1.2 City of Boulder
In Boulder, we believe that mobility for people of all abilities is a fundamental right. We strive to
provide a transportation system with a variety of safe, accessible and sustainable travel options
that connect people with each other and the places they want to go. This builds a stronger
community where everyone feels a sense of belonging.
City Profile
The ADA defines a person with a disability as having “a physical or mental impairment that substantially
limits one or more major life activities. Major life activities include, but are not limited to, caring for
oneself, performing manual tasks, seeing, hearing, eating, sleeping, walking, standing, lifting, bending,
speaking, breathing, learning, reading, concentrating, thinking, communicating, and working.”6
Of the City of Boulder’s 107,125 residents, 7,113 (8.3%)
have a disability.7
About 63% of those residents with a disability are age
sixty-five or older.8
In addition, nearly 6% of employed Americans will
experience a short-term disability (under 6 months) each
year, caused by illness, pregnancy or injury.9
Over 70% of Americans with travel-limiting disabilities
compensate by reducing their daily travel.10
The graphic above displays additional data regarding the major disability types in the state of Colorado.
For further statistics, refer to the ADA 101 Brochure at bit.ly/ADA101_brochure.
City ADA Plan Efforts to Date
Prior to this current update, the City of Boulder’s previous ADA Plan was created in 1991 and contained
a short chapter relevant to transportation infrastructure’s ADA compliance. The plan is available in print
but not online.
The city’s 2014 Transportation Master Plan (TMP) and 2019 TMP both called for the update of the city’s
transportation ADA Self-Evaluation and Transition Plan. The 2019 TMP’s vision and goals for
transportation are to create “a safe, accessible and sustainable multimodal transportation system
connecting people with each other and where they want to go.” To achieve this, “our transportation
system will be safe, equitable, reliable, provide travel choices, support clean air and our climate
commitment.” Additionally, a Boulder policy contained within the TMP is to develop a complete,
6 Source: U.S. Department of Labor
7 Source: U.S. Census Bureau, 2013-2017 American Community Survey 5-Year Estimates
8 Source: City of Boulder Human Services Strategy: Mapping Our Future, 2012-2017
9 Source: Council for Disability Awareness, 2018
10 Source: Bureau of Transportation Statistics, 2018
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equitable and accommodating transportation system to meet the needs of those with mobility
impairments, older adults, youth, non-English speakers and low-income persons. A TMP key next step is
Action 9.C, which calls for completing and implementing the ADA Self-Evaluation and Transition Plan for
the city’s transportation system.11
In February 2020, the City’s Risk Management Office led the release of an RFP to find a consultant to a)
review existing city policies for ADA compliance and act as an on-call reviewer for proposed
development plans and optionally, b) to conduct an ADA inventory evaluation of street furniture, on-
street parking, sidewalks, curb ramps/detectable warning surfaces, pedestrian crossings and accessible
pedestrian signals. Unfortunately, due to the budgetary shortfalls resulting from COVID-19, this effort
has been delayed until at least 2022.
ADA Coordinator and Grievance Procedure
As noted in the Title II section above, municipalities are required to develop an ADA grievance
procedure and establish a staff ADA Coordinator to review community complaints. To further this effort,
city staff created a new page on the city website which outlines the city’s ADA policies and provides a
Complaint Form to file an ADA access grievance with the appropriate city department. The complaint
procedure is outlined step-by-step to ensure transparency and accountability.
Additionally, in Fall 2020, staff developed a new Inquire Boulder topic area for “People with Disabilities
Info” so that residents can submit ADA-related questions or problems to staff for review. The topic has a
spatial location listed as well, so requests can then by pushed into the Beehive asset management
system and reassigned as a work order (as needed, say for a damaged curb ramp) to the appropriate
work group.
View the webpage here.
City of Boulder ADA Coordinator
James Brown, City of Boulder Risk Manager
Email: RiskManagement@bouldercolorado.gov
Phone: 303-441-3075
City of Boulder ADA Grievance Procedure
Americans with Disabilities Act Notice
ADA Complaint Form
ADA Complaint Procedures and Instructions
1.3 ADA Self-Evaluation for the City’s Transportation System
Scope of Evaluation
The focus of the ADA Self-Evaluation for the City of Boulder’s transportation system centers on five main
facility types which enable the functioning of accessible pedestrian access routes.
11 City of Boulder 2019 Boulder Transportation Master Plan
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Sidewalks Multi-Use Paths Curb Ramps Pedestrian Signals
& Crossings
Transit Stops
These facilities include:
See the graphic below for a brief summary of the quantity of these facilities present within city limits.
The ADA Self-Evaluation also examines existing city programs, policies,
and construction standards/guidelines to understand and promote
best practices for accessible design.
The city’s transportation division recognizes that to obtain a complete
understanding of where there is not ADA compliance within the above
facility types, a precise and comprehensive inventory should be
conducted. However, given the cost of a comprehensive inventory
and current funding constraints, completing a full citywide inventory
is not realistic to obtain at this time.
There are achievable steps, however, to populate our database of
accessibility related information for transportation infrastructure on a
project-level basis. For example, the improved accuracy and storage
capability of the city’s Beehive asset management system will enable
staff to note improvements which bring facilities up to ADA
compliance during capital or operations projects.
City staff is collaborating with Public IR to develop a GIS collector app
to gather accessibility-related data and is in the process of
determining whether a volunteer-run data effort in key
neighborhoods, such as those identified in the 2019 suite of city plans
(e.g., the Transportation Master Plan, Pedestrian Plan, and Low Stress
Walk and Bike Network Plan) may be feasible in the future. These
plans offer a wealth of guidance for prioritizing areas in need of
improvements and will help inform the development of priorities for
upgrading accessible facilities in the ADA Transition Plan. Project staff
will begin development of this plan in early 2021.
Guiding Principles
In order to continue fostering an inclusive and accessible city for all Boulder residents and visitors, the
city has outlined a few key priorities to frame this Self-Evaluation work and support those workgroups
implementing, upgrading and maintaining accessible facilities. These include:
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1018 -1011
TRANSITION PLAN
Q3-Q4
1011
TRANSITION PLAN WORK
BEYOND
•
~ PUBLIC ENGAGEMENT & COMMUNICATIONS p
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report
@
report
000
SAFETY: At the heart of the City of Boulder’s transportation policies is the Vision Zero
Program, which recognizes that even a single traffic death is unacceptable. The 2019
Safe Streets Report identifies both areas of safety concern to address as immediate
improvement priorities and programmatic/policy-level adjustments to ensure design
standards support the creation of safe and accessible facilities for all. Protection of
those most vulnerable road users (including pedestrians, cyclists, children, seniors and
people with disabilities) remains a high priority.
ACCESSIBILITY: Providing access for all, whether someone is rolling to dinner on Pearl
Street or navigating a historic neighborhood with a walker to see the fall colors, is a
foundational priority. Accessibility is a measurable attribute, but it is also an indicator of
inclusion and belonging. Honoring that access needs may vary, staff worked with a
variety of stakeholder groups throughout the engagement phase to obtain their
feedback on access barriers, while also providing an online map where participants
could log particular barriers with notes and photos to describe their experience.
INTEGRATION WITH RELATED PLANS: A number of recently adopted city plans offer
integrated support for furthering accessibility goals, including the 2019 TMP, Pedestrian
Plan and Low-Stress Walk and Bike Network Plan. These plans speak to a citywide goal of
creating and maintaining transportation facilities for people of all ages and all abilities.
Timeline
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Part 2: Literature Review & Background
2.1 Guiding Policies & Programs Overview
An overview of relevant standards, guidelines and policies at both the federal and state level
which inform accessible design guidelines and prioritize construction of accessible facilities
within the City of Boulder. Also see Technical Requirements section above.
Federal Level
1990 Americans with Disabilities Act (ADA)
The Act was signed into law on July 26, 1990 as a wide-ranging civil rights law that prohibits, under
varying circumstances, discrimination based on disability.
2002 ADA Accessibility Guidelines (ADAAG)
General and technical requirements that are applied during the design, construction and alternation of
buildings and facilities covered by titles II and III of the ADA, which are required regulations issued by
federal agencies, including the Department of Justice and the Department of Transportation.12
ADAAG forms the design basis for all city construction projects. In some cases, as with construction of
curb ramps, city staff design transportation features to PROWAG (see below) instead, which go above
and beyond ADAAG requirements.
View the ADAAG 2002 amended document here: https://www.access-board.gov/guidelines-and-
standards/buildings-and-sites/about-the-ada-standards/background/adaag
2011 Draft Pedestrian Right-of-Way Access Guidelines (PROWAG)
The U.S. Access Board developed new draft PROWAG to address accessibility for pedestrian access to
facility types in greater detail than is covered in ADAAG, including multi-use paths, curb ramps, and
pedestrian signals, and other components of public rights-of-way. The Access Board is a federal agency
tasked with providing design guidance and developing accessibilty guidelines to ensure people with
disabilities receive equal access to the “built environment, transportation, commuications, medical
diagnostic equipment, and information technology.”
The draft PROWAG would ensure that access for persons with disabilities is provided wherever a
pedestrian way is newly built or altered, and that the same degree of convenience, connection, and
safety afforded the public generally is available to pedestrians with disabilities. Once these guidelines
are adopted by the Department of Justice, they will become enforceable standards under Title II of the
ADA. Design standards included in PROWAG which contain stricter guidelines than included in ADAAG
would superceed the current guidelines.
If adopted, draft PROWAG would require accessible pedestrian signals and pedestrian pushbuttons to be
standardized for new signal installation and would also require these accessible features to be included
when the signal controller and software are altered, or the signal head is replaced.
View the full draft guidelines here: https://www.access-board.gov/attachments/article/743/nprm.pdf
12 Source: United States Access Board
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Seals
Crack Filling and Sealing
Diamond Grinding
Dowel Bar Retrofit
Scrub Sealing
Slurry Seals
Surface Sealing
Spot High-Friction
Treatment
Fog Seals
Joint Crack Seals
Joint Repairs
Pavement Patching
Maintenance
Alteration
Add11!on of New La er of As halt
Ca e Seals
Hot In-Place Re elm
Microsurfacm Thm -L1ft
Mill & F1II/Mill & Overla
New Constructton
0 en-raded Surface Course
Re a 1 1tat10n an Reconstruction
2013 Department of Justice Briefing Memo -ADA Resurfacing Technical Assistance
The graphical representation of the 2013 DOJ
memo (to the left) was prompted to clarify when
ADA requirements are triggered, separated by
maintenance versus alternation activities in
pavement management work.
The memo explores differing interpretations and
inconsistences in application for when curb ramp
construction is triggered in a project’s scope of
work. General maintenance work does not
trigger ADA upgrades. However, when project
work in the “alteration” category occurs, then
curb ramps should be installed within the scope
of project work, to meet ADA standards for the
project.13
The City’s Pavement Management Program begins each paving season with curb and gutter repair work
and ADA compliant curb access ramp upgrades, which offers a good example of city practices which
adhere to advisement from this DOJ memo.
2009 (with 2011 revisions) Manual on Uniform Traffic Control Devices (MUTCD)
The MUTCD defines the standards used by road managers nationwide to install and maintain traffic
control devices on all public streets, highways, bikeways, and private roads open to public travel. The
MUTCD, which has been administered by the FHWA since 1971, is a compilation of national standards
for all traffic control devices, including road markings, highway signs, and traffic signals. It is updated
periodically to accommodate the nation's changing transportation needs and address new safety
technologies, traffic control tools, and traffic management techniques. Additionally, ADA standards
point to MUTCD for guidance on providing alternative, accessible routes during construction. There is
also an allowance for a temporary lack of access due to short-term maintenance needs, such as an
emergency street feature repair. Use of the MUTCD is mandatory on all public highways, roads and
streets in Colorado.
The MUTCD also provides standards to follow when installing pedestrian pushbuttons, which must be
both usable and accessible. “Usable” signals must meet surface slope, reach range and operable parts
requirements. “Accessible” signals must include additional features beneficial to sight-impaired
pedestrians, detailed in the Definitions chapter. Standards for accessible pedestrian signals (APS) are
included within the MUTCD standards but these are not outright required. In terms of APS guidance, the
MUTCD indicates that pushbuttons should be located “as close as possible to the crosswalk line furthest
from the center of the intersection and as close as possible to the curb ramp.”
13 Source: U.S. Department of Justice and U.S. Department of Transportation, Joint Technical Assistance on Title II of the Americans with
Disabilities Act Requirements to Provide Curb Ramps When Streets, Roads, or Highways Are Altered through Resurfacing
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State Level
2018 Colorado Department of Transportation (CDOT) Standards
CDOT’s Roadway Design Guide addresses several key design standards and safety recommendations,
including accessible pedestrian design guidance (based on PROWAG) and safety within traffic
engineering. In May 2019, CDOT developed a new curb ramp standard that is more applicable to
common conditions and accounts for tolerance in design. In 2020, the City of Boulder updated the city’s
Design and Construction Standards (DCS) to adopt CDOT’s new curb standards. Current practice holds
that if the City is performing roadway work next to a CDOT curb ramp, staff will update the curb ramp
features to meet ADA compliance, as necessary.
The city recognizes the latest CDOT Standard Drawings (currently 2019), except when city standards
are more stringent, staff designs to the more robust of the two given design constraints.
• M-608-1 for sidewalk ramps (2019 CDOT Curb Ramp standards)
• M-609-1 for driveway ramps associated with attached sidewalks (2012 CDOT curb, gutters and
sidewalk standards) with ROW Inspector approval required prior to installation
2.2 Other Municipalities
To support the development of this Self-Evaluation, city staff conducted best practice research on ADA
Plan processes. Interviews with those who administered ADA Plan efforts in Eugene, OR and Adams
County, CO highlighted public engagement best practices (such as outreach at community festivals),
options for conducting an ADA compliance inventory (spearheaded by interns with consultant quality
checks or completed by seasonal maintenance staff using a GIS-based app, for example) and strategies
for noting where design exceptions apply (attaching a design engineer’s variance).14 15
The City of Seattle offered smart data management recommendations, including using GIS data to map
planned curb ramp construction or reconstruction updates and subsequently updating asset quality
maps frequently to note completed improvements. From a mapping perspective, Seattle also discovered
innovative ways to chart accessible routes based on sidewalk quality ratings logged during their ADA
data inventory process. Such displays provide useful examples for the city to consider as we continue to
update our best practices for access management and mapping.16
2.3 External Partners
Due to the nature of travel and utilization of various travel modes, accessibility does not exist
within a single municipality’s bubble. In development of the city’s ADA Self-Evaluation for the
transportation system, it is crucial to understand ongoing efforts of entities which City of Boulder
residents with disabilities may interact with frequently to meet their mobility needs.
Boulder County
Boulder County released an RFP for development of an ADA Self-Evaluation & Transition Plan for
Boulder County facilities, communications (including a website assessment), trailheads, exterior facilities
and programs in August 2019, to include project management, physical barrier surveys/reports,
inventory database/mapping, county staff training and on-call ADA support as needed. The County
14 Jess Hastings, PE, 2018 Phone interview with Melanie Sloan
15 Jennifer Willer, Transportation Planner, 2018 Phone interview with Melanie Sloan
16 Michael Shaw, ADA Coordinator and Emily Burns, Asset Management Advisor, 2019 Phone interview with Jenny Godwin
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chose Meeting the Challenge, based out of Colorado Springs, as their consultant. Their ADA Plan effort
continues to move forward in 2020 and will conclude in 2021 with a completed Transition Plan to
prioritize the County’s ADA projects moving forward.
Regional Transportation District (RTD)
The Regional Transportation District (RTD) owns and operates a majority of Boulder's Community Transit
Network (CTN). The City of Boulder collaborates with RTD, Via Mobility Services, and the University of
Colorado Boulder to plan and fund Boulder's local bus service. RTD also operates the Access-a-Ride bus
service, offered to persons with disabilities who cannot access the existing bus and rail systems.
Ensuring the accessibility of bus stops within the City will involve a partnership with RTD to inventory
and assess current conditions at stops. See the Major Gaps & Challenges section for further details and
improvement recommendations. Staff spoke with RTD in early 2020 to discuss accessibility policies and
practices related to transit stops. Of the 619 bus stops within city limits, ownership of amenities and
responsibility for maintenance go hand in hand. 481 bus stops are under the city’s ownership and
maintenance purview, 125 are under RTD’s and 24 are under the University of Colorado Boulder’s (CU)
(see the Infrastructure & Data section for an ownership map).
Initial takeaways from the discussion with RTD’s ADA Manager include:
RTD & ADA COMPLIANCE: There are over 10,000 stops in RTD’s system. RTD does not
technically own any stops, as the right-of-way where stops are located is owned by the
municipality. RTD may own shelters or other features. According to federal regulations,
transportation entities are not required to conduct an ADA Self-Evaluation, and there are no
immediate plans for RTD to complete one.
COMPLIANT DESIGN: The best RTD representatives for the City to utilize when including RTD on
a project team is a member of the Capital Program Department. When a stop is relocated or
improved it triggers ADA upgrades, as needed. RTD attempts to partner with municipalities
where possible to install bus pads/stops, but the agency typically does not install sidewalk. Any
contractor completing work at RTD stops should be utilizing the ADA bus stop form to ensure
ADA compliance is met.
SNOW MAINTENANCE: The property owner adjacent to the stop is responsible for clearing the
sidewalk. For the 2020/2021 snow season, the city has a contract to plow 39 high-use bus stops
twice a day, or to the extent that human and financial resources permit. RTD and the University
of Colorado Boulder plow other high ridership stops. Snow removal is performed at the
remaining RTD transit stops on a limited basis by city staff or contractors, typically by request.
NOTIFICATION OF CONCERNS: In general, RTD staff will directly notify City staff if they receive
ADA compliance complaints specific to transit stops owned and maintained by the city. RTD staff
is also involved in the review of design and engineering plans for new bus stops and bus stop
improvements being constructed by the city, providing an additional perspective related to ADA
access for passengers.
Via Mobility Services
Via Mobility Services operates the HOP route which circulates through the city and also offers point-to-
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point pick-up and drop-off services for residents with mobility impairments. The HOP buses and service
are ADA-compliant. HOP buses each have a ramp to accommodate passengers who use wheelchairs,
and all the buses can "kneel," meaning they can be lowered to curb height for easier boarding. The
driver asks those using a wheelchair if they want to be secured or not. If yes, the driver secures the chair
with specialized straps that hook to the floor of the bus. An electronic annunciator broadcasts each stop
through a speaker to help those with vision impairments and an interior electronic sign shows the next
stop for those who have a hearing impairment.
HOP drivers receive training on using the ramp and securement equipment with refresher training every
year. Drivers also receive training on the appropriate treatment of those who have disabilities. HOP
drivers also perform pre-and post-trip inspections of their vehicles to make sure all of the equipment,
including ADA equipment, is in working order.
Via also provides Access-a-Ride service that is ADA-compliant, door-to-door transportation in vehicles
with wheelchair lifts for Boulder residents who have disabilities. That service complements the fixed-
route, public bus services in the city for those who cannot easily use the public transit system. Via
drivers assist passengers with boarding and off-boarding and will provide door-through-door service
upon request.17
Part 3: Boulder Existing Conditions
3.1 Guiding Policies & Programs Overview
An overview of the relevant local standards, guidelines, policies and programs which influence
accessible design and construction of accessible facilities within the City of Boulder. Many of
these are living documents, evolving to match local and regional recommendations.
Design Standards
The city’s design standards outlined below provide guidance for the construction of transportation
infrastructure. These reference documents ensure that meeting ADA compliance in design is a project
priority alongside other city goals.
2019 City of Boulder Design and Construction Standards (DCS)
All civil engineering design completed within the city limits (including new or rebuilt sidewalks, curb
ramps and multi-use paths) must conform to the DCS.
The goal of these standards is to protect public health, safety and welfare in both the construction and
maintenance of public improvement projects within the city. The comprehensive nature of these
standards applies to the provision of necessary right-of-way, transportation and utility services.
The sections of the DCS quoted below are most relevant to ADA requirements, including those related
to sidewalk and multi-use path design, as well as the acccessibility of construction detours.
17 Lisa Curtis, 2020 Email Interview with Jenny Godwin
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Chapter 2: Transportation Design
2.08 Sidewalks
(A)Required
Sidewalks are required on both sides of all new streets, except for residential streets that were
approved without required sidewalks pursuant to Chapter 9-12, “Subdivision,” B.R.C. 1981, and
Section 2.09, “Residential Streets.”
(B)Conformance with the Transportation Master Plan
Off-street sidewalks may be required as part of any project or development proposal in
conformance with the TMP.
(C) Compliance with Americans with Disabilities Act (ADA)
All public sidewalks shall comply with the requirements of the ADA’s “Standards for Design,”
(see 2010 DOJ standards) which includes without limitation sidewalk widths, grades, locations,
markings, surface treatments, and access ramps.
Additionally, Chapter 8 of the DCS outlines proposed measures to address impacts to
pedestrians and other non-automobile, wheeled users, intended to minimize the adverse effects
of sidewalk and multi-use path temporary closures. In general, detour routes are recommended
to offer a reasonable accommodation via a comparable facility in type and width to that closed
for construction.
Chapter 8: Temporary Traffic Control Plan
(6) Sidewalks: The following special considerations shall be given to proposed closures of
sidewalks:
a. Adjacent to streets not classified as “Local” in the Transportation Master Plan;
b. Located in the Central Area General Improvement District (CAGID) or University Hill
General Improvement District (UHGID) boundary areas;
c. Impacted for more than seven days;
d. Where no other sidewalk exists adjacent to the roadway;
e. Serving a school zone or transit stop, or
f. Requiring pedestrians to detour to a facility on a separate parallel roadway. Such
proposed closures must demonstrate that impacts cannot be avoided through
alternative construction methods, that the duration and extent of impacts has been
minimized, and that an adequate detour has been provided.
(8) Multi-Use Paths: Special consideration shall be given to proposed closures of sidewalk
facilities which have been designated as multi-use paths. Such proposals shall demonstrate that
impacts cannot be avoided through alternative construction methods, that the facility cannot be
reasonably relocated through reassignment of vehicle lanes or other existing facilities, that the
duration and extent of impacts has been minimized, and that an adequate detour has been
provided. Detours routes must be of similar width and surface type to the permanent facility.
2.13 Transit Stop Facilities
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New transit stops and enhancements to existing transit stops shall be designed in accordance
with RTD’s “Bus Infrastructure Standard Drawings” and with consideration of NACTO’s “Transit
Street Design Guide.”
Chapter 11: Technical Drawings
CDOT & RTD Standard Drawings
The DCS contains three RTD standard drawings that staff refer to during design, which include:
• SD-A100A: Architectural Pedestrian Shelter Plans
• SD-C120: Civil Bus Stop Layout
• SD-C123: Civil Bus Pad
DCS Updates
In 2019, Phase I updates were made to the DCS to develop transportation standards that align with
industry best practices, increase travel safety and implement approved TMP policies. Staff has heard
feedback from community members and stakeholders and has considered and incorporated their
feedback into the proposed changes.
Phase II of the update will speak to high-level TMP goals and begin in 2021. 2021 updates will focus on
sight trianges, street geometric design, landscape maintenance and tech drawings. Accessibility focused
updates are flagged to be addressed in future years work, as budget and staffing allows.
Desired future DCS updates include:
• 2.03 traffic study
• BRC Title 8: sidewalk liability
• 8.02 traffic signal standards
• 8.04 work zone traffic control
• 2.08 sidewalk, including width standards (from 4 feet to 5 feet minimum and 5 feet to 6 feet
preferred design width)
2020 City Muncipal Code (Boulder Revised Code: BRC)
The BRC acts as a charter for the City as a municipal government. Available both online and in written
form, the BRC includes adopted ordinances not yet codified as well. Of most relevance to this ADA Plan’s
scope is TITLE 8 – PARKS, OPEN SPACES, STREETS, AND PUBLIC WAYS.
BRC Standards for Sidewalk Reconstruction/Replacement
(b)Any existing sidewalks, or portions thereof, shall be reconstructed or replaced:
(1)Where any vertical displacement exceeds three-quarters of an inch;
(2) Where any lateral displacement of adjoining sidewalk exceeds one inch;
(3)Where the surface condition of the sidewalk has deteriorated, cracked, settled, or
chipped, so as to create or constitute a hazard or unsafe condition to the public;
(4) Where the transverse slope of the sidewalk exceeds one inch per foot or in which the
combination of transverse or longitudinal grade is insufficient for adequate drainage;
(5) Where the sidewalk is less than four feet wide in any residential zoning district in the
city and less than six feet wide in any business or industrial zoning district in the city, if
16
the sidewalk or any portion thereof constitutes a hazard to pedestrian safety; or
(6) Where there is not at least a five-foot transition in the direction of the sidewalk on
any sidewalk adjacent to a driveway.
Historic Preservation Guidelines
2007 City of Boulder General Design Guidelines for Boulder’s Historic Districts and Individual
Landmarks
2.5 Sidewalks
Original historic walkway materials offer an important character element and should be retained
and preserved. Flagstone should be replaced with flagstone and concrete with concrete, unless
a block is predominantly paved with flagstone, then flagstone can be substituted for removed
concrete. New walkways should be “compatible in location, pattern, spacing, dimensions,
materials and color with existing walkways that contribute to the overall historic character of
the area.” New sidewalks are required to meet ADA guidelines.
8.8 Americans with Disabilities Act
Places of public accommodation are required to provide access to their services and programs
under provisions of the Americans with Disabilities Act. In the case of historic buildings, some
provision for using alternative measures exists if the property is historically or architecturally
significant enough to merit such treatment. When changes to a building or site are necessary,
careful consideration must be given to how the changes can be incorporated without
compromising the integrity of the historic building, its character defining features, or its site.18
2013 A Plan for the City of Boulder’s Historic Preservation Program
The city’s Historic Preservation program intersects with many other city departments, reflecting the
institutional value of historic preservation in Boulder. This arrangement also illustrates the complex
relationship of historic preservation with other city goals, such as housing, economic vitality,
transportation, and environmental sustainability. In addition, the Community Planning and Sustainability
Department and Historic Preservation program collaborates with the Development Review, Land Use,
and the Local Environmental Action divisions. For example, alteration permits/certificates pertaining to
disability access are evaluated on a case-by-case basis to provide maximum accessibility with minimum
impact to historic structures. Pavement Management Program staff follow a best practice of obtaining
alteration certificates when planning to perform work in historic districts.
The City of Boulder is committed to providing universal access to people with disabilities through the
building code. To this end, the Historic Preservation program should continue to explore innovative
ways to make sure that all designated historic properties meet the Americans with Disabilities Act and
provide a high level of life safety without compromising important historic character defining features.
The Plan identifies the need for collaboration across departments to achieve the City’s commitment to
universal access to historic properties (in relation to this Plan’s scope, most typically tied to curb ramp
and sidewalk upgrades).19
18 Source: City of Boulder, Landmarks Preservation Advisory Board
19 Source: City of Boulder, Community Planning & Sustainability Department
17
Long Range Planning
2019 Transportation Master Plan (TMP)
The 2019 TMP’s vision and goals for transportation are to create “a safe, accessible and sustainable
multimodal transportation system connecting people with each other and where they want to go.” To
achieve this, “…our transportation system will be safe, equitable, reliable, provide travel choices,
support clean air and our climate commitment.” Additionally, a Boulder policy contained within the TMP
is to develop a complete, equitable and accommodating transportation system to meet the needs of
those with mobility impairments, older adults, youth, non-English speakers and low-income persons. A
TMP key next step is Action 9.C, which calls for completing and implementing the ADA Self-Evaluation
and Transition Plan for the city’s transportation system.
2019 Pedestrian Plan
The 2019 Boulder Pedestrian Plan’s vision and goals include creating a walkable, accessible, barrier-free
pedestrian system for everyone. One component of this effort is enhancement of snow removal
practices, which will enhance access to transit and more generally, improve accessibility outcomes for
those using mobility devices. The Plan recognizes that not all pedestrian facilities are accessible
currently, and this can pose challenges and safety concerns for those using mobility devices. Immediate
priorities outlined within the plan include completion of the ADA Self-Evaluation and Transition Plan.
2019 Low-Stress Walk and Bike Network Plan
In conjunction with the Pedestrian Plan, the Low-Stress Walk and Bike Network Plan aims to foster a
network of low-stress facilities to increase walking safety, comfort and accessibility for those of all ages
and abilities. Future study of the plan’s vision for Neighborhood GreenStreets and Pedestrian
Improvements Areas (PIAs) could lead to enhanced integration with the ADA Self-Evaluation &
Transition Plan’s outlined needs, such as sidewalk and curb ramp installation and upgrades. Data
collected from the ADA Plan’s efforts will feed in to cost estimates for PIA upgrades.
Traffic Operations & Safety Guidelines
2011 Pedestrian Crossing Treatment Installation Guidelines (PCTIG)
There are a variety of pedestrian crossing treatments present in the City of Boulder, all in keeping with
ADA standards. The most basic crossing type is a signed/marked crosswalk, with additional features
added depending on physical conditions and pedestrian and vehicle volumes, and vehicular speeds.
These additional features include “STATE LAW – YIELD TO PEDESTRIANS” signs, Rectangular Rapid Flash
Beacons (RRFBs), High-Intensity Activated Crosswalk (HAWK) beacons, and curb extensions with median
refuge islands for pedestrians.
ADA standards for crossings include:
• The requirement that crosswalk surfaces be firm, stable and slip resistant, with no large gaps
present and be built to at least 48 inches in width.
• Refuge islands must be at least 5 feet wide and contain detectable warning surfaces.
• Additionally, the ADA standard requirements for pedestrian refuge islands dictate the addition
of accessible provisions, as opposed to medians (which lack pedestrian waiting areas) and
therefore are not held to the same accessible standard.
18
The PCTIG uses minimum pedestrian volume thresholds to determine the appropriate crossing
treatment type. The presence of young, elderly, and disabled pedestrians receives greater weight. The
“Pedestrian Crossing Treatment Installation Guidelines” state a goal for all crosswalks to comply with
the ADA to maximize user mobility. And “…where a new crosswalk is installed in a curbed roadway, curb
ramps will include a detectable warning surface.” Additionally, the guide recognizes that installing raised
pedestrian crossings at right-turn bypass islands helps improve access and visibility for pedestrians and
other users. Also, to note, the installation of crossing treatments triggers the addition of pedestrian curb
ramps where not currently existing or upgrading of non-compliant ramps, as applicable. The city’s
current practice is to re-evaluate, upgrade or retrofit crossings when the engineer provides this
direction, triggered by a specific request or a safety evaluation (such as one due to a crash trend).
2020 Update: Though staff intended to update the PCTIG guidelines in 2020, due to reduced financial
and staff resources resulting from the COVID-19 pandemic, this effort has been put on hold. Staff will
revisit the need for an update when funds become available (timeframe unknown).
2018 Traffic Signal Practices Manual Working Draft
The City’s current traffic signal practices guidance was updated in 2018 to document current practice
and assure alignment with Vision Zero safety goals. To date, the operational, phasing, and safety
mitigation portions of the draft are complete. Upcoming additions (projected to be made in 2022 and
beyond, given reduced financial and staff resources) will address construction standards and signal
timing optimization practices (cycle length and progression) with the goal of providing step by step
notation on when traffic signals are built and upgraded, and information on how signal are to be
maintained.
According to the City’s 2018 “Traffic Signal Practices Manual Working Draft,” Accessible Pedestrian
Signals (APS) are currently installed on a case-by-case basis, based on demonstrated need with
consideration for noise impacts and the cost of installation. The City considers the installation of APS at
locations where known support facilities for visually impaired citizens are nearby, or when requested by
residents for a route currently used by visually impaired residents. There are currently over a dozen
traffic signals within the city with APS functionality (see Infrastructure & Data section for a map showing
APS locations). View more details on APS features in the Appendix.
2019 Vision Zero: Safe Streets Report
The 2019 Safe Street Report reviewed crash data from 2015 through 2017 to compile findings and
actionable steps to eliminate serious and fatal crashes occurring in the city. Guidelines to ensure
appropriate treatments were applied, as well as continued support of pedestrian head-starts (leading
pedestrian intervals or LPI). View the Infrastructure & Data section for a map of where accessibility-
focused pedestrian treatments are located, including LPI’s, APS and Rapid Rectangular Flashing Beacons
(RRFB).
19
3.2 Programs to Construct/Upgrade Accessible Facilities
As accessibility-related design guidance evolves (including ADA standards and PROWAG), so too
does the upgrading of transportation facilities. Upgrades to features such as curb ramps are
triggered when certain types of project work are planned on adjacent roadways (see 2013
Department of Justice Briefing Memo, also described on page 6).
Pavement Management Program (PMP)
The City of Boulder’s budget priorities for transportation funding further the safety and preservation of
the transportation system, including maintaining all streets in a good and safe condition. The
Transportation Division has established a Pavement Management Program (PMP) which includes
inspecting and rating all streets on a three-year interval to provide a snapshot of existing conditions and
guide where pavement repairs will be made in future years.
Pavement management typically begins with curb and gutter repair work and ADA compliant curb
access ramp upgrades. Typically, this work occurs in the spring when warm temperatures support
concrete repairs.
Annual Sidewalk Repair Program (ASRP)
The City of Boulder targets a specific area each year (“Sidewalk Repair Zones”) in Boulder (with multiple
years required for larger repair areas) to repair damaged sidewalks and install curb access ramps at
intersections. All repairs are made in accordance with the Boulder Revised Code (BRC).
The City of Boulder repairs sidewalks when:
• Any vertical displacement exceeds 3/4 inch;
• There is a crack more than one inch wide;
• The surface has deteriorated, cracked or settled;
• The sidewalk does not allow adequate drainage; or
• The sidewalk is a safety hazard.
Additionally, the city repairs sidewalks where a tripping hazard exists due to the presence of city street
trees. The City of Boulder shares the cost of sidewalk repairs with property owners (as specified in the
BRC). Single-family residential property owners within the sidewalk repair area are not assessed more
than $450 per property, no matter the total cost of the work. There is no charge for repairs, upgrades or
installation of curb access ramps. The ADA requires the city to provide curb access ramps at
intersections. The City installs ramps, where missing, and upgrades existing ramps to meet current
standards.
The Annual Sidewalk Repair Program divided the city into 32 repair zones. To note: There are three
University of Colorado properties within the city (University of Colorado: Boulder main campus, East
Campus Research Park and Williams Village) which were excluded from the zone boundaries since the
city does not maintain sidewalks at these properties. Each of the 32 zones were assigned a score and
ranked in 2010 according to 13 prioritization factors:
• Damaged Sidewalk
• Enhanced Pedestrian Crossings
• Pedestrian Volumes at Crosswalks
20
• Trip Incident Complaints
• Land Use Characteristics
• Schools
• Medical, Special Services, and Senior Facilities
• Parks and Recreational Facilities
• Transit System
• Transit Ridership
• Multimodal Corridors
• Percent of Households with No Access to a Vehicle
• Percent of Population with a Disability
Prior to full adoption of the ASRP’s repair zone system, the city only upgraded existing ramps if they
showed 50% or more damage, for the sake of maximizing the available funding to meet the greatest
need. Most existing, non-compliant ramps were not upgraded. After Priority Zone #1 was completed,
the City practice changed to begin upgrading all non-compliant ramps within targeted priority zones,
regardless of the percentage of damage.
As of Fall 2020, two zones have been completed (Zone 1: Downtown Boulder and Zone 2: University Hill)
and one zone is partially complete (Zone 3: Broadway east to 28th & Balsam/Edgewood/Valmont south
to Pine/Spruce/Walnut/Pearl). View the Infrastructure & Data section to see the Annual Sidewalk Repair
Program citywide prioritization map, plus list of completed curb ramps.
Miscellaneous Sidewalk Repair Program
The Miscellaneous Sidewalk Repair Program was developed to target sidewalks repairs that pose
accessibility concerns, or which impact the safety of the traveling public, outside of the year’s Annual
Sidewalk Repair Program zone work. The repairs are usually identified by community members through
Inquire Boulder (the city’s online customer service portal) and typically include cost-sharing with
adjacent property owners. However, homeowners are not always willing to contribute to the repair and
thought the Boulder Revised Code does allow for the city to complete the work and then charge the
associated property owner, this is rarely carried out.
• Property owners pay for half of the repair costs for sidewalks adjacent to their property.
• Flagstone sidewalk repairs typically come at a higher cost, with property owners still responsible
for paying half of the repair costs.
• If a property owner chooses to have repairs done by their own city-licensed contractor, the city
can reimburse property owners for up to 50 percent of the cost of having the city's contractor
make the repairs.
• The $450 maximum charge for single-family homeowners does not apply to the Miscellaneous
Sidewalk Repair Program.
Missing Sidewalk Links Program
The Missing Sidewalk Links Program identifies, prioritizes, and constructs missing sidewalk segments to
provide a continuous pedestrian network and ensure a safe walking environment. Construction of
missing sidewalk links supports the Pedestrian Plan and Transportation Master Plan by eliminating
breaks and discontinuities in the sidewalk system and ensuring adequate connections to transit.
Projects are identified by community members and then added to prioritized lists of "small" or "large"
missing sidewalk links. Small projects cost less than $75,000 and are completed using funds from the
21
city's Pedestrian Facilities budget. Large missing sidewalk link projects cost more than $75,000 and are
prioritized and assessed for inclusion in the annual budget process. Prior to beginning a missing sidewalk
link project, the City of Boulder will inform adjacent property owners, residents, and interested parties
about the upcoming work.
The Transportation Division prioritizes construction of small and large missing sidewalk link projects
based on several factors, including existing utility and roadway conditions. There are currently 30
prioritized large missing link projects, 44 prioritized small missing link projects and three missing link
projects funded for construction in the near future.
Missing Links data was imported to the city’s GIS asset management system in December 2019.
Identified gaps in the sidewalk network are labeled as either “Missing Link from Imagery,” (as identified
by City GIS staff) “DRCOG Missing Link,” (as identified by the Denver Regional Council of Governments)
or listed as either small or large links from the City’s Missing Sidewalk Links Program. View the
Infrastructure & Data section to see a map of identified missing sidewalk links within the city.
Multi-Use Path Design & Maintenance Program
When city staff designs multi-use paths, the AASHTO Guide for the Development of Bicycle Facilities
(Design of Shared Use Paths), the City of Boulder DCS and BRC are all referenced to ensure accessibility
guidelines such as standards for path width and cross-slope are met.
It is the city’s goal to design multi-use paths to meet draft PROWAG; however, inconsistences in design
have been identified. If the city’s intention is to meet PROWAG in design, referencing the “Comparison
of Proposed Technical Provisions Applicable to Shared Use Paths and AASHTO Guide” online would be a
useful first step.20
Additionally, curb ramps accessing multi-use paths follow the DCS, which references CDOT’s standards
for ramps. ADA standards require curb ramps to span the full width of shared use paths.
The majority of Boulder’s extensive multi-use path system (74 miles) is maintained by City
Transportation Maintenance or the adjacent property owner. The exceptions to this are the Boulder
Creek Path, which is maintained by Parks and Recreation and the segment of the Broadway multi-use
path between Regent and University, which the University of Colorado Boulder maintains.
Upgrades or reconstruction of multi-use paths occur as part of a separately funded capital improvement
project, or through the annual multi-use path maintenance program. Multi-use path maintenance
needs, as identified by staff or community request, are logged and managed by the city transportation
project manager. Identified projects are evaluated annually to develop the next two-year list of
prioritized projects. Priority is based on available budget, scope, location, and presence of any safety
concerns.
3.3 Infrastructure Data
The City’s asset management system contains data on the five transportation infrastructure types
outlined in the scope of this ADA Self-Evaluation, however, not all data contains ADA compliance
information. A newly developed enhanced data framework, created by the city’s Public IR Department
20 Source: U.S. Access Board, Comparison of Proposed Technical Provisions Applicable to Shared Use Paths and AASHTO Guide
22
■
and facilitated through Beehive will ensure the desired ADA compliance data is capture in the future,
whether through individual project work and upgrades or longer-term, through a full system inventory.
Existing data will help frame accessibility upgrades prioritized in the ADA Transition Plan. Below are a
handful of maps displaying the most pertinent accessibility data currently available.
Figure 1: City of Boulder Accessible Pedestrian Signal Locations
Figure 2: City of Boulder Missing Sidewalk Links
Figure 3: Transit Stop Ownership
Figure 4: Transit Stop Snow Maintenance Responsibility
Figure 5: Annual Sidewalk Repair Program Prioritization
Figure 6: Curb Ramps Updated/Installed to Meet ADA
23
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Figure 1: City of Boulder Accessible Pedestrian Signal Locations
24
-------=======--------------Miles
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-Missing Links Funded for Construction
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Figure 2: City of Boulder Missing Sidewalk Links
25
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27
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22
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28
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Curb Ramps Upgraded/Installed to Meet ADA
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Figure 6: Curb Ramps Upgraded/Installed to Meet ADA
29
-
3.4 Community Input
Project staff crafted an engagement process for the ADA Self-Evaluation that included direct outreach
through accessibility-focused events and presentations to stakeholder groups. See the Outreach
Summary in the Appendix for further details. The ADA 101 brochure paired with staff’s intro
presentation offered overview of the federal requirements, the need locally and the goals of the city’s
ADA Plan. To gather community feedback, staff distributed a “barriers mapping” questionnaire to
stakeholders (see Appendix for full questionnaire). The events and presentations outlined below
occurred between June 2019 and February 2020, engaging over one hundred people.
Staff worked with the city’s Communications Department to pair in-person events with online outreach
through city social media, city transportation newsletters, an Inside Boulder News (IBN) video feature
and newsletters to the ADA Plan list as well as online engagement opportunities through Be Heard
Boulder. The Be Heard Boulder page offered opportunity for community members to complete the
barriers-mapping questionnaire and place a “pin” on the city map to note areas of accessibility concern.
Staff also worked with Boulder’s Channel 8 (IBN) News to organize a three-part series of short videos
speaking to the ADA Plan’s efforts. Interviewees included John Couch, a wheelchair user and customer
with the Center for People w/Disabilities (CPWD), Judy Dixon, a member of the National Federation of
the Blind and Cory Lasher (recently retired from the city) who organized the city’s Parks and Recreation
Department’s EXPAND Program for People with Disabilities. The videos aired as filler-material during
Channel 8 programming and were used to encourage community input through Be Heard Boulder.
Internal & External Stakeholder Groups
Internal Departments/Divisions
•Capital Projects
•Transportation Planning (formerly GO Boulder)
•Historic Preservation
•Multi Use Path Maintenance Program
•Neighborhood Services
•Pavement Management Program (PMP)
•Planning & Development Services (P&DS)
•Traffic Operations
Interested Individuals
•People with disabilities
•Parents using strollers
•Caregivers
•Those with friends/family with disabilities
Stakeholder Groups
•Boulder Local Coordinating Council (LCC)
•Center for People with Disabilities (CPWD)
•CU Chancellor's Accessibility Committee
•National Federation of the Blind, Boulder Chapter
•Pedestrian Action Committee 2.0
•Seniors Community Advisory Committee (SCAC)
•Youth Opportunities Advisory Board (YOAB) 30
I ACCESSIBL:
I BOULDER
ADA SELF•EVALUATIO H AND TRAN SIT ION PLAN
In Boulder, we believe that mobility for
people of all abilities is a fundamental
right. We strive to provide a transportation
system with a variety of safe,accessible
and sustainable travel options that
connect people with each other and
with the places they want to go.
This builds a stronger community
in which everyone feels a sense
of belonging.
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Outreach Materials
ADA 101 Brochure Inside Boulder News (IBN Segment) & Channel 8 Videos
bit.ly/ADA101_brochure https://vimeo.com/342773649 /
www.beheardboulder.org/accessible-boulder/widgets/14073/videos
Outreach Platforms
City of Boulder website Be Heard Boulder page
bouldercolorado.gov/transportation/ada https://www.beheardboulder.org/accessible-boulder
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Questionnaire Response Themes
At the beginning of the engagement process, project staff developed a “barriers mapping” questionnaire
which was distributed at ADA Plan outreach events and posted on Be Heard Boulder. The questionnaire
offered community members opportunity to self-identify accessibility gaps within the city. The feedback
window lasted for six months from June to December 2019. The website generated 447 visits, with over
100 questionnaire responses (both in person and online). The top five major themes included:
1. Weather-Related Challenges: Respondents cited challenges with accessing bus stops and
amenity centers during the winter. Icy and unplowed sidewalks may limit or restrict movement
entirely. Isolation was cited as a related effect.
2. Transit Challenges: Respondents cited concern with RTD’s service area and number of stops,
particularly noting the lack of access to senior centers. Simply reaching the stops, particularly
those far from one’s place of origin or accessed via narrow sidewalks, was frequently mentioned
as a challenge. Many seniors cited an enhanced need for efficient service during the winter, or
as they age and prefer not to drive. Others spoke to a lack of dignity for disabled passengers and
an impatience among fellow travelers.
3. Safety: Respondents commonly cited a lack of perceived safety traveling the city’s
transportation network, citing narrow sidewalk width and difficulty sharing space with people
traveling more quickly, like those on bikes. Many mentioned high vehicular speeds, lack of
attention or failure to yield as concerning issues.
4. Crosswalk Challenges: Respondents cited several challenges at crossings, including concern with
the brevity of allocated pedestrian crossing time, lack of striping at some high-frequency
crosswalks and general driver inattention to pedestrians crossing the street.
5. Sidewalk Challenges: Respondents cited uneven or narrow travel surfaces and driveway curb
cuts in neighborhoods as challenges to mobility. Historic neighborhoods often present
additional challenges, such as those created by uneven flagstone pavers. Sidewalk blockages
also emerged as a major access challenge (such as improperly parked bikes, product displays,
vegetation obstructions or construction work without an accessible detour).
Those words and challenges most cited in the questionnaire are displayed in the word cloud:
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Questionnaire Quotes
“The biggest challenges are improperly
maintained sidewalks. Cars block the
sidewalks and construction projects
block sidewalks without a proper
detour for wheelchairs. Improper snow
removal makes it difficult to get around
and through curb cuts. I think it is great
that City of Boulder is doing an ADA
Self-Evaluation & Transition Plan!
“I walk with a cane and
walking long distances is
difficult. The distance to bus
stops proves challenging.
Ice and snow are a
challenge in the winter.”
“Universal design is better for
everyone, and an inclusive
environment helps us all.
Because my mother cannot go
anywhere without me, her
disability is my disability.”
“I would like our community to be
fully accessible to everyone living,
working & visiting in it. And as a
stroller-age parent I have some
immediate experience (though
much lower stakes than someone
using a wheelchair) of trying to
get somewhere with wheels.”
“Freedom of mobility is a right for
everybody. Accessibility is a matter
of equity. Insufficient winter
maintenance is especially
challenging for navigating
intersections. Walkabouts could
better foster accessibility --
especially with wheelchairs.”
“I do not use the bus currently
but expect I will need to in the
future. Crowded sidewalks are a
challenge, crossing multiple lane
streets within signal timing.”
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Part 4: Findings & Areas of Improvement
4.1 Existing City Best Practices
The City of Boulder Transportation & Mobility Department goes above and beyond ADA standards to
follow the enhanced guidelines presented in the draft PROWAG for both new construction and
alterations to pedestrian facilities in the public right-of-way, including sidewalks and curb ramps. The
city’s approach to the construction of pedestrian signals and crossings, as well as new transit stops (to
which bus service is provided by the regional transportation provider, RTD, and maintained either by the
city, RTD or CU Boulder), all follow current ADA law.
Between October 2019 and January 2020, project staff conducted interviews with five Transportation
and Public Works workgroups involved in implementing policies and programs to identify best practices
for supporting accessibility as well as areas for improvement (as noted in the Major Gaps & Challenges
section below).
Findings from these interviews regarding existing city best practices include:
Accessibility is Prioritized Through Programs and City Standards
Existing city construction policies, best practices and programs continue to advance accessibility goals.
For example, the Pavement Management Program and Annual Sidewalk Repair Program both upgrade
facilities (sidewalks and pedestrian ramps) to meet ADA compliance. Both the design of capital
improvement projects and construction of pedestrian crossing treatments meet ADA standards. Also,
the city is in the process of updating its construction standards to better foster accessibility, including
the already-completed Design and Construction Standards (DCS) Phase 1 updates to curb ramp design.
In addition, periodic updates to city reference documents such as the Traffic Signal Practices Manual will
offer future potential to further define best practices related to accessibility requests (such as for
installation of Accessible Pedestrian Signals).
Accessibility is Noted as a Long-Range Planning Theme (see Long-Range Planning section on page 18)
Creation of a safe and accessible transportation environment, designed with vulnerable road users in
mind, is a far-reaching theme within the city’s long-range planning efforts, including the 2019 plan series
(Transportation Master Plan, Pedestrian Plan and Low-Stress Walk and Bike Network Plan). The planned
update of the TMP was what first sparked the creation of this ADA Plan for the city’s transportation
system.
Accessibility is Enhanced During Upgrades to Pedestrian Crossings and Traffic Signals
For community members with mobility impairments, extending signal walk timing can be very beneficial,
either in conjunction with Accessible Pedestrian Signal (APS) installation or as a standalone safety
feature. The city recently adopted a practice which reset all traffic signals across the city (with the
exception of one particularly complicated intersection at 28th and Colorado Avenue) to align with
MUTCD’s adjustment to the pedestrian signal operating speed from 4 feet/sec down to 3.5 feet/sec.
Additionally, city staff considers the use of “press & hold” functionality to assist people with mobility
impairments by extending crossing times (based on a slower speed than the 3.5 feet/sec pedestrian
speed). The “press & hold” functionality adjustment is currently made on a case-by-case, per-request
basis.
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Accessibility is Designed within Construction Detour Communications
Communication about closures impacting pedestrians and cyclists and the alternative access routes
provided is typically facilitated through several communications channels, depending on the traffic
volumes of a street, the number of lanes or facilities closed and the duration of such closures. For both
long-and short-term closures, a best practice involves posting to the city-maintained Cone Zones Map
(http://boulderconezones.net), which displays city construction projects and their impacts. A city best
practice, which is shared with those posting info to the Cone Zones map, is to include notation of where
the project is happening by referencing the street name and cross-street(s), which is attached to the
automatically generated text-only construction list at https://bouldercolorado.gov/transportation/list-
of-cone-zone-projects, in a format which is compatible with screen readers. For those community
members interested in further details on a project’s construction impacts, information such as the
project manager or contact’s phone number and a project website are also provided.
Accessibility is Front of Mind in Meeting Seasonal Challenges
In preparation for the Winter 2020/2021 season, city staff utilized RTD’s ridership data to reprioritize the
highest-use bus stops for a hired contractor to clear. There is an unmet need for snow clearance at
lower ridership stops but given the city’s budgetary limitations, there is not room for adding additional
stops to the existing contract. In recognizing this gap, the city developed a new Shovel a Stop volunteer
program on Count Me In Boulder (the city’s volunteer platform), encouraging residents to give their
neighbors a hand by signing up to shovel un-claimed bus stops, often nearby to their residences. As of
April 2021, 15 residents have volunteered to assist with snow removal at 19 stops.
4.2 Major Gaps & Challenges
The accessibility gaps and proposed strategies outlined in this section will inform development of
the ADA Transition Plan beginning in 2021, which will note priority order, long term versus short
term strategies and financial obligations for addressing identified gaps.
The major categories of challenges include:
1)Consistency in Standards/Design/Construction
2) Communications/Engagement
3)Data Tracking/Monitoring
4)Funding/Coordination/Prioritization
CATEGORY #1: Consistency in Standards/Design/Construction
1) Notation of and Justification for a Lack of ADA Compliance
It is a city best practice to always attempt to meet ADA standards in project design to the maximum
extent possible. However, the city does not currently have an established practice to provide written
documentation describing why a pedestrian facility in the public right-of-way, such as a sidewalk or curb
ramp, qualifies for an exception to meeting ADA standards. Most typically, a lack of compliance would
be due to structural impracticability. According to ADA standards: “Full compliance will be considered
structurally impracticable only in those rare circumstances when the unique characteristics of terrain
prevent the incorporation of accessibility features.” There is also need for a system to document when
upgrades (say to the width of a sidewalk) are financially infeasible within a given project’s scope.
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Strategies to Address This Gap
a) FORMALIZE DOCUMENTATION: It would be beneficial for the city to formalize clear
documentation practices across departments to ensure a consistent strategy for noting
when a lack of ADA compliance exists, including defendable notation of structural
impracticability, environmental constraints such as on extremely steep city streets and
cost barriers.
b) STANDARDIZE DOCUMENTATION MECHANISM: Section 1.05 of the DCS “Alterations,
Modifications, and Waivers” concerns modifications requests, and is used quite
infrequently, but could become the mechanism used to document non-compliance. The
DCS calls for this sort of documentation by the Public Works Director when a project
design does not meet standards. For curb ramps which do not meet ADA compliance,
the city could utilize CDOT’s existing variance form.21
c) PROJECT FILE MEMO: Another best practice improvement would be to include a memo
within a project file noting where and why a facility qualifies for an exception. This
would ideally be uploaded and tracked within the Beehive asset management system in
the future.
d) ADA COMPLIANCE SCORING: From a data mapping perspective, it could be useful in the
future to assign an ADA compliance score to those pedestrian facilities in the public
right-of-way listed in the city’s GIS inventory. For example, this would allow for
identifying which curb ramps completely meet ADA standards (100% compliance),
nearly meet ADA standards (say 85-99% of features in compliance), or partially meet
ADA standards (>85% compliance). This effort would assist with targeting upgrades at
the highest need locations from an accessibility standpoint.
e) ADA NON-COMPLIANCE TRACKING: With formalized institution of the city’s ADA
Grievance procedure online, plus the establishment of a new Inquire Boulder category
for ADA (in October 2020) these channels will allow for more accurate tracking of when
and where community members report ADA non-compliance. Ensuring open
communication between the ADA Coordinator/Risk Management group and those
departments (namely, Transportation & Mobility and the Planning & Development
Services Department (P&DS)) tasked with completing pedestrian facility upgrades, will
improve needs identification.
2)Lack of Distribution of Consistent Design Standards Across Departments
Though city infrastructure is designed by staff, there is not a consistent practice for distributing written
instructions to contractors to note design standards they must adhere to, so different contractors may
follow different design standards (ADA versus draft PROWAG, for example). There is also a lack of clarity
surrounding staff expectations on this topic.
Additionally, the city does not currently have a standardized, written approach for post-construction
inspection of curb ramps to ensure their adherence to draft PROWAG. The city inspector reviews
formwork before final concrete is poured, which is beneficial, but not enough to ensure the subsequent
21 Source: Colorado Department of Transportation. 2019 Curb Ramp Variance Support Document
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feature is built to meet accessibility standards. The level of review also varies between maintenance
upgrades, where in-field layout adjustments may occur, and construction of new facilities.
Holistically, there is a desire for enhanced collaboration and communication between departments, such
as between Transportation & Mobility and private development work in the public right-of-way, led by
P&DS.
Strategies to Address This Gap
a) DESIGN CHECKLIST: Developing and then distributing a standardized ADA/PROWAG
design checklist among partnering departments could assist with ensuring design
consistency and provide guidance for decision-making in design. The development of
the ADA Transition Plan will offer opportunity to determine how best to formalize the
inclusion of accessible design standards within the roles and responsibility documents
developed by project managers.
b) POST CONSTRUCTION INSPECTION: The city should include post-construction
inspection of accessible facilities as a standard practice within project close-out. This
might involve an accessibility-focused staff training for those constructing pedestrian
facilities and a framework for discussing this information at a contractors and inspectors
meeting.
c) STAFF TRAINING: Providing training to applicable staff on ADA compliance for
pedestrian facilities, including noting where a preference for draft PROWAG exists,
could help address inconsistencies.
d) CULTURE OF COORDINATION: Long-term, the city should aim to foster a culture where
there is consistent coordination among city departments and workgroups, so that
irrespective of the department implementing a program, project or enhancement,
accessibility is a priority of the work.
3) Inconsistency in Accessibility of Construction and Events Closures and Detours
All street closures and construction detours require a Methods of Handling Traffic plan (MHT). Though
often these are approved by the city’s Transportation Maintenance division, the P&DS right-of-way
inspection team often handles their own MHTs for private development projects. Though this review is
intended to ensure detours are made accessible according to federal guidelines, with different entities
approving these plans, inconsistencies have been identified. There have been instances when
accessibility guidelines do not translate out in the field and staff receive complaints from residents.
Strategies to Address This Gap
a) CHECKLIST DEVELOPMENT: In conjunction with the construction detours
communications effort listed in the Communications/Engagement section below, staff
could develop a checklist that includes a standard order of operations for
detours/closures, noting the appropriate timeframe for submitting a traffic control plan
and stating the requirements for creating accessible detours.
b) SPOT CHECKS: Staff could also collaborate with the Transportation Operations division
to identify if accessibility spot checks might help ensure greater compliance in the field.
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CATEGORY #2: Communications/Engagement
1)Need for More Involvement of the Disability Community in Project Planning & Policy Updates
It goes without saying that those users who most benefit from the accessibility or lack thereof of
particular design elements have a high stake in how the feature’s design translates from theory to
practice. Though many previous city transportation projects have thoughtfully involved stakeholders
from groups either representing the local disability community or with a high interest in accessibility
(such as the National Federation of the Blind, Boulder Chapter, Senior Community Advisory Committee
and Center for People with Disabilities) there is room for additional inclusion in the arena of both
project planning and program/policy modifications.
Strategies to Address This Gap
a) ONGOING ENGAGEMENT: An existing best practice employed by the Transportation
Planning division is to present upcoming project work and engagement opportunities at
Boulder County’s Mobility for All meetings. Other divisions could follow suit to ensure
that this community of mobility-focused providers and advocates for people with
disabilities are aware of project updates and engagement opportunities. Additionally,
there is potential to further integrate experiential activities into outreach events as well,
to ensure the accessibility of events such as walking tour routes. Integrating messaging
and icons that are inclusive (for example, a wheelchair user in the Walk and Bike Month
logo) embraces our community’s diversity.
b) INNOVATIONS DEVELOPMENT: Transportation design is a constantly evolving field.
Ensuring that members of the disability community are involved in review of
innovations is key to ensuring their maximum benefit. For example, in response to the
city’s recent street closures (“streeteries”) for restaurants due to the COVID-19
pandemic, residents with disabilities reached out to inquire about the loss of disabled
parking stalls and the need for mid-block ramp access to curbside restaurants. City staff
were able to pivot and meet these requests quickly, however, a proactive review of the
streeteries design by members of the disability community could have ensured these
needs were met prior to installation.
c) CONSULTATION ON PEDESTRIAN CROSSINGS: The National Federation of the Blind’s
minority report recommends that state and local governments consult with the local
blind community to determine whether to provide APS on an intersection-by-
intersection basis. This would be an extremely lengthy and time-consuming practice
given the number of traffic signals within city limits. However, should the city decide to
modify its APS installation practices, a consultation with the Boulder Chapter of the
National Federation of the Blind would be a key action item. Longer term, there is
potential to develop a stronger standard practice for when APS installation is justified,
potentially with use of the National Cooperative Highway Research Program (NCHRP)
prioritization tool guidelines, which is a recommended resource that CDOT also
utilizes.22
22 Source: National Cooperative Highway Research Program, 2007 Accessible Pedestrian Signals: A Guide to Best Practices
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Further collaboration with the disability-advocacy community could illuminate long-
term best practices for a variety of pedestrian crossing types, considering the needs of
people with vision, hearing or mobility impairments. This could perhaps be facilitated
through convening an accessibility oversight group, with members identified through
the ADA Self-Evaluation & Transition Plan’s outreach efforts.
2) Inconsistent Communications Regarding Construction and Events Closures and Detours
Though in most cases an effort is made to post roadway closures in advance of project work,
contractor’s schedules change unexpectedly, sometimes accelerating the work with little time to notify
the public of impacts. Other times, work impacting pedestrian facilities is not listed on the Boulder’s
Cone Zones map (www.boulderconezones.net), and when Admin staff receive a complaint not
associated with a listed project, they then must spend time attempting to track down the person or
department in charge of the work to address the community member’s compliant.
Strategies to Address This Gap
a) BEST PRACTICES DOCUMENT: In conjunction with the recommendation above to
develop a checklist that includes a standard order of operations for detours/closures,
staff could establish and communicate a construction notifications best practices
document across departments, from the Transportation & Mobility Department to
Utilities to P&DS to Facilities (as well as to private developers and ROW inspectors), in
collaboration with Communications Staff, outlining when to post a project’s
impacts/closure/detour route on Cone Zones (and who is responsible for such posting)
as well as additional outreach strategies warranted based on the scale of the project
work. This would help alleviate tensions surrounding expectations for closures. This is
especially important for that project work which results in sidewalk, curb ramp, bus stop
or multi-use path closures.
b) CONE ZONES HOW-TO: Ensure all appropriate departments have the resources they
need to post to the Cone Zones map. The Public Works Admin Team has an existing best
practices/how-to file. Ensure those not comfortable with posting to Cone Zones or who
do not have the time to post know who to contact within their department to ensure
the appropriate information is listed. The Business Service Division has recently
established a weekly email reminder system and Cone Zones informational template to
aid in this effort.
c) SHARING OF TEXT BASED WEBPAGE: When sharing the link to the Cone Zones map, an
effort should be made to also share the link to the text-based List of Cone Zone Projects
webpage so those using eReaders are able to access this information as well.
d) REPLACEMENT TOOL: As of Fall 2020, staff is in the process of developing a new tool to
replace Cone Zones, which will integrate better with Beehive. Ensuring that the public-
facing component of the map remains accessible will be an important part of this effort.
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CATEGORY #3: Data Tracking/Monitoring
1) Lack of ADA-Related Infrastructure Inventory
Though much progress has been made, without a complete picture of the city’s pedestrian facilities in
the public right-of-way, staff cannot accurately estimate the existing lack of ADA compliance or
budgetary amount associated with bringing these facilities up to full compliance citywide. Maintaining
an active infrastructure record for these facilities would assist with strategic planning to determine
when upgrades are needed in the future and would be beneficial in justifying requests for additional
funds or grant-seeking opportunities.
The city’s GIS inventory for transportation facilities has not typically been updated with geographic or
ADA features post-construction. Some workgroups do have a practice for providing notation of when
facilities are upgraded or newly constructed to meet ADA standards (such as the PMP’s annual repair
work on curb ramps and sidewalks) but they did not always do so, as tracking of this information only
began recently. Also, there are other workgroups who do not track and inventory the accessibility of
built facilities. For example, when multi-use paths are newly constructed or retrofitted, accessibility-
related information on the path’s features are not inventoried.
Strategies to Address This Gap
An updated inventory would include a detailed accessibility evaluation of existing transportation
features, notably curb ramps, sidewalks, multi-use paths, pedestrian crossings/traffic signals and
transit stops, to provide an understanding both on a neighborhood and citywide level of the
number of features meeting or failing to comply with ADA standards.
If this effort is to be carried out at the highest level of accuracy, a significant amount of funding
would need to be dedicated to hire a consultant such as those the city spoke with in 2019 (see
Inventory Consultant Investigation in Appendix). Given the current funding shortfalls due to
COVID-19, it is unlikely such funding will be available soon. However, there are interim
strategies the city can employ to ensure accurate data is acquired and logged in the meantime:
a) ASSET MANAGEMENT PROGRAM ADOPTION:
• City staff should work with the city’s IR/GIS division to establish the Beehive
asset management system as the preferred way of tracking accessibility-
related data, including logging the compliance or lack thereof of curb ramps,
sidewalks, multi-use paths, pedestrian crossings/traffic signals (including
locations of APS) and transit stops.
• This will include disseminating best practices resources to all departments
which upgrade, construct or evaluate transportation facilities, including
Transportation & Mobility, Utilities, P&DS and Facilities, so they feel
confident either inputting data into Beehive themselves or collaborating
with IR to ensure this essential information is inputted.
b) ASSET MANAGEMENT TRACKING DURING PROGRAM/PROJECT WORK:
• Tied to the above, this will require tracking and inventorying of the
accessibility of transportation infrastructure when doing project work, to
ensure consistency of project upgrades (such as evaluating the curb ramps
and sidewalk slopes during the process of creating a new Neighborhood
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GreenStreet). Tracking this data in Beehive will ensure a log is available to
refer to and update over time.
• In this vein, ensuring that in the future, a member of the Transportation &
Mobility Department capital projects group is involved in initial planning for
new projects that affect the accessibility of transportation infrastructure
would better foster these collaborative opportunities and allow for the
scoping out of accessibility upgrades during the existing conditions phase of
the project.
c) DEVELOPMENT OF PEDESTRIAN CROSSING INVENTORY:
• Another outstanding inventory need is that of pedestrian crossing locations
and types, noting physical features and whether they meet ADA standards
(or draft PROWAG). There is not currently an inventory of this nature.
• This would assist with planned accessibility and safety upgrades at key
locations. Ideally, such an inventory would trigger providing greater clarity
regarding ADA requirements within the pedestrian crossing approval and
installation guidelines themselves.
d) TRACKING OF PARTNERS’ EFFORTS:
• A further challenge to maintaining an accurate inventory is that multiple
entities are responsible for ADA compliance. Though far easier to track city-
sponsored construction or facility upgrades, conscious effort should be
made to log partners’ efforts, as well, and to explore strategies to ensure
data is synced between agencies.
• For example, at the statewide level, CDOT-owned signals within city limits
represent nearly half of the total number of signals, at 70 out of 144. All
signals, however, are maintained by the city, which also provides
opportunity to note compliance during regular maintenance. Other CDOT
work, such as the 2020 enhancement/addition of 97 ADA compliant ramps
on state highways within the city, should be tracked appropriately as well.
2)Lack of Knowledge of Transit Stop ADA Compliance
RTD has yet to complete its ADA Self-Evaluation and Transition Plan, naming the high cost and extensive
geographic nature of RTD’s service as the major barriers to completing one. Therefore, RTD does not
have an inventory of their stops generally, nor notation of those meeting ADA compliance. Until this is
completed, the city only has a piecemeal understanding of accessibility gaps, primarily only identified
through complaints or when relocating or designing new stops within the city.
Currently, when RTD receives an accessibility-related complaint from a customer regarding a bus stop in
Boulder, the complaint goes through its Customer Care office, then is routed to the RTD Boulder
division, who goes out to inspect the issue as needed. RTD staff will relay confirmed issues to city staff as
appropriate, yet there is currently no formal process for this.
Additionally, the city’s current system for prioritizing transit stop improvements does not include ADA
accessibility or lack thereof as a prioritization factor (this is also recommended by draft PROWAG).
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Since both RTD and the city lack a coordinated effort for tracking when bus stops are out of ADA
compliance, typically community member complaints are routed through the City’s Risk Management
Office and are tracked as standalone concerns.
Strategies to Address This Gap
a) INVENTORY OF TRANSIT STOPS: Ideally, when the citywide ADA Self-Evaluation and
Transition Plan RFP is relaunched, the chosen consultant will inventory transit stops
within their project scope. This will establish an ADA compliance baseline to work from
and provide updates to.
b) TRACK COMMUNITY COMPLAINTS: With the institution of the ADA Grievance
procedure online, this channel will act to track community complaints regarding bus
stop compliance more accurately.
c) RTD’S NEW TRACKING SYSTEM: Additionally, when staff talked with RTD’s ADA
Manager he shared that RTD is instituting a new tracking system which may lead to
more effective bus stop issue routing to city staff in the future. A follow-up on the new
system’s progress is recommended.
CATEGORY #4: Funding/Coordination/Prioritization
1) Program Funding to Upgrade Features to Meet ADA Compliance Lags Behind the Need
The funding outlook for programs which upgrade features to meet ADA compliance, such as the Annual
Sidewalk Repair Program, Miscellaneous Sidewalk Repair Program and Missing Sidewalk Links Program,
lags far behind the need.
As an example, given the current pace at which the Annual Sidewalk Repair Program can make
improvements (completing a small zone every year or large zone every two years), and with only 3 of 32
zones completed by the end of 2020, at the current pace it will take between 30 to 60 more years to
upgrade the facilities in every zone within the program. The program funding matches the pace of work,
which has been forced to decrease as pavement costs increase. Compounding this, the $450 per
property assessment cap on homeowners has not increased since program development in 1993, while
overall costs have increased substantially since then.
Strategies to Address This Gap
a) ADJUST HOMEOWNER COST SHARING: Annual Sidewalk Repair Program staff should
work with Finance to determine whether it might be appropriate to make a cost
adjustment to the $450 cap on homeowner cost-sharing with the city. This adjustment is
likely not desirable currently given the COVID-19 crisis but may be more appropriate in
the future.
b) ALIGN WORK EFFORTS: One opportunity to increase the funding available to make
accessibility updates is to align Annual Sidewalk Repair Program project work with new
Transportation Planning division-led long-range planning efforts such as the build-out of
Neighborhood GreenStreets and the Low Stress Walk and Bike Network. As these
programs prioritize future project work, there is potential to bundle improvement types,
42
such as integrating accessibility upgrades before striping a new Neighborhood
GreenStreet. Combining work plans and funding sources is a logical effort which should
be explored in further detail to ensure striping/markings upgrades are not conducted
without coordination. This would not supersede the existing Missing Sidewalk Links
Program work but be a helpful addition to it.
c) PURSUE GRANT FUNDING: Staff should continue to pursue grant funding and other
opportunities to leverage additional money to meet accessibility upgrade needs outside
the scope of planned yearly improvements (as outlined through those programs above).
Take for example the city’s Spring 2021 AARP Community Challenge Grant application to
fund bus stop improvements, complete pavement upgrades and maintain ADA access in
a high-priority area proximate to a low-income, Boulder Housing Partners residence for
seniors and people with disabilities. Though this grant pursuit was not successful, it
resulted in a needs investigation in collaboration with key stakeholders and laid the
groundwork for improvement identification should funding become available. Other
potential grants to meet accessibility needs should be investigated annually, such as
DRCOG’s Community Mobility Planning Implementation (CMPI) set-aside for small
infrastructure projects.
2)Lack of Pedestrian Facility Improvement Programs’ Integration with Long-Range Planning
The existing prioritization models for the Annual Sidewalk Repair Program and Missing Sidewalk Links
Program were created in 2010 and 2018, respectively, and do not reflect the city’s most recently
adopted plans. Not only have city demographics changed since then, but transit routes have also been
modified, traffic conditions have changed, Vision Zero policies have been adopted and most recently,
the 2019 TMP, Pedestrian Plan and Low-Stress Walk and Bike Network Plan have outlined new priorities
and targeted improvement areas (for example, the Pedestrian Plan’s Pedestrian Improvement Areas).
Strategies to Address This Gap
a) CONSISTENCY WITH LONG RANGE PLANS: The two main pedestrian facility
improvement programs (Annual Sidewalk Repair Program and Missing Sidewalk Links
Program) could be revamped to be more consistent with the city’s long-range planning
focus areas. It is likely that improved models for prioritization would build off existing
frameworks and layer in new factors of high importance in creating accessible
pedestrian networks.
b) SOLICIT FEEDBACK: In updating the prioritization factors for these programs, staff
should also be transparent about these factors with the public via the two programs’
webpages. For example, currently, the Missing Sidewalk Links Program page simply says:
“The Transportation Division prioritizes construction of small and large missing sidewalk
link projects based on several factors, including existing utility and roadway conditions.”
There may be additional opportunities to solicit community and stakeholder feedback
on prioritization practices, such as through holding at public hearing item at a monthly
Transportation Advisory Board (TAB) meeting.
3) Need for Enhanced Accessibility-Focused Collaboration in Historic Neighborhoods
There is potential to better align ADA compliance and accessibility within existing historic district
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protections. This is achieved through ensuring the ability to modify properties, while maintaining
historic character, to meet access needs.
There is recent history of collaboration between the Historic Preservation Department and the
Pavement Management Program (PMP), particularly in relation to sidewalk repairs. For example, the
PMP has modified its practices when requested to meet aesthetic goals, such as by leaving out the
typical sidewalk concrete cure (process of maintaining the proper moisture and temperature during the
setting process) to better reflect historic character. However, other times, current practice results in
one-off conversations regarding historic districts when ADA compliance work is planned within a
district’s boundaries.
Strategies to Address This Gap
a) DOCUMENT POLICIES: Transportation and Historic Preservation staff should work
together to formalize a structure and document policies to ensure streamlined
coordination.
b) FLAGSTONE EXCEPTIONS: Additionally, staff should develop a policy noting why
flagstone sidewalks qualify for an exception to meeting ADA standards on historic
properties due to a preservation need.
c) PRE-PLANNING: Developing a proactive, front-end approach would involve noting
compliance needs by location and the improvements schedule planned within historic
districts. Pre-planning work could help codify these preferences for collaboration. Then,
PMP and Historic Preservation could collaborate and agree upon concrete mixes,
homeowner cost share and other relevant factors to ensure both divisions’ needs are
met (alongside accessibility goals).
d) SHOWCASE COLLABORATION: From a programming perspective, there are
opportunities to showcase the collaborative approach forged between these
departments, perhaps through partnering with the accessibility community to host a
walk in a historic district during May (Historic Preservation Month), with supporting staff
from both departments sharing historically relevant information.
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Part 5: Next Steps
5.1 Transition Plan
Though COVID-19 will shift in-person engagement benchmarks, the team continues to advance this
effort. Staff will launch the ADA Transition Plan process in mid/late 2021 to prioritize, plan, refine and
draft a schedule to make the improvements identified in Section 4.2 of this ADA Self-Evaluation. This
effort will involve identifying key stakeholders to implement the various recommended strategies to
address identified gaps. Community feedback received during the Self-Evaluation phase will be utilized
in this plan’s development. The ADA Transition Plan will be presented to TAB to receive their
recommendation to City Council before the end of 2021.
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Definitions
Accessible Pedestrian Signals (APS): An APS and pedestrian pushbutton is an integrated device that
communicates information about the WALK and DON’T WALK intervals at signalized intersections in
non-visual formats to pedestrians who are blind or have low vision. There are essentially two types of
accessible pedestrian signals. The first, accessible pedestrian signals (APS) may or may not include a
signal timing “press & hold” functionality feature (also defined below). The second type is a Rectangular
Rapid Flashing Beacon (RRFB) crosswalk signal, which follows MUTCD standards. 23
Providing accessible signs and signals can be considered both a programmatic and communications
strategy to accommodate the needs of people with disabilities. The current average cost of installing a
pair of APS in the City of Boulder is $1,100.
The current APS features standardized within the city are:
-Pushbutton locator tone
-Actuation indicator (speech message that says “wait” and may list cross streets verbally)
-Automatic volume adjustment (based on location/proximity to nearby residences/businesses)
-Walk indication
o Audible tones
o Audible speech message
Other, optional APS features:
-Tactile arrow (aligned with crosswalk direction)
-Actuation indicator (with light)
-Walk indication
o Vibrotactile indicator24
Rapid Rectangular Flashing Beacons (RRFBs): RRFBs are user-activated, flashing rectangular-shaped
yellow lights which are located alongside pedestrian crossing warning signs. They flash for a set amount
of time after activated, alerting roadway users to the presence of pedestrians. They are not associated
with a legal requirement for vehicles to stop, but rather act as a warning device. Within the city, most
RRFBs, once pushed, display an audible message to remind pedestrians that vehicles may not stop.
23 Source: National Cooperative Highway Research Program, APS Design in New Construction
24 Source: National Cooperative Highway Research Program, APS Primary Features
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Appendix
Outreach Summary
Accessible Boulder Symposium Meeting | June 11, 2019
The Symposium was organized by Graham Hill of Shared
Paths and Craig Towler of Amputee Concierge and tied to
Walk & Bike Month. The event brought together community
mobility advocates and partners, people with disabilities
and related city departments. Project staff shared ongoing
efforts to increase the transportation system’s accessibility
through the ADA Self-Evaluation and Transition Plan. Staff
invited participation in the accessibility questionnaire and
mapping effort housed on Be Heard Boulder and available in
paper form at the event.
Boulder Local Coordinating Council (LCC) Meeting | June 10, 2019
The Boulder LCC, chaired by Angel Bond (Boulder County Mobility for All Program Manager), invited
project staff to speak about ADA Plan at their monthly meeting. The attendees represented a variety of
community organizations including senior service organizations, advocacy organizations for people with
disabilities, affordable housing advocates and more. Project staff provided a brief overview of the ADA
Plan process and community opportunities to identify accessibility challenges through Be Heard Boulder.
Project staff distributed ADA 101 Plan brochures and printed Accessibility Barriers questionnaires.
CU Chancellors Accessibility Committee Meeting | September 5, 2019
The subcommittee within the Office of Diversity, Equity & Community Engagement invited city staff to
47 speak at their monthly meeting. Staff’s presentation prompted a fruitful discussion about CU’s
ongoing evaluations of accessibility. CU accessed a portion of campus for ADA compliance in terms of
housing (1990’s), then access to programs (website, procedures, communications) and a self-assessment
of buildings/facilities is underway. There was interest in the disability statistics within the ADA 101
brochure, and discussion regarding how these differ from those of the campus population. Members of
the subcommittee were curious to better understand the city’s policies regarding requests for APS
installation, and whether other cities have adopted APS installation as a standard for new signals.
Fall Hike at Wonderland Lake Trailhead | October 17, 2019
The hike allowed participants an opportunity to experience
navigating rocky terrain and various grades in a wheelchair.
Organized by Open Space & Mountain Parks (OSMP) staff
Topher Downham and Vijay Viswanathan, who are wheelchair
users themselves, the event offered opportunity to speak to the
ADA Plan’s efforts and promote Topher’s “Boulder OSMP
Accessible Trails and Sites” Guide. A handful of community
members joined for the hike and others engaged with attendees
as they rolled the trail.
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Senior Community Advisory Community (SCAC) Meeting | September 10, 2019
Staff were invited by committee members to discuss the Plan at their regular meeting. Staff tied the
support for accessibility improvements to the draft (at the time) 2019 TMP and Pedestrian Plan, which
GO Boulder staff presented at the same committee meeting. Committee members identified areas of
the city that may pose access issues for people with disabilities.
Winter Walk and Bike Week – Wheelchair Roll and Stroll | February 11, 2020
Led by Topher Downham of OSMP, ADA Plan staff
joined community members (including a member of
The Pedestrian Advisory Committee (PAC) 2.0 and
Mark McIntrye from the Transportation Advisory
Board (TAB) on an accessible roll around the Boulder
Main Library and Civic Center area outside.
Community members stopped to chat with the group
and learn about the event’s purpose. Staff provided an
update on the ADA Self-Evaluation to attendees.
Topher provided a scavenger hunt which encouraged performing tasks a typical wheelchair user would
when visiting a library.
Youth Opportunities Advisory Board (YOAB) Meeting | September 6, 2019
Attendees included students from both public and private Boulder high schools, as well as Brandon
Blew, the YOAB Program Coordinator. Staff presented an overview of ongoing ADA Plan efforts,
highlighting the types of accessibility obstacles people with disabilities may face in navigating the city.
YOAB members offered to spread the word about the accessibility questionnaire through clubs at
school, and one student speculated whether Fairview High School is accessible. Students were generally
interested in access to buildings and how that is regulated, and by whom. Project staff followed up with
a text message that YOAB members could send to explain the ADA Plan and engagement opportunities
to their friends and family.
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Barriers Mapping Questionnaire
Available on Be Heard Boulder and distributed in-person
1. What three words would you use to describe Boulder’s current transportation system for
walking, biking and rolling (including our sidewalks & curb ramps, multi-use paths, and access to
transit facilities)?
2. What is your interest in increasing accessibility in Boulder?
3. What are the biggest challenges to your mobility or that of someone you know while walking,
biking or rolling here in Boulder?
4. What seasonally dependent challenges do you face when traveling in Boulder?
5. Are there any particular neighborhoods or streets where you face barriers to accessibility?
(Consider also dropping a pin on our Accessibility Map here:
https://www.beheardboulder.org/accessible-boulder/maps/ada-accessibility-mapping).
6. Are there any transportation programs or policies in Boulder that you’re aware of that you think
could better foster accessibility?
7. How do you typically get around Boulder (check all that apply)?
Driving
Biking
Walking
Rolling (Wheelchair or Other Assistive Device)
RTD
Access-a-Ride/Via
Other
8. Do you use any assistive devices to navigate the transportation system (check all that apply)?
Wheelchair
Walker
Cane
Other Mobility Devices
9. Do you identify as having a disability?
10. Do you have any family members or friends with disabilities?
11. Would you like to keep updated on this project? If so, please provide your name and email
below.
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■
Inventory Consultant Investigation
The city’s current ability to hire an ADA inventory consultant is severely limited given the lack of
available funding, compounded by budget shortfalls due to COVID-19. Hopefully, with the citywide ADA
Self-Evaluation & Transition Plan RFP re-launch in 2022, there is potential for knowledge sharing based
on previous consultant interviews (highlights listed below). Ideally, the RFP process will include a search
for a consultant who can conduct a citywide ADA-compliance inventory of pedestrian facilities.
In 2019, Staff looked to peer cities when researching potential consultants to lead data collection of the
transportation system’s attributes including curb ramps, sidewalk features, multi-use paths, pedestrian
crossings and bus stops. These peer cities included Mesa, AZ, Seattle, WA, Clayton, MO and others.
Project staff then conducted interviews with four consultants (Beneficial Designs, Cole, Continental
Mapping and MDS Technologies) offering services and technology to complete ADA compliance
inventories to understand the latest technology alternatives, data format, estimated costs and time
required for inventory completion.
Takeaways Include
• Consultants offering lower-cost inventory options often compromise data quality.
• On the other hand, those consultants offering highly accurate equipment and extensive ADA
experience quoted exorbitant estimates of up to $1 million for a citywide system inventory.
• LIDAR (Light Detection and Ranging) technology, though powerful and comprehensive, does not
provide the level of detail required to accurately capture ramp dimensions, slopes, and sidewalk
damage. Other challenges include tree obstructions (if using aerial LIDAR) and parked car
obstructions (if using street-level LIDAR mounted on a vehicle).
• Many companies require that either their techs or vehicles are used to operate the inventory
equipment, increasing the cost significantly (overnight accommodations, travel costs, etc.)
• Oftentimes, though sidewalk inventories can be completed with technology such as carts or
segue ways, curb ramp inventories must be done by hand, which is quite time intensive.
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