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Designing Sidewalks and Trails for Access

Part II of II: Best Practices Design Guide

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Sidewalks are critical transportation routes for communities. They allow pedestrians to travel from one place to another, stimulate business districts by encouraging leisure shopping, and keep communities safe by providing more activity on the street. Integrating pedestrians, including pedestrians with disabilities, into the project planning process is critical to the success of a transportation network. Too often transportation policies focus on the needs of motorists and do not consider the needs of pedestrians. Similarly, accessibility is often thought of as a separate issue to be addressed after the planning and development process is complete.

Figure 3-1. People with and without disabilities should be actively involved throughout the entire project planning process.
Figure 3-1. People with and without disabilities should be actively involved throughout the entire project planning process.

In order to improve transportation systems for people with disabilities, accessibility should be integrated into the project planning process. Access should be addressed at the beginning of the public involvement process and throughout project development. Transportation agencies must carefully reexamine existing policies and programs to determine if they are discriminatory. Furthermore, accessibility issues need to be addressed throughout an organization. Changes are difficult in bureaucracies, but unless accessibility issues are institutionalized throughout an organization, people with disabilities will be denied the mobility that the rest of the population takes for granted. Mobility is a basic right and it is the responsibility of transportation agencies to guarantee this right by ensuring that physical barriers are removed, audible and visual information is provided, and facilities are maintained to be fully accessible. Accessible design is the basic tenet pedestrian design, and all project design should apply accessible design fundamentals and overlay best practices. This principle assures that facilities will be usable and safer for all pedestrians. If a facility is not accessible, it is most likely not safe.

The planning process, referred to in this chapter, pertains to project development planning, including pedestrian system planning, public outreach, land use considerations, and preliminary facility designs. Many transportation projects involve not only the decisions of transportation agencies, but associated agencies, politicians, developers, local businesses, and citizens. In order to ensure that all pedestrians are considered throughout the planning, development, and installation processes, interested parties must redefine internal goals and allocate the necessary resources to integrate accessibility into all transportation programs and projects.

3.1 Recent legislation

During the 1990s, several key pieces of legislation were passed that impacted transportation planning. The first piece of legislation was the Americans with Disabilities Act (ADA) of 1990, which protects the civil rights of people with disabilities. Secondly, the 1991 reauthorization of the Federal transportation policy, the Intermodal Surface Transportation Efficiency Act (ISTEA), specifically called for mainstreaming pedestrian travel into the transportation system. ISTEA increased the Federal-aid funding options for pedestrian facilities and programs. This allowed communities the ability to make a wide range of planning and funding decisions regarding the allocation of their Federal transportation dollars. In 1998, the Transportation Equity Act for the 21st Century (TEA-21) extended the opportunities established in ISTEA and increased funding for pedestrian facilities. However, even with these landmark laws, there are still gaps at the local level (where transportation decisions are made) between increased Federal-aid funding and the ADA requirements for pedestrian accessibility.

3.1.1 Americans with Disabilities Act (ADA)

As public entities covered under Title II of the Americans with Disabilities Act (ADA), transportation agencies are required and have a major responsibility to implement accessibility in their facilities and programs. Although some cities have developed innovative approaches to upgrading their facilities to meet the needs of people with disabilities, many cities still lack accessible transportation networks.

The Title II Implementing Regulations for the ADA require all newly constructed and altered facilities (including sidewalks) must be readily accessible to people with disabilities (Section 1.4.1). Transportation agencies are responsible for developing a transition plan for existing sidewalk networks to identify accessibility deficiencies in the facilities and establish a schedule for improvements. In order to be effective, a transition plan (required to be completed by January 1995) should be integrated into the transportation element of a city's capital improvement program (CIP), and other local improvement and funding programs.

3.1.2 Federal transportation legislation (ISTEA and TEA-21)

ISTEA called for a more balanced focus of transportation planning and investment decisions. TEA-21, signed into law June 1999, builds on the many changes made by ISTEA. Because of ISTEA and TEA-21, planners have started to obtain more input from local users, which has led to the development of transportation facilities that better meet the needs of local users, including underserved communities, such as people with disabilities.

3.2 Prioritizing pedestrian access

Pedestrians are an integral part of the transportation system and should be equally prioritized with other modes, such as automobiles. For example, the decision to design a corner with a wide turning radius to benefit trucks should be carefully weighed against the negative impacts that wide turning radii have on pedestrians. Institutionalized standards, policies, design guidelines, and public participation should provide all pedestrians equal service within the transportation system.

There is a lack of knowledge on the part of transportation providers and public policy sectors regarding the needs of pedestrians. Transportation planners and engineers often do not receive formal training on pedestrian issues and designs. This has contributed to transportation systems that encourage motor vehicle use and discourage walking. University courses should be developed that teach students how to balance the needs of all users and to design universally accessible pedestrian environments. Workshops and training materials should identify pedestrian needs at the beginning and the end of transportation planning in order to create accessible pedestrian networks. Agency employees and decisionmakers have a responsibility for raising awareness and educating the public about the need for accessible facilities.

3.2.1 Sidewalk installation

When landuse plans have development activities (e.g., business and residential areas and school trips), pedestrian activities should be anticipated. Accessible design is a requirement and does not depend on the number of users. Practice in accessible design should be as advanced as vehicle usage design. When sidewalks are not available, pedestrians are forced to share the street with motorists, access to public transportation is restricted, and children have fewer play areas that are safe. Therefore, whenever possible, accessible sidewalks should be provided. The following guidelines have been established to assist local jurisdictions with determining when and where pedestrian facilities are needed Planning, Design, and Operation of Pedestrian Facilities: Unpublished Draft Final Report (2000), NCHRP, Project 15-20, TRB, Washington, D.C.):

To initiate the sidewalk installation guidelines above, and to promote accessible sidewalk facilities, municipalities should consider the following recommendations:

3.2.2 Pedestrian oriented detail

Installing sidewalks is critical to providing pedestrian access. However, prioritizing the needs of pedestrians extends beyond the basic step of providing a sidewalk network. The quality of the pedestrian experience should also be addressed during the project planning process. The first step towards providing a quality pedestrian experience is to provide a buffer zone that separates the pedestrian from the motorist. This can be accomplished by providing a wide sidewalk or a sidewalk setback, such as a planting strip. In addition, planners and designers should consider the following pedestrian oriented details:

When pedestrian details are included, pedestrians are more comfortable using the sidewalk facilities, neighborhoods are safer because there are more people out in the community, and commercial areas thrive.

3.2.3 National policy

To address the goal of effective transportation networks, Federal transportation legislation calls for the mainstreaming of pedestrian projects into the planning, design, and construction of the national transportation system. As a result, the Federal Highway Administration (FHWA) has developed a policy statement regarding the integration of walking into the transportation infrastructure. The policy statement was developed in cooperation with other agencies and organizations that address pedestrian issues, such as the American Association of State Highway and Transportation Officials (AASHTO) and the Institute of Transportation Engineers (ITE). The key principle included in the policy statement specifies that "bicycling and walking facilities will be incorporated into all transportation projects unless exceptional circumstances exist" (Federal Highway Administration, 2000). This is the principle for Federal-aid Highway Programs that State, regional, and local transportation agencies should use in their planning process.

3.2.4 State and local sidewalk policies

There is significant work to be done to ensure that the recent FHWA policy on mainstreaming nonmotorized transportation is institutionalized at the State and local levels. Transportation policies should be reexamined by State and local governments, and programs should be developed that provide resources for constructing and maintaining an accessible pedestrian network.

Within many State and local agencies, it is difficult for pedestrian projects to compete with the priorities that have been placed on automobile travel. Some States do not allow State transportation funds to be used for sidewalk construction or maintenance, reserving the funds for roadway use only.

At the local level, many cities do not systematically require sidewalk installations on new roadway projects, or they may leave installation details to the discretion of local developers. This lack of guidance often leads to narrow walkways, obstacles in the path of travel, and other design practices that do not adequately meet pedestrian needs. To address this issue, local standards for sidewalk design guidelines should be created and must be followed by developers and others responsible for sidewalk installation.

Maintenance of sidewalk facilities is also a significant problem in many localities. While some transportation agencies take responsibility for sidewalk maintenance, others hold property owners accountable. It is recommended that sidewalk maintenance should be the responsibility of the transportation agency and should be carried out using strategies similar to road maintenance.

3.3 Local land use and zoning

There is a strong connection between transportation planning and land use regulations. The content of land use regulations can encourage an accessible pedestrian network if pedestrian needs and mobility issues are incorporated into the development of local zoning and subdivision ordinances. Land use decisions are most often made at the local level. Although State regulations impact zoning, town and city regulations generally allow local decisionmakers to guide development. The following sections are based on a report prepared for the Transportation Research Board entitled, Planning, Design, and Operation of Pedestrian Facilities:Unpublished Draft Final Report (2000).

3.3.1 Traditional land use patterns

Traditionally, zoning ordinances have eliminated mixed-use developments and separated urban and suburban areas based on designated use and specified allowable densities. These practices have led to increased dependency on automobiles and longer trip distances. Similarly, subdivision ordinances have focused on the motor vehicle as the primary mode of transportation. Typically, subdivision ordinances lack requirements for sidewalks on streets and pedestrian connections between the street and building entrances.

Also, the zoning and subdivision restrictions of a locality may limit a designer's ability to maximize sidewalk accessibility. For example, a designer of a new sidewalk may intend to create an accessible facility. However, the designer may be unable to do so if the subdivision regulations do not allocate sufficient right-of-way to make pedestrian facility accessible. Municipalities have an obligation under Title II of the ADA to make the newly constructed and altered facilities readily accessible. According to the ADA Title II Implementing Regulations, "a public entity shall make reasonable modifications in policies, practices, or procedures when the modifications are necessary to avoid discrimination on the basis of disability."

3.3.2 Land use recommendations

The following recommendations promote an accessible pedestrian environment and should be considered during a locality's review of its zoning ordinance:

The following recommendations promote an accessible pedestrian environment and should be considered during a locality's review of its subdivision ordinance:

3.4 Comprehensive planning

The transportation component of a region's comprehensive master plan (CMP) has a significant impact on transportation policy. If an assumption is made that individuals prefer to drive, communities will only be designed to accommodate motorists. Transportation systems that neglect pedestrian needs guarantee increased automobile use within the community, define the layout of the community, and determine local quality-of-life patterns.

Unless there is a specific strategy for funding new pedestrian projects, the need for these projects will often not be recognized. Therefore, for pedestrian projects to be implemented, they must be included in a city's capital improvement plan (CIP). Projects listed in the CIP are ranked for priority according to a specific scoring system. Accessibility projects can be listed in the CIP and should be included as part of larger projects. Traditionally, pedestrian projects have not ranked well because they are often small in scale. However, existing ranking systems should be reevaluated to consider areas where pedestrian projects rank very highly, such as public health and safety, maintenance, socio-economic impact, neighborhood impact, social justice, coordination with other projects, and land use.

3.4.1 Pedestrian master plans

To help guide long-term pedestrian planning, many municipalities are developing pedestrian master plans. Pedestrian master plans outline the framework of the pedestrian network and identify improvements that will enhance the pedestrian environment and increase opportunities to choose walking (with and without assistive devices) as a mode of transportation. Pedestrian master plans, such as the one adopted by the City of Portland in April 1998, outline policies, street classifications, design guidelines, capital projects, and funding strategies that affect pedestrians.

Transportation agencies should address accessibility in all components of a pedestrian master plan. The goal of the pedestrian master plan is to encourage walking as the preferred mode of transportation and, therefore, must consider the mobility and travel needs of all people. Integrating accessibility into pedestrian master plans is required by law and will avoid costly and time-consuming modifications to designs and installations that provide pedestrian networks that work for people of all abilities.

3.4.2 Pedestrian design guides

Pedestrian design guides are a complementary component of the pedestrian master plan intended to ensure that all sidewalk facilities promote the objectives identified in pedestrian master plans. Pedestrian design guides are developed by transportation engineers to provide a uniform set of guidelines that are applicable to most situations and to further promote walking as a mode of transportation. Without thoughtful design guidelines, conflicts between competing functions may produce conditions that are less than ideal for pedestrians and, particularly, for people with disabilities.

Accessibility should be an integrated topic within pedestrian design guides. Every design specification should be consistent with the needs of people with disabilities. If accessibility is not integrated into the design guide, it will continue to be addressed as an afterthought.

3.5 Prioritizing resources

While all new construction should be planned and designed to meet accessibility standards, improvements to existing infrastructure that enhance accessible pedestrian networks should be prioritized by transportation planners, engineers, and agencies. Pedestrian improvements should be designed to achieve the maximum benefit for their cost, including initial cost and maintenance cost, as well as reduced reliance on more expensive modes of transportation. Where possible, improvements in the right-of-way should stimulate, reinforce, and connect with accessible transportation networks. A good model is Accessible Rights of Way: A Design Guide (U.S. Access Board, 1999).

Redefining transportation planning to include pedestrian needs and accessibility requires new systems for prioritizing resources. An evaluation of existing conditions and feedback from public involvement sessions should provide planners with useful information about the community's pedestrian needs. This information should then be prioritized to ensure that the most beneficial improvements are made first. The following principles provide guidance to designers when planning access improvements and establishing priorities:

Many cities, such as Austin, Texas; Seattle, Washington; San Francisco, California; and Portland, Oregon, have extensive programs to improve accessibility in their communities. The Portland program focuses on adding access improvements to existing projects and making additional improvements to locations receiving heavy pedestrian use. Portland also takes about 100 specific requests per year for improvements from people with disabilities.

The City of West Palm Beach, Florida, has developed a long-range transportation plan based on the hierarchy of users. The needs of pedestrians are the number one priority in the West Palm Beach model. The goal of this project is to "reverse the current transportation paradigm, which has to a great extent neglected all users except the automobile, and begin a shift toward balance and equity" (Transportation Division, City of West Palm Beach, 1999).

3.6 Funding strategies

Almost every Federal-aid highway funding category may be used for building, altering, or improving accessible pedestrian facilities. It is up to each State's Metropolitan Planning Organizations (MPOs) and localities to set priorities on how Federal-aid Highway funds are used. The following is a list of some of the provisions included in the Federal-aid Highway Program as amended by the Transportation Equity Act for the 21st Century (TEA-21) (U.S. Department of Transportation, 1998):

Accessible pedestrian projects can also be funded through other Federal-aid Highway Programs including Federal Lands Highway Program, National Scenic Byways Program, Congestion Mitigation and Air Quality Improvement Program, Transportation and Community Systems Preservation Pilot Program (TCSP), and Job Access and Reverse Commute Grants. In addition, TEA-21 allows Federal transit funds to be used for pedestrian access improvement projects. These funds are to be used for investments that provide "pedestrian and bicycle access to a mass transportation facility" for the establishment and enhancement of coordination between mass transit and other forms of transportation (U.S. Department of Transportation, 1998).

3.7 Site development

Site development focuses on planning and design issues on an individual project basis. Developing accessible sidewalk facilities at the project level is most effective when the needs of pedestrians are institutionalized into the planning process. If broader elements, such as land use and regional coordination, do not support pedestrian planning, individual projects become very challenging.

3.7.1 Pedestrian level of service

When developing a specific transportation project, the level of service for motor vehicles is often evaluated. The effectiveness of a transportation facility is evaluated on an A-F grading system. Level A identifies facilities that are free flowing with very efficient travel speeds and few interruptions. Level F represents streets with high congestion, low speeds, and many signalized interruptions.

Some transportation agencies are addressing the discrepancies in evaluating only the level of service for motorists. The Florida Department of Transportation is in the process of developing a multimodal level of service plan with guidelines for pedestrians. Streets that best serve motorists often do not serve pedestrians at all. For example, a Level A street for motorists could be a Level F for pedestrians, especially for people with disabilities.

To address the discrepancies between the needs of motorists and pedestrians, a balance should be created between the two modes. Pedestrian level of service models should be developed that include the following factors in addition to capacity:

Figure 3-2. Multiple parking lots with narrow sidewalks  provide a low quality pedestrian experience and increase the number of potential conflict points between motorists and pedestrians.

Figure 3-2. Multiple parking lots with narrow sidewalks provide a low quality pedestrian experience and increase the number of potential conflict points between motorists and pedestrians.

Figure 3-3. Access management strategies aimed at reducing the number of driveway crossings and increasing the width of the sidewalk corridor significantly improve the pedestrian experience.

Figure 3-3. Access management strategies aimed at reducing the number of driveway crossings and increasing the width of the sidewalk corridor significantly improve the pedestrian experience.

3.7.2 Access management

Access management regulates the movement of a variety of modes at key locations such as intersections, parking facilities, and alleys. Successful access management programs reduce or consolidate the number of driveways to parking areas and businesses and provide raised medians to control vehicular turning movements (Washington State Department of Transportation, 1997).

Pedestrians benefit from access management policies because (Washington State Department of Transportation, 1997):

People with disabilities gain particular benefits from access management policies that reduce the number of driveway crossings in parking areas. In many suburban and some urban shopping centers, commercial facilities are designed with parking lots in front of the store for the convenience of automobile drivers. Oftentimes, these parking lots are designed for the maximum parking needs (e.g., holiday shopping) and are larger than necessary for most of the year. In some locations, a row of stores may each have their own parking lot entrances and exits. Such locations seldom provide sidewalks. When sidewalks are provided, they are generally narrow, which forces wheelchair users to negotiate rapidly changing cross slopes at driveway crossings.

Access management policies aimed to improve a parking area should consider placing parking lots behind the building whenever possible. By doing this, people using the sidewalks do not have to travel through a parking lot of cars. Furthermore, pedestrian and automobile conflict points are reduced because the cars are not crossing over the sidewalk as they enter the parking facility. If parking in the back is not possible, access management policies should:

3.7.3 Design constraints

Because sidewalks are located outdoors, they are influenced by more factors than if they were located in controlled indoor environments. Topography, weather conditions, and other unavoidable environmental constraints are among the many factors that influence site development. Although environmental constraints complicate design, they should not be used as an excuse to avoid making facilities accessible to people with disabilities. During the design stage of a project, each environmental factor should be carefully considered and creative solutions should be employed. If environmental constraints are not addressed, the accessibility, usability, and funding of a facility will be compromised. For example, if a designer does not understand the topography of a site and fails to include a base map or profile of existing conditions in the construction plans, the sidewalk installer who may have no understanding of pedestrian and access issues may be making design decisions.

The ADA requires that alterations be accessible. Existing infrastructure and environmental constraints complicate the ability to create an accessible facility. Building and street design, as well as previously installed structures such as traffic poles and fire hydrants, all impact how easily designers can make accessibility improvements. The same creative engineering necessary to make improvements for motorists (e.g., add a vehicle lane, reconstructing an intersection) must be applied to accessible sidewalk and crosswalk design.

3.8 Public involvement

Both ISTEA and TEA-21 (Federal Transportation Legislation) encourage State and local governments to involve citizens in the transportation planning process. This allows the community to be involved in economic, environmental, and quality of life decisions. Involving pedestrians with disabilities in the planning process helps to improve accessibility in the community. Although citizens are not directly responsible for construction on public rights-of-way, they add a unique local perspective and personal experience to the planning process. For example, a resident might know of a better site for a playground or sidewalk than a regional planner who is less familiar with the area. In addition, citizens who live and travel in an area are often the best equipped to identify where transportation network problems exist.

Benefits of involving the community early on and throughout the planning process, include:

3.8.1 Making accessibility provisions at public meetings

For public involvement to be successful, it is important to provide opportunities for all segments of the community to participate in the process. The ADA requires that public agencies convene all meetings or breakout groups in accessible buildings. The following accommodations encourage participation:

3.8.2 Outreach strategies for initiating community involvement

People with disabilities can provide valuable input to all types of transportation projects. Their assistance is particularly crucial to ensure that mobility and accessibility needs are addressed. Even people with disabilities who may not have an understanding of accessibility requirements under the law can provide valuable descriptions regarding what has proven to be accessible or inaccessible for them. They can identify where linkages and connections will serve their transportation needs and where existing improvements may be deficient. To increase participation by people with disabilities, agencies should use proactive outreach techniques. Good sources for contacting people with disabilities include:

Contact information for a variety of national organizations and advocacy groups representing people with disabilities is provided in Appendix C. Many of the organizations have local and regional branches and may serve as key resources for identifying local users.

3.8.3 Public involvement strategies

ISTEA's promotion of public involvement became the impetus for the development of more innovative and user friendly public involvement strategies. TEA-21 continued the emphasis on developing creative public involvement techniques. Participation by people with disabilities should be included in every public involvement strategy. Summaries of useful strategies are listed below (U.S. Department of Transportation, 1996).

Transportation fair - A one-day event used to generate citizens' interest in transportation issues and in specific projects and programs.

Citizen surveys - A written or verbal questionnaire distributed to a sample group of citizens representative of a larger group. Citizen surveys are effective because they are short and simple and do not require significant resources from the sponsor or participant. They provide agencies with an understanding of citizen perceptions and preferences. They can also provide agencies with a preliminary understanding of how the public will react to a proposed project. Transportation agencies can develop surveys targeted towards accessibility issues to gain a better understanding of the needs of local people with disabilities.

Visual preference surveys - A series of visuals showing various types of development and amenities used to obtain feedback about the aesthetic preferences of the community.

Facilitation - A group in which a neutral facilitator guides the members through the problem-solving process. To be effective, the facilitator should possess or obtain the following information:

During the planning process, the facilitator should:

Charrette - A meeting focused on addressing a specific problem or issue. Participants work as a group to develop solutions to issues (e.g., new developments, traffic calming installations, pedestrian transportation improvements). Charrettes are effective community tools because all participants work through issues and create final solutions.

Focus groups - A small discussion group convened by transportation agencies to gauge public opinion on a specific issue. Because focus groups are generally informal and all ideas and opinions are accepted without criticism, they often generate fresh concepts and energy. Focus group members are selected by the sponsor depending on the issue being discussed. For example, an agency needing to learn more about how people with visual impairments feel about detectable warnings on curb ramps would only invite people with visual impairments to participate (then would be surprised if wheelchair users later expressed concerns about decisions), but an agency interested in how accessibility should be incorporated into an agency's long-range plan would be more likely to convene a group consisting of people with and without disabilities.

Collaborative task force - A committee established to resolve a specific issue within a restricted time limit. Citizens are able to directly influence an agency's policies and provide officials with an understanding of the values and needs of the participants. Collaborative task forces are also helpful ways to resolve an impasse or controversy related to a project. Creating a collaborative task force regarding accessibility would be a unique way to empower people with disabilities and ensure they have a voice in the planning process.

Citizens' advisory committee - A committee of interested parties that meets regularly to address common issues and concerns. Because participants meet on a regular basis, they are familiar with one another and the discussion topic. Citizens' advisory committees foster positive interactions between citizens and government, and provide a forum for agencies to present new goals and programs. Citizens' advisory committees are especially useful to agencies that are low on staff. Citizens' advisory committees are most successful when an agency liaison participates and the representatives are very dedicated and hold a variety of opinions. Citizens volunteering their time to an advisory board need to feel that their input is valuable; therefore, agencies should incorporate their feedback into the decisionmaking process. In some communities, citizens' advisory committees have been established to address ADA compliance and other accessibility issues.

The selection of the most appropriate public involvement technique depends on where the agency is in the planning process and what type of feedback the agency needs. For example, a public survey might provide useful information in the early planning stages of a project, whereas an advisory committee might be more appropriate for in-depth planning discussions further into the development process.

3.8.4 Community involvement in sidewalk assessments

Sidewalk assessments that evaluate existing conditions can be useful in prioritizing future improvements. For detailed information, agencies should collect objective measurements using a methodology such as the Sidewalk Assessment Process, which is outlined in Chapter 11. However, if an agency's time or resources are limited, less intensive assessment strategies should be considered. For example, a subjective or objective accessibility checklist can be developed by the agency, that may include elements of the Sidewalk Assessment Process (Chapter 11). Citizens working individually or in organized groups can assist with the assessment of sidewalks by participating in either the Sidewalk Assessment Process or by using agency checklists. Areas identified as problematic should be reevaluated by the agency at a later date. Regardless of the technique employed, it is very important for community participants to see changes made as a direct result of their assistance. It is extremely frustrating for citizens to identify problems that an agency has no intention of improving.

An example of a subjective accessibility checklist based on the Walkability Checklist developed for the U.S. Department of Transportation in 1997 is presented in Appendix B. This accessibility checklist may be reproduced or reorganized to meet the needs of specific agencies. The accessibility checklist is intended to identify areas within the community that provide less than adequate pedestrian access. Anyone who has an interest in pedestrian facilities can provide valuable information using the checklist. However, people with disabilities may be able to provide the most useful information because they have firsthand knowledge of accessibility issues. Checklists should be translated into large text, Braille, and/or electronic format to accommodate people with vision impairments.

Many communities provide a telephone number where sidewalk problems can be reported and improvements requested. This source of assessment can be valuable to a Public Works department.

Updated: 2/10/2014
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