ADVISORY COMMISSION ON DISABILITIES AGENDA ITEM
ACTION REQUESTED:
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Receive the staff memo regarding ADA parking in Downtown Naperville.
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DEPARTMENT: Transportation, Engineering and Development
SUBMITTED BY: Peter Zibble, Operations Manager
BOARD/COMMISSION REVIEW:
Will be reviewed by the commission at the May 1, 2019 ACD meeting.
BACKGROUND:
At the February 6, 2019 meeting of the Advisory Commission on Disabilities, the commission discussed issues associated with ADA parking in the downtown. Two motions were made regarding this topic.
1. A motion to request staff to reassess its current guidelines related to ADA parking and determine how the city can provide more consistent distribution of parking spaces in downtown Naperville.
2. A motion to direct staff to investigate options to implement guidelines that avoid parking spaces that have impediments to access.
DISCUSSION:
ADA Parking in the Downtown
This matter was discussed with Jennifer Louden, Deputy Director of TED who oversees the transportation and engineering teams for the city. The placement of accessible spaces in downtown has had a long history. Over the years, attempts have been made to place the parking spaces based on requests from both residents and business owners. This led to an uneven distribution and spaces located in difficult to access areas. Furthermore, as businesses and residents come and go, the locations chosen were not always the most desirable. This method also resulted in frequent relocation of spaces which made it more difficult for users to find spaces.
The Transportation Team currently considers three primary issues with regard to the downtown parking spaces: the total number available, the accessibility requirements of a space, and the overall distribution of spaces in the downtown.
Of the roughly 3,200 public parking spaces in the downtown, including parking lots, parking garages, and on-street spaces, there are 82 designated as ADA spaces. This is approximately 2.5% of the total number. To help ensure that this number is appropriate, staff performs a monthly count of all occupied spaces in the downtown. On average, the ADA spaces are occupied at a rate of about 60% of the rate at which the standard parking spaces are occupied. For example, if 80% of all of the standard parking spaces are occupied, 48% of the ADA spaces are occupied. These comparative rates provide guidance to staff on the overall demand for spaces. Providing the proper number of spaces is critical in the congested downtown where both standard and ADA spaces can be difficult to find during peak times.
A great deal of consideration is given to the accessibility requirements of the space itself. All spaces must be relatively flat, no more than 2% slope in each direction. Each space must have an accessible route from the space to the network of public sidewalks which also has slope requirements. There may not be any obstructions in the space. These requirements are generally easier to accommodate in a parking lot or parking garage. On-street spaces often do not meet these criteria because of the crown of the road, the distance from the space to a curb-ramp, or, in the case of parallel parking spaces, the adjacent sidewalk is encumbered by poles or trees which make exiting on the passenger side difficult. For these reasons parking lots and garage facilities are often preferable to on-street spaces. Please note that on-street ADA parking spaces are not required, but when provided, they should meet to the accessibility requirements to provide a barrier free route to the sidewalk.
Lastly, the overall distribution of spaces is important. Since parking spaces downtown are not intended to serve specific businesses, ADA spaces need to be distributed to best serve all of the downtown destinations. A coverage map was created for visual reference showing a coverage area for on-street spaces, parking lot spaces, and the parking garage entrances. A two-hundred-foot radius, which is approximately the distance of half a block, was used. Although there is no required distance a space must be from a destination, 200’ was used to best graphically identify underserved areas of town. Private ADA parking spaces are also shown on the exhibit and have been given consideration as part of the of the overall distribution plan, but are not included in the coverage map.
Although the Transportation Team has put thoughtful consideration into the ADA spaces in the downtown and continues to monitor their utilization, the team is open to requests. A formal request may be submitted to the city through the Online Help Center or by phone at 630-420-6100 Option 4. Requests are reviewed by Transportation, Engineering, and Legal. These staff members consider many factors. What is the reason for the proposed location? Does this space meet the accessibility requirements and/or what infrastructure improvements are required? Are there other accessible spaces nearby? What do other stakeholders think, such as the adjacent businesses and the Downtown Naperville Alliance?
Formal requests from the Advisory Commission can be made directly to staff and will follow this process as well to ensure that all factors are considered.
Guidelines to Avoid Impediments to Access
The American’s with Disabilities Act (ADA) as documented in the 2010 ADA Standards for Accessible Design and the Illinois Accessibility Code (IAC) dictate requirements for ADA parking spaces and the required accessible route into the building. The two documents are very similar in content and format. For reference, the bulk of the pertinent information is found in Section 502: Parking Spaces, Chapter 4: Accessible Routes, and Section 406: Curb Ramps. The 2010 ADA Standards provides additional advisory information in the text to assist with interpretations. A commentary document is also publicly available.
A local municipality has the right to implement more rigid regulations if it sees fit by amending the Municipal Code. Staff has considered this option and has the following concerns:
• The development of the state and federal standards went through a lengthy, multi-year process that incorporated numerous stakeholder groups, field testing, public comment and analysis. Changes to the regulations could have unintended impacts of certain user groups. A thorough, local, public involvement process would be recommended prior to consideration by the City Council of any amendments to the Municipal Code.
• Naperville would need to enforce and defend, in court if necessary, any municipal amendments.
Staff from the Transportation, Engineering and Development group recommend an alternative to additional regulations to help address concerns raised by this advisory group. As the reviewers of new development and redevelopment, the professional engineers and planners on staff would like to hear your concerns first-hand. Those concerns could be provided in a written format or a representative or two from the commission could set up a time to meet with the team to discuss issues. As reviewers, city staff are not able to require designers to implement improvements above and beyond those required by law, but they are in a position to identify when improvements to a given plan can be made and encourage designers to make small but meaningful changes to their designs.
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