ADA Curb Ramp Clarifications
When we initially developed the new SUDAS/Iowa DOT Design Chapter 12 based on ADA, one of the main points of contention was the issue of resurfacing. The question was if all resurfacing projects triggered the need to install curb ramps. On July 1st, we received information from FHWA, Iowa Division, that the DOJ/U.S. DOT developed clarifications on what constitutes resurfacing and further identified work elements that are considered maintenance. The links to these documents are included below.
Based on those clarifications, the Iowa ADA Standardization Design Committee (consisting of SUDAS, Iowa DOT, and Iowa FHWA staff) met to revise Section 12A-2 accordingly. Here's a summary of the changes made:
- Resurfacing is an alteration the triggers the requirement for curb ramps – new or reconstruction of non-conforming curb ramps.
- There are additional surface treatments listed that may have been considered maintenance that are now an alteration. For example, mill and fill, microsurfacing, and thin lift overlays are alterations.
- Incorporated the same expanded list of maintenance activities that is included in the DOJ/U.S. DOT technical assistance document.
- The DOJ/U.S. DOT technical assistance document stated that, “A combination of several maintenance treatments occurring at or near the same time may qualify as an alteration and would trigger the obligation to provide curb ramps.” We included that language following the list of maintenance items. It will be up to the individual agency to determine what constitutes “several” and will need to document that decision if the determination is maintenance.
- Revised the numbered descriptions for the various situations depicted in Figure 12A-2.06. As a result of information provided in the technical assistance document, our committee asked for further clarification on "where must curb ramps be provided." The response, according to Federal regulation 28 CFR 35.151, indicates, “When there is an alteration on the street where there are curbs or barriers in the path of travel between the sidewalk on one side of the street to the sidewalk on the other side of the street, curb ramps are required. Barriers can be the grass portion from the back of curb to the pedestrian walkway.” This clarification impacted situation #3 on Figure 12A-2.06 - in those situations, construction of a curb ramp is now required. The DOJ/U.S. DOT clarification also necessitated revisions of situations #4 and #5.
The updated version of Chapter 12 has been approved by Iowa FHWA and the SUDAS Board of Directors and is included on the Iowa DOT and SUDAS websites (see the Section 12A-2). SUDAS printed versions were distributed with the 2014 Edition updates. To see a marked up version of the changes from the 2013 to the 2014 Edition, click here.
It is important to note that these requirements must be included in any project let after January 1, 2014.
Archived Design Manuals
You asked for it and we are now providing it! We received requests to provide access to archived previous editions of the SUDAS Design Manual. We only went as far back as the 2004 Edition, but please don't be afraid to contact us if you need an older edition. Check out the archived Design Manual page!
Paul presented a SUDAS update at the Iowa Chapter APWA Fall Conference in September. Most of this presentation detailed the ADA curb ramp clarifications (discussed on the left). To see this presentation, please click here.
PLEASE remember the SUDAS program consists of two manuals - the Design Manual and the Standard Specifications. If you have both manuals in your office, please make sure you carefully read anything we mail to you. The binders for the two manuals look very similar or might be the same (depending on when you purchased your SUDAS Standard Specifications). This does not mean it's the same manual!!! If you have questions about your manuals, please compare the contents of the manual to this website or call us for clarification.
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