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To

,
The Managing Committee,
Chennai City Connect,
9th Floor, SKCL Towers,
Triton Square, unit no c3 - c7,
TVK Industrial Estate, Guindy
Chennai, Tamil Nadu 600032

Subject: Analysis of the ITDP Regulations from the perspective of Persons
with Disabilities.

Sir/Madam,
On behalf of Persons with Disabilities in India, who are estimated to be around
10% of the total Indian Population, we would like to place on record our
appreciation for the work being done by Chennai City Connect, especially in
light of the fact that the venture is non profit and is being done by
professionals who are taking time out from their schedules to try and make
Chennai a better place to live in. A better road layout system is beneficial for
people of all ages, backgrounds and abilities. The document “Better Streets,
Better Cities” contains many laudable measures and again we would like to say
that these were much needed.

However, we believe that if the city is to become truly inclusive for persons
with disabilities such as those who use crutches, wheelchairs or mobility
scooters, the deaf, and the blind and visually impaired, certain additional
measures must be taken. By including such measures in a preliminary planning
stage, the ultimate costs of such inclusions will be minimal and relative to this,
the benefits to persons with disabilities in the city of Chennai will be
tremendous. Besides persons with disabilities, the elderly stand to benefit
greatly from these measures. As you are aware, India became a signatory to
the United Nations Convention on the Rights of Persons with Disabilities in the
year 2007, which mandates that measures must be taken to make all public
infrastructure and services accessible for persons with disabilities

Specific Feedback And Input

While considering the needs for pedestrian design, a clear provision needs to
be made for those pedestrians with disabilities. As you aware India has not yet
formulate clear standards with respect to access to pavements and the road
system and therefore international standards must be adopted, on the lines of
what has been done in the United Kingdom1.

PART A: Footpaths
With regard to Footpaths (Para 2.1 of Better Streets, Better Cities), the
provisions made in the document2are extremely important, however, the
inclusion of other provisions in light with international standards may help in
making the footpaths more accessible for persons with disabilities as well as
the population in general:

1. Grade3: The sidewalk grade ideally should not exceed 5 percent. In cases
where the gradation is beyond this, a level landing must be installed.
The size of this landing should be large enough to allow wheelchair users
to stop and rest without blocking the flow of pedestrians. In areas with
steep slopes, consider installing wide sidewalk corridors that permit the
wheelchair user to travel in a zig-zag motion.

1
http://assets.dft.gov.uk/publications/access-inclusive-mobility/inclusive-mobility.pdf pp. 2.3
2
A continuous unobstructed minimum width of 2m
ƒ No breaks or obstructions at property entrances and side streets
ƒ Continuous shade through tree cover
ƒ No railings or barriers that prevent sideways movement on and off the footpath
ƒ Elevation over the carriageway (e.g. +150mm) and adequate cross slope for storm water
runoff. At the same time, the elevation should be low enough for pedestrians to step onto and
off of the footpath easily
ƒ Surmountable gratings over tree pits to increase the effective width of the footpath
3
Guidelines taken from http://www.bikewalk.org/pdfs/sopada_fhwa.pdf, p. 9.
2. Cross Slope4: The maximum cross slope permitted by the Americans with
Disabilities Act Accessibility Guidelines (ADAAG) is 2 percent. Severe
cross slopes require wheelchair users and other pedestrians to work
against the effects of gravity to maintain their lateral balance.
Pedestrians using crutches or canes may be forced to turn sideways in
order to keep their base of support at a manageable angle. Severe cross
slopes can cause wheelchair users to veer towards the curb and into the
street, the impact of which are compounded when combined with steep
grades and uneven surfaces. See Annexure A for illustration.

3. Handrails5 : Where the grade drop-off adjacent to the sidewalk is 460
mm or more, a handrail or guard is recommended as an aid to persons
with visual limitations. Continuous handrails should be provided on both
sides of all ramps or stairs, or wherever three or more steps are
provided. Handrails should be of a smooth, easy to grip design, no more
than 50 mm in diameter; and mounted at an appropriate height.
Handrail ends should terminate either by turning down, or by going into
the wall as an aid to persons who have visual limitations. Where height
differences are significant, guards are required on both ramps and stairs.
Handrails and/or guards should not be located within 1000 mm of any
roadway.

4. Surface materials6
The following need to be kept in mind while deciding the surface
materials for sidewalks:
• Changes in level: The material should not be cobbled etc. and should
be consistent in level.

4
Id.
5
http://www.toronto.ca/diversity/pdf/accessibility_design_guidelines.pdf, p. 6.
6
http://www.bikewalk.org/pdfs/sopada_fhwa.pdf p. 11
• Firmness, stability, and slip resistance: The material should be durable
for use by wheelchair, crutches and other assistive devices regardless of
the season.
• Dimensions of gaps, grates and openings: Tiled surfaces should not
have grates, and there should be no fear of crutches or wheels entering
into any.
• Visual consistency: Decorative textured surface materials can make it
more difficult for pedestrians with vision impairments to identify
detectable warnings, which provide critical information about the
transition from the sidewalk to the street. For these reasons, brick and
cobblestone are not recommended. Creative alternatives include smooth
walkways with brick trim, and colored concrete.

5. Zones: The ITDP document gives three zones into which the sidewalk
area is divided7.It is important for these divisions to be clearly
demarcated by means of colour, and by some minor surface indicators
which are discernable to persons with vision impairment. With regard to
driveway crossings, part of frontage, they should be designed with the
principles of recognizing that frontage is public property and needs to be
create impediments to persons with disabilities from enjoying their right
to public way8:

6. Curb Ramps9:
• Curb ramp slopes must be regulated in a manner that creates least
impediments for persons with disabilities. The heights of curbs must
7
A. Pedestrian zone. This zone provides continuous space for walking and should be clear of
any obstructions. It should be at least 2m wide.

B. Frontage zone. Provides a buffer between street-side activities and the pedestrian zone.
Next to a compound wall, the frontage zone can become a plantation strip.

C. Furniture zone. This is a space for landscaping, furniture, lights, bus stops, signs, and
private property access ramps.
8
http://www.bikewalk.org/pdfs/sopada_fhwa.pdf p. 17
9
http://www.bikewalk.org/pdfs/sopada_fhwa.pdf p. 21.
also be limited to permit easy access to sidewalks in case a curb
ramp is inaccessible for any unforeseen reason.
• Users must have enough room to maneuver towards the direction of
the crosswalk. There must be a bottom level landing of clear space
outside the direction of motor vehicle travel. A level landing at the
top of the ramp is also a must.
• A strip of detectable warnings must be installed at the bottom of a
perpendicular curb ramp.
• People with vision and cognitive impairments have difficulty
detecting where the street begins and ends. Detectable warnings,
contracting surface materials, and barrier posts are measures that
can be used to convey the transition between the street and sidewalk
at depressed corners.
• Significant changes of grade as pedestrians travel from the down
slope of the ramp to the up slope of the gutter can cause wheelchair
users to fall forward and should be limited accordingly.
See Annexure B for illustrations

PART B: Pedestrian Medians and Refuges

1. With regard to Pedestrian Medians and Refuges (Para 2.5 of Better
Streets, Better Cities), the design should insist on curbed or barrier
medians to physically separate pedestrians and motorists rather than
painted flush, or gates/fences. Furthermore, all medians should be
accessible to pedestrians.

2. The nose of the median should be extended beyond the crosswalk. If a
cut through is provided, it should be at of a width which allows two
wheelchair users to pass each other. In addition the edges of the cut
through must be perpendicular to the street being crossed.
3. Ramped medians should have a curb ramp at either end and a level
landing, again large enough to accommodate a wheelchair. For all
medians, cut through or ramped, a strip of detectable warnings should
be located at the entrance and exit.

4. In case of a Corner Island, the design should be similar to those of the
median. The island should be raised and designed with curb ramps or a
pedestrian cut-through along with detectable warning strips.

See Annexure C for Illustration

PART C: Pedestrian Crossing

In cases of Pedestrian Crossing (Para 2.6 of Better Streets, Better Cities) the
following additional guidelines should be in place to assist persons with
disabilities:

Traffic Signals10: Both audible and flashing crossing signals should be provided
as an aid to persons who have hearing or visual impairment.
• Audible pedestrian signals should be loud enough to be heard clearly
above the ambient noise (i.e.: at least 15 decibels louder than ambient
noise).
• Two different audible pedestrian signals, identifying when it is safe to
cross either direction, (as indicated by a separate tone) are required for
persons with visual disabilities.
• Where extended time is required to cross, (e.g., by seniors and persons
with disabilities), a clearly marked pedestrian button should be available
and mounted on a pole beside the curb cut, at an accessible height for
persons with disabilities.

10
Guidelines from http://www.toronto.ca/diversity/pdf/accessibility_design_guidelines.pdf p.
35.
• Tactile features should be provided as an aid to persons who have both
hearing and vision limitations. (ie. A tactile or vibro-tactile feature on
pushbuttons.)
• In locations frequently used by seniors or persons with disabilities e,g,
near gardens, special schools, special homes etc. crossing timing should
be provided to permit pedestrians, or wheelchair users to cross safely.

PART D: Landscaping

With regard to Landscaping (Para 2.7 of Better Streets, Better Cities ) as the
document points out trees11 are also one of the most common causes of
sidewalk cracks and changes in level. When water is limited, tree roots tend to
push through the surface and spread out rather than down to look for new
water sources. Tree branches should be maintained as hanging branches can be
a safety hazard, especially for pedestrians with vision impairments who may
not detect them. Other pedestrians with mobility impairments may have
difficulty bending under them.

PART E: Bus Stops

Regulations regarding Bus Stops (Para 2.8 of Better Streets, Better Cities)
should be disabled friendly and ideal guidelines can be found here12.
See Annexure E for Illustration.

PART F: Street Furniture

1. Regarding Street Furniture (Para 2.10 of Better Streets, Better Cities)
and furniture zones, street furniture can cause problems for both

11
Id.
12
http://assets.dft.gov.uk/publications/access-inclusive-mobility/inclusive-mobility.pdf para
6.
wheelchair users and for people who are visually impaired of making it
apparent to people with reduced mobility13.

2. The positioning of posts, poles etc. must be consistent and away from
general lines of movement. Thus lamps (and signs) should be mounted on
walls or buildings whenever possible; if not, then placing them at the back
of the footway as near the property line as possible is acceptable.

3. Waste bins should continue down or close to ground level and should be of a
rounded design. Bins should be colour contrasted to their surroundings.
Bins, Bollards and flowerbeds should adhere to a minimum height so as to
not create problems for persons with low vision.

PART G: On Road Parking

1. On Road Parking (Para 2.11 of Better Streets, Better Cities) must include
accessible parking which is needed for drivers using wheelchairs or with
other mobility difficulties. Along with at major areas of commerce and
recreation, accessible parking is especially needed near major transit stops,
for use by those who wish to transfer from a car to a bus or train.

2. Reserved Parking must be demarcated with a sign with the international
symbol of accessibility mounted high enough so it can be seen while a
vehicle is parked. Adequate space must be kept on both sides of the vehicle
for entry/exit and unloading of wheelchairs, scooters or other mobility
devices14.

See Annexure D for illustration.

13
Guidelines from http://assets.dft.gov.uk/publications/access-inclusive-mobility/inclusive-
mobility.pdf pp. 3.7
14
http://www.independentliving.org/mobility/mobility.pdf p. 5.
PART H: Street Lighting

Street lighting (Para 2.14 of Better Streets, Better Cities) is indeed very
important for people with disabilities.
All public thoroughfares and pedestrian routes need illumination to ensure safe
access for persons with disabilities at sidewalks, bus stops, or parking areas
leading to public facilities or amenities. The following are the guidelines as
prescribed under the Toronto Accessibility Design Guidelines15.
1. Lighting levels of 100 lux. (10 ft. candles) measured at the ground of all
accessible pedestrian entrances are recommended as an aid to persons with
visual disabilities.
2. At frequently used pedestrian routes (including paths, stairs, and ramps)
recommended lighting levels should be 30 lux. (3 ft. candles).
3. In accessible parking areas, lighting levels are recommended to be a
minimum of 50 lux (5 ft. candles) at accessible parking spaces and along
accessible routes from areas of parking to accessible entrances.
4. Lighting sources should be selected and located at, or beside steps and
stairs, to ensure clear definition of treads, risers, and nosings.
5. All lighting over pedestrian routes should be evenly distributed, provide a
reasonable colour spectrum, and minimize cast shadows for persons with
low vision.
6. Supplementary lighting should be provided to highlight all key way-finding
signage.
7. Lighting standards or posts should be mounted to one side of pedestrian
walkways so as not to inhibit free movement of persons using mobility aids.
8. Low-level lighting standards should be tall enough to clear usual levels of
water logging accumulation.

15
http://www.toronto.ca/diversity/pdf/accessibility_design_guidelines.pdf p. 36
9. Overhead light fixtures should be mounted on standards that ensure clear
headroom of 2030 mm is available, below fixtures or supports, as an aid to
persons with visual limitations.
10. Lighting of landscape on special site features should be designed and
installed to minimize direct glare to both pedestrians and building users.

Conclusion
As mentioned above, the changes/additions specified are necessary for persons
with disabilities to have equal access to the city of Chennai and its streets and
pavements. These changes/additions are in line with international standards
and we firmly believe that the incidental costs and efforts of including them at
this stage will be minimal, yet the benefits which can be achieved for persons
with disabilities would certainly set new precedents for all Indian cities. In the
light of the above, we strongly urge Chennai City Connect to incorporate the
suggestions mentioned above to ensure that the document “Better Streets
Better Cities” adheres to the principles of equality and non-discrimination as
enshrined in the Constitution of India, and also to ensure that India is
compliant with its obligations to its disabled citizens and to the international
community under the UNCRPD. In conclusion, we deeply appreciate the hard
work and effort that has gone into the preparation of the document “Better
Streets Better Cities” and sincerely hope that the additional measures
benefitting the disabled while planning street design be incorporated in your
plan.

We would also like to place on record our willingness to assist you on this issue.

Thanking you,

Inclusive Planet Centre for Disability Law and Policy
Amba Salelkar Email: amba.salelkar@gmail.com
With input from
1. AccessAbility
Shivani Gupta. Email: shewany@gmail.com

To be added
Annexure A

From: http://www.bikewalk.org/pdfs/sopada_fhwa.pdf p. 10
Annexure B – Curb Ramps

From http://www.bikewalk.org/pdfs/sopada_fhwa.pdf p. 21
Annexure C Corner Islands and Medians

From http://www.bikewalk.org/pdfs/sopada_fhwa.pdf p. 32
Annexure D: Parking Spaces

From http://www.independentliving.org/mobility/mobility.pdf p. 6
Annexure E: Bus Stops for the Disabled

From http://assets.dft.gov.uk/publications/access-inclusive-
mobility/inclusive-mobility.pdf