It would be difficult to devise a specific ceiling on compliance costs that would take into account the vast diversity of enterprises covered by the ADA's public accommodations requirements...
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Readily achievable (Section-By-Section Analysis and Response to Comments)
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Appendix D: Photometric Measurements
Measurements were made with a circular one-degree field of view with the tripod-mounted detector set approximately 52 inches higher than the measured surface and at a horizontal distance...
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Issue 1: APS volume
Volume adjustments differ by manufacturer: some devices can be set through a hand-held PDA, while others require adjusting set screws on a control board mounted in the pedestrian signal...
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RESEARCH NEEDS
Research is needed to determine whether signal faces mounted at the roadside will be effective in the roundabout context....
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